REVIEW OF BYRON SHIRE INTEGRATED PEST MANAGEMENT DIRECTIONS DOCUMENT AND IPM POLICY.
Ellen White for Byron Shire Chemical Free Landcare
May 2018
Our concerns about the Policy document, based as it is on inaccuracies and assumptions in the Directions document, is that it leaves little room for the public to understand improvements or to participate in aiding those improvements.
Of greatest concern is that the consultants reject the communities Right to Know what is being used in their environment, where, and how often. The document does not give confidence that either staff or the consultants are realistically assessing the dangers of the chemicals used. This means that they will be resorted to more frequently and perhaps more carelessly than otherwise. Under these conditions, ‘Risk Assessment’ can be risky.
We believe there needs to be a process incorporated into the strategy whereby Council staff can seek information from the public on alternatives to be used in particular situations, or on particular sites. Byron Shire has many organic farmers and concerned citizens- there are many untapped skills and much knowledge within the community.
We believe that Byron Shire Council can do far better than the legislation requires and thus support its many organic farmers and set an excellent example for other authorities, farmers, and home owners who contribute to the burden of toxics in our environment.
Community Consultation for this document has been poor, particularly in the realms of alternatives to pesticides.
REGULATION
While the consultants appear satisfied with pesticide regulation in Australia, we do not share their confidence in the APVMA. (p4)
From the APVMA website: https://apvma.gov.au/node/15901
“The APVMA does not conduct laboratory tests of agvet chemicals and products—nor does it undertake product trials or field tests of chemicals for applicants. Applicants are responsible for coordinating and conducting all scientific studies required by the APVMA to satisfy the statutory criteria—as outlined in the data guidelines. APVMA regulatory scientists then scientifically assess this information before deciding the outcome of an application.”
These “assessments’ are based on the ‘active’ component and not on the whole product which includes so-called ‘inerts’ which are thought not to themselves have pesticide effects but which increase the activity of the ‘active’ component.
In 2015, the IARC classified glyphosate (by itself, not the formulated product) as 2A – probably carcinogenic to humans. The classification is based on: Limited evidence of carcinogenicity in humans and sufficient evidence of carcinogenicity in experimental. The IARC also noted concerns about glyphosate formulations having increased toxicity due to synergistic interactions. Then there is possible synergisms with other products in the environment or the home.
The Cancer Council of Australia’s position statement on pesticides notes that little research has been done on the link between pesticide exposure and cancer but that occupational exposure is likely to be the most risky. https://wiki.cancer.org.au/policy/Position_statement_-_Pesticides_and_cancer
After the IARC assessment, a political bunfight ensued with Monsanto employees orchestrating efforts to undermine the assessment and the credibility of the IARC. Glyphosate came up for reregistration in the EU in 2017 and Monsanto interference in the registration process was alarming. https://www.gmwatch.org/en/news/latest-news/17847
The IARC also issued a response to these ongoing attacks http://www.iarc.fr/en/media-centre/iarcnews/pdf/IARC_response_to_criticisms_of_the_Monographs_and_the_glyphosate_evaluation.pdf
Similarly, despite their lack of research in Australia, the APVMA issued a response in July 2017 following the corporate line. As the IPM consultants note “the APVMA rejected the findings of the IARC and reported there was insufficient evidence to support any change to their advice on the safety and use” It is noteworthy that, unlike the APVMA which uses corporate studies, the IARC uses peer reviewed research.
Other governments took more stringent measures than in Australia: lawyers Baum Hedlund Aristei Goldman provide a list of countries where glyphosate is banned or constrained. (https://www.baumhedlundlaw.com/toxic-tort-law/monsanto-roundup-lawsuit/where-is-glyphosate-banned/). Six Middle Eastern countries have also banned glyphosate products. (https://sustainablepulse.com/2017/10/13/six-middle-eastern-countries-ban-glyphosate-herbicides-over-probable-carcinogen-fears/#.WwTAzCC0bIU )
Monsanto, Dow Chemicals, Syngenta, Bayer all have a long history of political and academic corruption. At both the State and Federal levels, we have the same failure in legislation, policy, or regulation in mining, forestry, pharmaceuticals. Byron Shire can do better.
