San Francisco “Natural Resources” Herbicide Usage Up 57% in 2017

We have recently analyzed the data for herbicide use in the full year 2017 for San Francisco’s so-called “Natural Resources Department” (NRD – formerly Natural Areas Program). It’s up 57% from the previous year.

NRD is a department of San Francisco Recreation and Parks Department (SFRPD). We were greatly encouraged when NRD started reducing herbicide use in 2014. Before that, pesticide use had increased sharply from 2009 onwards. (You can read an article about that here: SF’s Natural Areas Program – more pesticide in 2013.) Another sharp reduction in 2016 was even more encouraging – though it’s never come down to 2008 or 2009 levels. (The graph above shows annual NRD herbicide usage in fluid ounces of active ingredient.)

But this year, it’s up again, almost to 2015 levels. We have been hoping that SFRPD is working to eliminate all Tier I and Tier II herbicides, with leadership from the Department of the Environment (SF Environment).

For the rest of SFRPD (excluding Harding Golf Course, which is managed under a PGA contract), they have actually reduced usage. They use a greater variety of herbicides than NRD, of which more later. But they are using less – across all their parks and golf courses – than the NRD is. NRD forms a quarter of the area of SFRPD.

WHAT’S WRONG WITH THESE HERBICIDES?

NRD uses four herbicides: Two that SF Environment classifies as Tier I (“Most Hazardous”) and two classified as Tier II (“More Hazardous”). The Tier I herbicides are Roundup/ Aquamaster (glyphosate) and Garlon 4 Ultra (triclopyr); and Stalker/ Polaris/ Habitat (imazapyr) and Milestone VM (Aminopyralid) are Tier II. (In the first picture, with the white dog, the sign posted on Mount Davidson indicates they are using Aquamaster, Garlon, and Milestone in March 2018.)

These hazard rankings can change: Roundup/ Aquamaster (glyphosate) was reclassified from Tier II to Tier I when the World Health Organization found it was a probable human carcinogen. Milestone (Aminopyralid) was reclassified from Tier I to Tier II, despite the fact that it is extremely persistent and mobile in the environment.

THE FEARSOME FOUR

As you research these herbicides, you may find – as we did – that much of the research originates with the companies that produce them. It may be unbiased, but the evidence is that it often is not. So we looked for other sources, which are easier to find for well-established herbicides like glyphosate (Roundup or Aquamaster). It doesn’t mean the others are innocuous.

ROUNDUP or AQUAMASTER (Glyphosate)

  • Carcinogenic. In April 2015, the World Health Organization determined glyphosate was a “probably carcinogenic.”  EPA scientist Dr Marion Copley  sent a letter before her death saying it was essentially certain that glyphosate  causes cancer. She also said that as a chelater, it was likely an endocrine disruptor.
  • Associated with birth defects. It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).
  • Bad for the soil. Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
    It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • Bad for other living things. It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

  • Garlon is even more hazardous than Roundup. It’s been classified as Tier I for at least as as long as we have been monitoring pesticide use in San Francisco.
  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  • Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  • About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs  may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans.  Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  • It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  • It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Garlon can persist for up to two years in dead vegetation .

The NRD uses Garlon extensively against oxalis. If it terminated its war on oxalis, it could stop using Garlon altogether.

POLARIS, HABITAT, STALKER  (Imazapyr)
This is a relatively new pesticide, and not much is known about it — except that it’s very persistent. In Sweden, it was found in the soil 8 years after a single application. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment.

It can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product  is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”
It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001 because of groundwater concerns.

MILESTONE (Aminopyralid)
Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as  a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.
Nevertheless, after an outcry and problems, Dow AgroSciences stopped selling Milestone in the UK for a number of years. It’s also prohibited for use in New York.

IT’S TIME TO STOP

There’s growing evidence that herbicides are more dangerous, more mobile, and more persistent than their manufacturers claim. Glyphosate, for instance, is widely found in all water sources, in the soil – and in people. A UCSF study of glyphosate in urine found: “Glyphosate residues were observed in 93% of urine samples in voluntary public testing in the U.S. general population; this is higher than the frequency observed in Europe using GC-MS (43.9%)”  and “exposure is likely due to dietary intake or environmental exposure.”

