Roundup, Garlon, and Pesticide-Free Parks

New evidence has emerged that Monsanto influenced the Environmental Protection Agency  (EPA) to downplay the cancer-causing risk of Roundup. This pesticide, and others that may be even more hazardous, are used in our parks and watersheds. And now, since San Francisco is adding ground water to the Hetch Hetchy water we have been getting, our water may contain traces of these hazardous chemicals.



Bloomberg and other news sources show that Monsanto offered to ghost-write sections of the EPA report on glyphosate, and sought the help of an EPA official to kill the reports that glyphosate is a probable carcinogen.

We reported earlier that a letter by an EPA employee Dr Marion Copley, written as she was dying, says: “It is essentially certain that glyphosate causes cancer.” She also said it is an endocrine disruptor, and alleged corruption within the EPA.

A California Superior Court judge has ruled that Roundup can be added to the Prop 65 list of known carcinogens, despite Monsanto’s attempts to block such a listing. “State regulators were waiting for the formal ruling before moving forward with the warnings, said Sam Delson, a spokesman for the state Office of Environmental Health Hazard Assessment.” 

Dr Copley’s letter only used glyphosate (Roundup, Aquamaster) as an example. The letter hinted that other chemicals might have fared similarly – that is, not been properly evaluated because of corporate influence on EPA employees. We the public cannot assume that toxicology tests performed by the companies producing the pesticides or scientists they may pressure are sufficient to prove the chemicals are harmless.


Roundup has been used for years by SFRPD and other city entities. Only in  2015 was it designated a Tier I (most hazardous) pesticide. We tracked its use in San Francisco’s Natural Areas from 2008 to 2016. (It’s also used in other parks, and by the PUC, but we have not compiled those data.)

In the bar-graph here, the green section represents Roundup. The Natural Resources Department (NRD) increased its use of Roundup each year from 2009 to 2013, then decreased it in 2014, slightly increased it in 2015, and now has brought it down to below 2010 levels – though not as low as in 2009 or 2010.

The orange section is Garlon, a Tier I (Most Hazardous) herbicide that’s considered even more toxic than Roundup. Garlon is also supposed to be twenty times as toxic to women as to men. (See page 28 of this California Native Plant Society Presentation which discusses best management practices in herbicide use: Law_Johnson 2014 presentation toxicity )

Nowadays, Garlon in San Francisco is used only by the Natural Resources Department against Bermuda buttercups (oxalis).


SF Environment has responded to community concerns (including a petition opposing pesticides in schools and parks that has more than 12,000 signatures) by introducing a list of restrictions on the use of Tier I (but not Tier II) chemicals. (Their Tier system classifies all allowable pesticides as Tier III – Least Hazardous, Tier II – More Hazardous, and Tier I – Most Hazardous.)

Though we believe the restrictions do not go far enough, they are a start. SF Environment has not published the final version, but there is a current draft. We are providing our comments to the Commission for the Environment and to SF Environment in the hope that they will modify the conditions under which use of Tier I herbicides are permitted. (We’ll post about this soon.)

But – starting 2017, SF Environment is going to approve the use of something new: Milestone VM Plus. It’s a mix of Garlon and Milestone VM (aminopyralid). This combination is being approved as a Tier II herbicide. Amino-pyralid is the pesticide so persistent that it lasts for years – and if an animal eats treated vegetation, its droppings become toxic too. It was considered a Tier I pesticide until SF Environment decided to reclassify it as Tier II in 2013. It’s banned in New York and effectively in a number of other states too.

We’ve protested. Here’s our letter:

Dear Commissioners, Director Raphael, and Dr Geiger,

We are dismayed that a new triclopyr-based pesticide is being added to the 2017 pesticide list, and in combination with aminopyralid – and that too as Tier II. This is at a time when we’re working to *remove* triclopyr (as Garlon) from the list. We refer to Milestone VM Plus, which is Aminopyralid, triisopropanolamine salt, 2%; Triclopyr, triethylamine salt, 16%. It’s for injection and for tree stumps. As we understand it, this is a mixture of Garlon 3 and Milestone.

This could be disastrous. Triclopyr is one of the most toxic herbicides still on the list. And Milestone VM (Aminopyralid) is uncannily persistent – it can last for years. If vegetation treated with it is eaten by animals and excreted, the excreta still contains enough herbicide to harm plants. Until 2013, Milestone was considered a Tier I chemical for its persistence – and then changed to Tier II (possibly at the request of the Natural Resources Department, since other SFRPD departments don’t use Milestone VM.)  If Milestone VM Plus is used on trees in a forest or stand of trees, it could weaken adjacent healthy trees through the intergrafted root network, thus destabilizing groups of trees.

