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HomeMy WebLinkAboutCOM 0489.584 2018-2020 'ese r Pl n 100 Association. November 18, 2019 The Honorable Aaron Chung Chairman, County Council, County of Hawai'i Hawai'i County Building 25 Aupuni Street Hilo, HI 96720 cot�n��lte�t�n�on�rrt l���v��ii�,ot�nt�.s�ot� Re: Bill 101 -Herbicide Ban for County of Hawaii (2°a Draft) Dear Chairman Chung and Council Members: On behalf of the Western Plant Health Association(WPHA), I'm writing in opposition to Bill 101 which would amend Section 1, Chapter 14, Hawai'i County Code 1983 (2016 Edition, as Amended)to prohibit the use of herbicides on all County owned or maintained properties and waterways. WPHA represents the interests of crop protection and fertilizer manufacturers, biotechnology providers, and agricultural retailers in Hawaii, California, and Arizona. WPHA thanks the author for her interest in assuring the safety of the public and environment. While we appreciate the amendments to the bill, which will provide a longer phaseout of products identified in the bill, we believe that the bill is still fundamentally flawed because of its pre-determined outcome. The bill presumes that the County can within four years move to the identified alternative practices and still meet its obligation to its workers to provide a safe work environment. However, most of the alternative weed control mechanisms are higher risk practices. Alternative pest control techniques, such as hand labor, mechanical removals or animal grazing pose heightened safety risks to public servants, so we continue to be concerned that this bill will result in the public and county workers being placed at far greater safety risks. WPHA believes that Bill 101 will result in dramatic cost increases to the County. Studies have been conducted which estimate that the cost of using alternative weed control techniques or non- registered/exempt pesticide products can double the cost of weed and insect control to municipalities and roadside maintenance departments. A report issued by the City of Encinitas, a seaside community in California with a population of approximately 70,000 estimated that "the conversion to a non-chemical program would cost as much as 80% to 100% more than the city's current expenditures. This finding was reported after Comm. Ito 'T Ref. o:Vt Ref. oto NOV 2 0 2019 a thorough examination by Mark Hosford,Public Works Deputy Director, and Jason La Riva,Park and Beach Superintendent. This was due to two main reasons: 1. The use of non-chemical measures in controlling some pests is not as effective as chemical measures, and 2. In order to achieve the same effectiveness, the frequency of application of non-chemical measures usually occurs more often. We believe the more appropriate path forward is for the County to continue its efforts to expand its utilization of Integrated Pesticide Management, which is reducing reliance on chemical uses of herbicides while continuing to assure public and environmental safety. The argument that legally registered pesticides are unsafe is a misstatement. Before any product can be registered for sale and use in the United States, it must be approved by the U.S. Environmental Protection Agency (US-EPA). The US-EPA is the head scientific body in the United States that sets strict scientific policies and guidelines for pesticide products to ensure they can be used safely and effectively. During the registration process these products undergo hundreds of comprehensive scientific studies. Bill 101 appears to be driven by an interest to eliminate the use of glyphosate products. The author of Bill 101 has expressed significant concerns about the safety of glyphosate,the leading herbicide used around the world. While we appreciate that recent information being distributed to public officials would be of concern to anyone whose goal is to protect the public health, the information being distributed is incorrect. To help clarify the facts surrounding the safety of glyphosate, WPHA is providing the attached information. The facts demonstrate that the overwhelming weight of evidence developed from worldwide scientific studies support the safety of glyphosate. WPHA appreciates the opportunity to provide comments on this issue, and sincerely hopes that after consideration of our concerns and information we have provided on the safety of all registered herbicides and glyphosates specifically, the committee will recognize that Bill 101 is unnecessary and vote no. WPHA thanks the committee for its consideration of our comments and we are available for additional information regarding this issue at i-eii.eep('r�)hecitillapl,,i7i.t,�,()r-. Sincerely, Renee Pinel President/CEO Westetz T'lar t Health Association Background on WHO,IARC and Glyphosate Classification I. Glyphosate and Its Global Uses Glyphosate was developed in 1974 and has been in continual use since that time. Over the years, various formulations have been developed and these formulations are widely used in more than 160 countries around the world by farmers, municipalities, and homeowners. • Landowners or municipalities can also use the herbicide to eliminate weeds, for example, around fences, railways, public rights of way, or near utility lines. • Homeowners use glyphosate lawn and garden herbicides to kill weeds in, for example, sidewalks, driveways, or gardens. • Farmers use glyphosate-based herbicides as one option to control weeds on their cropland. Glyphosate has been safely used for several decades. National regulatory authorities and independent experts around the world agree that there is no evidence that glyphosate cause's cancer, even at high dosage levels. Numerous studies from the last forty years assessing the carcinogenicity and genotoxicity of glyphosate support this conclusion. 