name additional commentsboe.hawaii.gov/meetings/notices/meeting material library... ·...

The following individuals added their name(s) to the petition that can be found on page 12:

Name Additional Comments

Dr. Jana Boggs

Nanea Lo

Dr. John Nix

Debra Nix

Eva-Maria von Bronk

Lori Barrie

Maryann Broyles

Barbara Nosaka

Richard J. Janik

Lea Taylor

Dwayne Munar

Maha Conyers

Dr. Tom Gourley

Jonathan Boyne

Laurie Quarton

Janice Bond

Nadine Newlight

Gina Fulop

Michelle Galarza

Shay Chan Hodges

Meredith Cross I am a parent of a toddler, that will one day potentially be enrolled in one of the schools affected by the policies that are determined today.

Joanna Weber

Samu János

Emily Dudley

Meg Schofield Undoubtedly you will hear conflicting testimony about the effects (or not) of exposure to glyphosate-based herbicides. I don't think you need to have 100% iron-clad proof that it CAUSES cancer in order to take precautionary action. There was a

time when research appeared to be inconclusive on the negative health effects of cigarette smoking, and now of course it is widely accepted. We should be concerned about the potential exposure to the keiki and school staff, in particular groundskeepers, and everyone who spends time on our DOE campuses. Not only that, but consider the runoff that washes these chemicals into the streams and oceans, affecting countless other life forms including our precious reefs and marine life! There is certainly enough evidence to warrant taking progressive action to stop the use of glyphosate. Please show our youth that adults can take thoughtful, pono action, with the BIG picture in mind.

Pam Murphy

Yvette Celiz

Ruta Jordans

Tlaloc Tokuda

Lynn Albrecht

Timothy Starbright

Kanoi Sumang Plus, as an alumni of Waimea Canyon Middle School and Waimea High School on the island of Kaua'i it is alarming to hear that the water that was tested in those schools were contaminated with Atrazine which is linked to cancer. I personally drank from that contaminated water while in

school and while spraying was still prevalent. Thanks to bill #2491 that was passed by the Kaua'I County Council to prohibit spraying within buffer zones by agrochemical companies, it only makes sense for the same prohibition efforts to be applied to school grounds keepers and its related staff. Further, the same measurers should be applied to all schools and residential areas in and across Hawaii.

Denise Woods

Dr. Vinayak Vinayak

Teresa Gardner As we know, kids spend a lot of time outdoors playing on the grass.

Laurie DeRego

Chris Santomauro

Michele Nihipali

Dr. Susan Caswell

Citizen A H

Hope & Richard DeMarco

Diane Koerner When my children were still in school, they often got asthma attacks linked to pesticide (herbicide and insecticide) use in or around their school or ball fields.

According to the American Academy of Pediatrics, pesticides such as Roundup are linked to childhood cancers, neurobehavioral and cognitive deficits, and asthma. In adults, in addition to acute exposure symptoms such as headaches and asthma attacks,

pesticide exposure has been linked to Non-Hodgkin's lymphoma, bladder and colon cancer, Parkinson's disease, depression, and disrupting our endocrine systems, according to the Hawai'i Center for Food Safety.

Roger Harris

Marge Freeman

Marlies Lee I’m very concerned about my health, my children’s health, my animals health, our lands health and my neighbors health!!! Please say NO to toxic chemicals being used on all Hawaiian Islands, don’t let other countries use us as Guinea Pics for their toxic products!!! Please stop the abuse!!

Felicia Ferrance

Valerie Reid

Susanne Kiriaty

Devon Benton

Sheri White

Linda Delgado

Dwayne Munar

Tara Mattes

Ido Kek

Lynn Azar

Maureen Lynch

Joanna Weber

Matthew LoPresti

Joann Fechner

Earl Kim

Haley Hildebrand I'm a School-Based Behavioral Health Specialist at Kealakehe Elementary in West Hawaii, who is deeply passionate about the

social emotional benefits of gardens, and work with students regularly in our garden. In the garden we do not use pesticides, and have found success with natural, non-toxic integrated pest management solutions. However, it concerns me to see our custodians spraying pesticides at our school, especially near our garden and watch as spray blows into our peace garden. I'm also concerned about their own exposure, especially during the summer months when they seem to spray most frequently. This is a public health concern.

Kathleen Espamer

Patricia Gardner

Mary Hackney

Carolynn Griffith

Jazmyne Geis

Richard Thornhill

Barbara Nosaka

Terry Huth

Lynda Barry

Katherine Kane

Rene Siracusa

Danielle Spitz

William Hackett

Michael Stauber

Andy Thomas

Zoe Alexander

Julia Fujioka

Nalei Kahakalau

Ronald Foreman

Laura Hagan

Daniel Foreman

Joseph O’Leary

Dianne Liu

Ingrid Eichenbaum

Vicky Oxner

Natalie Haneberg

Jonathan Boyne

Alan Young

Debra Vitola

Sherrie Moore

Lois Crozer

Ronny German

Marilyn Mick

Laurie Leland

Leslie J.

Barbara Barry I strongly support all efforts to minimize chemical exposure to our at the schools and playgrounds in Hawai’i. As a former self employed organic based landscaper, I know that this can be done economically and effectively without the use of toxic chemicals. There are several non toxic products that do not harm our keiki or destroy our pollinators. I strongly urge the Hawaii School Board to adopt these safe landscaping products immediately. I have grandchildren that attended Makawao Elementary. Mahalo for doing the right thing.

Harvest Edmonds

Ray Moody

Noenoe Campbell

Mary N.

Pamela Wai'olena

Daya Akina

Donald Erway

Shannon Velazquez

Lori Nakamura-Higa Dewayne Johnson is a name you should be familiar with as he was a school's groundskeeper that was required to spray glyphosate-based herbicides and later was awarded millions in damages by a California jury claiming glyphosate use and exposure was the cause of his Non-Hodgkin's Lymphoma. Of course the company is appealing. What's also important to keep informed of is that there are currently 13,000 lawsuits filed also claiming that glyphosate has caused Non-Hodgkin's Lymphoma in them as well. Any doubt or dismissal surrounding this toxic herbicide should no longer be an option. This is indeed an urgent and serious issue, not just to be heard, but to be acted upon.

Valerie Allen

Sonja Oliveri

Mike Moran

Dr. Lauren Ampolos

Nancy Silva

Gary Johnson

Janice Banks

Susan Bleznick

Anchun Tien Please enact an official policy banning pesticides to protect public health and encourage any schools who are struggling to make the transition to seek out resources and assistance available.

Natalie Alexander

DiDi Leong

Marian Cruz

Tia Pearson

Kirstin Morris

Victoria Olson

Nancy Haag

Sharon Depauw

Mel Cup Choy

Dana Keawe

Robert Abell

Laura Ramirez

Brucella Berard

Emmaleah Stauber

Mitsuko Hayakawa

Beverly Walker

Bellodgia Yamamoto It’s time our state takes the use of Glyphosate and other hazardous pesticides very seriously. Recently Dewayne “Lee” Johnson a former school groundskeeper in California became the first plaintiff to successfully sue Monsanto/Bayer for the cause of his non-Hodgkin lymphoma for close to $300 Million. The DOE has an amazing opportunity to put an end to putting our keiki and others at risk due to toxic chemical exposure. Keiki and glyphosate are a bad combination!! Banning glyphosate based herbicides and any other hazardous herbicides used in DOE land management is a profound message to our children

and our Aina that we care about our future.

Linda Steininger

Ninon Rynerson

Renee Hocevar

Julie Sharrer

Cindy Aban

Jim Cazel

Katrina Raphaell

John Mcguire

Aleina Chun

Becca Harris

Maxine Hoffman

Johanna Stone

Gloria J. Howard

Val Hertzog

Frank Schultz

Gregory Puppione

Kari Matadobra Neem oil is amazing and worth the effort over harsh chemicals that get into keiki's bodies and into the oceans. I have also read how glyphosates can actually bind to important metals in the soil and render them useless, thus depleting the nutritional quality of food. The word I remember was "chelating," which from my studies of Chemistry mean Schools need to be supported in using what is best for keiki, and there are many non-toxic alternatives available.

Dan Cappello

Kater Hiney We all know everything on an island ends up in the marine environment, that being

said, Hawaii as a state should not use glyphosate-based products ever on any land, in fact the selling and usage of it should be banned statewide. As a community we know that there are alternative options to use as weed control methods or even use alternative ground covers. We owe it to our flora and fauna of Hawaiian Islands to not use these toxic products.

Barbara Wilhite Protect our children by placing a ban on any/all pesticides. Their health and lives depend on it.

Sherry Pollock

Sue Perley

Tovah Stafford

Kai Nishiki

JK Deller

Melissa Hill

Lori Kizer

Katie Horgan

Delaney de la Barra

Rhaya Celestyne

Melody Zeitler

Don Cooke

Belgica Heredia

Heidi Leonhard

Candace Marx

Kūʻike Kamakea-Ohelo

Brett Gobar

Susan Schluederberg

Elisabeth Iwata

Neville Bruce

Teri Hammer (Late)

Donald Leisman (Late)

Gerard Ridella (Late)

Camilla Bowman (Late)

Kay Martin (Late)

Penny Hartman (Late)

Simone Targo (Late)

David Foltz (Late)

Richard Kornfeld (Late)

Barbara Johns (Late)

Wanda Turner (Late)

Samantha Sherline (Late)

Danielle Drosnock (Late)

Laura Boyajian (Late)

May Cheung (Late)

Judith Gilbert (Late)

Robert Clyne (Late)

Michelle Krueger (Late)

Mae Basye (Late)

Aurelie Ward (Late)

Janett Orndorf (Late)

Camille Chong (Late)

Thomas Friedman (Late)

Anne-Marie Sancho (Late)

Debra Cameron (Late)

My name is________ and I am a resident of__________. Thank you for hosting a meeting to discuss the use of glyphosate-based herbicides on DOE land. I appreciate the efforts the DOE has already taken to use integrated pest management. An overwhelming body of evidence has demonstrated that exposure to glyphosate-based herbicides is linked to cancer and other illnesses. I am concerned about the potential exposure to the keiki and school staff, in particular groundskeepers who may be required to spray as a requirement of their job. Many other towns and school districts have taken similar steps to protect public health by banning glyphosate and other pesticides and have successfully transitioned to organic land management practices, even in climates similar to Hawaii with little to no cost difference. Please enact an official policy banning glyphosate-based herbicides to protect public health and encourage any schools who are struggling to make the transition to seek out resources and assistance available. Mahalo for your consideration.

The following individuals added their name(s) to the petition that can be found on page 18:

Name Additional Comments

Christina Kaleiwahea Please ban glyphosate based herbicides and follow the recommendations of the Young Progressives Demanding Action.

Natalie Toma We need to protect the future leaders and innovators of tomorrow, alongside the school staff who create an environment where they can learn and develop. This includes the groundskeepers who may be required to spray herbicides as a job requirement. By banning glyphosate, we would be joining several countries and U.S. municipalities who are taking the necessary steps to begin that process or who have already restricted and banned glyphosate, and other pesticides. The State of Hawaiʻi has already taken a bold stand once before in favor of public health and protecting our keiki with the passage of Act 45 in 2018, regulating Restricted Use Pesticides (RUPs), pesticide buffer zones around schools, and the banning of Chlorpyrifos. We can take a stand once more for the benefit of present and future generations and find sustainable solutions such as transitioning to organic land management.

Kawika Pegram By banning glyphosate, we would be joining several countries and U.S. municipalities who are taking the necessary steps to begin that

process or who have already restricted and banned glyphosate, and other pesticides. The State of Hawaiʻi has already taken a bold stand once before in favor of public health and protecting our keiki with the passage of Act 45 in 2018, regulating Restricted Use Pesticides (RUPs), pesticide buffer zones around schools, and the banning of Chlorpyrifos. We can take a stand once more for the benefit of present and future generations and find sustainable solutions such as transitioning to organic land management. I ask the DOE to enact an official policy banning glyphosate-based herbicides to protect public health, and to encourage any schools who are struggling to make the transition to seek out the resources and assistance available.

Jeanné Kapela

Leslie Lopez

Shane Albritton

Jonah Keohokapu

Tina Wildberger

Javier Mendez

Clare Hanus

Justin Salisbury

Cindy A8

Nenita Cabanilla

Miguel Menjivar

Melia Leslie

Kiana Otsuka

Gina Alcos

Joseph Nicholas

Anne Marie Call

Jonah Keohokapu

Brian Jahn

Shirley Yamauchi

Mireille Ellsworth

Melissa Riggs

Shannon Rudolph

Sharon Willeford As a retired elementary school teacher of 35 years in Kona, and a victim of Organophosphate poisoning ( forcing me to retire early and suffer with bleeding sores and total system shut down for 3 years and STILL suffering 8 years later) - I literally BEG you to PROTECT Our KEIKI!

Kathleen Horgan

Beatrice DeRego

David Negaard

Laura Dvorak

Kalani Watkins

Diane Spencer

Jessica Mitchell

Will Caron The chemical glyphosate, contained in Roundup and other poisons, is a known carcinogen linked to cancers like non-Hodgekin lymphomas. The company that manufactures Roundup, Monsanto, was forced to pay a massive settlement to a victim that developed one of these blood cancers as a result of exposure. Our children are our future. There is no acceptable level of exposure, no acceptable level of risk for keiki. There is also no reason we could not go pesticideless

on our campuses. There are many other ways of controlling pests and weeds without relying on poisons. Please ban Glyphosate from our schools.

Ashleigh Loa We need to protect the future leaders and innovators of tomorrow, alongside the school staff who create an environment where they can learn and develop. This includes the groundskeepers who may be required to spray herbicides as a job requirement. By banning glyphosate, we would be joining several countries and U.S. municipalities who are taking the necessary steps to begin that process or who have already restricted and banned glyphosate, and other pesticides. The State of Hawaiʻi has already taken a bold stand once before in favor of public health and protecting our keiki with the passage of Act 45 in 2018, regulating Restricted Use Pesticides (RUPs), pesticide buffer zones around schools, and the banning of Chlorpyrifos. We can take a stand once more for the benefit of present and future generations and find sustainable solutions such as transitioning to organic land management.

Kelley Anne Ringor (Late)

Felila Faletoi (Late)

Monique Omalza (Late)

Chante Galton (Late)

Kimberly Berengie (Late)

Hailie-Belle Berengue (Late)

Jarence Berengue (Late)

Wilbur Berengue (Late)

Jeanie Berengue (Late)

Support HB 723 and HB 1285 Please ban glyphosate on public schools! Our keiki deserve to learn in schools that are free from chemical harm. That is why I'm asking you, today, to put a policy banning the use of glyphosate-based pesticides on public school campuses on a future BOE agenda. An overwhelming body of evidence has demonstrated that exposure to glyphosate-based herbicides is linked to cancer and other illnesses. I am concerned about the potential exposure to the children and school staff, in particular groundskeepers who may be required to spray as a requirement of their job. At least sixty-one cities, counties, and communities across twenty-two states, and twenty-seven countries worldwide, have moved to halt or restrict the use of glyphosate on public lands due to environmental and human health risks. These places have successfully transitioned to organic land management practices, even in climates similar to Hawai'i, with little to no cost difference. Please enact a board policy banning glyphosate-based herbicides to protect our keiki's health, require training for appropriate DOE personnel, and make the creation of pesticide-free schools a strategic priority for the department. Mahalo for championing safe schools for our children.

"David H. Dinner" <[email protected]>

06/19/2019 12:03 PM

To [email protected] cc

Subject Glyphosate

It is sad that I even need to send this request. What could be more important than protecting our keidi from chemical exposure to toxins like Roundup? Please ban glyphosate from our schools NOW. Mahalo.AlohaDavid DinnerKilauea HI

David DinnerCertified Biodynamic and Visionary Craniosacral Care and [email protected] 639 7845

********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Mapuana Kupuna <[email protected]>

06/19/2019 12:09 PM


Subject Ban Glyphosate In Schools

We need to stop exposing all keiki to these carcinogenic chemicals.Mahalo nui loa!April Peterson********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Lea Taylor <[email protected]>

06/19/2019 12:09 PM


Subject Ban Toxins from our schools! Ensure our children's good health!

Dear BOE Hawaii, Please join the dozens of other municipalities and school districts who have already adopted policies to ban the use of glyphosate-based herbicides.

A growing body of peer reviewed studies and internal industry documents released through recent court cases have revealed disturbing health and environmental risks associated with exposure to glyphosate-based herbicides.

The American Academy of Pediatricians has flagged concerns about the heightened susceptibility of children to the toxicity of pesticides both in acute incidents and low-level chronic exposure and cited the need for government bodies to take greater action to prevent exposure. The International Agency for Research on Cancer has identified glyphosate as a probable known carcinogen since 2015.

School groundskeepers are another vulnerable population who may be regularly exposed to glyphosate as a requirement of their job. Recently DeWayne “Lee” Johnson a former school groundskeeper in California became the first plaintiff to successfully sue Monsanto/Bayer for the cause of his non-Hodgkin lymphoma. Also, let me just express disdain at the fact that when I asked for healthier foods at the schools when my daughter was attending, I was scoffed at. I sent the BOE suggestions and meal plans for less toxic food and fresh vegetables, fruits and meat in their diet. Instead I was told they weren't interested. WERE NOT INTERESTED. A couple of years ago I went to a parents' school function at the Intermediate school and they served everyone the leftover chicken dish from the day's lunch. I got food poisoning. The meals offered are HORRIBLE and unhealthy. I hope that you are now making headway on healthy food - my daughter is gone and graduated but please, do something about toxins. Mahalo, Lea ********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Patricia Blair <[email protected]>

06/19/2019 12:18 PM

To "[email protected]" <[email protected]>

cc Subject Ban all pesticides near or on Hawaii

School Campuses. Concern for our children’s health should be a given. Thank you.

Patricia Blair, Kailua

Sent from my iPad********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

Anthony Allen <[email protected]>

06/19/2019 12:29 PM


Subject Ban Glyphosate

Hello Board of Education,

Please do the right thing and Ban Glyphosate, a known carcinogen from being used on public school campuses in our state?

It’s a no brainer! Please let me know how each of you voted on this issue as will be putting it on Hawaiian social media.

Sincerely,

Anthony AllenKauai********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

Zach Street <[email protected]>

06/19/2019 12:37 PM


Subject Meeting regarding pesticide use at our schools

Aloha Board Members,Mahalo for hosting meetings regarding pesticide use in our schools.The situation now seems quite clear: glyphosate is a hazard to human health, and to the soil, and should not be used in Hawai’i, especially not in our schools.I know you care for our keiki, and I know cost-effective maintenance of our grounds is important also, but in this case, the true cost is far greater than we once realized; Glyphosate is harming our keiki.This harm is now clear and undeniable, and we can inflict this poison upon our keiki no longer. I urge your to immediately cease the use of glyphosate products and use the opportunity to design a creative solution, perhaps one that connects our keiki to the ‘āina - involving the haumana in the care of the grounds - instead of spraying toxic poison in the areas they learn, develop, and play.Our future depends on us returning to our local and Hawaiian values of caring for the land, and living with it, and an abrupt stop to the colonial practices of poison and conquest.Let’s take this moment to take a step toward the future, and leave the poison on the past.Mahalo nō,Zach StreetHilo, Hawai’iSent from my iPhone********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

weareallone <[email protected]>

06/19/2019 01:44 PM


Subject NO glyphosate poison on public land! Poisoning kids (and adults) and animals and water, is NOT OKAY.

PLEASE join the dozens of other municipalities and school districts who have already adopted policies to ban the use of glyphosate-based herbicides.We can no longer poison our environs and expect to thrive! Poison anywhere means poison EVERYWHERE. It spreads to water, air, plants, animals and people. Thank you, Valerie Gilbert********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

MaryLu Kelley <[email protected]>

06/19/2019 02:17 PM


Subject We must ban glyphosate use on public school campuses

Aloha,Hawaii Board of Education please join the dozens of other municipalities and school districts who have already adopted policies to ban the use of glyphosate-based herbicides.

A growing body of peer reviewed studies and internal industry documents released through recent court cases have revealed disturbing health and environmental risks associated with exposure to glyphosate-based herbicides.

The American Academy of Pediatricians has flagged concerns about the heightened susceptibility of children to the toxicity of pesticides both in acute incidents and low-level chronic exposure and cited the need for government bodies to take greater action to prevent exposure. The International Agency for Research on Cancer has identified glyphosate as a probable known carcinogen since 2015. We must ban glyphosate use on public school campuses NOW!!!Thank you,Mary Lu Kelley3644 Lawaiuka RoadLawai, HI 96765********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Eliel Starbright <[email protected]>

06/19/2019 02:34 PM


Subject Please ban the use of glyphosate-based herbicides on DOE school grounds.

I requesting that the Board of Education draft and adopt an official policy banning the use of glyphosate-based herbicides on DOE school grounds .********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Denis Johnston <[email protected]>

06/19/2019 02:45 PM


Subject glyphosate

I am writing to request that the Hawaii Board of Education ban glyphosate use on public school campuses. It has been banned in most of Europe as well as some of the states of America. A recent report from the International Agency for Research on Cancer (IARC) concluded that the herbicide and its formulated products are probably carcinogenic in humans. I could go on about the dangers of glyphosate, but have elected to spare you the infinite details regarding Monsantos Round-Up and the effects of glyphosate on mammals (humans).

Link to read what is happening on Kaua`i: https://www.theguardian.com/us-news/2015/aug/23/hawaii-birth-defects-pesticides-gmo

Aloha,Denis & Dawn Johnston


Aloha Board Members, My name is Kanoi Sumang and I am a resident of Kaunakakai, Hawaii and I also live in Hanapepe, Kaua'I Part-Time. Thank you for hosting a meeting to discuss the use of glyphosate-based herbicides on DOE land. I appreciate the efforts the DOE has already taken to use integrated pest management. An overwhelming body of evidence has demonstrated that exposure to glyphosate-based herbicides is linked to cancer and other illnesses. I am concerned about the potential exposure to the keiki and school staff, in particular groundskeepers who may be required to spray as a requirement of their job.

Plus, as an alumni of Waimea Canyon Middle School and Waimea High School on the island of Kaua'i it is alarming to hear that the water that was tested in those schools were contaminated with Atrazine which is linked to cancer. I personally drank from that contaminated water while in school and while spraying was still prevalent. Thanks to bill #2491 that was passed by the Kaua'I County Council to prohibit spraying within buffer zones by agrochemical companies, it only makes sense for the same prohibition efforts to be applied to school grounds keepers and its related staff. Further, the same measurers should be applied to all schools and residential areas in and across Hawaii. Many other towns and school districts have taken similar steps to protect public health by banning glyphosate and other pesticides and have successfully transitioned to organic land management practices, even in climates similar to Hawaii with little to no cost difference. Please enact an official policy banning glyphosate-based herbicides to protect public health and encourage any schools who are struggling to make the transition to seek out resources and assistance available. Mahalo for your consideration. Sincerely, Kanoi Sumang, Kaunakakai & Hanapepe, Hawaii.

deb kimball <[email protected]>

06/19/2019 03:12 PM


Subject Pesticide

Please ban the use of glyphosate-based herbicides on DOE school grounds—it has brought lethal results to workers and others.Mahalo,Deborah KimballMo’ili'ili********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Lorna Holmes <[email protected]>

06/19/2019 03:13 PM


cc Subject ban glyphosphate at schools

Aloha BOE,Please ban glyphosphate at schools; it should also not be used near schools. The American Academy of Pediatricians has flagged concerns about the heightened susceptibility of children to the toxicity of pesticides both in acute incidents and low-level chronic exposure and cited the need for government bodies to take greater action to prevent exposure. The International Agency for Research on Cancer has identified glyphosate as a probable known carcinogen since 2015.Glyphosphate is not safe even for adults, and certainly not for children.Mahalo,Dr. Lorna HolmesHonolulu 96817


Dave Kisor <[email protected]>

06/19/2019 03:23 PM


cc Subject A k-12 campus is no place for

biochemical warfare

Aloha BOE

It's actually quite ludicrous that someone is actually using a biochemical warfare agent on a school campus. Face ity, those applying it a re required to be in full biochemical warfare battle dress, but students are exposed to the drift or may even play where it had been sprayed. They may not be eating it, but inhaling it is not good for their developing bodies.

Look how long it took the VA and the Navy to finally accept the fact that sailors on ships just a few miles off shore were being poisoned by the spraying. Monsanto / Bayer has so many big number law suits against them that it would behoove you to find a non toxic alternative to roundup.

The story Monsanto gave was you need only spray an area once and now some weeds have not only become immune to it, they practically crave it. There are alternatives to brute force poisons and although it may take longer to kill the weeds, the keiki deserve better than to be around that toxic of a substance.

Mahalo,Dave Kisor: East Hawai'i Island resident; Veteran, USN / USNR; Geographer; retired USFS wild land fire research tech.

||||||||||||||| > .̂^< |||||||||||||||Cats & computers. Bring them into your home and your life is no longer your own.Don't get upset when things don't work, but rather be amazed when they do!Life is an exercise in how well you handle disappointment!********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Debra Preston <[email protected]>

06/19/2019 03:45 PM


cc Subject Roundup/Glyophosphate use

Please stop the use of this dangerous product on all lands. This product is known to cause cancer and should not be used in any publicly accessible area.Thank you. May you find happiness, joy, and love in your life today and always. Aloha.********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Steve Phillips <steve@localharvesthawaii .com>

06/19/2019 04:34 PM


Subject Round Up

Please ban Round Up on school property. Lets keep our children safe. Thanks,

Steve PhillipsLocal Harvest, [email protected]********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

JANICE MONSON <[email protected]>

06/19/2019 05:18 PM


Subject Weed killer

Please do not poison our children with weed killers that cause cancer. The evidence is in, please keep these dangerous chemicals away from our children.

Janice Monson Grandparent and former DOE employee ********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

Marcy <[email protected]>

06/19/2019 05:52 PM


Subject Pesticides

It is extremely important that we not expose anyone, especially children to these dangerous chemicals. Thanks for your time.

Marcy Cayton


[email protected]

06/19/2019 09:06 PM


Subject Glyphosate causes cancer - ban from all schools

Dear Education Dept

A carcinogen should not be near children. Ban use of Roundup herbicide on all school grounds.

Ray Songtree

Hanalei808-378-4152********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Suzanne Skjold <[email protected]>

06/19/2019 10:04 PM


Subject Support of ban of glyphosates on school grounds

Aloha, I am writing to add my support to the experts and advocates proposing a ban on glyphosate products on school grounds. I have read respected studies and even industry documents from recent court cases, and feel the likelihood that exposure to glyphosates causes both negative health and environmental outcomes requires a ban to protect our keiki.Our standard should not be we are sure they harm keiki, but that we are sure they do NOT harm keiki (and teachers and workers) before using on school grounds. From the evidence shared in court cases and from the American Academy of Pediatricians, it seems very clear this standard to protect our children is not even close to being met.A pretty lawn is not nearly as important as cancer-free keiki, and right now the evidence suggests the price for that lawn is indeed that more children and workers will develop cancer . You can easily address this risk with a ban, as dozens of other cities and school districts are doing, and ensure our keiki can be safe from toxic chemicals when they go to school to learn.Thank you for doing all you can to protect keiki while they learn in our public schools!With aloha,Suzanne SkjoldKaimuki Resident********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Cory Harden <[email protected]>

06/19/2019 11:26 PM


Subject no pesticides

Aloha Board members,Please ban pesticides in schools. The risks are too great, and there are safe alternatives.mahalo, Cory Harden, Hilo********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Board of Education Meeting, Leilehua High School Library 1515 California Ave, Wahiawa June 24th, 2019 5-6 PM Aloha Members of the Board of Education, My name is Jun Shin. I am the Environmental Justice Action Committee Chair for the Young Progressives Demanding Action (YPDA), an organization whose members work toward building a Hawaiʻi that is just, equitable, and sustainable through community organizing and issue advocacy. The bulk of our membership, which includes more than 1,000 residents, statewide, is comprised of millennials. YPDA is grateful to the board for hosting a meeting to have an important conversation on the usage of glyphosate-based herbicides on the Department of Education (DOE) land. We appreciate that the department itself has already begun to use integrated pest management. Our keiki are our future. We need to protect the future leaders and innovators of tomorrow, alongside the school staff who create an environment where they can learn and develop. This includes the groundskeepers who may be required to spray herbicides as a job requirement. As the World Health Organization points out, unlike adults, children are at a stage where they are continuously developing their nervous systems, immune systems, digestive systems, etc and exposure to environmental toxicants can lead to irreversible damage1. Crucially, a working

group of experts from 11 countries also met at the World Health Organization’s International Agency for Research on Cancer (IARC) in March of 2015 under a strictly scientific, independent, rigorous process, and reviewed published scientific evidence while evaluating the carcinogenicity of five organophosphate insecticides and herbicides including glyphosate, with glyphosate being classified by the IARC as “probably carcinogenic to humans”2. By banning glyphosate, we would be joining several countries and U.S. municipalities who are taking the necessary steps to begin that process or who have already restricted and banned glyphosate, and other pesticides. The State of Hawaiʻi has already taken a bold stand once

before in favor of public health and protecting our keiki with the passage of Act 45 in 2018, regulating Restricted Use Pesticides (RUPs), pesticide buffer zones around schools, and the banning of Chlorpyrifos. We can take a stand once more for the benefit of present and future generations and find sustainable solutions such as transitioning to organic land management. YPDA joins the community in requesting the DOE to enact an official policy banning glyphosate-based herbicides to protect public health, and to encourage any schools who are struggling to make the transition to seek out the resources and assistance available. Thank you for the opportunity to offer comments on a very important issue, Jun Shin, Environmental Justice Action Committee Chair Young Progressives Demanding Action (YPDA) 1561 Kanunu St. Cell: 808-255-6663 Email: [email protected] CC: [email protected] 1 https://www.who.int/ceh/risks/en/

2 https://www.iarc.fr/featured-news/media-centre-iarc-news-glyphosate/

mailto:[email protected]

Merri Murphy <[email protected]>

06/20/2019 06:13 AM


Subject Toxic shcools

Please can you not use glysophate on public property? Perhaps you could also help stop the toxic spraying of geo-engineering. Please do respond with any information that might help.Mahalo, Merri********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

Jah Sunbear <[email protected]>

06/20/2019 08:53 AM


Subject Poison free schools

I support the ban on Glyphosate to protect our children while they learn in a place that we send them every day. It is wrong and irresponsible to expose them to the harmful chemicals that they spray every day on those crops

Sent from my iPhone********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

Mose orion <[email protected]>

06/20/2019 09:35 AM


cc Subject Glyphosate

Aloha, I understand that you are going to hold a discussion on the use of glyphosate at school. I would like to strongly encourage you to ban the use of it! It has and is being shown that it causes many problems to humans including cancer. Children are more affected by their environment than adults. Please do not allow the use of glyphosate anywhere near a school. Really, it needs to be banned entirely everywhere!Thank you for your time,Mose Oppenheimer, Kilauea ********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Geoffrey Last <[email protected]>

06/20/2019 12:13 PM

To "[email protected]" <[email protected]>,

cc bcc BOE Hawaii/BOE/HIDOE

Subject Round-up. Glyphosate.

Enough is enough. There is NOW to much information out there about spraying Roundup and other herbicides and pesticides and there effect on human health and the environment . It is criminal to be spraying around schools and parks let alone the highways the county should become liable for damage to community health with all this information. WAKE UP find alternative ways. Call on community for ideas and help. Pas new legislation NOW. Geoffrey Last. 35 year resident of Pahoa.Sent from my iPad********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

Sierra Knight <[email protected]>

06/20/2019 12:42 PM


cc Subject Pesticide Free Schools - Testimony

Aloha

I am a teacher for the DOE in Maui and have worked at various schools. Children and staff need to be in a safe, clean, non toxic environment. I want to beg you, implore you, appeal to your sense of decency to do the right thing: Stop all use of pesticides, herbicides, Round UP- any glyphosate product. Also, any bee harming substances. There are alternatives and now is the time to implement them. We can not knowingly poison our children when the evidence is there that they are harmful. Deadly.

I once had a student in California who lived and went to school near heavily sprayed fields, who had non-specific Hodgkins disease.just like the plaintiff who won his case. We know now this is a disease caused from glyphosate, which is used extensively in agriculture. She was an 11 year old who was dying. This was 1990. They knew this was dangerous then, Monsanto just hid the evidence. States and Counties have been using this for decades, and from here on out, they are liable for damages because the truth has been used as supportive evidence in these suits won against Monsanto.

Now many countries around the world are banning these chemicals that the Trump EPA says are just fine. Just like his ‘molecules of freedom’ for CO2, chemicals, no problem. Despite him, in the US, many cities and counties are banning glyphosate. Please take this moment and opportunity, with resources available, to implement a program on each island, a protocol expected for each school and property to be pesticide free. Be a leader in this movement to protect the aina.

Mahalo for your serious consideration. Count seven generations ahead... You are an ancestor.

