Pesticide Report of Green Aces (Greenbelt Committee on Enviromental Sustainablity)


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Report of Greenbelt Advisory committee on environment on pesticide use in Greenbelt. Contains 12 recommendations adopted by City Council as guides for decision making and reduction of use. Recommends organic land care

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Pesticide Report of Green Aces (Greenbelt Committee on Enviromental Sustainablity)

  2. 2. Table of Contents Page1. BACKGROUND 31.1 Use of the Precautionary Principle and Tools 31.2 Precautionary Principle Tools for Decision Making and Action 32. FINDINGS 42.1 Step One: Identify the Possible Threat and Characterize the Problem 42.2 Step Two: What is Known and Not Known About the Threat? 5 2.2.1 Pesticides and Health Generally 5 2.2.2 Pesticide Use By the City Staff 7 2.2.3 Pesticide Use by Residents and Businesses of Greenbelt 102.3 Step Three: Reframe the Problem to Help Decide What REAC Needs to Do 112.4 Step Four: Assess Alternatives---How Have Other Communities Addressed the 11 Issues? What Are the Possible Alternatives? 2.4.1 Examples from Canada: Bans, Phase Outs, and Public Education 12 2.4.2 Mandating and Defining Integrated Pest Management (IPM)--- 13 Maryland IPM In-Schools Legislation 2.4.3 Other Innovative US Ordinances 14 2.4.4 The Organic Pest Management and the Organic Land Care Movement 15 in Landscaping3. RECOMMENDATIONS 173.1 Step Five: Determine the Course of Action and Recommendations 173.2 Specific Recommendations to Council 173.3 Step Six: Monitor and Follow Up 19Appendices 20Appendix A---SUMMARY REPORT BY CITY OF GREENBELT STAFF 20Appendix B-- ONTARIO COLLEGE OF PHYSICIANS REPORT SUMMARY 27Appendix C—SAMPLE PESTICIDE LABEL 30Appendix D---EPA CRITERIA FOR EVALUATION OF CHEMICAL 31CARCINOGENICITYAppendix E---EXAMPLES OF CANCER RISK ASSESSMENT 35Appendix F---PESTICIDE BY-LAW OF THE CITY OF TORONTO 36Appendix G---BEST PRACTICE REVIEW REPORT SUMMARY 38Appendix H--TOWN OF MARBLEHEAD BOARD OF HEALTH ORGANIC 41PEST MANAGEMENT REGULATIONSAppendix I---ANNOUNCEMENT OF ORGANIC LAND CARE BASIC 47TRAINING FOR MUNICIPAL OFFICIALS OR TRANSITIONINGLANDSCAPERSAppendix J---RESOURCES ON PESTICIDES AND ALTERNATIVES 488/14/2007 2
  3. 3. 1. BACKGROUNDIn fall of 2004, REAC asked City Council to study the issue of pesticide use within Greenbelt. Thisrequest was then sent to Greenbelt Staff for review. City staff recommended that REAC itself dothe study. In 2005 City Council requested REAC to: 1) review pesticide use by the City, 2) studypesticide use in general, and 3) make recommendations to Council. Over the past 18 months,REAC has invited experts on the topic to committee meetings and its members have studied theissue working with City Staff.Public Works Staff has worked very cooperatively with REAC and provided all informationrequested. They have also shared their informed perspective on the topic of concern. REAC wishesto express our thanks and acknowledgment to the Staff for the help provided.Using a six-step process, based on the Precautionary Principle, this report presents a summary offindings of the pesticide study and provides a set of recommendations for the Council to consider.1.1 Use of the Precautionary Principle and ToolsConsistent with the United Nations (1992), and numerous international conventions and statementsand the President’s Council on Sustainable Development (1996), REAC endorses what has come tobe known as the Precautionary Principle (Tickner, Raffensperger, and Myers, 2001). Theprecautionary principle broadly states: “When an activity raises threats of harm to human health orthe environment, precautionary measures should be taken even if some cause-and-effectrelationships are not fully established scientifically.” (taken from the January 1998 Wingspread Statementon the Precautionary Principle). The Rio Declaration from the 1992 United Nations Conference onEnvironment and Development, also known as Agenda 21 (which the United States signed and ratified)similarly stated: In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost- effective measures to prevent environmental degradation (The Rio Declaration from the 1992 United Nations Conference on Environment and Development, also known as Agenda 21).1.2 Precautionary Principle Tools for Decision Making and ActionIn the publication (Tickner, Raffensperger, and Myers, The Precautionary Principle in Action: AHandbook 2001) written for the Science and Environmental Health Network, the authors identify asix step set of tools for arriving at policy decision making in an area when there is some uncertainty.This report follows this process as a method of organizing the report--- starting with anidentification of the problem and moving to actionable recommendations. The six steps are:Step One: Identify the possible threat and characterize the problemStep Two: Identify what is known and what is not known about the threat.8/14/2007 3
  4. 4. Step Three: Reframe the problem to describe what needs to be doneStep Four: Assess alternatives.Step Five: Determine the course of action.Step Six: Monitor and follow upWe move through each of the steps in this report to Council. Our findings are presented in stepsOne to Four. Steps Five and Six contain the recommendations to Council. A number ofappendices are included. Appendix A prepared by Bill Phelan contains the report of City Staff onRecent Pesticide Use and summarizes city staff views. Appendices B to J contain other relevantinformation and are identified within the document in appropriate sections.2. FINDINGS2. 1 Step One: Identify the Possible Threat and Characterize the ProblemThe impetus to study the use of pesticides in Greenbelt, grew out of concerns for public andenvironmental health (human, animal and plant) specific to Greenbelt, the wider Chesapeake BayWatershed, and the global community of which we are also a part. Concerns at these threegeographic levels can be summarized briefly as follows: • The initial request to REAC for the study of pesticide use in Greenbelt grew out of two specific incidents in 2004 ---a broad based spraying by GHI of an area around Hillside to control invasive plants, and the observation by a member of REAC of evidence of a broad based herbicide spraying by the City along the sidewalk on the route to the metro along Cherrywood Lane and very close to Indian Creek. These citizens were concerned for their own health, the ecology of their neighborhood, and the damage to wildlife, especially as some of the spraying was on slopes that went directly into the local streams. In both cases the expressed intent by GHI and the City was a positive goal. In one case the goal of the spraying was to control invasive species, and in another case the goal was control plants that were deemed too close to a public sidewalk where mowing with a large mower was not possible. It should be noted that both GHI and the City have reduced the broad based spraying that prompted the initial concern in 2004. • The request for the study also grew out of wider general concerns for the Chesapeake Bay Watershed. The Chesapeake Bay Foundation (CBF) has described the bay as “dangerously out of balance,” and a “system in crisis.” Last year’s “Annual State of the Bay Report” summary states, “The Chesapeake and its rivers and streams are dying…” While the sources of the problem are many, on a per acre basis urban run off is estimated to contribute 7 times the pollution that farm areas contribute. The 2000 Chesapeake Bay Agreement adopted a goal of a “Chesapeake Bay free of toxics by reducing or eliminating the input of chemical contaminants from all controllable sources to levels that result in no toxic or bioaccumulative impacts on the living resources that inhabit the Bay or on human health.” The Toxics 2000 Strategy recommends the implementation of “Projects and programs that reduce the use of pesticides, promote less toxic alternatives, or employ other voluntary efforts that ultimately8/14/2007 4
  5. 5. reduce pesticide loads to the watershed.” The Chesapeake Bay Strategy recognizes that “Nonpoint-sources, particularly urban stormwater runoff, represent a substantial source of chemical contaminants to the Bay and its tidal rivers”. This fact, coupled with, “…increasing population and expanded development within the watershed” suggest that efforts to reduce the toxic contributions from individuals and homeowners should have a significant cumulative benefit for the Bay and its rivers. • Finally, Greenbelt is part of the global community. There is a general recognition that the global environment is under grave stress from numerous sources related to burning of fossil fuels, and extensive use of chemical fertilizers and pesticides, most of which have unknown long term effects. Worldwide use of pesticides increases yearly and estimates are that 3 billion kilograms of pesticides are spread annually. According to the USDA over 100 million pounds of pesticides were applied to ornamental landscapes alone in the year 2002 (in the USA).2.2 Step Two: What is Known and Not Known About the Threat? The following is a summary of our findings presented under the following topics: 1. Pesticides and Health Generally 2. Pesticide Use by the City of Greenbelt 3. Pesticide Use by Residents and Businesses in Greenbelt (on this topic little is known currently, however we include it because one of the things REAC increasingly came to realize was of importance of this issue to the problem)2.2.1 Pesticides and Health Generally • Definititon of Pesticides as Used in this Document: Pesticides are “substances or mixtures of substances that prevent, destroy, repel, or mitigate pests, or defoliate, desiccate, or regulate plants” (Massachusetts Department of Food and Agriculture Pesticide Bureau). Herbicides, fungicides, insecticides, miticides, avicides and rodenticides are all considered pesticides. • Pests are and may be known as undesirable plants, insects, fungi, bacteria, and rodents, birds and other animals. Common examples in turf grass and the landscape can be, but are not limited to, crabgrass, knotweed, poison ivy, chinch bugs, grubs, and a variety of plant pathogens. • While the REAC working group looked at pesticides generally, most of our work has been with regard pesticides as applicable to landscape care. We consider only in a limited manner issues related to pesticides designed for in-door use, or insect control. • According to the United States Environmental Protection Agency (EPA) “By their very nature, most pesticides create some risk of harm. [They] can cause harm to humans, animals, or the environment because they are designed to kill or [harm]… living organisms.” US court cases have ruled that: it is not legal for companies that make pesticides and pest control companies to say that a pesticide is “safe.” They cannot claim it is “safe” even if it is registered for public use and even if it is used as directed.8/14/2007 5
