HomeMy WebLinkAboutCOM 0271.295 2012-2014 (Q.° CENTER FOR
FOOD SAFETY
July 1, 2013
To: Office of the County Clerk, Hawai'i
counciltestimony(%co.FIawai'i.hi.us
COUNTY CLERK
COUNTY OF EAWAI'j
From: RECEIVED �f��
Bill Freese, Science Policy Analyst Time By/LEI
Center for Food Safety Dat. t} '�r�
bfreese@centerforfoodsafety.org
Regarding: Bill No. 79 -
AN ORDINANCE AMENDING CHAPTER 14 OF THE HAWAI'I COUNTY
CODE 1983 (2005 EDITION, AS AMENDED), BY ADDING A NEW ARTICLE
RELATING TO PROHIBITION OF GENETICALLY MODIFIED ORGANISMS.
Thank you for the opportunity to provide testimony on Bill 79. Some of the references cited are
also being submitted separately from this testimony, including two Appendices. For all
supporting materials being submitted,the filename will begin"CFS ....." followed by the
author(s) and year of publication for scientific papers, or other filename that identifies the
material.
Center for Food Safety(CFS) is a non-profit organization based in Washington, DC that supports
sustainable agriculture and opposes harmful agricultural and food production technologies. I am
the science policy analyst at CFS, and have 14 years of experience working on agricultural
biotechnology issues. I am author of many reports in this area, including a peer-reviewed
scientific paper critiquing the US safety testing and regulatory regime for genetically modified
organisms.' I am widely quoted on biotechnology issues in the mainstream and scientific press,
and have testified before Congress. I am also familiar with the GMO situation in Hawai'i based
on numerous visits over the past decade, and offered comments on behalf of CFS regarding
Hawai'i County's prohibition of the cultivation of genetically modified taro and coffee.
CFS urges County Council members to support Bill 79 for the protection it affords to the Big
Island's agriculture, environment and the health of its citizens.
I'd like to briefly address three subjects:
1) Hazards of pesticide use with GE crop field tests on Hawai'i
2) Why Hawai'i County cannot rely on EPA for protection from these hazards; and
3) Examples of pesticide regulation by states and municipalities in view of EPA's
deficient regulation
' Freese W& Schubert D (2004). "Safety testing and regulation of genetically engineered
foods,"Biotechnology and Geneti Engineering Reviews 21: 299-324.
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email:office @centerforfoodsafety.org I www.centerforfoodsafety.org www.truefoodnow. mm.
Ref. To:�/f? L
Ref. Date - O 2 [urn
Hazards of Pesticide Use with GM Crop Field Tests on Hawai'i
Hawai'i is ground zero for experimentation with genetically modified crops,with more field tests
than any other state in the nation since field tests began in 1987 (Appendix A). In 2012 alone,
USDA data show 160 releases conducted on 740 field test sites (Appendix B). Because Hawai'i
is much smaller than Midwestern states that have experienced nearly as many releases, it has a
higher density of field tests. For instance,Hawai'i has had 5.4 times more GE crop field releases
:..J. per unit area than Illinois. This means that in general,more people in Hawai'i live in close
— proxitr ity`fo field test sites than residents of Midwestern states like Illinois.
Most of the field tests have involved GE corn,though in recent years more experimental GE
soybeans and a sprinkling of other crops have been tested. But unfortunately,we know very
little else, except that none of these experimental GE crops meet any of Hawai'i's food needs.
As noted above, most GE crop field tests in Hawai'i involve corn, and corn is one of the most
chemical intensive of crops. Enormous quantities of nitrogen and phosphorous fertilizer are
applied,2 in addition to heavy doses of pesticides.3 Fertilizer runoff can severely impact aquatic
life, and is a major cause of the dead zone in the Gulf of Mexico.4 Pesticides include herbicides,
which kill weeds; insecticides for insect pests, and fungicides to control plant disease.
Growing GE seed corn uses even more pesticides than growing corn for animal feed,with up to
12 trips across the field per crop.5 I'm told that one can grow two or three corn crops a year in
Hawai'i,rather than just one crop as on the mainland,which potentially leads to a doubling or
tripling of the pesticidal impact on each acre of land.
