volume III

Document Number
17544
Parent Document Number
17540
Document File
Document

INTERNATIONAL COURT OF JUSTICE

CASE CONCERNING
AERIAL HERBICIDE SPRAYING

ECUADOR
V.
COLOMBIA

MEMORIAL OF ECUADOR

VOLUME III

ANNEXES

28 APRIL 2009VOLUME III

ANNEXES V OLUME III

ANNEXES

T ABLE OF C ONTENTS

CHEMICAL LABELS AND SAFETY INFORMATION

Annex 103 Argentina, Roundup TRANSORB Material Safety Data Sheet
Annex 104 Argentina Roundup Ultramax Label Recommendations

Annex 105 Australia Roundup Label

Annex 106 Australia Roundup Biactive Label

Annex 107 Australia Roundup CT Label
Annex 108 Australia Roundup PowerMAX Label

Annex 109 Brazil Roundup Label

Annex 110 Canada Roundup Original Label

Annex 111 Canada Vision Silviculture Herbicide Label
Annex 112 Cosmoagro, S.A., Cosmo-Flux 411F

Annex 113 Colombia Cosmo-Flux 411F Label

Annex 114 Cosmo-Flux 411F Safety Data Sheet

Annex 115 Colombia Roundup SL Label
Annex 116 Ecuador Ranger 480 Label

Annex 117 Germany Roundup TURBO Label

Annex 118 Germany Roundup UltraMax Label

Annex 119 Italy Roundup 450 Plus

Annex 120 Japan Roundup Agrochemical Registration
Annex 121 Japan Roundup Product Safety Data Sheet

Annex 122 South Africa Roundup Label

Annex 123 United Kingdom Glyphosate 360 Label

Annex 124 United Kingdom Roundup Ultra ST Label

iAnnex 125 United States Roundup Export Label , United States Pesticide
Product Label System, Registration No. 524-308 (9 July 1997)

Annex 126 United States Fuete SL Label , United States Pesticide Product

Label System, Registration No. 524-308 (19 Feb. 2002)
Annex 127 United States Roundup Original Label

Annex 128 United States Roundup Pro Label

Annex 129 United States Roundup SL Label, United States Pesticide Product
Label System, Registration No. 524-308 (15 Nov. 2001)

Annex 130 Intentionally Omitted

SCIENTIFIC AND TECHNICAL REPORTS

Annex 131 C. André Lévesque & James E. Rahe, Herbicide Interactions with
Fungal Root Pathogens, with Special Reference to Glyphosate ,
Annu. Rev. Phytopathol., Vol. 30 (1992)

Annex 132 United States Environmental Protection Agency, Glyphosate
Reregistration Eligibility Decision Fact Sheet (Sep. 1993)

Annex 133 D.C. Sands et al., Characterization of a Vascular Wilt of

Erythroxylum coca Caused by Fusarium oxyspurum f. sp.
Erythrowyli Forma Specialis Nova, Plant Disease, Vol. 81, No. 5
(May 1997)

Annex 134 United States Environmental Protection Agency, GLYPHOSATE
– Report of the Hazard Identification Review Committee (20 Apr.
1998)

Annex 135 Intentionally Omitted

Annex 136 United States Department of Agriculture, Agricultural Research
Service, Discovery and Development and Mechanism of Action of
Biocontrol Agents for Perennial and Annual Weeds (1 Oct. 1993

– 30 Sep. 1998)
Annex 137 United States Department of Agriculture, Agricultural Research

Service, Mechanisms of Microbial-Plant Interactions Related to
Biocontrol of Weeds and Narcotic Plants (1 Oct. 1993 – 30 Sep.
1998)

iiAnnex 138 Ron Collins, Agronomist, Weed Science Laboratory, Agricultural
Research Service, United States Department of Agriculture,

Glyphosate Aerial Application to Control Erythroxylum sp. In
Colombia: Spray Droplet Evaluation, Draft (23 Dec. 1998)