Sincerely

Sierra Knight


Dani <[email protected]>

06/20/2019 01:21 PM


Subject Toxicity on our humans

PLEASE stop use of glyphosate (Round up) on state properties. I work at our elementary schools and am APPALLED whenever I see that the State of Hawaii STILL uses poisons that HAVE ALREADY BEEN BANNED IN MANY COUNTRIES! Have you not gotten the word? Thank you,Danielle Guion


Will Davis <[email protected]>

06/20/2019 01:28 PM


Subject re: Hawaii BOE please ban Roundup from public schools to protect students and avoid more law suits

Dear Hawaii Board of Education,I am a Hawaii substitute teacher. Please ban Roundup and similar toxic restricted use pesticides from Hawaii’s schools to protect students and to avoid more law suits.Let’s look at the health danger from glyphosate in Roundup. The risk of non-Hodgkin lymphoma in glyphosate-based herbicides-exposed individuals was increased by 41%, reports a new study published in Mutation Reviews / Reviews in Mutation Research, online Feb 10, 2019. The most recent court settlement against Bayer, which bought out Monsanto, was for over 2 billion dollars, for a couple that got non-Hodgkin lymphoma from exposure to glyphosate. Such law suits could be made against the Hawaii Department of Education if a child is harmed by Roundup sprayed in a school.

Glyphosate may create harm in subsequent human generations. "Assessment of Glyphosate Induced Epigenetic Transgenerational Inheritance of Pathologies and Sperm Epimutations: Generational Toxicology,” was published in Scientific Reports, 2019.In this study, toxic damage was found in 2nd and 3rd generation rats from exposure to the probable carcinogen glyphosate in the 1st generation rats. Thus, “glyphosate ... promotes generational toxicology in future generations.”Why does the Environmental Protection Agency promote glyphosate? They are working for Monsanto, not the public good, as the following study proves. Environmental Sciences Europe, published in 2019, "How did the US EPA and IARC reach diametrically opposed conclusions on the genotoxicity of glyphosate-based herbicides?” The paper details why the EPA and International Agency for Research on Cancer (IARC) differ regarding glyphosate and cancer. The EPA which used unpublished industry sources found 99% of evidence that glyphosate is not genotoxic. The IARC relied on published studies and found 74% of which indicate glyphosate is genotoxic. This paper shows that the EPA’s cancer classification is scientifically baseless.Please see the following recent letter in The Garden Island which explains the inverse correlation between pesticides exposure and IQ scores. As

serum levels of pesticides go up, IQ scores go down:https://www.thegardenisland.com/2019/06/14/opinion/understanding-pesticides-can-be-complex/Thus if the Hawaii Department of Education abides by the EPA and promotes glyphosate in school yards or playgrounds, this could damage school children. Furthermore, it should be evident, damage to children by glyphosate in school yards could result in law suits against the Hawaii Department of Education.Banning glyphosate and other neurotoxic pesticides in schools will help create healthy, happy, productive, and brilliant kids for a better world.Thank you.Sincerely,Will M. Davis4215 Hoala St., Apt. 101Lihue, HI [email protected]********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

[email protected] by: [email protected]

06/20/2019 04:34 PMPlease respond to

[email protected]


Subject Re: BOE meeting on 6/24. Ban pesticides on school grounds!

Dear Hawaii Board of Education,

Aloha Board Members,

Mahalo for hosting a meeting to discuss the use of pesticides in DOE schools. We appreciate the efforts the DOE has taken to use integrated pest management (IPM).

It's clear that better safety measures must, and can, be taken to protect tour keiki. Scientific evidence shows that exposure to pesticides is linked to cancer and other illnesses. As a person in the landscape, so-called "green" industry, I'm appalled that there is still potential exposure to the keiki and school staff, in particular groundskeepers, who may be required to spray as a requirement of their job.

This is not reinventing the wheel, even though Hawaii has the dubious distinction of using the most Roundup in the country. Many other towns and school districts have taken similar steps to protect public health by banning pesticides and have successfully transitioned to organic land management practices, even in climates similar to Hawaii with little to no cost difference.

Please ban and replace Glyphosphate aka Roundup with better, less toxic pesticides that will protect public health by helping to make the transition to seek out resources and assistance more available to all schools.

Mahalo for your consideration.

Sincerely,janice palma-glenniePO Box 4849 Kailua Kona, HI 96745-4849********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

chris hayden <[email protected]>

06/20/2019 07:24 PM


cc Subject Please ban glyphosate

Please ban glyphosate use on school campuses.

Sent from my iPhone********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection. ********************************************************************************

Norris Thomlinson <[email protected]>

06/20/2019 10:02 PM


Subject Please ban glyphosate use on DOE land

1 attachment

signature.ascsignature.asc

Aloha Board,

I've felt concerned for several years about the use in landscaping of chemical herbicides such as those based on glyphosate. I'm very glad to hear you're already minimizing use of poisons, and that you're considering ending the use of glyphosate altogether. I strongly support a transition to safer landscaping practices. This would benefit our especially-vulnerable children, as well as adult landscaping workers, teachers & other staff, and members of the public like myself who spend time on school grounds visiting public libraries.

Mahalo for your attention to this important health and environmental issue,

Norris ThomlinsonPahoa, Hawai'i********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

clare loprinzi <[email protected]>

06/21/2019 03:25 AM


cc Subject malama na keiki


O Clare Loprinzi kou inoa. I worked on this issue 35 years ago in Oregon and it was done. We need to stop poisoning our keiki. As a healthcare provider and traditional midwife I demand you to do the right thing, There is so much overwhelming proof that the pesticides are toxic but also that the younger the children are the more it effects them, including the baby in the puna state( womb). Thank you for hosting a meeting to discuss the use of glyphosate-based herbicides on DOE land. I appreciate the efforts the DOE has already taken to use integrated pest management.

Please enact an official policy banning glyphosate-based herbicides to protect public health and encourage any schools who are struggling to make the transition to seek out resources and assistance available.

Mahalo Clare Loprinzi


Linda Morgan <[email protected]>

06/21/2019 08:50 AM


Subject Glyphosate use at schools

Although some scientific studies conclude that glyphosate is nontoxic, other research indicates a correlation between exposure to glyphosate and many chronic diseases, including cancer, asthma, ADHD, diabetes, obesity, autism, ALS, and more. Since it's use is possibly/probably harmful to human health, and alternative methods of weed control are both available and cost effective, I support the ban of the use of glyphosate containing herbicides on all public school grounds. I cringe when I see it being sprayed at Na'alehu Elementary where I work. It is our job to provide a school environment safe from health hazardous chemicals. Please ban the use of glyphosate-based herbicides at Hawaii schools.Linda MorganP.O. Box 377406Ocean View, HI 96737********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

"Cynthia K. Hathaway" <[email protected]>

06/21/2019 01:09 PM


Subject Ban glyphosate

Aloha Board of Education,

I strongly encourage Hawaii Board of Education to ban glyphosate-based herbicidesuse on public school campuses. I am a secondary teacher in Hilo. We now know there are dangers associated with the use of glyphosate, why continue to use it?Our keiki deserve better than poison, we all do. As a tax payer, I strongly object to supporting the status quo/Monsanto with my my tax dollars Our state of Hawaii is best suited to set examples for our nation because we possess intrinsic values reflecting a heritage of our own,.. those values can impact the world if we stay true to them and call upon our courage for change. Let us lead the way towards healthy bodies, healthy minds, and a healthy environment.Thank you.Cynthia HathawayKea’au, Hawaii. 96749


Sacral Wizard <[email protected]>

06/21/2019 02:12 PM

To BOE_Hawaii <[email protected]>

cc Subject Please stop using Roundup or

Pesticides on school Property


My name is Val Hertzog and I am a resident of Kapaa. I have been a teacher on the island of Kauai since 2008. Currently, I teach at St.Catherine School in Kapaa. This subject is extremely important to me as an educator. I want to see the children I teach to grow up without any illnesses, diseases or cancers. Although I am currently teaching at a private school, I hope this passes so I can share with my administrators how the DOE protects their keiki.

Thank you for hosting a meeting to discuss the use of glyphosate-based herbicides on DOE land. I appreciate the efforts the DOE has already taken to use integrated pest management.

An overwhelming body of evidence has demonstrated that exposure to glyphosate-based herbicides is linked to cancer and other illnesses. I am concerned about the potential exposure to the keiki and school staff, in particular groundskeepers who may be required to spray as a requirement of their job.Please click on the link below and or print out a copy for your meeting regarding spraying pesticides on school grounds.http://www.panna.org/resources/schools-playgrounds#.XQ1lAWToU0Z.emailMany other towns and school districts have taken similar steps to protect public health by banning glyphosate and other pesticides and have successfully transitioned to organic land management practices, even in climates similar to Hawaii with little to no cost difference.

Please enact an official policy banning glyphosate-based herbicides to protect public health and encourage any schools who are struggling to make the transition to seek out resources and assistance available.


Sincerely,Val Hertzog, Island of Kauai ********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

The Hawai‘i Alliance for Progressive Action (HAPA) is a public non-profit organization under Section 501(c)(3) of the Internal Revenue Code. HAPA’s mission is to catalyze community empowerment and systemic change towards valuing ‘aina (environment) and people ahead of corporate profit.

June 21, 2019

Hawaii State Board of Education PO Box 2360 Honolulu, HI 96804 Re: BOE policy regarding glyphosate use on DOE land


Thank you for hosting a meeting to discuss the use of glyphosate on DOE school grounds.

On behalf of the Hawaii Alliance for Progressive Action (HAPA) we respectfully encourage the BOE to formally adopt a policy banning the use of glyphosate on DOE land / public school campuses.

From our preliminary e-mail correspondence with the DOE facilities staff it is clear that the DOE has taken important steps to minimize pesticide use, and to train school groundskeepers in other less or non-toxic Integrated Pest Management practices, that seek to use pesticides as a last resort. HAPA applauds the DOE for these efforts.

However, given the increasing number of studies that demonstrate the health risks associated with glyphosate, we would encourage the board to join the dozens of other municipalities and school districts across the county and move towards formalizing a policy that bans glyphosate use on school campuses/DOE property all together.

According to a 2012 report by the American Academy of Pediatrics (AAP) entitled “Pesticide Exposure in Children,” “Children encounter pesticides daily and have unique susceptibilities to their potential toxicity. Acute poisoning risks are clear, and understanding of chronic health implications from both acute and chronic exposure are emerging. Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.” [1] As for glyphosate, there's a growing body of evidence on health impacts associated with exposure to glyphosate-based herbicides such as “Roundup,” including endocrine disruption, organ damage and birth defects.

Board of Directors: Gary L. Hooser President Andrea N. Brower Ikaika M. Hussey Co-Vice Presidents Kim Coco Iwamoto Treasurer Bart E. Dame Secretary Paul Achitoff Kaleikoa Kaʻeo Michael Miranda Walter Ritte Jr. Pua Rossi-Fukino Karen Shishido Leslie Malulani Shizue Miki

The Hawai‘i Alliance for Progressive Action (HAPA) is a public non-profit organization under Section 501(c)(3) of the Internal Revenue Code. HAPA’s mission is to catalyze community empowerment and systemic change towards valuing ‘aina (environment) and people ahead of corporate profit.

In 2015, the International Agency for Research on Cancer, a division of the World Health Organization, and the world’s leading authority on cancer, unanimously concluded that glyphosate is “probably carcinogenic to humans.” [2]

Today more than 13,000 plaintiffs have filed suit against Monsanto in the United States alleging they developed non-Hodgkin lymphoma due to exposure to Monsanto’s glyphosate-based weed killers, such as Roundup. Of the three cases that have been heard to date, in each case juries have found in favor of the plaintiffs. Internal industry documents uncovered during these trials have revealed that Monsanto suppressed evidence of health risks of its herbicides.

School groundskeepers are another at-risk population due to their potential exposure on the job. For example, DeWayne “Lee” Johnson is a former California school groundskeeper who was regularly exposed to glyphosate on the job and was diagnosed with terminal non-Hodgkin lymphoma. He was the first plaintiff to successfully sue Monsanto for his cancer. Today he is taking what time he has left to educate other groundskeepers on the health risks. It is worth noting that Mr. Johnson’s job description was also referred to as “Integrated Pest Management”, yet still required regular pesticide use.

Many other towns and school districts have taken similar steps to protect public health by banning glyphosate and have successfully transitioned to organic land management practices, even in climates similar to Hawaii with little to no cost difference. [3]

Resources are currently available to provide additional trainings for any schools who might have difficulties transitioning away from herbicide use. We welcome the opportunity to partner with the DOE/BOE and bring additional resources, such as experts in organic land management practices, to assist as needed.

Mahalo for your consideration and please do not hesitate to reach out if we can be of assistance.

Sincerely,

Anne Frederick, Executive Director References:

[1] American Academy of Pediatrics, Pesticide Exposure in Children, December 2012, vol. 130, issue 6. [2] World Health Organization, International Agency for Research on Cancer, IARC Monographs Volume 112: evaluation of five organophosphate insecticides and herbicides, 20 March 2015. [3] https://www.baumhedlundlaw.com/toxic-tort-law/monsanto-roundup-lawsuit/where-is-glyphosate-banned/

Kris Coffield, Chair · David Negaard, Vice Chair · Mireille Ellsworth, Secretary · Amber Adjuja, Treasurer · Marcia Linville, Non-Male SCC Representative · Justin Hughey, Non-Female SCC Representative

REGULATION OF GLYPHOSATE USE ON PUBLIC SCHOOL CAMPUSES

JUNE 24, 2019 · HAWAI ’ I BOARD OF EDUCATION COMMUNITY MEETING · CHAIR CATHERINE PAYNE

POSITION: Please place a policy banning the use of glyphosate-based pesticides and requiring

training for appropriate Hawai’i Department of Education personnel on a future BOE agenda.

RATIONALE: Glyphosate kills. Glyphosate-containing herbicides and products, including

Roundup, are used for landscaping purposes throughout the State, including on public school

campuses. Yet, the World Health Organization's International Agency for Research on Cancer’s

Monograph 112, published in 2017, states that there is evidence in humans for the carcinogenicity

of glyphosate, which has been positively associated with non-Hodgkin lymphoma.

Moreover, IARC Monograph 112 further contends that there is sufficient evidence of the

carcinogenicity of glyphosate in experimental animals to conclude that a causal relationship has

been established between exposure to the agent and human cancer. To protect its citizens, in

2017, the State of California added glyphosate to a list of chemicals recognized as carcinogens

in the California Labor Code and under California's Proposition 65, also known as the Safe

Drinking Water and Toxic Enforcement Act of 1986.

In 2018, a California trial court upheld an award of $78.5 million in damages to Lee Johnson, a

school groundskeeper, after a jury determined he contracted non-Hodgkin lymphoma through

repeated exposure to glyphosate-containing herbicides he applied throughout his school district.

2

This decision was followed by a similar verdict in 2019, in which a California jury awarded $2

billion to Alva and Alberta Pilliod, finding that the couple’s use of Roundup over thirty years for

residential landscaping substantially impacted their development of non-Hodgkin’s lymphoma.

At least sixty-one cities, counties, and communities across twenty-two states, and twenty-seven

countries worldwide, have moved to halt or restrict the use of glyphosate on public lands due to

environmental and human health risks. It’s time for the HIDOE to do the same. To that end, we

are asking you to place a policy banning the use of glyphosate-based pesticides and requiring

training for appropriate Hawai’i Department of Education personnel on a future BOE agenda. We

have included proposed policy language below for your consideration. Let’s preserve our

children’s health by moving the department toward pesticide-free schools.

We are committed to delivering a quality education for all of our islands’ keiki. That includes

ensuring that they are safe from cancer-causing chemicals.

POLICY 305-XX

PESTICIDE USE AND SAFETY The Department of Education shall implement a pesticide safety program that protects the health

and welfare of students and employees. To the greatest extent possible, the department shall

curtail the use of pesticides for turf, landscape, and outdoor pest management.

Pesticides containing glyphosate shall not be used on any school campus or other Department of

Education property. The Department shall provide annual training to all appropriate school

personnel, including educational officers and school custodians, in pesticide safety, restrictions,

and regulations.

In situations that threaten the public health and safety or for the control of invasive species that

pose a threat to the environment, a school may request a waiver from the provisions of this policy.

All requests for waivers from this policy shall be subject to Board approval.

3

This policy shall apply to any substance or mixture of substances intended for preventing,

destroying, repelling, or mitigating any pest; any substance or mixture of substances intended for

use as a plant regulator, defoliant, or desiccant; herbicides; fungicides; insecticides; and

rodenticides.

The Superintendent of Education is instructed to establish regulations, guidelines, or both to

implement this policy.

Teaching Today for Hawaii’s Tomorrow

1200 Ala Kapuna Street Honolulu, Hawaii 96819

Tel: (808) 833-2711 Fax: (808) 839-7106 Web: www.hsta.org

Corey Rosenlee

President

Osa Tui Jr. Vice President

Logan Okita

Secretary-Treasurer

Wilbert Holck Executive Director

Chair Payne and Members of the Board of Education:

The Hawaii State Teachers Association requests that the BOE put a policy in

place restricting the use of harmful herbicides and pesticides on our

public school campuses, and this topic to be put on the next BOE meeting

agenda as an action item. [See Attached proposed policy] This policy should

not only require the Department of Education to report its current usage and plans

for future usage of glyphosate and glyphosate-containing herbicides on and around

Department of Education properties, including schools and playgrounds, but it

should also restrict the use of these dangerous chemicals.

The World Health Organization's International Agency for Research on

Cancer (IARC) evaluated the carcinogenic risks of glyphosate, and IARC

Monograph 112, published in 2017, classified glyphosate as probably

carcinogenic to humans, stating that there is limited evidence in humans

for the carcinogenicity of glyphosate, and a positive association has been

observed for non-Hodgkin lymphoma. These chemicals should not be used

in and around our public schools which could cause health risks for our

students, staff, teachers, and community members.

Yet, in Hawai'i, pesticide misuse continually endangers the well-being of our keiki.

According to an investigation conducted by the Cascadia Times, pesticide

application at large agrochemical companies on Kaua'i is ten times the national

average and includes the neurotoxins chlorpyrifos, atrazine, and paraquat, which

have been linked to developmental disabilities in young children.

Pesticides also waft over school communities and sicken our students, after being

sprayed on windy days. In 2007, for example, nearly a dozen students at Kahuku

High and Intermediate fell ill when a nearby farmer ignored windy weather while

applying restricted use pesticides. In 2008, in Waimea on Kaua'i, dozens of students

TESTIMONY BEFORE THE BOARD OF EDUCATION

RE: The use and regulation of herbicides and pesticides on our public school campuses

MONDAY, JUNE 24, 2019

COREY ROSENLEE, PRESIDENT

HAWAII STATE TEACHERS ASSOCIATION

Teaching Today for Hawaii’s Tomorrow

1200 Ala Kapuna Street Honolulu, Hawaii 96819

Tel: (808) 833-2711 Fax: (808) 839-7106 Web: www.hsta.org

Corey Rosenlee

President

Osa Tui Jr. Vice President

Logan Okita

Secretary-Treasurer

Wilbert Holck Executive Director

got sick after farmers applied pesticides on a nearby seed corn plot. Therefore these

chemicals should definitely not be used on nor around our public school campuses,

This policy is one step that is imperative toward first knowing what is being used,

or being planned on being used, and taking action to eliminate this unnecessary

threat to the safety of our keiki, our teachers, and everyone in our public schools.

The Hawaii State Teachers Association asks that your committee to allow this

item, to create this new policy, to be put on its next agenda as an action

item as we feel our community, our teachers, and our students deserve to have this

information as it could affect their health, and a restrictive policy to protect them

from future use of these products.

POLICY 305-XX

PESTICIDE USE AND SAFETY

The Department of Education shall implement a pesticide safety program that protects the health and welfare of students and employees. To the greatest extent possible, the department shall curtail the use of pesticides for turf, landscape, and outdoor pest management. Pesticides containing glyphosate shall not be used on any school campus or other Department of Education property. The Department shall provide annual training to all appropriate school personnel, including educational officers and school custodians, in pesticide safety, restrictions, and regulations. In situations that threaten the public health and safety or for the control of invasive species that pose a threat to the environment, a school may request a waiver from the provisions of this policy. All requests for waivers from this policy shall be subject to Board approval. This policy shall apply to any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest; any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant; herbicides; fungicides; insecticides; and rodenticides. The Superintendent of Education is instructed to establish regulations, guidelines, or both to implement this policy.

HOUSE OF REPRESENTATIVES

STATE OF HAWAII

STATE CAPITOL HONOLULU, HAWAII 96813

June 24, 2019

TESTIMONY FOR: Hawai’i Board of Education Members FROM: Rep. Amy Perruso (D-46, Wahiawā, Whitmore Village, Launani Valley) SUBJECT: Use of glyphosate-based pesticides on public schools During the 2019 legislative session, I served as Vice Chair of the Lower and Higher Education Committee for the Hawai’i House of Representatives. Part of my responsibilities including chairing hearings related to resolutions referred to LHE. On March 18, I heard House Concurrent Resolution 119 and House Resolution 109, which called upon the Hawai’i Department of Education to report on its use of glyphosate-based herbicides, like Roundup, on public school properties. At the hearing, DOE officials stated that such herbicides were prohibited under departmental policy. Accordingly, I deferred the resolutions. My office later learned, however, that such prohibitions do not exist, leading to the continued use of Roundup at public schools. In response to this information, I moved to reconsider my previous deferrals on March 25 and pass both resolutions unamended. LHE members voted unanimously to support my recommendation. We know that glyphosate-based herbicides are harmful to our keiki. In 2018, a California jury awarded $78.5 million to Lee Johnson, a school groundskeeper, after finding that he contracted non-Hodgkin lymphoma through repeated exposure to glyphosate-containing herbicides he applied throughout the school district in which he worked. In 2019, a similar decision was made in which a California jury awarded $2 billion to Alva and Alberta Pilliod, who developed non-Hodgkin’s lymphoma after using Roundup during thirty years of residential landscaping. HIDOE has a responsibility to keep our keiki safe from danger, including harmful pesticides. Therefore, I am asking you to place a policy banning the use of glyphosate-based pesticides and requiring training for appropriate Hawai’i Department of Education personnel on a future BOE agenda. I have included proposed policy language below for your consideration.

Let’s partner with community members to create pesticide-free schools. Our children’s health can’t afford for us to wait.

POLICY 305-XX

PESTICIDE USE AND SAFETY The Department of Education shall implement a pesticide safety program that protects the health and welfare of students and employees. To the greatest extent possible, the department shall curtail the use of pesticides for turf, landscape, and outdoor pest management. Pesticides containing glyphosate shall not be used on any school campus or other Department of Education property. The Department shall provide annual training to all appropriate school personnel, including educational officers and school custodians, in pesticide safety, restrictions, and regulations. In situations that threaten the public health and safety or for the control of invasive species that pose a threat to the environment, a school may request a waiver from the provisions of this policy. All requests for waivers from this policy shall be subject to Board approval. This policy shall apply to any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest; any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant; herbicides; fungicides; insecticides; and rodenticides. The Superintendent of Education is instructed to establish regulations, guidelines, or both to implement this policy. Sincerely,

Amy Perruso Rep. Amy Perruso

Stephanie Seneff <[email protected]>

06/21/2019 05:06 PM


Subject glyphosate use on DOE land.


First of all, I want to thank you for hosting a meeting to discuss the use of glyphosate-based herbicides on DOE land. I appreciate the efforts the DOE has already taken to use integrated pest management.

My name is Stephanie Seneff and I am a part-time resident of Princeville. I am also a Senior Research Scientist at MIT, and my current work focuses on the toxicity of glyphosate to humans. I am finding that glyphosate is far more toxic than we have been led to believe, and it is arguably a causal factor in many autoimmune, neurological and metabolic diseases, in addition to its now well acknowledged effects as a carcinogen, as judged by the successful lawsuits in California.

Glyphosate use on core crops has increased alarmingly in the past two decades, almost exactly in step with the rise in autism rates. While correlation does not always mean causation, there are now many published papers that show that glyphosate causes multiple disruptions in human health that are known to be features of autism. Many other chronic diseases are also increasing alarmingly in recent times, and I believe that glyphosate is a major contributor to these increases.

I am therefore very concerned about the potential exposure to the keiki and staff in Kauai's public schools. Furthermore, the groundskeepers are at special risk, as their job requirement may include spraying glyphosate, putting them potentially in direct skin contact or exposure by breathing the glyphosate fumes.

It is gratifying to me that many cities and towns around the country are starting to legislate restrictions in the use of glyphosate in public areas. These communities are finding effective and economical organic land management practices to control weeds without harming the environment. Kauai is a beautiful island with many species of birds, amphibians and sea life that are also in harm's way when glyphosate is used.

I hope you will see that it is imperative to restrict the use of glyphosate, and an official policy of banning glyphosate will be a terrific step towards assuring that our keiki are protected from harm, and that the Kauai environment, both land and sea, remains healthy and vital.


Sincerely,Stephanie Seneff, Princeville.

-- Stephanie SeneffSenior Research ScientistMIT Computer Science and Artificial Intelligence Laboratory********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted

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Shilla <[email protected]>

06/21/2019 06:29 PMPlease respond to

"[email protected]" <[email protected]>


cc Subject No-spray schools

Dear Board Members,My name is Shilla Romero and I am a resident of Laupahoehoe, Hawaii.Please enact an official policy banning pesticides to protect public health. There is an overwhelming body of evidence proving the link to cancer and other illnesses. Mahalo for your consideration.********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Sky Ardee <[email protected]>

06/22/2019 05:00 AM


Subject re: Glyphosate on School Grounds

To whom it may concern,I'm writing to urge the BOE to please strongly consider implementing a complete ban on the use of glyphosate-based herbicides (along with all other routine-use pesticides) on school properties. I'm the father of a little boy who loves to explore outside and stick stuff in his mouth; given the known and unknown hazards of the chemical and the particular vulnerability of keiki--both to frequent exposure while playing outside and to all forms of poisoning due to their smaller body size--eliminating this unnecessary and toxic substance from areas where children play seems like a complete "no-brainer."Mahalo for your consideration.Respectfully,S. Roversi-Dealconcerned father and farmer********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Diane Koerner <[email protected]>

06/22/2019 08:04 AM


cc Subject Fw: Glyphosate Testimony & Facts for

Monday's Meeting


My name is Peggy Kadey. I live in Kapaa. I am a senior who loves our children, all animals and the land.

There is conclusive evidence that Roundup and other glyphosate containing products are extremely dangerous to our health. Over the last 15 years I have collected hundreds of pages of information on Roundup. These include incidents of injury, news articles, facts on ingredients, and how other communities are banning Glyphosate products.My husband and I began a support group for the chemically injured in 2003. We did not expect to receive calls from people who had just experienced injury or witnessed injury to animals after our county sprayed Roundup Pro, but that’s what happened. There is a high rate of asthma among the children who live in Hawaii. Their lungs are fragile. Damage to lungs opens up their little bodies to take in more poison. I understand since my lungs have been injured by chemicals. No one can do their best work when they are suffering. Why would we want to spray poison near those we love?Monsanto, in a letter to NCAP admits that “Isopropylamine salt of glyphosate, the active ingredient in Roundup herbicide, makes up 41% of the formulation Excess isopropylamine is present at about 0.5% of the Roundup formulation.”The MSDS on Isoproptlamine says under acute effects, “Harmful if swallowed, inhaled, or absorbed through skin. Material is extremely destructive to tissue of the mucous membranes and upper respiratory tract, eyes and skin.”

“The surfactant makes up 15.4 percent of the Roundup formulation.” The surfactant is polyethoxylated tallowamine (POEA). It causes eye burns, skin redness, swelling, blistering, nausea, and diarrhea according to information gathered by the Journal of Pesticide Reform, fall 1998 issue,VOL.19, No. 3 .

I would be glad to scan and send supporting documents at your request.Peter Soares worked for the Kauai County Parks spraying Roundup under the fence lines. He knew it was very poisonous. He developed ALS. He and I were friends the year before he died. He remembers feeling sick as he tried to continue doing what the county had ordered him to do. He risked his life for his job.It is time to think about what we are doing as a state. Rachael Carson knew this was coming when she wrote “Silent Spring”. Mankind needs to make wiser decisions for the sake of our children. Please do the right thing and stop spraying herbicides at our schools.Very sincerely,

Peggy Kadey

President of Kauai Network for the Chemically Injured5345 Luana Street, Kapaa, HI 96746********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You

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Joseph Kohn MD <[email protected]>Sent by: Joseph Kohn MD <[email protected]>

06/22/2019 10:10 AM


cc Subject No Toxic Pesticides on School

Campuses

Join the dozens of other municipalities and school districts who have already adopted policies to ban the use of glyphosate‐based herbicides. They are not safe for humans or our environment. Ignoring the data will expose BOE members to personal financial liability for any harmful effects.

A growing body of peer reviewed studies and internal industry documents released through recent court cases have revealed disturbing health and environmental risks associated with exposure to glyphosate‐based herbicides.

The American Academy of Pediatricians has flagged concerns about the heightened susceptibility of children to the toxicity of pesticides both in acute incidents and low‐level chronic exposure and cited the need for government bodies to take greater action to prevent exposure. The International Agency for Research on Cancer has identified glyphosate as a probable known carcinogen since 2015.

School groundskeepers are another vulnerable population who may be regularly exposed to glyphosate as a requirement of their job. Recently DeWayne “Lee” Johnson a former school groundskeeper in California became the first plaintiff to successfully sue Monsanto/Bayer for the cause of his non‐Hodgkin lymphoma.

At the meeting on the 24th groundskeepers implementing organic land management practices will be on hand to share how they have successfully transitioned away from glyphosate use with little to no cost difference.

There is no rational reason to pollute our own environment or destroy ecosystems.

Thank you for your very kind attention.

Joseph Kohn MDFounder, We Are One, Inc. ‐ www.WeAreOne.cc ‐ WAO493 Pio Dr Apt 209Wailuku, HI 96793‐2641808‐359‐6605 [email protected]

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Christine Ahia <[email protected]>

06/22/2019 04:51 PM


Subject Please ban the use of glyphosate-based herbicides

Aloha,I’d like to encourage you to completely ban the use of glyphosate-based herbicides in our public schools. As more and more research indicates, our students have an elevated susceptibility to the toxicity in these herbicides. Not only are students routinely exposed to spraying, the custodians and groundskeepers are also very much at risk. Other faculty are exposed to these toxins too on campuses.We claim to be interested in promoting good health practices and habits on our campuses, so this would be an extension of this thinking that would benefit everyone on the school grounds.I worked for the DOE on O’ahu and in several East Hawai’i schools for close to 20 years and my children attended DOE schools. We do not want to have public school attendance as a risk factor for cancer in students, custodians, and faculty members. I strongly ask you to consider mandating the use of nontoxic products throughout our campuses.

Sincerely,Christine Ahia


Victor Zue <[email protected]>

06/22/2019 05:00 PM


Subject Gyphosate use on DOE land

Aloha, Board Members:

My wife and I own a home in Princeville, HI, and we spend about half of our time here. We have been aware of the danger of Glyphosate ever since Bill 2491, and have been strong supporters of banning it worldwide. In recent years, Glyphosate is fast becoming known as the worst of all pesticides/herbicides for all living things, as well as the good earth. We cannot believe that anyone would consider applying it anywhere, much less near schools!

Hawaii in general and Kauai in particular has been in the forefront of protecting our people and our land. Please do the right thing by banning its use near schools.

Mahalo nui loa.

Victor Zue, 4041 Aloalii Drive, Princeville, HI 96722

--

Victor

===========================================Victor ZuePrincipal Investigator, CSAILDelta Electronics Professor, EECSMassachusetts Institute of TechnologyPhone: +1.617.253.8513Assistant: Marcia Davidson ([email protected]; +1.617.253.3049)===========================================


Patricia Fallbeck <[email protected]>

06/22/2019 06:47 PM


Subject Poison

Sent from my iPhone

Begin forwarded message:

To: The Board of EducationRE: Use of Round-up on school groundsWe have just achieved a control on glyphosates in the State and it is my understanding you are proposing using it on school grounds where children, teachers, and staff can be exposed to its detrimental effects. I hope this is an error in reporting. I am a former educator and this issue is of great concern to me.Please inform me of the misconception or your reason for proceeding with this kind of plan.A rerply to this email is greatly appreciated!Dr. Patricia FallbeckProfessor Emeritus3448 Laawailoa LaneKoloa, HI, 96756

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I am John Routt Reigart, MD, Fellow American Academy of Pediatrics. Professor Emeritus of Pediatrics, Medical University of South Carolina I have worked to protect children from Environmental Hazards for 50 Years. Among other activities I was the first Chair of the US Environmental Protection Agency’s Children’s Health Protection Advisory Committee. I also have Co-authored the Fifth and Sixth Edition of the EPA Publication: Recognition and Management of Pesticide Poisonings. I was the first chair of the board of the Children’s Environmental Health Network (for 20 years) a National NGO. I am presently President of the Board of Beyond Pesticides, another NGO. I have chaired the American Academy of Pediatrics Committee on Environmental Health. Children are at great risk from toxic chemicals, including pesticides, for many reasons. They have many years of and after exposure to express the results of pesticide exposures. As developing humans, they are at risk for disruption of critical development of their organ systems, including their brains and other portions of their nervous system. I recently was the senior author of a publication reviewing the evidence regarding the relationship between early life pesticide exposure and Autism Spectrum Disorder and ADHD. (Children's low-level pesticide exposure and associations with autism and ADHD: a review. Roberts JR, Dawley EH, Reigart JR. Pediatric Research. 2019 Jan; 85(2):234-241.) For carcinogens, the time between exposure and onset of the disease may be many years and children have many years to express this outcome Children differ also in their absorption and metabolism of toxic materials including pesticides. They eat for food for their body weight than adults. They breathe more. They drink far more water and other fluids for their size. The have more skin area for their weight and have thinner skin that more readily absorbs chemicals. They spend more time close to the floor and soil. For these and many more reasons it is critically important to eliminate or at least limit children’s exposure to pesticides. In my own community, Mount Pleasant, SC, we have already drastically decreased use of exposure to pesticides in our playing fields. We are in the process of converting to a total organic system in managing playing fields where children and adolescents play. I believe it is critical that the Board of Education eliminate the use of glyphosate (Round Up and other formulations) on Department of Education land. Glyphosate has multiple likely and proven adverse effects. The most concerning well documented effect is that Glyphosate has been deemed a probable human carcinogen by IARC – the International Agency for Research on Cancer. Due to these toxicities my community has almost totally eliminated the use of Glyphosate and never uses it in any place where children might be exposed either directly or indirectly by mechanisms such as runoff. We are just one of the many municipalities and other public entities that have eliminated exposure to glyphosate. The Board of Education should likewise protect children in its schools and playing fields from exposure to glyphosate.

