08/04/2024
PUBLIC COMMENTS DUE BY AUG 7!! NO MORE HERBICIDES AND NO DRINE USE IN SIUSLAW NATIONAL FOREST!!
https://cara.fs2c.usda.gov/Public//CommentInput?Project=66006
Artfarm Barn Coast Range Association
STOP the SPRAY at Beaver Creek, Oregon Yes on 21-177
Comment sent in by Carol Van Strum:
The Forest Service asks for “Preliminary public feedback on invasive w**d management options” for preparation of its NEPA and NFMA documents:
Siuslaw Integrated Invasive Species Project.pdf
Draft Proposed Action.pdf
Included in those options is the use of herbicides, disturbing evidence of the Forest Service reverting to thoroughly discredited unlawful behavior banned by the federal courts forty years ago:
Save Our Ecosystems v. Clark:Nos. 83-3908 et al. (9th Cir. January 27, 1984):
9. More and more chemicals are added to our environment daily without adequate information about the long-range effects on health and environment. The EPA, in effect, acknowledges that data on the herbicides in this case are inadequate since the registration is conditional under an exception to the normal registration process. See 7 U.S.C. § 136a(c)(7).
13. EPA's data is partial at best, and suspect at worst, because of the testing scandals. The availability of the data of the chemical companies is also in question. See Monsanto Co. v. EPA, 564 F. Supp. 552 (E.D.Mo.1983), probable jurisdiction noted, U.S. , 104 S. Ct. 230, 78 L. Ed. 2d 224 (1983). Monsanto is opposing the disclosure of EPA health and safety data before the Supreme Court while it argues here that the Forest Service may rely on that data. These two positions appear irreconcilable. Any data relied upon in an EIS must be made available to the public. See California v. Block, 690 F.2d 753, 765 (9th Cir.1982); 40 C.F.R. § 1502.21.
As the Forest Service has little or no independently sourced information on any of its proposed poisons and relies on EPA registration, the Forest Service must at the very least include in its NEPA and NFMA documents the following information :
-- The current EPA registration status of each product with particular emphasis on conditional registration;
-- For any chemical that is conditionally registered, the Forest Service must identify what testing or other data are missing from the registration.
-- Copies of or links to any and all peer-reviewed, independently funded and conducted toxicity, persistence, and environmental studies conducted by or for the U.S. Forest Service of each proposed product, its metabolites and break-down products, its inert ingredients, AND especially any and all toxicity studies of any combination of two or more proposed products;
-- Copies of or links to any and all peer-reviewed toxicity, persistence, and environmental studies conducted by nonindustry-funded research of each proposed product, its metabolites and breakdown products, its inert ingredients, AND especially any and all toxicity studies of the combination of two or more proposed products;
– Copies of or links to any studies, analyses, or reference to the presence of any PFAS “forever chemicals” in any active or inert ingredient of any of the proposed products, an important need as PFAS have been found in more than 60 percent of registered pesticides, see https://www.theguardian.com/environment/article/2024/jul/23/pfas-pesticides-epa-research:
at least 60% of active ingredients approved for use in common pesticides over the last 10 years are PFAS, and about 40% overall.
Moreover, companies are not required to disclose when PFAS are used as an inert ingredient.
See also:
https://ehp.niehs.nih.gov/doi/10.1289/EHP13954
https://ehp.niehs.nih.gov/doi/full/10.1289/EHP15445?utm_campaign=Monthly+TOC+Alert&utm_medium=email&utm_source=SendGrid
https://ehp.niehs.nih.gov/doi/full/10.1289/EHP11512
https://ehp.niehs.nih.gov/doi/full/10.1289/EHP10634
-- Copies of or links to any and all peer-reviewed toxicity, persistence, and environmental studies conducted by anyone anywhere of the combination of two or more proposed products; for example:
https://medicalxpress.com/news/2024-07-cancer-pesticides-cases.html
comparing cancer effects of exposure to multiple pesticides to cancer from smoking:
[T]he impact of pesticide use on cancer incidence rivaled that of smoking. The strongest association was among non-Hopkins lymphoma, leukemia, and bladder cancer. In these types of cancers, the effects of pesticide exposure were more pronounced than the effects of smoking.
"We present a list of major pesticide contributors for some specific cancers, but we highlight strongly that it is the combination of all of them and not just a single one that matters," (emphasis added)
See also: https://boerenlandvogels.nl/sites/default/files/Final%20version%20of%20TAP%20review.pdf, Pesticides and human chronic diseases: Evidences, mechanisms, and perspectives
– Detailed contour maps and explanations for each projected spray site showing all surface and groundwater sources within or down-slope from the site.