  6. 6. • According to Center for Disease Control studies (2005 Third National Report on Human Exposure to Chemicals, as reviewed by the Pesticide Action Network of North America (PANNA)), most people in the U.S. have pesticides in their bodies, and 6-11 year olds have levels four times and 12-19 year olds three times what EPA considers safe. • Pesticides may kill or harm desirable organisms in addition to those they target. There is growing evidence of the hazards associated with long-term use of pesticides. Pesticide exposure in humans has been associated with birth defects; numerous cancers, including non-Hodgkin’s lymphoma, (the second fastest growing cancer in the U.S.); Parkinson’s disease and other neurological disorders; immune systems problems; and male infertility. The web site for Beyond Pesticides gives summary information on the effects of the most commonly used pesticides, as well as providing information on organic lawn care. • After a comprehensive systemic review of the literature, the Ontario College of Family Physicians (OCFP) in April of 2004 strongly recommended that people reduce their exposure to pesticides wherever possible. The review shows consistent links to serious illnesses such as cancer, reproductive problems and neurological diseases, among others. The study also shows that children are particularly vulnerable to pesticides. “Many of the health problems linked with pesticide use are serious and difficult to treat – so we are advocating reducing exposure to pesticides and prevention of harm as the best approach”, said Dr. Margaret Sanborn of McMaster University, one of the review’s authors. Appendix B is a copy of the executive summary of this report. The full text of the report is available at: 20Paper%2023APR2004.pdf • The full range of harm from pesticides is not known. This is because few studies have looked at: how pesticides affect children; what happens when people are exposed to them long-term; what happens when people are exposed to a few different pesticides at the same time; what happens when they combine with other chemicals or medicines in our bodies; what happens if a person is exposed to a pesticide over and over again (Maryland Pesticide Network in Pesticides: The Risks, Prevention and Healthier Choices, 2006). • EPA does not currently evaluate or consider the endocrine disrupting properties of pesticides during registration or re-registration. Recent press reports have highlighted (Science News September 2006; Beyond Pesticides September 6 2006) that some species of male fish are acquiring female sexual characteristics at unusually high frequencies in the Potomac River and its tributaries, prompting concerns about pollutants that might be causing the problem. Environmentalists have long pointed to pesticides and other endocrine disrupting chemicals as having the potential for wreaking such hormonal chaos. Many scientists believe that wildlife provides early warnings of effects produced by endocrine disruptors, which may as yet be unobserved in humans. A recent study found that the commonly used lawn pesticide formulation Round-Up, with the active ingredient glyphosate, causes damaging endocrine effects in fetuses. ( ( 6
  7. 7. • Recent public concerns raised by EPA science staff have called into question the efficacy of EPA rule making in the area of pesticides. For example, on August 2, 2006 the New York Times reported on recent actions of EPA Staff Unions representing 9,000 of EPAs own staff scientists, "We are concerned that the agency has not, consistent with its principles of scientific integrity and sound science, adequately summarized or drawn conclusions" …about the chemicals. The EPA scientists’, also charge that EPAs Administrator is willfully ignoring evidence that "pesticides damage the developing nervous systems of fetuses, infants and children," and are calling on EPA to cancel the registrations of 20 pesticides in the organophosphate and carbamate chemical family. • EPA regulations do not currently require the labeling of inert ingredients in pesticides. Recently, 14 States (including Maryland) have asked EPA to require disclosure of inert ingredients. The federal Environmental Protection Agency requires "active" toxic ingredients that kill insects and weeds to be listed on labels now but does not require such a listing of inert ingredients which have been considered proprietary. "There is no logical reason for EPA to mandate disclosure of those ingredients that harm pests, but exempt from disclosure other ingredients that cause serious health and environmental problems," said New York Attorney General Eliot Spitzer, who has taken the lead for the states asking the EPA to expand the labeling requirement. According to the petition inert ingredients make up as much as 99 percent of a pesticide and are known or suspected causes of cancer, nervous system disorders, liver and kidney damage and birth defects as well as environmental damage. The petition includes 40 pages of scientific data and legal precedent that the state officials say support their case. The state officials seek to have the inert chemicals listed with a caution that they "may pose a hazard to man or the environment." They note that the EPA alone has the authority to force the change. (information from © Copyright 2006 The New York Times Company). • Protecting public and environmental health is the primary concern of the Pesticide Working Group of REAC. Given the information stated above, this report will recommend the City staff adopt a balanced approach to pesticide use that places protection of public and environmental health at the forefront.2.2.2 Pesticide Use By the Public Works StaffA major focus of our review was the use of pesticides for land care and management by theGreenbelt Public Works Staff. We did not review pesticide use by the City for in-door space pestcontrol. Current practices and views of Public Works Staff are described in Appendix A in thedocument entitled “Pesticide Summary” written by Bill Phelan. • The responsibility for pest control in the public property and public spaces of the City of Greenbelt is the responsibility of the Public Works Department and within Public Works the Assistant Director of Public Works has responsibility for pest control. • Public Works personnel have indicated that they welcomed the REAC review, and have been supportive and cooperative and have aided the committees review.8/14/2007 7
  8. 8. • As part of the study REAC asked for and received City records of pesticide use for land care, and also staff perspective on the pesticide issue. A summary of recent use is included in Appendix A. • It is important to note that the EPA toxicity categorization presented in Appendix A is for “acute exposure” and is not an evaluation of the long-term or cumulative effects of exposure to humans, animals, or plants. Current federal pesticide labeling laws require pesticide manufacturers to include acute (short-term), and not chronic (long-term) health risk information on pesticide labels. Therefore, product-specific cancer risk information is not readily available. An example of a pesticide label is provided in Appendix D. An explanation of the 4 acute toxicity categories as provided by EPA is given below.Toxicity Categories and Pesticide Label StatementsEPA uses the following criteria to determine the toxicity category of pesticides. These criteria are based onthe results of animal tests done in support of registration of the pesticide. Category I is the most toxic. I II III IV Up to and including From 500 thru Greater than 5000Oral LD50 From 50 thru 500 mg/kg 50 mg/kg 5000 mg/kg mg/kgInhalation LC Up to and including From 2.0 thru 20 Greater than 20 From 0.2 thru 2 mg/liter50 0.2 mg/liter mg/liter mg/literDermal LD Up to and including From 200 thru 2000 From 2,000 thru Greater than 20,00050 200 mg/kg. mg/kg 20,000 mg/kg mg/kg No corneal Corrosive; corneal Corneal opacity reversible opacity; irritationEye effects opacity not reversible within 7 days; irritation No irritation reversible within 7 within 7 days persisting for 7 days. days Moderate Severe irritation at 72 Mild or slightSkin effects Corrosive irritation at 72 hours irritation at 72 hours. hoursHuman hazard signal wordToxicity Category I - All pesticide products meeting the criteria of Toxicity Category I shall bearon the front panel the signal word "Danger. In addition if the product was assigned to ToxicityCategory I on the basis of its oral, inhalation or dermal toxicity (as distinct from skin and eye localeffects) the word "Poison shall appear in red on a background of distinctly contrasting color andthe skull and crossbones shall appear in immediate proximity to the word "poison.Toxicity Category II - All pesticide products meeting the criteria of Toxicity Category II shall bearon the front panel the signal word "Warning.Toxicity Category III - All pesticide products meeting the criteria of Toxicity Category III shallbear on the front panel the signal word "Caution.8/14/2007 8