Sincerely, J. Routt Reigart, MD. FAAP 812 Harbour Watch Court Mount Pleasant, SC Phone 843-693-0658 6/23/2019

https://www.ncbi.nlm.nih.gov/pubmed/30337670

https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=2ahUKEwin5vOG-v_iAhXKT98KHYtyDBYQFjAAegQIBxAC&url=https%3A%2F%2Fwww.iarc.fr%2F&usg=AOvVaw0SNettF24ixZK8uESj-edc






Joyce Kehoe Smith <[email protected]>

06/23/2019 12:01 PM


Subject Non-toxic Hawaii Schools

As a parent, I support non-toxic Hawaii schoolsNo spray or round up near, in, or around schools.Also, healthier cleaning products.We need to protect our children.Joyce Kehoe Smith********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

marghee maupin <[email protected]>

06/23/2019 01:39 PM


cc marghee maupin <[email protected]>

Subject Pesticide spraying in schools

I am writing to you with great concerns about the health of children on Kauai that is threatened by the cocktails of pesticides that are sprayed on school grounds. I am a primary care provider and I have a mobile primary care business where I see children and families from all over the island. It is very difficult to determine the causes of their symptoms and illnesses when it is not clear what they are exposed to (for instance at a public school) on a regular basis. These toxic chemicals are known to negatively impact the life of animals, plants and human beings. Children are especially vulnerable to the effects of chemical exposure, because their bodies and minds are still developing. They also tend to spend more time closer to the ground where the chemicals have been applied, or where they have settled. There has been minimal research done looking at the effects of low level chemical exposure over a long period of time, not to mention the exposure of multiple chemicals layered (or mixed together), which scientifically creates novel and unknown compounds that we cannot determine the comprehensive effects of. Besides the dangers to children, dangers are present for the school staff and groundskeepers. The man who was working as a school groundskeeper was initially awarded close to 300 million dollars after he was poisoned with toxic chemicals while working as a groundskeeper. He is now dying. The department of education is opening themselves up to lawsuits such as this. If for no other reason, the spraying should be stopped immediately, because I do not believe the Department of Education has the funds to fight cases that could cost them millions of dollars for each case. It makes sense to stop using the poison (that is dangerous to all life) in schools where children are growing and learning, and use the funds that are spent on the chemicals for groundskeeping that is toxic free. Aloha,Marghee Maupin, APRNPrimary Care Provider, Kauaiwww.marghee.com

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1

Statement

by Beyond Pesticides to Hawai’i Board of Education

State of Hawai’i on

Pesticide Use on Hawai’i School Campuses June 24, 2019

Thank you for convening this meeting to discuss the use of pesticides, including the

use of glyphosate-‐based herbicides on Department of Education (DOE) land. We urge the Board to adopt clear policies that eliminate the use of hazardous pesticides and require the adoption of organic practices for managing playing fields, landscapes, and buildings. The use of the herbicide glyphosate and its associated hazards represent serious deficiencies with our federal and state regulatory controls and calls for the direct involvement of the Board of Education to protect children and those working in the school system. Children are especially vulnerable to pesticides’ adverse effects, from chronic diseases to learning disabilities, because they take in more pesticides than adults relative to body weight and are going through developmental phases of life.

We submit this statement on behalf of our members in Hawai’i. Founded in 1981 as a

national, grassroots, membership organization that represents community-‐based organizations and a range of people seeking to bridge the interests of consumers, farmers and farmworkers, Beyond Pesticides advances improved protections from pesticides and alternative pest management strategies that eliminate a reliance on pesticides. Our membership and network span Hawai’i and the nation. With respect to glyphosate-‐based herbicides, an overwhelming body of evidence has demonstrated that exposure to the herbicide is linked to cancer and other illnesses. We are concerned about the potential exposure to the students and school staff, in particular groundskeepers who may be required to spray as a requirement of their job. Many towns and school districts have taken steps to protect public health by banning glyphosate and other pesticides and have successfully transitioned to organic land management practices, even in climates similar to Hawai’i with little to no cost difference.

Children’s Unique Vulnerability to Pesticides Children face unique dangers from pesticide exposure. In 2012, the American Academy of Pediatrics (AAP) released a landmark policy statement, Pesticide Exposure in Children, on the health impacts of pesticide use around children, acknowledging the risks posed by both acute

2

and chronic exposure.1 AAP’s statement notes that, “Children encounter pesticides daily and have unique susceptibilities to their potential toxicity.” The report discusses how kids are exposed to pesticides every day in air, food, dust, and soil. Children also frequently come into contact with pesticide residues on treated lawns, playing fields, pets, and indoor spaces. As the U.S. Environmental Protection Agency (EPA) points out in its document, Pesticides and Their Impact on Children: Key Facts and Talking Points:2

• “Due to key differences in physiology and behavior, children are more susceptible to environmental hazards than adults.”

• “Children spend more time outdoors on grass, playing fields, and play equipment where pesticides may be present.”

• “Children’s hand-‐to-‐mouth contact is more frequent, exposing them to toxins through ingestion.”

As far back as 1993, the National Academy of Sciences reported that children were more susceptible to chemicals than adults, estimating that 50% of lifetime pesticide exposures occur during the first five years of life.3 In 1999, researchers knew that children’s developing organs created “early windows of great vulnerability” during which exposure to pesticides can cause great damage.4 While these facts are not new, there has been little action by lawmakers to adequately address these risks. Speaking in reference to a report published in the journal Endocrinology in 2015, Phillipe Grandjean, MD, professor of environmental health at Harvard T.H. Chan School of Public Health, said in a statement, “Unfortunately, current testing paradigms do not properly assess the impact of risk factors during vulnerable exposure windows. Without new policies and guidelines, we cannot have a universal healthy start for children.”5 The risks borne by children in these “windows of vulnerability” have critical implications for children’s long-‐term health. A 2017 study found that residential pesticide use during pregnancy increases a child’s risk of developing a brain tumor by 40%.6 A 2000 report found

1 Roberts JR, Karr CJ; Council On Environmental Health. 2012. Pesticide exposure in children. Pediatrics. 2012 Dec; 130(6):e1765-‐88. 2 EPA. ND. Pesticides and Their Impact on Children: Key Facts and Talking Points. https://www.epa.gov/sites/production/files/2015-‐12/documents/pest-‐impact-‐hsstaff.pdf 3 National Research Council, National Academy of Sciences. 1993. Pesticides in the Diets of Infants and Children, National Academy Press, Washington, DC: 184-‐185. 4 Landrigan, P.J., L Claudio, SB Markowitz, et al. 1999. “Pesticides and inner-‐city children: exposures, risks, and prevention.” Environmental Health Perspectives 107 (Suppl 3): 431-‐437. 5 Harvard TH Chan School of Public Health. 2015. Parents exposure to chemicals prior to conception linked to child’s health problems. https://www.hsph.harvard.edu/news/hsph-‐in-‐the-‐news/parents-‐exposure-‐to-‐chemicals-‐prior-‐to-‐conception-‐linked-‐to-‐childs-‐health-‐problems/ 6 Bagazgoïtia, N et al. 2017. Maternal residential pesticide use during pregnancy and risk of malignant childhood brain tumors: A pooled analysis of the ESCALE and ESTELLE studies (SFCE). International Journal of Cancer. https://doi.org/10.1002/ijc.31073 http://onlinelibrary.wiley.com/doi/10.1002/ijc.31073/full

3

preconception exposures to the herbicide glyphosate, found by the California Department of Pesticide Regulation to be the most frequently used pesticide in schools,7 moderately increase the risk for spontaneous abortions in mothers exposed to these products (e.g., Roundup),8 and a 2018 report adds weight to this study, finding a correlation between glyphosate exposure during pregnancy and a shortened pregnancy.9 Another analysis, published in 2010, found that women exposed to pesticides in their homes or in yards were twice as likely to have offspring with neural tube defects than women who did not use pesticides.10 Studies have determined that children’s exposure to pesticides, like the herbicide 2,4-‐D, can pass from mother to child through umbilical cord blood and breast milk.11,12

Although much of the research on vulnerable windows focuses on exposure during pregnancy, childhood exposures clearly present a significant risk that is documented in the scientific literature. A 2010 meta-‐analysis on residential pesticide use found that exposure to pesticides during pregnancy and early childhood was associated with an elevated risk of childhood leukemia.13 A separate 2015 meta-‐analysis by Harvard researchers focused specifically on early-‐life exposure added weight to earlier research, finding a significantly increased risk of leukemia associated from herbicide exposure, which the authors indicate could occur at child care facilities, on athletic fields, and school grounds, all areas germane to this proposal.14

Pesticides used on turf and lawns can make their way indoors, resulting in chronic re-‐exposure. Once applied to lawns, these products drift and are tracked indoors where they settle in dust, air, and on surfaces, and may remain in carpets.15,16 Pesticides in these environments

7 California Department of Pesticide Regulation. 2016. California School and Child Care Pesticide Use Report Summary. https://apps.cdpr.ca.gov/schoolipm/school_ipm_law/2016_pur_summary.pdf 8 Arbuckle, T. E., Lin, Z., & Mery, L. S. (2001). An Exploratory Analysis of the Effect of Pesticide Exposure on the Risk of Spontaneous Abortion in an Ontario Farm Population. Environ Health Perspect, 109, 851–857. 9 Parvez, S et al. 2018. Glyphosate exposure in pregnancy and shortened gestational length: a prospective Indiana birth cohort study. Environmental Health. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5844093/. 10Brender, JD., et al. 2010. Maternal Pesticide Exposure and Neural Tube Defects in Mexican Americans. Ann Epidemiol. 20(1):16-‐22. 11 Pohl, HR., et al. 2000. Breast-‐feeding exposure of infants to selected pesticides. Toxicol Ind Health. 16:65-‐77. 12 Sturtz, N., et al. 2000. Detection of 2,4-‐dichlorophenoxyacetic acid (2,4-‐D) residues in neonates breast-‐fed by 2,4-‐D exposed dams. Neurotoxicology 21(1-‐2): 147-‐54. 13 Turner, M.C., et al. 2010. Residential pesticides and childhood leukemia: a systematic review and meta-‐analysis. Environ Health Perspect 118(1):33-‐41. 14 Mei Chen et al. 2015. Residential Exposure to Pesticide During Childhood and Childhood Cancers: A Meta-‐Analysis. 136 (4) 719-‐729; DOI: 10.1542/peds.2015-‐0006 https://pediatrics.aappublications.org/content/136/4/719. 15 Nishioka, M., et al. 1996. Measuring lawn transport of lawn-‐applied herbicide acids from turf. Env Science Technology, 30:3313-‐3320.

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increase the risk of developing asthma, exacerbate a previous asthmatic condition, or even trigger asthma attacks by increasing bronchial hyper-‐responsiveness.17 This is especially important as young children’s crawling behavior and proximity to the floor account for a greater potential than adults for dermal and inhalation exposure to contaminants on carpets, floors, lawns, and soil.18 Biomonitoring testing has documented pesticide residues in children after lawn care applications. Residues of lawn pesticides, like 2,4-‐D and mecoprop, were found in 15 percent of children tested, ages three to seven, whose parents had recently applied the lawn chemicals.19 In one study, children in areas where glyphosate is routinely applied were found to have detectable concentrations in their urine.20 Several studies on the widely used synthetic pyrethoid class of pesticides, such as bifenthrin, a pesticide frequently used in schools,21 has linked urinary concentrations in children to learning disabilities and other developmental impacts. In a 2015 study, boys with detectable urinary 3-‐PBA, a biomarker for exposure to pyrethroids, were three times more likely to have ADHD compared to those without detectable levels of the chemical.22 A separate 2015 study found similar results, with exposure to deltamethrin, another pesticide often used in schools, 23 corresponding to higher likelihood of having ADHD. “Although we can’t change genetic susceptibility to ADHD, there may be modifiable environmental factors, including exposures to pesticides that we should be examining in more detail,” said lead author Jason Richardson, PhD, associate professor in the Department and Environmental and Occupational Medicine at Rutgers Robert Wood Johnson Medical School and a member of the Environmental and

16 Nishioka, M., et al. 2001. “Distribution of 2,4-‐D in Air and on Surfaces Inside Residences. Environmental Health Perspectives 109(11). 17 Hernández, AF., Parrón, T. and Alarcón, R. 2011. Pesticides and asthma. Curr Opin Allergy Clin Immunol.11(2):90-‐6. 18 Bearer, CF. 2000. The special and unique vulnerability of children to environmental hazards. Neurotoxicology 21: 925-‐934; and Fenske, R., et al. 1990. Potential Exposure and Health Risks of Infants following Indoor Residential Pesticide Applications. Am J. Public Health. 80:689-‐693. 19 Valcke, Mathieu, et al. 2004. Characterization of exposure to pesticides used in average residential homes with children ages 3 to 7 in Quebec. National Institute of Public Health, Québec. 20 Acquavella, J. F., et al. 2004. Glyphosate Biomonitoring for Farmers and Their Families: Results from the Farm Family Exposure Study. Environ Health Perspect. 112(3), 321-‐326. 21 California Department of Pesticide Regulation. 2016. California School and Child Care Pesticide Use Report Summary. https://apps.cdpr.ca.gov/schoolipm/school_ipm_law/2016_pur_summary.pdf. 22 Wagner-‐Shuman, Melissa. 2015. Association of pyrethroid pesticide exposure with attention-‐deficit/hyperactivity disorder in a nationally representative sample of U.S. children. Environmental Health.14:44 https://doi.org/10.1186/s12940-‐015-‐0030-‐y https://ehjournal.biomedcentral.com/articles/10.1186/s12940-‐015-‐0030-‐y. 23 California Department of Pesticide Regulation. 2016. California School and Child Care Pesticide Use Report Summary. https://apps.cdpr.ca.gov/schoolipm/school_ipm_law/2016_pur_summary.pdf.

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Occupational Health Sciences Institute (EOHSI).24 A 2017 study on synthetic pyrethroids found that higher levels of the insecticide’s metabolites in a child’s urine were associated with externalizing disorders, which relate to how defiant or disruptive a child is. When considering other factors that relate to pesticide reform legislation, we urge lawmakers to keep in mind the costs that both residents and schools systems must bear when it comes to these health impacts. Increased risks for childhood cancer, asthma, and developmental disorders like ADHD put immense stress on parents, teachers, administrators, and school budgets, and must be part of the calculation when opponents invariably discuss how the loss of hazardous chemicals will impact their bottom line.

A Systems Approach Eliminates the Need for Toxic Pesticides DOE can incentivize land managers to transition to practices that have been shown to maintain turf expectations with no significant long-‐term financial implications. In 2011, the state of New York enacted the Child Safe Playing Fields Act, prohibiting the use of toxic pesticides on school grounds and playing fields.25 To assess the effectiveness of the act after its initial implementation, New York State conducted a school district survey in 2013, comparing results to a prior, 2000 questionnaire on the topic. The state found that, adjusted for inflation, median total expenditure by school district was negligible ($1,350 [$1,804 adjusted for inflation] in 2000 vs. $1,890 in 2013).26 The survey also revealed fewer parental complaints over pesticide use, and increased use of non-‐pesticidal pest management tactics in outdoor areas (more overseeding, aeration, organic fertilizer use).27 Sixty-‐six percent of school districts indicated that the implementation of the law caused a reduction in the use of pesticides in the school district.28 In Connecticut, where a law similar to New York’s has been in place for school grounds for over a decade, and includes all municipal playgrounds,29 experience has found similar results. The state’s pesticide regulatory agency notes on its website, in response to a question on the expense of organic lawn care, “If your lawn is currently chemically dependent, initially it may be more expensive to restore it. But in the long term, an organic lawn will actually cost you

24 Rutgers University Press Release. 2015. Common pesticide may increase risk of ADHD. Science Daily. https://www.sciencedaily.com/releases/2015/01/150129125552.htm. 25 New York Safe Playing Fields Act. 2010 http:/www.dec.ny.gov/chemical/41822.html. 26 Braband, Lynn. 2013. Pest Management Practices: A Survey of Public School Districts in New York State. New York State IPM Program. https://ecommons.cornell.edu/bitstream/handle/1813/43853/pest-‐mgmt-‐schools-‐NYSIPM.pdf?sequence=1. 27 Ibid. 28 Ibid. 29 Connecticut Bill 1502 Section 448, Line 17579. 2015. http://www.cga.ct.gov/2015/TOB/s/pdf/2015SB-‐01502-‐R00-‐SB.pdf.

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less money. Once established, an organic lawn uses less water and fertilizers, and requires less labor for mowing and maintenance.”30 The key to the organic approach is not in the use of product, but an understanding of soil and pest ecology. While conventional, chemical-‐intensive turf and landscape management programs are generally centered on a synthetic product approach that continually treats the symptoms of turf problems with toxic chemicals, an alternative, systems-‐based approach focuses on the root causes of pest problems, which lie in the soil. These cutting edge land management techniques reveal that toxic pesticides are not needed for successful turf management. Organic land management is a problem-‐solving strategy that supports the natural cycling of nutrients that nature has already put in motion. It is a ‘feed-‐the-‐soil’ approach that centers on natural, organic fertilization, soil amendments, microbial inoculants, compost teas and microbial food sources, and top dressing as needed with high quality finished compost. This approach incorporates preventive steps based on supporting soil biology to improve soil fertility and turf grass health, organic amendments based on a soil analysis that determines need, and specific cultural practices, including mowing height, aeration, dethatching, and over-‐seeding. Research from the University of Maryland finds that proper mowing height alone can reduce weed and diseases by 50 to 80% in fescue grass, a common variety planted in many regions of California.31 In the case of mowing high, the natural system supported by this practice is an increase in the root depth of grass. Deeper roots provide greater capacity for the grass to draw water and nutrients from the soil, and stronger grass plants are better able to crowd out weeds or cope with pest pressure. Likewise, frequent aeration can build soil health by breaking up soils compacted from play or nutrient deficiencies, maintaining good soil crumb structure, and allowing oxygen to enter the system. Because many weeds, such as plantain and dandelion, thrive in hardpan soil, aeration acts as a non-‐toxic pesticide alternative. Another practice, overseeding, functions very well to prevent weeds. By overseeding at the end of the growing season, bare patches are eliminated, and grass grows densely so as to crowd out any germinating weed seeds. Organic fertilizers and soil amendments are used in order to provide a gentle, slow release of a range of macro and micronutrients that nourish the lawn and landscape by feeding soil microorganisms. As biological life in the soil grows, microbial activity can become so productive that it begins to cycle up to two pounds of nitrogen per 1,000 square feet each month of the growing season. Thus, the focus is not on using fertilizer products to sustain cosmetic appearances, but using fertilizers that enable soil life to naturally sustain grass and landscape plants. Thus, the practices incorporated as part of an organic “feed the soil” approach build resiliency, allow the system to bounce back to its previous state after a disturbance. By fostering healthy

30 Connecticut Department of Energy and Environmental Protection. 2016. Organic Lawn Care. https://www.ct.gov/deep/cwp/view.asp?a=2708&q=382644 31 University of Maryland. 2016. Mowing/Grasscycling. https://extension.umd.edu/hgic/mowinggrasscycling-‐lawns

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soil biology, this approach leads to reduced need for outside inputs, such as synthetic pesticides and fertilizers. When properly maintained, lawns and playing fields cared for in this way meet the same expectations of conventional, chemically managed turf.

Organic landscape management practices and the ever-‐expanding product line of natural alternatives has enabled a cost parity between the conventional and natural approach. A report produced by nationally renowned turf grass expert Chip Osborne in coordination with Grassroots Environmental Education, which looks specifically at the cost of conventional and organic turf management on school athletic fields, concludes that once established, a natural turf management program can result in savings of greater than 25% compared to a conventional turf management program.32 In addition, research from Harvard University determined that, ultimately, total operating costs of its organic maintenance program were the same as a conventionally based program. In a 2009 New York Times article,33 the school determined that irrigation was reduced by 30%, saving 2 million gallons of water a year as a result of reduced irrigation needs. The school had also been spending $35,000/year trucking yard waste off site, which the university can now use for composting, saving an additional $10k/year due to the decreased cost and need to purchase fertilizer from off-‐campus sources.34 While a decade ago the organic approach required slightly increased up-‐front costs and saw savings in the long run, technology and practices have now progressed to the point where parity can often be achieved from the outset.

Given that the states of Connecticut35 and New York,36 at least 24 California communities,37 and a majority of Canadian provinces38 have enacted laws that reduce pesticide use, and more and more organic lawn care companies are entering this growing market, there are significant resources to assist school land managers in the state in implementing organic land management on DOE land.

Failures within U.S. EPA Pesticide Regulatory System Harm Hawai’i The Federal Insecticide Fungicide and Rodenticide Act (FIFRA), the law governing pesticide registration and use in the U.S., relies on a risk-‐benefit assessment, which allows the use of pesticides with known hazards based on the judgment that certain levels of risk are acceptable. However, the U.S. Environmental Protection Agency (EPA), which performs risk assessments, assumes that a pesticide would not be marketed if there were no benefits to using it and therefore no risk/benefit analysis is conducted or evaluated by the agency "up front." Registration of a pesticide by EPA does not guarantee that the chemical is “safe,” particularly

32 Osborne, Charles and Doug Wood. 2010. A cost Comparison of Conventional (Chemical) Turf Management and Natural (Organic) Turf Management on School Athletic Fields. Grassroots Environmental Education. http://www.grassrootsinfo.org/pdf/turfcomparisonreport.pdf 33 Raver, Anne. 2009. The Grass is Greener at Harvard. http://www.nytimes.com/2009/09/24/garden/24garden.html?_r=2 34 Harvard University. 2009. Harvard Yard Soils Restoration Project Summary Report. http://www.slideshare.net/harvard_uos/harvard-‐yard-‐soils-‐restoration-‐project-‐summary-‐report-‐22509-‐4936446 35 Connecticut Bill 1502 Section 448, Line 17579. 2015. http://www.cga.ct.gov/2015/TOB/s/pdf/2015SB-‐01502-‐R00-‐SB.pdf 36 New York Safe Playing Fields Act. 2010 http:/www.dec.ny.gov/chemical/41822.html 37 Map of US Pesticide Reform Policies. 2019. https://www.google.com/maps/d/viewer?mid=1VLpVWvifO2JOrgxf1-‐d1DLyDruE&ll=39.03573413957711%2C-‐94.19459570507814&z=5 38 Canadian Association of Physicians for the Environment. Cosmetic Pesticides-‐Provincial Policies and Municipal Bylaws: Lessons Learned and Best Practices. 2016. https://cape.ca/wp-‐content/uploads/2016/08/Pesticides-‐Policy-‐Report-‐FINAL.pdf

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for vulnerable populations such as children. Below are examples of concern within the pesticide registration process. By restricting the most toxic pesticides children could be exposed to on turf, DOE could address the deficiencies of EPA’s pesticide registration system. Conditional Registration Puts Untested Pesticides on the Market EPA will often approve the use of a pesticide without all of the necessary data required to fully register the chemical, and will assign it a "conditional" registration. The agency assumes that while it waits for additional data the product would not cause adverse impacts that would prevent an eventual full registration. A recent report (2013) from the Government Accountability Office, entitled EPA Should Take Steps to improve Its Oversight of Conditional Registrations,39 strongly criticizes this process, citing poor internal management of data requirements, constituting an “internal control weakness.” The report states, “The extent to which EPA ensures that companies submit additional required data and EPA reviews these data is unknown. Specifically, EPA does not have a reliable system, such as an automated data system, to track key information related to conditional registrations, including whether companies have submitted additional data within required time frames.” However, these recommendations do not go far enough. Pesticides without all the data required for a full understanding of human and environmental toxicity should not be allowed on the market. Several historic examples exist of pesticides that have been restricted or canceled due to health or environmental risks decades after first registration. Chlorpyrifos, an organophosphate insecticide, which is associated with numerous adverse health effects, including reproductive and neurotoxic effects, had its residential uses canceled in 2001. The state of Hawai’i banned other uses in 2018. Others, like propoxur, diazinon, carbaryl, aldicarb, carbofuran, and more recently endosulfan, have seen their uses restricted or canceled after years on the market due to unreasonable human and environmental effects. EPA Fails to Test or Disclose “Inert” Ingredients Despite their innocuous name, so-‐called “inert” ingredients in pesticide formulations are neither chemically, biologically, or toxicologically inert; in fact, they can be just as toxic as the active ingredient. Quite often, “inert” ingredients constitute over 95% of the pesticide product. In general, “inert” ingredients are minimally evaluated, even though many are known to state, federal, and international agencies to be hazardous to human health. For example, until October 23, 2014,40 creosols, chemicals listed as hazardous waste under Superfund regulations and considered possible human carcinogens by EPA,41 were allowed in pesticide formulations without any disclosure requirement. EPA recently took action to remove cresols and 71 other “inert” ingredients from inclusion in pesticide formulations as a result of petitions from health and consumer groups. However, numerous hazardous “inerts” remain. For example, a 2009 study, entitled Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical,

39 Government Accountability Office. August 2013. EPA Should Take Steps to Improve Its Oversight of Conditional Registrations. GAO-‐13-‐145. http://www.gao.gov/products/GAO-‐13-‐145. 40 Environmental Protection Agency. October 2014. EPA Proposes to Remove 72 Chemicals from Approved Pesticide Inert Ingredient List. http://yosemite.epa.gov/opa/admpress.nsf/bd4379a92ceceeac8525735900400c27/3397554fa65588d685257d7a0061a300!OpenDocument. 41 Environmental Protectin Agency. October 2013. Cresol/Cresylic Acid. http://www.epa.gov/ttnatw01/hlthef/cresols.html.

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Embryonic, and Placental Cells,42 found that an “inert” ingredient in formulations of the weed killer Roundup (glyphosate), polyethoxlated tallowamine (POEA), is more toxic to human cells than the active ingredient glyphosate, and, in fact, amplifies the toxicity of the product – an effect not tested or accounted for by the pesticide registration process.

Pesticide manufacturers argue against the disclosure of “inert” ingredients on pesticide product labels, maintaining that this information is proprietary. Limited review of “inert” ingredients in pesticide products highlights a significant flaw with the regulatory process. Rather than adopt a precautionary approach when it comes to chemicals with unknown toxicity, EPA allows uncertainties and relies on flawed risk assessments that do not adequately address exposure and hazard. Then, when data becomes available on hazards, these pesticides, both active ingredients and “inerts,” have already left a toxic trail on the environment and people’s well-‐being.

Label Restrictions are Inadequate. From a public health perspective, an inadequate regulatory system results in a pesticide product label that is also inadequate, failing to restrict use or convey hazard information. While a user may be able to glean some acute toxicity data, chronic or long-‐term effects will not be found on products’ labels. Despite certain pesticides being linked to health endpoints, such as exacerbation of asthma,43 learning disabilities,44 or behavioral disorders,45 this information is not disclosed on the label. Furthermore, data gaps for certain health endpoints are also not disclosed.

Mixtures and Synergism are Inadequately Regulated. In addition to gaps in testing “inert” ingredients and their mixtures with active ingredients in pesticide products, there is an absence of review of the health and environmental impacts of pesticides used in combination. A study by Warren Porter, PhD., professor of zoology and environmental toxicology at the University of Wisconsin, Madison, examined the effect of fetal exposures to a mixture of 2,4-‐D, mecoprop, and dicamba exposure —frequently found together in common lawn care products used in schools— on the mother’s ability to successfully bring young to birth and weaning.46 A 2011 study, entitled Additivity of pyrethroid actions on sodium influx in cerebrocotorial neurons in primary culture,47 finds that the combined mixture’s effect is equal to the sum of the effects of individual pyrethoids. This equates to a cumulative toxic loading for exposed individuals. When a pesticide may become more or less toxic depending

42 Benachour and Seralini. 2009. Glyposate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells. Chemical Research and Toxicology. http://pubs.acs.org/doi/abs/10.1021/tx800218n. 43 Hernandez et al. 2011. Pesticides and Asthma. Current opinion in allergy and clinical immunology. http://www.ncbi.nlm.nih.gov/pubmed/21368619. 44 Horton et al. 2011. Impact of Prenatal Exposure to Piperonyl Butoxide and Permethrin on 36-‐Month Neurodevelopment. Pediatrics. http://www.ncbi.nlm.nih.gov/pubmed/21300677 45 Furlong et al. 2014. Prenatal exposure to organophosphate pesticides and reciprocal social behavior in childhood. 46 Cavieres MF, Jaeger J, Porter W. Developmental toxicity of a commercial herbicide mixture in mice: I. Effects on embryo implantation and litter size. Environmental Health Perspectives. 2002;110(11):1081-‐1085. 47 Cao et al. 2011. Additivity of Pyrethroid Actions on Sodium Influx in Cerebrocortical Neurons in Primary Culture. Environmental Health Perspectives. http://ehp.niehs.nih.gov/1003394/.

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upon its formulation48 -‐-‐and EPA is only now beginning to consider whether to fully test end-‐use pesticide products-‐-‐49 the only acceptable approach for children’s health in the face of this uncertainty is precaution.

How Other States and Localities Protect Children and School Staff A comprehensive policy for schools addresses pests indoors and outdoors. Below we outline elements of a comprehensive policy.

Posting Notification Signs for Indoor Pesticide Applications States use different approaches in providing school pesticide use information to parents, students, and staff. Some require the posting of notification signs and/or the distribution of notices directly to the affected population. Posted notification signs warn those in the school when and where pesticides have been or are being applied. This is a vehicle for basic right-‐to-‐know if the posting occurs in an area where it is easily seen by parents, students, and staff. It is important to post signs for indoor pesticide applications because of the extensive period of time students and school employees spend at school. Signs posted prior to commencement of the pesticide application, rather than after, are more protective. The prior notification system effectively enables people to take precautionary action. Because of the residues left behind after an application, signs should remain posted for at least 72 hours. It takes time for pesticides to start breaking down and some pesticide residues can least for weeks. Signs should also be posted at all main entrances of the building and the specific area sprayed, on the main bulletin board, and, for more comprehensive notification, in the school newspaper or on the daily announcements. Posted signs should state when and where a pesticide is applied, the name of the pesticide applied and how to get further information, such as a copy of the material safety data sheet (MSDS) and the product(s) label.

Hawaii does not have any statewide posting requirements for indoor school pesticide applications.

Posting Notification Signs for Outdoor Pesticide Applications For a wider range of protection, states should require posting pesticide notification signs for outdoor pesticide applications as well. Students who play sports or people who sit on the lawns incur a high risk when applications occur on school property. Dermal exposure can occur when a football player gets tackled, a soccer player slides to make a block, or a student sits on the grass to eat lunch or watch a game. Inhalation exposure can occur when a player breathes in kicked up dust and dirt and pesticide residues. Even spectators at a game or passersby face inhalation exposure to pesticides that volatilize or vaporize off the treated area.

Hawaii does not have any statewide posting requirements for outdoor school pesticide applications.

48 Donley, Nathan. 2016. Toxic Concoctions. Center for Biological Diversity, https://www.biologicaldiversity.org/campaigns/pesticides_reduction/pdfs/Toxic_concoctions.pdf 49 Regulations.gov. 2019. Petition Seeking Revised Testing Requirement of Pesticides Prior to Registration. EPA. https://www.regulations.gov/docket?D=EPA-‐HQ-‐OPP-‐2018-‐0262

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Prior Written Notification Written notification of pesticide use is a good way to make sure that all parents, children, and staff are aware and warned of pesticide use in the schools. Limited notification-‐based registries provide a less effective means of notifying people and do not qualify as right-‐to-‐know because of their limited scope. Requiring that individuals place themselves on registries, sometimes only with a doctor’s letter, afford the opportunity to be informed about pesticide use in the school only to those who already know about the dangers of toxic exposure. Prior notification should be 72 hours in advance to make sure the information has been received, to get further information regarding the pesticide, and to make arrangements to avoid the exposure, if necessary. Notification should include the name of the pesticide(s), a summary of the adverse health effects listed on the Material Safety Data Sheet (MSDS) and label, the day and time, and area of the application and how to obtain a copy of the MSDS and label.

Hawaii does not have any statewide requirements for providing prior written notification of pesticide use.

Prohibitions on Use Limiting when and what pesticides may be applied in and around schools is important to the reduction of pesticide exposure. Pesticides should never be applied when students or employees are in the area or may be in the area within 24 hours of the application. In reality, certain types of pesticides, such as carcinogens, endocrine disrupters, reproductive toxins, developmental toxins, neurotoxins, persistent compounds and substances, bioaccumulative substances, and toxicity category 1 acutely toxic pesticides should not be used around children.

Hawaii does not have any state laws restricting pesticide use in schools.