Annex 139 United States Department of Agriculture, Agricultural Research
Service, Strategies for Controlling Narcotic Plant Production
(30 Sep. 1995 – 29 Sep. 2000)

Annex 140 United States Department of Agriculture, April 2001 Colombia
Coca Eradication Verification Mission Trip Report (13 June

2001)
Annex 141 Ronald T. Collins & Charles S. Helling, Surfactant-Enhanced

Control of Two Erythroxylum Species by Glyphosate , Weed
Technology, Vol. 16 (2002)

Annex 142 United States Environmental Protection Agency, GLYPHOSATE
– 2nd Report of the Hazard Identification Assessment Review
Committee (22 Jan. 2002)

Annex 143 United States Environmental Protection Agency, Office of
Prevention, Pesticides and Toxic Substances, Report on Issues
Related to the Aerial Eradication of Illicit Coca in Colombia,

Response from EPA Assistant Administrator Johnson to Secretary
of State (19 Aug. 2002)

Annex 144 United States Department of State, Bureau for International
Narcotics and Law Enforcement Affairs, Report on Issues
Related to the Aerial Eradication of Illicit Coca in Colombia:
Chemicals Used in the Aerial Eradication of Illicit Coca in

Colombia and Conditions of Application (Sep. 2002)
Annex 145 Intentionally Omitted

Annex 146 United States Environmental Protection Agency, Office of
Pesticide Programs, Details of the 2003 Consultation for the

Department of State: Use of Pesticide for Coca and Poppy
Eradication Program in Colombia (June 2003)

Annex 147 United States Department of Agriculture, Agricultural Research
Service, Pathogens of Narcotic Crops and Their Use in
Biological Control Strategies to Reduce Narcotics (1 Oct. 1998 –
30 Sep. 2003)

iiiAnnex 148 United States Department of State, Bureau for International
Narcotics and Law Enforcement Affairs, Report on Issues

Related to the Aerial Eradication of Illicit Coca in Colombia:
Updated Report on Chemicals Used in the Aerial Eradication
Program (Dec. 2003)

Annex 149 United States Environmental Protection Agency, Office of
Pesticide Programs, Letter and Consultation Report from
Administrator Leavitt (17 Nov. 2004)

Annex 150 Rick A. Relyea, The Impact of Insecticides and Herbicides on the

Biodiversity and Productivity of Aquatic Communities ,
Ecological Applications, Vol. 15, No. 2 (2005)

Annex 151 Keith R. Solomon et al., Environmental and Human Health
Assessment of the Aerial Spray Program for Coca and Poppy
Control in Colombia , prepared for the Inter-American Drug
Abuse Control Commission (CICAD) section of the Organization

of American States (OAS), 31 Mar. 2005
Annex 152 National University of Colombia, Institute of Environmental

Studies, Observations on the “Study of the effects of the Program
for the Eradication of Unlawful Crops by aerial spraying with
glyphosate herbicide (PECIG) and of unlawful crops on human
health and the environment (10 May 2005)

Annex 153 Ecuadorian Scientific-Technical Commission, Technical Report
from the CCTE on the CICAD Document on the Study of the

Effects Produced by Spraying Glyphosate (within the coca crop
eradication program) on the Border Between Ecuador and
Colombia (2 June 2005)

Annex 154 United States Environmental Protection Agency, Office of
Pesticide Programs, CICAD Environmental and Human Health
Assessment of the Aerial Spray Program for Coca and Poppy

Control in Colombia (Ecological Effects Assessment) (26 Oct.
2005)

Annex 155 Inter-American Drug Abuse Control Commission (CICAD),
Interim Report on Follow-Up Studies: Environmental and Human
Health Assessment of the Aerial Spray Program for Coca and
Poppy Control in Colombia, (July 2006)

ivAnnex 156 United States Department of State, Report to Congress: A
Preliminary Evaluation of the Risk Posed to Colombia’s

Amphibians and Threatened Species by the Government of
Colombia’s U.S.-Supported Program of Aerial Eradication of
Illicit Crops (Aug. 2006)