7 II. IARC Classification of Glyphosate as a Group-2A Probable Carcinogen The first time glyphosate was reviewed by the International Agency for Research on Cancer (IARC), a specialized agency of WHO, was in March 2015. IARC evaluates and disseminates information on cancer risks through publications, meetings, courses, and fellowships. This was the first time since 1991 that IARC reviewed any pesticide. On the basis of its initial review, IARC assigned a classification of"probable human carcinogen" (Group 2A) to glyphosate—a category that also includes workers in barber shops and shift work. IARC is one of four programs within the World Health Organization ()vVHO) that has reviewed glyphosate, and the only one to have made such a finding. III. Limitations of the IARC Classification The 2A classification of"probable carcinogen" does not mean that glyphosate causes cancer in humans. As such, the classification by IARC is confusing and can cause substantial concern among the millions of glyphosate users globally. There are several additional limitations in IARC's classification: • Unlike regulatory reviews that review all available data over an extended period of time, IARC makes its conclusion on a limited data review during a meeting lasting one week. • The classification was not premised on any new or original research but rather on a survey of a limited number of publicly available articles. • IARC's methodology is based on a hazard analysis as opposed to a risk assessment and concomitant classification used by national regulatory bodies. o A cancer hazard refers to an agent that can cause cancer under limited circumstances. o A cancer risk is an assessment or estimate of carcinogenic effects caused by exposure to an agent identified as a potential or probable cancer hazard. o IARC does not consider risk or likelihood of harm to humans. As such, an agent may be classified as a cancer hazard by IARC even though the cancer risk is low at current human exposures. • IARC performs hazard classification independently of chemical mode of action and without exposure assessment whereas the WHO/FAO Joint Meeting on Pesticide Residues—which assesses the risk of pesticide residues in food and has repeatedly concluded glyphosate residues do not cause cancer—conducts risk assessment at exposure level in food commodities. • As acknowledged by IARC, there is "limited evidence in humans for the carcinogenicity of glyphosate."' In fact, by IARCs own classification scheme, an agent may be classified in the "probable human carcinogen" category even when there is inadequate evidence of carcinogenicity in humans but sufficient evidence of carcinogenicity in experimental animals. IV. International Responses and Studies to Date A number of international and national regulatory bodies evaluate glyphosate as part of mandated periodic reviews, and several have recently released preliminary conclusions finding glyphosate use to be safe. • EU/German Federal Institute for Risk Assessment. The European Union is currently conducting an assessment of glyphosate. Germany—as the Rapporteur Member State for the European Union(EU}recentlyconcluded in its 2015 health risk assessment report to the EU that the available data does not show carcinogenic or mutagenic properties of glyphosate nor does it show that glyphosate is toxic to fertility, reproduction or embryonal/fetal development in laboratory animals. • WHO/FAO Joint Meeting on Pesticide Residues (JMPR). The WHO/FAO Joint Meeting on Pesticide Residues concluded in 2011 that the long-term and short-term Katherine Guyton, Dana Loomis, Yann Grosse et al, Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate, Lancet Oncology (Mar. 20, 2015), available at j�q././dx.doi.org=/10.I 016/S 1470-"045(15)70134-8, ----------—-------------- .�. intakes of glyphosate residues are unlikely to present a public health concern or risk to consumers. This conclusion supported its earlier findings from 2006 and 2003 that glyphosate was not toxic. Public media reports as well as member state comments at the recent Codex Committee on Pesticide Residues meeting indicate a lack of clarity stemming from the IARC classification of glyphosate. As such, the recently announced WHO expert task force to determine whether there is a need to update JMPR's prior assessments may help provide some clarity to the situation. • Canadian Pest Management Regulatory Agency (PMRA). In April 2015, PMRA published its Proposed Re-evaluation Decision document, noting that the overall weight of evidence indicates that glyphosate is unlikely to pose a human cancer risk and that it is finalizing its review. This supports PMRA's prior findings. • Australian Pesticides and Veterinary Medicines Authority. In 2013, Australian regulatory authority concluded that the weight and strength of evidence shows that glyphosate is not genotoxic, carcinogenic, or neurotoxic. • Argentine Interdisciplinary Scientific Council. In 2009, the Argentinian regulatory authority determined that on the basis of epidemiological studies reviewed, there was no correlation between exposure to glyphosate and cancer incidence nor adverse effects on reproduction. • U.S. Environmental Protection Agency. The EPA has previously assigned glyphosate the lowest cancer classification- Group E—evidence of non-carcinogenicity for humans - indicating glyphosate does not pose a cancer risk to humans. The agency recently issued a desk statement in April 2015 recognizing that their prior assessments (from as recently as last year) concluded that glyphosate does not cause cancer and noting that the Agency will continue their work to finalize the current regulatory assessment of glyphosate.