– Proposed detailed plans for after-spray monitoring soil and both surface and groundwater for contaminants of the proposed products used, and the time frame for such monitoring;
-- Any and all data on each endangered or threatened species of mammal, amphibian, reptile, fish, bird, plant, insect, or other organism within a mile of the proposed spraying;
– Site-specific history of any previous application[s] of herbicides on each target site by the Forest Service or any other entity in the past 60 years, and current testing for residues, PFAS, and dioxins on any previously sprayed site;
– Detailed information about all aspects of a drone application for each proposed site, including but not limited to those described in https://www.farmprogress.com/technology/what-to-know-before-making-a-spray-drone-pesticide-application, with particular attention to the need for safety precautions and procedures for possible crashes or dumping of herbicide:
Before creating and implementing a flight plan, inspect the field properly for any obstacles or any other operational considerations that will require the drone to stop or veer from the planned flight route. In most cases, using only background maps (aerial/satellite imagery) is not reliable enough to avoid all possible obstacles in the field so in-field checks before take-off are must for safe operations and to avoid any damage to the spray drone.
Loss of signal between the drone and remote controller is common when flying large fields or tall crops like corn and creates significant crash risks for the operators. Utilizing signal transmitters like DJI relay can reduce the risk of drone losing the connection with the controller in these situations where the drone is out of sight. It is also important to set up the base on high ground so the drone is in the visual line of sight as much as possible during application.
If the Forest Service is unable or unwilling to provide all of the above information, no chemical poisons should be proposed or used for this project.
Note that all of the proposed product labels warn against contaminating ground or surface water. Given the very uneven and usually steep terrain in the Siuslaw, it's well nigh impossible to apply any of the proposed poisons without having it run off or drain into ground water or surface water:
aminopyralid
https://www.epa.gov/pesticides/epa-addresses-ecological-risks-posed-aminopyralid
https://www.corteva.us/content/dam/dpagco/corteva/na/us/en/products/us-land-management/DF_Aminopyralid_Family_of_Herbicides_Broch.pdf
https://www3.epa.gov/pesticides/chem_search/ppls/081927-00082-20201019.pdf
" Not for Sale, Sale into, Distribution, and/or Use in Nassau and Suffolk counties of New York State."
:This chemical has properties and characteristics associated with chemicals detected in groundwater. The use of this chemical in areas where soils are permeable, particularly where the water table is shallow, may result in groundwater contamination. ...
Manure and urine from animals consuming grass or hay treated with this product may contain enough aminopyralid to cause injury to sensitive broadleaf plants. Do not aerially apply this product within 50 feet of a border downwind (in the direction of wind movement), or allow spray drift to come in contact with, any broadleaf crop or other desirable broadleaf plants.... Avoid application under conditions that may allow spray drift because very small quantities of spray may seriously injure susceptible crops ….
Trees adjacent to or in a treated area can occasionally be affected by root uptake of this product. Do not apply Alligare Aminopyralid 2SL Herbicide within the root zone of desirable trees
fluazifop-p-butyl, Fusilade, Syngenta
https://www.solutionsstores.com/fluazifop
(by most international regulatory agencies' definitions, the active ingredient is a PFAS and what inerts, including any PFAS it contains, is unknown.)
https://pubchem.ncbi.nlm.nih.gov/compound/fluazifop-p-butyl
GHS Classification TreeHazard Statement CodesH200: Physical Hazards
* H226: Flammable liquid and v***r [Warning Flammable liquids]
* GHS Classification TreeHazard Statement CodesH300: Health Hazards�H317: May cause an allergic skin reaction [Warning Sensitization, Skin]
* GHS Classification TreeHazard Statement CodesH300: Health Hazards�H361: Suspected of damaging fertility or the unborn child [Warning Reproductive toxicity]
* GHS Classification TreeHazard Statement CodesH300: Health Hazards�H361d: Suspected of damaging the unborn child [Warning Reproductive toxicity]
* GHS Classification TreeHazard Statement CodesH400: Environmental Hazards�H400: Very toxic to aquatic life [Warning Hazardous to the aquatic environment, acute hazard]
clethodim Shadow, UPL Corporation Limited Group Company. 24-UPL-1549
https://www3.epa.gov/pesticides/chem_search/ppls/070506-00484-20240411.pdf
ENVIRONMENTAL HAZARDS DO NOT apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. DO NOT apply where runoff is likely to occur. DO NOT apply where weather conditions favor drift from areas treated. DO NOT contaminate water when disposing of equipment washwater or rinsate. The use of this product may pose a hazard to the federally designated endangered species of Solano Grass and Wild Rice. Use of this product is prohibited in the following areas where the species are known to exist: Solano Grass: Solano County, California: the vernal lakes area bounded by the Union Pacific Railroad and Hastings Road to the north, Highway 113 to the east, Highway 12 to the south, and Travis Air Force Base to the west. Wild Rice: Hays County, Texas. NON-TARGET ORGANISM ADVISORY STATEMENT This product is toxic to plants and may adversely impact the forage and habitat of non-target organisms, including pollinators, in areas adjacent to the treated area. Protect the forage and habitat of non-target organisms by following label directions intended to minimize spray drift. PHYSICAL OR CHEMICAL HAZARDS Combustible. DO NOT use or store near heat or open flame.
