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HomeMy WebLinkAboutCOM 0489.460 2018-2020 y '` VOTING MEMBERS DAVID Y.IGE mSUZANNE CASE GOVERNOR OF HAWAII ",- �� DEPARTMENT OF LAND&NATURAL '� - ,: RESOURCES DOUG CHIN 2 f-- ¢„J'€ LIEUTENANT GOVERNOR �"8 HISC�. �' PHYLLIS RESOURCES 4'1 U� HAWAII DEPARTMENT OF AGRICULTURE 'IP•. r-,,, ,, O E'q -..i. , � �` 1' ', KEITH KAWAOKA D.Env. p�' ;:5 1:1 x e ' DEPARTMENT OF HEALTH f g, S`P,E,[It., NICHOLAS COMERFORD,Ph,D. r Cli i ' UNIVERSITY OF HAWAII t �E ---ir ' MARY ALICE EVANS '` HAWAII INVASIVE SPECIES COUNCIL OFFICE OF PLANNING.DEPARTMENT OF y A BUSINESS,ECONOMIC DEVELOPMENT& e * v 1151 PUNCHBOWL ST,#325 TOURISM m�, ° HONOLULU,HAWAII 96813 DAVID RODRIGUEZ DEPARTMENT OF TRANSPORTATION Testimony of the Hawaii Invasive Species Council Before the Hawaii County Council C.7.1"--- Wednesday, November 20, 2019 --:, 9:00 AM r _ West Hawaii Civic Center, Kailua-Kona, Hawaii --(-.c--, BILL 101, DRAFT 2F.-...:-?* :: -1. AN ORDINANCE AMENDING CHAPTER 14, HAWAII COUNTY CODE 1983 (2016 IN) EDITION, AS AMENDED), BY ADDING A NEW ARTICLE 24, RELATING TO HERBICIDE' USE Bill 101, Draft 2, proposes to amend Chapter 14 of the Hawaii County Code 1983 (2016 Edition, as amended) by adding a new Article 24, "Relating to Herbicide Use." The Hawaii Invasive Species Council (HISC) offers the following comments. The HISC is comprised of the directors or designees of six state agencies and was established to provide interagency coordination on invasive species policy and funding. Hawaii is a global hotspot for species invasions, and invasive species cost our state hundreds of millions, if not billions, of dollars each year in damages to natural resources, agriculture, human health, and our economy. Protecting Hawaii from the impacts of invasive species requires a broad toolbox of mitigation strategies, including manual, chemical, and biological control tools. In January 2019 the HISC adopted Resolution 19-1, "Supporting the.Use Of Best- Available Science In Regulation Of Herbicides And Recognizing the Utility Of Glyphosate As A Tool For Invasive Species Control." This resolution supports the findings of the HISC Research and Technology Working Group, which produced a position paper entitled "Understanding the Value of Glyphosate in Protecting Hawaii." Both documents are attached to this testimony for reference. In summary, the HISC supports the use of scientific evidence, including reliance on expertise at the Hawaii Department of Agriculture (HDOA) and the US Environmental Protection Agency (EPA), as the basis for discussions regarding the regulation of herbicides and other chemical tools in Hawaii. The HISC recognizes that chemical tools that have been vetted by the EPA and HDOA for use in Hawaii can be important components of an integrated management strategy for the mitigation-of invasive species impacts. The HISC is a funder and partner of the Big Island Invasive Species Committee (BIISC), a project of the University of Hawaii's Pacific Cooperative Studies Unit. Since Fiscal Li1.im comm. tie, Ref.To: G[council Ref.Date NOV 2 0 2019..,. Year 2005 the HISC has invested roughly $7M in BIISC's capacity to conduct targeted. early detection, control, and outreach work relating to invasive plants, animals, and fungi on Hawaii Island. The HISC is interested in ensuring that the efforts of BIISC to control or eradicate invasive plants, some of which are on County lands, can continue in a cost-effective manner. Draft 2 of this measure includes an exemption allowing for officers or employees of the County to apply herbicides directly into the trunk of cut stump of a targeted invasive species using incision point injection or cut stump application. This method can be very useful for administering small, effective doses of herbicide in certain use cases, such as the treatment of large albizia trees. There are other invasive plant species that may not be effectively treated using this method due to their growth habit or the type of herbicide applications to which they are susceptible, including BIISC targets like smokebush (Buddleja madagascariensis), Molucca raspberry (Rubus sieboldii), pampas grass (Cortaderia jubata), cotoneaster (Cotoneaster pannosus), rubbervine (Cryptostegia madagascariensis), poison devil's pepper (Rauvolfia vomitoria), gorse (Ulex europaeus), and others. The HISC suggests amending this language to provide an exemption for officers, employees, or contractors of the County with respect to a direct application of one or more prohibited herbicides directly to a targeted invasive species, provided that application is consistent with EPA and HDOA guidance. The HISC appreciates the opportunity to provide comments on this measure. Attachment 1: HISC Resolution 19-1, Supporting the Use Of Best-Available Science In Regulation Of Herbicides And Recognizing the Utility Of Glyphosate As A Tool For Invasive Species Control Attachment 2: Understanding the Value of Glyphosate in Protecting Hawai`i (A position paper of the HISC Research and Technology Working Group) Attachment 1 VOTING MEMBERS DAVID V.IGESUZANNE CASE GOVERNOR OF HAWAII 11$', DEPARTMENT OF LAND R NATURAL RESOURCES JOSH GREEN �*= 1-10501"z': DENISE ALBANO LIEUTENANT GOVERNOR a: p �_ �i.