Annex 157 Ecuadorian Scientific Commission, The Plan Colombia Aerial
Spraying System and its Impacts on the Ecosystem and Health on
the Ecuadorian Border (April 2007)

Annex 158 Charles A. Menzie, PhD, Pieter N. Booth, MS & Susan B. Kane

Driscoll, PhD, with contributions/advice from Angelina J.
Duggan, PhD, Charlotte H. Edinboro, DVM, PhD, Anne
Fairbrother, DVM, PhD, Marion Joseph Fedoruk, MD, CIH,
DABT, FACMT, Janci Chunn Lindsay, PhD, Katherine

Palmquist, PhD & Brian J. Prince, MRQA, Evaluation of
Chemicals Used in Colombia's Aerial Spraying Program and
Hazards Presented to People, Plants, Animals, and the
Environment in Ecuador (Apr. 2009)

Annex 159 Inter-American Drug Abuse Control Commission (CICAD),
Second Phase Environmental and Human Health Assessment of

the Aerial Spray Program for Coca and Poppy Control in
Colombia (date unknown)

Annex 160 Charles S. Helling & Mary J. Camp, United States Department of
Agriculture, Verifying Coca Eradication Effectiveness in
Colombia (date unknown)

v ANNEX 103

Argentina, Roundup TRANSORB Material Safety Data Sheet ANNEX 103

Monsanto Argentina S.A.I.C.
Maipú 1210, 10th Floor –

Cap.Fed.
Customer Service Center
0810-MONSANTO (6667268)

[email protected]

01 Product
MATERIAL SAFETY DATA SHEET Identification

Roundup TRANSORB
Product Name:

Chemical Not applicable

Name:
Not applicable

Synonyms:

[…]

[PAGE 3]

[…]

09 Spills and Losses

Contain or place a barrier around the spilled liquid on the soil or other impervious
surfaces using earth, sand, bentonite, attapulgite clay, or other absorbent materials.

Take the material contaminated with the spilled liquid, place it in a plastic bag and then
into a metal drum and, finally, proceed to dispose of according to the instructions found
in section 13.
Be sure to keep the spill away from drains, sewers, canals and waterways. ANNEX 103

1 10 10

010

01

Nombre del Producto:

Nombre Químico:

Sinónimos:

Revisión: F03ha: 19|10|05 02 Composición Química
del Producto

Ingrediente activo : Sal isopropilamina de glifosato ……………………………………………… 64,8% (peso/ volumen)

Ingredientes Inertes: ………………………………………………………………………………………………… 59.4% (peso/ volumen)

CAS Reg. No. para ingrediente activo: 110

La identidad química exacta no se especifica ya que es información comercial secreta de la
empresa Monsanto. 03 Identificación
de los Peligros

Contacto con la piel, contacto con los ojos, inhalación e ingestión.

Puede causar irritación ocular temporaria.

No se estima que produzca efectos nocivos importantes si se siguen las
instrucciones de uso recomendadas.

No se estima que produzca efectos nocivos importantes si se siguen las
instrucciones de uso recomendadas.

No se estima que produzca efectos nocivos importantes si se siguen las
instrucciones de uso recomendadas.

¡CUIDADO! Puede provocar irritación ocular Primeros Auxilios
04

Lave de inmediato con abundante agua. Continúe por lo menos 15
minutos. Si la víctima tiene lentes de contacto, retírelos en caso de que
sea posible y seguro hacerlo. Busque a un médico oftalmólogo.

Lave la zona afectada con abundante agua. Lave la ropa antes de volver
a utilizarla.

Tome aire fresco.

Ofrezca de inmediato agua para beber. Nunca administre algo por vía
oral a una persona inconsciente. No induzca al vómito salvo que así lo
indique personal médico. Se puede acudir a un médico o Centro de
Control de Envenenamiento para consultas.

Este producto no es un inhibidor de colinesterasa.