indaziflam, Dow Chemical
https://www3.epa.gov/pesticides/chem_search/ppls/000264-01105-20110726.pdf
" This product is toxic to fish, aquatic invertebrates, and plants. Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean water mark. Do not contaminate water when disposing of equipment rinsate or washwater. This product may enter water through spray drift or runoff. Follow directions for use to avoid spray drift and runoff. A level well maintained vegetative buffer strip between areas to which this product is applied and surface water features including ponds, streams, and springs will reduce the potential of this product entering water from rainfall-runoff. Runoff of this product will be reduced by avoiding applications when rainfall is forecasted to occur within 48 hours. Surface Water Advisory: This pesticide may impact surface water quality due to runoff of rain water. This is especially true for poorly draining soils with shallow ground water. This product is classified as having high potential for reaching surface water via runoff for several months or more after application. Ground Water Advisory: This pesticide has properties and characteristics associated with chemicals detected in ground water. This chemical may leach into ground water if used in areas where soils are permeable, particularly where the water table is shallow."
chlorsulfuron, Bayer
https://www3.epa.gov/pesticides/chem_search/ppls/000432-01561-20201005.pdf
GROUND WATER ADVISORY Chlorsulfuron is known to leach through soil into groundwater under certain conditions as a result of label use. This chemical may leach into groundwater if used in areas where soils are permeable, particularly where the water table is shallow. SURFACE WATER ADVISORY This product may impact surface water quality due to runoff of rain water. This is especially true for poorly draining soils and soils with shallow ground water. This product is classified as having high potential for reaching surface water via runoff for weeks after application. A level, well-maintained vegetative buffer strip between areas to which this product is applied and surface water features including ponds, streams, and springs will reduce the potential loading of chlorsulfuron from runoff water and sediment. NON-TARGET ORGANISM ADVISORY This product is toxic to plants and may adversely impact the forage and habitat of non-target organisms, including pollinators, in areas adjacent to the treated area.
clopyralid
https://www3.epa.gov/pesticides/chem_search/ppls/035935-00057-20221207.pdf
HAZARDS TO HUMANS AND DOMESTIC ANIMALS DANGER Corrosive. Causes Irreversible Eye Damage. Harmful If Absorbed Through Skin Or Inhaled. Avoid contact with skin, eyes or clothing. Do not get in eyes or on clothing. Wear goggles or face shield when handling. Avoid breathing dust. Wash thoroughly with soap and water after handling. Remove contaminated clothing and wash clothing before reuse.
For use only on non-residential turf such as athletic and recreational sports fields, cemeteries, golf courses, industrial sites, noncropland, parks, rights-of-way, and roadsides. Turfgrass and lawn uses are restricted to non-residential sites. Note: In the states of California, Oregon and Washington, turfgrass and lawn uses are restricted to golf courses only.
glyphosate (Roundup)
https://www3.epa.gov/pesticides/chem_search/ppls/042750-00061-20231205.pdf
(A cursory search will also bring up the THOUSANDS of lawsuits brought against Monsanto/Bayer for non-hodgkins lymphoma caused by glyphosate/Roundup,
imazapic
https://www3.epa.gov/pesticides/chem_search/ppls/071368-00099-20150528.pdf
Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contaminate water when cleaning equipment or disposing of equipment washwaters or rinsate. This chemical demonstrates the properties and characteristics associated with chemicals detected in ground water. The use of this chemical in areas where soils are permeable, particularly where the water table is shallow, may result in ground water contamination.
imazapyr
https://www3.epa.gov/pesticides/chem_search/ppls/081927-00024-20110805.pdf
DO NOT use on food or feed crops. DO NOT use on Christmas trees. DO NOT apply this product within one-half mile upstream of an active potable water intake in flowing water (i.e., river, stream, etc.) or within one-half mile of an active potable water intake in a standing body of water, such as a lake, pond or reservoir.
