Letter from World Wildlife Fund regarding herbicide spraying in Colombia, November 21, 2001

Letter from World Wildlife Fund regarding herbicide spraying in Colombia, November 21, 2001
21 November 2001

The Honorable Russ Feingold
United States Senate
Room 506 Hart SOB
Washington, DC 20510

Dear Senator Feingold:

We have reviewed the August 20, 2001 State Department response to your letter of August 3 on aerial application of herbicides in Colombia. The response reflects attention to some of the human health issues related to the spraying of glyphosate. However, the response fails to adequately address the environmental impact of aerial fumigation or to consider the full range of human health impacts from spraying. We elaborate on these points below.

The State Department response relies on the assertion that environmental damage from illicit crop production outweighs the environmental damage from widespread aerial spraying. We do not believe that in bringing an end to the human and ecological damage caused by the illegal drug trade, the U.S. and Colombian governments are justified in using aerial fumigation tactics that also pose potentially serious risks to human and ecosystems health. Certainly, it is wrong to accept such a conclusion in the absence of sufficient data. Furthermore, in the absence of adequate alternative development programs, aerial fumigation may cause even further human misery and environmental degradation as communities lose food crops and are forced to retreat further into previously uncultivated areas.

The State Department asserts that the use of glyphosate is safe. The safety claims made relative to a specific pesticide product are valid only when there is adherence to the formulation, application, storage, disposal, worker safety and general safety precaution requirements specified by the manufacturer. Every pesticide product registered with the United States Environmental Protection Agency (U.S. EPA) has a warning that states: "It is a violation of Federal law to use this product in any manner inconsistent with its labeling." We are concerned that the manufacturer's application requirements (as specified for the commercially available Roundup products produced by Monsanto), set forth in Appendix A to this letter, are violated by the aerial fumigation activities in Colombia. Therefore product claims of safety are no longer valid.

Furthermore, data submitted to the U.S. EPA by the registrant during the registration process to determine the parameters of "safe use" are developed in response to the typical usage patterns for which the product will be applied in the U.S. The U.S. EPA's designation of glyphosate as safe does not cover landscape applications in tropical forests laced with rivers and streams. And, we doubt that there are data available which indicate the impact of extensive, landscape wide, whole watershed application of this broad-spectrum herbicide.

The information provided by the State Department regarding surfactants, inerts and other additives used to enhance the efficacy of glyphosate is insufficient. Frequently the specific formulation of a pesticide, including inerts, is more toxic than the active ingredient alone. This has been clearly demonstrated in the case of glyphosate. The fact that Cosmoflux, an additive produced in Colombia, is not registered in the U.S. is very troublesome and is in no way mitigated by the assurance that the Colombian government has approved its use.

The damage caused by drift, spraying on non-target areas, and misapplication of the pesticide is a significant concern, and is one of the reasons that the manufacturer does not recommend aerial application of glyphosate. A salient example of drift occurred when Senator Wellstone and other Embassy and congressional staffers were in Colombia in December 2000 to observe spraying operations. DynCorp could not effectively control drift during the demonstration and sprayed Senator Wellstone, as well as the other members of the delegation.

Additionally, widespread aerial fumigation is a concern. Very little concrete information and few data are available comparing conditions subsequent to aerial fumigation to pre-spraying conditions. Tropical soils treated with glyphosate are likely to be altered. Further, defoliated areas will be subject to increased erosion under the heavy rainfall conditions common to the sprayed areas, and river systems may carry glyphosate to non-target regions, even neighboring countries.

As a result of all of these issues we remain alarmed about the potential, long-term, devastating consequences on the Colombian environment, one of most biologically rich places on the planet. The State Department response inadequately answered questions about the ecological impacts of wide-scale aerial applications of glyphosate. Attached, as Appendix B is a list of questions, comments, and requests for clarification and information. We respectfully request that you submit WWF's questions to the State Department and solicit a response.

On July 13, 2001, WWF President, Kathryn S. Fuller sent a letter to all members of the U.S. House of Representatives recommending the elimination of aerial application of Roundup until an adequate environmental impact study has been conducted. We recommend that the Government Accounting Office (GAO) conduct a study of the environmental impact of the aerial application of glyphosate. We request that you work to ensure that such a study be conducted, and we will be available to provide technical assistance as you deem appropriate.

Thank you for you interest and concern about this issue.