With endocrine disruptors, the old theory “the dose makes the poison” doesn’t work. They are potent at very low levels.

These are parks that we visit with our families, including kids and pets. Kids are particularly vulnerable to pesticides because of their low body weight and rapid growth. These are the watersheds that feed chemicals into our groundwater (which is also now being added to our domestic water supply).

The San Francisco Forest Alliance stands for No Pesticides in our Parks.

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Two Cheers for NAP’s Herbicide Use in 2014

[Note: This article has been edited to add a section on dead birds near Kezar Stadium.]

NAP Herbicide use by active ingredient 2014We’ve been following the use of hazardous herbicides by the Natural Areas Program (NAP) for some years now – and it’s been rising steadily. We recently compiled the data for 2014. For the first time since 2009, 2010, NAP’s use of Tier I and Tier II herbicides actually declined. (San Francisco’s Department of the Environment – SFDOE – sorts acceptable herbicides into three tiers. Tier III is Least Hazardous; Tier II, More Hazardous; and Tier I, Most Hazardous.) It’s even below 2010 levels, though considerably higher than 2009. We consider this an encouraging development.

The main herbicides NAP uses are:

  • Garlon 4 Ultra (triclopyr),
  • Stalker (imazapyr)
  • Aquamaster, also called Roundup Custom (Glyphosate)
  • Milestone VM (Aminopyralid)

Garlon is Tier I, and the other three are Tier II. NAP uses no Tier III herbicides. All these herbicides have downsides, but Garlon is the most problematic. SFDOE considers it a ‘high priority to find an alternative.’ Why?

  • Risks to humans – and the risk to women of child-bearing age is 20 times higher than to men
  • Risks to birds – relatively small amounts can reduce birds’ breeding success
  • Risk to animals – dogs may be especially sensitive to Garlon because their kidneys take longer to process the chemical.
  • Persistence – it can remain in the soil for years.

In 2008, Marin Municipal Water Department made a thorough review of several pesticides. The triclopyr chapter chapter from their draft report is linked here: Chap4_Triclopyr_8_27_08

A presentation from the California Invasive Plant Council (which supports the use of herbicides) has an interesting assessment of risk factors for various herbicides – including triclopyr. It’s linked here: Law_Johnson 2014 presentation toxicity

McLaren Park's Flowered Grassland and Forest

McLaren Park’s Flowered Grassland and Forest

The Natural Areas program is still the largest user of  Tier I herbicides in the SFRPD, (with one exception we’ll discuss below). It’s mainly Garlon used on oxalis, the yellow-flowering plant that covers San Francisco hillsides in spring, and which they consider an invasive non-native plant (together with about 35 species of plants, including fennel).

Oxalis flowers early and spectacularly in Spring, providing abundant nectar to bees, butterflies and other insects. It then dies back, making way for other plants. In any case, knocking back the oxalis merely opens the niche to the next most adapted plant, most likely also non-native, to expand into the vacated area.

OTHER MEASURES OF HERBICIDE USE

number of herbicide applications by NAP 2014The first graphs showed a comparison based in the volume of the active ingredient, which is the metric the Department of the Environment prefers. This second graph show NAP’s herbicide use in terms of number of applications (which is a proxy measure of breadth of exposure to the herbicides). The number of applications in 2014 rose slightly from 2013, but not close to the 7-year high in 2012.

NAP herbicide applications by volume 2014The third graph shows the volume of herbicides used (which includes both the active ingredient and the so-called ‘inert’ compounds that are not always in fact inert). Here too NAP has reduced its usage in 2014. By this measure, NAP still hasn’t dropped back to 2010 levels, mainly reflecting the changed product mix with less Garlon in 2014.