Integrated Pest Management A good organic/integrated pest management (IPM) program can eliminate the unnecessary application of synthetic, volatile pesticides in schools. The main elements of a good organic/IPM program include: 1) monitoring to establish whether there is a pest problem, 2) identifying the causes of the pest problem, 3) addressing the cause by changing conditions to prevent problems, 4) utilizing pest suppression techniques, if necessary, that are based on mechanical and biological controls, and 5) only after non-‐toxic alternatives have been tried and exhausted, use the least toxic pesticide. Because organic is defined in law and IPM is not, an IPM policy must be clearly defined and include a written policy guide with a prohibited and acceptable materials list. Material that could be considered after using other methods include boric acid and disodium octoborate tetrahydrate, silica gels, diatomaceous earth, insect growth regulators, insect and rodent baits in tamper resistant containers or for crack and crevice placement only, microbe-‐based insecticides, botanical insecticides (not including synthetic pyrethriods) without toxic synergists, and biological (living) control agents.

Hawaii does not have any statewide requirements for implementing Integrated Pest Management (IPM).

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The Dangers of Glyphosate Glyphosate, which has been mistakenly characterized as a relatively innocuous herbicide and is now known to pose multiple dangers to human health and the environment, demonstrates the failure of the risk assessment paradigm for regulating toxic chemicals and the dangers of ignoring the importance of microbiota. Glyphosate (N-‐phosphono-‐methyl glycine) is a broad spectrum, post-‐emergent, non-‐selective systemic herbicide used on non-‐cropland, as well as a variety of crops. It has seen the largest use in crops that are genetically engineered to be tolerant to it, where it kills most grassy and broadleaved plants. Glyphosate products, such as Monsanto’s Roundup, are formulated with surfactants and other ingredients to increase its effectiveness. Glyphosate’s major metabolite is aminomethyl phosphonic acid (AMPA). Glyphosate is translocated to meristematic tissues in the plant (where active cell division occurs.) There it blocks the activity of the enzyme 5-‐enolpyruvylshikimate-‐3-‐phosphate synthase (EPSPS), a key enzyme in the shikimate pathway of production of aromatic amino acids, ultimately leading to the plant’s death by starvation.50 Since animals do not use the shikimate pathway, the manufacturer of glyphosate (Monsanto) claims it is “safe” for humans. However, this safety claim ignores glyphosate’s adverse effect on beneficial bacteria essential to human health. EPA classifies glyphosate as a Group E carcinogen—evidence of non-‐carcinogenicity for humans—based on the lack of convincing evidence of carcinogenicity in studies submitted to the agency by Monsanto. However, contrary to EPA’s finding of evidence of non-‐carcinogenicity, epidemiological studies have found a positive association between exposure to glyphosate-‐based herbicides and cancer. On March 20, 2015, the International Agency for Research on Cancer (IARC) announced that it had classified glyphosate as a class 2A carcinogen, as “probably carcinogenic to humans.”51 This category is the most definitive of any based on standard laboratory animal testing. We focus on glyphosate in light of the continuing flood of science and legal information on its hazards. Using glyphosate based herbicides as a clear example of the failures of the federal regulatory system to protect the health of our children, Hawai’i DOE should adopt a comprehensive school pesticide and pest management policy, as outlined above, which prohibits the use of all synthetic pesticides.

50 Industry Task Force on Glyphosate, 2017. Glyphosate: mechanism of action. http://www.glyphosate.eu/glyphosate-‐mechanism-‐action. 51 IARC, 2016. IARC Monographs on the evaluation of carcinogenic risk to man. Lyon :International Agency for Research on Cancer, volume 112. Some Organophosphate Insecticides and Herbicides: Glyphosate. http://monographs.iarc.fr/ENG/Monographs/vol112/mono112-‐10.pdf.

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Problems with risk assessment EPA’s risk assessment of glyphosate is based on direct effects of the active ingredient alone, as demonstrated in laboratory tests. The chemical must demonstrate a toxic effect that is related to the dose received. When this model is applied to glyphosate, it fails to identify the most important impacts of glyphosate as it is used. The first problem is that glyphosate is not used alone. “Inert” ingredients in glyphosate products A number of surfactants and other ingredients are added to glyphosate products to make them more effective as herbicides, including 5-‐chloro-‐2-‐methyl 3(2H)-‐isothiazolone, FD&C Blue No. 1, glycerine, 3-‐iodo-‐2-‐propynyl butyl carbamate, light aromatic petroleum distillate, methyl p-‐hydroxybenzoate, polyoxyethylene alkylamine, propylene glycol, sodium sulfite, sodium benzoate, sodium salt of o-‐phenylphenol, and sorbic acid. Health effects that are associated with these so-‐called “inert” (non-‐disclosed) ingredients include genetic damage, reduced fertility, thyroid damage, eye irritation, anemia, reduced survival of offspring, and skin irritation.52 Polyethoxylated tallowamine or POEA—a surfactant used in Roundup and other herbicidal products—has been identified as particularly toxic. 53 Hazards of glyphosate products In contrast to the results of the manufacturer’s tests of glyphosate alone, an increasing number of studies have found that formulated glyphosate products (e.g., Roundup) are more toxic than glyphosate alone. Symptoms following acute exposure to glyphosate formulations include: swollen eyes, face and joints; facial numbness; burning and/or itching skin; blisters; rapid heart rate; elevated blood pressure; chest pains, congestion; coughing; headache; and nausea.54 Glyphosate and its formulated products adversely affect embryonic, placental and umbilical cord cells, and affect fetal development.55 Chronic exposure to glyphosate-‐based herbicides can result in significant liver and kidney damage.56 Human cell endocrine disruption has also been observed to occur at concentrations well below those considered “acceptable,” including disruption at the androgen receptor, inhibition of transcriptional activities on estrogen receptors on HepG2, decreased aromatase activity, DNA damage, and cytotoxic effects.57 52 Caroline Cox, 2004. Northwest Center for Alternatives to Pesticides Factsheet: Glyphosate. 53 Tsui, M., & Chu, L. 2003. Aquatic toxicity of glyphosate-‐based formulations: comparison between different organisms and the effects of environmental factors. Chemosphere., 52(7), 1189-‐1197. 54 Caroline Cox, 2004. Northwest Center for Alternatives to Pesticides Factsheet: Glyphosate. 55 Paganelli, A., Gnazzo, V., Acosta, H., López, S.L. and Carrasco, A.E., 2010. Glyphosate-‐based herbicides produce teratogenic effects on vertebrates by impairing retinoic acid signaling. Chemical research in toxicology, 23(10), pp.1586-‐1595. 56 Mesnage, R., Arno, M., Costanzo, M., Malatesta, M., Séralini, G.E. and Antoniou, M.N., 2015. Transcriptome profile analysis reflects rat liver and kidney damage following chronic ultra-‐low dose Roundup exposure. Environmental Health, 14(1), p.70. 57 Gasnier, C., et al. 2008. Glyphosate-‐based herbicides are toxic and endocrine disruptors in human cell lines. Toxicology, doi:10.1016/j.tox.2009.06.006. Defarge, N., Takács, E., Lozano, V.L., Mesnage, R.,

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New science and glyphosate Besides looking at the total formulation in addition to the active ingredient, newer scientific studies have looked in greater depth at glyphosate’s mode of action and the implications for human and ecological health. Glyphosate works by disrupting a crucial pathway for manufacturing aromatic amino acids in plants –but not animals— and, therefore, many have assumed that it does not harm humans. However, many bacteria do use the shikimate pathway, and 90% of the cells in a human body are bacteria. The destruction of beneficial microbiota in the human gut (and elsewhere in and on the human body) is, therefore, a cause for concern –and a major contributor to disease. In addition, the destruction of soil microbiota leads to unhealthy agricultural systems with an increasing dependence on agricultural chemicals. Looking even deeper at the mode of action of glyphosate, other scientists have found that it starves and sickens the very crop plants that it is supposed to protect. It is dangerous to base the review of chemicals on the assumption that microbiota is irrelevant to assessing dangers. While it is well known that taking a course of antibiotics disturbs microbes that help digest food, disturbing the microbiota has greater consequences than a bout of diarrhea. It can contribute to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-‐resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. Antibiotic Resistance The spread of antibiotic resistance is a health care crisis of major proportions. The Centers for Disease Control and Prevention (CDC) call it “one of the world’s most pressing public health problems.”58 Many bacterial infections are becoming resistant to the most commonly prescribed antibiotics, resulting in longer-‐lasting infections, higher medical expenses, the need for more expensive or hazardous medications, and the inability to treat life-‐threatening infections. The development and spread of antibiotic resistance is the inevitable effect of the use of antibiotics.59 Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance. With the explosion of antibiotic resistance in the U.S. and worldwide, antibiotic use in crop and livestock production is a major public health issue. Use of antibiotics like glyphosate in agriculture allows residues of antibiotics and antibiotic-‐resistant bacteria to emerge on agricultural lands, move through the environment, contaminate waterways, and ultimately

Spiroux de Vendômois, J., Séralini, G.E. and Székács, A., 2016. Co-‐formulants in glyphosate-‐based herbicides disrupt aromatase activity in human cells below toxic levels. International Journal of Environmental Research and Public Health, 13(3), p.264. 58 CDC, “Get Smart: Know When Antibiotics Work.” http://www.cdc.gov/getsmart/antibiotic-‐use/fast-‐facts.html. 59 Thomas F. O’Brien, 2002. Emergence, Spread, and Environmental Effect of Antimicrobial Resistance: How Use of an Antimicrobial Anywhere Can Increase Resistance to Any Antimicrobial Anywhere Else, Clinical Infectious Diseases 2002; 34(Suppl 3):S78–84.

15

reach consumers in food. Both the human gut and contaminated waterways provide incubators for antibiotic resistance. In addition to the promotion of weed resistance by widespread application of glyphosate and use of glyphosate-‐resistant genes in agriculture, there is evidence that glyphosate at levels used in agriculture results in bacterial resistance to antibiotics important in fighting human pathogens and infections.60 As EPA stated for another antibiotic, if “bacterial resistance to oxytetracycline from pesticidal use occurs, it is most likely that it would be caused by development of resistance from non-‐pathogenic bacteria in orchards which later transferred their resistance to human bacterial pathogens.” 61 Therefore, EPA risk assessments based on toxic effects in animal and human models is inadequate for determining and managing the risk of antibiotic resistance promoted by glyphosate use. Ecological impacts In addition to recent science showing the much greater toxicity of glyphosate products than the technical active ingredient to aquatic and semi-‐aquatic organisms,62 an important finding is that glyphosate-‐tolerant plants release glyphosate into the soil, where it has a continued impact. Glyphosate is also released to the soil by dead plants. “Once in soil, glyphosate may be adsorbed onto soil particles, degraded by microbes, or transferred to deeper soil horizons, migrating via soil pores or root canals. However, some agricultural practices, such as phosphorous amendment, may re-‐solubilize glyphosate in soils, making it available for leaching and to the rhizosphere of non-‐target plants.”63 Glyphosate adsorbed to soil particles may move in wind or water, affecting organisms off the target field. Its use in agriculture has had a significant impact on monarch butterfly populations through the reduction of milkweed stands.64 However, the potentially much greater impact of glyphosate through its effects on soil microbiota is unknown and require long term studies.65 The recent science on glyphosate –and we have only looked at the tip of the iceberg—reveals the inadequacy of the risk assessment model for protecting humans and the environment from pesticides. From toxicity testing of the technical active ingredient, glyphosate appeared to have 60 See GMOs, Glyphosate, and Antibiotic Resistance below. 61 USEPA. 2006. “Report of the Food Quality Protection Act (FQPA) tolerance reassessment progress and risk management decision (TRED) for oxytetracycline.” 62 For example: Tsui, M.T. and Chu, L.M., 2003. Aquatic toxicity of glyphosate-‐based formulations: comparison between different organisms and the effects of environmental factors; Chemosphere, 52(7), pp.1189-‐1197. Relyea, R.A., 2005. The lethal impact of Roundup on aquatic and terrestrial amphibians. Ecological applications, 15(4), pp.1118-‐1124. 63 Gomes, M.P., Smedbol, E., Chalifour, A., Hénault-‐Ethier, L., Labrecque, M., Lepage, L., Lucotte, M. and Juneau, P., 2014. Alteration of plant physiology by glyphosate and its by-‐product aminomethylphosphonic acid: an overview. Journal of experimental botany, 65(17), pp.4691-‐4703. 64 Pleasants, J.M. and Oberhauser, K.S., 2013. Milkweed loss in agricultural fields because of herbicide use: effect on the monarch butterfly population. Insect Conservation and Diversity, 6(2), pp.135-‐144. 65 Kremer, R.J., 2017. Soil and environmental health after twenty years of intensive use of glyphosate. Adv Plants Agric Res 2017, 6(5): 00224.

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minimal health and environmental effects. But when scientists look at the effects of the complete product –and more importantly, the effects as mediated by microbiota in the soil and the gut— it has been shown to have health and environmental effects that threaten the lives of myriad species, including our own.

Conclusion We urge the Board to enact an official policy banning all synthetic pesticides and herbicides, and adopt a comprehensive policy for school building and land management implementing effective organic practices. Our future depends on having a healthy environment in which to learn. Thank you.

Choon James <[email protected]>

06/23/2019 06:26 PM


Subject SUPPORT PESTICIDE FREE HAWAI’I SCHOOLS!

Aloha,

Thank you for your efforts to address these issues relating to the health of our students.

It's very important that we try to protect the long-term health of thousands of our school children. There are alternatives to the dangerous and poisonous pesticides used in our schools and public lands.

We sincerely hope the BOE leadership will boldly make a wise decision to support pesticide free schools in the Hawaiian Islands. It's the right thing to do and it will prevent many health issues and heartaches in the future for our children and support workers on the school campuses. We're also concerned about schools like Waialua where they are next to agricultural fields with significant amounts of regular chemical spraying.

We look forward to supporting you in provide pesticide free school campuses!

Mahalo, Choon James Koolauloa********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

�

Date: June 23, 2019 To: Hawai‘i State Board of Educa=on Re: Strong Support for Banning Use of Glyphosate by Hawai‘i Department of Educa=on Hearing: June 24, 2019 at 5pm, Leilehua High School

Thank you for the opportunity to express our strong support for enactment of an official policy of the Hawai‘i State Board of Educa=on to ban the use of glyphosate-based herbicides by the Hawai‘i Department of Educa=on.

The World Health Organiza=on's Interna=onal Agency for Research on Cancer maintains that glyphosate is a probable cause of cancer in humans. California and the European Union have taken ac=on to restrict the use of glyphosate in public places. Costco has recently decided to stop selling Roundup (a glyphosate herbicide) in their stores na=onwide.

Eighty five percent of K-12 public non-charter schools in Hawai‘i have ac>ve school garden programs, which typically grow edible plants that students consume as 1

classroom tas=ngs. Restric=ng the use of glyphosate on and around school proper=es is a prudent ac=on to protect the health of students and school staff.

Hawaii's mo\o states, "Ua ma ke ea o ka ‘āina i ka pono," the life of the land is perpetuated in righteousness. Please do what is pono and ban the use of glyphosate for the safety of Hawaii's public school students and staff.

Thank you very much for this opportunity to tes=fy.

Me Ke Aloha,

Lydi Bernal Coordinator, Hawai‘i Farm to School Hui Hawai‘i Public Health Ins=tute (HIPHI)

Safety and Wellness Survey, 2017-20181

hiphi.org • 850 Richards Street, Suite 201 • Honolulu, Hawai‘i 96813

HUI MEMBER CORE ORGANIZATIONS:

Grow Some Good/Maui School Garden Network

‘Iolani School/Oʻahu Farm to School Network

Kōkua Hawaiʻi Founda=on

Mala‘ai: Culinary Gardens of Waimea Middle School/Hawaiʻi Island School Garden Network

Mālama Kaua‘i/Kaua‘i School Garden Network

Pacific Resources for Educa=on and Learning

Sustainable Molokai/Molokai School Garden Network

The Kohala Center

The Hawai‘i Farm to School Hui is a statewide network whose mission is to strengthen Hawaii’s farm to school movement by suppor;ng our island networks in the areas of capacity building, resource development and sharing, professional development, and policy development and advocacy. Farm to school programs include school gardens, educa8on, and school food improvements through local procurement. The Hui is comprised of five island-level networks, community organiza;ons and schools, and representa;ves from the Hawai‘i Departments of Agriculture, Educa;on, and Health and the University of Hawai‘i. The Hui formed in 2010 and became a program of the Hawai‘i Public Health Ins;tute (HIPHI) in 2017.

Jennifer Noelani Ahia <[email protected]>

06/23/2019 10:22 PM


Subject Fwd: Please Ban Pesticide Use

Sent from my iPhone


From: Jennifer Noelani Ahia <[email protected]>Date: June 23, 2019 at 9:39:26 PM HSTTo: [email protected]: Please Ban Pesticide Use

Aloha,My name is Noelani Ahia. I am a licensed healthcare provider on Maui. I am asking with the utmost serious plea, to end the use of pesticides and herbicides anywhere near our schools or anyplace that our children, our sacred trust, could come in contact.

I lost my niece 5 years ago to an unexplainable condition. When she was born we spent 2 months in the NICU with her at Kapiolani hospital on O’ahu. There were over 70 newborns there at the time. Many from Kaua’i who lived near where Monsanto sprayed. There were babies born with their intestines outside their body, and several other deformations. I heard many people say “we need a cure for these illnesses.” As a healthcare professional, all I could think was “we need to eliminate the causative factor so our precious loved ones don’t end up poisoned and in critical condition in the first place. “

We must eliminate the cause. And for many of these vulnerable newborns, the cause is pesticide contamination via their unsuspecting mama’s. Did you know Hawaii has the highest rate of pediatrics cancer compared to all the states in the U.S.?

Please, if you are a parent, grandparent, aunty, uncle, do what is Pono and protect our keiki with everything you’ve got. They deserve life!!Mahalo nui,Noelani Ahia808-269-9995

Sent from my iPhone********************************************************************************

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Susan Gregory <[email protected]>

06/23/2019 10:35 PM


Subject Fwd: No Pesticides in Schools

Sent from my iPhone


From: Susan Gregory <[email protected]>Date: June 23, 2019 at 10:29:34 PM HSTTo: doe_hawaii@k12_hawaii.usSubject: No Pesticides in Schools

Aloha, please do not use pesticides on school grounds. Do not expose keiki to toxic poisons with harmful effects. Pesticide is toxic.

Keiki are increasingly suffering from weakened immune systems. Poison in schools is not helpful.

Mahalos, Susan Gregory808-666-1924

Sent from my iPhone


Becky Gardner <[email protected]>

06/24/2019 10:59 AM


cc Subject Testimony opposed to use of

glycophosohate

I apologize. My testimony is late; but I recently learned more about the national litigation trends relating to Roundup. It is pretty alarming to learn about the conduct of Bayer/Monsanto to coverup the dangers of glyphosate. I urge the board to dedicate just 15 minutes to reading this litigation summary, available at this link.https://usrtk.org/monsanto-roundup-trial-tracker-index/I think it would be prudent for government agencies to severely curb the use of these substances unless it knows it can shoulder the costs of potential liabilities. Pasting the first 2 articles of that litigation summary below:~~~~~~~~<~~~~~~<~~~~~~<

Monsanto Roundup Trial TrackerPrint Email Share TweetThis blog by Carey Gillam is updated regularly with news and tips about the lawsuits involving Monsanto’s glyphosate-based Roundup weed killer products. See our Monsanto Papers pages for discovery documents. Please consider donating here to support our investigation. June 13, 2019

Monsanto, Bayer Struggle to Keep Up with Growing Roundup Cancer LitigationTurmoil both in and outside courtrooms appears to be growing for Monsanto, a unit of German owner Bayer AG, as the company works to meet overlapping deadlines for appeal actions in the three Roundup cancer trials Monsanto has lost so far at the same time that the company must prepare for new trials at the end of this summer.The weight of the litigation burden was laid out by a Monsanto/Bayer attorney in a recent California Court of Appeal filing seeking more time to file a brief in Monsanto’s appeal of the first case it lost last summer.That plaintiff in that case, Dewayne “Lee” Johnson, was awarded $289 million by a San Francisco jury who determined that Johnson’s non-Hodgkin lymphoma was caused by his exposure to Monsanto’s glyphosate-based herbicides. As part of the $289 million, the jury ordered $250 million in punitive damages after Johnson’s attorneys presented evidence that Monsanto suppressed the evidence of the risks of its herbicides.The trial judge lowered the damage award to $78 million, and Johnson is cross-appealing to reinstate the full verdict.Monsanto’s appeal argues, among other things, that if the court refuses to reverse the judgment there should be no punitive damage award at all, even if Johnson is awarded a small amount for compensatory damages.In the recent filing, Bryan Cave attorney K. Lee Marshall told the court he needs an extension of time to prepare the next brief that is due in the Johnson appeal because of the various deadlines in the multiple cases Monsanto is defending against. He cited post-trial motion deadlines in Pilliod v. Monsanto, in which a jury ordered Monsanto pay more than $2 billion in damages, and deadlines in Hardeman v. Monsanto, in which a jury ordered the company to pay roughly $80 million in damages. Monsanto is seeking to overturn both those verdicts as well.Last week, Monsanto filed notice in federal court that it – along with insurer Liberty Mutual

Insurance Co. – had posted a $100 million bond as it plans to appeal the Hardeman verdict. The company has a July 2 hearing on its request for the trial judge to set aside the verdict and order a new trial.“In light of the imminent post-trial motion briefing deadlines in Hardeman and Pilliod, I am, and will be, devoting a significant amount of time over the next several weeks to the post-trial motions that challenge the enormous verdicts in those cases. These time-sensitive commitments will substantially impair my ability to devote time to prepare… in this appeal,” Marshall told the court.As well, he wrote, the Johnson case is “unusually complex and presents numerous complicated issues.” In-house counsel at Bayer wants to review, comment on and edit the reply brief before it is filed, he added.The Johnson appeal is being handled on an expedited basis due to Johnson’s declining health and terminal cancer diagnosis. Johnson’s attorneys have said they expect oral arguments to be set for the appeals by September or October, with a final ruling expected within 90 days following oral arguments, possibly by Thanksgiving.If Monsanto loses its bid for a new trial in the Hardeman case the company is expected to file an appeal with the Ninth Circuit Court of Appeals in a process that would likely drag into next spring, attorneys involved in the litigation said.Meanwhile, the next trial is set to get underway Aug. 19 in St. Louis, the longtime hometown for Monsanto before it was acquired by Bayer in June 2018. The case involves plaintiff Sharlean Gordon, a cancer-stricken woman in her 50s. The case was filed in July 2017 on behalf of more than 75 plaintiffs and Gordon is the first of that group to go to trial.More than 13,000 plaintiffs have filed suit against Monsanto in the United States alleging they developed non-Hodgkin lymphoma due to exposure to Monsanto’s glyphosate-based weed killers, such as Roundup.As the litigation proceeds, Bayer investors grow more restless and many are pushing Bayer to seriously consider a global settlement, sources say. Various analysts put a potential settlement number between $2 billion to $3 billion on the low side, up to $10 billion or slightly more as the high end of a range.Bayer’s shares have fallen 44 percent since the Johnson verdict was handed down last August.An internal Bayer email dated June 13 revealed that the company is launching a new marketing effort aimed at distancing itself from Monsanto’s questionable conduct.The email sent from Bayer CEO Werner Baumann stated: “We are currently facing questions of public trust. This challenge is also an opportunity for us to demonstrate what we stand for. That’s why we areraising the bar as we are setting off on a journey to elevate our efforts in transparency,sustainability and how we engage with our stakeholders. As the new leader in agriculture, weaim to set standards that not only align with the norms of our industries, but push all of us to bebetter.”“Transparency is our foundation. We will evolve our engagement policies that ground all of ourinteractions with scientists, journalists, regulators and the political sphere in transparency,integrity and respect,” the internal Bayer email states.

May 17, 2019

Up Next – Trial In Monsanto’s Hometown Set for August After $2 Billion Roundup Cancer VerdictAfter three stunning courtroom losses in California, the legal battle over the safety of Monsanto’s top-selling Roundup herbicide is headed for the company’s hometown, where corporate officials can be forced to appear on the witness stand, and legal precedence shows a history of anti-corporate judgments.Sharlean Gordon, an cancer-stricken woman in her 50s, is the next plaintiff currently set for trial.

Gordon v. Monsanto starts Aug. 19 in St. Louis County Circuit Court, located just a few miles from the St. Louis, Missouri-area campus that was the company’s longtime world headquarters until Bayer bought Monsanto last June. The case was filed in July 2017 on behalf of more than 75 plaintiffs and Gordon is the first of that group to go to trial.According to the complaint, Gordon purchased and used Roundup for at least 15 continuous years through approximately 2017 and was diagnosed with a form of non-Hodgkin lymphoma in 2006. Gordon has gone through two stem cell transplants and spent a year in a nursing home at one point in her treatment. She is so debilitated that it is difficult for her to be mobile.Her case, like that of the thousands of others filed around the United States, alleges use of Monsanto’s glyphosate-based herbicides caused her to develop non-Hodgkin lymphoma.“She’s been through hell,” said St. Louis attorney Eric Holland, one of the legal team members representing Gordon. “She’s horribly injured. The human toll here is tremendous. I think Sharlean is really going to put a face on what Monsanto’s done to people.”Gordon said the hardest part about preparing for trial is determining what evidence to present to the jury within the three-week time span that the judge has set for the trial.“This evidence against them, their conduct, is the most outrageous I’ve seen in my 30 years of doing this,” Holland said. “The things that have gone on here, I want St. Louis juries to hear this stuff.”That Gordon trial will be followed by a September 9 trial also in St. Louis County in a case brought by plaintiffs Maurice Cohen and Burrell Lamb.Monsanto’s deep roots in the community, including a large employment base and generous charitable donations throughout the area, could favor its chances with local jurors. But on the flip side, St. Louis is regarded in legal circles as one the most favorable places for plaintiffs to bring lawsuits against corporations and there is a long history of large verdicts against major companies. St. Louis City Court is generally considered the most favorable but St. Louis County is also desired by plaintiffs’ attorneys.The approach of the August and September trials comes on the heels of a stunning $2 billion verdict issued against Monsanto May 13. In that case, a jury in Oakland, California awarded married couple Alva and Alberta Pilliod, who both suffer from cancer, $55 million in compensatory damages and $1 billion each in punitive damages. The jury found that Monsanto has spent years covering up evidence that its herbicide causes cancer.That verdict came only a little more than a month after a San Francisco jury ordered Monsanto to pay $80 million in damages to Edwin Hardeman, who also developed non-Hodgkin lymphoma after using Roundup. And last summer, a jury ordered Monsanto to pay $289 million to groundskeeper Dewayne “Lee” Johnson who received a terminal cancer diagnosis after using Monsanto herbicides in his job.Aimee Wagstaff, who was co-lead counsel for Hardeman, is set to try the Gordon case in St. Louis with Holland. Wagstaff said she plans to subpoena several Monsanto scientists to appear on the witness stand to answer questions directly in front of a jury. She and the other attorneys trying the California cases were not able to force Monsanto employees to testify live because of the distance.MEDIATION MEETING MAY 22The trial losses have left Monsanto and its German owner Bayer AG under siege. Angry investors have pushed share prices to the lowest levels in roughly seven years, erasing more than 40 percent of Bayer’s market value. And some investors are calling for Bayer CEO Werner Baumann to be ousted for championing the Monsanto acquisition, which closed in June of last year just as the first trial was getting underway.Bayer maintains that there is no valid evidence of cancer causation associated with Monsanto’s herbicides, and says it believes it will win on appeal. But U.S. District Judge Vince Chhabria has ordered Bayer to begin mediation talks aimed at potentially settling the sprawling mass of lawsuits that includes roughly 13,400 plaintiffs in the United States alone. All the plaintiffs are cancer victims or their family members and all allege Monsanto engaged in a range of deceptive

tactics to hide the risks of its herbicides, including manipulating the scientific record with ghostwritten studies, colluding with regulators, and using outside individuals and organizations to promote the safety of its products while making sure they falsely appeared to be acting independently of the company.A May 22 hearing is being held in part to define details of the mediation process. Bayer has indicatedthat it will comply with the order, but may not yet be ready to consider settling the litigation despite the courtroom losses.Meanwhile, the litigation that originated in the United States has crossed the border into Canada where a Saskatchewan farmer is leading a class action lawsuit against Bayer and Monsanto making allegations that mirror those in the U.S. lawsuits.“THE QUEEN OF ROUNDUP”Elaine Stevick of Petaluma, California was supposed to be the next in line to take on Monsanto at trial. But in his order of mediation, Judge Chhabria also vacated her May 20 trial date. A new trial date is to be discussed at the hearing on Wednesday.Stevick and her husband Christopher Stevick sued Monsanto in April of 2016 and said in an interview that they are eager to get their chance to confront the company over the devastating damage they say Elaine’s use of Roundup has done to her health. She was diagnosed in December 2014 at the age of 63 with multiple brain tumors due to a type of non-Hodgkin lymphoma called central nervous system lymphoma (CNSL). Alberta Pilliod, who just won the most recent trial, also had a CNSL brain tumor.The couple purchased an old Victorian home and overgrown property in 1990 and while Christopher worked on renovating the interior of the house, Elaine’s job was to spray weed killer over the weeds and wild onions that the couple said took over a good portion of the property. She sprayed multiple times a year until she was diagnosed with cancer. She never wore gloves or other protective clothing because believed it to be as safe as advertised, she said.Stevick is currently in remission but nearly died at one point in her treatment, Christopher Stevick said.“I called her the ‘queen of Roundup’ because she was always walking around spraying the stuff,” he said.The couple attended parts of both the Pilliod and Hardeman trials, and said they are grateful the truth about Monsanto’s actions to hide the risks are coming into the public spotlight. And they want to see Bayer and Monsanto start warning users about the cancer risks of Roundup and other glyphosate-based herbicides.“We want the companies to take responsibility for warning people -even if there is a chance that something would be harmful or hazardous for them, people should be warned,” Elaine Stevick said.(Published first in Environmental Health News)Follow @Careygillam on Twitter

shocking, snowballing lo********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

Mary Fraser <[email protected]>

06/20/2019 03:24 PM


cc Subject Pesticide usage in school

5 attachments

The_Unintended_Consequences_of_Using_Glyphosate_Dec-2015.pdfThe_Unintended_Consequences_of_Using_Glyphosate_Dec-2015.pdf

chapter-10---pesticide-health-effects-and-children.pdfchapter-10---pesticide-health-effects-and-children.pdf Kids need Protection-EPA.docxKids need Protection-EPA.docx

Exec Summary- A Generation in Jeopardy.docxExec Summary- A Generation in Jeopardy.docx Toxic_concoctions.pdfToxic_concoctions.pdf

Pesticides should never be used anywhere near children. They are more susceptible to the effects due to their immature endocrine system and their intimate contact with the environment. See the report from the EPA that is attached.I am attaching a paper detailing the consequences of glyphosate, the active ingredient in the pesticide Roundup and other glyphosate based formulations. This paper can be found on the national website of the Sierra Club, which is an endorsement of its veracity.I am also attaching other scientific papers that speak to the toxicity of pesticides.There are 18,000 registered pesticides. Please ban them all for use in schools. The entire formulations of pesticides are never tested. I am attaching a paper about toxic concoctions that explains this.Regards,Mary Fraser********************************************************************************This email was scanned by the Cisco IronPort Email Security System contracted by the Hawaii Dept of Education. If you receive suspicious/phish email, forward a copy to [email protected]. This helps us monitor suspicious/phish email getting thru. You will not receive a response, but rest assured the information received will help to build additional protection.********************************************************************************

1

The Unintended Consequences of Using Glyphosate (the main ingredient in the herbicide Roundup)

By Sharon Rushton, Ann Spake, and Laura Chariton December, 2015

Glyphosate-based herbicides are now the most commonly used herbicides in the world. They are still promoted as “safe”, despite scientific evidence of their harm to health and the environment. This report describes Glyphosate’s properties, including its persistence, activity and mobility, and herbicidal mechanism of action. It demonstrates how Glyphosate, Glyphosate herbicide formulations with adjuvants, and associated metabolites could contaminate and harm all facets of an ecosystem, including the soil biology and composition, water, and non-target plants, aquatic organisms, amphibians, reptiles, invertebrates, animals, and humans. It further demonstrates that using Glyphosate could increase the risk of fires, erosion, and herbicide-resistant super weeds. I. OVERVIEW Glyphosate was patented by Monsanto as an herbicidal agent in 1974.1 It has become the most popular herbicide in the world since Glyphosate tolerant genetically modified (GM) crops were commercialized in the mid-1990s, together with the assumption (perpetrated by Monsanto) that the herbicide is safe for health and the environment. Agricultural use of Glyphosate in the US increased from less than 5000 to more than 80,000 metric tons/yr. between 1987 and 2007.2 As well as being used on GM Roundup Ready crops, Glyphosate herbicides are increasingly used as desiccants on conventional grain crops to dry them before harvest, making the grains easier to harvest and store without rotting. The herbicide is also widely used on public roads, railway lines, parks, open space, forests, and other public places as well as on private home gardens. Non-agricultural use has risen steadily in the U.S., from 2270 metric tons/yr. in 1993 to 9300 metric tons/yr. in 2007.3 The widespread and massive application of glyphosate herbicides has resulted in extensive contamination of the environment. A 2014 study on US water systems (including rivers, lakes, streams, lakes ponds, wetlands, precipitation, soil and sediment, soil water, ditches, drains, and groundwater) across 38 states found Glyphosate in 39.4% of samples and its principle metabolite AMPA (aminomethylphosphonic acid) in 55% of samples.4 70% of rain samples tested positive for Glyphosate. 1 Monsanto. Glyphosate and Roundup Brand Herbicides. Available at: http://www.monsanto.com/glyphosate/pages/default.aspx 2 Battaglin WA, Meyer MT, Kuivila KM, and Dietze JE. Glyphosate and Its Degradation Product AMPA Occur Frequently and Widely in U.S. Soils, Surface Water, Groundwater, and Precipitation. Journal of the American Water Resources Association (JAWRA) 2014, 50, 275-290, DOI:10.111/jawr.12159 3 Sirinathsinghji E. 2014. Widespread Glyphosate Contamination in USA. Institute of Science in Society. Available at: http://www.i-sis.org.uk/Widespread_Glyphosate_Contamination_in_US.php 4 Battaglin WA, Meyer MT, Kuivila KM, and Dietze JE. Glyphosate and Its Degradation Product AMPA Occur Frequently and Widely in U.S. Soils, Surface Water, Groundwater, and