  9. 9. Toxicity Category IV - All pesticide products meeting the criteria of Toxicity Category IV shallbear on the front panel the signal word "Caution.Child hazard warning - Every pesticide product label shall bear on the front panel the statement "keep outof reach of children. Only in cases where the likelihood of contact with children during distribution,marketing, storage, or use is demonstrated by the applicant to be extremely remote, or if the nature of thepesticide is such that it is approved for use on infants or small children, may the Administrator waive thisrequirement.Further information on these criteria and labeling requirements is published in the Code of FederalRegulations (40 CFR 156.10).Source: signal words on pesticide labels (refers only to acute toxicity not long termeffects)Signal Word Toxicity Approximate amount needed to kill the average personDanger (Category 1) Highly toxic A taste to teaspoonWarning (Category II) Moderately toxic A teaspoon to a tablespoonCaution (Category III and IV) Slightly toxic An ounce to more than a pint • To obtain information on such things as evaluation of cancer risk, one must determine the ingredients in the product and look up information under the chemical name. Appendix D gives an explanation of the EPA cancer risk ratings and Appendix E gives examples of an evaluation of the cancer risk classification given by the Program on Breast Cancer and Environmental Risk Factors (BCERF) database on Turf Pesticides and Cancer Risk Data Base for some of the chemicals contained in two of the products listed on the City Listing; Manage and Kleen-up. For more information, see • Public Works Staff has indicated that they have significantly reduced the use of chemical pesticides since the REAC review started and they report that attempts are being made to use the least toxic chemicals. However, while limiting their use, the city continues to use some chemicals that have been classified as Category I and II, and a few others that are in the Category III and IV as to acute toxicity, but have been classified as “likely carcinogens” or for which sufficient information is not available on long term effects. • Public Works Staff indicates that they have fully adopted Integrated Pest Management (IPM). • Integrated Pest Management (IPM) definition. As defined in a report on school compliance with the Maryland IPM-In School legislation Integrated Pest Management8/14/2007 9
  10. 10. (IPM) is a pest management system of prevention, monitoring and control that eliminates or mitigates economic and health damage caused by pests while minimizing the use of pesticides and their associated health risks. IPM does this through a combination of practices such as site or pest inspections, pest population monitoring, and evaluating the need for pest control. Pest control methods include sanitation, structural repairs, mechanical and living biological controls, other non-chemical methods. As defined in the “Maryland IPM in Schools Legislation”, only when nontoxic options are exhausted or shown to be unreasonable, may the use of the use of the least toxic chemical pesticides be considered. • While the Public Works Staff are following Best Practice guidelines for application and use of pesticides as required by law and directed in industry manuals, REAC was not made aware that Greenbelt has a written statement concerning adoption of and definition of IPM implementation in Greenbelt. • Integrated Pest Management suffers from not being specifically defined and implementation can range from infrequent use of chemical pesticides as a last resort to more frequent pesticide use with much less caution. This issue was recently noted with reference to the study of compliance with Maryland In-School Pesticide law that directs schools to use IPM. As defined in that legislation, pesticides should only be after all other alternatives had been tried. • It is not clear that the understanding of IPM adopted by the City of Greenbelt is that indicated in the Maryland School law that requires that pesticides be used only when other alternatives have been tried and found not to be effective. • The city contracts for a substantial portion of lawn care. The city currently has two contracts with TruGreen (formerly known as ChemLawn). According to Public Works Staff, the city does not have pesticide use in the lawn care contract. When pesticides are needed in turf areas, the City does the application. However, Trugreen is allowed to use a glyphosate product (like Roundup) to spot spray weeds in the landscape contract (median landscaping on Mandan, Hanover, Cherrywood and Breezewood). Trugreen uses Manage for control of nutsedge- as Public Works Staff note that it cannot be controlled by other means such as hand weeding. It should be noted that Manage contains Oryzalin (EPA number 72167-15-74477) as an active ingredient and that this product has been deemed by EPA as likely to be a carcinogenic to humans in the 1999 USEPA Cancer Risk Category. • Greenbelt is a recognized leader in city beautification, promotion of native plants and other positive landscaping practices. Largely due to resource restraints and perceived levels of citizen expectations for aesthetics of land care, the Public Works Staff has indicated that the elimination of chemical pesticides use would create problems for the city as described in their “Pesticide Summary.”8/14/2007 10
  11. 11. 2.2.3 Pesticide Use by Residents and Businesses of GreenbeltAs the City Summary Report prepared by Public Works Staff demonstrates, City use of pesticides islimited, and is being reduced. However, use by citizens and businesses for lawn control in allprobability is a greater problem in terms of health risks and environmental degradation. At thistime, REAC has limited information on pesticide use by private citizens, GHI, condominiums andapartments, businesses and other governmental entities in and around Greenbelt. We note, however, that over the past year, GHI has made notable efforts in environmentalstewardship through hiring an environmental land care manager, through efforts of the WoodlandsCommittee, and the newly formed Sustainability Committee in fostering planting of Native Plantsand moving toward more sustainable practices of land care. GHI has recently sponsored purchaseand installing of rain barrels and has prepared a brochure on rain gardens sent to cooperativemembers.2.3 Step Three: Reframe the Problem to Help Decide What REAC Needs to Do• The material above documents the recognized health hazards to humans and wildlife of pesticide use. It also documents the Cities’ expressed adherence to IPM, and also their perceived need to continue limited use of certain chemical pesticides for aesthetic, plant health, safety and resource reasons. Given this knowledge, what is the best recommendation for REAC to make with regard to the City use of pesticides?• The prevalence of pesticide use by private residents and businesses is unknown to REAC. Given that residents and businesses cover a larger area than that covered by the City Staff, and pesticide use may well be more prevalent and uninformed among residents than by the City, it is clear that resident and business pesticide usage could well be a large threat to health and environment. The question is what needs to be done in this regard?• Can a third way be found that will address the aesthetic, health, safety and resource concerns of the City as well as the health and safety concerns raised by citizens and environmental groups?2.4 Step Four: Assess Alternatives---How Have Other Communities Addressed the Issues? What Are the Possible Alternatives?Greenbelt is not unique in struggling with this issue. In this section, we include information on 4topics that discuss alternative ways of approaching the issues. • Examples of what has been done in Canada on the pesticide issue • Examples from two US municipalities (Marin County CA; and Marblehead MA) • The Maryland IPM In School Legislation8/14/2007 11
  12. 12. • Organic Pest Management (OPM) and the Organic Land Care movement2.4.1 Examples from Canada: Bans, Phase Outs, and Public Education • Bans and Phase Outs. Within Canada, as of 2006, about 70 municipalities, covering about two-thirds of the population, have passed by-laws prohibiting the use of pesticides for cosmetic reasons within their communities. These include major cities such as Toronto, London and Montreal, as well as smaller jurisdictions such Hudson and, Port Mooney. An example of such a by-law (Toronto) is presented in Appendix F. These by-laws have been challenged in the courts in Canada by the pesticide industry. TruGreen-Chemlawn was a major sponsor of these challenges. Recently Canadas top court upheld Torontos pesticide ban by refusing to hear an appeal brought by pesticide industry. Torontos City Council passed a by-law in 2003 outlawing cosmetic pesticide use on lawns and gardens. Much earlier the Canadian courts in a case involving the town of Hudson ruled: “it is not necessary for municipalities to prove or decide that it has proven the exact health effects of pesticides. That there is cause for concern and that it is considered prudent to reduce pesticide exposure is sufficient to pass a by-law controlling pesticides in the community.” • These by-laws do not outlaw all pesticide use, but have clearly defined exceptions to the ban. • Toronto and other municipalities have usually taken an approach of phasing in the prohibitions over time and combined the ordinance with educational work. In the case of Toronto, polling of residents found that most residents did not use pesticides, however enough used lawn and garden pesticides that the effects were measurable in the urban streams in the spring and summer. Toronto found that a large majority of even those residents currently using pesticides were in favor of the ban. The by-laws provided the impetus to actually change the behavioral norms for accepted and desirable landscaping behavior. • In 2004, a best practice review was done to assess the effectiveness of the by-laws and educational campaigns in pesticide reduction as measured by surveys and sales of pesticides. The study included 62 communities, and an in-depth study of results in 9 communities, including 3 in the United States and 2 in Europe. The remainder was in Canada. The study concluded that: Only those communities that passed a by- law and supported it with education or made a community agreement were successful in reducing the use of pesticides by a high degree (51-90%) (see summary table below). Education and outreach programs alone, while more popular than by-laws, are far less effective. We could find none that have achieved more than a low reduction (10- 24%) in pesticide use to date. (The Impact of By-Laws and Public Education Programs on Reducing the Cosmetic/Non-Essential, Residential Use of Pesticides: A Best Practice Review. Kassirer Jay, Koswan, and Wolnick Chris. Jointly prepared by the Canadian Centre for Pollution Prevention and Cullbridge Marketing and Communications, March 2004).8/14/2007 12