COMPARISON WITH OTHER SFRPD

In 2013, NAP used nearly as much herbicide as all of the rest of SFRPD put together. (We exclude Harding Golf Course, which is managed by the PGA Tour under contract and not by SFRPD.)

In 2014, NAP actually used a lot less herbicide than SFRPD. (Not as low as the 4% quoted by Mr Ginsberg, but only 26%. Since NAP has about a quarter of the total acreage owned by SFRPD within the city, this is more or less in line with the rest of the park.)

SFRPD overall (ex NAP and ex Harding) used a lot more herbicide than in 2014 than in 2013. Here’s why:

  • A mistake in Gleneagles.  In March 2014, Gleneagles golf course used a huge amount of triclopyr (512 fl ounces), while its normal usage is little or nothing. In fact, except for NAP, triclopyr is little used by SFRPD. Gleneagles also used 36 fl oz of Sapphire, a golf-specific product that is supposed only to be used when getting ready for a tournament. At the annual pesticide review meeting, SFRPD’s Integrated Pest Management Coordinator confirmed that it was a mistake by an outside contractor.
  • Kezar Stadium soccer field’s new herbicide. Kezar Stadium used Drive XLR8 (quinclorac) on the soccer field in November and December 2014.  This required an exception, because it’s not approved for use on city-owned property. The stadium was closed for three months, so SFDoE considered the risk acceptable. We wondered why, if the stadium was closed, they could not just plow the thing under and start anew, but apparently that would be a capital budget issue. We hope these kinds of questions do get asked somewhere in SFRPD. Coincidentally, Golden Gate Audubon reported a number of dead birds showing up in the area, but Drive XLR8 is not considered especially toxic to birds and there’s no indication the two things are related. [Edited to Add: Actually, they may be related. See section at the end.] Anyway, Chris Geiger of SFDOE confirmed Drive XLR8 was a Tier I pesticide that would not be moved on to the approved list; this usage was a one-off.

Adjusted for the two incidents above, SFRPD reduced its non-NAP herbicide use by about 20% from 2013 to 2014. In fact, its usage this year was below NAP’s herbicide usage for 2013, and it used only a tiny amount of Tier I herbicide. But for exceptional incidents like the ones described about, NAP remains the single largest user of Tier I herbicides in SFRPD.

NAP vs other SFRPD 2014 n 2013

We applaud NAP’s reduction of herbicide use in 2014, and call for it to eliminate use of all Tier I and Tier II herbicides.

DEAD ROBINS NEAR KEZAR

[This section was added 22 Feb 2015.]

As we mentioned above, there were reports of dead birds around Kezar Stadium. We learned that they were mostly robins (but Golden Gate Audubon also mentioned blackbirds and sparrows), and the person who found them spotted several dead birds where ordinarily even one is unusual. We assumed that the use of Drive XLR8 on the Kezar Stadium turf was unrelated, because our research indicated no especial threat to birds.

But further investigation suggest that the problem chemical could be not the active ingredient, but ethylene glycol used in the formulation. Ethylene glycol is better known as anti-freeze, and it’s toxic to mammals and birds. The Cornell University College of Veterinary Medicine says the following on its “Consultant” website:

“Ethylene glycol, antifreeze, toxicity is often fatal in birds. Oxalate crystals are found in renal tissue at necropsy.” It lists the signs, which include sudden death: “Anorexia, Ataxia, Diarrhea, Dullness, Dysmetria, Neck weakness, Seizures or syncope, Sudden death, Torticollis, Trembling, Tremor.”

Robins love digging in the grass for worms and such, and with the stadium closed they would have had undisturbed access. If the worms on the field were poisoned by ethylene glycol, so would the robins.  There’s no way to tell for sure, because as far as we know none of the dead birds was kept for a necropsy (like an autopsy for animals).

But anyway, the good news is that the Department of the Environment does not plan to use this product again.