We urge you to delete Milestone VM Plus from your restricted list. It’s no better than using Garlon with some added Milestone. If it must be retained, please classify it as Tier I.

San Francisco Forest Alliance

[Edited to Add: Unfortunately, Milestone VM Plus was approved and classified as Tier II. The 2017 List is given here as a PDF: sfe-th-2017-reduced-risk-pesticide-list ]


This year,  San Francisco started adding well water drawn from under the city to our tap water. Roundup or Aquamaster (glyphosate) and other pesticides such as Garlon (triclopyr), Milestone (aminopyralid), and Stalker (imazapyr) – and their breakdown products, some of which may be even more toxic – could well be contaminating our water supply.

Pesticide supporters argue it doesn’t matter, because the amounts are small. But:

  • Herbicides (and other chemicals) could interact in ways that are unpredictable. No one has researched them.
  • There’s no way of knowing how much the cumulative exposure is for any individual. This is particularly a concern for children, whose low body weight and fast growth make them especially vulnerable; and for people with illnesses or chemical sensitivities.
  • Importantly, if they are endocrine disruptors – which means they act like hormones in the human body – tiny amounts can have a disproportionate impact. It’s an exception to the “dose makes the poison” saying. Here’s an article that cites references to studies showing endocrine disruption from glyphosate: Why Low Dose Pesticides are Still Hazards.


We have heard some parents don’t take their children to Glen Canyon any more, owing to pesticide concerns. One of the restrictions that SF Environment will impose is no use of Tier I pesticides in areas frequented by children. (Tier II herbicides will still be allowed.)

While the San Francisco Forest Alliance asks for no pesticides in our parks (and watersheds), San Francisco could make a start by converting parks with children’s play areas to Pesticide-Free Parks. Here’s an example from Seattle.

Opponents of restricting pesticide use in this way might fear that the park looks awful, so we went and had a look. It was a sunny afternoon, and the park was beautiful.

The park was full of kids of all ages, from babies and toddlers to teenagers. One man rocked his tiny pink-clad baby daughter.  Another dad brought his small son to kick a ball around in the grass. School age kids chased each other with squirt-guns. Some families brought their dogs, who are allowed in the park. It must be a relief to know that you can safely take your family to such a park, and not encounter Roundup or Garlon, Stalker or Milestone VM.

The park has a nice playground.

It also had an organic community garden…

… complete with a green roof.

And a rain garden.

And a multilingual welcome sign.

It was a lovely example of the kind of Inclusive Environmentalism that San Francisco Forest Alliance stands for.

Sutro Forest Herbicide Projections: Bad News for San Francisco’s Natural Areas?

pesticide use number n vol 2008 to 2012Our regular readers will know that we’ve been following the Natural Areas Program’s (NAP) increasing use of pesticides with some dismay. When we got the 2012 data, it was clear that pesticide use had increased by every measure. That story is HERE: Natural Areas Program Uses Even More Pesticides.  Imagine our concern, then, when the Sutro Forest Draft Environmental Impact Report outlined the amounts of pesticides they contemplate using as part of their destructive plan for the forest on Mount Sutro Open Space Reserve. It’s between 5 and 15 times the amount that NAP is using on all its properties. (Sutro Forest has been essentially pesticide-free since 2008.)

NAP’s own DEIR on the Significant Natural Resource Areas Management Plan – SNRAMP or Sin-Ramp – doesn’t quantify the amounts of pesticides it would need to implement its plan. But the Sutro Forest numbers suggest that we’re looking at multiples of their existing levels of use.

Like many, we’re very concerned about this pesticide use. It’s bad for human beings, for pets, for the environment and for wildlife. We recently came upon this excellent article by David Stang. It’s reprinted here with permission. Of the pesticides reviewed, NAP is using Milestone VM, Roundup (or Aquamaster, with the same active ingredient – glyphosate), and Imazapyr.  (Note: All the illustrations are ours.)



By David Stang

pacific chorus frog - public domain image (NPS)Recently an agricultural services firm was retained to spray the herbicide Milestone VM on nearby pastures to kill clover and other broadleaf plants. After spraying, rains washed some of the herbicide downhill from the pastures into the ponds below. Before the spraying, the ponds were full of tadpoles. A few days after spraying, there were no tadpoles in the ponds examined.

