Pesticide regulation

Does licensing means it’s safe?

PMRA claims 2,4-D is safe

On Monday, February 21, 2005, the Pest Management Regulatory Agency (PMRA) made an interim announcement that the pesticide 2,4-D can be used safely on lawns and turf when label directions are followed.

Illegal statement “Subsection 4(2) of the PCP Act states that

“No person shall package, label or advertise a control product in a manner that is false, misleading or deceptive or is likely to create an erroneous impression regarding its character, value, quantity, composition, merit or safety.”

“The terms “safe” or “safer” in the context of environmental claims (e.g., environmentally safe” or “safe for the environment”) may be misinterpreted as relating to personal safety and, as a result, may cause some confusion

Safe today- unsafe yesterday

Reduced application rate Reduced frequency of application to

twice a year maximum Institutions of buffer zones Time lag before new labels Result: anyone using a product with an

old label is therefore not using it ‘safely’

Exclusion of one form from re-evaluation PMRA excludes from its assessment

the most toxic form of 2,4-D amine, DEA, because “ the database…does not support the DEA form of 2,4-D,” and that “Mitigation measures for the DEA form of 2,4-D may be proposed depending on the outcome of the current review of this additional information.”

How common is DEA in lawn care products? 92 % of lawn care products, both

domestic and commercial, contain mixed amines (DMA + DEA)– 85 % of the manufacturing concentrates, – 98.59 % of the weed-and-feed products,

and – 80 % of PMRA registered formulas of 2,4-D

2,4-D used alone or in mixtures?

The PMRA did not have a list of W&F products registered under CFIA and did not even know how many there are.

86.6 % of W&F products are mixed with mecoprop or mecoprop and dicamba.

Why is it important? Because pesticides are only tested

alone, never in mixtures Even the U.S. EPA says that they don’t

have a clue how to assess the health effect of mixtures.

PMRA notes that these mixtures are synergistic (under the value section),

But no attempt at evaluating increased risk resulting from that synergy

Mixed mostly with de-registered form of mecoprop racemic mecoprop (indicated by a (+/-) on the

label)is to be de-registered by the PMRA because of a lack of safety data.

industry can sell products containing it to unsuspecting users until the end of 2009.

78.22% of all 2,4-D formulations, including 88.57% of W&F products are currently formulated with racemic mecoprop.

Most of a pesticide product is formulants On average, formulants make up 32 % of a

pesticide product. The level of formulants can go up to 99 % or

more in domestic products (the ones homeowners can buy).

Formulants are secret in Canada. Neither government or industry feels that consumers have a right to know what they are.

2,4-D Formulants 30 of 2,4-D U.S. formulants are also

registered in Canada. Likely that most of them are used in one

or the other 2,4-D Canadian products. The PMRA itself recognizes 26 % of

these formulants as potentially toxic (7 on list 2 and 2 on list 4B).

2,4-D Formulants

In the U.S., 70 % of those formulants are already recognized as chemically, biologically, or toxicologically active under various Acts and Regulations.

and 43 % (13) are or have been used as pesticide active ingredients

Formulant examples

Many are readily absorbed through skin, lungs and digestive system

Ex: antifreeze, wood alcohol (methanol) and xylene

Glutaraldehyde is very toxic when breathed in or ingested

General flaws in Assessment

Meaning of “Science-based process”: Should question the implication that using science

can define an "acceptable risk". Science may illuminate risks, but the degree of acceptability is a decision for society.

Terms like “assume”, “estimate”, “unlikely” and “not expected” riddle the report.

EPA to update and revise its data requirements (announced in March 05)

Pesticides remain on the market even when their data requirements are not met (2,4-D)

Dioxins

2,4-D not monitored for dioxins since 1983, in spite of having had contamination problems

PMRA asking for analyses of the wrong dioxins (with 4 or more chlorines instead of the ones containing 2 or 3 chlorine

Limited requested dioxin data not yet submitted The PMRA also still assumes that people use

pesticides according to labels, while most surveys and studies indicate that they do not

Byproducts ignored

2,4-D re-evaluation totally ignores the consistent presence of the toxic breakdown product 2,4-dichlorophenol

Air contamination of 2,4-D

PMRA claims 2,4-D not volatile Widespread in air and rain samples (in 60 %

of US air samples) EC estimates that 17 % of applied 2,4-D is

found in air Drift has been measured up to 50 miles

distance and damaged various crops Even low volatile products drifted 10 miles 2,4-D particle and vaporization lift-off greater

than other phenoxy herbicides.

Water contamination of 2,4-D Very soluble in water USGS found it in 12% agricultural stream

samples, 13.5 % urban stream samples and 9.5 % general samples

SK studies - Found in 93-100% dugout samples (turnover), 98 % return irrigation water (Cessna), 50-100% lakes (Donald), ponds and groundwater (Waite), rain, and with general diffuse distribution (Donald)

Pesticide contamination of drinking water Groundwater contamination SK and US More extensive US data shows

widespread contamination in surface waters. SK data too.