All of the biotechnology companies that operate in Hawai'i—Monsanto, DuPont-Pioneer, Dow,
Syngenta and BASF—are experimenting with and actively developing herbicide-resistant crops,6
which are genetically engineered to permit heavy and repeated applications of often toxic
herbicides. For instance, Dow has tested corn resistant to 2,4-D,part of Agent Orange used in
2 USDA statistics show that in 2010, US farmers applied on average a historical high of 140 lbs.
of inorganic nitrogen fertilizer per acre; and a hefty 60 lbs./acre phosphate. Corn alone
accounted for 46% (nitrogen) and 47% (phosphate)of the nitrogen and phosphate fertilizer
applied in all of US agriculture in 2010.
3 Corn accounted for roughly 40% of total agricultural herbicide use in 2005,while over 80%of
the toxic herbicide atrazine (see below) is applied to corn.
4 Diaz, RJ (2008). "Spreading dead zones and consequences for marine ecosystems," Science
321: 926-929.
5 Thomison,PR(undated). "Cultural practices for optimizing maize seed yield and quality in
production fields,"
6 For a list of genetically modified crops awaiting deregulation(commercial approval)by USDA,
see top two tables at http://www.aphis.usda.gov/biotechnology/petitions table pen.ding.shtrnl.
Note that most of these crops are engineered for resistance to one to 3 herbicides each.
7 For a readable overview of some of these new herbicide-resistant crops, see: Kilman, S. (2010).
"Superweed outbreak triggers arms race,"Wall Street Journal,June 4,2010.
2
the Vietnam War. Many scientific studies link exposure to 2,4-D to non-Hodgkin's lymphoma, a
terrible cancer of the immune system that kills 30% of those afflicted with it. Other studies have
found 2,4-D exposure linked to low sperm counts in workers and reproductive impacts in
experimental animals. 2,4-D is contaminated with highly toxic dioxins, and is banned in Norway
and Sweden.8
BASF is experimenting with corn and canola resistant to imidazolinone herbicides,which are
strongly linked to bladder cancer.9
Pesticide drift10
Any pesticide can drift beyond the field of application to affect neighboring or distant fields,
people and wild plants and animals. Some pesticides are more drift-prone than others. Pesticide
drift is known to happen even when all regulations are followed.
Pesticide drift comes in several forms. First,pesticides often drift as they are being applied,
especially when winds exceed 10 mph, which is often the case in Hawai'i. While the application
of some pesticides is prohibited when it is windy, it is widely known that such rules are often not
followed, leading to unintended exposures. Pesticides can also volatilize and drift many days to
months after application, a phenomenon known as vapor drift, and can also be carried in the
wind as pesticide-laden dust. According to a 2001 report by the U.S. Geological Survey, which
has conducted extensive investigations into pesticidal pollution for many years:
"After they are applied, many pesticides volatilize into the lower atmosphere, a process that can
continue for days,weeks, or months after the application, depending on the compound. In
addition, pesticides can become airborne attached to wind-blown dust."
Hazards from pesticide drift
A growing number of epidemiological studies link pesticide drift to specific diseases, including
autism,Parkinson's disease, and leukemia." With high winds and/or hot temperatures,
pesticides can drift for miles, even dozens of miles.
Monitoring in California has found airborne pesticide levels that routinely exceed acceptable
health standards, in some cases miles from the site of application. One example is the nerve
toxin chlorpyrifos, a restricted use insecticide that has been strongly linked to attention deficit
8 See CFS comments to EPA regarding new use registrations for 2,4-D on 2,4-D-resistant corn
and soybeans, in supporting materials as"CFS 2,4-D Resistant Crop Comments to EPA"
9 Koutros, S et al (2009). "Heterocyclic aromatic amine pesticide use and human cancer risk:
Results from the U.S. Agricultural Health Study,"Int. J. Cancer 124: 1206-1212.
10 For this section, see: Owens, K and Feldman J(2004). "Getting the drift on chemical trespass:
Pesticide drift hits homes, schools, and other sensitive sites throughout communities,"Pesticides
and You,Vol. 24,No. 2: 16-21.
11 For this section,unless otherwise noted, see: Goldman P,Brimmer JK and Ruiz V. (2009).
"Pesticides in the Air—Kids at Risk: Petition to EPA to protect children from pesticide drift,"
Earth Justice and Farmworker Justice, October 2009.