I believe it is incumbent on those working in weed control to keep well informed on developments. This is especially the case where young people are involved, either through working in the field or through contact with agricultural pesticides in public spaces.
PESTS FOR WHICH ALTERNATIVES ARE AVAILABLE
I expect the consultants mean European Wasps (Vespula germanica) (p6) rather than hornets (Vespa spp.) which don’t occur in Australia (but for which an alert warning has been issued). These are effectively killed with detergent.
Bindii : a number of alternatives are available: always before flowering – ammonium sulphate (NH4)2SO4) is one. Jerry Coleby Williams provides another – dry washed sand, sulphate of potash (K2SO4) and iron sulphate (FeSO4). Small infestation – manual removal
SITUATIONS WHICH REQUIRE FURTHER THOUGHT
Roadsides (p9,10): Asphalt plants have a waste product following pothole maintenance – it may be possible to utilise waste bitumen with a base of recycled concrete around certain posts and guard rails.
Nutgrass (p9) grows most rapidly in full sunlight when adequate nutrients are available. It becomes more serious when allowed to grow without competition from other plants and this can occur when annual weeds are removed manually or by herbicide. Nutgrass is severely restricted by shade – geofabric is useful. Jerry Coleby Williams advocates an alkaline pH and heavy mulching.
AREAS WHERE CESSATION IS YET TO BE ACHIEVED
Premier sports fields (8 of the 23 fields). Case Study 3. It is commendable that BSC has improved its horticultural practices and changed some of the pesticides used to those of lower poison ratings.
2016 Kamba M (MCPA and Dicamba)(S5 hazardous, caution) ; broad-leaved weeds
2016 Diclofop Methyl (S6); – herbicide, some grasses – does not appear to have been registered for turf
2016/2018 MSMA (monosodium methyl-arsenate; has been downgraded from S7 dangerous poison to S6- poison) – paspalum;
2016/2018 Sempra (Halosulfuron-methyl S5) – sedges (including nutgrass)
2018 Acelepryn (not requiring scheduling) – insecticide, army worm
2018 Specticle (Indeziflam S6) –pre-emergent herbicide
MSMA, an organo-arsenical undergoes environmental degradation to the more toxic inorganic arsenite by microbial communities. This will accumulate in the soil and can contaminate waterways through soil runoff. The label states that ‘it is too hazardous to be recommended for the home garden’. It is poisonous if absorbed by skin contact or swallowed.
In the US, in 2009 MSMA uses on athletic fields, parks, residential lawns, forestry, non-bearing fruit and nut trees, and citrus orchards were cancelled. Its registration in the USA now allows it to be only used on cotton, sod farms, golf courses, and highway rights-of-way, and it cannot be used in Florida except for on cotton in certain counties.
WEST BYRON SEWAGE TREATMENT PLANT CONSTRUCTED WETLANDS
(P14) I can find no mention of Parrots Feather (Myriophyllum aquaticum) in either the NSW Biosecurity Act (2015) nor in its Regulations (2017) although Eurasian Water Milfoil (Myriophyllum spicatum) is listed in the Biosecurity Act. This latter species has not been recorded in Australia thus its status is as a Weed Alert on NSW Weedwise.
Glyphosate has been used frequently in the past to control the Parrots Feather infestation, apparently with little success. Glyphosate, highly toxic to frogs, is particularly persistent in aquatic situation, with a half-life of 5 months in water but persisting in bottom sediments for at least a year in many cases (Romanowski 2011 Wetland Weeds). Romanowski points out that the wetting agents may be equally problematic.
Parrots Feather does not set seed. It thrives on high nutrient input, slow-moving water, and high light intensity. Nothing can be done about the first two but light may be manipulated. Obviously in at least one wetland cell, the reeds are not shading out the Parrot’s Feather. Are they being affected by the recurrent herbicide treatments?