Because none of the tadpoles had legs before the spraying, they could not have developed into adult frogs and walked off. Nor could any predator have managed to get every single one of them. And a “control group” — waterways not affected by pasture runoff — still had the tadpoles they had before this spraying. Adult frogs may have been killed as well – the evenings at the ponds after spraying were much quieter than just prior to the spraying.

We could suspect that pasture runoff of Milestone VM into our ponds is the culprit. A literature search confirms this hypothesis (see below).

Studies have shown that herbicides and pesticides may have both direct and indirect effects on tadpoles:

  • Very, very low concentrations of pesticides and herbicides have been found to be a major factor in high levels of deformities in frogs and tadpoles1, and studies have shown that herbicides such as Roundup cause DNA damage in tadpoles.2
  • Very low concentrations may kill tadpoles and frogs in just one day.3
  • Those that are not killed outright by herbicides may die of delayed effects. Malathion, for instance, in very low doses destroys zooplankton that eat algae that floats in the water. With the zooplankton gone, the algae grew rapidly and prevented sunlight from reaching the algae at the bottom of the pond, which tadpoles eat. Some tadpoles then starve to death.4
  • Tadpoles that do not starve will mature slowly, or grow so slowly that they may not reach maturity.5
  • If tadpoles reach maturity, and become adult frogs, herbicides may weaken their immune systems, leaving them susceptible to chytrid fungus infections.6

The known dangers of herbicides for frogs and toads is acknowledged by the National Park Service which, for Yosemite National Park, required that “Herbicides will not be applied within 750 meters (2,500 feet) of known breeding habitat for the Yosemite toad.”7

Where pasture runoff flows into streams, ponds, or even ditches, the use of herbicide or pesticide in our pastures should be suspended until the dangers of any proposed substance can be carefully evaluated.

Herbicides that are known to be toxic to wildlife include Milestone VM, Roundup, Powerline and Arsenal, and Tordon K. It seems likely that all herbicides are toxic to wildlife.

2013-03-14 (2)Milestone VM

Milestone VM contains the active ingredient aminopyralid.

Aminopyralid dissolves very easily and is persistent in water. It has high leachability and mobility. It is toxic to algae, oysters, aquatic plants8, fish, honeybees and earthworms9.Aminopyralid is also on PAN International’s List of Highly Hazardous Pesticides10.

Recently aminopyralid was at the center of public and media attention in the United Kingdom. Gardeners discovered that using manure from animals that grazed on or were fed hay from aminopyralid-sprayed roadsides caused their garden crops to fail or develop abnormally. In fact, the University of Minnesota Extension Service describes this problem in their fact sheet, “Use Caution When Harvesting and Feeding Ditch Hay.”11

Aminopyralid is of concern to vegetable growers as it can enter the food chain via manure which contains long lasting residues of the herbicide. It affects potatoes, tomatoes and beans, causing deformed plants, and poor or non-existent yields. Problems with manure contaminated with Aminopyralid residue surfaced in the UK in June and July 2008, and at the end of July 2008 Dow AgroSciences (the manufacturer of Milestone) implemented an immediate suspension of UK sales and use of herbicides containing Aminopyralid. A company statement explained: “Consistent with its long-standing commitments to product stewardship, and in cooperation with United Kingdom regulators, Dow AgroSciences has asked the Pesticide Safety Directorate (PSD) for a temporary suspension of sales and use of herbicides containing aminopyralid. The suspension shall remain in place until assurances can be given that the product and subsequent treated forage and resultant animal wastes will be handled correctly.”12

If it is unsafe to eat vegetables raised with manure from pastures treated with Milestone, how safe can it be to eat plants that themselves have been treated with Milestone? Are the horses in treated pastures safe?

Of concern to all is the 2005 claim by the EPA that “There are no acute or chronic risks to non-target endangered or non-endangered fish, birds, wild mammals, terrestrial and aquatic invertebrates, algae or aquatic plants”13, despite the fact that the EPA report cites studies such as “Acute Toxicity to Larval Amphibians Using the Northern Leopard Frog, Rana pipiens, as a Biological Model.”

Even if Milestone/aminopyralid were safe for tadpoles, it would only be when applied at recommended doses to non-sloping land. The recommended dose is just 7 fluid ounces per acre, according to the EPA.14


Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

Other commonly used herbicides also put wildlife at risk. Roundup, for instance, kills birds, fish, tadpoles, bees, worms – at least 76 different species.