  13. 13. They also found that controversy itself resulted in reduced use. For example, the publicity around the Hudson legal challenge led to large reductions in pesticide use, prior to the favorable court decision. The Executive summary is included in appendix G. The complete report can be found at: Mandating and Defining Integrated Pest Management (IPM)- --Maryland IPM In-Schools LegislationIn 1998 and 1999, the Maryland State Legislature passed legislation that mandated that schools inMaryland follow and an IPM program and that “pesticides are only to be considered as an optionwhen non-toxic options are unreasonable or have been exhausted, in order to a) minimize the use ofpesticides and b) minimize the risk to human health and the environment associated with pesticideapplications.” The law also mandates including potential adverse health effects from exposure to thepesticides in the notices provided to parents/guardians and employees prior to applications and afteremergency applications of pesticides.According to the Maryland Pesticide Network report, Are We Passing the Grade? Assessing MD Schools’Compliance with IPM-In-Schools Law, published in 2004) implementation has been mixed and confusedby a manual that did not track well to the legislation especially the definition of IPM in the8/14/2007 13
  14. 14. legislation. Specifically they noted that schools were not properly instructed to exhaust all otheralternatives before using pesticides and to enact the strict notification provisions. However, theynote that some school systems such as Ann Arundal and Montgomery are examples of successfulimplementation. As described in Safer Schools, a National Report, published in April 2003: Richard Stack, IPM supervisor for Montgomery County schools, coordinates one of the nation’s longest running school IPM programs...He believes that “pesticides are 99% unnecessary.” The IPM crew for these schools removes hornet nests manually, catches rodents in traps instead of relying on pesticides, and uses vacuum cleaners to eliminate small insect pests. School building and cafeteria staff receive annual training regarding the IPM-in- Schools program, and each school is monitored at least twice monthly for pest issues and IPM compliance, a process involving intensive inspection of food service areas, trash rooms, loading docks, and interviews with building services managers. The Montgomery schools program has succeeded largely because of preventive measures taken by the schools, including sanitation, heat treatment, sand blasting, biological management, and pest exclusion. The schools have altered storage practices, storage shelving designs, and food inspection practices in order to prevent pests on school grounds and in school buildings.(As presented in: Are We Passing the Grade? Assessing MD Schools’ Compliance with IPM-In-Schools Law, September 2004)The report notes that in addition to adherence to the legal instructions with regard to IPM“Education in the form of workshops, training sessions, and written materials is an essentialcomponent of an IPM program for everyone from administrators, teachers, maintenance, personnel,cafeteria staff and nurses to parents and students. Regular monitoring, record keeping, andevaluation are also necessary to guarantee a successful IPM.”2.4.3 Other Innovative US OrdinancesWithin the United States, there are fewer communities that have adopted laws such as Canada;however there are a number of jurisdictions that have passed pesticide legislation. We note twobelow. • Marin County California, Integrated Pest Management (IPM) legislation passed in 1998 includes specific goals for reduction in pesticide use from 1997 (by 75 percent by the year 2004) and also not using pesticides unless other alternatives are tried. • A more recent example (2005), is that of a small town in Massachusetts-- Marblehead–a town in which the Department of Health has mandated Organic Pest Management (OPM) for city property. A copy of their ordinance is included in Appendix H. This legislation is notable in that it embraces a positive alternative, rather than simply a ban as most of the Canadian legislation does.8/14/2007 14
  15. 15. 2.4.4 The Organic Pest Management and the Organic Land Care Movement in LandscapingAs defined in the Marblehead legislation:Organic Pest Management is a problem-solving strategy that prioritizes a natural, organicapproach to turf grass and landscape management without the use of toxic pesticides. It mandatesthe use of natural, organic cultural practices that promote healthy soil and plant life as a preventativemeasure against the onset of turf and landscape pest problems. Essential OPM practices include, but are not limited to: • regular soil testing; • addition of approved soil amendments as necessitated by soil test results, following, but not limited to, the recommendations of NOFA/Mass (Northeast Organic Farmers’ Association/Mass) and/or the Organic Material Review Institute of Eugene, OR; • selection of plantings using criteria of hardiness; suitability to native conditions; drought, disease and pest-resistance; and ease of maintenance; • modification of outdoor management practices to comply with organic horticultural science, including scouting, monitoring, watering, mowing, pruning, proper spacing, and mulching; • the use of physical controls, including hand-weeding and over-seeding; • the use of biological controls, including the introduction of natural predators, and enhancement of the environment of a pest’s natural enemies; • through observation, determining the most effective treatment time, based on pest biology and other variables, such as weather and local conditions; and eliminating pest habitats and conditions supportive of pest population increases.Organic Land Care. Recently in the United States and Canada, there have been efforts to applyorganic farming principles and standards to urban and suburban land care and management. TheNortheast Organic Farming Association (NOFA) and SOUL (Society of Organic Urban Land Care)have developed organic land care standards and also have developed educational and certificationprograms for land care professionals. They noted that the landscape industry is undergoing rapidchange as it responds to a growing demand for organic practices.• The Northeast Organic Farming Association Organic Land Care Committee for Connecticut and Massachusetts has prepared a set of standards for organic land care. REAC has a copy of these standards. They have also prepared a Citizens Guide that can be downloaded and they offer periodic courses that can result in certification for landscape professionals. They also maintain a listing of certified land care professionals on their web site and there are two listings from Maryland on the site 15
  16. 16. • Within their Citizens Guide they note: “The guiding principle of organic land care is ecological stewardship.’ They note: The watchword, as in the ancient medical tradition, is “First, do no harm.” This applies to many aspects of the health of the land and the people living on it. One of the most harmful practices to be avoided is the use of synthetic chemicals like pesticides and fertilizers. Important objectives of organic land care include: Working with natural systems to enhance biological cycles rather than seeking to dominate them; Maintaining and improving the long-term health of soils; Avoiding pollution when creating or caring for landscapes (NOFA, Citizens Guide to Organic Land Care 2004).• The CT-Mass NOFA Standards for Organic Land Care cover all aspects of land care, including: site analysis, soil health, fertilizers and soil amendments, planting and plant care, lawn and lawn alternatives, invasive plants, weeds, mulches, pest management, wildlife management, and disease control.• For each of these areas, the standards include an overview and management practices that are designated as preferred, allowed, or prohibited. Preferred practices and materials are those considered to be ecologically appropriate and in accordance with the goals of organic land care. Allowed practices and materials are acceptable when needed but should be reduced in favor of the preferred alternatives. Prohibited practices and materials are not acceptable in organic land care.• According to the SOUL website: “Organic land care practices go beyond Integrated Pest Management (IPM), beyond the use of so-called organic fertilizers and pesticides. They acknowledge the concept of intrinsic health, and seek to create environments that cater to the well-being of all their inhabitants. Organic land care professionals know that they are but stewards of the land, and can at best hope to work WITH nature, never to dominate it.”• SOUL Certified Organic Land Care Professionals are certified to have the knowledge and experience to provide Organic Land Care according to the SOUL Organic Land Care Standard. The SOUL Organic Land Care Standard was developed to define the practice of Organic Land Care for the public and for professionals in the industry. This standard clarifies the term "organic", and is intended to protect the public from misleading claims and practices.• In addition to the NOFA courses, Gaia College offers on-line programs in organic land management. More information can be obtained at the site below.• In addition, The National Coalition for Pesticide-Free Lawns periodically offers an on- line/telephone lunch time course entitled-- Organic Land Care Basic Training for Municipal Officials and Transitioning Landscapers. This three-part teleconference explains the Simple Steps to beginning an organic turf program and will cover the basic concepts, methods, and materials needed to get started. The training is geared toward school or park and recreation officials, however landscapers interested in transitioning are encouraged to attend (see appendix I) for more information.8/14/2007 16