Has there been any monitoring of the effect of this high pesticide use on the aquatic systems in the wetland and in Belongil Creek?
BUSH REGENERATION
Simplistic and emotional language relating to weeds has become commonplace in agriculture and Landcare. The trend over the last few decades has been to refer to the growth of non-native plants in disturbed habitats as an ‘invasion’ of natural environments. The resultant ‘war on invasives’ is underpinned with ‘scientific’ theories, scaremongering and far-reaching policies, based on highly subjective opinions of ‘good’ plants verses ‘bad’ plants.
Emotive language makes it difficult to see scientific, unbiased views on the ecological roles and impacts of exotic species. Many academics are calling for a different view of weeds and have commented on the language used to pave the way to an ‘attack on weeds’. Amongst them Dr. John Dwyer’s address at the 18th Australian Weeds Conference is an excellent outline of the issue.
The section on ‘Emerging issues and potential solutions in Byron Shire’ is highly biased and full of emotive assumptions. It is difficult to tease apart the situations on which the consultants base their conclusions. It is also clear that training in chemical-free strategies and techniques may benefit, especially within bush regeneration. In this Shire, both Bitou Bush and Lantana have had large scale reductions without pesticide use.
As stated in this document, millions of taxpayer dollars have been invested in the employment of bush regenerators using pesticides. As a Council employee stated ‘grant funds will not be available if pesticide is not used’. There are a number of contractors active in chemical-free bush regeneration in this Shire yet there expertise has been untapped. Costings should take into consideration environmental cradle-to-grave costs – environmental effects during production and transport, health effects, effects on biodiversity which are seldom monitored, etc.
For those of us who take an ecological approach to weed control rather than a War on Weeds the consultants focus on ‘invasive’ weeds, while conventional, implies that the underlying disturbance conditions which ‘weeds’ take advantage of will not be addressed. The lumping together of situations in which disturbance conditions are maintained (urban), with those in which disturbance conditions may be increasing (STP), and areas where, given proper strategies and techniques, disturbance conditions should be decreasing (bush regeneration) is inappropriate for teasing out strategies to address them.
A more sophisticated approach is required, one which accurately assesses environmental risk, and also one which recognizes the role of weeds in the landscape and uses them for regeneration. (See the use of Camphor Laurel in rainforest regeneration by the Rainforest CRC: http://rainforest-crc.jcu.edu.au/issues/ITFL_camphor.pdf )
The adverse impacts listed on p21 are ludicrous. I have been active in chem-free bush regeneration for over 25 years and have never had an injury; loss of habitat can have extremely adverse effects when large areas are aerially or ground sprayed as for Bitou Bush; damage to non-target species is less likely with manual techniques though chemical damage might not show immediately; erosion and siltation can occur with pesticide use as in the erosion caused along Wilson’s Creek with the poisoning of Coral Trees; etc etc.
The example given on P21 is interesting. McLeods Shoot bush regeneration site is a small narrow area with a good canopy including many non-native trees and the remaining pesticide use appears to be spraying of grass on the perimeter. What is hoped to be achieved? Costly without long-term effect.
PESTICIDE REDUCTION IN OTHER JURISDICTIONS
This section does not reflect the extent of pesticide reduction/elimination in other jurisdictions. PAN Europe has developed a Pesticide-Free-Towns-Network which lists additional Countries for Europe, and a map of southern Europe showing towns which ban pesticides in public spaces. Though the consultants have referenced this (http://www.pesticide-free-towns.info/policy-strategies) they have failed to report it fully referencing only 6 overseas cases. For an even fuller description see the website of Baum, Hedlund, Aristei, Goldman lawyers. https://www.baumhedlundlaw.com/toxic-tort-law/monsanto-roundup-lawsuit/where-is-glyphosate-banned/ . They say
“EU public opinion is leaning in favor of a glyphosate ban. In a 2016 poll of the five largest EU countries, over 66 percent of respondents said they favored a glyphosate ban. Over 1.3 million people signed a petition in 2017 calling for a European ban of glyphosate. That public pressure caught the attention numerous Members of European Parliament, who have cited the petition as the foundation for instituting an EU ban.