 

 

 

SF’s Natural Areas Program Beats Own Pesticide Record in 2013

This article is adapted with permission from SutroForest.com

UCSF, which owns and manages most of Mt Sutro Forest, recently decided not to use pesticides there. This may make it the only wild land in San Francisco that is reliably free of pesticides. Most of the others  fall under the misnamed Natural Areas Program (NAP) of San Francisco Recreation and Parks Department (SF RPD). NAP is responsible for around 1100 acres in San Francisco in 32 parks. It has a very different attitude to pesticides.

NAP Number of applicns 2008-2013NAP’s RISING PESTICIDE USE

We’ve been tracking NAP’s rising herbicide use, compiling reports we obtain under San Francisco’s Sunshine Act. (The report for 2012 is HERE; and for 2011 is HERE.) For a year or two, we hoped the rise was an anomaly. Apparently not. With the 2013 data in, the best things we can say are that the rate of increase is not as high as in the last four year; and that the number of applications fell.

But the volume of toxic herbicides used still rose.

People have asked us: But why complain about NAP? Surely a garden like Golden Gate Park with all those lawns and golf courses uses lots more herbicide than NAP? This year, we tracked that too. NAP also uses more pesticides than the rest of SFRPD put together.

NAP USES MORE HERBICIDES THAN THE REST OF SFRPD

NAP vs Other SFRPD 2013NAP, which manages one-fourth of the area under the SF RPD, uses more pesticide than the rest of SF RPD put together. That counts all the golf courses except Harding, which is apparently under contract to be tournament-ready.

Also, NAP is the main user of the most toxic pesticides. San Francisco’s Department of the Environment (SF DoE) – which watches out for pesticide use on city-owned property – rates the permitted pesticides into three Tiers. Tier III is the least hazardous; Tier II is more hazardous; and Tier I is most hazardous. NAP is the major user of the Tier I pesticide, Garlon.

VOLUMES UP

As we mentioned earlier, NAP’s pesticide use continued to increase in 2013, though the number of applications went down. The lower number of applications slightly reduces the opportunities for exposure to freshly applied toxins. But this is more than offset by the fact that actual amounts of pesticides continued to rise – and that many of these chemicals are the ones that are most toxic and very persistent.

Volume of pesticide use by NAP 2008-2013

THE FOUR PESTICIDES NAP USES

NAP currently uses four pesticides: Glyphosate (Roundup/ Aquamaster); Triclopyr (Garlon 4 Ultra); Imazapyr (Polaris or Stalker); and Aminopyralid (Milestone VM). They are all of concern. Of these, SF DoE rates Garlon as Tier I (most hazardous); the remaining three are currently rated as Tier II.

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

Despite the manufacturer’s claims, there is evidence that these herbicides are not safe. Our article summarizing this is HERE: Natural Areas Program: Toxic and Toxic-er.

ROUNDUP/ AQUAMASTER (Glyphosate)

Classified as a Tier II (More Hazardous) chemical by the San Francisco Department of the Environment, this is the most-used pesticide of the four. However, there’s been growing evidence that it’s not a safe herbicide.

  1. Toxic to human cells, particularly embryonic and placental cells. Here’s an article in Scientific American, about the effect of Roundup on human cells – not just the active ingredient, Glyphosate, but the “inert” one, POEA. (Aquamaster does not contain POEA.)
  2. Damage to liver, red blood cells, lymph system. Here’s a series of research articles detailing some of illnesses caused by Roundup.
  3. Link to birth defects. Here’s an abstract of a May 2010 article in the journal Chemical Research in Toxicology.
    heart breaking

    heart breaking

    It indicates that Roundup increased retinoic acid activity in vertebrate embryos, causing “neural defects and craniofacial malformations.” The actual article, which we read elsewhere describes some of the birth defects: microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (a single eye in the middle of the forehead); and neural tube defects. Our summary of this article is HERE.

  4. Linked to cancer, specifically, Non-Hodgkins Lymphoma. A 1999 article on research linking Roundup to cancer, specifically non-Hodgkins lymphoma, and HERE is a follow-up published in 2008 in the International Journal of Cancer.
  5. Dangerous to amphibians. This article cites University of Pittsburgh research showing Roundup is highly lethal to amphibians.
  6. Suspected endocrine disruptor. Initial research suggests that it is an endocrine disruptor in human cell lines. It’s on the list of chemicals the EPA is reviewing for endocrine disruption.

