DEA's massive herbicide spray program for cannabis eradication
Fri, 5 Jun 1998 09:57:50 EDT
>From: Jay Feldman <email@example.com>
>Please circulate this widely.
>We did get an extension through the end of June on the comment period for
>the herbicide draft environmental impact statement for cannabis eradication
>on federal, non-federal and Indian lands. While we do not have anything in
>writing, the word from congressional offices that have helped us on this is
>that DEA will incorporate all comments received through the end of June into
>the hearing record and, therefore, address them in the final EIS. Offices
>that have been involved heavily are Rep. David Skaggs (D-CO), who sits on
>DEA Appropriations subcommittee, and Rep. Peter DeFazio (D-OR) who has a
>longstanding concern with pesticide use and is a fan of NCAP. Thank's NCAP.
>Rep. Henry Waxman's (D-CA) office worked with us and is looking into things
>and we are talking with Senator Patrick Leahy's office. Folks in California
>(Joannie Clayburgh with Californians for Pesticide Reform) have gotten
>Senator Barbara Boxer's office involved. And, Nancy McFadden in Tennesee has
>been kicking up a lot of dust in her neck of the woods. Terry Shistar has
>been feeding all this to the Sierra Club.
>Now, we need to get comments in on the EIS, and push for the use of
>alternatives to herbicides in the DEA's program. The EIS is available on
>line at http://www.usdoj/dea/programs/cannibis/pubmeet/fednoti.htm. (Please
>note that cannibis is the spelling that they use for cannibis on the web
>address. Must be some sort of secret code). If you contact USDA, Jack
>Edmundson (301-734-8274) or Vicky Wickheiser (301-734-4844) and they will
>send you a copy of the DSEIS.
>Thanks for your work on this. Please let us know what you are able to do on
>this. More later.
>May 29, 1998
>Environmental Protection Officer
>4700 River Road
>Riverdale, MD 20737-1228
>Re: Draft Supplement to the Environmental Impact Statements for Cannabis
>Dear Mr. Edmundson:
> The Drug Enforcement Administration's (DEA) proposed massive herbicide
>spray program across the United States for eradication of cannabis raises
>serious questions regarding widespread public and environmental exposure
>that would take place and therefore requires greater public involvement than
>has so far been received by DEA during the 45-day comment period. We
>respectfully request that the DEA extend the public comment period by 45
> It is not our intent to stop state and federal manual clearance efforts of
>cultivated cannabis. However, in light of new legislation and environmental
>concerns associated with pesticide, including herbicide, use, we believe
>that the Draft Supplement to the Environmental Impact Statements for
>Cannabis Eradication in the Contiguous United States and Hawaii (DSEIS)
>requires more public input than has received during the short comment period.
>The 45-day comment should be extended to 90 days and public outreach improved
> The established 45-day comment period is too short, especially since the
>program, as proposed, affects every state, federal, non-federal and Indian
>lands. It is unusual, given the controversy associated with this approach
>to eradication in the past, that the public comment period would be less
>than 90 days. Although staff at USDA/APHIS and DEA have been helpful in
>answering questions, the DSEIS notification and distribution procedure
>utilized by the
>May 29, 1998
>government has had the effect of generating limited public involvement to
>date. According to the DEA, Notice of Public Meetings, the 45-day comment
>period began with the U.S. Environmental Protection Agency's formal Notice
>of Availability. Copies of the DSEIS were sent to all respondents to a
>Federal Register Notice of Intent that the DEA says was published on August
>13, 1996, those who returned a mailing list query from USDA and those who
>called and requested the document. As a result of this process, it appears
>that the National Coalition Against the Misuse of Pesticides (NCAMP) as well
>as other groups were dropped from the USDA mailing list to the receive the
>DSEIS. This is despite NCAMP's active involvement in this issue going back
>to 1983, including as a plaintiff in litigation on this matter with the
>Sierra Club and Friends of the Earth (Sierra Club, National Coalition
>Against the Misuse of Pesticides, Friends of the Earth v. DEA) when the DEA
>was using paraquat as the herbicide of choice in its eradication efforts.
>NCAMP receives many DEIS documents in its office without going through this
> DEA and USDA should be working with groups to conduct outreach in seeking
>public comment on a program of this magnitude and nature. The government, as
>far as we can tell, conducted no real outreach efforts, but simply announced
>in the Federal Register five public meetings to receive public comments.
>The herbicides being proposed for use are toxic materials with adverse
>effects that have not been fully analyzed in compliance with federal
> The risk assessment methodology which the DEIS uses (Risk Assessment in the
>Federal Government, Managing the Process, NAS, 1983) does not fully conform
>with the statutory requirements to look at the total load of dietary and
>non-dietary exposure associated with the use of the chemicals proposed.