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Glyphosate formulations are often claimed to be safe by industry-linked sources. However, these claims are based on outdated and largely unpublished studies on the isolated ingredient glyphosate, commissioned by manufacturers in support of their application for regulatory authorization.5 6 In contrast, independent studies show that Glyphosate is toxic and commercial glyphosate herbicide formulations, which contain extra added ingredients (adjuvants) are more toxic than Glyphosate alone. As demonstrated in this report, respected scientific studies show that there is a strong correlation between Glyphosate and Glyphosate formulations and serious health and environmental hazards, including disruption of hormonal systems and beneficial gut bacteria, damage to DNA, developmental and reproductive toxicity, birth defects, cancer and neurotoxicity. Glyphosate-based herbicides can harm all facets of an ecosystem, including the soil biology and composition, water, and non-target plants, aquatic organisms, amphibians, reptiles, invertebrates, animals, and humans. Glyphosate use could foster herbicide-resistant super weeds. Glyphosate is a patented desiccant (a drying agent) and could greatly increase the risk of fire. Glyphosate’s effect on the soil composition could lead to greater risk of runoff and erosion. Glyphosate and its metabolites can be highly active and mobile and persist for many years in the environment, depending on conditions. Using toxic Glyphosate and Glyphosate formulations could not only harm beneficial vegetation and wildlife but could also jeopardize public health and safety. Moreover, we support the Precautionary Principle, as described in the Marin Countywide Plan; “The Precautionary Principle carries the sense of foresight and preparation, and is the common-sense idea behind many adages: ‘Be careful’, ‘Better safe than sorry’; ‘Look before you leap’; ‘First, do no harm’. Historically, many environmentally harmful activities were stopped only after they resulted in environmental degradation or serious harm to many people. The precautionary principle is an approach characterized by minimizing or eliminating potential hazards at the onset of an activity instead of the approach that determines an ‘acceptable level of harm’.”7

Therefore, in accordance with the Precautionary Principle and scientific evidence of Glyphosate’s and Glyphosate formulations’ harm to health and the environment, we recommend a Glyphosate-free approach to vegetation management. Precipitation. Journal of the American Water Resources Association (JAWRA) 2014, 50, 275-290, DOI:10.111/jawr.12159 5 European Commission Health & Consumer Protection Directorate-General. Review report for the active substance glyphosate. 2002. Available at: http://bit.ly/HQnkFj 6 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:205. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/ 7 Marin County Community Development Agency, 2007. Marin Countywide Plan. Marin County. Pg. 1.3-11

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II. GLYPHOSATE’S PROPERTIES AND HERBICIDAL MECHANISM OF ACTION A. How Glyphosate Kills Plants Besides being a broad-spectrum systemic patented herbicide, Glyphosate is also a patented mineral chelator, antibiotic, and desiccant. It disrupts plants’ metabolic shikimate pathway, which starves plants of essential nutrients and weakens their immune systems. Moreover, Glyphosate’s desiccating effects reduce a plant’s ability to uptake water. It essentially gives the plants a condition similar to “Aids”. As a powerful antibiotic, Glyphosate also kills beneficial bacteria and other microorganisms in the soil. Beneficial organisms fix atmospheric nitrogen for plants’ consumption and are necessary for healthy plant growth.8 Without these beneficial microorganisms in the soil to compete with and suppress harmful plant soil-borne pathogens, the lethal soil-borne pathogens, such as Fusarium (**see below), take over and ultimately kill the weakened plants.9 10 11 **Fusarium is a naturally occurring soil fungus that is a plant pathogen. Fusarium invades the roots of plants and either kills the plant outright or prevents normal growth.12 Moreover, if you destroy the beneficial bacteria and microorganisms in the soil, then the desired plants you replace the invasive plants with will not have the soil components they need to survive. B. Glyphosate Can Have High Activity and Mobility 1. Glyphosate’s Activity and Movement in Soil: Depending on conditions, Glyphosate can have high activity and movement in the soil. Glyphosate’s toxicity is compounded by its persistence in the environment. Many studies show that glyphosate remains, chemically unchanged in the environment for long periods of time. Research shows that even when glyphosate binds to soil particles, it will cyclically “desorb” or lose its attraction to soil and become active as an herbicide.13 8 Carlisle, S.M. and Trevors, J.T. (1988), "Glyphosate in the environment." Water, Air, and Soil Pollution 39:409-420. 9 Levesque, C.A. (1987), "Effects of glyphosate on Fusarium spp.: its influence on root colonization of weeds, propagule density in the soil, and crop emergence." Can. J Microbiol. Vol 33, pp 354-360. 10 Sanogo, S., et al,(2000) "Effects of herbicides on Fusarium solani f. sp glycines and development of sudden death syndrome in glyphosate-tolerant soybean." Phytopathology, v. 90 (N1): 57-66. 11 Kremer, R. and Means, N. (2009) Glyphosate and glyphosate-resistant crop interactions with rhizosphere microorganisms. European Journal of Agronomy. Available at: http://naldc.nal.usda.gov/download/35795/PDF 12 Levesque, C.A. (1987), "Effects of glyphosate on Fusarium spp.: its influence on root colonization of weeds, propagule density in the soil, and crop emergence." Can. J Microbiol. Vol 33, pp 354-360. 13 American Bird Conservancy, Pesticide Profile – Glyphosate. American Bird Conservancy. Available at: http://www.abcbirds.org/abcprograms/policy/toxins/profiles/glyphosate.html

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A study entitled; “Hydrogen-bonding Interactions Between the Herbicide Glyphosate and Water-soluble Humic Substances” by Piccolo and Celano, has shown that glyphosate can readily desorb from soil particles in some soil types and can be highly mobile in the soil environment.14 Four soils were used in the study. The key findings included:

• “Levels of adsorption of glyphosate varied in the different soils according to their composition. Least adsorption occurred in the soils containing lower levels of iron oxide. The clay mineral content was also found to be important. Soils containing higher levels of clay minerals adsorbed more glyphosate. However, desorption readily occurred in soil with a high clay mineral but low iron oxide content.

• Large parts of the fixed herbicide can be easily returned to the soil solution. • The least adsorbing soils desorbed up to 80 per cent of the adsorbed herbicide

and the high adsorbing soils released between 15 and 35 percent of the glyphosate adsorbed.

• In soils that are unable to bind with glyphosate long enough for microbial degradation to take place, the herbicide can be extensively mobile in the soil environment.

• Desorbed glyphosate can leach to lower soil layers. • Glyphosate can bond with water soluble humic substances found in soil solution.

Humic substances are the soil components primarily responsible for the mobility of pesticides in soil. Glyphosate can be transported with humic substances to lower soil depths.”15

Another study entitled “Adsorption of Glyphosate on the Clay Mineral Montmorillonite” by Morilla, Undabytia and Maqueda16, found: “Adsorption of glyphosate on clay minerals decreased in the presence of copper, due to the formation of glyphosate-copper complexes. The study concluded that in relation to glyphosate release and mobility in soil, it is necessary to take into account both the soil type and any element in the soil capable of forming complexes with glyphosate.”17 2. Glyphosate’s Activity and Mobility in Water: During rainfall events, storm water collects pesticides, such as insecticides, herbicides and fungicides, and transports them to ditches, streams, rivers, lakes, and estuaries (called surface waters). In addition, agricultural practices and landscape maintenance that use these toxic substances can also contaminate runoff and compromise the health 14 Piccolo, A., Celano, G., 1994. Hydrogen-bonding interactions between the herbicide glyphosate and water-soluble humic substances. Environ. Toxicology and Chemistry 13(11), 1737-1741. 15 Buffin, D., Jewell, T., Health and environmental impacts of glyphosate. 2001:16. Pesticide Action Network UK. Available at: http://www.foe.co.uk/sites/default/files/downloads/impacts_glyphosate.pdf 16 Morillo, E., Undabeytia T. and Maqueda C., 1997. Adsorption of glyphosate on the clay mineral montmorillonite: Effect of Cu(II) in solution and adsorbed on the mineral. Environ. Sci. and Technol. 31(12), 3588-3592. 17 Buffin D, Jewell T. Health and environmental impacts of glyphosate. 2001:16. Pesticide Action Network UK. Available at: http://www.foe.co.uk/sites/default/files/downloads/impacts_glyphosate.pdf

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of watersheds.18 Pesticides may also be washed down through soil and rock layers into underground water sources, such as aquifers (called groundwater). Glyphosate is being detected in surface waters and groundwater wherever it is used. Glyphosate residues have been detected in surface waters across the European Union. The European Glyphosate Environmental Information Sources (EGEIS) summarized surface water monitoring from 1993-2009 for thirteen European countries. Over 50,000 samples were included. Glyphosate was found in 29% of these samples and Glyphosate’s breakdown product, AMPA, was found in 50% of the samples.19 A 2011 study entitled; “Fate and transport of glyphosate and aminomethylphosphonic acid in surface waters of agricultural basins”20 found that Glyphosate and AMPA were frequently detected in surface waters (at a rate of 100% in rivers) of four agricultural basins in the United States. The frequency and magnitude of detections varied across basins, and the load as a percentage of use, ranged from 0.009 to 0.86%, and could be related to three general characteristics: source strength (high application rates), rainfall resulting in overland runoff, and a flow route that does not include transport through the soil. 18 National Oceanic and Atmospheric Administration. 2012. Water Quality: How Toxic Runoff Affects Pacific Salmon and Steelhead. National Oceanic and Atmospheric Administration. Available at: http://www.westcoast.fisheries.noaa.gov/publications/habitat/fact_sheets/stormwater_fact_sheet.pdf 19 Friends of the Earth Europe, 2013. The environmental impacts of glyphosate. Friends of the Earth Europe. Available at: https://www.foeeurope.org/sites/default/files/press_releases/foee_5_environmental_impacts_glyphosate.pdf 20 Coupe RH, Kalkhoff SK, Capel PD and Gregoire C, 2011. “Fate and transport of glyphosate and aminomethylphosphonic acid in surface waters of agricultural basin”. Pesticide Management Science, 67, doi: 10.1002/ps.2212

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Summary of Data on Glyphosate in Surface Waters Source: Friends of the Earth Europe (2013)21

Glyphosate residues have also been detected at low levels in groundwater, which is used for drinking water. “The European Glyphosate Environmental Information Sources (EGEIS) summarized groundwater monitoring from over 8900 European locations between 1993 and 2009, and found a low percentage (1.3%) contaminated with glyphosate, with 270 (.07%) samples above the maximum permitted in drinking water (0.1 ug/litre).22 Monitoring of small boreholes in four Danish counties found glyphosate present in 8.8% of the wells analysed, with 3.4% exceeding the drinking water maximum. In France, glyphosate accounted for 2.9% of all samples exceeding the drinking water limit in samples of raw water destined for public supply (2000-2002). Results of monitoring in Catalonia in north east Spain between 2007 and 2010 found the glyphosate in 41% of 140 groundwater samples, with a maximum of 2.5μg/litre and an

21 Friends of the Earth Europe, 2013. The environmental impacts of glyphosate. Friends of the Earth Europe. Available at: https://www.foeeurope.org/sites/default/files/press_releases/foee_5_environmental_impacts_glyphosate.pdf 22 Horth H., 2010. EGEIS, Monitoring results for surface and groundwater. Available at: http://www.egeis.org/documents/11%20Detection%20in%20SW%20and%20GW%20draft%20v3.pdf

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average of 0.2μg/litre23.”24 A more recent 2014 study entitled; “Glyphosate and Its Degradation Product AMPA Occur Frequently and Widely in U.S. Soils, Surface Water, Groundwater, and Precipitation”25 summarizes the results of 3,732 water and sediment and 1,018 quality assurance samples between 2001 and 2010 from 38 states. They found Glyphosate in 39.4% of samples (1470 out of 3732) and its metabolite AMPA (aminomethylphosphonic acid) in 55% of samples. Water samples included streams, groundwater, ditches and drains, rivers, soil water, lakes, ponds, wetlands, precipitation, soil and sediment, and waste water treatment plants. Other U.S. studies have also detected Glyphosate in the air and rain and in water from spring snow-melt26. A study entitled; “Pesticides in Mississippi air and rain; A comparison between 1995 and 2007”, disclosed that glyphosate was found in over 75% of air and rain samples tested in Mississippi in 2007.27 The study revealed that involuntary exposure to the herbicide can be significant. C. Glyphosate and Its Metabolites Can Persist For Many Years In The Environment, Depending On Conditions A number of studies have shown that, depending on conditions, Glyphosate and its metabolites can persist for many years in the environment. Nomura and Hilton (1977) reported glyphosate half-lives of up to 22 years in soils with pH<6 and organic matter contents of over 90 g kg-1.28 AMPA, a toxic and major metabolite of glyphosate, has also been found to be very persistent, with a half-life in soil between 119 and 958 days.29 30 In

23 Sanchis J et al ,2012. Determination of glyphosate in groundwater samples using an ultrasensitive immunoassay and confirmation by on-line solid-phase extraction followed by liquid chromatography coupled to tandem mass spectrometry Analytical and Bioanalytical Chemistry 402 :2335-2345 24 Friends of the Earth Europe, 2013. The environmental impacts of glyphosate. Friends of the Earth Europe. Available at: https://www.foeeurope.org/sites/default/files/press_releases/foee_5_environmental_impacts_glyphosate.pdf 25 Battaglin WA, Meyer MT, Kuivila KM, and Dietze JE. Glyphosate and Its Degradation Product AMPA Occur Frequently and Widely in U.S. Soils, Surface Water, Groundwater, and Precipitation. Journal of the American Water Resources Association (JAWRA) 2014, 50, 275-290, DOI:10.111/jawr.12159 26 Battaglin W.A., Rice K.C., Focazio M.J., Salmons S. and Barry R.X., 2009. The occurrence of glyphosate, atrazine, and other pesticides in vernal pools and adjacent streams in Washington, DC, Maryland, Iowa, and Wyoming, 2005–2006. Environmental Monitoring and Assessment 155, 281-307. 27 Majewski MS, Coupe RH, Foreman WT, Capel PD Environ Toxicol Chem. 2014 Feb 19. doi: 10.1002/etc.2550. Pesticides in Mississippi air and rain: A comparison between 1995 and 2007. 28 Nomura, N.S., Hilton, H.W., 1977. The adsorption and degradation of glyphosate in five Hawaiian sugarcane soils. Weed Res. 17:113–121. 29 World Health Organization (WHO), 1994. Glyphosate. Environmental Health Criteria 159. The International Programme on Chemical Safety (IPCS). WHO, Geneva.

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water, glyphosate has a long persistence in sediments. Hun-Min Hwang and Thomas M. Young Environmental Quality Laboratory Department of Civil and Environmental Engineering, University of California, Davis prepared a report for MMWD about MMWD watershed lands entitled; "Final Report - Environmental decay of glyphosate in broom-infested Mt. Tamalpais soils and its transport through stormwater runoff and soil column infiltration". The report reached the following conclusions:

• Half-life in soil of Glyphosate and its metabolite AMPA: The half-life of glyphosate in soil was 44 days. The half-life of AMPA in soil was 46 days.

• Half-life in broom leaves that failed to drop to ground: Concentrations of glyphosate in broom leaves didn’t exhibit significant changes over the 84 days of the study period, indicating that half-life of glyphosate is likely to be much longer than 84 days as long as the leaves remain attached to the stems and branches.

Other records of glyphosate persistence include31 32:

• 249 days on Finnish agricultural soils; • Between 259 and 296 days on eight Finnish forestry sites; • Between one and three years on 11 Swedish forestry sites; • 335 days on a Canadian forestry site; • 360 days on three Canadian forestry sites; • 12 to 60 days in pond water following direct application; • Glyphosate residues in pond sediment were found 400 days after direct

application; • More than one year in studies of pond sediments in the US.

Glyphosate travels through soil, air and water. The longer Glyphosate persists in the environment, the greater the chance of cumulative impacts and exposure of non-target plants, wildlife, pets and humans to the herbicide. Residents, pets and wildlife could be exposed to Glyphosate by walking through open space and breathing in contaminated airborne dust particles. Children could be exposed while playing on a contaminated field. Children, pets and wildlife could also be exposed by drinking water from contaminated streams and ponds. III. THE TOXIC EFFECTS OF GLYPHOSATE ON NON-TARGET PLANTS, AQUATIC ORGANISMS, AMPHIBIANS, REPTILES, INVERTEBRATES, ANIMALS, AND HUMANS A. Glyphosate Use Would Harm Beneficial Vegetation

30 Buffin, D., Jewell, T., 2001. Health and Environmental Impacts of Glyhosate. Pesticide Action Network UK. Available at: http://www.foe.co.uk/sites/default/files/downloads/impacts_glyphosate.pdf 31 Reviewed by Cox, C., 1995b op cit 12. 32 Buffin, D., Jewell, T., 2001. Health and Environmental Impacts of Glyhosate. Pesticide Action Network UK. Available at: http://www.foe.co.uk/sites/default/files/downloads/impacts_glyphosate.pdf

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Glyphosate can be acutely toxic to non-target plants, including aquatic plants and algae. The effects of this toxicity on natural plant succession alters the ecology of treated areas. In most cases, the plant species diversity will decrease, and along with it, the numbers of insects, mammals and birds utilizing these areas as habitat.33 34 1. Review Of How Glyphosate Kills Plants: As mentioned before, besides being a broad-spectrum systemic patented herbicide, Glyphosate is also a patented mineral chelator, antibiotic, and desiccant. It disrupts plants’ metabolic shikimate pathway, which starves plants of essential nutrients and weakens their immune systems. Moreover, Glyphosate’s desiccating effects reduce a plant’s ability to uptake water. It essentially gives the plants a condition similar to “Aids”. As a powerful antibiotic, Glyphosate also kills beneficial bacteria and other microorganisms in the soil. Beneficial organisms fix atmospheric nitrogen for plants’ consumption and are necessary for healthy plant growth.35 Without these beneficial microorganisms in the soil to compete with and suppress harmful plant soil-borne pathogens, the lethal soil-borne pathogens, such as Fusarium (**see below), take over and ultimately kill the weakened plants.36 37 **Fusarium is a naturally occurring soil fungus that is a plant pathogen. Fusarium invades the roots of plants and either kills the plant outright or prevents normal growth.38 Moreover, if you destroy the beneficial bacteria and microorganisms in the soil, then the desired plants you replace the invasive plants with will not have the soil components they need to survive. 2. How Glyphosate Kills Non-Target Plants: Glyphosate doesn’t just kill the targeted weeds but kills adjacent beneficial vegetation too. Glyphosate can readily desorb from soil particles in some soil types and can be highly mobile in the soil environment. Glyphosate travels from the root system of the targeted weed into the soil where it is picked up by adjacent roots of desirable plants and trees, ultimately killing them.

33 Santillo, D.J. et al (1989), "Response of songbirds to glyphosate-induced habitat changes on clear-cut." Journal of Wildlife Management, v. 53 no. 1, 64-71. 34 Connor, J.F. and McMillan, L.M. (1990), "Winter utilization by moose of glyphosate-treated cutovers." Alces 26:91-103. 35 Carlisle, S.M. and Trevors, J.T. (1988), "Glyphosate in the environment." Water, Air, and Soil Pollution 39:409-420. 36 Levesque, C.A. (1987), "Effects of glyphosate on Fusarium spp.: its influence on root colonization of weeds, propagule density in the soil, and crop emergence." Can. J Microbiol. Vol 33, pp 354-360. 37 Sanogo, S., et al,(2000) "Effects of herbicides on Fusarium solani f. sp glycines and development of sudden death syndrome in glyphosate-tolerant soybean." Phytopathology, v. 90 (N1): 57-66. 38 Levesque, C.A. (1987), "Effects of glyphosate on Fusarium spp.: its influence on root colonization of weeds, propagule density in the soil, and crop emergence." Can. J Microbiol. Vol 33, pp 354-360.

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Don Huber PhD and Joe Holland authored an article on glyphosate and plant diseases in the European Journal of Agronomy (2009). The article demonstrates that Glyphosate predisposes plants and trees to disease and toxins. The article shows that glyphosate can increase the spread of Phytophthora (Sudden Oak Death) in oak trees (non-target species) among other plants. Glyphosate is also a threat to non-target plants as a result of spray drift from target areas. In the US, sub-lethal doses of herbicides have been blamed for reducing winter hardiness and resistance to fungal diseases in trees.39 Studies of the impact of spray drift include:

• “A study of the effects of spray drift of a glyphosate formulation on British species commonly found in nature reserves. The plant species were exposed to spray drift at different distances, wind speeds and application rates (o.5 and 2.2 kg a.i./ha). Death and severe growth suppression occurred at a distance of 2-6 meters from the sprayer. Sub-lethal effects could be detected up to 20 metres away for one species, Prunella vulgaris (self heal). Some species were consistently more sensitive including Digitalis purpurea (foxglove), Centaurea nigra (hard head), Prunella vulgaris (self heal) and Lychnis flos-cuculi (ragged robin). Epinasty (more rapid growth of the upper side of an organ causing for example curling in a leaf) was the most frequent symptom of damage40…

• A study looked at species typical to UK woodland margins, hedgerows and field margins. The plant communities were exposed to glyphosate and other herbicides each year for at least three years. The effects of sub-lethal doses were measured on species yield, flowering performance, seed production, seed variability and invasion of new species. All species showed some effects within an eight-metre zone41…

• A UK Forestry Commission study into the decline of hedgerow ash found that 19 percent of hedgerow ash showed symptoms of dieback. Trees in rural areas were more badly affected than urban trees. In rural areas, dieback was strongly associated with arable land. The Forestry Commission believes that hormone and glyphosate herbicides commonly affect hedgerow trees and may in part be responsible for the dieback in ash.42” 43

B. Toxic Effects of Glyphosate on Aquatic Organisms Glyphosate can contaminate surface water either directly as a result of aquatic weed control or indirectly when glyphosate bound to soil particles is washed into rivers, 39 ENDS Report 193, February 1991. 40 Marrs R.H., Williams, C.T., Frost, A.J. and Plant, R.A. 1989. Assessment of the effects of herbicide spray drift on a range of plant species of conservation interest. Environ. Pollut 59(1), 71-86. Cited in WHO, 1994 op cit 7. 41 Marrs, R.H. and Frost, A.J., 1997. A microcosm approach to the detection of the effects of herbicide spray drift in plant communities. J. of Environ. 42 Forestry Commission. Bulletin 93, Ash dieback. HMSO. London. (Reported in: ENDS Report 193, February 1991.) 43 Buffin D, Jewell T. Health and environmental impacts of glyphosate. 2001: 16. Pesticide Action Network UK. Available at: http://www.foe.co.uk/sites/default/files/downloads/impacts_glyphosate.pdf

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streams, lakes and estuaries44. Studies show that peak herbicide concentrations tend to occur during the first runoff after herbicide application and that herbicide flushes can occur during runoff for several weeks to months following application. When herbicides enter our waterways via stormwater runoff, they can cause a variety of adverse effects to aquatic species. In addition to directly impacting salmon and steelhead, the toxics can harm or kill the aquatic insects that salmon eat. Pollution risks vary depending on the particular chemical, the amount transported in stormwater, and environmental persistence.45 Studies with fish show that glyphosate can be moderately toxic alone, but when combined with the surfactant normally found in commercial products, the toxicity is greater.46 47 Glyphosate and commercially formulated products containing POEA (Polyoxyethylenetallowamine) surfactant are toxic to fish and to some aquatic invertebrates48 49. POEA is about 30 times more toxic to fish than glyphosate50.

The toxicity of glyphosate increases with higher temperatures in fish; one study found that the toxicity of glyphosate doubled in bluegill and in rainbow trout test subjects when the temperature of the water was increased from 45 to 63 degrees F.51 52

44 World Health Organisation (WHO), 1994. Glyphosate. Environmental Health Criteria 159. The International Programme on Chemical Safety (IPCS). WHO, Geneva. 45 National Oceanic and Atmospheric Administration, 2012. Water Quality: How Toxic Runoff Affects Pacific Salmon and Steelhead. National Oceanic and Atmospheric Administration. Available at: http://www.westcoast.fisheries.noaa.gov/publications/habitat/fact_sheets/stormwater_fact_sheet.pdf 46 Folmar, L.C. et al (1979) "Toxicity of the herbicide glyphosate and several of its formulations to fish and aquatic invertebrates." Archives of Environmental Contamination and Toxicology, v 8, 269-278. 47 Austin, A.P., et al (1991), "Impact of an organophosphate herbicide (glyphosate) on periphyton communities developed in experimental streams." Bulletin of Environmental Contamination and Toxicology, v. 47, 29-35. 48 World Health Organisation (WHO), 1994. Glyphosate. Environmental Health Criteria 159. The International Programme on Chemical Safety (IPCS). WHO, Geneva. 49 Cox, C., 1995b. Glyphosate, Part 2: Human Exposure and Ecological Effects. J. Pesticide Reform 15 (4), 14-20. 50 Servizi, J.A., Gordan, R.W. and Martens, D.W., 1987. Acute toxicity of Garlon 4 and Roundup herbicides to salmon, Daphnia and trout. Bull. Environ. Contam. Toxicol. 33, 355-361. Cited in Cox, C. 1995b op cit 12. 51 Folmar, L.C. et al (1979) "Toxicity of the herbicide glyphosate and several of its formulations to fish and aquatic invertebrates." Archives of Environmental Contamination and Toxicology, v 8, 269-278. 52 Austin, A.P., et al (1991), "Impact of an organophosphate herbicide (glyphosate) on periphyton communities developed in experimental streams." Bulletin of Environmental Contamination and Toxicology, v. 47, 29-35.

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The thesis entitled; “Neurotoxicity of pesticides to salmon: Physiology to Ethology” by Keith Bryan Tierney with the Simon Fraser University Biological Sciences Department53, demonstrates that pesticides routinely found in the environment can adversely affect neurological systems in salmon. When the nervous system is affected, it impairs environmental information about food, predators, mates, siblings or environmental conditions. The major focus of Tierney’s studies is on the impairment of the relatively exposed olfactory sensory neurons (OSNs), since their functionality is critical to several indispensable behaviors. The responses of OSNs to various behaviorally-relevant odorants were impaired following exposure to several pesticide classes, including triazine (e.g. atrazine), carbamate (e.g. IPBC), organophosphorus (e.g. dimethoate), and phenylurea (e.g. linuron) pesticides, as well as a pesticide formulation (i.e. Roundup). In many cases, within minutes of exposure to environmentally realistic (part per billion) concentrations, impairments of greater than 50% in OSN responses were noted. In an exposure, the uptake and distribution of pesticides and their metabolites have capacity to alter the neurological system. Clearly, the impairment of this system translates to a genuine survival challenge. C. Toxic Effects of Glyphosate on Amphibians Vernal pools are sensitive environments that provide critical habitats for many species, including amphibians. In 2005 and 2006, water samples were collected from vernal pools and adjacent flowing waters in parks in Iowa, Washington, D.C., and Maryland, prior to and just after the local use of glyphosate (Battaglin et al. 2008)54. At each site there was a treatment pool (with adjacent glyphosate use), a control pool (with no glyphosate use nearby), and a flowing stream (with multiple potential glyphosate sources). In addition, a park in Wyoming was a study control with no reported glyphosate use nearby. Results indicate that vernal pools and adjacent streams can be contaminated by the use of herbicides within parks to control weeds in cropped areas or to kill noxious or nonindigenous plants. Contamination also originates from pesticide use occurring outside park boundaries (Battaglin et al. 2008)55. Glyphosate was detected in 31 of 76 samples with a maximum concentration of 328 μg/L, measured in a sample collected from a vernal pool in Rock Creek Park, Washington, D.C. That sample was collected seven days after glyphosate was applied by backpack sprayer in the area near the site to control lesser celandine (Ranunculus ficaria) and one day after approximately 3 cm of rain fell at the site. 53 Tierney, K., 2007. Neurotoxicity of pesticides to salmon: Physiology to ethology. Simon Fraser University. Available at: http://summit.sfu.ca/item/8281 54 Battaglin, W. A., K. C. Rice, M. J. Focazio, S. Salmons, and R. X. Barry. 2009. The occurrence of glyphosate, atrazine, and other pesticides in vernal pools and adjacent streams in Washington, D.C., Maryland, Iowa, and Wyoming, 2005-200. Environmental Monitoring and Assessment 155:281-307 55 Battaglin, W. A., K. C. Rice, M. J. Focazio, S. Salmons, and R. X. Barry. 2009. The occurrence of glyphosate, atrazine, and other pesticides in vernal pools and adjacent streams in Washington, D.C., Maryland, Iowa, and Wyoming, 2005-200. Environmental Monitoring and Assessment 155:281-307

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Deleterious effects on the development and survival of amphibians have been observed at various levels of exposure to commercial glyphosate formulations, in some cases at concentrations of 1,000 μg/L or less (Cauble and Wagner 200556; Edginton et al. 200457; Howe et al. 200458; Relyea 200559; Dinehart et al. 200960). Most of these studies indicate that commercial glyphosate formulations are more toxic than pure glyphosate due to the effects of the surfactants used (Howe et al. 200461: Bringolf et al. 200762). For example, a University of Pittsburgh study by Dr. Rick Relyea entitled; “The Impact of Insecticides and Herbicides on the Biodiversity and Productivity of Aquatic Communities”63 examined the impact of four globally common pesticides, including Roundup, on the biodiversity of aquatic communities containing algae and 25 species of animals. The study revealed that the application of Roundup, at a concentration equivalent to direct overspray on a wetland (3.8 mg glyphosate/L), resulted in a 22% reduction in species richness of all animal taxa in the communities. Moreover, Roundup completely eliminated two species of tadpoles and nearly exterminated a third species, resulting in a 70% decline in the species richness of tadpoles. The toxic effect of Glyphosate on amphibians could increase the risk of West Nile Virus: Research has shown that Glyphosate kills tadpoles and frogs. Since these amphibians eat mosquito larvae, use of Glyphosate, due its harm to the amphibians, could significantly increase the risk of West Nile Virus. 64

56 Cauble, K., and R. S. Wagner. 2005. Sublethal effects of herbicide glyphosate on amphibian metamorphosis and development. Bulletin of Environmental Contamination and Toxicology 75:429–435. 57 Edginton, A. N., P. M. Sheridan, G. R. Stephenson, D. G. Thompson, and H. J. Boermans. 2004. Comparative effects of pH and Vision® on two life stages of four anuran amphibian species. Environmental Toxicology and Chemistry 23(4):815–822 58 Howe, C. M., M. Berrill, B. D. Pauli, C. C. Helbing, K. Werry, and N. Veldhoen. 2004. Toxicity of glyphosate-based pesticides to four North American frog species. Environmental Toxicology and Chemistry 23(8):1928–1934. 59 Relyea, R. A. 2005. The lethal impacts of Roundup® and predatory stress on six species of North American tadpoles. Archives of Environmental Contaminant Toxicology 48:351–357. 60 Dinehart, S. K., L. M. Smith, S. T. McMurry, T. A. Anderson, P. N. Smith, and D. A. Haukos. 2009. Toxicity of a glufosinate- and several glyphosate-based herbicides to juvenile amphibians from the Southern High Plains, USA. Science of the Total Environment 407:1065–1071. 61 Howe, C. M., M. Berrill, B. D. Pauli, C. C. Helbing, K. Werry, and N. Veldhoen. 2004. Toxicity of glyphosate-based pesticides to four North American frog species. Environmental Toxicology and Chemistry 23(8):1928–1934. 62 Bringolf, R. B., W. G. Cope, S. Mosher, M. C. Barnhart, and D. Shea. 2007. Acute and chronic toxicity of glyphosate compounds to glochidia and juveniles of Lampsilis siliquoidea (Unionidae). Environmental Toxicology and Chemistry 26(10):2094–2100. 63 Relyea, R. 2005. The Impact of Insecticides and Herbicides on the Biodiversity and Productivity of Aquatic Communities. Ecological Society of America. 15(2):618-627. Available at: http://whyy.org/91FM/ybyg/relyea2005.pdf 64 Richard A. Relyea, PhD. Ecological Applications, vol.15, No.2, 2005