� � HAWAII DEP,'Ui.Jb4E:IT OF AGRICULTURE •onridp— K.EITII KAWAOKA D Env. /� DEPARTMENT OF HEALTH mt&Sgy;NIA a� ,,,,y '` NICHOLAS CONIERFORD,Ph,D. '" % UNIVERSITY OF.HAWAll °a I LEO ASUNCION ' a HAWAII SPECIES COTTNCIL OFFICE OF PLANNING,DEPARTMENT OF ,ji i BUSINESS,ECONOMIC DEVELOPMENT ,,; 1151 PUNCHBOWL ST,#325 TOURISM "' ZZs HONOLULU,HAWAII .96813 DAVID RODRIGUEZ DEPARTMENT OF TRANSPORTATION RESOLUTION 19-1 SUPPORTING THE USE OF BEST AVAILABLE SCIENCE IN REGULATION OF HERBICIDES AND RECOGNIZING THE UTILITY OF GLYPHOSATE AS A TOOL FOR. INVASIVE SPECIES CONTROL WHEREAS glyphosate is the active ingredient in herbicide formulations registered in the State of Hawaii; and WHEREAS glyphosate is used to control invasive plant species that threaten native plant habitat, alter ecosystem function, decrease agricultural production, and increase risk:of wildfire; and WHEREAS the International Agency for Research on Cancer (IARC) of the World Health Organization in 2015 identified limited evidence in humans for the carcinogenicity of glyphosate in humans and classified glyphosate as "probably carcinogenic to humans," irrespective of dose; and W.IIEREAS the US Environmental Protection Agency found in the 2017 Summary Review of Recent Analysis of Glyphosate Use and Cancer Incidence in the Agricultural Health Study no statistically significant relationship between exposure to glyphosate when used according to label and cancer incidence in humans; and WHEREAS the US Environmental Protection Agency and the Hawaii Department of Agriculture are responsible for regulation of pesticides that are used in Hawaii; and WHEREAS, Chapter 194, Hawaii Revised Statutes, authorizes the Hawaii Invasive Species Council to advise and coordinate invasive species-related efforts with and betweenstate,federal, international,and private programs, and to coordinate the State's position with regard to invasive species; and RECOGNIZING that there has been considerable public discourse, including policy discussions, over the use of chemical control tools; and RECOGNIZING efforts to mitigate the impacts of invasive species in Hawaii are best served by having a broad array of pest management strategies that include appropriate mechanical, chemical, and biological control tools; now, therefore, BE IT RESOLVED that the Hawaii Invasive Species Council recognizes the utility of glyphosate,when used according to label requirements, as a tool usedto control invasive plants in Hawaii for the protection of native ecosystems, agricultural production, and wildfire mitigation; and BE IT FURTHER RESOLVED that the Hawaii Invasive Species Council supports the use'©f best available science, including reliance on expertise at the Hawaii Department of Agriculture, as the basis for discussions regarding the regulation of herbicides and other chemical tools in Hawaii; and BE IT FURTHER RESOLVED that certified copies of this Resolution be transmitted to the Governor of Hawaii,the President of the State Senate,the Speaker of the State House of Representatives, and to the directors or chairpersons of each HISC agency. Adopted by the Hawaii Invasive Species Council on the following date: January 29, 2019 ` ' :"L�� 1 'e L Suzle D. Case, Departn1 T nt of Land& ►,.tural (D_eni§�✓¢ (49,'d Albano, Department of Agriculture Reso res "�� Keith Kawaoka,D. Env., Dep.Iwent of Health D id Ro•; guez, Department of Transportation .._.„.0,14,4"4„ii Leo Asuncion, Office of Planning, Department Nicholas Comerfo1d, Ph.D., University of of Business, Economic onornic. Development, and Hawaii Tourism Attachment 2 Understanding the Value of could not be ruled out. A chart listing other substances that are probably carcinogenic to humans, Glypho sate in Protecting Hawaii such as very hot beverages and wood fires, is below. A position presented by the Hawai`i Invasive Species In 2017, the US Environmental Protection Agency Council (HISC) Research and Technology Working evaluated the cancer risk of glyphosate to humans in Group the Draft Human Health Risk Assessment in Support of Registration Review. The EPA determined that January 2019 glyphosate was "not likely to be carcinogenic to humans" and supports continuation of current approved use patterns. So, how could we have The Position apparently conflicting positions from respected Glyphosate is the active ingredient in many herbicide scientific agencies? formulations registered in the State of Hawai`i to control non-native weed species in many different IARC Evaluations of Selected Products and types of environments. Glyphosate-based herbicides Chemicals are critical weed management tools that help Processed red meat maintain profitability in local agriculture, turf and (consumption) inogcrnic landscape industries, prevent degradation of our Alcoholic beverages to h lmans natural environments, mitigate wildfires through Tobacco creation of firebreaks and control of fire-prone Very hot beverages : Prribably invasive grasses, and reduce disease vector habitats. Red meat(consumption), With several decades of regulated use, this pesticide ' Glyphosate .. cat cine enic to technology has proven to be one of the most cost- Biomass'fuel (wood fire) humcrrr. effective options in weed control with no historical Aloe vera whole leaf extract reports of environmental or human health impacts in Gingko biloba Hawai`i. The new Hawai`i Interagency Biosecurity Goldenseal root powder Plan (HIBP) provides an ambitious mission toKava extract caremog`mmc to protect against new and existing biological threats to Radio frequencyhu�?2ans the local economy, environment and health of our Electromagnetic � fields island state. Pesticides, including glyphosate, are integral technology options for rapid, effective Hazard vs. Risk interventions against these threats. We recognize Hazard is defined as a potential source of harm or growing interest by some stakeholders to limit or in adverse health effect on a person, while risk is the some cases ban the use of chemical control options. likelihood of harm or adverse health effects due to Efforts to restrict or ban these tools, however, could exposure of the hazard. The IARC Monographs compromise the feasibility of participating agencies Program evaluates cancer hazards distinct from for implementing a well-developed plan to protect actual risk. This means that the IARC classified Hawai`i. We recommend a careful consideration of glyphosate as a hazard even though it may be risk and benefits in any future discussions about unlikely to cause cancer with current known uses and policies relating to glyphosate use, and endorse the exposure rates.The EPA conducts risk assessment of expertise within our state and federal agencies hazard exposures under normal or adverse use responsible for pesticide regulation. patterns. Therefore, the IARC determination of hazard and EPA determination of risk may not be The Controversy conflicting. In 2015, the International Agency for Research on Cancer (IARC) published an evaluation of Risk Management glyphosate categorizing this chemical as "probably Risk management is the process of identification, carcinogenic." The IARC uses this classification evaluation, and prioritization of risks, along with the when a positive association has been observed adoption of corresponding measures to minimize the between exposure to the agent and cancer but other potential impact due to hazard exposure. Pesticide explanations for the observations, such as chance, risk in Hawai`i is managed through the registration and regulation processes administered by the Us Tolearn.about.the differences between EPA in coordination with the Pesticide Branch of thehazards and risks,of glyphosate go to: Hawai`i Department of Agriculture. Each registered pesticide product has a set of vetted guidelines International Agency for Research on Cancer, explicitly stating how, when and where a pesticide 2017. Some organophosphate insecticides and can be applied, as well as how much and by whom. herbicide : tetrachlorvinphos, parathion,', The product label also describes any protective malathion, diazinon and glyphosate FARC equipment or training required for the applicator. WorkingGroup Lyon: IARC Monogr Eval These specified conditions are determined by Carcuiog Risk C heiY Hum, 112,pi.9-31 established scientific protocols that aim to minimize 17ttps Ilinonog aphs.larc fr/vp the risk factors to people and the environment. In content/uploads/2018/071rndno1 12 pdf addition, the College of Tropical Agriculture and Human Resources (CTAHR) offers the "Pesticide US Environmental Protection Agency.2017. Risk Reduction Education" short course for Draft Humaff Health and Ecolog cal Risk educating and training professional applicators on Assessments for.Glyphosate proper pesticide stewardship.Any use of a registered https://www.epa.gov/ingredients-used- pesticide that is inconsistent with the label pesticide-ptoducts/drat human-health-and- instructions is illegal and punishable by law. ecological-risk-asses�,nlents glvpllosate Alternate positions that support the prohibition of To learn about the llawai`i Interagency glyphosate potentially undermine the authority and Biosecurity Plan2017-2027 go to regulatory protocols established by these federal and state agencies. A ban on glyphosate would also Hawai`i Department'of Agriculture: remove currently irreplaceable tools for combatting hitt�://hdoa.ha 'aii. =ov!hlog/mam'nrl 7 invasive species, creating extreme challenges for 02biosecur-itvllan/._z local, state and federal agencies charged with protecting the unique,fragile ecosystems of Hawaii. Hawai` Invasive Species Council: Prohibiting effective tools could potentially result in littp://dlnr.havvaii.gov/Itisc/plans/hibp/ civ/hire/plans/l sbpl the irreversible debilitation of our food, water, residential landscapes, and rare native plants and This position paper was prepared by the staff and animals, all of which are heavily impacted by stakeholders participating in the HISC Research invasive species. Prohibition of this tool could also and Technology Working Group and does not in result in increased costs for physical control of and of itself reflect a position of the Council. invasive plants in forests and urban environments. Pesticides, including herbicides, are technologies that have greatly benefitted from public and scientific scrutiny over the decades since their introduction. Today's pesticide safety standards and use guidelines are a direct result of this scrutiny and help ensure that the risks associated with exposure are minimized. When used according to label instructions, in concert with established integrated pest management practices, herbicides suchas glyphosate are an invaluable tool in managing invasive plants.