  17. 17. 3. RECOMMENDATIONS3.1 Step Five: Determine the Course of Action and RecommendationsStep five involves taking all the information collected thus far to determine what needs to be done inthe specific issues before the working group? Is there a need to change or modify the behaviors thatwere the cause of the initial concern? What is the best way to do this? What does the weight ofevidence lead to in terms of a course of action?Thanks to the dedication of City Staff and high levels of citizen interest, REAC has concluded thatGreenbelt is in a position to be an innovative leader in Maryland in the efforts to promote the healthof its citizens and the Chesapeake Bay Watershed by endorsing and promoting best practice landcare stewardship throughout Greenbelt. We urge the City Council to do so in as many ways aspossible.3.2 Specific Recommendations to CouncilThe following are 12 concrete steps, some with performance goals, which REAC urges the City ofGreenbelt to act upon in a timely manner. These recommendations have grown out of our two-yearreview of pesticide use and its alternatives. REAC recommends that: Adoption of Organic Land Care Standards and Organic Pest Management (OPM) for Care of Public Lands and Phasing out of chemical pesticides by 2010 1. City Council set a goal for Greenbelt of meeting the Northeast Organic Farming Association Standards for Organic Land Care and adopting a program of Organic Pest Management (OPM) for all public lands of Greenbelt by January 2010. A copy of these standards has been provided to city staff. 2. City Council set a goal of phasing out the cosmetic use of chemical pesticides on public lands by 2010 and providing City staff with adequate resources to do so. By cosmetic use is meant any use other than the direct protection of the public and environmental health. Organic Land Care and Pesticide Use Monitoring Group 3. City Council instruct REAC to establish a citizen Organic Land Care and Pesticide Use Working and Monitoring Group that will be tasked with supporting and monitoring the implementation of Organic Land Care practices within the city. Every two years this group would review the City’s progress in phasing out the cosmetic use of pesticides by the City and substitution of Organic Pest Management and Organic Land Care.8/14/2007 17
  18. 18. Formal Written Policies and Procedures for Organic Land Care for City Staff and Contractors 4. City staff develop formal written policy and procedures with regard to pesticide use by Public Works staff that is consistent with goals noted above of meeting Organic Land Care and Organic Pest Management standards and the “pesticide as the last resort” guideline as defined in the Maryland Integrated Pest Management in Schools legislation in its’ implementation of IPM. 5. The City require best Organic Pest Management and Organic Land Care practices among its contractors, and should include clauses in contracts requiring use of Organic Pest Management and Organic Land Care. The City should favor local businesses whenever possible. Citizen Right to Know 6. City staff be required to report to the public on a yearly basis the brand names, listed ingredients, EPA ratings, planned locations, and amount and frequency of use of any pesticides applied to public lands within Greenbelt by the city staff or city contractors, and that this be publicized in a widely read publication, such as the News Review, well ahead of dates of application.City Staff Training and Professional Development 7. Council provide funding for adequate training and professional development in Organic Land Care methods for city staff such as the organic land care certification programs now offered by the Northeast Organic Farming Association (NPFA), Society for Organic Urban Land Care (SOUL), and other groups.Partnerships with Other Government Entities, Local Businesses, and Citizen Groups 8. The city of Greenbelt partner wherever possible with: federal, state, other local government entities, national and local environmental and watershed groups; and other interested civic groups in obtaining funding, technical support, and volunteers to help achieve the goal of Organic Land Care for Greenbelt by 2010.A Comprehensive Study of All of Greenbelt’s Impact--with Metrics and assessment of whatMust be Done to Reduce Pollution and Restore Health of the Chesapeake Bay. 9. REAC recommends that the City seek funding and/or volunteers to conduct comprehensive study designed to assess impact from Greenbelt upon the Chesapeake Bay Watershed, and develop specific goals, metrics, and practices that will be necessary to reduce the on-going environmental degradation. As noted in the body of this report, The Chesapeake Bay has been described as a “system in crisis,” and on a per acre basis the urban areas have been estimated to contribute 7 times the pollution into the Bay as rural areas. 10. The study should also address the impact of land care practices and pesticide use by private citizens and businesses within Greenbelt. REAC was able to find little information about the extent of pesticide and chemical fertilizer use by residents and businesses. As we proceeded, we became convinced that addressing citizen use on private property must be a significant part of any effort to reduce usage. The study might also access public support for8/14/2007 18
  19. 19. policies or legislation that would prohibit pesticide use for cosmetic purposes. The city should also seek counsel concerning the legality of legislation such as the Canadian By-laws against cosmetic use of pesticides within Maryland. Public Outreach and Education Campaign 11. The City and partners engage in a strong public education campaign designed to inform residents of Bay friendly and Organic Land Care, and to provide interested citizens with knowledge of alternatives to pesticide use. Outreach and education tools include: household brochures, workshops, Greenbelt Recreation Department courses, and experimental community demonstration gardens. Appreciation, Encouragement, and Rewards for City Staff 12. City staff be given appreciation, encouragement, and rewards for their efforts to transition the city to Organic land Care and help to restore the Chesapeake Bay Watershed. Thanks to the efforts of dedicated city staff, Greenbelt is known for its beautiful gardens, and hopefully will soon be known as a leader and innovator in the area of Organic Land Care.3.3 Step Six: Monitor and Follow UpNo matter what action is taken, it is critical to monitor that activity over time to identify expectedand unexpected results. All of the recommendations noted above should be monitored andfollow-up should be incorporated into the actions.8/14/2007 19
  20. 20. Appendix A---Summary Report by Greenbelt Public WorksStaff PESTICIDE SUMMARY Pesticides are not used routinely on the majority of City-managed property and there hasbeen a significant reduction in the variety, toxicity, and amount of pesticides used by City crewsover the last 10 years. For example: • Less than 10% (estimate) of the 450 acres of developed parkland and landscape areas are treated with pesticides annually. • Less than 1% (estimate) of the 7,300 street trees maintained by city crews are treated with pesticides annually. • Less than 5% (estimate) of the 27 miles of rights of way are treated with pesticides annually. • Less than 25% (estimate) of the 70 acres of turf/ballfields are treated with pesticides annually. This year because of a severe grub infestation 75% of fields were treated. At Schrom Hills Park alone, we estimate over 50% of the turf was killed. When pesticides are used, they are part of an integrated program of controls, known as“Integrated Pest Management,” which encourages use of non-chemical approaches - such asphysical, mechanical, and biological – over chemical. The City horticulture staff is veryfamiliar with the theories, practices and processes of IPM which have been used by the City ofGreenbelt for many years. Management strategies of IPM will vary from one situation toanother, location to location, and year to year, based on changes in pest populations. IPMfocuses on developing an understanding of and an ability to monitor the grounds ecosystem, andaddresses topics such as weed and insect identification, pest monitoring, and how to protectpests’ natural enemies. The following details provide an overview of general pesticideapplication practices (following IPM) for those sites where pesticides are used: • Pesticides are applied by or under close supervision of a certified pesticide applicator. (The City currently has four Certified Pesticide Applicators and an additional four Registered Pesticide Applicators. The State of MD trains, tests and registers Certified Pesticide Applicators. Registered Pesticide Applicators are trained and tested in-house by Certified Pesticide Applicators and are registered with the State. The Registered Pesticide Applicators are supervised by Certified Pesticide Applicators.) • Pesticides are only applied when weather conditions permit. • Low-toxicity pesticides are used. • Pesticide applicators receive annual re-certification training and additional integrated pest management training. • Pesticide applications are accompanied by public notification (signs). • Pesticide inventories and pesticide application records are kept. The City primarily purchases Category III pesticides in an effort to use the least toxic optionfor each control issue. To further reduce pesticide use, the horticultural staff now uses a largevolume of organic controls (nematodes, beneficial fungal and bacterial products, mulching in8/14/2007 20