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D. Toxic Effects of Glyphosate on Reptiles and Potential Increase in the Risk of Lyme Disease According to Jacob Leone ND reporting to the Marin Health Council on March 25, 2014, Lyme disease is endemic to California and Marin County. Regarding epidemiology, he reported that there is greater incidence of Lyme disease in Marin County than HIV or Breast Cancer. An article entitled; “Lizard, Tick, Lyme Disease Study Yields Surprise” by David Perlman stated; "The tiny black-legged ticks, abundant throughout the woods of Northern California, carry microbes that can cause Lyme disease in humans they bite. The common Western Fence Lizards eat those ticks by the millions. Wherever the lizards abound, the population of disease- carrying ticks would be low. That's what scientists have believed. And the smaller the tick population, the lower the risk of Lyme disease. Fewer lizards should result in more of the dangerous ticks. Western fence lizards carry a protein in their blood that kills the Borrelia bacteria, which cause Lyme disease. When the ticks feed on the lizards' blood, the protein cleanses their bodies of the bacteria, so their annoying bites no longer pose a Lyme disease risk."65 “In 1998 it was discovered that when a Western black-legged tick feeds on a Western fence lizard, the Lyme disease causing bacteria, Borrelia Borgdorferi, is killed. The tick lives but its blood is cleansed of the Borrelia bacteria, so its next bite becomes more of a nuisance than a threat to one's health.” “In areas with Western Fence Lizards, about 5% of ticks carry the disease, while in other areas 50% of ticks harbor the disease.”66 A study on the impact of glyphosate formulations with POEA on the New Zealand Common Skink, a type of lizard, found that skinks sprayed with glyphosate plus POEA selected warmer microclimates and had slower sprint speeds, which can result in lower survival rates.67 Selecting hotter microclimates can lead to dehydration and greater predation rates, as skinks are more likely to be basking in exposed areas. Sprint speed is an important predictor of lizard health and survival as lizards with slow sprint speeds find it harder to capture prey and escape predators.68 Based on the study’s findings, New Zealand’s Department of Conservation expressed concern about the use of glyphosate formulations containing POEA in areas that are inhabited by rare or threatened lizard species.69 Although the study did not specifically examine the impact of glyphosate formulations with POEA on the Western Fence Lizard, it is reasonable to expect that the formulations 65 Perlman, D., Feb. 22, 2011. Lizard, Tick, Lyme Disease Study Yields Surprise. SF Gate 66 Website of Hastings, a biological Field Station of the University of California. Available at: http://www.hastingsreserve.org/ 67 Carpenter, J. K., 2013. Evaluating the effect of glyphosate formulations on the New Zealand common skink (Oligosoma polychroma) (Honours thesis). Victoria University of Wellington, Wellington. 68 Miles, D. B., 2004. The race goes to the swift: fitness consequences of variation in sprint performance in juvenile lizards. Evolutionary Ecology Research, 6(1), 63‐ 75. 69 Carpenter, J. The effect of glyphosate herbicides on lizards. New Zealand Department of Conservation – Te Papa Atawbai. Available at: http://www.ecogecko.co.nz/documents/glyphosate%20lizards.pdf

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could have a similar adverse impact on the Western Fence Lizard as they did on the New Zealand Common Skink. If so, then the use of Glyphosate formulations could reduce Western Fence Lizards populations and thereby increase the percent of ticks that harbor Lyme disease. E. Toxic Effects of Glyphosate on Invertebrates Studies have shown that glyphosate can have both a direct toxic effect and an indirect impact due to habitat change or destruction on invertebrates. 1. Direct and Indirect Toxic Effects of Glyphosate on Forest-Dwelling Invertebrates: Below are two studies that demonstrate a direct toxic effect and indirect effect due to habitat change on forest-dwelling invertebrates:

• “A laboratory study found that Roundup exposure caused a decrease in the survival and a decrease in body weight of woodlice70.”71

• “In the US, a three-year study found that herbivorous insects and ground invertebrates were significantly reduced up to three years after treatment with Roundup in a four-to-five-year-old clear-cut planted with spruce seedlings. The vegetation did not recover over the study period and the authors concluded that the effects on the forest organisms were mainly due to habitat change72.”73

2. Indirect Toxic Effects of Glyphosate on Monarch Butterflies: Glyphosate’s indirect effect on invertebrates due to habitat destruction is also exemplified by the decline of Monarch butterfly numbers.74 A 2011 study led by Isabel Ramirez at Universidad Nacional Autonoma found that Monarch butterfly migration abundance had been declining over the previous 17 years due to extreme weather conditions, over-logging of the Monarch’s migratory destination in Mexico and herbicidal destruction (via glyphosate use) of their breeding grounds in the US. The larvae of this species feed almost exclusively on milkweed plants, making abundance of Monarch butterflies critically dependent on milkweed availability. Yet, milkweed is being destroyed by glyphosate treatment of GM crops. Studies assessing milkweed population in Iowa recorded a 90% and 79% loss between 1999-2009 and 2000-2009 respectively. The authors speculate that with such widespread glyphosate usage, milkweed may almost completely disappear from croplands altogether, resulting in a further decline of

70 Mohamed, A.I. et al, 1992. Effects of pesticides on the survival, growth and oxygen consumption of Hemilepistus reaumuri. Trop. Zool. 5, 145-153. Cited in Cox 1995b (Reference 12). 71 Buffin, D., Jewell, T., Health and environmental impacts of glyphosate. 2001: 19. Pesticide Action Network UK. Available at: http://www.foe.co.uk/sites/default/files/downloads/impacts_glyphosate.pdf 72 172. Cited in WHO, 1994 op cit 7. 73 Buffin, D., Jewell, T., Health and environmental impacts of glyphosate. 2001:19. Pesticide Action Network UK. Available at: http://www.foe.co.uk/sites/default/files/downloads/impacts_glyphosate.pdf 74 Sirinathsinghji, E. ISIS Report 19/09/11: Glyphosate and Monarch Butterfly Decline. Institute of Science in Society. 2011. Available at: http://www.i-sis.org.uk/Glyphosate_and_Monarch_Butterfly_Decline.php

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Monarch butterflies.75 3. Direct Toxic Effects of Glyphosate on Honeybees: A 2014 Study entitled; “Effects of field-realistic doses of Glyphosate on honeybee appetitive behavior”76 shows that Glyphosate can disrupt learning behaviors in honeybees and severely impair long-term colony performance. The scientists who conducted the study used field-realistic levels of glyphosate, similar to what honeybees may encounter on a farm growing GMOs. They found that learning behavior (elemental learning and non-elemental associative learning) and short-term memory retention decreased significantly compared with control groups. Since the bees don’t die immediately when exposed to glyphosate, they bring the chemical back to the hive, where larvae come into contact with it. The scientists speculate that “successful forager bees could become a source of constant inflow of nectar with Glyphosate traces that could then be distributed among nest-mates, stored in the hive and have long-term negative consequences on colony performance.”77 F. Toxic Effects Of Glyphosate On Animals And Humans In March 2015, the International Agency for Research on Cancer, part of the World Health Organization (WHO), determined that glyphosate is probably carcinogenic to humans and therefore classified the herbicide as a Group 2A carcinogen.78 79 According to the report “GMO Myths and Truths – Edition 2” by genetic engineers John Fagan, PhD, Michael Antoniou, PhD, and Claire Robinson, MPhil; “Toxic effects of glyphosate and Roundup include disruption of hormonal systems and beneficial gut bacteria, damage to DNA, developmental and reproductive toxicity, birth defects, cancer, and neurotoxicity.”80 “Roundup and other glyphosate herbicide formulations have never been tested or assessed for long-term safety for regulatory purposes. Only glyphosate alone was

75 Sirinathsinghji, E. ISIS Report 19/09/11: Glyphosate and Monarch Butterfly Decline. Institute of Science in Society. 2011. Available at: http://www.i-sis.org.uk/Glyphosate_and_Monarch_Butterfly_Decline.php 76 Herbert LT, Vazquez DE, Arenas A, Farina WM. 2014. Effects of field-realistic doses of glyphosate on honeybee appetitive behavior. The Company of Biologists Ltd. Available at: http://www.ncbi.nlm.nih.gov/pubmed/25063858 77 Herbert LT, Vazquez DE, Arenas A, Farina WM. 2014. Effects of field-realistic doses of glyphosate on honeybee appetitive behavior. The Company of Biologists Ltd. Available at: http://www.ncbi.nlm.nih.gov/pubmed/25063858 78 Bunge, J., Health Agency Says Widely Used Herbicide Likely Carcinogenic. Wall Street Journal. 2015. Available at: http://www.wsj.com/articles/health-agency-says-widely-used-herbicide-likely-carcinogenic-1426885547 79 American Cancer Society, Known and Probable Human Carcinogens. American Cancer Society. 2015. Available at: http://www.cancer.org/cancer/cancercauses/othercarcinogens/generalinformationaboutcarcinogens/known-and-probable-human-carcinogens 80 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:205. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/

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tested. Even the industry tests on glyphosate alone revealed toxic effects, including malformations81.”82 Based on outdated and unpublished studies on the isolated ingredient glyphosate, commissioned by manufacturers in support of their application for regulatory authorization83, the GMO and Pesticide industry authors claim that glyphosate and glyphosate herbicide formulations are non-toxic to animals and humans because glyphosate’s sole mechanism of toxicity is the shikimate biochemical pathway, which plants have but animals lack.84 This is false, as glyphosate also affects other pathways that are present in animals and humans.85 “Glyphosate and Roundup have been found to interfere with the retinoic acid signaling pathway, which affects gene expression in animals and humans. When disrupted, it can result in the development of malformations. Glyphosate and Roundup negatively affect gut bacteria that are vital to the healthy functioning of the immune system. Glyphosate is a chelator of essential nutrient metals, making them unavailable to the plant and therefore to the consumer. Glyphosate and Roundup are endocrine Disruptors, an effect that can lead to multiple health problems during development and adult life. The endocrine disruptive effects are most worrying, as they manifest at very low doses and can lead to ill health when exposure takes place over long periods of time.”86 Study findings regarding the endocrine-disruptive effect of glyphosate and its commercial formulations include the following:

• “Glyphosate herbicide altered hormone levels in female catfish and decreased egg viability. The study concluded that the herbicide is harmful to catfish reproduction. Roundup disrupted production of the steroid hormone progesterone in mouse cells. Glyphosate herbicide was a potent EDC in rats, causing disturbances in reproductive development after exposure during puberty.87

81 Antoniou M, Habib MEM, Howard CV, et al. Teratogenic effects of glyphosate-based herbicides: Divergence of regulatory decisions from scientific evidence. J Env Anal Toxicol. 2012;S4:006. doi:10.4172/2161-0525.S4-006. �� 82 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:205. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/ 83 European Commission Health & Consumer Protection Directorate-General. Review report for the active substance glyphosate. 2002. 84 European Commission Health & Consumer Protection Directorate-General. Review report for the active substance glyphosate. 2002. 85 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:205. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/ 86 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:215. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/ 87 Romano RM, Romano MA, Bernardi MM, Furtado PV, Oliveira CA. Prepubertal exposure to commercial formulation of the herbicide Glyphosate alters testosterone levels and testicular

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• In an in vitro experiment in human cells, glyphosate herbicides prevented the

action of androgens, the masculinizing hormones, at levels up to 800 times lower than glyphosate residue levels allowed in some GM crops used for animal feed in the USA. DNA damage was found in human cells treated with glyphosate herbicides at these levels. Glyphosate herbicides disrupted the action and formation of estrogens, the feminizing hormones. The first toxic effects were found at the low dose of 5 ppm and the first endocrine disruption at 0.5 ppm – 800 times less than the 400 ppm level authorized for some animal feeds.88

• Roundup herbicide at environmentally relevant exposure levels (down to

0.00023% glyphosate dilution of the commercial formulation) caused the dysregulation of large numbers of genes in human breast cancer cells grown in the laboratory in vitro. Of the 1,550 genes analyzed, expression of 680 was either increased or decreased. Roundup was able to replace and work synergistically with estrogen, which is required for growth of the breast cancer cells. This demonstrates the strong potential endocrine disruptive potential of glyphosate in this hormonal system. The authors commented, “There remains an unclear pattern of very complex events following exposure of human cells to low levels of glyphosate, but events surrounding the altered levels of expression of only three genes... out of the entire battery tested, are both complicated and potentially damaging to adult and fetal cells.”89

• Glyphosate alone increased the proliferation of estrogen-dependent breast cancer cells by estrogenic mechanisms in vitro.90

• An in vivo study of Roundup administered to rats in drinking water diluted to 50 ng/L glyphosate equivalence – half of the level permitted in drinking water in the EU91 and 14,000 times lower than that permitted in drinking water in the USA92 – resulted in severe organ damage and a trend of increased incidence of mammary tumours in female animals over a 2-year period of exposure.93 This type of non-

morphology. Arch Toxicol. 2010;84:309-317. 88 Gasnier C, Dumont C, Benachour N, Clair E, Chagnon MC, Séralini GE. Glyphosate-based herbicides are toxic and endocrine disruptors in human cell lines. Toxicology. 2009;262:184-91. doi:10.1016/j.tox.2009.06.006. �� 89 Hokanson R, Fudge R, Chowdhary R, Busbee D. Alteration of estrogen-regulated gene expression in human cells induced by the agricultural and horticultural herbicide glyphosate. Hum Exp Toxicol. 2007;26:747-52. doi:10.1177/0960327107083453. 90 Thongprakaisang S, Thiantanawat A, Rangkadilok N, Suriyo T, Satayavivad J. Glyphosate induces human breast cancer cells growth via estrogen receptors. Food Chem Toxicol. 2013. doi:10.1016/j.fct.2013.05.057. 91 Council of the European Union. Council directive 98/83/EC of 3 November 1998 on the quality of water intended for human consumption. Off J Eur Communities. 1998. Available at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do? uri=OJ:L:1998:330:0032:0054:EN:PDF. 92 US Environmental Protection Agency (EPA). Basic information about glyphosate in drinking water. 2014. Available at: http://water.epa.gov/drink/contaminants/basicinformation/glyphosate.cfm#four. 93 Séralini GE, Clair E, Mesnage R, et al. [RETRACTED:] Long term toxicity of a Roundup

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linear endocrine disruptive effect of glyphosate and Roundup is not taken into account in safety evaluations, resulting in exposures to the public that could lead to severe illness and reproductive and developmental problems.”94

G. Glyphosate Herbicide Formulations With Added Adjuvants Are More Toxic Than Glyphosate Alone According to the report “GMO Myths and Truths – Edition 2” by genetic engineers John Fagan, PhD, Michael Antoniou, PhD, and Claire Robinson, MPhil; “Commercial glyphosate herbicide formulations contain extra added ingredients (adjuvants) and are more toxic than glyphosate alone.”95 “The added ingredients (adjuvants) are toxic96 and increase the toxicity of glyphosate by enabling it to penetrate plant and animal cells more easily, making it more bioavailable.97 98 99”100 “In an in vitro study, eight out of nine major pesticides tested in vitro in their complete formulations, including Roundup, were up to 1,000 times more toxic to human cells than their isolated active ingredients. This increased toxicity of the complete formulation compared with the active ingredient alone was found to be a general principle of pesticide toxicology.101”102 In June 2009, Scientific American published an article by Crystal Gammon and Environmental Health News entitled; “Weed-Whacking Herbicide Proves Deadly to

herbicide and a Roundup- tolerant genetically modified maize. Food Chem Toxicol. 2012;50:4221-4231. 94 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:215. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/ 95 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:205. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/ 96 Bradberry SM, Proudfoot AT, Vale JA. Glyphosate poisoning. Toxicol Rev. 2004;23:159–167. �� 97 Benachour N, Séralini GE. Glyphosate formulations induce apoptosis and necrosis in human umbilical, embryonic, ��and placental cells. Chem Res Toxicol. 2009;22:97–105. doi:10.1021/tx800218n. �� 98 Haefs R, Schmitz-Eiberger M, Mainx HG, Mittelstaedt W, Noga G. Studies on a new group of biodegradable ��surfactants for glyphosate. Pest Manag Sci. 2002;58:825-33. doi:10.1002/ps.539. �� 99 Richard S, Moslemi S, Sipahutar H, Benachour N, Seralini GE. Differential effects of glyphosate and Roundup on ��human placental cells and aromatase. Env Health Perspect. 2005;113:716-20. �� 100 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:206. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/ 101 Mesnage R, Defarge N, de Vendomois JS, Séralini GE. Major pesticides are more toxic to human cells than their ��declared active principles. BioMed Res Int. 2014;2014. doi:10.1155/2014/179691. �� 102 Fagan J PhD, Antoniou M PhD, Robinson C MPhil. GMO Myths and Truths 2nd Edition. Earth Open Source. 2014:4.1:206-207. Available at: http://earthopensource.org/earth-open-source-reports/gmo-myths-and-truths-2nd-edition/

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Human Cells”. The article is about a 2008 research study by Nora Benachour and Gilles-Eric Seralini, molecular biologists at University of Caen, France, entitled; “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells”103. Benachour and Seralini “found that Roundup’s inert ingredients amplified the toxic effect on human cells—even at concentrations much more diluted than those used on farms and lawns.”104 POEA (polyethoxylated tallowamine) is a surfactant, or detergent, derived from animal fat. It is added to Roundup and other herbicides to help them penetrate plants’ surfaces, making the weed killers more effective. According to Crystal Gammon, “Researchers Benachour and Seralini tested four different Roundup formulations, all containing POEA and glyphosate at concentrations below the recommended lawn and agricultural dose. They also tested POEA and glyphosate separately to determine which caused more damage to embryonic, placental and umbilical cord cells.”105 Seralini’s team studied multiple concentrations of Roundup, which “ranged from the typical agricultural or lawn dose down to concentrations 100,000 times more dilute than the products sold on shelves. The researchers saw cell damage at all concentrations.”106 Benachour and Seralini demonstrated that “Glyphosate, POEA and all four Roundup formulations damaged all three cell types (embryonic, placental and umbilical cord cells). Umbilical cord cells were especially sensitive to POEA. Glyphosate became more harmful when combined with POEA, and POEA alone was more deadly to cells than glyphosate.” – a finding the researchers call “astonishing.”107

“This clearly confirms that the inert ingredients in Roundup formulations are not inert,” wrote Benachour and Seralini, “Moreover, the proprietary mixtures available on the

103 Benachour, N. Seralini, G. Glyphosate Formulations Induce Apoptosis and Necrosis in Human Ubilical, Embryonic, and Placental Cells. 2008. American Chemical Society. Journal Chemical Research in Toxicology (Jan. 2009). Available at: http://pubs.acs.org/doi/abs/10.1021/tx800218n 104 Gammon, C. Environmental Health News. 2009. Weed-Whacking Herbicide Proves Deadly to Human Cells. Scientific American. Available at: http://www.scientificamerican.com/article/weed-whacking-herbicide-p/ 105 Gammon, C. Environmental Health News. 2009. Weed-Whacking Herbicide Proves Deadly to Human Cells. Scientific American. Available at: http://www.scientificamerican.com/article/weed-whacking-herbicide-p/ 106 Gammon, C. 2009. Weed killer kills human cells. Study intensifies debate over ‘inert’ ingredients. Environmental Health News. Available at: http://www.environmentalhealthnews.org/ehs/news/roundup-weed-killer-is-toxic-to-human-cells.-study-intensifies-debate-over-inert-ingredients 107 Gammon, C. Environmental Health News. 2009. Weed-Whacking Herbicide Proves Deadly to Human Cells. Scientific American. Available at: http://www.scientificamerican.com/article/weed-whacking-herbicide-p/

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market could cause cell damage and even death at the residual levels found on Roundup-treated crops, such as soybeans, alfalfa and corn, or lawns and gardens.”108

Similarly, the study entitled; “Differential Effects of Glyphosate and Roundup on Human Placental Cells and Aromatase” by Sophie Richard, Safa Moslemi, and Gilles-Eric Seralini (June 2005) noted that: “Surprisingly, Roundup is always more toxic than its active ingredient (glyphosate)”… and that “…the presence of Roundup adjuvants enhances glyphosate bioavailability and/or bioaccumulation.”109

In conclusion, adjuvants have been proven to be extremely toxic by themselves and to dramatically amplify the toxicity of the main active ingredient of an herbicide. Complete herbicide formulations are up to 1000 times the toxicity of their isolated active ingredients. H. Children Are Particularly Vulnerable to Pesticides, including Glyphosate According to the article by Pesticide Action Network North America entitled; “A Generation In Jeopardy”110, pesticides are undermining our children's health and intelligence. Children are particularly vulnerable because of the following well-documented pesticide exposure pathways: 1. "In their first six months of life, children take in roughly 15 times more water than the average adult per pound of body weight.111 Children also inhale more air. Up to around age 12, a child’s breathing rate is roughly twice that of an adult, which means a child will inhale roughly double the dose of a pesticide in the air from spray drift or household use."112 113 2. "Exposure to pesticides occurs largely through touching, inhaling or ingesting. For each of these routes, children are much more likely to absorb what they come into contact with than adults. The skin of infants and young children, for example, is particularly permeable, and the skin surface area relative to body weight is much greater

108 Gammon, C. Environmental Health News. 2009. Weed-Whacking Herbicide Proves Deadly to Human Cells. Scientific American. Available at: http://www.scientificamerican.com/article/weed-whacking-herbicide-p/ 109 Richard S, Moslemi S, Sipahutar H, Benachour N, Seralini GE. Differential effects of glyphosate and Roundup on human placental cells and aromatase. Env Health Perspect. 2005;113:716-20. Available at: http://www.ncbi.nlm.nih.gov/pubmed/15929894 110 Schafer, K. Marquez, E. 2012. A Generation in Jeopardy – How pesticides are undermining our children’s health & intelligence. Pesticide Action Network North America 111 Landrigan, P.J., L. Claudio, S.B. Markowitz, G.S. Berkowitz, B.L. Brenner, H. Romero, et al. “Pesticides and Inner-City Children: Exposures, Risks, and Prevention.” Environ Health Persp. June 1999. 107 Suppl 3.: 431-437. 112 Miller, M.D., M.A. Marty, A. Arcus, J. Brown, D. Morry and M. Sandy. “Differences Between Children and Adults: Implications for Risk Assessment at California EPA.” International Journal of Toxicology. October 2002 21(5): 403-418. 113 Schafer, K. Marquez, E. 2012. A Generation in Jeopardy – How pesticides are undermining our children’s health & intelligence. Pesticide Action Network North America

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in children than adults.114 The lung surface area relative to rate of breathing is also higher among children,115 and absorption levels in the gastrointestinal tract are also greater (especially for alkaline pesticides), as adult levels of gastric acid are not reached until a child is about two years old."116 117 3. "As noted above, the brain and nervous system are especially vulnerable during fetal development and for the first six months of life. During this period the blood-brain barrier, which provides the adult nervous system some protection from toxic substances, is not yet fully developed."118 119 4. "Finally, young bodies are less equipped to process and excrete harmful chemicals as the liver and kidneys—the body’s primary detoxifying organs—are not yet fully developed. Levels of enzymes that help the body process chemicals are also not yet at full strength."120 121 These findings mean that children, as well as a subpopulation of adults, are much more likely to have adverse health effects from pesticide exposure. Policies should account for this variability and should protect all, including the most vulnerable. I. The Amount Of Glyphosate Used When Sponge Dabbing The Herbicide Is Equal To Or Greater Than The Amount Used When Spraying The Substance A number of vegetation managers assume that sponge dabbing Glyphosate on a weed is less toxic than spraying the substance. However, this supposition is incorrect. According to Dr. Don Huber (Emeritus Professor of Plant Pathology at Purdue University) and Bob Streit (Crop, Seed, Technology and Soil remediation Consultant), sponge dabbing typically uses a much higher concentration of Glyphosate than spraying. 114 Miller, M.D., M.A. Marty, A. Arcus, J. Brown, D. Morry and M. Sandy. “Differences Between Children and Adults: Implications for Risk Assessment at California EPA.” International Journal of Toxicology. October 2002 21(5): 403-418. 115 Bennet, W.D. and K.L. Zeman. “Effect of Body Size on Breathing Pattern and Fine-particle Deposition in Children.” Journal of Applied Physiology. Sept 2004 97(3): 821-826. 116 Louis, G.B., United Nations Environment Programme, International Laour Organisation, World Health Organization, Inter-Organization Programme for the Sound Management of Chemicals, and International Program on Chemical Safety. “Principles for evaluating health risks in children associated with exposure to chemicals.” 2006. Available at: http://site.ebrary.com/id/10214527. 117 Schafer, K. Marquez, E. 2012. A Generation in Jeopardy – How pesticides are undermining our children’s health & intelligence. Pesticide Action Network North America 118 Schwenk, M., U. Gundert-Remy, G. Heinemeyer, K. Olejniczak, R. Stahlmann, W. Kaufmann, et al. “Children as a Sensitive Subgroup and Their Role in Regulatory Toxicology: DGPT Workshop Report.” Archives of Toxicology. Jan 2003 77(1): 2-6. Louis et al. 2006, op. cit. 119 Schafer, K. Marquez, E. 2012. A Generation in Jeopardy – How pesticides are undermining our children’s health & intelligence. Pesticide Action Network North America 120 Furlong, C.E., N. Holland, R. Richter, A. Bradman, A. Ho and B. Eskenazi. “PON! Status of Farmworker Mothers and Children as a Predictor of Organophosphate Sensitivity.” Pharmacogenetics and Genomics. March 2006 16(3): 183–190. 121 Schafer, K. Marquez, E. 2012. A Generation in Jeopardy – How pesticides are undermining our children’s health & intelligence. Pesticide Action Network North America

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Therefore, when sponge dabbing weeds, the total amount of Glyphosate used would be about the same as spraying BUT the amount entering the soil at a particular site would be much greater! IV. GLYPHOSATE INCREASES THE RISK OF FIRE, RUNOFF & EROSION, AND HERBICIDE-RESISTANT SUPER WEEDS A. Glyphosate Is A Patented Desiccant And Could Greatly Increase The Risk Of Fire Glyphosate is a patented desiccant. Its desiccating effects reduce a plant’s ability to uptake water. As already mentioned, glyphosate has non-target impacts. Glyphosate use could lead to Sudden Oak Death (see below), Oak Wilt, and a host of Scorch Diseases in which plants can no longer absorb sufficient water and thereby become very flammable. More dry and dead non-target vegetation increases the risk of fire. Don Huber PhD and Joe Holland authored an article on glyphosate and plant diseases in the European Journal of Agronomy (2009). The article demonstrates that Glyphosate predisposes plants and trees to disease and toxins. In Maryland parks, glyphosate was found to have a very deleterious effect on Red Oaks. The article shows that glyphosate can increase the spread of Phytophthora (Sudden Oak Death) in oak trees among other plants. B. Glyphosate Changes The Soil Composition And Could Increase Runoff & Erosion The New York Times article by Stephanie Strom entitled; “Misgivings About How A Weed Killer Affects The Soil”122 explains the negative effects glyphosate has on soil, effects that include compaction and resultant increased run-off. Biotech crops, such as Roundup Ready crops, are genetically engineered to withstand Glyphosate-based herbicides. The use of Glyphosate has grown exponentially, along with biotech crops. Pervasive use of Glyphosate has caused the rise of superweeds, which are more resistant to the herbicide. To fight them, farmers sometimes have to spray the toxic herbicide two to three times during the growing season. Strom interviewed a number of farmers who are rethinking their methods. Dennis Von Arb, a farmer in Iowa, stated; “Anything you put on the land affects the chemistry and biology of the land, and that’s a powerful pesticide (Glyphosate).” Mike Verhoef, another farmer in Iowa, said he switched to biotech corn and soybeans on his 330 acres and almost immediately problems occurred. He noticed that his soil was becoming harder and more compact, requiring a bigger tractor and more gas to pull the same equipment across it. As a result, Verhoef switched back to growing conventional crops again. Strom also noted; “Dirt in two fields around Alton where biotech corn was being grown was hard and compact. Prying corn stalks from the soil with a shovel was difficult, and when the plants finally came up, the roots were trapped in a chunk of dirt. In comparison, 122 Strom S. 2013. Misgivings About How Weed Killer Affects The Soil. New York Times. Available at: http://www.nytimes.com/2013/09/20/business/misgivings-about-how-a-weed-killer-affects-the-soil.html

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conventional corn in adjacent fields could be tugged from the ground by hand, and dirt with the consistency of coffee grounds fell off the corn plants’ knobby roots.” “Because glyphosate moves into the soil from the plant, it seems to affect the rhizosphere, the ecology around the root zone, which in turn can affect plant health”, said Robert Kremer Ph. D., Professor of Soil Microbiology at University of Missouri and recently retired USDA scientist, who has studied the impact of Glyphosate on soybeans for more than a decade and has warned of the herbicide’s negative impact on soil health.123 Compaction of soil affects the water-holding capacity of the soil and reduces the infiltration rate, which further accelerates erosion by increasing the risk of water run-off.124 125 C. Glyphosate-Resistant Super Weeds Consistent with herbicides used in the past, weeds resistant to glyphosate are causing huge agronomic and ecological concerns as farmers are forced to abandon whole fields of crops.126 The spread of glyphosate-resistant weeds is increasing dramatically. Since the commercialism of Roundup Ready Crops in 1996, resistant weed species have been emerging at a rate of 1 per year. Glyphosate-resistance was first documented in ryegrass in 1996 in Australia. Up until 2003, 5 resistant populations had been documented worldwide. Since 2007, there has been a 5-fold increase in the spread of resistant weeds. In 2010, world-wide coverage was estimated to have reached 120 million hectares and US coverage was estimated at 4.5 million hectares, with 13 different species in 73 different locations.127 The super weeds’ mechanisms for resistance include reduced glyphosate uptake, and/or mutations in the EPSPS gene that make it less susceptible to inhibition by the herbicide. Resistant weed species listed by the WeedScience database include: Palmer Amaranth, Common Waterhemp, Common Ragweed, Giant Ragweed, Ripgut Brome, Australian Fingergrass, Hairy Fleaben, Horseweed, Sumatran Fleabane, Sourgrass, Julnglerice, Goosegrass, Kochia, Tropical Sprangletop, Italian Ryegrass, Perennial Ryegrass, Rigid Ryegrass, Ragweed Parthenium, Buckhorn Plantain, Annual Bluegrass, Johnsongrass, 123 Strom S. 2013. Misgivings About How Weed Killer Affects The Soil. New York Times. Available at: http://www.nytimes.com/2013/09/20/business/misgivings-about-how-a-weed-killer-affects-the-soil.html 124 Glyphosate.eu. 2013 The problem of soil erosion in Europe. Available at: http://www.glyphosate.eu/problem-soil-erosion-europe 125 European Soil Data Centre. 2009. Water erosion and compaction. European Soil Data Centre. Available at: http://esdac.jrc.ec.europa.eu/projects/SOCO/FactSheets/ENFactSheet-02.pdf 126 Ho, M. ISIS Report 01/02/10: GM Crops Facing Meltdown in the USA. Institute of Science in Society. 2010. Available at: http://www.i-sis.org.uk/GMCropsFacingMeltdown.php 127 Sirinathsinghji, E. ISIS Report 28/11/11: Monsanto Defeated by Roundup Resistant Weeds. Institute of Science in Society. 2011. Available at: http://www.i-sis.org.uk/Monsanto_defeated_by_herbicide_resistant_superweeds.php

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Gramilla mansa and Liverseedgrass.128 Glyphosate-resistant weeds are not restricted to areas near fields of crops. Resistance can occur in any location where multiple rounds of herbicide treatments are applied, including forests, open spaces, and parks. Resistant common Waterhemp was first documented in fields in Missouri, US, in 2004, after 6 consecutive years of growing Roundup Ready soybeans.129 Similarly, during a 2014 lecture in Marin County, Bob Streit (Crop, Seed, Technology and Soil remediation Consultant) stated that herbicide-resistant super weeds could develop after multiple consecutive years of using glyphosate-based herbicides on weeds in the Marin Municipal Water District Watershed. V. COUNTRIES AND LOCAL JURISDICTIONS THAT HAVE BANNED GLYPHOSATE The following Countries and local jurisdictions have banned glyphosate: A. Netherlands In 2014, the Dutch Parliament voted to ban glyphosate herbicides for non-commercial use in the Netherlands, starting the end of 2015.130 B. Sri Lanka In May 2015, Sri Lanka’s president, Maithripala Sirisena, announced that the import of glyphosate would no longer be allowed in the country. Sri Lanka had already banned the sale of glyphosate herbicides in March of 2014, but the decision was overturned in May 2014 after a review. The new ban by President Sirisena (elected in January 2015 after the overturn of the previous ban) is expected to stand. The ban is largely due to the association of Glyphosate use with rising rates of chronic kidney disease (CKD) throughout the Sri Lankan Farming community. CKD has affected 15% of people working in the northern part of Sri lanka, of which 400,000 patients, and 20,000 deaths are related to Monsanto’s chemicals.131 128 Ho M., Sirinathsinghji E. Why Glyphosate Should be Banned – A Review of Its Hazards to Health and the Environment. Institute of Science in Society. 2012; 5.1 Available at: http://permaculturenews.org/2012/11/01/why-glyphosate-should-be-banned-a-review-of-its-hazards-to-health-and-the-environment/ 129 Ho M., Sirinathsinghji E. Why Glyphosate Should be Banned – A Review of Its Hazards to Health and the Environment. Institute of Science in Society. 2012: 5.1 Available at: http://permaculturenews.org/2012/11/01/why-glyphosate-should-be-banned-a-review-of-its-hazards-to-health-and-the-environment/ 130 Lilley, J. “Netherlands Bans Monsanto’s Roundup to Protect Citizens from Carcinogenic Glyphosate”. Global Research. May 2015. Available at: http://www.globalresearch.ca/netherlands-bans-monsantos-roundup-to-protect-citizens-from-carcinogenic-glyphosate/5451552 131 Sarich, C. “Sri Lanka’s Newly Elected President Bans Glyphosate (Monsanto Roundup) – Deadly Chronic Kidney Disease Increased 5-Fold”. Global Research. May 2015. Available at: http://www.globalresearch.ca/sri-lankas-newly-elected-president-bans-glyphosate-monsanto-roundup-deadly-chronic-kidney-disease-increased-5-fold/5451936

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C. Bermuda In May 2015, Bermuda Minister of Health, Jeanne Atherden, announced that, effective immediately, any importation of Glyphosate/Roundup has been suspended, pending the continuing assessment of the emerging research.132 The suspension was made shortly after the International Agency for Research on Cancer (IARC), the cancer agency of the World Health Organization (WHO), identified Glyphosate to probably be carcinogenic to humans and classified the herbicide as a Group 2A carcinogen. D. France In June 2015, French Ecology Minister Segolene Royal announced a ban on the sale of Glyphosate in garden centers throughout France.133 The ban was enacted three months after the World Health Organization’s classification of Glyphosate as being probably carcinogenic to humans. E. Town of Fairfax, California In April 2001, the Town of Fairfax banned the use of pesticides, including Glyphosate, on town property. F. City of Belvedere, California In August 2005, the City Government of Belvedere resolved that the City shall only permit the application of pesticides to City-owned sites, which, if used on or around food crops, would allow such crops to carry the label “organic”, pursuant to the U.S. Government National Organic Program for food production. The resolution was established in order to protect people and pets who use the recreation areas from the dangers of certain pesticides and certain fertilizing chemicals. G. City of Sausalito, California In 2014, the City of Sausalito City Council voted for a moratorium on the use of Roundup and Surflan, pending a review of need and alternatives, on city parks, playgrounds, and open space. H. City of Richmond, California In February 2015, the City Council of Richmond California unanimously voted to enact a 12-month ban on all toxic pesticides, including Glyphosate. I. Marin Municipal Water District In July 2015, the Marin Municipal Water District (MMWD) Board of Directors voted to continue a ban on the use of pesticides, including Glyphosate, in the MMWD watershed. 132 Sarich, C. “Bermuda Suspends Glyphosate-Ridden Monsanto Roundup Indefinitely”. Natural Society. May 2015. Available at: http://www.globalresearch.ca/bermuda-suspends-glyphosate-ridden-monsanto-roundup-indefinitely/5449207 133 Schlanger, Z. “France Bans Sales of Monsanto’s Roundup in Garden Centers, 3 Months After U.N. Calls It ‘Probable Carcinogen’ ”. Newsweek. June 2015. Available at: http://www.newsweek.com/france-bans-sale-monsantos-roundup-garden-centers-after-un-names-it-probable-343311

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J. School Districts in Marin County The Reed School District in Tiburon, California, the Larkspur-Corte Madera School District in Corte Madera, California, and the Mill Valley School District in Mill Valley, California have banned the use of pesticides, including Glyphosate, on school grounds. The above list of bans on Glyphosate and other pesticides not only reveals governments’ concerns about the potential harm that the toxic herbicide(s) can cause, but also demonstrates their ability to manage vegetation without the use of Glyphosate and other pesticides. VI. CONCLUSION Using Glyphosate herbicides could not only harm beneficial vegetation and wildlife but could also jeopardize public health and safety. This risk is unnecessary and unacceptable. In accordance with the Marin County Precautionary Principle, which requires “the selection of the alternative that presents the least potential threat to human health and the natural systems”, we recommend a Glyphosate-free approach to vegetation management.

