Loading...
HomeMy WebLinkAboutCOM 0093.018 1998-2000 Y 1 1/ I 12/23/98 TESTIMONY RE FUNDING FOR THE MARIJUANA ERADICATION PROGRAM BY: RENE SIRACUSA RECEIVED P. O. Box 1520 _ Pahoa, HI 96778 a 124 1 county Counc I have brought with me today the draft of the Supplemental Environmental Impact Statement (SEIS) of April 1998, entitled "Cannabis Eradication in the Contiguous United States and Hawaii ". This study was commissioned by the DEA and prepared by the U.S. Department of Agriculture. If you have not read it, if you have not studied it in detail, then your have not informed yourself sufficiently to vote on this agenda item. Basically, this document is an in -depth look at three (3) herbicides which the DEA wishes to use in the eradication program: Glyphosate (commonly marketed under the brand names of "Roundup" and "Rodeo "), 2,4, -D and Triclopyr. Our local police will probably testify that they do not intend to use herbicides in their eradi- cation efforts. However, they will be under increasing pressure from the DEA to do so, especially if they wish to continue being eligible for these federal funds. And when they succumb to this pressure, they will not have to come back to you for permission to include herbicides. They will "just do it ". It therefore • behooves us all, as intelligent, caring and morally upright persons, to inform ourselves about these chemicals, their usage, their effects on humans and the environment, and then make an informed decision as to whether or not we believe this is the proper way to address the problem. All the information which I will discuss today is drawn from this SEIS. One exception to this has to do with the effects of he bi- cide drift and contamination of water catchment systems. The reason for this is that the SEIS does not discuss this issue at all. The SEIS discusses the effects of all 3 herbicides on water quality in lakes and rivers and aquatic life. There are serious o problems in these cases, as anyone who has ever read the warning label on "Roundup" may be aware. But there is a far cry between a free - running, continually flushing river, stream'or lake, and a stationary water tank, which will tend to concentrate any con- taminants and pass these along to families (adults, children and fetuses). Anyone who has ever stood underneath the rotors of a c hovering helicopter is aware.of how much wind is generated. Even J � a small amount of herbicide applied through a smalyozzle can be whipped around as a mist over a fairly wide area. LPlants being treated in this way on a vacant lot may very well enter into the • catchment systems of innocent neighbors, and coat their lawns, fruit trees and gardens. Indeed, we have heard complaints of this nature from time to time. "Glyphosate is strongly absorbed to soil and does not • readily move out of the soil once absorbed. In some cases, however, it•' • has been reported to take up to 174 days [almost 6 months] to break down half the original glyphosate." Thus, a vegetable garden and its produce would be unusable by a family for up to 6 months,,'if, 1 0 0 'tom - hiv n G EttLesajd F0.L it 'em ai{3 O S I 'E6 rox woo o o wind direction from an eradication resulted in overspray. Likewise the family chickens, pecking in the upper soil layers, could become contaminated and become unusable for meat or eggs. "Glyphosate has been shown to cause irritation to the gastro- intestinal tract and lungs, as demonstrated in "in vivo" toxicity studies as well as human poisoning incidents "(p. 78). Among the impurities and metabolites of the Glyphosate formu- lations are AMPA (Aminomethyl - phosphate), N- nitrosoglyphosate and 1,4- Dioxane. Relatively little is known about the biological activity of AMPA. Shall we use our population as guinea pigs? The other two mentioned compounds have a carcinogenic potential, but the risk is "difficult to quantify" (p.79). According to the existing guidelines, the Office of Drinking Water of the USEPA has proposed a 10 -day health advisory for glyphosate of 17.5 mg /L and a long -term health advisory of 1 mg /L. They consider this to be "Using a very conservative approach for quantitatively charac- terizing risk" (p.87). The second herbicide, 2,4, -D can be used in either of two forms: as an amine salt or an ester of 2,4, -D. The amine salts dissolve more readily in water than the isoctyl ester form. So they are of particular concern in catchment systems, especially since they are odorless. Half of the 2,4, -D is removed from the water within 50 days (Rubin 1982). 2,4,- dichlorophenol, as well as other substances, is produced during breakdown (Nesbitt and Watson, 1980, and Eder and Weber, 1980). This appears to be a very long time for breakdown of contamination in open catchment systems. for drinking water caused by accidental discharge or overspray. In soils, absorption of 2,4, -D is greatest in acidic soils (Johnson et al, 1995) or soils with large amounts of organic matter. By and large, the soils on the Big Island are both. Reproductive and TQratogenic effects (p. 110): teratology studies on 2,4, -D indicate that malformations are likely to occur only at doses that are fetotoxic (toxic to fetuses) or maternally toxic (Munro et al., 1992). Also, there is evidence that 2,4, -D may adversely affect male reproduction.