November 2, 2000

Gerry Miller, Sr. Environmental Planner
Plant Health and Pest Prevention Services
California Department of Food and Agriculture
1220 N Street, A-357
Sacramento, CA 95814

Dear Mr. Miller:

The Redwood Chapter of the Sierra Club consists of Napa, Sonoma, Lake, Mendocino, Solano, Humboldt, Del Norte, West Siskiyou Counties, and parts of Trinity County. The Chapter wishes the following amended comments to be included in the report your task force will be issuing to the State Legislature regarding the protection of the public health and environment during implementation of the Glassy-winged Sharpshooter (GWSS) Eradication Program.

First of all, we would like to address the toxicity to humans of the pesticides that have been used so far to control the GWSS. Second, we will present environmental data regarding these pesticides (see List of Attachments for supporting documentation and additional information), and third, we will offer our recommendations for an environmentally sound approach to control of the GWSS.

The pesticide chlorpyrifos may be absorbed through the skin as well as inhaled, and acute exposure may cause convulsions, dizziness, labored breathing, unconsciousness, vomiting, pupillary constriction, muscle cramping, excessive salivation, and blurred vision. Poisoning from chlorpyrifos may affect the central nervous system and the respiratory system. Persons with respiratory ailments, recent exposure to cholinesterase inhibitors, cholinesterase impairment, or liver malfunction are at increased risk from exposure to chlorpyrifos. Some organophosphates may cause delayed symptoms beginning 1 to 4 weeks after an acute exposure which may or may not have produced immediate symptoms. In such cases, numbness, tingling, weakness, and cramping may appear in the lower limbs and progress to incoordination and paralysis. Improvement may occur over months or years, and in some cases residual impairment may remain. Effects of chronic exposure may include impairment of memory and concentration, disorientation, severe depressions, irritability, confusion, headache, speech difficulties, delayed reaction times, nightmares, sleepwalking, and drowsiness or insomnia. It is considered moderately toxic.

Organophosphorus and carbamate pesticides (classes which include chlorpyrifos and carbaryl, respectively) primarily affect the nervous system by inhibiting acetylcholinesterase (AchE) enzyme activity. This enzyme's main function in the nervous system is to break down the neurotransmitter acetylcholine. When AchE is altered by organophosphate and carbamate pesticides, it cannot perform this breakdown function and acetylcholine accumulates. Acetylcholine accumulation increases nerve impulse transmission and leads to nerve exhaustion and, ultimately, failure of the nervous system. When the nervous system fails, muscles do not receive the electrical input they need to move. The respiratory muscles are the most critical muscle group affected, and respiratory paralysis is often the immediate cause of death. (See Linda C. Glaser's article, "Wildlife Mortality Attributed to Organophosphorus and Carbamate Pesticides, attached.)

Carbaryl may also be absorbed through the skin and acute exposure can cause convulsions, dizziness, labored breathing, nausea, unconsciousness, vomiting, pupillary constriction, blurred vision, incoordination, muscle cramping, and excessive salivation. On contact it causes redness and pain. It is toxic to the nervous and respiratory systems and is considered moderately to very toxic.

Imidacloprid is moderately toxic; symptoms of poisoning would include fatigue, twitching, cramps, and muscle weakness, including weakness of the muscles necessary for breathing. Imidacloprid may be weakly mutagenic and a minimal carcinogenic risk.

Since in the north coast area the coho salmon and steelhead populations are already threatened, and further insults, such as increased amounts of pesticides in the watershed, could be disastrous, our information on environmental effects of pesticides focuses mainly on aquatic effects. We do include some information on effects to pollinators, beneficial insects, and birds, since reductions of such species will only make the population of the GWSS increase and would be otherwise damaging to the environment. For instance, Linda C. Glaser states in "Wildlife Mortality Attributed to Organophosphorus and Carbamate Pesticides" (attached): "...mortality is the primary documented effect on wildlife from organophosphorus and carbamate pesticides. Organophosphorus and carbamate pesticide toxicity is not specific to a target "pest", and lethal effects are seen in nontarget organisms; birds appear to be the most sensitive class of animals affected by these pesticides."

NIOSH notes that chlorpyrifos may be hazardous to the environment; special attention should be given to crustacea and fish. Extension Technology Network (EXTOXNET) states that chlorpyrifos is very highly toxic to freshwater fish, aquatic invertebrates, and estuarine and marine organisms. Application of concentrations as low as 0.01 pounds of active ingredient per acre may cause fish and aquatic invertebrate deaths. Chlorpyrifos accumulates in the tissues of aquatic organisms. Due to its high acute toxicity and its persistence in sediments, chlorpyrifos may present a hazard to sea bottom dwellers. Aquatic and general agricultural uses of chlorpyrifos pose a serious hazard to wildlife and honeybees. It is moderately to very highly toxic to birds.