GARLON (Triclopyr)

NAP accounts for 96% of the use within SF RPD of this Tier I (Most Hazardous) chemical. Garlon kills broad-leaved plants (not grasses or conifers) by sending them a hormonal signal to grow uncontrollably. This weakens the plant until it dies. Its breakdown products are triclopyr acid and then ‘TCP’ – both of which are, fortunately, somewhat less toxic than Garlon. (Imazapyr, by contrast, has a breakdown product that is neurotoxic.)

Our article is based on the Garlon chapter of Draft Vegetation Management from the Marin Muncipal Water District (which can be found here as a PDF file). It was a pretty thorough multi-source review of what was known about the chemical, and it clarified the risks: birth defects; kidney damage; liver damage; damage to the blood. What stood out, though, was how much is not known, particularly about the effects of repeated low-level exposure. There simply isn’t that much research out there, and few human studies. “Although triclopyr has been registered in the US since 1979, there are still very few studies on triclopyr that are not part of the EPA registration process.” Most of the research that exists is on Garlon 4. What NAP uses is Garlon 4 Ultra. It’s similar but isn’t mixed in kerosine. It’s mixed in a less flammable but apparently equally toxic methylated seed oil.

What is known makes uncomfortable reading.

  • Birth defects. Garlon “causes severe birth defects in rats at relatively low levels of exposure.” The rats were born with brains outside their skulls, or without eyelids. “Maternal toxicity was high” and exposed rats also had more failed pregnancies.
  • Damage to kidneys, liver, blood. Rat and dog studies showed damage to the kidneys, the liver, and the blood. It’s insidious, because there’s no immediate effect that’s apparent. If someone’s being poisoned, they wouldn’t even know it. In a study on six Shetland ponies, high doses killed two ponies in a week, and two others were destroyed.
  • Skin absorption. About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast.
  • Dogs may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans. “The pharmacokinetics of triclopyr is very different in the dog, which is unique in its limited capacity to clear weak acids from the blood and excrete them in the urine.” Dow Chemical objected when EPA said that decreased red-dye excretion was an adverse effect, so now it’s just listed as an “effect.”
  • Insufficient information. There was insufficient information about Garlon’s potential effect on the immune system, or as an endocrine disruptor.
  • Not quite carcinogenic. It isn’t considered a carcinogen under today’s more lenient guidelines, but would have been one under the stricter 1986 guidelines.
  • Probably alters soil biology. “There is little information on the toxicity of triclopyr to terrestrial microorganisms. Garlon 4 can inhibit growth in the mycorrhizal fungi…” (These are funguses in the soil that help plant nutrition.) No one knows what it does to soil microbes, because it hasn’t been studied.
  • Dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Some effect on honey bees. It doesn’t generally kill adult honeybees, but there are no studies of other insects. Some studies show slight “acute toxicity” to honeybees.
  • Garlon can persist in dead vegetation for up to two years.

Given all the information we do have on this chemical (and all the information we don’t have ) we have to question why native plant restoration is worth spraying poisons on some of the highest points in our city. Garlon must be used when the weather is wet; if the plants don’t have water, they will not grow and the chemical won’t work. But the runoff from these hills is enormous during the rain – it washes down in rivulets and streams, and it will end in the reservoirs, the groundwater, and the bay.

IMAZAPYR

Classified as a Tier II (More Hazardous) chemical by the San Francisco Department of the Environment, this is another pesticide used mainly by NAP. In 2013, NAP accounted for 97% of the imazapyr used by SFRPD. NAP started using Imazapyr even before the SF DoE had approved its use. Now it’s being used in Sutro Forest. Here’s our article on Imazapyr.

The main issues with it are that plants push it out through their root system, so that it can spread and affect other plants; it is very persistent. Its breakdown product is neurotoxic. It’s banned in Europe.