Roundup contains glyphosate as its active ingredient. Glyphosate dissolves readily and is very persistent in water. It is toxic to birds, fish, honeybees and earthworms15and is listed by PAN International as a highly hazardous pesticide16. Its maker, Monsanto, was convicted of false advertising in 2007 for its claim that Roundup was “practically non-toxic” to mammals, birds, and fish.17 Some of the scientific evidence for the safety of Roundup comes from studies with falsified results.18

The U.S. Environmental Protection Agency (EPA) has identified 76 species that may be endangered by glyphosate use19.An important study has shown that glyphosate kills tadpoles20. A University of Pittsburgh biologist has found that the herbicide caused an 86-percent decline in the total population of tadpoles.21A recent study found that even at concentrations one-third of the maximum concentrations expected in nature, Roundup still killed up to 71 percent of tadpoles raised in outdoor tanks.22

Out of concern for these issues as well as human health, European Union member states are warned that they “must pay particular attention to the protection of the groundwater in vulnerable areas, in particular with respect to non-crop uses,” when using glyphosate23.According to EPA, short-term exposure to elevated levels of glyphosate may cause lung congestion and increased breathing rates and, in long-term exposure, kidney damage, reproductive effects24. Glyphosate has also been associated with Parkinson’s disease.25Increased adverse neurologic and neurobehavioral effects have been found in children of applicators of glyphosate26.Female partners of workers who apply glyphosate are at higher risk of spontaneous abortion27.Some glyphosate-based formulations and metabolic products have been found to cause the death of human embryonic, placental, and umbilical cells in vitro even at low concentrations. The effects are not proportional to glyphosate concentrations but dependent on the nature of the adjuvants used in the formulation.28

Powerline and Arsenal

glen canyon imazapyr under treesPowerline and Arsenal contain the active ingredient imazapyr, which has been listed for withdrawal from the market in the European Union.29It is highly soluble and moderately persistent in water. It is also toxic to fish, honey bees and earthworms30. Imazapyr’s potential to leach to groundwater is high and surface runoff potential is high31.One field study found that between 40 and 70 percent of applied imazapyr leached down to the lowest depth tested32. If imazapyr leaches down below 18 inches (where microbial activity is limited) the chemical can be expected to persist for more than a year33.EPA cautions that imazapyr-based herbicides can place terrestrial and aquatic plant species in “jeopardy.”34

Tordon K

Tordon K has the active ingredient picloram. Picloram is a persistent herbicide that is highly leachable, very soluble in water and does not degrade readily in water. It is toxic to birds, fish, honeybees and earthworms. It has also been identified as an endocrine disruptor3536and is on PAN International’s List of Highly Hazardous Pesticides37.EPA’s evaluation of picloram states, “eventual contamination of groundwater is virtually certain in areas where residues persist in the overlying soil. Once in groundwater, the chemical is unlikely to degrade even over a period of several years.”38

Anyone who would advocate against herbicides will face the might of organized agriculture, the lawn care business, and even the EPA. A paper on the Environmental Safety of Forestry Herbicides39, for instance, argues that the herbicides named in the present article – imazypyr, glyphosate, and picloram, as well as many others – are “less toxic than caffeine”, “less toxic than aspirin” and “are safe for animals because the biochemical basis for toxicity does not exist.” The article goes on to claim “herbicides positively affect water quality by reducing sedimentation rates.”

I’d like to think that we could send herbicides to the last roundup. But it seems more likely that herbicides will continue to send wildlife to that roundup.

End Notes

1 Fellers G, Sparling D; Wafting Pesticides taint far-flung frogs, Environmental Toxicology and Chemistry, 2001; Science News, Dec 16,2000, Vol 158, p391; Science News, 9-5-98,p150.