En caso de necesitar más información para una guía sobre primeros auxilios o tratamiento en caso de
emergencia con seres humanos, realice una llamada al Centro de Atención al Cliente 0810-MONSANTO
(6667268)

Página 1 de 6ANNEX 103

1 10 10

010

09 Derrames y Pérdidas

Contenga o endique el derrame de líquidos sobre suelo u otras superficies impermeables, utilizando tierra, arena,
bentonita, atapulguita u otros materiales absorbentes. Recoja el material contaminado con el líquido derramado,
colóquelo en una bolsa plástica y luego en un tambor de metal, y finalmente proceda a la disposición de acuerdo
con las instrucciones que se encuentran en la sección 13.
Asegúrese de mantener el derrame alejado de drenajes, cloacas, canales y cursos de agua.

Datos Toxicológicos
10

Rata, LD50: 5.108 mg/kg peso corporal. Prácticamente no tóxico.
Categoría FIFRA IV.

Conejo, 6 animales, ensayo OECD 404:
Días necesarios para la recuperación: 3
Índice de Irritación Primaria (PII): 0,5/8,0
Esencialmente no irritante. Categoría FIFRA IV.

Conejo, 6 animales, ensayo OECD 405:
Días necesarios para la recuperación: 3
Irritación leve. Categoría FIFRA III.

NOTA: Para la realización del test de inhalación este producto fue artificialmente aerolizado. Esta
condición no es alcanzada naturalmente durante el proceso de transporte y, por lo tanto, este material es clasificado como NO PELIGROSO para
transporte en conformidad con los ítems 2.6.2.2.4.7 (b) y (c) del UN Recommendations on the Transport of Dangerous Goods.

10 10,4 mg/l (extrapolación de CL50 4h: 2,6 mg/l).
Incidencia positiva: 0 %

Ensayo(s) de mutagenicidad in vitro e in vivo:

1 Toxicidad NOAEL: 000
Órganos/sistemas afectados :
Otros efectos:

Toxicidad NOAEL: 0000
Órganos/sistemas afectados:
Otros efectos:

NOEL:: Tumor 0 000
Toxicidad NOAEL: 000
Tumores:
Órganos/sistemas afectados:
Otros efectos:

Tumor NOEL 0 000

Toxicidad NOAEL: ~ 000

Página 3 de 6 ANNEX 104

Argentina Roundup Ultramax Label Recommendations ANNEX 104

Faster
absorption

Faster control
Top end
performance

[…]

Application to perennial crops

Applications to vineyards, yerba mate, tea, citrus trees or fruit trees should
be made using the doses required to control the weeds present. In all cases,

avoid spraying leaves, fruits or green stems of cultivated plants, by directing
application to the base of the trunk of plants older than three years, carefully
protecting those less than three years old.

For sugar cane, use a chemical glove soaked in the Roundup
UltraMax Solution at 10%, controlling the weeds without affecting
the crop, regardless of its development state. ANNEX 104

Recomendaciones del Marbete

Roundup UltraMax es un herbicida selectivo para el control postemergente de las malezas anuales y perennes en Soja RR, Maíz RR
y algodón RR, cultivos genéticamente modificados, tolerantes al principio glifosato. De acción sistémica, es absorbido por hojas y
tallos verdes y traslocado hacia las raíces y órganos vegetativos subterráneos, ocasionando la muerte total de las malezas

emergidas. También se puede usar como no selectivo para el control de malezas en áreas agrícolas, industriales, caminos, vías
férreas, etc como se indica en este marbete.
Los efectos son graduales, sobre todo en las especies perennes, donde después de transcurridos 4-5 días desde la aplicación
comienza el amarillamiento y marchitamiento de hojas y tallos que culminan con la muerte total de las malezas.