According to a BASF Safety Data Sheet from Europe, it’s “Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment.” However, a BASF Material Safety Data Sheet from the US says, “There is a high probability that the product is not acutely harmful to fish. There is a high probability that the product is not acutely harmful to aquatic invertebrates. Acutely harmful for aquatic plants.”

Interesting.

MILESTONE VM (Aminopyralid)

SF DoE originally classified this chemical as Tier I, Most Hazardous, because of its uncanny persistence. In 2013, it was reclassified as Tier II – More Hazardous. At the time, we protested that the down-classification would increase its use; SF DoE didn’t think so. But this year, NAP’s use of Milestone has risen 200% from 2012. (Only NAP uses Milestone in the SF RPD.)

Milestone is even more persistent that Imazapyr, and can survive being ingested by animals. Thus, if it is used to treat plants and animals eat and excrete them, they spread the poison. It is banned in New York for fear it will get in the groundwater, and was for a time banned in the UK.

STILL RISING

For purists, we also calculated NAP’s pesticide usage based on “Active Ingredient” and based on “Acid Equivalent.” (The post explaining those measure is HERE.) By those calculations, it’s gone up even more.

NAP Pesticide by Active Ingredient 2008-2013NAP Pesticide by Acid Equiv 2008-2013 Index of NAP Pesticide Use 2009-2013

The graph above shows index numbers of the various indicators, with a base of 2008 (i.e, 2008 = 100). After a dip in 2009, NAP’s pesticide use has trended upward for four years. We cannot quite understand the need for the continuous rise in pesticide use in NAP. We can only wonder if it correlates to budget availability.

We call upon SF RPD to stop all Tier I and Tier II herbicide use in Natural Areas. It would make the Natural Areas more … natural. And it would halve SF RPD’s herbicide consumption, and nearly eliminate their use of Tier I pesticides.

NAP vs SF RPD Other 2013

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.)

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THE LAST ROUNDUP

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

Roundup

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 http://www.sciencedaily.com/releases/2005/08/050804053212.htm

4 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds http://www.sciencedaily.com/releases/2005/08/050804053212.htm

10 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_090116.pdf

11 University of Minnosota Extension Service, “Use Caution When Harvesting and Feeding Ditch Hay.” http://www.extension.umn.edu/distribution/livestocksystems/components/M1197.pdf

15 Pesticide Properties DataBase http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

16 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_1101.pdf

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 [http://planetwaves.net/contents/faking_it.html 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)] [http://www.mindfully.org/Pesticide/Roundup-Glyphosate-Factsheet-Cox.htm 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. — http://dic.academic.ru/dic.nsf/enwiki/56554

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 Findshttp://www.sciencedaily.com/releases/2005/08/050804053212.htm

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. http://pubs.acs.org/doi/abs/10.1021/tx800218n%5D.

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 http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

37 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/gbr.htm

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 http://www.aces.edu/pubs/docs/A/ANR-0846/

SF’s Natural Areas Program Uses Even More Pesticides

The 2012 final data are in, and it’s official: In 2012, the Natural Areas Program (NAP) used more pesticides than in any year from 2008 (the first year for which we have data provided by the City). This is true by any measure, as the graphs below indicate. [Note: Graph edited to indicate units]

[Edited to Add: NAP also used more Tier I pesticide – the most toxic – than the rest of SF RPD areas together. HERE]

pesticide use number n vol 2008 to 2012

Depending on the measure you choose, usage has increased anywhere from 12% to 40% from 2011. It’s between 3 and 4 times the usage in 2008.

THE FEARSOME FOUR AGAIN

What pesticides have they been using?

The same as before: Tier II and Tier I pesticides, defined as more hazardous and most hazardous. (For a detailed discussion of these chemicals, click HERE:  Natural Areas Program’s Pesticides: Toxic and Toxic-er.