  21. 21. lieu of pre-emergent herbicides) and is evaluating ways to expand uses of these controls.(Pesticides have not been used in City playgrounds since Spring 2005. Weeds have beencontrolled through heavy mulching – and changing of mulch when weeds do appear.) Bill Phelan, Assistant Director of Public Works, authorizes both the purchasing of allpesticides and the application of all pesticides by the horticultural staff. A chart is attacheddetailing all pesticides used by the City.Pesticide Free Cities There are a number of cities in Europe and Canada and a few cities in the United States(primarily in the northwest) that are “pesticide free”. However, after researching the cities in theUS, they have not totally eliminated the use of pesticide but have only designated certain parksand playgrounds as “pesticide free.” There are a number of things that are still treated in thepesticide free parks when needed: • Infestation of noxious weeds that cannot be mowed or controlled by other means. • Sprays to control wasp and hornet nests around restrooms and shelters. • Treatment of stagnant water to control mosquito larva. • Treatment of over population of pests such as grubs, cutworms, ticks and bagworms when alternate means have not controlled the problem and further infestation will cause significant damage. If pesticide use was eliminated in city-maintained parks, playgrounds, ballfields, landscapebeds, it would be a major challenge for us to keep the same level of citizen satisfaction in theappearance of the parks with these new policies. Even with using best practices and alternativemeans of control, we feel labor cost would need to increase significantly to keep up withweeding landscape beds and replacement of diseased plant materials, additional equipment willneed to be purchased, and some landscape areas will need to be redesigned. It would alsorequire additional dollars to be spent on alternative product purchases. As an example, treatinggrubs in turf with nematodes is several times more expensive than treatment with the productscurrently being used and has a much greater chance of failing to control the grubs. There aresignificant concerns that our inability to use pesticides may reduce the quality of our parks andcould threaten the long-term health of the City’s parks, trees, shrubs and flowers.8/14/2007 21
  22. 22. PLAYGROUNDS Playgrounds Equip. Maint. Landscaping Mowing 1 court Crescent City City Contract 2 court Northway City City Contract 3 court Gardenway City City Contract 14 court Laurel Hill City City Contract 54 court Crescent City City Contract Community Center City City Contract Greenbriar Park City City Contract Ivy & Lastner City City Contract SHL Comm. Ctr. City Contract Contract St. Hugh’s City City Contract 1 court Southway City City Contract 2 court Southway City City Contract 5 court Gardenway City City Contract 39 court Ridge City City Contract 73 court Ridge City City Contract Buddy Attick Park City City City Fayette Place City City Contract GreenSpring Park City Contract Contract Plateau & Ridge City City Contract Schrom Hills Park City City City Westway City City Contract 2 court Laurel Hill City GHI GHI 4 court Plateau City GHI GHI 8 court Southway City GHI GHI 38 court Ridge City GHI GHI 2 court Research City GHI GHI 7 court Southway City GHI GHI 12 court Hillside City GHI GHI 44 court Ridge City GHI GHI Greenwood Village City Greenwood Greenwood 7128 Ora Glen Court City Windsor Green Windsor Green 7251 South Ora Ct. City Windsor Green Windsor Green 7854 Jacobs Drive City Windsor Green Windsor Green 7230 Mandan Road City Windsor Green Windsor Green 7356 Frankfort Dr. City Windsor Green Windsor Green 8301 Canning Terr. City Windsor Green Windsor Green The City has not used chemicals on playgrounds since Spring of 2005. Weeds have beencontrolled by heavy application of engineered wood fibers – or removal of old surfacing andweeds and replacement with new surfacing when weeds are too numerous to hand pull.However, specific problems could develop in the future and it may be necessary to treatplaygrounds with chemicals; i.e. insect infestation of trees.8/14/2007 22
  23. 23. BALLFIELDS & LANDSCAPE AREAS Landscaping/ Maintenance MowingBallfieldsBraden Field City CityNorthway Field City CitySchrom Hills City CityMandan Road City CityMcDonald Field City CityLandscape BedsWindsor Green City & Contract ContractSpringhill Lake City & Contract ContractGreenbriar City & Contract ContractGreenbrook Estates City & Contract ContractSchrom Hills City CityBuddy Attick Park City CityGlen Oaks City & Contract ContractHanover – Bus. Side City & Contract Contract Includes 2 circlesSouthway City Contract Includes 193@Sway bedsUnderpassesHillside Underpass City ContractGardenway City ContractUnderpassLibrary Underpass City ContractRoosevelt Center City ContractUnderpassFacilitiesCommunity Center City ContractYouth Center City ContractPolice Facility City ContractPublic Works City ContractCity Office Bldg. City ContractMuseum City ContractSpringhill Lake Rec City & Contract ContractBuddy Attick Park City CitySchrom Hills City City8/14/2007 23
  24. 24. PESTICIDES USED BY THE CITYAll pesticides are grouped by the EPA into one of four categories based on acute toxicity. Category Iis the most toxic and category IV the least toxic. Category III and IV- Slightly Toxic to Relatively Non-ToxicChemical Current Use Option to Chemical *Frequency Size of Type of Areaand of Use Treatment Area TreatedSignalWordManage Selective control No effective treatment Limited Less than 1,000 Landscape bedsCaution of nutsedge available sf.Dipel Pro Pest control on Insecticidal soaps – 50% Rare 10,000 sf. – Street Trees(Organic) ornamentals efficiency 25,000 sf.Caution Beneficial insects/ remove & replace plantsMerit Pest control in Beneficial nematodes in Turf- rare >100,000 sq ft of Ballfields,Caution turf and turf- not always Ornamentals- turf treated this Azaleas, German ornamentals effective. Limited year due to heavy Irises, some Replace ornamentals infestations in daylilies with resistant varieties ballfield turfMach2 Pest control in Beneficial nematodes in One time >100,000 sq ft BallfieldsCaution turf turf- not always treated this year effective. due to heavy infestations in ballfield turfBayleton Fungal control Remove and replace One Time 1,000 sf. – 9,999 Hawthorne treesCaution on ornamentals trees, shrubs & flowers sf. for severe Quince rustPrincep Pre-emergent Hand weeding Rare Less than 1,000 Tree & shrubCaution vegetation Corn gluten- sf. beds where control tried/ineffective weeds are out of controlAcclaim Post emergent Hand remove (Used for One Time 1,000 sf. – 9,999 BallfieldsCaution grass control crabgrass and sf. goosegrass)Snapshot Pre-emergent Hand weeding Rare 1,000 sf. – 9,999 Landscape bedsCaution vegetation Corn gluten- sf. where weeds are control tried/ineffective out of controlRoundup Non-selective Torch type machine n/a Not currently used Landscape beds,Pro vegetation (Propane Burner), because Kleenup Sidewalk crack control horticultural vinegar- Pro is same weeds, Post Emergent neither kills the root product at ½ the Infields of cost ballfields* Frequency of Use:Limited - Specific areas treated as needed approximately 1-2 times annually.Rare – Specific areas treated as needed less than one time per year.One Time – Specific weed problems treated one time within past 20 years. At some point specific problem may reappear and another treatment may berequired.8/14/2007 24
  25. 25. Category II- Moderately Toxic (The three products used in this category have oral and dermal toxicities in the category III &IV range, but eye contact with the straight chemical will cause substantial damage)Chemical Current Use Option to Chemical *Frequency Size of Type of Areaand of Use Treatment Area TreatedSignalWordFinale Post emergent None (Only used for Rare Less than 1,000 Landscape bedsWarning- vegetation horsetails) This weed sf.eye control has a severe root systemcontact and cannot be handcauses pulled.)substantialdamageDimension Pre-emergent Hand remove One Time 50,000 sf. Used once atWarning - turf control Mandan Fieldeyecontactcausessubstantialdamage**Kleen- Non-selective Torch type machine Limited > 100,000 sf. Landscape beds,up Pro vegetation (Propane Burner), Sidewalk crackWarning control horticultural vinegar- weeds, Post Emergent neither kill the root Infields of ballfields** Kleen-up is a product with the same chemical composition as Round-Up Pro, but it contains adifferent surfactant. Our best guess is that the surfactant in Kleenup is different and causes eye irritation,which would create a need for a Warning label.8/14/2007 25