Chlorpyrifos is moderately persistent in soils, with a half-life of between 60 and 120 days, but can range from two weeks to over one year, depending on soil type, climate, and other conditions. In water at pH 7 and 25 C, it has a half-life of 35 to 78 days.NIOSH notes that carbaryl may be hazardous to the environment; special attention should be given to fish and honeybees. EXTOXNET states that carbaryl is moderately toxic to aquatic organisms. Residue levels in fish were 140-fold greater than the concentration of carbaryl in water. Carbaryl is lethal to many non-target insects, including bees and beneficial insects. It is bound by organic matter and can be transported in soil runoff; it has a half-life in water at neutral pH of about 10 days.

The toxicity of Imidacloprid to fish is moderately low and its half-life in water is much greater than 31 days at pH 5, 7, and 9.It is highly toxic to bees if used as a foliar application. Imidacloprid is toxic to upland game birds. Its half-life in soil is 48-190 days, depending on the amount of groundcover (groundcover causes it to break down faster).

The specimen label for Merit 75 WP (75% Imidacloprid) states: "This product is highly toxic to aquatic invertebrates. 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.

"This product is highly toxic to bees exposed to direct treatment or residues on blooming crops or weeds. Do not apply this product or allow it to drift to blooming crops or weeds if bees are visiting the treatment area.

"This chemical demonstrates the 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." "Do not apply through any irrigation system."

Kelly Moran, Legislative Committee Vice Chair for Sierra Club California, researched the following information on pesticides in surface waters:
Water quality research conducted in California by storm water programs, wastewater treatment plants, and Regional Water Boards over the last several years has identified widespread toxicity in local creeks, urban runoff, and wastewater treatment plant effluent (examples of locations where chlorpyrifos-related toxicity has been found include the Sacramento River, Newport Bay, and Central Contra Costa Sanitary District's effluent). A majority of the toxicity was ultimately traced to the pesticides diazinon and chlorpyrifos use in urban and suburban areas. Study results indicated that pesticide use according to label instructions could not be ruled out as a cause of wastewater and storm water toxicity. Based on the water quality data, USEPA listed 53 waterbodies in California as impaired due to diazinon in urban runoff and 7 waterbodies as impaired due to chlorpyrifos in urban runoff as part of the final 1998 section 303(d) (Clean Water Act) list of impaired water bodies in California. Note that very few California water bodies have been monitored for chlorpyrifos and fewer still have been monitored for toxicity associated with chlorpyrifos, so it is likely that the surface water problems caused by chlorpyrifos are substantially greater than indicated above.Chlorpyrifos is an extremely common, heavily used insecticide. California is one of the highest use states for chlorpyrifos.

[note: The risk assessments cited below are all USEPA risk assessments for reregistration of chlorpyrifos, all released in 1999 and 2000]

In urban areas, chlorpyrifos receives significant use. Chlorpyrifos is one of the top five insecticides used in residential settings; it is present in 18% of all households (HED Preliminary Risk Assessment, page 59). As the HED Preliminary Risk Assessment states, there are many non-residential urban sites of use, such as turf and ornamental plants, structural pest control, commercial buildings, schools, daycare centers, hotels, restaurants and other food-handling establishments, hospitals, stores, warehouses, food manufacturing plants, and vehicles.

Environmental releases of chlorpyrifos can occur during handling, mixing, loading and applying activities. Post-application releases from lawns and other landscaping, outdoor hardscape (e.g., patios, paths, sidewalks, streets, driveways, curbs, and gutters), structures, pets, and treated building interior and exterior elements (e.g., carpeting, crack & crevice areas, baseboards) can also occur.

The presence of elevated levels of chlorpyrifos in surface waters and surface water discharges is a widespread problem (risk assessment pages 28-29, 102-103, 178, 191, 25-206). On page 90, the risk assessment notes that chlorpyrifos is "one of the [NOAA-] inventoried pesticides found most often in coastal aquatic biota." The urban portion of these problems is at least as significant as the agricultural portion. In the Drinking Water Assessment (page 20), USEPA notes that "the NAWQA monitoring data now available do strongly imply that overall impacts of chlorpyrifos on surface waters from non-agricultural uses is at least as significant as from agricultural uses, with the % detections over 0.01 ppb, the 90th percentile values, and the 95th percentile values all higher in the streams draining primarily urban watersheds than in the streams draining primarily agricultural watersheds."

EPA needs to consider cumulative effects of chlorpyrifos and other substances present in surface waters. As a recent article in Environmental Science and Technology noted: "The NAWQA study reveals that low-level mixtures are the most common form of pesticide occurrence in streams and groundwater. Long-term exposure to low-level mixtures of pesticide compounds, punctuated with seasonal pulses of high concentrations, is an exposure pattern that may not be adequately accounted for in present criteria."

(Robert J. Gilliom, Jack E. Barbash, Dana W. Kolpin, and Steven J. Larson, "Testing Water Quality for Pesticide Pollution," Environmental Science and Technology, April 1 1999, page 164A-169A.)

The following issues need to be addressed in the cumulative impacts analysis:

use of multiple chlorpyrifos products in the same watershed,

use of multiple organophosphate pesticides in the same watershed,

use of chlorpyrifos products with multiple active ingredients near surface waters, and

potential impacts of inert ingredients in chlorpyrifos products on water quality.