(p. 110) And a few studies may suggest carcinogenic potential for 2,4, -D (p. 112), Can we afford to take the risk? Is marijuana eradication worth it? The third herbicide discussed in the SEIS is the one that the DEA leans toward the most. It is a close chemical cousin of Agent Orange. Did I see your ears perk up? And well they should. We are all old enough to remember that chemical's use during the Viet Nam War as a defoliant. After the war the US Forest Service used it for a while for weed suppression in the National Forests in Oregon. It wasn't long before there were noted a statistically significant number of major birth defects, especially spina bifida. A class action suit by afflicted parents forced the Forest Service to dis- continue use of Agent Orange and pay a handsome settlement. Never- theless, we can be sure that the parents would have preferred to have normal healthy babies. Imagine both the personal costs and the social costs to our island. Are we prepared to "chance'um "? f TRICLOPYR; ([( 3, 5, 6,- tric 2- pyridinyl)oxy]acetic acid Ref: pp. 129 Table 3 -48 Couuuercial Triclopyr Formulations Formulation Active ingredient Inert ingredients GARLON 3A Triethylamine salt water ethanol emulsifiers surfacants GARLON 4 Butoxyethyl ester kerosene Ref: pp. 129 Triclopyr has NOT been used in the DEA Cannabis eradication para 1 program. Point to If this product is to be used are drift control ponder additives such as Nalco -Trol or Arborchem -38 in- corporated to reduce spray drift. Ref: pp. 130 d. Fate in water para 5 Half of the triclopyr is removed in 4 days. The major breakdown product is oxamic acid (Woodburn et al., 1993). Oxamic Acid: NH COCOOH a high melting cyrstalline acid intermediate between oxalic acid and oxamide. Oxalic Acid: (COOH) or H C 0 is a poisonous strong dicarbaxylic Point to ponder Do we want the breakdown by- product of triclopyr oxalic acid in our water or run off from rain that is a strong poisonous acid. Ref: pp. 136 (a) Surface Water In the DEA program, surface water CAN be contaminated with herbicide if rainfall runs off the treated area carrying herbicides with it. Operating procedures and mitigation measures prohibit direct spray of water resources or when surface runoff (rain) is likely within 48 hours of application. Ref: pp. 138 (b) Groundwater para 1 The majority of the amine (CARLON 3A) will be transported out of the treatment area through movement of groundwater. For the ester ( GARLON 4), an equal amount of the triclopyr will be transported in runoff through movement to groundwater. Ref: pp 143 (2) Aquatic Species para 1 The ester formulation is more toxic to most aquatic organisms than the amine formulation, and the expected enviromrntal concentrations of ester are higher than those of the amine. 1/ '1RICLOPHR; O O Ref: pp. 145 4. Human Health Effects a. Hazard Identification (1) Acute Toxicity and Mechanisms of Action para 1 Although the toxicity of triclopyr is relatively well characterized, the mechanisms of action in mammals are unclear and there are NO clinical or epidemiology studies regarding toxic effects in human s. Triclopyr is a pyridine analogue of 2,4,5 -T. PYRIDINE: A toxic water - soluble flammable liquid heterocy- clic base C HETERROCYCLIC BASE: Rings of atoms of differant elements. Ref: pp. 145 (1) Acte Toxicity para 1 However, many of the potential health effects of 2,4,5 -T [the pyridine analogue to make triclophr] are related to the occurrence of 2,3,7,8 - tetrachlorodibenzo -p- dioxin (TCDD) in 2,4,5 -T. This containminant is NOT likely to be present in the triclophr fomulations. Point to Pounder Do we want the chance of "NOT LIKELY" to be accepted invohring such a hazardous chemical as this? Remember that the pyrindine analogue has the word DIOXIN attached to it. One of the most toxic compounds known to man. Remember the area known as "The Love Canal" incident. Ref: pp146 (2) Role of Inerts para 1 GARLON 3A contains ethanol. para 2 Ethanol's toxicity is exteremely well daracterized in humans, and the hazards of exposure include intoxication, as well as liver cirrhosis and fetal alcohol syndrome (WHO, 1988). Ref: pp 147 GARLON 4 contains kerosene para 1 The material safety data sheet (MSDS) for Garlon 4 specifies that inhalation exposure to Garlon 4 vapors may cause CNS depression attributable to kerosene (DowElanco, 1994). CNS depression is consistent with exposure by inhaling kerosene (ATSDR, 1995) Ref: pp 154 (1) Existing Guidelines para 1 The U.S. EPA's Office of Prevention, Pesticides, and Toxic Substances, which is responsible for the registration of pesticides, has derived a provisional RfD for triclopyr of 0.005 mg /kg /day (U.S.EPA, 1995d). RfD: (Referance dose) Oral dose not likely to be associ- ated with adverse effects over lifetime exsposure in the general population, including sensitive subgroups. O O SUMMARY OF THE FINAL ENVIROMENTAL IMPACT STATEMENT ON THE ERADICATION OF CANNABIS ON FEDERAL LANDS AND INTERMINGLED FORESTS AND RANDELANDS IN THE UNITED STATES (excerts from ) Ref: pp A -3 This EIS also provides the basic background information needed for the "Tiering" of future projects- specific analyses in accordance with the CEQ regulations for implementing NEPA (40 CFR 1502.20). That is, should any future site - specific eradication projects conducted by DEA require an Enviromental assessment or EIS, DEA WILL incorp- orate, by REFERANCE, the findings of this EIS and concen- trate on the site - specific issues. Ref: pp A -10 Disposal Alternative 3 leave cannabis on site (after herbicidal eradication) Notification that the area will be sprayed would be posted at all major points of of access to the area Ref: pp A -11 "Signs posted warning of spray at access points" "At least 100 feet from water for aerial spyraying" "Wind no more than 6 mph" " No rain expected within 2 hours" Ref: pp B -8 Alternative 2 Herbicidal Eradication Under this alternative, DEA would emphasize herbicidal eradication techniques; both directed and broadcast methods would be allowed. State and local authorities WOULD follow all operational procedures shown in Table 2 -1 for herbici- dal methods. It is imperative that any planned Program Review must address the potential impacts and dangers from herbicides used in the marijuana eradication program. It is my firm belief, based on my reading of the SEIS, that the ramifications of this herbicide use are more dire than the marijuana problem. It is like shooting cockroaches with a cannon, while allowing the rats to proliferate. The "rats" in this analogy are the hard drugs. If you vote to fund this program you will be poisoning the people and the aina to eradicate marijuana, while allowing hard drugs to continue to flourish. It is time to prioritize. Please reject the money and let's find kinder gentler ways to resolve our problems. Thank you.