  • Aquamaster/ Roundup (Glyphosate). (Tier II)  This is one of the world’s most widely used herbicides, but in vitro research has linked these chemicals to changes to human cells, some of which are of the kind that could cause birth-defects. The EPA is studying whether it is an endocrine disruptor. The fact that it’s widely used gives us little comfort; a different widely used herbicide has just been declared unacceptably toxic to bees.
  • Garlon (Triclopyr). (Tier I) To NAP’s credit, they have reduced the use of this extremely toxic herbicide since the peak in 2010. It’s a Tier I pesticide, and associated with numerous diseases in humans, and potential kidney impacts on dogs.
  • Polaris (Imazapyr). This Tier II herbicide is a problem because it spreads (it doesn’t stay where it’s applied) and it persists (it doesn’t break down easily). It’s a relatively new herbicide, and we don’t know quite what it does – though its breakdown product  is neuro-toxic. It’s banned in Europe, and neighbors are fighting against its use in privately owned forests in Northern California.
  • Milestone (Amino-pyralid). This Tier I toxic chemical sticks around even more persistently than imazapyr. It was banned for a time in the UK because if animals eat and excrete it, the excreta are still poisonous – as is the manure made from it. It’s banned in New York state because they aren’t sure it won’t poison the water. NAP’s used it in Lake Merced, Pine Lake, Glen Canyon, and Mount Davidson, all of which are areas where water contamination is possible. [Edited to Add: In 2013, Milestone was reclassified as a Tier II chemical.]

BAD FOR PEOPLE, BUTTERFLIES AND FROGS

Of course these chemicals are not good for people, and one would think that in a city that is so conscious of organic and green produce and products, wild lands would be one area that we’d try to keep organic. Not so. We even found evidence of blackberry bushes being sprayed – during the fruiting season when children and adults, birds and animals feast on the bonanza of berries.

Recent research indicates that both triclopyr and imazapyr are potentially toxic to butterflies – but NAP continues to use both Garlon and Polaris on Twin Peaks, where NAP are also struggling to re-introduce the endangered Mission Blue butterfly. Glyphosate is known to be dangerous to amphibians; but NAP uses Aquamaster around Lake Merced, Pine Lake, and in Glen Canyon – all near water-courses.

Finally, we have another problem with this use: it may be glorifying chemical solutions. A few months ago, a “volunteer” in Glen Canyon was found applying an unapproved pesticide to an area near a trail, without posting any notices or keeping any record of amounts or conditions. He believed he was doing a good thing for the environment. We have heard since of many other instances of random herbicide application in Natural Areas.

PLEASE STOP TIER I AND TIER II PESTICIDES IN NATURAL AREAS

Furthermore, the list of plants on which it’s used also keeps expanding. It’s currently around 30, up from under 2 dozen a year ago. Some of the plants being sprayed aren’t on the list of the California Invasive Plants Council or USDA noxious plants lists.

We ask SF Recreation and Parks Dept  to stop using Tier I and Tier II pesticides in the Natural Areas. An escalating use of herbicides is bad for the environment and the people, pets and wildlife using these parks;  sends a damaging message about priorities; and indicates a lack of success.

The Natural Areas Program and Pesticides: Volumes and Numbers

We talked about pesticide use in the Natural Areas a number of times, and particular of the increasing volumes of the “Fearsome Four” pesticides they use most:

  • Glyphosate (Roundup or Aquamaster);
  • Triclopyr (Garlon or Garlon 4 Ultra);
  • Imazapyr (Polaris or Habitat); and
  • Amino-pyralid (Milestone).

[Read more about the effects of these herbicides HERE: SaveSutro’s article Toxic and Toxic-er.]

We got San Francisco’s Natural Areas Program pesticide use records under the Sunshine Act, and used them to create a graph of the number of applications by year. We’ve shown this graph at some of our presentations.

Recently someone spoke to us about the graph. “I asked NAP about it, and they said that possibly the number of applications has gone up, but the amount of pesticide use has gone down because they use less in each application.”

Possibly.  And possibly not.

VOLUMES ROSE MORE

What we found when we looked was that volumes have increased even more. (This is based again on the data provided us under the Sunshine Act.)