Aplicaciones en cobertura total

Para aplicaciones con equipos de mochila debe prepararse una solución de 0,500 a 1 Kg. de Roundup UltraMax cada 100 litros
de agua limpia, mojando uniformemente el follaje, sin que el producto llegue a gotear.
Con equipos pulverizadores terrestres debe utilizarse la dosis recomendada, diluida en agua limpia, a razón de 80-120 l/ha. Las

pastillas recomendadas son las de abanico plano trabajando a una presión cuadrada. Para preparar la solución de aspersión debe
llenarse el depósito con agua hasta la mitad, agregarse la dosis recomendada por Roundup UltraMax y completarse el llenado.
Debido a la alta solubilidad de Roundup UltraMax es suficiente la agitación provista por el retorno de la pulverizadora.

Importante

Después de una aplicación con Roundup UltraMax y antes de dañar mecánicamente las malezas tratadas, es necesario esperar 3
días en el caso de especies anuales y 4 a 5 en el de perennes para asegurar la completa translocación del Roundup UltraMax a
todos los órganos vegetativos de las plantas
Los mejores resultados se obtienen cuando la aplicación se realiza sobre malezas en activo crecimiento que no sufren efectos de
sequía, enfermedades o cualquier otro factor adverso a su normal desarrollo.
Evitar las aplicaciones sobre malezas cubiertas por tierra.

No pulverizar si se prevén lluvias durante las seis horas posteriores a la aplicación o cuando el follaje de las malezas esté mojado.
No pre – diluir el producto, agregarlo directamente al tanque del pulverizador.

En Post – emergencia de variedades de soja Roundup Ready (RR)
Sojas geneticamente modificadas: Partiendo de una soja RR libre de la competencia de malezas vivas en el momento de la
siembra (ya sea convencional o directa), la primera aplicación de Roundup UltraMax en pos – emergencia (de cultivo y malezas)
se recomienda cuando las malezas alcanzan un máximo de 15 cm. de altura o diámetro. En ese momento, y para la generalidad

de los casos donde también hubiera malezas perennes emergidas, se recomienda la aplicación de una dosis de 1,1 a 1,3 k / ha.
En caso de especies de malezas más exigentes (ej. Gramón, cebollin) la dosis requerida puede ser de 1,6 a 1,8 k / ha. El referido
desarrollo de las malezas anuales suele alcanzarse entre los 30 y 40 días después de la siembra de cultivo, cuando la soja RR
presenta 3-4 hojas verdaderas.

Debido a que Roundup UltraMax no es un herbicida residual, puede ser necesaria una segunda aplicación para controlar las
malezas que emergieran con posterioridad al primer tratamiento. En este caso se recomienda aplicar entre 0,8 y 1,0k/ha de
Roundup UltraMax adicional para completar el control.

Con estas dosis se controlan las malezas anuales, tanto latífoliadas como gramíneas y también malezas perennes.

En Post- emergencia de híbridos de maíz Roundup Ready (RR): Partiendo de un maíz RR libre de la competencia de malezas

vivas en el momento de siembra (ya sea convencional o directa) la primera aplicaron de Roundup UltraMax en post- emergencia
(de cultivo y malezas) se recomienda cuando las malezas anuales (gramíneas o latífoliadas) alcanzan un máximo de 15 cm. de
altura o diámetro, antes de que comience la competencia que puede afectar el rendimiento y estado del maíz 4 hojas (V4). En ese
momento, se recomienda la aplicación de una dosis de 1,3 Kg. /ha. Si las malezas son de mayor tamaño pueden aplicarse hasta
2,6 Kg. /ha.

En caso de ser necesaria una segunda aplicación para controlar las malezas que emergieran con posterioridad al primer
tratamiento, se recomienda aplicar entre 0,8 y 1 Kg. /ha de Roundup UltraMax adicional, para completar el control. Las

http://www.elijoroundup.com.ar/ultramax_recomendaciones.phprlANNEX 104

aplicaciones no deben realizarse después de que el cultivo alcanzó el estado de 8 hojas, ya que podrían producirse daños e el

cultivo.