>Since the passage of the Food Quality Protection Act (FQPA) in 1996,
>Congress incorporated in pesticide law a requirement that EPA evaluate
>dietary and non-dietary exposures to pesticides together. Congress adopted
>this recommendation at the suggestion of the National Research Council (NRC)
>of the National Academy of Sciences (NAS) in its report Pesticides in the
>Diets of Infants and Children. Because of the large potential pesticide
>exposure associated with the DEA proposal, the additional exposure of these
>chemicals on top of exposure that occurs through conventional crop and
>non-crop uses must be calculated.
>May 29, 1998
> The other consideration that is not fully addressed under the proposal is
>the impact of the proposed spray program on children. Here, too, FQPA
>requires that the impact of the pesticides proposed for use be evaluated for
>their impact on children. The point here is that the addition of the
>proposed herbicide uses changes children's overall exposure to these
>chemicals and therefore the consequent risk to children must be calculated.
>If reliable data is not available, additional safety factors must be adopted.
>DEA's Chemicals of Choice Are Hazardous
> All the chemicals that DEA has proposed using, trichlopyr, 2,4-D and
>glyphosate, are hazardous to human health and the environment. Given the
>conditions in which these herbicides can be used, there are serious concerns
>that the DSEIS has disregarded key label information on the products
> Trichlopyr. The label on Garlon 3A (trichlopyr) states:
>Do not apply on ditches used to transport irrigation water. Do not apply
>where runoff or irrigation water may flow onto agricultural land as injury
>to crops may result. Do not graze lactating dairy animals or harvest hay
>from treated areas for one year following treatment. Do not graze areas
>treated with more than 2 quarts GARLON 3A per acre for one year following
>treatment. Withdraw livestock from forage treated with 2 quarts GARLON 3A
>herbicide per acre or less at least 3 days before slaughter during the year
>Garlon 4 is extremely toxic to fish. Triclopyr resembles 2,4,5-T
>structurally, and like the phenoxy herbicide, mimics plant growth hormones
>called auxins, interfering with the normal plant growth response. A large
>issue of concern regarding 2,4-D and possibly triclopyr is the endocrine
>disrupting effects of the chemical. Exposure to estrogen mimics, like
>2,4-D, for example, can disrupt the delicate balance that regulate growth,
>development, sexual traits, and many other functions.
> Glyphosate. The primary metabolite of glyphosate on plants is
>aminomethylphosphonic acid (AMPA), which is further converted to
>formaldehyde. Glyphosate exposure in humans has caused respiratory effects,
>and skin and eye irritation. There has been a high degree of concern
>associated with the surfactant often mixed with glyphosate. EPA
>acknowledges that the
>May 29, 1998
>glyphosate has the potential to contaminate surface waters and result in
>oxygen loss from decomposition of dead plants, leading to fish kills.
> 2,4-D. As cited above, the grave concern about endocrine disrupting
>effects of 2,4-D raises questions as to whether this toxic material should
>be a part of any weed control program. 2,4-D is associated with a long list
>of chronic adverse health effects from neurological effects to liver and
>kidney function changes to reproductive effects to cancer. Epidemiological
>studies of farmers have tied the chemical to elevated rates of non-Hodgkin's
>lymphoma. Under certain conditions the chemical may persist in the soil for
>DEA's Resources Should not Be Used To Control Ditchweed
> It is inappropriate for DEA to engage in a ditchweed eradication effort,
>especially with a chemical intensive approach. The focus of the agency
>should be cultivated cannabis crops. To become a more generalized weed
>control agency would be to go beyond the scope of the agency. There are
>alternative weed control measures on rangeland and pastures that should be
>Alternatives Are Too Easily Dismissed
> The public's annual exposure to pesticides is at 4.5 billion pounds.
>Overall, it is too high. Specifically, the vast majority of use is
>unnecessary, given the availability of alternative methods that are not
>reliant on toxic chemicals. While this situation is going on, the
>population of the United States lives with a rate of one in four people
>getting cancer annually. One in 600 children get cancer before the age ten.
>One in eight women get breast cancer. One in five men get prostate cancer.
>Childhood asthma is increasing. We know that pesticide, including herbicide,
>use contributes to these diseases. As a result, pesticides with the health
>and environmental effects cited above can contribute to the already
>unacceptable disease rates. Therefore, this makes it critical that manual
>clearance be adopted as the standard practice.
> Given our concerns about the chemicals proposed in the DSEIS and the
>availability of alternative approaches, it is critical that the public has
>an opportunity to more fully consider the issues associated with the DEA
>cannabis eradication proposal. Spraying these chemicals on plots of cannabis
>in uncontrolled conditions on public or private lands raises serious
>questions of public health and environmental safety that must be more fully
>May 29, 1998
>public lands that have been set aside for natural uses and are established
>for wildlife protection and recreational use, the chemical-intensive
>approach undermines this purpose.
> Thank you for your attention to our request for an extension. We look
>forward to your response.
> Jay Feldman
> Executive Director
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