“In November of 2017, EU member states narrowly voted to relicense glyphosate for a period of five years. The vote was not without controversy; German Agriculture Minister Christian Schmidt (CSU) entered a ‘yes’ vote for his country without consulting with German Chancellor Angela Merkel (CDU) on the matter. His unilateral vote disregarded Germany’s Environment Minister, who had instructed Schmidt to abstain from voting. With Germany’s vote, the measure narrowly passed and glyphosate received a new license.
Following the scandal, six EU countries sent a letter to the European Commission, calling for an exit plan for glyphosate. France and Italy have stated they will carry out glyphosate bans by 2020, and Germany announced in 2018 that it will also issue a glyphosate ban.
This website also lists dozens of towns in the USA which have banned or restricted the use of glyphosate.
Six Middle Eastern States have also banned glyphosate https://sustainablepulse.com/2017/10/13/six-middle-eastern-countries-ban-glyphosate-herbicides-over-probable-carcinogen-fears/#.WwYO7SC0bIW
In Australia, there are many other jurisdictions other than those listed which use saturated steam weeding.
Byron Shire Council is to be commended that it has introduced synthetic pesticide-free techniques through much of the public spaces. The issue for this Council remains its use in bushland.
THE RECOMMENDATIONS
Recommendation 1: Undertake public communication
Unfortunately the Community Workshop (May 3) provided no opportunity for realistic feedback from the community to the Directions document and the Policy. Community members were asked to respond to questions which mirrored attitudes and assumptions in the Directions document where hazards and risks were taken totally out of context without adequate information for decision making. Hopefully Council staff would be better informed when making decisions.
There needs to be more transparency with regard to pesticide use to develop improvement indices.
Recommendation 2: Refining the current position
The consultants have downplayed the extent to which restrictions and bans have been successfully applied in other jurisdictions. We believe that many people do not comprehend the lack of rigorous scientific research behind APVMA regulations, so it is not surprising that many Australian authorities, farmers, home owners, and landcare groups have not taken the issue seriously. Unfortunately, many cases of Integrated Pest Management have meant ‘business as usual’, partly because of entrenched attitudes and values, the dominant ‘war on weeds’ paradigm, and lack of training in real alternatives. ‘Continuous improvement’ needs to stem from the best case scenario, not the medium or the worst.
Recommendation 3: Development of the Policy and IPM Strategy
The value of the Policy from which an IPM strategy will be developed relies on the validity of the Directions Document: this is worrying in its present form with its old-fashioned paradigms, and biases.
Recommendation 4: Mapping of pesticide exclusion and minimisation areas
From a moving forward perspective, we support the establishment of a mapped exclusion zone. This will also clearly identify the zone where pesticides are used. We believe that in this zone where ‘minimum pesticides are used’, Council should inform the public (via the website) on where pesticides are used, which pesticides are used, and for what reason so that the public can participate in better searches for alternatives.
Recommendation 5: Protocols for pesticide use:
It would be useful to separate cosmetic applications from real or perceived threats to safety, biodiversity, community assets, or amenity. Additionally emerging threats which may require localised one-off or limited treatments should be considered separately.
Unfortunately, as demonstrated in the Directions document, the belief that there is no effective alternative depends on your knowledge base.
Recommendation 6: Monitoring and reporting ‘continuous improvement’
Since pesticide use always requires reporting, it should be simple to compile a register within each Directorate of Council that may use pesticides. Quantative measures are essential but qualitative information should also be recorded. These include those listed by the consultants:
Beneficial outcomes in terms of pest reduction (in both exclusion and non-exclusion zones)
Adverse outcomes
Frequency of treatment
Variation in pest species abundance
Recording of emerging biosecurity threats
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