En Post – emergencia de variedades de algodón de Roundup Ready (RR)
Partiendo de un algodón RR libre de la competencia de malezas vivas en el momento de siembra (ya sea convencional o directa),
se recomienda la aplicación de Roundup UltraMax en post- emergencia (de cultivos y malezas) cuando las malezas alcancen un
máximo de 7 cm. de altura o diámetro y el algodón tenga hasta 4 hojas totalmente expandidas.

Entre el período de emergencia y 4 hojas expandidas del algodón podrán realizarse hasta dos aplicaciones de un máximo de 1,4
Kg. /ha de Roundup UltraMax cada una, con un intervalo entre ambas aplicaciones. Suficiente para que las plantas de algodón
crezcan, como mínimo dos nudos adicionales.

Las aplicaciones no deben realizarse entre el estado de 5 hojas y el estado de 20 % de apertura de frutos ya que podrán

producirse mermas en el rendimiento.

Podrán realizarse aplicaciones en cobertura total en pre- cosecha en el estado de 20% de apertura de frutas (bochas). En ese
momento podrán aplicarse hasta 2,5 kg/ha de Roundup UltraMax.

Aplicaciones en cultivos perennes

Las aplicaciones en viñedos, yerba mate, té, cítricos o frutales deben realizarse a las dosis requeridas para controlar las malezas
presente. En todos los casos debe evitarse que la pulverización alcance hojas, frutos o tallos verdes de las plantas cultivadas ,
dirigiendo la aplicación a la base del tronco de las plantas de más de tres añoso bien protegiendo a las de menos de tres años.

En caña de azúcar se puede usar guante químico embebido en una solución de Roundup UltraMax al 10 %, controlando las
malezas sin afectar el cultivo, sea cal fuera su estado de desarrollo.

Aplicaciones de presiembra en soja, maíz y girasol

Siembra convencional: Este tipo de aplicación es recomendable para lotes con altas infestaciones de Sorgo de Alepo, antes de

destinarlos a soja de primera, girasol, maíz y otros cultivos; logrando que crezcan libres de malezas. Es conveniente arar durante
el invierno y trabajar con rastra de doble acción al comienzo de la primavera con el objeto de trozar rizomas y uniformar su
brotación. Deberá dejarse crecer el sorgo de alepo hasta 30 – 50 cm. de altura y luego aplicar 1,400kg/ha de Roundup UltraMax.
Siembra directa: El uso de Roundup UltraMax es especialmente indicado para el control de las malezas presentes en el rastrojo
del cultivo anterior, antes o inmediatamente después de la implantación usando esta técnica. Se recomienda esperar 2 a 3 días
después de la cosecha para que las malezas recuperen la capacidad de absorber el herbicida y luego aplicar 1,4 – 2,0 kg./ha de

Roundup UltraMax.

Malezas que controla (aplicaciones no selectivas)

Roundup UltraMax controla un gran número de especies, se citan algunas.
Anuales: las malezas anuales son más susceptibles a Roundup UltraMax cuando tienen menos de 15 cm. de altura, usando una
dosis entre 1,0 y 1,60 Kg. por hectárea para gramíneas y de 1,4 a 2,1 Kg. por hectárea para latífoliadas.

Bajo ciertas condiciones naturales, existe la posibilidad de biotipos de una maleza que fueran tolerantes al glifosato y otros grupos de
herbicidas. Dichos biotipos tolerantes podrían tornarse dominantes después del uso repetido de dichos grupos de herbicidas. Atento
que la ocurrencia de poblaciones resistentes resulta difícil de detectar antes de la aplicación del herbicida, Monsanto no se

responsabiliza por ninguna perdida que pudiera resultar de la falla de este producto cuando se lo aplique para controlar biotipos de
maleza que hubieran desarrollado una tolerancia natural.

