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Home My WebLink AboutCOM 0489.617 2018-2020 Board of Directors November 20, 2019 2018 - 2020 West Hawaii Civic Center 74- 5044 Ane Keohokalole Highway, Building A President Kailua-Kona, Hawaii Joshua Uyehara Re: In Opposition to Bill 101 Vice-President Warren Mayberry Chair Chung and members of the Council: +. 0 Secretary Thank you for allowing the Hawaii Crop Improvement Association the opportunity to Dawn Bicoy provide comments in opposition to Bill 101 that amends Chapter 14, Hawaii County Code 1983, by adding a new article 24, relating to herbicide use. Treasurer Laurie Yoshida We understand the County and community interest regarding herbicide use and embrace the opportunity to engage in discussions to promote transparency and education. Directors-at-Large However, this bill lays the framework for undue burden on County agencies without Alan Takemoto substantive data necessitating the question. Additionally, it promotes misleading Mark Stoutemyer information while circumventing the appropriate regulatory authorities perpetuating a Leslie Campanian() dangerous lawmaking precedent. Dan Clegg Joshua Uyehara The U.S. Environmental Protection Agency (EPA) evaluates and registers herbicides Warren Mayberry against a standard of reasonable certainty that the use would cause no harm to human health or the environment. To make this determination, the EPA considers how much President Emeritus product residue is contributed to daily intake for users and then combines it with the Alan Takemoto amount of residue consumed by other routes of exposure. These routes include food and drinking water and residues from herbicide use in residential and non-occupational environments. Relevant routes of exposure are analyzed within an aggregate exposure assessment, these include the oral, dermal (absorption), and inhalation routes of exposure. Once calculated, the total consumption of residues is compared to the acceptable daily intake (ADI). The ADI for each product is set by toxicity studies that look at different effects, such as acute toxicity, chronic effects, sub-chronic effects, carcinogenicity, developmental and reproductive abnormalities, and mutagenicity. The ADI is then set at a minimum of 100 times lower than any dose level that presented harmful toxicity, ensuring the safety of the product. Speaking specifically to Glyphosate, as referenced in Section 14-141 of this bill, the EPA, which first assessed glyphosate in the 1980s and has reviewed it several times since, says it has "low toxicity for humans.". The European Food Safety Authority and the European Chemicals Agency, which advise the 28 members of the European Union, have also assessed glyphosate within the past five years and ruled it safe for use when Comm. No //��'��-tp' / Ref. To: P1010161 „,,\,w, ,,:s,„:‘,,As\N-,,,,,IAV-M , \,,\'‘k\ Z\A\ ' ''''' - •‘‘ \' '' ' ‘-'\ \--L"''''''—Y-'‘'"'\\ \'‘ l A �; �� z� ems ��ia , w applied appropriately. In 2017, the U.S. Agricultural Health Study (AHS), which followed more than 50,000 licensed pesticide applicators, farm workers, and their spouses for more than 20 years, found no connection between glyphosate-based herbicides and cancer. Additionally, the AHS focused on the real-world use of formulated products and not just glyphosate. The 2015 World Health Organization International Agency for Research on Cancer (IARC) assessment that reported glyphosate as a probable human carcinogen is an outlier study that is often misinterpreted. According to IARC, Glyphosate is listed under carcinogenic classification 2A, along with red meat and very hot beverages. A year after IARC issued its evaluation, a joint United Nations and World Health Organization panel concluded that glyphosate was "unlikely to pose a carcinogenic risk to humans.". The referenced IARC opinion is inconsistent with 40 years of scientific research on glyphosate and the conclusions of the U.S. EPA, the U.S. National Institutes of Health, the European Food Safety Authority, and regulators around the world. To address the concerns posed specifically regarding Dicamba, as referenced in the schedule under Section 14-143 of the proposed Bill 101, the EPA approved the use of specific dicamba products for in-crop application on dicamba-tolerant cotton and soybeans in November 2016. As part of the registration, these approved products are classified as Restricted Use Pesticides and annual training is required before a person can legally apply or purchase the product. Furthermore, these approved products are available for retail sale to and use by Certified Applicators. In addition, approved product labels provide instructions with specific application requirements that will help keep dicamba on its intended targets during application(e.g. nozzle type, wind speed, boom height, in- field buffers, application speed, etc.). Following label requirements helps to ensure on- target applications providing a safe, effective, and many times necessary tool for pest managers. Most pest managers use some form of Integrated Pest Management (IPM), which includes using beneficial insects, mechanized assistance, and basic monitoring fields for pests, using pesticides only when necessary to keep pest populations to a minimum. A recent study done by the County of Maui found that a shift from Glyphosate to a product with a similar capacity would result in an increase in spending unfeasible for any version of their proposed budget. Also, the replacement product yielded subpar results. To ban the schedule in Section 14-143 of Bill 101 would not only be unwarranted, but also financially reckless. As in all professions, pest managers need the ability to use the correct tool for each situation. Casting unsubstantiated doubt on the sometimes-necessary use of herbicides could severely impact Hawaii's unique climate by promoting breeding grounds for invasive species and detrimental pests, such as Albezia trees and Little Fire AfN \: \ �— � d s;� V'e't ,:.v off, g t° i, - VA A\\\ \\\\ ‘\',4st‘%\\ \ ‘4 \\kl&\ \\‘ ‘ ‘\\\*\\\\ , ;\ e Ant. Additionally, curtailing the use of herbicides for one user group will have far- reaching negative implications on Hawaii's ecosystem, and affiliated user groups. Consideration of what is appropriate and safe relative to the use of herbicides should be based on science and research. This work is best done by scientists and policymakers in a regulatory framework supported by the appropriate resources, like the EPA and Hawaii Department of Agriculture (HDOA). We all believe that Hawaii's people and the environment that we live in are valuable assets that should be protected. However, any proposed protections must be wisely applied. Herbicides are products that help keep Hawaii's environment and its people safe from invasive species and many harmful pests, both vegetative and otherwise. We strongly urge you to consider the negative impacts and regulatory propriety before voting on this bill. Mahalo for this opportunity to testify. Sincerely, Emmanuel Zibakalam Program Director, Hawaii Crop Improvement Association The Hawaii Crop Improvement Association is a Hawaii-based non-profit organization that promotes modern agriculture to help farmers and communities succeed. 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