3
hyperactivity disorder in children12 as well as Parkinson's disease. Chlorpyrifos is one of the
restricted use pesticides used on Kaua'i, but we have no idea where it is applied,how frequently,
or in what quantities.
Schoolchildren in western Kaua'i have been sickened due to pesticide drift from nearby GE seed
fields on at least three separate occasions. In 1993, a groundbreaking National Academy of
Sciences report established beyond doubt that kids are much more sensitive to health harms from
pesticides than adults (cited in Goldman et al 2009).
Hazards from pesticides in water
Another restricted use pesticide used in Hawai'i is atrazine, which is an extremely potent
hormone-disrupting compound that causes feminization of male frogs—a process described as
chemical castration—at extremely low,parts per billion, levels.13 It has also been linked to
breast and prostate cancer and low sperm counts.14 Atrazine has been banned in the European
Union based on these hazards. Atrazine is highly water soluble and is frequently detected at low
levels in ground and surface waters. Studies in Australia have linked atrazine runoff to coral reef
damage.
Cannot Rely on EPA
We would all like to believe that EPA protects us from pesticide harms. But sadly, this is not the
case. I'll briefly describe just two of many deficiencies in EPA regulations.
First, EPA regularly approves hazardous pesticides because by law it must weigh a pesticide's
supposed or claimed benefits against the health and environmental harms it causes. For instance,
EPA knows that chlorpyrifos is toxic, which explains why it has banned residential uses of the
insecticide,15 yet it's still the most heavily used insecticide in US agriculture.16 This sets up an
unfortunate double standard. Urban and suburban kids are protected from the health harms of
chlorpyrifos, but rural kids are not.'7 In Hawai'i,however, GE crop field tests often occur so
close to populated areas that people in both rural areas and towns are likely being exposed.
Second, EPA has failed to regulate pesticides to prevent harms from drift. EPA has struggled for
over 30 years with drift,yet still does not account for drift exposure in its safety assessments of
12 Bouchard MF et al (2010). "Attention-deficit/hyperactivity disorder and urinary metabolites
of organophosphate pesticides,"Pediatrics 125(6): e1270-el277.
13 Hayes, TB et al (2011). "Demasculinization and feminization of male gonads by atrazine:
consistent effects across vertebrate classes,"J. of Steroid Biochemistry and Molecular Biology
127: 64-73.
14 See 2006 interview of Dr. Hayes on Living on Earth, in supporting materials as Hayes
Interview 2006.
15 See Goldman et a12009, op. cit.
16 EPA(2011). "Pesticides Industry Sales and Usage: 2006 and 2007 Market Estimates,"EPA,
2011, see Table 3.6,note that chlorpyrifos is ranked l4 'among pesticides,but is the top-ranked
insecticide.
'7 See Goldman et al 2009, op. cit.
4
pesticides, and does not have enforceable drift-prevention rules on pesticide labels.l8 EPA
doesn't even include vapor drift or movement of pesticide-laden dust in its definition of pesticide
drift.19
Actions Taken By Other States and Municipalities in View of Deficient EPA Regulation
Other states and counties have recognized these deficiencies in EPA regulation, and established
their own rules in response.
For instance, seven states have established buffer zone requirements for pesticide applications to
protect people, especially kids, from pesticide drift. Eight states have imposed notification
requirements.20
Cities and counties have enacted pesticide regulations as well. For instance, counties in
California and Michigan impose restrictions on use of highly drift prone herbicides like 2,4-D to
protect nearby crops from drift damage. Of course, I think everyone would agree that protecting
human beings is more important than protecting crops.
Conclusion
By prohibiting the dangerous practice of growing GM seed crops, especially GM corn, and the
heavy use of toxic pesticides associated with it, Bill 79 would offer the citizens of Hawai'i
County protection against the health and environmental harms of pesticide use that citizens of the
other Islands are experiencing.
Sincerely,
Bill Freese, Science Policy Analyst, for
Center for Food Safety
18 Goldman et al 2009, op. cit.
19 Owens and Feldman(2004), op. cit., see footnote 7 and associated text.
20 Owens and Feldman(2004), op. cit.,Tables 1 and 2.
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