© 2008 Monsanto Argentina SAIC. | Términos y condiciones de uso del sitio | Avisos Legales

El titular de los datos personales tiene la facultad de ejercer el derecho de acceso a los mismos
en forma gratuita a intervalos no inferiores a seis meses, salvo que se acredite un interés
legítimo al efecto conforme lo establecido en el artículo 14, inciso 3 de la Ley Nº 25.326

La DIRECCION NACIONAL DE PROTECCION DE DATOS PERSONALES, Órgano de Control

de la Ley Nº 25.326, tiene la atribución de atender las denuncias y reclamos que se
interpongan con relación al incumplimiento de las normas sobre protección de datos
personales.

*Según bases, condiciones y recomendaciones de marbete en www.elijoroundup.com.ar

http://www.elijoroundup.com.ar/ultramax_recomendaciones.phprl ANNEX 105

Australia Roundup Label ANNEX 105

Roundup® - Front Label

CAUTION

KEEP OUT OF REACH OF CHILDREN
READ SAFETY INSTRUCTIONS BEFORE OPENING OR USING

®
Roundup Herbicide by Monsanto

ACTIVE CONSTITUENT : 360 g/L GLYPHOSATE
(present as the isopropylamine salt)

GROUP M HERBICIDE

Water soluble herbicide for non-selective control of many

annual and perennial weeds in certain situations.

IMPORTANT: READ THE ATTACHED BOOKLET
BEFORE USING THIS PRODUCT

N (Nufarm logo)
Distributed by
Nufarm Australia Limited ACN 004 377
780
103-105 Pipe Road, Laverton North,
VIC 3026
Tel: (03) 9282 1000 Fax: (03) 9282 1001
NRA Approval No 31393/

CONTENTS
5, 20, 55, 110, 115, 200, 400,
1000 LITRES
Batch no. :
Date of manufacture :
Barcode

28/04/2005 Page 1 of 15ANNEX 105

Roundup® - 250mL, 500mL, 1L

(front page)

CAUTION

KEEP OUT OF REACH OF CHILDREN

READ SAFETY DIRECTIONS BEFORE OPENING OR USING

Roundup® Herbicide by Monsanto

Active Constituent: 360g/L GLYPHOSATE (present as the isopropylamine salt)

Water soluble herbicide for non-selective control of many annual and perennial weeds
in certain situations.

Distributed by
Nufarm Australia Limited ACN 004 377 780
103-105 Pipe Road, Laverton North, VIC 3026

Tel: (03) 9282 1000 Fax: (03) 9282 1001
NRA Approval No. 31393/0703
Batch No. / Date of Manufacture
CONTENTS 250ml, 500ml & 1Litre

(back view of pack)
Roundup® herbicide by Monsanto kills weeds, unwanted grasses and vegetation in Domestic, Public

Services, Commercial and Industrial Areas.

HOW TO USE

DO NOT treat if rain is likely within 6 hours. DO NOT DISTURB treated weeds for 7 days after treatment.
WEEDS RATE HOW TO APPLY
CONTROLLED
General Mixed 10mL per 1L TIMING: Apply when weeds are actively growing. For best results on perennial weeds treat
Weeds water after flowering. Treat woody leaves from flowering to leaf fall (Jan-May). DO NOT spray plants
Annual and bearing edible berries.
Perennial Weeds
Woody Weeds 15mL per 1L APPLICATION: Uniform and complete spray to wet all leaves. Run off should not occur. 1 litre
water of spray will cover 10 square metres. The addition of a non-ionic surfactant is recommended at a
rate of 1ml of a 600g/L product (or equivalent) per 1L spray solution. Seeding or planting into
treated areas may proceed after 7 days.
NOT TO BE USED FOR ANY PURPOSE, OR IN ANY MANNER, CONTRARY TO THIS LABEL UNLESS AUTHORISED

HOW TO PREPARE:

Mix this product with clean water. Use only plastic lined brass, copper, fibreglass, aluminium, plastic or
stainless steel containers for mixing and application. DO NOT mix more than can be used within 5 days. Wash
out spray equipment thoroughly after use.