  26. 26. Category I- Highly Toxic (The two products used in this category have oral and dermal toxicities in the category III &IV range, but eye contact with the straight chemical will cause irreversible damage.)Chemical Current Use Option to Chemical *Frequency Size of Type of Areaand Signal of Use Treatment TreatedWord AreaConfront Selective Hand pull them- Limited 50,000 sf. – Turf andDanger- control of Corn Gluten- 100,000 sf. Ballfieldseye contact broadleaf expensive and notcan cause weeds in turf reliably effectiveirreversibledamage.Garlon 3a Used to treat Hand pull/backhoe- limited Less than 1000 LandscapeDanger- cut stumps of difficult and time sf Beds to killeye contact weed trees or consuming large weedcan cause shrubs trees primarilyirreversible by painting cutdamage. stumps*Frequency of Use:Limited - Specific areas treated as needed approximately 1-2 times annually.Rare – Specific areas treated as needed less than one time per year.One Time – Specific weed problems treated one time within past 20 years. At some point specific problem mayreappear and another treatment may be required.8/14/2007 26
  27. 27. Appendix B--ONTARIO COLLEGE OF PHYSICIANS SUMMARYReport8/14/2007 27
  28. 28. 8/14/2007 28
  29. 29. 8/14/2007 29
  30. 30. Appendix C—SAMPLE PESTICIDE LABEL8/14/2007 30
  31. 31. Appendix D---EPA CRITERIA FOR EVALUATIONOF CHEMICAL CARCINOGENICITYSource: EPA evaluates chemical carcinogenicity using data from many types of studies. • Most of the cancer risk information currently available is in the form of scientific results from studies of laboratory animals, such as rats or mice. • Other types of laboratory studies done at a smaller scale, such as individual cells, provide information about a chemicals ability to damage DNA or promote tumor growth. • Results from studies of groups of people exposed to certain chemicals, such as in the workplace or a community, may provide additional valuable information about a chemicals potential to cause cancer.For many chemicals, however, no human data are available, so we must rely on data from laboratoryand animal studies. Information on the species of laboratory animal tested, and the tumor typesobserved, provides some information about the extent to which the chemical may be carcinogenic.This information is just part of the total information EPA uses to estimate cancer risk. Otherinformation from human studies and laboratory analyses is not currently available from EPA for usein the Turf Pesticides and Cancer Risk database.EPAs cancer risk classification systems and categoriesIn classifying the cancer risk of a particular chemical, EPA uses a combination of all of these typesof evidence to arrive at a cancer risk category. EPAs cancer risk assessment methods have changedover the years to accommodate new scientific understanding. As a result, the four EPA cancer riskclassification systems cannot be combined or used interchangeably due to the different methodsused.Pesticide productsCancer risk categories do not apply directly to pesticide products. Rather, cancer risk informationpertaining to the products active ingredient(s) can be used in combination with other information toestimate potential risk. • Estimating the cancer-causing potential of a specific pesticide product involves many factors, such as the amount of active ingredient contained in the product, the application methods and rates used, proper use of personal protective equipment, and frequency and degree of exposure to the pesticide over time. • Current federal pesticide labeling laws require pesticide manufacturers to include only acute (short-term), and not chronic (long-term) health risk information on pesticide labels. Therefore, product-specific cancer risk information is not available. • Some states, such as California and Massachusetts, require that pesticides sold in those states carry labels specifying whether or not the products active ingredients have been identified as health hazards, such as carcinogens, reproductive toxins, etc. Other states may include this information on their labels as well.8/14/2007 31
  32. 32. Using RED documents and other pesticide review informationRe-registration Eligibility Decision, or RED, documents are risk assessment reports done by EPAto determine whether or not to continue the registration of older pesticide products. Olderpesticides (those first registered before 1984) must be re-evaluated by EPA to ensure that they meetcurrent health and safety standards. RED documents are publicly available and are included process.This process, which will take effect October 10, 2006, was established to ensure that all pesticidesdistributed and sold in the U.S. (not just older pesticides or those used on food crops) will be re-evaluated on a periodic basis to ensure they meet current health and safety standards. For moreinformation, see Pesticide Registration. As pesticides are reviewed as part of this process, riskinformation will be added to the Turf Pesticides and Cancer Risk Database as it becomes available.2005 USEPA Cancer Risk ClassificationThe following descriptors from the 2005 Guidelines for Carcinogen Risk Assessment can be used as anintroduction to the weight of evidence narrative in the cancer risk assessment. The examples presented in thediscussion of the descriptors are illustrative. The examples are neither a checklist nor a limitation for thedescriptor. The complete weight of evidence narrative, rather than the descriptor alone, provides theconclusions and the basis for them.Carcinogenic to HumansThis descriptor indicates strong evidence of human carcinogenicity. It covers different combinations ofevidence. • This descriptor is appropriate when there is convincing epidemiologic evidence of a causal association between human exposure and cancer. • Exceptionally, this descriptor may be equally appropriate with a lesser weight of epidemiologic evidence that is strengthened by other lines of evidence. It can be used when all of the following conditions are met: a. there is strong evidence of an association between human exposure and either cancer or the key precursor events of the agents mode of action but not enough for a causal association, and b. there is extensive evidence of carcinogenicity in animals, and c. the mode(s) of carcinogenic action and associated key precursor events have been identified in animals, and d. there is strong evidence that the key precursor events that precede the cancer response in animals are anticipated to occur in humans and progress to tumors, based on available biological information. In this case, the narrative includes a summary of both the experimental and epidemiologic information on mode of action and also an indication of the relative weight that each source of information carries, e.g., based on human information, based on limited human and extensive animal experiments.Likely to be Carcinogenic to HumansThis descriptor is appropriate when the weight of the evidence is adequate to demonstrate carcinogenicpotential to humans but does not reach the weight of evidence for the descriptor "Carcinogenic to Humans."Adequate evidence consistent with this descriptor covers a broad spectrum. As stated previously, the use ofthe term "likely" as a weight of evidence descriptor does not correspond to a quantifiable probability. Theexamples below are meant to represent the broad range of data combinations that are covered by thisdescriptor; they are illustrative and provide neither a checklist nor a limitation for the data that might support8/14/2007 32
  33. 33. use of this descriptor. Moreover, additional information, e.g., on mode of action, might change the choice ofdescriptor for the illustrated examples. Supporting data for this descriptor may include: • an agent demonstrating a plausible (but not definitively causal) association between human exposure and cancer, in most cases with some supporting biological, experimental evidence, though not necessarily carcinogenicity data from animal experiments; • an agent that has tested positive in animal experiments in more than one species, sex, strain, site, or exposure route, with or without evidence of carcinogenicity in humans; • a positive tumor study that raises additional biological concerns beyond that of a statistically significant result, for example, a high degree of malignancy, or an early age at onset; • a rare animal tumor response in a single experiment that is assumed to be relevant to humans; or • a positive tumor study that is strengthened by other lines of evidence, for example, either plausible (but not definitively causal) association between human exposure and cancer or evidence that the agent or an important metabolite causes events generally known to be associated with tumor formation (such as DNA reactivity or effects on cell growth control) likely to be related to the tumor response in this case.Suggestive Evidence of Carcinogenic PotentialThis descriptor is appropriate when the weight of evidence is suggestive of carcinogenicity; aconcern for potential carcinogenic effects in humans is raised, but the data are judged not sufficientfor a stronger conclusion. This descriptor covers a spectrum of evidence associated with varyinglevels of concern for carcinogenicity, ranging from a positive cancer result in the only study on anagent to a single positive cancer result in an extensive database that includes negative studies in otherspecies. Depending on the extent of the database, additional studies may or may not provide furtherinsights. Some examples include: • a small, and possibly not statistically significant, increase in tumor incidence observed in a single animal or human study that does not reach the weight of evidence for the descriptor "Likely to Be Carcinogenic to Humans." The study generally would not be contradicted by other studies of equal quality in the same population group or experimental system (see discussions of conflicting evidence and differing results, below); • a small increase in a tumor with a high background rate in that sex and strain, when there is some but insufficient evidence that the observed tumors may be due to intrinsic factors that cause background tumors and not due to the agent being assessed. (When there is a high background rate of a specific tumor in animals of a particular sex and strain, then there may be biological factors operating independently of the agent being assessed that could be responsible for the development of the observed tumors.) In this case, the reasons for determining that the tumors are not due to the agent are explained; • evidence of a positive response in a study whose power, design, or conduct limits the ability to draw a confident conclusion (but does not make the study fatally flawed), but where the carcinogenic potential is strengthened by other lines of evidence (such as structure-activity relationships); or • a statistically significant increase at one dose only, but no significant response at the other doses and no overall trend.8/14/2007 33