metsulfuron methyl
https://labelsds.com/images/user_uploads/Manor%20Label%205-10-19.pdf
https://www3.epa.gov/pesticides/chem_search/ppls/066222-00050-20011004.pdf (CONDITIONAL REGISTRATION)
Injury to or loss of desirable trees or other plants may result from failure to observe the foIlowng: Do not apply Metsulfuron Methyl 60DF Herbicide (except as recommended), or drain or flush equipment on or near desirable trees or other plants, or on areas where their roots may extend, or in locations where the chemical may be washed or moved into contact with their roots. Do not use on lawns, walks, driveways, tenniS courts, or similar areas. • Prevent drift of spray to desirable plants. • Do not contaminate any body of water including irrigatlon water
https://www3.epa.gov/pesticides/chem_search/ppls/000279-09593-20191126.pdf
Metsulfuron Methyl is known to leach through soil into groundwater under certain conditions as a result of label use. Metsulfuron Methyl may leach into groundwater if used in areas where soils are permeable, particularly where the water table is shallow. Surface Water Advisory This product may impact surface water quality due to runoff of rain water. This is especially true for poorly draining soils and soils with shallow ground water. This product is classified as having high potential for reaching surface water via runoff for several weeks or more after application. A level, well-maintained vegetative buffer strip between areas to which this product is applied and surface water features including ponds, streams, and springs will reduce the potential loading of this product from runoff water and sediment. Runoff of this product will be greatly reduced by avoiding applications when rainfall or irrigation is expected to occur within 48 hours. Windblown Soil Particles Advisory This product has the potential to move off-site due to wind erosion. Soils that are subject to wind erosion usually have a high silt and/or fine to very fine sand fractions and low organic matter content. Other factors which can affect the movement of windblown soil include the intensity and direction of prevailing winds, vegetative cover, site slope, rainfall, and drainage patterns. Avoid applying this product if prevailing local conditions may be expected to result in off-site movement. Non-target Organism Advisory This product is toxic to plants and may adversely impact the forage and habitat of non-target organisms, including pollinators, in areas adjacent to the treated area. Protect the forage and habitat of non-target organisms by minimizing spray drift. For further guidance and instructions on how to minimize spray drift, refer to the Spray Drift Management section of this label
https://www3.epa.gov/pesticides/chem_search/ppls/000352-00439-20071108.pdf
This herbicide is injurious to plants at extremely low concentrations. Nontarget plants may be adversely effected from drift and run-off
picloram
https://assets.greenbook.net/L107372.pdf
This pesticide is toxic to some plants at very low concentrations. Non-target plants may be adversely affected if pesticide is allowed to drift from areas of application. ...his chemical is known to leach through soil into groundwater under certain conditions as a result of agricultural use. Use of this chemical in areas where soils are permeable, particu larly where the water table is shallow, may result in groundwater contamination. This chemical can contaminate surface water through spray drift. Under some conditions, picloram may also have a high potential for runoff into surface water (primarily via dissolu tion in runoff water), for several months post-application. These include poorly draining or wet soils with readily visible slopes toward adjacent surface waters, frequently flooded areas, areas over-laying extremely shallow groundwater, areas with in-field canals or ditch es that drain to surface water, areas not separated from adjacent surface waters with vegetative filter strips, and areas over-laying tile drainage systems that drain to surface water
https://s3-us-west-1.amazonaws.com/agrian-cg-fs1-production/pdfs/Tordon_22K_Label1h.pdf
sethoxydim
https://www3.epa.gov/pesticides/chem_search/ppls/000228-00619-20100518.pdf
For terrestrial uses, do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwaters. ENDANGERED SPECIES CONCERNS The use of any pesticide in a manner that may kill or otherwise harm an endangered species or adversely modify their habitat is a violation of Federal law.
https://assets.greenbook.net/00-05-03-10-07-2024-Poast_Herbicide_-_label.pdf
sulfometuron methyl
https://assets.greenbook.net/L107346.pdf
DO NOT apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. DO NOT contaminate water when disposing of equipment washwater or rinsate. Exposure to SFM 75 can injure or kill plants. Damage to susceptible plants can occur when soil particles are blown or washed off target onto cropland. Drift and runoff may be hazardous to aquatic organisms in neighboring areas. Do not apply where runoff is likely to occur. Do not apply when weather conditions favor drift from treated areas.
triclopyr
https://www3.epa.gov/pesticides/chem_search/ppls/081927-00011-20210628.pdf
This pesticide is toxic to fish. Do not apply directly to water, to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contaminate water when cleaning equipment or disposing of equipment washwaters or rinsate. This chemical has properties and characteristics associated with chemicals detected in groundwater. The use of this chemical in areas where soils are permeable, particularly where the water table is shallow, may result in groundwater contamination.
CONCLUSION
The Forest Service should withdraw herbicides from its list of options for controlling invasive species if it cannot provide the information listed above, as well as provide detailed plans and procedures for ensuring no contamination of surface or groundwater, no contamination of endangered, threatened, or non-target species, and no damage to non-target plants will occur.
Submitted by Carol Van Strum
Five Rivers, Oregon 97390