  • Between 2010 and 2011 the number of applications went up 21%. The volume of pesticide (in fluid ounces) used went up by 25%.
  • Between 2009 and 2010, the number of applications went up 184%. The volume of pesticide used went up by 365%.

So here’s that graph:

(Milestone doesn’t show up here because until now, the volume of applications has been small. Possibly, given its persistence, we should count it cumulatively?)

[Click HERE for more about ” Milestone” – aminopyralid.]

Edited to Add: For those interested in details of NAP’s pesticide use, calculated four different ways (number of applications; volume; active ingredient; and “acid equivalent”) here’s an article with details:

Click here for SaveSutro’s article: Measuring Pesticide Use by the Natural Areas Program

This graph that summarizes it by comparing pesticide use on various measures to 2008 levels. Pesticide use went down in 2009, then increased sharply in 2010 by all measures. In 2011, it rose in volume terms and number of applications, and declined very slightly when measured by active ingredient or acid equivalent.

—————–

[Edited to replace with the more precise and detailed calculation, above.]

Edited to Add (for those with a technical bent): SF RPD used various formulations of glyphosate over the years. Technically, to compare them you need to calculate “Acid Equivalents” of the various formulations. We did this exercise,  converted them to Aquamaster equivalents, and adjusted the numbers. It made no significant difference. Between 2010 and 2011 the number of applications went up 21%. The adjusted volume of pesticide used went up 52%. Between 2009 and 2010, the number of applications went up 184%. The adjusted volume of pesticide used went up 264%.


Natural Areas Pesticides: The Fearsome Four

Three of the Four on Mt Davidson

The Natural Areas Program (NAP) uses four herbicides classified as “Most Hazardous” (Tier I) or “More Hazardous” (Tier II) by San Francisco’s Department of the Environment (DoE):

  • Garlon 4 Ultra (triclopyr)
  • Roundup or Aquamaster (glyphosate)
  • Polaris or Habitat (imazapyr)
  • Milestone (aminopyralid)

All these chemicals have serious problems: they’re associated with birth-defects and pregnancy failures; they’re endocrine disruptors; they poison animals, especially amphibians but also reduce bird-nesting success; and/or they’re persistent – they stick around.

For details of the risks associated with each one, read the article Natural Areas Program’s Pesticides: Toxic and Toxic-er.

We often get questions about this, especially from people who have heard about NAP from its supporters.

Source: SaveSutro.com (derived from from SF City records)

Q:  They hardly ever use pesticides, right? Just once every few years?

A:  NAP applied pesticides 86 times in 2011, up from 71 the year before. (We’re relying on City records here. There may be gaps.)

Q: But maybe they used less in each application?

A: The amounts used went up in proportion.

Q: Don’t they use very small amounts? Doesn’t the dose makes the poison?

A: In 2010, NAP used more Tier I herbicides than any comparable park department. (We don’t have compiled data for 2011 for other parks departments.)  Anyway, “the dose makes the poison” isn’t always true. Here’s what the American Chemical Society said in its Public Policy Statement, Testing for Endocrine Disruption:

Endocrine disruption is the alteration of the endocrine system that causes adverse health effects in an intact organism, or its progeny, or (sub)populations. Endocrine hormones naturally act at ultra-low concentrations and certain chemicals are suspected of altering endocrine function at similarly low concentrations, which sometime occur in the environment. A large and growing body of environmental health literature shows that endocrine disrupting substances have complicated dose-response curves that do not fit the central tenet of regulatory toxicology, namely, that the ‘dose makes the poison.’

Q: But aren’t they herbicides… don’t they act only on plants?

A:  They act differently on plants and on animals, but they still can – and do – impact animals (and people).  They may use different bio-chemical pathways in animals and in plants, and thus have different effects. None of these effects is good. The city of San Francisco subscribes to the “Precautionary Principle” – if you don’t know the effects, don’t use it. The natural areas are where children explore, people walk, and pets are exercised. This is not a risk they should take.