  34. 34. Inadequate Information to Assess Carcinogenic PotentialThis descriptor is appropriate when available data are judged inadequate for applying one of theother descriptors. Additional studies generally would be expected to provide further insights. Someexamples include: • little or no pertinent information; • conflicting evidence, that is, some studies provide evidence of carcinogenicity but other studies of equal quality in the same sex and strain are negative. Differing results, that is, positive results in some studies and negative results in one or more different experimental systems, do not constitute conflicting evidence, as the term is used here. Depending on the overall weight of evidence, differing results can be considered either suggestive evidence or likely evidence; or • negative results that are not sufficiently robust for the descriptor, "Not Likely to Be Carcinogenic to Humans."Not Likely to be Carcinogenic to HumansThis descriptor is appropriate when the available data are considered robust for deciding that there isno basis for human hazard concern. In some instances, there can be positive results in experimentalanimals when there is strong, consistent evidence that each mode of action in experimental animalsdoes not operate in humans. In other cases, there can be convincing evidence in both humans andanimals that the agent is not carcinogenic. The judgment may be based on data such as: • animal evidence that demonstrates lack of carcinogenic effect in both sexes in well-designed and well-conducted studies in at least two appropriate animal species (in the absence of other animal or human data suggesting a potential for cancer effects), • convincing and extensive experimental evidence showing that the only carcinogenic effects observed in animals are not relevant to humans, • convincing evidence that carcinogenic effects are not likely by a particular exposure route, or • convincing evidence that carcinogenic effects are not likely below a defined dose range.A descriptor of "not likely" applies only to the circumstances supported by the data. For example, anagent may be "Not Likely to Be Carcinogenic" by one route but not necessarily by another. In thosecases that have positive animal experiment(s) but the results are judged to be not relevant tohumans, the narrative discusses why the results are not relevant.Multiple DescriptorsMore than one descriptor can be used when an agents effects differ by dose or exposure route. Forexample, an agent may be "Carcinogenic to Humans" by one exposure route but "Not Likely to BeCarcinogenic" by a route by which it is not absorbed. Also, an agent could be "Likely to BeCarcinogenic" above a specified dose but "Not Likely to Be Carcinogenic" below that dose becausea key event in tumor formation does not occur below that dose.8/14/2007 34
  35. 35. Appendix E---EXAMPLES OF CANCER RISKASSESSMENTSummary report on Oryzalin (EPA number 72167-15-74477) an activeingredient in the MANAGE product (first product on the city list) Cancer Risk Information 1999USEPA Cancer Risk Category: Likely to be Carcinogenic to HumansSpecies and Tumor Types: Multiple sites (thyroid, mammary); F344 rats (M & F).NOTE: Cancer risk classifications are specific to active ingredients, not products. To arrive at anoverall health or cancer risk evaluation for a pesticide product, active ingredient cancer riskinformation should be used together with other risk and exposure information, such as USEPA RiskManagement Decision Documents (REDs, IREDs, TREDs, and others).Summary report on ingredient Sodium Acifluorfen listed underKleenUP in the data baseCancer Risk Information OtherUSEPA Cancer Risk Category: Likely to be Carcinogenic to Humans (High Doses); NotLikely to be Carcinogenic to Humans (Low Doses)Species and Tumor Types: Liver; B6C3F1 & CD-1 mice (M& F).NOTE: Cancer risk classifications are specific to active ingredients, not products. To arrive at anoverall health or cancer risk evaluation for a pesticide product, active ingredient cancer riskinformation should be used together with other risk and exposure information, such as USEPA RiskManagement Decision Documents (REDs, IREDs, TREDs, and others).8/14/2007 35
  36. 36. Appendix F---PESTICIDE BY-LAW OF THE CITYOF TORONTOPESTICIDES, USE OF§ 612-1. Definitions.§ 612-2. Restrictions.§ 612-3. Offences.[HISTORY: Adopted by the Council of the City of Toronto 2003-05-23 by By-lawNo. 456-2003.1 Amendments noted where applicable.]GENERAL REFERENCES1Editor’s Note: This by-law was passed under the authority of section 130 of the Municipal Act, 2001, S.O. 2001, ch. 25.Section 2 of this by-law states that it comes into force 2004-04-01.Property standards — See Ch. 629.§ 612-1. Definitions.As used in this chapter, the following terms shall have the meanings indicated:ENCLOSED — Closed in by a roof or ceiling and walls with an appropriate opening or openingsfor ingress or egress, which openings are equipped with doors which are kept closed except whenactually in use for egress or ingress.HEALTH HAZARD — A pest which has or is likely to have an adverse effect onthe health of any person.INFESTATION — The presence of pests in numbers or under conditions which involve animmediate or potential risk of substantial loss or damage.PEST — An animal, a plant or other organism that is injurious, noxious or troublesome, whetherdirectly or indirectly, and an injurious, noxious or troublesome condition or organic function ofan animal, a plant or other organism.PESTICIDE — Includes: A. A product, an organism or a substance that is a registered controlproduct under the federal Pest Control Products Act which is used as a means for directly orindirectly controlling, destroying, attracting or repelling a pest or for mitigating or preventing itsinjurious, noxious or troublesome effects.B. Despite Subsection A, a pesticide does not include:TORONTO MUNICIPAL CODE§ 612-2 PESTICIDES, USE OF612-2 2005 - 02 - 16(1) A product that uses pheromones to lure pests, sticky media to trap pests or “quick-kill” trapsfor vertebrate species considered pests, such as mice and rats.(2) A product that is or containsonly the following active ingredients:[Amended 2004-05-20 by By-law No. 385-2004](a) A soap;(b) A mineral oil, also called “dormant or horticultural oil”;(c) Silicon dioxide, also called “diatomaceous earth”;(d) Biological pesticides, including Bt (bacillus thuringiensis) andnematodes; [Amended 2005-02-16 by By-law No. 121-2005](e) Borax, also called “boric acid” or “boracic acid”;(f) Ferric phosphate;8/14/2007 36
  37. 37. (g) Acetic acid;(h) Pyrethrum or pyrethrins;(i) Fatty acids;(j) Sulphur; or(k) Corn gluten meal.§ 612-2. Restrictions.A. No person shall apply or cause or permit the application of pesticides within theboundaries of the City.B. The provision set out in Subsection A does not apply when pesticides are used:(1) To disinfect swimming pools, whirlpools, spas or wading pools;(2) To purify water intended for the use of humans or animals;(3) Within an enclosed building;(4) To control termites;(5) To control or destroy a health hazard;(6) To control or destroy pests which have caused infestation to property;(7) To exterminate or repel rodents;(8) As a wood preservative;TORONTO MUNICIPAL CODEPESTICIDES, USE OF § 612-3612-3 2005 - 02 - 16(9) As an insecticide bait which is enclosed by the manufacturer in a plastic ormetal container that has been made in a way that prevents or minimizes accessto the bait by humans and pets;(10) For injection into trees, stumps or wooden poles;(11) To comply with the Weed Control Act2 and the regulations made there under; or(12) As an insect repellent for personal use.§ 612-3. Offences.Any person who contravenes any provision of this chapter is guilty of an offence and,upon conviction, is liable to a fine or penalty provided for in the Provincial Offences Act.32Editor’s Note: See R.S.O. 1990, c. W.5.3Editor’s Note: This section was passed under the authority of section 425 of the Municipal Act, 2001, S.O. 2001, ch. 25, and,under section 61 of the Provincial Offences Act, R.S.O. 1990, c. P.33, a person convicted of an offence under this section isliable to a fine of not more than $5,000.8/14/2007 37
  38. 38. Appendix G---BEST PRACTICE REVIEW SUMMARY8/14/2007 38
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  41. 41. Appendix H-- TOWN OF MARBLEHEAD BOARD OF HEALTH ORGANIC PEST MANAGEMENT REGULATIONS Adopted: December 7, 2005 Effective: December 22, 2005Carl D. Goodman, Esq., ChairmanDavid B. Becker, D.M.D., M.P.H.Helaine R. HazlettWayne O. Attridge, Director of Public Health TOWN OF MARBLEHEAD BOARD OF HEALTH ORGANIC PEST MANAGEMENT REGULATIONSSECTION I – FINDINGS & PURPOSEThe Board of Health does hereby find that:All pesticides are toxic to some degree and the commonplace, widespread use of pesticides isboth a major environmental problem and a public health issue; andAll citizens, and in particular children, as well as other inhabitants of our natural environment,have a right to protection from exposure to hazardous chemicals and pesticides in particular; andA balanced and healthy ecosystem is vital to the health of the town and its citizens; and as suchis also in need of protection from exposure to hazardous chemicals and pesticides; and8/14/2007 41