CChhaapptteerr 1100 —— PPeessttiicciiddee HHeeaalltthh EEffffeeccttss aanndd CChhiillddrreenn Children are ubiquitously exposed to low levels of pesticides in their food and environment, yet there has been a paucity of studies on the long-term health effects of these exposures (10, 26, 32). Many pesticides persist in the environment, are often transferred long distances from their original area of application, are routinely detected in human tissue, and are transferred across the placenta and via breast milk (1, 19). Relative to adults, children eat more in proportion to their body weight, resulting in more concentrated exposures. Intakes by children of the four primary pesticides (chlorpyrifos, malathion, diazinon, and atrazine) appear to come primarily from the ingestion of solid food (2). Another common exposure source is indoor and outdoor home pesticide applications, where children may be exposed by playing on floors, treated lawns and play areas, or by handling treated pets (8). Agricultural uses of pesticides may expose children inadvertently from spray drift or farm work (31). Children present a number of unique characteristics with regard to risks from exposure to pesticides and other environmental pollutants. The most vulnerable time is during fetal development when the brain is known to be subject to environmental influences at all phases of development, with critical windows at different points (6). Since in the female, ova are formed in the fetal stage, and environmental contaminants have been found in follicular fluid, the next generation of children born may be affected by their grandmother’s exposures (6). The newborn child has low levels of the enzyme paraoxanase-1, which detoxifies organophosphate pesticides (7). Environmental contaminants may pose a greater risk to children than adults for another reason: children have a longer life expectancy in which to develop diseases with long latency periods. For example, if a 70-year-old adult and a 5-year-old child are exposed to a carcinogen with a 40-year latency period, the child has a much higher lifetime risk of developing adverse health consequences (20). Studies in children have so far demonstrated subtle neurotoxic effects of low level, intrauterine, or early childhood exposures to a variety of environmental agents including lead, methyl mercury, and PCBs. While studies of pesticide health effects in children are still lacking, it is possible that a parallel model may emerge for low-level exposures to pesticides, some of which are by design neurotoxic (28, 32, 33). A range of developmental disabilities including learning disabilities, attention deficit hyperactivity disorder, developmental delays, autism, and behavioural disorders are of great importance due to possibly increasing incidence, and personal and public health costs. (12, 17, 18, 33). These are disorders of unknown etiology with a link between genetic susceptibility and environmental factors, perhaps including pesticides in some small proportion of cases (18, 27). Research is urgently needed to fill in the many gaps in this area. Summary of Findings Concerning Children The few studies we found which addressed children’s health effects from exposures to pesticides have been discussed in detail in each relevant chapter and will be summarized here. Several studies found associations between pesticide exposures and solid tumours in children. An elevated rate of kidney cancer was associated with paternal pesticide exposure through

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agriculture (11). Four studies found associations with brain cancer: two found associations with indoor household use of pesticides (9, 30), one with parental farming occupation (16), and one with parental occupational exposure to pesticides (34). Several studies in this review implicate pesticides as a cause of hematologic tumours in children. One study found an association with childhood non-Hodgkin’s lymphoma (5), and several studies found elevated childhood leukemia rates with pesticide exposure (16, 21, 23, 24). An excellent study by Ma (23) showed an association between maternal pesticide exposure and childhood leukemia. More detailed information on these studies is in Chapters 3–5. In the genotoxicity or immunotoxicity area (Chapter 6) there were two studies relevant to children. In the first, children with poor metabolizer polypmorphisms, genotyped at birth and representing just over 40% of the Montreal study group, had overall increased risk of acute lymphocytic leukemia if exposed to pesticides in utero or during childhood, especially for exposure to repellents and sprays for outdoor insects during pregnancy, and exposure to mite and spider killers during pregnancy or between birth and leukemia diagnosis. Herbicide use (mainly 2,4-D), both during pregnancy and in childhood, showed a consistent interaction with poor metabolizer genes and was associated with a 2-fold increase in leukemia incidence (14). Phillips (29) found that children exposed to chlordane and/or heptachlor had more cytokine panel abnormalities than matched controls. Neurodevelopmental effects (Chapter 8) were found in pre-school children in pervasive pesticide exposure situations in Mexican valley agriculture, and likely resulted from maternal, in-utero, and early childhood exposures (13). The only other study of effects on children (15) found substantially higher proportions of residents — including adolescents — exposed to pesticides from aerial spraying drift to have mental and emotional symptoms compared to those not exposed by aerial spraying, consistent with other studies of broader nervous system function. In the reproductive review (Chapter 9), findings suggested that occupational exposure to agricultural chemicals including pesticides may cause intrauterine growth retardation, and may increase a woman’s risk of giving birth to children with congenital anomalies, such as limb defects, nervous system and musculoskeletal defects, cryptorchidism and hypospadias, cardiovascular defects, oral clefts, and other multiple and specific defects. The adverse reproductive effects that are non-fatal produce future risks for the individual and for the next generation. Intrauterine growth retardation has been shown to increase susceptibility in later life to hypertension, type 2 diabetes, heart disease, and breast and prostate cancer (3, 4). Men with birth defects are twice as likely to produce children with birth defects (22). Future Studies There have been some plans to develop a parallel Canadian cohort study that would be complementary to the US National Children’s Study, a study that will follow a cohort of 100,000 children from the prenatal period to adulthood to study environmental influences on health and development. Scientists from Health Canada were involved in the planning along with the US National Institute of Child Health and Human Development, the US Environmental Protection Agency, the Centers for Disease Control and Prevention, and the National Institute of Environmental Health Sciences. The Canadian involvement is dependent on federal funding which as of February 2004 is still uncommitted. Such a large and comprehensive prospective study is vital and would finally provide sufficient data to inform whatever policy decisions are necessary to protect our children and their futures.

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Chapter 10 — Children

RReeffeerreenncceess 1. Anderson HA, Wolff MS. Environmental contaminants in human milk. J Expo Anal

Environ Epidemiol 2000;10 Suppl 6:755–760.

2. Andrew Clayton C, Pellizzari ED, Whitmore RW, Quackenboss JJ, Adgate J, Sefton K. Distributions, associations, and partial aggregate exposure to pesticides and polynuclear hydrocarbons in the Minnesota Children’s Pesticide Exposure Study (MNCPES). J Expo Anal Environ Epidemiol 2003;13(2):100–111.

3. Barker DJP, Eriksson JF, Forsen T, Osmond C. Fetal origins of adult diseases. Int J Epidemiol 2002;31:235–239.

4. Barker DJP. The developmental origins of adult disease. Eur J Epidemiol 2003;18(8):733–736.

5. Buckley JD, Meadows AT, Kadin ME, Le Beau MM, Siegel S, Robison LL. Pesticide exposures in children with non-Hodgkin lymphoma. Cancer 2000;89:2315–2321.

6. Chance GW, Harmsen E. Children are Different: Environmental Contaminants and Children’s Health. Can J Public Health 1998;89 Suppl 1:S9–S19.

7. Chen J, Kumar M, Chan W, Berkowitz G, Wetmur JG. Increased Influence of Genetic Variation on PON1 Activity in Neonates. Environ Health Perspect 2003 Aug;111(11):1403–1410.

8. Cooper K, Vanderlinden L, McClenaghan T, Keenan K, Khatter K, Muldoon P, Abelsohn A. Children’s Health Project: Environmental Standard Setting and Children’s Health [report on the Internet]. Toronto: Canadian Environmental Law Association, Ontario College of Family Physicians Environmental Health Committee; 2000 [cited 30 March 2004]. Available from http://www.cela.ca/ch_health/titlepg.htm

9. Davis JR, Brownson RC, Garcia R, Bentz BJ, Turner A. Family pesticide use and childhood brain cancer [comment]. Arch Environ Contam Toxicol 1993;24:87–92.

10. Eskenazi B, Bradman A, Castorina R. Exposures of children to organophosphate pesticides and their potential adverse health effects. Environ Health Perspect 1999;107 Suppl 3:409–419.

11. Fear NT, Roman E, Reeves G, Pannett B. Childhood cancer and paternal employment in agriculture: the role of pesticides. Br J Cancer 1998;77:825–829.

12. Goldman LR, Koduru S. Chemicals in the environment and developmental toxicity to children: a public health and policy perspective. Environ Health Perspect 2000;108 Suppl 3:443–448.

13. Guillette EA. An anthropological approach to the evaluation of preschool children exposed to pesticides in Mexico. Environ Health Perspect 1998;106(6):347–353.

14. Infante-Rivard C, Labuda D, Krajinovic M, Sinnett D. Risk of childhood leukemia associated with exposure to pesticides and with gene polymorphisms. Epidemiology 1999;10(5):481–487.

15. Keifer M, Rivas F, Moon JD, Checkoway H. Symptoms and cholinesterase activity among rural residents living near cotton fields in Nicaragua. Occup Environ Med 1996;53:726–729.

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16. Kristensen P, Andersen A, Irgens LM, Bye AS, Sundheim L. Cancer in offspring of parents engaged in agricultural activities in Norway: incidence and risk factors in the farm environment. Int J Cancer 1996;65:39–50.

17. Landrigan P, Kimmel C, Correa A, Eskenazi B. Children’s health and the environment: Public health issues and challenges to risk assessment. Environ Health Perspect 2004;112(2):257–265.

18. Landrigan PJ, Schechter CB, Lipton JM, Fahs MC, Schwartz J. Environmental Pollutants and Disease in American Children: Estimates of Morbidity, Mortality, and Costs for Lead Poisoning, Asthma, Cancer and Developmental Disabilities. Environ Health Perspect 2002;110(7):721–728.

19. Landrigan PJ, Sonawane B, Mattison D, McCally M, Garg A. Chemical Contaminants in Breast Milk and Their Impacts on Children’s Health: An Overview. Environ Health Perspect 2002;110(6):A313–A315.

20. Landrigan, PJ, JE Carlson, CF Bearer, JS Cranmer, RD Bullard, RA Etzel, J Groopman, JA McLachlan, FP Perera, JR Reigard, L Robison, L Schell, WA Suk. Children’s health and the environment: A new agenda for prevention research. Environ Health Perspec 1998;106 Suppl 3:787–794.

21. Leiss JK, Savitz DA. Home pesticide use and childhood cancer: a case-control study [comment]. Am J Public Health 1995;85(2):249–252.

22. Lie RT, Wilcox AJ and Skjærven R. Survival and reproduction among males with birth defects and risk of recurrence in their children. JAMA 2001;285:755–760.

23. Ma X, Buffler PA, Gunier RB, Dahl G, Smith MT, Reinier K, Reynolds P. Critical windows of exposure to household pesticides and risk of childhood leukemia. Environ Health Perspec 2002;110(9):955–960.

24. Meinert R, Kaatsch P, Kaletsch U, Krummenauer F, Miesner A, Michaelis J. Childhood leukaemia and exposure to pesticides: results of a case-control study in northern Germany. Eur J Cancer 1996;32A:1943–1948.

25. Meinert R, Schuz J, Kaletsch U, Kaatsch P, Michaelis J. Leukemia and non-Hodgkin’s lymphoma in childhood and exposure to pesticides: results of a register-based case-control study in Germany. Am J Epidemiol 2000;151(7):639–646.

26. National Research Council. Pesticides in the Diets of Infants and Children. Washington DC: National Academy Press; 1993.

27. National Research Council. Scientific Frontiers in Developmental Toxicology and Risk Assessment. Washington DC: National Academy Press; 2000.

28. Needleman HL. Childhood lead poisoning: the promise and abandonment of primary prevention. Am J Public Health 1998;88(12):1871–1877.

29. Phillips TM. Assessing environmental exposure in children: immunotoxicology screening. J Expo Anal Environ Epidemiol 2000;10 Suppl 6:769–775.

30. Pogoda JM, Preston-Martin S. Household pesticides and risk of pediatric brain tumors. Environ Health Perspec 1997;105(11):1214–1220.

31. Pollack SH. Adolescent occupational esposures and pediatric-adolescent take-home exposures. Pediatr Clin North Am 2001;48(5):1267–1289.

32. Rice DC. Issues in Developmental Neurotoxiclogy: Interpretations and Implications of the Data. Can J Public Health 1998;89 Suppl 1:S31–S39.

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33. Schettler T. Toxic Threats to Neurological Development. Can J Public Health 2001;109 Suppl 6:813–816.

34. Van Wijngaarden E, Stewart PA, Olshan AF, Savitz DA, Bunin GR. Parental occupational exposure to pesticides and childhood brain cancer. Am J Epidemiol 2003;157(11):989–997.

Kids need Protection

Children are at a greater risk for some pesticides for a number of reasons. Children's internal organs are still

developing and maturing and their enzymatic, metabolic, and immune systems may provide less natural protection

than those of an adult. There are "critical periods" in human development when exposure to a toxin can

permanently alter the way an individual's biological system operates.

Adverse effects of pesticide exposure range from mild symptoms of dizziness and nausea to serious, long-term

neurological, developmental and reproductive disorders. Americans use more than a billion pounds of pesticides

each year to combat pests on farm crops, in homes, places of business, schools, parks, hospitals, and other public

places.

From EPA website

Kid’s Health- from “A Generation in

Jeopardy”- by Pesticide Action

Network

Executive Summary Children today are sicker than they were a generation

ago. From childhood cancers to autism, birth defects

and asthma, a wide range of childhood diseases and

disorders are on the rise. Our assessment of the latest

science leaves little room for doubt: pesticides are one

key driver of this sobering trend.

As the recent President’s Cancer Panel reports, we have

been “grossly underestimating” the contribution of environmental

contamination to disease, and the policies

meant to protect us have fallen far short. Nearly 20 years

ago, scientists at the National Research Council called

for swift action to protect young and growing bodies

from pesticides.1 Yet today, U.S. children continue to be

exposed to pesticides that are known to be harmful in

places they live, learn and play.

This report reviews dozens of recent studies that examine

the impact of pesticides on children’s health. Our

analysis reveals the following:

• Compelling evidence now links pesticide exposures with harms to the structure and functioning of the brain and nervous system. Neurotoxic pesticides are clearly implicated as

contributors to the rising rates of attention deficit/

hyperactivity disorder, autism, widespread declines in

IQ and other measures of cognitive function.

• Pesticide exposure contributes to a number of increasingly common health outcomes for children, including cancer, birth defects and early puberty. Evidence of links to certain

childhood cancers is particularly strong.

• Emerging science suggests that pesticides may be important contributors to the current epidemic of childhood asthma, obesity and diabetes. • Extremely low levels of pesticide exposure can cause significant health harms, particularly during pregnancy and early

childhood.

Prioritizing children’s health requires real change As a nation, we value the wellbeing of our children. In

addition to our natural urge to protect what we love, we

know that at a societal level their successful development

is key to a vibrant, secure future. Poll after poll shows

more than 80 percent of Americans consider healthy

children a top priority. We must line up our practice and

policies with these values.

By Nathan Donley, Ph. D.Center for Biological Diversity

July 2016

HOW THE EPA IGNORES THE DANGERS OF PESTICIDE COCKTAILS.

Toxic Concoctions

1

Executive Summary

ore than 1 billion pounds of pesticides are used in the United States each year, applied to agricultural fields and orchards, residential lawns, playgrounds and parks. Pesticides are often mixed with other pesticides and chemicals before

application or after, and the individual ingredients in these mixtures can interact in such a way as to enhance their toxic effects. This is referred to as “synergy,” and it can turn what would normally be considered a safe level of exposure to people, wildlife and the environment into one that causes considerable harm. Although pesticide mixtures in the environment have been extensively documented, the Environmental Protection Agency generally only assesses the toxicity of pesticides individually, in isolation from potential real-life scenarios where these pesticides may interact with other chemicals. The EPA, which is tasked with ensuring that pesticides do not result in unreasonable harm to human health and the environment, often rationalizes this approach by stating that studies measuring mixture toxicity are often not available for analysis. Our analysis, however, contradicts that claim by utilizing a publicly available information source (data from the U.S. Patent and Trademark Office) that provides a disturbing snapshot of pesticide synergy and the potential for widespread danger to people, waterways and wildlife — risks the EPA has repeatedly failed to identify and consider during its approval process. For this report we conducted an intensive search of patent applications that were germane to all pesticide products containing two or more active ingredients approved by the EPA in the past six years from four major agrochemical companies (Bayer, Dow, Monsanto and Syngenta). Among our key findings:

• 69 percent of these products (96 out of 140) had at least one patent application that claimed or demonstrated synergy between the active ingredients in the product;

• 72 percent of the patent applications that claimed or demonstrated synergy involved some of the most highly used pesticides in the United States, including glyphosate, atrazine, 2,4-D, dicamba and the controversial neonicotinoids thiamethoxam, imidacloprid and clothianidin, among others, indicating that potential impacts could be widespread.

This suggests that synergistic action between pesticide active ingredients is much better documented and more common than current EPA pesticide assessments would indicate. Further, it appears that pesticide companies are in fact collecting information about the synergistic effects of their products that they are not sharing with the EPA. Recognizing that pesticide synergy data are widely available and that the synergistic relationships between pesticides can have serious implications for human and environmental health, the EPA must now take action to properly consider the potential consequences of pesticide synergy.

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Introduction Pesticide Registration Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), before a pesticide can be sold or distributed in the United States it must be registered — that is, approved — by the EPA. By law the EPA can only register a pesticide if its use will not cause unreasonable adverse effects on the environment.1 To analyze whether any possible adverse effects may occur, the agency requires that toxicity studies be submitted to it by the chemical companies that plan to sell the pesticide (subsequently referred to as “pesticide registrants”). These studies typically analyze the relative toxicities of the pesticide to different taxa of plants and animals.2

Once these data are analyzed, the EPA conducts a cost-benefit analysis that weighs the environmental costs with the purported economic benefits of pesticide use and decides whether or not to register a given pesticide.

The data that are required to be submitted by pesticide registrants almost always involve the use of a single pesticide in the absence of any other added chemicals. In reality pesticide exposures never occur in isolation. Pesticides are typically sold as formulations, meaning the pesticide is mixed with other chemicals in the bottle. These other chemicals can be other pesticides or “inert” ingredients, which are chemical additives that can affect the toxicity or absorption of the pesticide.3 In addition, pesticide products are often mixed in the field before application with other ingredients called “adjuvants”4 and/or other pesticide products. Pesticides that are applied on different geographic areas can also migrate away from the site of application and mix together in the environment.5

The EPA toxicity data requirements from chemical companies that focus on a single ingredient, combined with the fact that government and academic researchers often don’t have the means to study the vast landscape of mixture toxicity in sufficient detail, leads to an enormous gap in our knowledge of pesticide mixture toxicity.

Chemical Interactions When chemicals mix in the environment, one of two things can happen: 1) the chemicals can interact in such a way as to change their toxicity profiles or 2) no interaction occurs. When chemicals do not interact, this is generally referred to as “additivity,” which means that no chemical in the mixture influences the toxicity of the other chemical(s) and toxicity can be estimated by how the chemicals act on their own. Alternatively, chemicals can interact to increase or decrease toxicity beyond the sum of the individual effects, which is referred to as “synergism” or “antagonism,” respectively.6

Synergism is particularly worrisome from a regulatory point of view, because, if it is not properly taken into account, adverse effects on human health or the environment can be much greater than originally estimated.

The EPA’s current guidance on how to assess mixture toxicity to humans directs the agency to assume that no interaction is occurring as a default unless available data indicate otherwise.7

In practice, because of the enormous data gaps on mixture toxicity, the EPA almost exclusively ends up assuming “no interaction” when the agency analyzes mixture toxicity to humans. There is currently no guidance on how the EPA assesses mixture toxicity to plants and animals other than humans, and the ecological risk assessment process does not generally assess pesticide mixture toxicity.6

Patent Applications The extensive gaps in our knowledge of mixture toxicity ultimately weaken the EPA’s ability to effectively regulate pesticides, and new sources of data need to be identified. One new source of data was recently brought to the forefront with EPA’s approval of Enlist Duo, a new pesticide product from Dow that combines glyphosate and 2,4-D into one formulation for use on second generation genetically engineered crops. Following its registration of Enlist Duo, in preparing to defend itself in subsequent litigation on the registration

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decision, the EPA came across a patent application from Dow that indicated glyphosate and 2,4-D result in synergistic toxicity to plants. This meant that the EPA’s evaluation of the product at the registration phase lacked a full consideration of impacts to nontarget plants, including endangered species. The discovery of this patent application spurred the EPA to further request any relevant data from Dow about possible synergies and ultimately ask a court to vacate its decision to register Enlist Duo.8

When a company or individual wants to patent a chemical mixture in the United States, the United States Patent and Trademark Office (USPTO) has to determine whether there is something nonobvious about the mixture that could presumably only be found through research and development done by the applicant.9

For chemical mixtures of pesticides, the applicant will often demonstrate this by claiming that the chemicals have synergistic activity. Therefore, when a chemical company applies for patent protection on a mixture of multiple pesticides, it is often accompanied by data that demonstrate synergistic toxicity to the organisms that are going to be targeted by the pesticide mixture.

In the case of Enlist Duo, the fact that publicly available data from a patent application was unknown to the EPA until it was working to defend itself in litigation highlights just how broken this process is. Enormous data gaps, coupled with nonconservative measures of mixture toxicity, have created a precarious framework of assumptions that, in many cases, underestimates the toxicity of pesticide mixtures to humans and the environment. Analysis Pesticide Products For this analysis we sought to understand just how extensive the patent landscape was regarding claims of pesticide synergy. To ensure that our analysis was relevant to pesticide mixtures that were going to be encountered in the environment, we limited it to products that

contain multiple pesticide ingredients (subsequently referred to as “active ingredients”). Specifically, we identified all of the products from four major agrochemical companies (Bayer, Dow, Monsanto and Syngenta — hereafter referred to as “The Big Four”) the EPA approved in the past six years that contained two or more active ingredients.10

This way we identified pesticides that were absolutely certain to be co-applied because they are sold together in a single product. A more detailed description of our methodology is outlined in Appendix A.

We found 140 products from The Big Four, approved between June 2010 and June 2016, that contained at least two active ingredients. Each product contained anywhere from two to six active ingredients, and all were characterized as an herbicide, insecticide or fungicide/nematicide. The largest group of multi-ingredient products from The Big Four that have been approved in the past six years was herbicides, accounting for 67 of the 140 products. A breakdown of the products by company indicates that Bayer, Dow, Monsanto and Syngenta had 49, 26, 5 and 60 products that were included in our analysis, respectively. Synergy Patents We then searched various databases for patent applications that made a claim of synergy for at least two of the active ingredients in the product (methodology outlined in Appendix A). Only patent applications submitted to the USPTO were included in this analysis; patent applications in other countries were excluded. All patent applications that were granted, denied or still in the application process were included in our analysis because the status of the application has no bearing on the underlying accuracy of the synergy claims. The USPTO generally does not pass judgment on whether synergy exists or not; it takes applicants at their word, only considering whether the claims are nonobvious and therefore patentable. Remarkably, of the 140 pesticide products included in our analysis that contain multiple active ingredients, 96 had at least one patent

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application that claimed or demonstrated synergy between the active ingredients in the product, a total of 69 percent (Figure 1a and Appendix B). These 96 products had at least one patent application and as many as six, claiming or demonstrating synergy between the active ingredients in the product. The majority of patent applications contained experimental data that were included in the application as evidence of the claimed synergy. For all patent applications, synergy was claimed or demonstrated for target organisms (i.e. synergistic toxicity to target insect species for insecticidal ingredients). A breakdown of the patent synergy claims by company indicates that 71 percent (35/49), 46 percent (12/26), 40 percent (2/5) and 78 percent (47/60) of Bayer, Dow, Monsanto and Syngenta products had patent applications that claimed synergy between at least two of the active ingredients in the product, respectively. As some of the approved products contained similar ingredients, many patent applications covered multiple products. There were a total of 47 patent applications that covered the ingredient mixtures in the products included in our analysis.11 Many of the ingredients covered by

these patent applications are very widely used, with 72 percent (34/47) of patent applications involving high use ingredients (more than 1 million pounds used per year in the U.S. agricultural sector) (Figure 1b).12

Acuron, a case study In 2015 the EPA conditionally registered a pesticide product from Syngenta called Acuron (EPA Reg. No. 100-1466, Decision No. 470872). Acuron combines four different active ingredients — bicyclopyrone, S-metolachlor, mesotrione and atrazine — into a single formulation to control weeds in cornfields. The approval of the Acuron product was combined with the approval of the new active ingredient bicyclopyrone, and therefore went through public review and comment.13

In response to the Center for Biological Diversity’s public comments regarding possible synergistic effects of Acuron, the EPA stated: “Concerning synergistic effects, the agency does not routinely include a separate evaluation of mixtures of active ingredients. However, there are some data available to the agency regarding synergistic effects and EPA believes it adequately addressed the issue of synergism between bicyclopyrone and atrazine.”14 But the EPA provides no information on how it addressed this issue of synergism as there is no mention of this analysis in the ecological risk assessment,15

no separate analysis was provided to the public, and there was no mention of whether synergy was analyzed for ingredient combinations other than bicyclopyrone and atrazine. The agency further indicated that a study of acute toxicity of Acuron to mammals was analyzed and did not indicate synergy was occurring.14 However, it did not analyze chronic toxicity to mammals or acute and chronic toxicity to all other taxa like birds, fish, invertebrates and plants as a result of Acuron exposure prior to approving this product.

As Acuron is a Syngenta product that was approved in the past six years, it was included in our patent analysis. We found three patent applications claiming synergistic toxicity to plants

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from exposure to the ingredients in this product: the combination of 1) S-metolachlor and mesotrione (app # 12374219), 2) mesotrione and atrazine (app # 12675156) and 3) atrazine and S-metolachlor (app # 08930901) (Appendix B). Since bicyclopyrone has the same mode of action as mesotrione,16 it is likely that any synergy observed with mesotrione and other ingredients will be present with bicyclopyrone and those ingredients as well. Synergistic toxicity of mesotrione and atrazine to certain species of plants has also been extensively documented in the literature.17- 22 Finally, in publicly available promotional materials for Acuron, Syngenta has not only claimed that mesotrione and bicyclopyrone work synergistically with atrazine to kill plants, but they have mapped out the exact mechanism by which synergy occurs.23

It is clear that there are at least three and as many as five layers of synergy that result from the combination of ingredients in Acuron (Figure 2). This synergistic toxicity has been demonstrated for species of plants, and plant health is a very important part of the ecological risk assessment process. EPA’s failure to accurately account for toxicity to nontarget plants can lead to damage of crops in nearby fields, harm to endangered or threatened species of plants and harm to vital aquatic and terrestrial plant communities and the wildlife that rely on them. The EPA is charged with ensuring that pesticide use results in no unreasonable adverse effects to the environment or harm to endangered or threatened species. It is still unclear how the agency came to its conclusion for Acuron without properly considering this publicly available, relevant information.24

Discussion Our analysis indicates that there are patent applications claiming or demonstrating synergistic action for 69 percent of the recently approved products from The Big Four pesticide companies that contain multiple active ingredients. This percentage is very high and disconcerting. Synergy between chemicals is not generally thought to be a very common phenomenon, which is one reason regulatory agencies typically assume additivity. However, in the case of premixed products, this high percentage makes perfect sense. Combining synergistically acting chemicals into a single product not only allows a company to gain patent protection on the combination of ingredients in their product, but, from a product performance point of view, it makes sense to combine ingredients that will enhance each other’s ability. Unfortunately enhancing toxicity to target organisms will often enhance toxicity to many nontarget organisms as well. Perhaps most worrisome is that 72 percent of the patent applications we identified claimed or demonstrated synergy with some of the most highly used pesticides in the United States, including glyphosate, atrazine, 2,4-D, dicamba and the controversial neonicotinoids thiamethoxam, imidacloprid and clothianidin, indicating that potential impacts could be widespread. We’re also certain that 69 percent is an underestimate of how many of these products have synergistic activity. There are multiple reasons for this conclusion:

1. We only took into account U.S. patent applications. In our search we found multiple relevant patent applications filed with other countries as well as with the World Intellectual Property Organization (WIPO). For example, a U.S. patent application could not be identified for the product combining methoxyfenozide and spinetoram (EPA reg No. 62719-666), however Dow submitted a patent application

http://www.wipo.int/�

http://www.wipo.int/�

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to the WIPO claiming that this active ingredient combination works synergistically to kill an insect target organism.25

2. Many relevant patent applications may not be publicly available yet. The products that we analyzed were approved relatively recently, and it is therefore likely that some relevant patent applications were filed recently as well. The USPTO delays the publishing of patent applications for 18 months after the date of first filing.

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3. Because “inert” ingredients in pesticide products are not made available to the public, we were unable to search for patent applications that demonstrated synergy between the active ingredients and other ingredients contained in the pesticide product. We did come across many patent applications claiming synergy between the active ingredients in the analyzed products and commonly used “inert” ingredients;

So any patent applications filed within the past year and a half may not be publicly available and would not have been identified by our search strategy.

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4. Searching for patent applications is surprisingly difficult. It is possible that our search strategy (Appendix A) missed relevant patent applications.

however, the lack of ingredient transparency in pesticide products prohibited the inclusion of possibly relevant patent applications. Therefore, more layers of synergy may be present in these products than were identified in this analysis.

5. We only searched for claims of synergy in patent applications. As was the case with Acuron, some of these chemical combinations may have been demonstrated to act synergistically on target or nontarget organisms in peer-reviewed scientific studies. Any such study would not have been identified in our analysis. Furthermore, any unpublished, internal studies done by chemical companies would, of course, not be identified either.