Sincerely,

William Eichbaum
Vice-President, Endangered Spaces Program
World Wildlife Fund

Cc: Rand Beers, State Department
Appendix A
Manufacture's requirements

a) No non-target exposure to other foliage, green stems, exposed non-woody roots or fruit crops, desirable plants and trees.
b) No application directly to water, to areas where surface water is present or to inter-tidal areas.
c) No application at a height greater than 10 feet above the top of targeted plants.
d) No application in a way that will contact workers or other persons, either directly or through drift as only protected handlers may be in the area during application.
e) Enforcement of the specified Restricted Entry Interval (REI) of workers or other persons into treated areas (i.e., in the case of Roundup PRO the REI is 4 hours, meaning that no individual may enter fields sprayed with glyphosate until 4 hours after application).
f) Enforcement of spray drift management requirements that must be followed to avoid off target drift movement from aerial applications.

Appendix B:
Questions

Glyphosate
1. The toxicity of glyphosate depends on the commercial formulation used. We request more data on the commercial formulation of the Roundup Ulta, Cosmoflux and any other inert ingredients in the mixture being used. Please clarify the discrepancies between the response to question 1 and 2. Tab 1 says 41% glyphosate, 44.5% water and 14.5 surfactant blend. The next paragraph says 44% glyphosate, water 55% and 1% cosmo.

2. The State Department letter asserts, "scientific literature on pesticides and herbicides indicates that glyphosate-based products could potentially cause skin and eye irritation, especially to persons directly handling, mixing, or manually applying the product. If these problems occur, they are short-term, reversible, and do not pose a serious health risk. The allegation that animals die as a result of exposure to the glyphosate is inconsistent with the scientific literature on the subject." Peer reviewed and published scientific studies document glyphosate's serious toxic effect on invertebrates, amphibians, fish, beneficial soil microorganisms such as nitrogen-fixing bacteria and mychorrizae, and non-target plants. Is the State Department also denying reports of fish dying, many in small commercial or household fishponds?

3. What studies have been conducted that evaluate the chemical composition (Roundup Ultra combined with Cosmoflux) and the environmental impact of this product in the manner in which it is being applied and in the ecosystem in which it's being applied? Additionally, how relevant are the toxicology and environmental impact studies done in the U.S. in an environment as biologically diverse and ecologically complex as the Colombian Amazon and Northern Andes?

4. From the EPA Fact Sheet, glyphosate is listed as a Category III, not a Category IV chemical. For some glyphosate end use products (commercial formulations), it is considered a Category I or II level for eye irritation.

Cosmoflux-411F
5. From the information provided, it is not clear that testing has been done to compare toxicity with and without Cosmoflux. Are there studies that compare the toxicity of the glyphoshate mixture with and without Cosmoflux in the environment and manner in which it is being applied in Colombia?

6. Does Cosmoflux-411F perform the same function on human and animal skin, thus causing more damage than glyhposate alone?

7. The State Department letter states "Cosmo flux is 17 percent alcohol and 83 percent other added ingredients (inerts)." Inerts can be more damaging than the pesticide itself. We request detailed information on whole tank mixture formulation-all active ingredients, surfactants, inerts and other ingredients.

8. The State Department letter asserts that Cosmoflux "is produced in Colombia and has been cleared for use by the GOC, and is broadly used in commercial aerial spray operations in Colombia. While not sold in the US, its ingredients were nonetheless reviewed by the U.S. EPA and were found acceptable for use on food crops." We request a copy of review documentation and clearance. Specifically, what types of testing have been done? One cannot assess the impact of the substance alone; rather it should be examined as formulated and applied.

Drift
9. The State Department letter does not adequately address the issue of drift. The response focuses on crops but provides minimal consideration of natural vegetation. The response states, "if drift occurs, the type of affected vegetation varies; generally brush type environment is affected rather than cultivated crops." What is meant by brush and would this not have an effect on natural vegetation? We understand there are new studies underway by EPA related to drift and herbicides, and that some studies indicate that a buffer area of 75-1200 meters is needed to protect non-target vegetation in aerial application of glyphosate. What are the buffer area requirements being used within the context of the aerial fumigation campaign in Colombia? Are there limits to the size of the area cultivated that would be subject to aerial fumigation?

Other
10. We request the DEA studies for Colombia, and the other Andean countries that are cited in the letter, including documented agrochemical use on coca.

11. Does the application of herbicides take place only where alternative development is in place so as to not risk the dispersion and expansion of illicit crops into other areas that are not yet sprayed or does spraying also take place where there are no alternative programs in place? We request a description of what alternative development programs are slated for each area where fumigation is planned or has been carried out, and an assessment of what percentage of small farmers affected by fumigation are also direct recipients of alternative development programs. We also request an analysis of the cultivation and expansion of illicit crop production compared to areas where aerial fumigation interventions occur versus where they have not occurred.

As of November 30, 2001, this document was also available online at http://www.usfumigation.org/Literature/Letters/wwf.htm