3 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds

4 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds

10 PAN International List of Highly Hazardous Pesticides, 2009.

11 University of Minnosota Extension Service, “Use Caution When Harvesting and Feeding Ditch Hay.”

15 Pesticide Properties DataBase

16 PAN International List of Highly Hazardous Pesticides, 2009.

18 On two occasions the United States Environmental Protection Agency has caught scientists deliberately falsifying test results at research laboratories hired by Monsanto to study glyphosate. [(US EPA Communications and Public Affairs 1991 “Note to correspondents” Washington DC Mar 1)] [(US EPA Communications and Public Affairs 1991 Press Advisory. “EPA lists crops associated with pesticides for which residue and environmental fate studies were allegedly manipulated”. Washington DC Mar 29)] [(U.S. Congress. House of Representatives. Com. on Gov. Oper. 1984. “Problems plague the EPA pesticide registration activities”. House Report 98-1147)] In the first incident involving Industrial Biotest Laboratories, an EPA reviewer stated after finding “routine falsification of data” that it was “hard to believe the scientific integrity of the studies when they said they took specimens of the uterus from male rabbits”. [(U.S. EPA 1978 Data validation. Memo from K Locke, Toxicology Branch, to R Taylor, Registration Branch. Washington DC Aug 9)] [(U.S. EPA Office of pesticides and Toxic Substances 1983, “Summary of the IBT review program”. Washington D.C. July)] [Schneider, K. 1983. Faking it: The case against Industrial Bio-Test Laboratories. The Amicus Journal (Spring):14-26. Reproduced at [ Planetwaves] ] In the second incident of falsifying test results in 1991, the owner of the lab (Craven Labs), and three employees were indicted on 20 felony counts, the owner was sentenced to 5 years in prison and fined 50,000 dollars, the lab was fined 15.5 million dollars and ordered to pay 3.7 million in restitution. [(US Dept. of Justice. United States Attorney. Western District of Texas 1992. “Texas laboratory, its president, 3 employees indicted on 20 felony counts in connection with pesticide testing”. Austin TX Sept 29) ] [(US EPA Communications, Education, And Public Affairs 1994 Press Advisory. “Craven Laboratories, owner, and 14 employees sentenced for falsifying pesticide tests”. Washington DC Mar 4)] [ Glyphosate Factsheet (part 1 of 2) Caroline Cox / Journal of Pesticide Reform v.108, n.3 Fall98 rev.Oct00 ] ] Craven laboratories performed studies for 262 pesticide companies including Monsanto. —

19 U.S. Department of Agriculture, Forest Service, 1997. Herbicide Information Profile: Glyphosate

20 Hileman, B. (2005) Common herbicide kills tadpoles. Chemical & Engineering News. Washington 83(15):11

22 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds

23 European Commission, Health & Consumer Protection Directorate-General. Directorate E – Food Safety: plant health, animal health and welfare, international questions. E1 – Plant health. Glyphosate. 6511/VI/99-final. 21 January 2002.

25 Barbosa et al., 2001. Parkinsonism after glycine-derivative exposure. Mov. Disorder. 16: 565-568.

26 Garry et al., 2002. Birth defects, season of conception and sex of children born to pesticide applicators living in the Red River Valley of Minnesota, USA. Environ. Health Perspect. 110: 441-449.

27 Arbuckle et al., 2001. An exploratory analysis of the effect of pesticide exposure on spontaneous abortion in Ontario farm population. Environ. Health Persp. 109: 851-857.

28 Benachour Nora; Gilles- Eric Séralini (December 23, 2008). “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells”. Chemical Research in Toxicology 22: 97. doi:10.1021/tx800218n.

29 “Pesticides coming off EU market. Pesticide News No. 60, June 2003, pp. 8-10.

31 Washington State Department of Transportation. Imazapyr – Roadside Vegetation Management. Herbicide Fact Sheet. February 2006.

32 Vizantinopoulos, S. and P. Lolos. 1994. Persistence and leaching of the herbicide imazapyr in soil. Bull. Environ. Cont. Toxicol. 52:404-410.

33 “Ecological Risk Assessment of the Proposed Use of the Herbicide Imazapyr to Control Invasive Cordgrass (Spartina spp.) in Estuarine Habitat ofWashington State.” Department of Agriculture, Olympia, WA 98504. Prepared by ENTRIX Inc., Olympia, Washington. Project No. 3000901, October 30, 2003.

34 USEPA. Office of Pesticide Programs. 1987. EEB Review of 241-EEO. Washington, DC (April 21 & June 1)

35 Endocrine disruptors interfere with the endocrine glands that produce hormones that guide the development, growth and reproduction in people and animals. Disruption of hormones, which guide growth, development, intelligence, and reproduction, can result in irreversible harm, which is passed on to future generations.

36 Pesticide Properties Database

37 PAN International List of Highly Hazardous Pesticides, 2009.

38 U.S. EPA. Prevention, Pesticides, and Toxic Substances. 1995. Reregistration eligibility decision (RED): Picloram. Washington, D.C., Aug.

39McNabb, Ken. Environmental Safety of Forestry Herbicides