2019-12-12 Letter to Aaron Chung re Veto of Bill 101 relating to Herbicide Use (2)

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December 12, 2019 Page 2  The County should not indiscriminately prohibit herbicides that have no relationship to its current use of herbicides and create unnecessary concerns.  The EPA lists “Alachlor” as an herbicide used on agricultural crops.  The chemical “Trilopr” is not an active ingredient in any common herbicide and should not be included in the list. C. This Bill identifies and codifies one herbicide as a “probable carcinogen.” o The Bill relies upon the World Health Organization’s (WHO) listing of glyphosate as a “probable carcinogen.”  In 2015, the WHO International Agency for Research on Cancer (IARC) was one program (out of four) that published an evaluation of glyphosate categorizing it as “probably carcinogenic”.  The other three programs within the WHO that reviewed glyphosate found glyphosate not to be a probable carcinogen: 1. WHO Core Assessment Group; 2. WHO Guidelines for Drinking-Water Safety; and 3. WHO International Programme on Chemical Safety o In 2017, the EPA evaluated the cancer risk of glyphosate to humans and determined that glyphosate was “not likely to be carcinogenic to humans” when used according to the labels. Recommendation: o Delete the statement, “Exposure to these substances subjects the public, County workers, domestic animals and wildlife to a high risk of exposure to dangerous chemicals.” This is not an accurate statement. o Revise or delete the statement in the Findings and Purpose attributed to “dangerous chemicals” and “harmful chemicals.” o Revise or delete the statement in the Findings and Purpose related to WHO.  This statement does not represent the findings of the three other WHO programs or the findings of the EPA. 2. Operational Concerns A. Vegetation Management Transition Committee (Committee) o The transition period begins January 1, 2020.  The Committee is to be made up of seven highly specialized individuals that will be challenging to find.  The Committee “shall be residents of the County.”  This requirement limits the Committee from the expertise of non-residents and creates a problem when trying to fill these volunteer positions. Recommendation: County of Hawai`i is an Equal Opportunity Provider and Employer.