Donald coming up with study of MB,SK,AB small communities

Conclusion: When we look, we find

Is 2,4-D residual or persistent?

Would depend on the form As much as 6 months in still water 800-1900 days in groundwater Persist in wastewater treatment plants Soil: 2-296 day half/life Persists longer in marsh or wetland

sediment (no oxygen)

2,4-D in food

Found in 6 fruits and vegetables in 1990s (US)

In 75% milk samples in 1 study Not tested in wheat in US 1 Ag Canada study found it in wheat

seeds above Canadian tolerance level following late season 2,4-D treatment

2,4-D indoors In 60 % carpet dust and 100% dust of houses

tested Remains there for up to 1 year Concentration 10 times higher in week

following lawn treatment Resuspension of floor dust =major source of

2,4‑D in indoor air, with most particle size range of 2.5‑10 μm.

Applicators’ living quarters, desks and work vehicles - all surfaces contaminated

Do pesticide harm people?

Evidence that children’s body burden of pesticides is higher than adults

Evidence of human harm is constantly mounting

2,4-D linked to infertility, spontaneous abortions, cancer, neurological effects

Banning chlorophenoxy herbicides resulted in a decline of several health conditions (NHL)

Do pesticides harm wildlife?

Out of 80,000 birds tested for WNV, the single leading cause of death among birds in New York State was actually pesticide poisoning

Herbicides destroy habitat and food plants, insecticides kill food

2,4-D’s effects vary with animal group (see handout), bioaccumulates

BEE highly toxic to fish

“in Mississipi, Louisiana, and Alabama the Field Notes published quarterly by the National Audubon Society and the US Fish and Wildlife Service noted the striking phenomenon of “blank spots weirdly empty of all bird life” Silent Spring, p. 100

also reported for Winnipeg in the 70s in the book “Cities Under Siege”. According to a Regina birder who regularly visited his daughter in Winnipeg, Winnipeg was still such a blank spot until fairly recently. (article by Diether Pechken in LP)

Silent Spring quote on 2,4-D

”Poisonous range weeds have suddenly become attractive to livestock after spraying, and the animals have died from indulging this unnatural appetite” because “there is a temporary increase in sugar content, making the plant more attractive to many animals.” Silent Spring p.80

Silent Spring quote on 2,4-D 2,4-D…”after treatment with this chemical

there is a sharp increase in the nitrate content of corn and sugar beets. The same effect was suspected in sorghum, sunflowers. Spiderwort, lambs quarters, pigweed, and smartweed…when animals feed on vegetation containing an abnormal amount of nitrates, the micro-organisms in the rumen act on the nitrates to change them to highly toxic nitrites.” Silent Spring p. 80

Starvation without pesticides?

No one is talking about getting rid of all pesticides tomorrow morning

Using pesticides creates as many problems as it solves (e.g. secondary pests, susceptibility to pests or diseases)

A lot more pesticides are used now, and crop damage has not decreased

Pimentel claims that cutting 50% of pesticide use today would cause no decrease in crop production

Wood preservativesCreosote, pentachlorophenol and CCA

Chemical wood preservatives account for the single largest pesticide use in the US

All have high acute toxicity Move from pole into soils and then in aquatic

ecosystems Synergy of ingredients known All pose serious pollution problems on

disposal

Wood Preservatives (cont)

All are classified as carcinogens (As) to probable human carcinogens

All affect the immune and nervous systems

All interfere with reproduction and/or cause birth defects

Creosote and penta are known hormone disruptors

Pentachlorophenol

Banned in at least 26 countries Bioaccumulates in human body and

environment Commercial grade contaminated with

dioxins, furans and hexachlorobenzene, all recognized as carcinogens, mutagens, teratogens and ED

Acutely neurotoxic

Pentachlorophenol (cont)

Ubiquitous in environment Contaminating body tissues of 79 % general

US population EPA’s preliminary science review shows risk

of children exposed to soil contaminated with penta is 220 times acceptable level

13/14 jobs have unacceptable cancer risk

CCA wood

Until recently the most common wood treatment for home use (decks, playgrounds, fences etc)

manufacturers agreed to make a transition away from the use of CCA for the for the non-industrial market by Dec. 31, 2003. (rev2002-03)

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Aerial spraying

Regulated under Transport Canada Had assumed that more pesticide

used/application, but not necessarily true Drift depends on wind speed and droplet size.

Some studies show more drift. Applicators supposedly trained. However,

most of yearly complaints to SAF are from aerial spraying

Silent Spring p 73

“the chemical weed killers are a bright new toy. They work in a spectacular way; they give a giddy sense of power over nature to those who wield them, and as for the long-range and less obvious effects – these are easily brushed aside as the baseless imaginings of pessimists.”

“We stand now where two roads diverge. But unlike the roads in Robert Frost’s familiar poem, they are not equally fair. The road we have long been traveling is deceptively easy, a smooth super highway on which we progress with great speed, but at its end lies disaster. The other fork on the road – the one ‘less traveled by’ – offers our last, our only chance to reach a destination that assures the preservation of our earth.” Silent Spring p. 240