Pesticide companies likely possess additional information regarding pesticide synergy that they do not include in their patent applications. Patent applications are very different from scientific studies, which are the typical data source used by the EPA to assess risk. The latter are very descriptive and data intensive, while the former provide the bare minimum of information required to demonstrate to the patent office that their claim is legitimate. This does not necessarily mean that experimental data provided in patent applications are somehow less scientifically valid than data from scientific studies, only that more data may be available from the patent applicant than was provided to the patent office. The EPA acknowledged this fact in the Enlist Duo case by not just relying on the information contained in the relevant patent application, but also requiring Dow to submit any relevant data on the synergy between glyphosate and 2,4-D that was in its possession.8 In many cases the patent applicant will have additional data on synergism in their possession, as extensive experimentation is typically done before a company will invest the time and money to develop a product that they intend to market. It is important that this be kept in mind when scientifically evaluating the data contained in patent applications. We cannot say with absolute certainty that the patent data on synergy that we identified were not used in making registration decisions for these products. There are multiple reasons for this. The first is that, unlike Acuron, many individual products are given approval without public review and comment, so the analysis that went into the product approval, if any, is not shared with the public. Second, even when products do go through public review and comment, a mixture toxicity analysis is either not performed or not outlined in sufficient detail for the public to understand all of the lines of evidence that were used. However, given that, in the case of Enlist Duo, the EPA indicated that it just recently become aware that patent data on synergy exist and the fact that it is not common practice to do a mixture analysis for the ecological risk assessment, we think it is extremely likely

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that most, if not all, of these product approvals were made without taking into account this relevant patent information. It is also unclear why the EPA has not previously been made aware of these patent data by pesticide registrants. Registrants are required to submit information to the EPA that could raise concerns about the continued registration of a product or about the appropriate terms and conditions of registration.28

For example, pursuant to 40 CFR §159.195(a)(3), the registrant is required to submit information that indicates “[u]se of a pesticide may pose any greater risk than previously believed or reported to the Agency.” Data on chemical synergy would certainly fall into that category. It appears that chemical companies are using synergy to demonstrate that chemical combinations have some sort of novelty associated with them and are, therefore, patentable — yet when it comes to the toxicities associated with this synergy, this information never makes it to the EPA.

Recommendations Searching for patent applications can be a difficult process that takes considerable time and knowledge. Often the pesticide is not referred to by its common name in the patent application, making a simple keyword search insufficient to identify all relevant patent information. The EPA cannot rely on stakeholders to provide all of the necessary information from patent applications, but rather the EPA must place the burden to produce and submit information related to synergistic effects squarely where it belongs: on the pesticide registrant or applicant.

1. Registrants or applicants need to be made aware that failure to submit relevant data to the EPA will be a violation of their duties under Section 6(a)(2) of FIFRA.29

2. To identify patent data that are not affiliated with the pesticide registrant, the EPA needs to use a stepwise approach of

When applicable, enforcement should be pursued when registrants fail to provide those data.

doing a keyword and

3. Any claims of synergy need to be assessed for relevance given the label restrictions for the pesticide (or lack thereof) and the inert ingredients that are present in any formulation up for approval.

structure search for patent applications concerning the pesticide of interest followed by a rigorous analysis of the claims in the patent application.

4. Appropriate measures need to be taken to ensure that any registration decision is compliant with FIFRA. This may include label restrictions on mixing, increased in-field buffers, lower application rates or even product cancellation.

A full analysis of mixture toxicity needs to be taken into account for both the human health and ecological risk assessments. When patent applications or other data demonstrate synergistic toxicity to target organisms, that synergy needs to be assumed for all other nontarget organisms within that taxon. For instance if a mixture results in synergistic toxicity to a target insect, like an aphid, then that synergy needs to be assumed for all insects and possibly all other invertebrates in the ecological risk assessment unless available data indicate otherwise. This would be consistent with EPA’s current use of surrogate species to estimate toxicity to other species within the same taxon for the human health and ecological risk assessments. This is one way that the EPA can begin to take into account mixture toxicity given the extensive data gaps that are currently present. Conclusions The human health and ecological risk assessments are a key part of the EPA’s pesticide-approval process; without them the agency cannot justifiably conclude that a pesticide can be used without unreasonable harm. When relevant data are not included in the risk assessment, and nonconservative assumptions are made about mixture toxicity, it diminishes the process and ultimately underestimates harm to humans and the environment.

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The patent applications identified in this analysis are just the tip of the iceberg. The patent landscape on pesticide mixtures is vast and in no way limited to pesticides that are sold together in formulations. In fact, the implications of this analysis should extend far beyond that of multi-ingredient product approval. The entire pesticide-approval process is designed to narrowly assess the toxicity of individual active ingredients one at a time; yet when most of these active ingredients are being routinely co-applied on agricultural fields across the country, the initial analyses that were done are no longer relevant to real-world

exposure scenarios and are not an appropriate estimate of true risk. This analysis highlights the shortcomings of such a narrow approach. Since mixture toxicity is such a low priority for the EPA, it is no surprise that relevant information was missed for so long. Clearly pesticide synergy is not a rare occurrence and should no longer be treated as such. The EPA must take into account relevant patent data and other lines of evidence and fundamentally alter its approach to assessing pesticide mixtures.

Appendix A Methodology of Product Search We used the EPA’s Pesticide Product Label System database to conduct our search.30

In the “company name” search box we searched for “Bayer,” “Dow Agrosciences LLC,” “Monsanto Company” and “Syngenta Crop Protection,” which identified 685, 369, 176 and 539 products respectively. These are all of the pesticide products with “active” status for these four companies as of June 23, 2016 (a total of 1769). To identify the products that had their initial approval in the last six years and had multiple active ingredients, we found all active products that that had a date on or after June 23, 2010 in the “current status” column. We then searched the pesticide labels of each of those products. If the label indicated two or more active ingredients were present in the product, it was included in our analysis. Of the 1769 active products for these companies, 140 had multiple active ingredients and were first approved by the EPA in the past six years. All of these products are listed in Appendix B.

Methodology of Patent Search To identify all applicable patent applications, we used a multi-layered search strategy. First, we used the search engines from Google Patents,31 FreePatentsOnline32 and the USPTO33 to do simple keyword searches. The common names of each pesticide were searched concomitantly with the words “synergy,” “synergistic” or “synergism.” We found many relevant patents using this strategy, but quickly became aware of the limitations of doing a simple keyword search. Many patent applicants do not refer to pesticides by their common name but instead use a common core structure along with various possible side groups to describe the chemicals they want to patent. In order to identify these patents, we used a search engine called SureChEMBL.34 This allows the user to search patent applications for the chemical structure of the pesticide in conjunction with keywords. In addition, we used SciFinder35

to search patent applications by the pesticide’s Chemical Abstracts Service (CAS) number and filtered results by other pesticides mentioned in the patent or by the word “synergistic.”

All of the patents we identified were further scrutinized. First, any patent application that was not

submitted to the USPTO was discarded. This is because many of the patent applications submitted to other countries that we identified were in a language other than English; however, we note that this discarded information could likely be useful to the EPA. We then went through each of the identified patents and verified that claims of synergy were made for at least two of the active ingredients in the product. If it was stated anywhere in the patent application that a mixture of chemicals acted synergistically to produce toxicities to any organism, that patent was used in our analysis. However, we note that a strong majority of patent applications also contained experimental evidence of synergy. Notes were taken on each patent included in our analysis, including: 1) The company that was listed as the applicant or assignee of the patent application and whether this was different from the registrant of the product. 2) The taxa of the organism(s) for which synergy was claimed (plants, insects, fungi, nematodes). 3) If there was a possible difference in stereoisomer content of the chemicals in the pesticide product and the patent application. Since lambda-cyhalothrin is a mixture of enantiomers, one of which is gamma-cyhalothrin, any claims of synergy for one was assumed for the other. Similarly, since mefenoxam is one of the two enantiomers that are present in metalaxyl, any claims of synergy for one was assumed for the other. 4) If any experimental evidence of synergy was provided in the patent application as well as the magnitude of the synergy as measured by the Colby equation.36 If experimental data were provided in the application and a Colby analysis was performed, the extent of synergy (low, medium and high) was noted for each patent application. The observed response (Cobs) and the expected response (assuming no interaction) (Cexp) were used to make this determination. If the difference of Cobs and Cexp was less than 10, that was considered low synergy. If the difference of Cobs and Cexp was between 10 and 20, that was considered medium synergy. And if the difference of Cobs and Cexp was greater than 20 or if Cobs/Cexp was greater than 2, then that was considered high synergy. Also, if experiments were performed but no data were provided, or if experimental data were given but no Colby equation was done, we took note of that as well (Appendix B).

Appendix B

First App Reg Reg # Active Ingredients App # notes Taxa Appl App # notes Taxa Appl App # notes Taxa Appl

7/14/2010 D 62719-616 penoxsulam; cyhalofop

7/20/2010 S 100-1369 thiamethoxam; fludioxonil; azoxystrobin; mefenoxam 10496187 3 F S 10170902 1, 7 F S

7/25/2010 B 72155-90 2,4-D; dicamba; mecoprop-p; indaziflam 13841457 3 P B 12506456 3 P B

7/26/2010 B 72155-91 dicamba; penoxsulam; indaziflam 14026902 2, 7 P D 12506456 3 P B


8/2/2010 B 264-1103 Iodosulfuron-methyl-sodium; mesosulfuron-methyl

8/3/2010 D 62719-617 aminopyralid; metsulfuron methyl 12945099 6 P D

8/5/2010 S 100-1366 difenoconazole; thiamethoxam; lambda -cyhalothrin 12633063 1, 4 I S 9968173 3 I M, S 14215205 8 I S

8/5/2010 S 100-1367 difenoconazole; thiamethoxam; lambda -cyhalothrin 12633063 1, 4 I S 9968173 3 I M, S 14215205 8 I S

8/6/2010 D 62719-612 penoxsulam; isoxaben

9/3/2010 S 100-1352 fludioxonil; mefenoxam; azoxystrobin; thiabendazole 11563240 6 F, N S 10496187 3 F S

10/14/2010 B 432-1513 trifloxystrobin; triadimefon

10/29/2010 S 100-1384 thiamethoxam; mefenoxam; fludioxonil; azoxystrobin 10496187 3 F S 10170902 1, 7 F S

11/24/2010 S 100-1385 fomesafen; glyphosate

1/20/2011 B 352-846 aminocyclopyrachlor; chlorsulfuron

1/20/2011 B 352-848 aminocyclopyrachlor; metsulfuron-methyl 14172201 2, 4 P D

1/20/2011 B 352-847 imazapyr; aminocyclopyrachlor; metsulfuron-methyl 14172201 2, 4 P D

2/16/2011 S 100-1389 pinoxaden; fluroxypyr

3/2/2011 S 100-1396 fomesafen; glyphosate

3/10/2011 D 62719-630 2,4-D; aminopyralid 13014909 6 P D


3/11/2011 S 100-1377 azoxystrobin; propiconazole

3/11/2011 S 100-1378 azoxystrobin; propiconazole

3/24/2011 S 100-1393 fludioxonil; mefenoxam 8799310 1, 3 F S


4/12/2011 S 100-1364 chlorothalonil; acibenzolar-S-methyl

4/12/2011 B 72155-98 indaziflam; diquat dibromide; glyphosate 12506456 6 P B





4/29/2011 B 264-1132 clothianidin; Bacillus-firmus I-1582 12936700 3 I, F, N B



5/5/2011 D 62719-637 triclopyr; fluroxypyr

6/3/2011 S 100-1402 lambda -cyhalothrin; chlorantraniliprole


6/15/2011 S 100-1399 thiamethoxam; abamectin; thiabendazole; 11028776 7 I S 11563240 6 F, N S 11028769 7 F, N S

fludioxonil; mefenoxam; azoxystrobin 14183671 6 F, N S 10496187 3 F S 10170902 1, 7 F S

6/27/2011 D 62719-640 glyphosate; 2,4-D 14567574 6 P D 12147853 6 P D

8/12/2011 B 72155-106 2,4-D; isoxaben; mecoprop-p; dicamba 13841457 6 P B

8/17/2011 B 264-1134 Iodosulfuron-methyl sodium; thiencarbazone-methyl 12824951 6 P B


10/19/2011 S 100-1405 thiamethoxam; abamectin; thiabendazole; 11028776 7 I S 11563240 6 F, N S 11028769 7 F, N S

fludioxonil; mefenoxam; azoxystrobin 14183671 6 F, N S 10496187 3 F S 10170902 1, 7 F S

11/16/2011 S 100-1410 S-metolachlor; mesotrione 12374219 6 P S

12/6/2011 B 264-1135 thiencarbazone-methyl; pyrasulfotole; bromoxynil 12824951 4 P B

12/14/2011 S 100-1414 S-metolachlor; mesotrione; atrazine 12374219 6 P S 12675156 6 P S 8930901 3 P S

1/11/2012 S 100-1415 azoxystrobin; thiamethoxam

1/26/2012 B 432-1519 thiencarbazone-methyl; foramsulfuron; halosulfuron-methyl 13902364 5 P B 12824951 5 P B

2/1/2012 S 100-1433 azoxystrobin; difenoconazole 10496185 8 F S

2/2/2012 S 100-1427 thiamethoxam; mefenoxam; fludioxonil 13209926 2, 3 F Bf 8799310 1, 3 F S

2/2/2012 S 100-1426 thiamethoxam; mefenoxam; fludioxonil; thiabendazole 11563240 6 F, N S 8799310 1, 3 F S

2/2/2012 B 264-1091 fluopyram; tebuconazole

2/2/2012 B 264-1090 fluopyram; trifloxystrobin

2/2/2012 B 264-1085 fluopyram; pyrimethanil

2/2/2012 B 264-1084 fluopyram; prothioconazole

2/7/2012 D 62719-646 acetochlor; atrazine

2/14/2012 S 100-1429 pinoxaden; fenoxaprop-p-ethyl

2/15/2012 D 62719-645 clopyralid; aminopyralid 13715230 6 P D 14102818 6 P D

2/22/2012 S 100-1428 difenoconazole; mefenoxam

4/23/2012 S 100-1436 thiamethoxam; lambda -cyhalothrin 12633063 1, 4 I S 9968173 3 I M, S 14215205 8 I S

4/23/2012 S 100-1437 thiamethoxam; lambda -cyhalothrin 12633063 1, 4 I S 9968173 3 I M, S 14215205 8 I S

4/27/2012 B 72155-107 metsulfuron-methyl; thiencarbazone-methyl; indaziflam; dicamba 12824951 6 P B 12506456 3 P B


5/11/2012 B 264-1125 penflufen; clothianidin 11912773 6 I B

5/11/2012 B 264-1123 penflufen; prothioconazole 13061976 3 F B

5/11/2012 B 264-1122 prothioconazole; penflufen; metalaxyl 10508208 2, 3 F Bf 12663273 5 F B

5/11/2012 B 264-1124 penflufen; trifloxystrobin 12663273 4 F B

5/11/2012 B 164-1121 clothianidin; penflufen; trifloxystrobin; metalaxyl 11793763 6 I B 10486663 6 I B 12663273 5 F B

13209926 2, 3 F Bf 11912773 6 I B

6/20/2012 S 100-1383 sedaxane; difenoconazole; mefenoxam; thiamethoxam 12306870 1, 2, 6 I B 13209926 2, 3 F Bf 12278731 6 F S

6/21/2012 S 100-1440 abamectin; thiamethoxam 11028776 7 I S

8/2/2012 S 100-1442 S-metolachlor; mesotrione; atrazine 12374219 6 P S 12675156 6 P S 8930901 3 P S


10/31/2012 S 100-1441 chlorothalonil; difenoconazole 12066894 8 F S

12/6/2012 S 100-1455 mesotrione; prodiamine 12374195 6 P S

1/15/2013 M 71995-57 glyphosate; diquat dibromide

1/15/2013 M 71995-56 glyphosate; diquat dibromide

1/15/2013 S 100-1457 abamectin; thiamethoxam; mefenoxam; fludioxonil 11028776 7 I S 8799310 1, 3 F S


1/23/2013 S 100-1458 lambda -cyhalothrin; thiamethoxam 12633063 1, 4 I S 9968173 3 I M, S 14215205 8 I S

1/30/2013 S 100-1459 thiamethoxam; mefenoxam; fludioxonil; sedaxane 12306870 2, 6 I B 13209926 2, 3 F Bf 8799310 1, 3 F S

12278731 6 F S


12278731 6 F S

3/5/2013 D 62719-655 2,4-D; picloram

3/7/2013 D 62719-653 2,4-D; picloram



4/3/2013 D 62719-671 atrazine; acetochlor



6/11/2013 B 432-1527 imidacloprid; beta-cyfluthrin 9968175 2, 3 I M

6/12/2013 S 100-1444 thiamethoxam; fludioxonil; difenoconazole 7792845 4 F S

6/17/2013 S 100-1470 glyphosate; mesotrione


7/22/2013 D 62719-666 methoxyfenozide; spinetoram

8/8/2013 B 352-845 aminocyclopyrachlor; sulfometuron-methyl; chlorsulfuron

8/29/2013 D 62719-667 methoxyfenozide; spinosad

2/3/2014 D 62719-648 cyhalofop; fluroxypyr 12913235 6 P D

2/6/2014 S 100-1421 cyantraniliprole; thiamethoxam 11628145 2, 5 I Du



2/27/2014 D 62719-679 acetochlor; flumetsulam; clopyralid 12074809 3 P D

2/27/2014 M 524-614 acetochlor; flumetsulam; clopyralid 12074809 3 P D


12278731 6 F S

4/22/2014 M 524-616 dicamba; glyphosate 13099552 2, 6 P D 13751021 7 P M

5/16/2014 D 62719-680 sulfentrazone; cloransulam-methyl

5/29/2014 S 100-1527 thiamethoxam; difenoconazole; mefenoxam; fludioxonil; sedaxane 12306870 2, 6 I B 13209926 2, 3 F Bf 8799310 1, 3 F S

7792845 4 F S 12278731 6 F S

5/30/2014 S 100-1526 difenoconazole; mefenoxam; fludioxonil; sedaxane 8799310 1, 3 F S 7792845 4 F S 12278731 6 F S

6/10/2014 B 264-1168 fenoxaprop-p-ethyl; pyrasulfotole; bromoxynil octanoate;

bromoxynil heptanoate

7/16/2014 S 100-1540 propiconazole; azoxystrobin

7/29/2014 B 432-1533 foramsulfuron; iodosulfuron-methyl; thiencarbazone-methyl 13902364 5 P B 12824951 6 P B

9/29/2014 B 264-1170 spirotetramat; imidacloprid 13790375 7 I B



11/12/2014 B 432-1530 imidacloprid; spirotetramat 13790375 7 I B

12/2/2014 S 100-1530 sedaxane; difenoconazole; mefenoxam; thiamethoxam 12306870 1, 2, 6 I B 13209926 2, 3 F Bf 12278731 6 F S

12/22/2014 S 100-1549 azoxystrobin; propiconazole; lambda -cyhalothrin; thiamethoxam 12633063 1, 4 I S 9968173 3 I M, S 14215205 8 I S

12/23/2014 S 100-1550 azoxystrobin; acibenzolar-S-methyl



2/6/2015 B 264-1171 imidacloprid; fluopyram

4/13/2015 M 524-620 acetochlor; fomesafen



4/24/2015 S 100-146 atrazine; bicyclopyrone; S-metolachlor; mesotrione 12374219 6 P S 12675156 6 P S 8930901 3 P S

4/27/2015 D 62719-689 cloransulam-methyl; flumioxazin

7/17/2015 B 72155-114 tau-fluvalinate; tebuconazole

8/5/2015 S 100-1561 sedaxane; mefenoxam; fludioxonil 8799310 1, 3 F S 12278731 6 F S

8/23/2015 S 100-1450 thiamethoxam; mefenoxam; fludioxonil; azoxystrobin; thiabendazole 11563240 6 F, N S 10496187 3 F S 10170902 1, 7 F S

8/28/2015 D 62719-685 clopyralid; fluroxypyr; pyroxsulam



10/19/2015 S 100-1556 thiamethoxam; fludioxonil; difenoconazole; sedaxane 12306870 2, 6 I B 7792845 4 F S 12278731 6 F S

10/19/2015 S 100-1559 thiamethoxam; mefenoxam; thiabendazole; fludioxonil; sedaxane 12306870 2, 6 I B 11563240 6 F, N S 8799310 1, 3 F S

12278731 6 F S

11/10/2015 B 11556-186 diflubenzuron; permethrin

12/9/2015 B 264-1182 penflufen; trifloxystrobin; metalaxyl 12663273 5 F B

1/6/2016 D 62719-693 acetochlor; mesotrione; clopyralid 12074809 3 P D

2/3/2016 S 100-1564 thiamethoxam; difenoconazole; mefenoxam; sedaxane; 12306870 1, 2, 6 I B 13209926 2, 3 F Bf 12278731 6 F S

cytokinin; gibberellic acid; indole butyric acid

2/8/2016 S 100-1568 bicyclopyrone; mesotrione; S-metolachlor 12374219 6 P S

2/17/2016 B 264-1184 dicamba; tembotrione

2/24/2016 D 62719-702 penoxsulam; oxyfluorfen 13014869 6 P D


4/12/2016 S 100-1563 thiamethoxam; thiabendazole; sedaxane; mefenoxam; fludioxonil 12306870 2, 6 I B 11563240 6 F, N S 8799310 1, 3 F S

12278731 6 F S

6/16/2016 S 100-1587 fludioxonil; sedaxane; thiamethoxam 12278731 3 F S 12306870 2, 5 I B

6/20/2016 B 432-1537 fluopyram; trifloxystrobin

Column 1: Date that the product was first approved by the EPA

Column 2: Registrant of the approved product (D=Dow, M=Monsanto, S=Syngenta, B=Bayer)

Column 3: Registration number of the product. Information on products can be found by searching the registration number on the EPA’s Pesticide Product Label System found here:

https://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1

Column 4: A list of the active ingredients found in each product

Column 5: The patent application number. Patent applications can be searched by application number on USPTO’s Public Pair Portal found here:

http://portal.uspto.gov/pair/PublicPair

Column 6: Notes taken on the patent. For more detailed information see Appendix A

1 = Stereoisomer content of a pesticide in the product may differ from that analyzed in the patent.

2 = Applicant/assignee of patent application differs from the registrant of the product

3 = No experimental evidence was provided in the patent application

4 = Experimental evidence was provided in the patent application, which indicated low synergy

5 = Experimental evidence was provided in the patent application, which indicated medium synergy

6 = Experimental evidence was provided in the patent application, which indicated high synergy

7 = Experimental evidence was provided in the patent application but no Colby equation was performed

8 = Experiments were said to be performed but data were not provided in the patent application

Column 7: Taxa for which synergistic toxicity is claimed or demonstrated (P=Plants, I=Insects, F=Fungi, N=Nematodes)

Column 8: Applicant/assignee of the patent (D=Dow, M=Monsanto, S=Syngenta, B=Bayer, Du=DuPont, Bf=BASF)

Columns 9-12: Repeat columns 5-8

Columns 13-16: Repeat columns 5-8

https://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1

http://portal.uspto.gov/pair/PublicPair

References Cited 1 7 U.S.C. § 136a(c)(5)(C), (D); 40 C.F.R. § 152.112(e). 2 EPA. Pesticide Registration: Data Requirements for Pesticide Registration. Accessed 6/20/2016. Available at: https://www.epa.gov/pesticide-registration/data-requirements-pesticide-registration#nto. 3 Cox, C., and Surgan, M. (2006) Unidentified inert ingredients in pesticides: implications for human and environmental health. Environ Health Perspect, 114(12), 1803-1806. 4 EPA. Pesticide Registration: Pesticide Registration Manual: Chapter 1 - Overview of Requirements for Pesticide Registration and Registrant Obligations. Accessed 6/20/2016. Available at: https://www.epa.gov/pesticide-registration/pesticide-registration-manual-chapter-1-overview-requirements-pesticide#adjuvants. 5 Gilliom, R.J., Barbash, J.E., Crawford, C.G., Hamilton, P.A., Martin, J.D., Nakagaki, N., Nowell, L., Scott, J.C., Stackelberg, P.E., Thelin, G.P., Wolock, D.M. (2006) Pesticides in the Nation's Streams and Ground Water, 1992-2001: U.S. Geological Survey Circular 1291. Available at: http://pubs.usgs.gov/circ/2005/1291/. 6 Lydy, M., Belden, J., Wheelock, C., Hammock, B., Denton, D. (2004) Challenges in regulating pesticide mixtures. Ecology and Society 9(6): 1. Available at: http://www.ecologyandsociety.org/vol9/iss6/art1/. 7 EPA. (2000) Supplementary guidance for conducting health risk assessment of chemical mixtures. EPA/630/R-00/002. Accessed 6/21/2016. Available at: https://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=20533. 8 Respondents’ Motion for Voluntary Vacatur and Remand filed in Natural Resources Defense Council, Inc. v. U.S. EPA, No. 14-73353 (consolidated with 14-73359), ECF Dkt. No. 121 (filed November 24, 2015 9th Cir.). 9 35 U.S.C § 103. 10 Instead of identifying all of the products that were approved in the last six years that have multiple active ingredients, we decided to focus our analysis on just four companies. Our reasoning is that the EPA’s pesticide product label database is of limited utility. The only search terms are “product name,” “company name” or “EPA registration number.” The only way to identify all products approved by date is to search by company, so we focused our analysis on the major players in the agrichemical business. 11 The 47 USPTO patent application numbers are: 13014909, 11028776, 12074809, 14172201, 12945099, 12675156, 8930901, 12066894, 9968175, 13715230, 14102818, 12936700, 11793763, 13209926, 10486663, 11628145, 12913235, 9968173, 12633063, 14215205, 13099552, 13751021, 10496185, 10170902, 10496187, 7792845, 12147853, 14567574, 12506456, 13841457, 8799310, 11028769, 11563240, 14183671, 12374195, 12374219, 11912773, 12663273, 13061976, 14026902, 13014869, 10508208, 12278731, 13790375, 12306870, 13902364 and 12824951. 12 Usage information was collected from the USGS National Water-Quality Assessment (NAWQA) Program. Pesticide National Synthesis Project – annual pesticide use maps 2013. Available here: https://water.usgs.gov/nawqa/pnsp/usage/maps/compound_listing.php. High use ingredients (defined as more than one million pounds active ingredient used in the agricultural sector per year in the U.S.) covered by the identified patent applications include: 2,4-D, thiamethoxam, acetochlor, clopyralid, atrazine, mesotrione, S-metolachlor, chlorothalonil, imidacloprid, clothianidin, dicamba, glyphosate, azoxystrobin, bromoxynil. 13 EPA. Regulations.gov docket number EPA-HQ-OPP-2014-0355. Bicyclopyrone: New Proposed Tolerance in/on Corn commodities and a New Proposed Import Tolerance in/on Sugarcane. Available at: https://www.regulations.gov/docket?D=EPA-HQ-OPP-2014-0355. 14 EPA. (2015) Bicyclopyrone: Response to Public Comments on EPA's "Proposed Registration of the New Active Ingredient Bicyclopyrone." Document ID: EPA-HQ-OPP-2014-0355-0076. Available at: https://www.regulations.gov/document?D=EPA-HQ-OPP-2014-0355-0076. 15 EPA. Memorandum. (2015) Environmental Fate and Ecological Risk Assessment for Use of the New

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Herbicide Bicyclopyrone (NOA449280). Document ID: EPA-HQ-OPP-2014-0355-0015. Available at: https://www.regulations.gov/document?D=EPA-HQ-OPP-2014-0355-0015. 16 The United Soybean Board. Take Action. Herbicide Classification Chart. Accessed 6/22/2106. Available at: http://takeactiononweeds.com/wp-content/uploads/herbicide-classification-chart_2016.pdf. 17 Abendroth, J.A., Martin, A.R., Roeth, F.W. (2006) Plant Response to Combinations of Mesotrione and Photosystem II Inhibitors. Weed Technology, 20(1), 267-274. 18 Woodyard, A., Bollero, G., Riechers, D. (2009) Broadleaf Weed Management in Corn Utilizing Synergistic Postemergence Herbicide Combinations. Weed Technology, 23(4), 513-518. 19 Sutton, P., Richards, C., Buren, L., Glasgow, L. (2002) Activity of mesotrione on resistant weeds in maize. Pest Manag Sci, 58(9), 981-984. 20 Bollman, S.L., Kells, J.J., Penner, D. (2006) Weed Response to Mesotrione and Atrazine Applied Alone and in Combination Preemergence. Weed Technology, 20(4), 903-907. 21 Hugie, J., Bollero, G., Tranel, P., Riechers, D. (2008) Defining the Rate Requirements for Synergism between Mesotrione and Atrazine in Redroot Pigweed (Amaranthus retroflexus). Weed Science, 56(2), 265-270. 22 Walsh, M., Stratford, K., Stone, K., Powles, S. (2012) Synergistic Effects of Atrazine and Mesotrione on Susceptible and Resistant Wild Radish (Raphanus raphanistrum) Populations and the Potential for Overcoming Resistance to Triazine Herbicides. Weed Technology, 26(2), 341-347. 23 Syngenta. (2015) Acuron Technical Bulletin. Acuron™ corn herbicide defeats tough weeds current products are missing, Page 22. Downloaded on 6/30/2016 from: http://www.syngentacropprotection.com/prodrender/imagehandler.ashx?ImID=d40b0089-7648-491d-9d4f-c4f1c92d27bb&fTy=0&et=8. PDF of bulletin is on file with the authors. 24 The Center has initiated litigation challenging the EPA’s failure to consider the impacts of this approval on threatened and endangered species. See https://www.biologicaldiversity.org/news/press_releases/2015/pesticides-06-18-2015.html. 25 Dow Agrosciences LLC, Wang, Peng, Huang, Jim X., Dripps, James E., Yu, Alisa Y. (WO2015196339) SYNERGISTIC EFFECT OF SPINETORAM AND METHOXYFENOZIDE FOR CONTROL OF STEM BORER ON RICE. International patent application # PCT/CN2014/080526, filed June 23rd, 2014. 26 USPTO. USPTO Will Begin Publishing Patent Applications. November 27th, 2000. Available at: http://www.uspto.gov/about-us/news-updates/uspto-will-begin-publishing-patent-applications. 27 Bayer Cropscience LP, Reid, Byron L, Baker, Robert B, Bao, Nanggang N, Koufas, Deborah A, Kent, Gerald J, Baur, Peter. (Patent # 8,404,260). Synergistic pesticide compositions. USPTO Application number 12/410,840, filed March 25th 2009. This is an example of a patent application that demonstrates synergy between the active ingredient imidacloprid and commonly used inert ingredients. 28 40 C.F.R. § 159.195(a). 29 7 U.S.C. § 136d(a)(2). 30 Found here: https://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1. 31 Found here: https://patents.google.com/. 32 Found here: http://www.freepatentsonline.com/search.html. 33 Found here: http://appft.uspto.gov/netahtml/PTO/search-bool.html. 34 Found here: https://www.surechembl.org/search/ 35 Found here: https://scifinder.cas.org 36 Colby, S.R. (1967) Calculating Synergistic and Antagonistic Responses of Herbicide Combinations. Weeds, 15(1), 20-22.

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rmcspadden

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rmcspadden

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Cover image courtesy of Pl77 / Wikimedia Commons CC-BY-SA

rmcspadden

Typewritten Text

Mary Lacques <[email protected]>

06/24/2019 01:00 PM


cc Subject Testimony IN SUPPORT of enacting

policy to ban pesticides on DOE campuses

Aloha Board of Education Members,

My name is Mary Lacques and I am a resident of Haleiwa. I am a member of Hawai'i SEED and a former employee of the Honolulu Community Action Program (HCAP), which has 85 preschool classroom on DOE campuses.

I am so appreciative, and encouraged by your interest in learning more about the harmful effects of pesticide exposure to teachers, administrative staff, parents, and especially to the most vulnerable on your campuses-your students. As a home-based preschool teacher, I had the opportunity to visit many of your campuses, especially in the spring when orienting my young students and their parents to kindergarten.

In my thirteen years with HCAP, I noticed an increase in special ed students in our classrooms. Children are being constantly exposed to a myriad of toxins in this polluted, modern world, doesn't it make sense that their place of learning should be the safest and least harmful environment?

As you have heard by now, in the interest of protecting the public, several school districts around the country have banned pesticides from their campuses. The beauty of this transition to organic land management practices is that Hawai'i already has experts in our communities that have the knowledge and hands-on experience to make DOE campuses healthy places of learning.

We are trusting that you will enact policy banning pesticides to protect public health and encourage any schools who are struggling to make the transition to seek out resources and assistance available, especially at the meeting this afternoon.

Aloha,

Mary Lacques

P.O. Box 14

Haleiwa HI 96712

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KIM COCO IWAMOTO, ESQ.

Hawaii Board of EducationCommunity MeetingLeilehua High School LibraryMonday, June 24, 2019

Testimony in Strong Support of banning the use of glyphosate on DOE campuses

Dear Board Members,

In 2015, I wrote a Civil Beat column regarding the State of Hawaii’s responsibility to protect students, teachers, administrators and other campus personnel from the harms of pesticides - especially since the state mandates student attendance and directs the working conditions of state employees who work on DOE campuses. ( See attached.)

I concluded my column by citing the 2014 Hawaii Supreme Court case, Van Ness v. State Department of Education. In its unanimous decision, the Court held that Mr. Van Ness, who was a DOE teacher at Lahainaluna High School, should receive “compensation for the aggravation of his asthma resulting from his exposure to vog at work.”

The Court outlined all the ways the DOE could have lessened Mr. Van Ness’ exposure to vog, but the DOE failed to implement those safeguards - resulting in its liability to provide compensation to the injured teacher.

Today the BOE has ample knowledge and opportunity to safeguard its employees and students from glyphosate-based herbicides, which have already been adjudicated harmful. Please ban the use of glyphosate on DOE lands and mandate the use of organic land management practices.

Sincerely,

PO Box 235191Honolulu, HI 96823

[email protected], Q

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Jessica Scott <[email protected]>

06/25/2019 10:05 PM


Subject No pesticides or herbicides

When we know better, we do better. We know the dangers of using these harmful herbicides and pesticides. There are numerous lawsuits about cancer causing agents in these products. Let’s protect our keiki (and our aina) and stop the use of these horrible products.

We know better - let’s do better!

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