The cumulative use of organophosphate pesticides contributes to surface water toxicity problems. As the HED Preliminary Risk Assessment notes (page 61), EPA considers organophosphate pesticides to express toxicity through a common biochemical interaction. The combined effects of organophosphate pesticides have been demonstrated to cause additive toxicity in surface waters, as the risk assessment notes on pages 28, 98 and 103. It will be necessary for USEPA to evaluate the cumulative toxicity of chlorpyrifos, diazinon, and other organophosphates (as well as their degradates).

Carbamates are very water soluble. Like diazinon, they are commonly detected in runoff, especially in urban areas, and have been found in fog (Schomburg, C.J., D.E. Glotfelty, and J.N. Seiber, "Pesticide occurrence and distribution in fog collected near Monterey, California," Environmental Science and Technology, V. 25, 1991, p. 155-160). Part per billion concentrations in water have been shown to be toxic to fish and cladocerans (Cox, Caroline, "Carbaryl, Part 2," Journal of Pesticide Reform, V. 13, No. 2, Summer 1993).

There's been essentially no water quality monitoring of carbaryl in California, so we have no idea if it is a problem now. The EPA registration process and available regulatory processes provide no information to tell anyone if it will be an environmental problem if broadly used (e.g., for GWSS).

With the evidence presented in the above paragraphs in mind, we believe that loss of species, other types of environmental damage, and damage to human health could be irreversible and should certainly be given more consideration than immediate economic interests. The wine grape industry can find ways to maintain most of its vigor without putting the environment and our health at risk. Our recommendations to the task force are these:

In light of the information cited above, carbaryl and especially chlorpyrifos must not be used, nor should any other carbamates or organophosphates. Imidacloprid must not be allowed to reach groundwater or to run off into waterways. Pesticides that are carcinogens, reproductive or nerve toxins, or EPA Category I and II acute pesticides should be strictly avoided as well.
There must be no aerial application of pesticides because of the impossibility of controlling the drift.
For any application of pesticides, drift must be rigorously controlled in order to keep it within the boundaries of the property being treated.
There must be no forced pesticide application in homes, yards, and farms. Residents who have infestations of the GWSS must be given the choice of safe, alternative methods of abatement. This is especially important for the very young and the elderly and for those with health conditions that can be aggravated by exposure to pesticides. Also, organic and transitional farmers would suffer severe economic loss if forced to apply pesticides to their crops, so it is extremely important that they have a choice of non-toxic abatement methods.
Adequate funding must be made available for research into safe alternative methods of control of the GWSS, and programs should be put in place to make this information available to vineyard owners and others who have infestations of the insect.
Genetically modified organisms must not be considered as a means of control. The Sierra Club Biotechnology Policy states, in part: "We call for acting in accordance with the Precautionary Principle, meaning that when an activity raises the possibility of serious or irreversible harm to the environment or living creatures, precautionary measures that prevent the possibility of harm shall be taken even if the causal line between the activity and the possible harm has not been proven.
"In accordance with this Precautionary Principle, we call for a moratorium on the planting of all genetically engineered crops and the release of all GEOs into the environment, including those now approved. Releases should be delayed until extensive, rigorous research is done which determines the long-term environmental and health impacts of each GEO and there is public debate to ascertain the need for the use of each GEO intended for release into the environment.".
Bulk grapes and nursery stock from infested areas must be quarantined so as not to allow shipment to uninfested areas. Prohibiting import of these materials to unifested areas is the only certain means to control the artificial spread of the GWSS, because experience has shown that inspection and pesticide treatment is not fully effective. This strategy will result in some economic loss to the nursery industry and wineries, but the loss is small when compared to potential loss of the 50 billion-dollar wine industry in California. Further, the loss is minor when compared to potential personal health hardships and the devastating impact on the state's wildlife that will result from the widespread application of pesticides to control GWSS infestations, which are certain to occur without a quarantine. Pesticide application to crops and nursery stock from infested areas should never be used as a means of allowing them to be shipped.
All decisions regarding combating the GWSS should be completely transparent. Public input should be sought out and incorporated into public policy.

Respectfully submitted,

Margaret PenningtonChair, Redwood Chapter of the Sierra Club

List of Attachments

1. Wildlife Mortality Attributed to Organophosporus and Carbamate Pesticides, by Linda C. Miller, National Biological Service

2. International Chemical Safety Cards - Chlorpyrifos

3. EXTOXNET Pesticide Information Profile - Chlorpyrifos

4. Aquatic Ecotoxicity Summaries by Species for: Chlorpyrifos

5. International Chemical Safety Cards - Carbaryl

6. EXTOXNET Pesticide Information Profile - Carbaryl

7. Aquatic Ecotoxicity Information Profile by Species for: Carbaryl

8. EXTOXNET Pesticide Information Profile - Imidacloprid

9. Specimen Label for Merit 75 WP (75% Imidacloprid), page 1

10. Pesticides Used to Combat the Glassy-Winged Sharpshooter - PAN Database; EXTOXNET; Town Hall Coalition Toxics Committee, Occidental, CA