CAUTION:

DO NOT allow spray to contact or drift onto plants you do not want killed. Accidental contact must be hosed
with water immediately to reduce injury to plant. DO NOT allow chemical containers or spray to get into drains,
sewers, streams or pond. DO NOT spray directly on humans, pets, exposed food, food preparation areas or food
utensils.
STORAGE AND DISPOSAL: Store in the closed original container in a cool, dry place out of reach of

children. Do not store in direct sunlight. Dispose of empty container by wrapping in paper, placing in a plastic
bag and putting in the garbage.
SAFETY DIRECTIONS: Avoid contact with eyes and skin. Wash hands after use.
FIRST AID: If poisoning occurs, contact a doctor or Poisons Information Centre Ph: 13 11 26.

Only in Emergency call 1800 033 498 ALL HOURS
Refer to MSDS

Barcode

28/04/2005 Page 14 of 15 ANNEX 106

Australia Roundup Biactive LabelANNEX 106ANNEX 106ANNEX 106ANNEX 106ANNEX 106ANNEX 106ANNEX 106ANNEX 106 ANNEX 107

Australia Roundup CT LabelANNEX 107ANNEX 107ANNEX 107 ANNEX 108

Australia Roundup PowerMAX Label ANNEX 108
June 2005 RoundupPowerMAX™ - Front Label

CAUTION
KEEP OUT OF REACH OF CHILDREN
READ SAFETY INSTRUCTIONS BEFORE OPENING OR USING

Roundup

PowerMAX ™

Herbicide by Monsanto

ACTIVE CONSTITUENT : 540 g/L GLYPHOSATE
(present as the Potassium salt)

GROUP M HERBICIDE

Non selective herbicide for the control of many annual and
perennial weeds

READ THE ATTACHED BOOKLET BEFORE USING THIS PRODUCT

N (Nufarm logo)
Distributed by
Nufarm Australia Limited ACN 004 377 780
Tel: (03) 9282 1000 Fax: (03) 9282 10013026

Barcode CONTENTS * L
APVMA Approval No. 55687/*L/0505

* = 5, 10, 15, 20, 55, 110, 115, 200, 400, 450, 500, 1000
Batch Date of manufacture :

19/07/2005 Page 1 of 15ANNEX 108

Roundup PowerMAX ™- Label Booklet June 2005

Air temperature and relative humidity
DO NOT apply ROUNDUP PowerMAX by aircraft at temperatures above 30ºC. Increase spray output to at least
30L/ha when temperatures rise above 25ºC. Avoid application when relative humidity falls below 35%.

AVOID DRIFT
DO NOT apply treatments with spraying equipment or under weather conditions which are likely to cause spray
drift onto nearby susceptible crops, pastures or other sensitive plants. DO NOT apply treatments under very light

(less than 4km/h) or inversion conditions or where wind speeds exceed 12km/h.

A PPLICATION C HECK LIST

x Do not treat weeds under poor growing conditions due to moisture stress, waterlogging, severe frosting, insect
damage etc. Reduced performance may also occur where weeds are covered with dust or silt.

x Do not add surfactants, adjuvants or other pesticides except as specifically directed on this label.
x Rain within 1 hour of application which causes run-off may require re-treatment. Rainfastness is reduced if
weeds are not actively growing, under stress or conditions of low light intensity/darkness. The addition of

Wetter TX may improve rainfastness on Winter annual weeds.
x A withholding period for grazing is not required. However, it is recommended that grazing of treated plants be
delayed to ensure herbicide uptake. Certain plants such as Soursob, Variegated thistle, Sorghum and Johnson

grass may be naturally toxic to stock when eaten in large quantities under certain conditions. Where plants are
known to be toxic, grazing should be delayed until complete desiccation of treated plants has occurred.
x Apply treatments to weeds which have at least one true leaf (broadleaf weeds) or two leaves (grasses) to

provide an adequate surface area for herbicide uptake.
x If heavy grazing has occurred, allow regrowth to 6-8 cm before spraying and use the higher rates
recommended.

P ROTECTION OF C ROP, NATIVE AND O THER NON -TARGET P LANTS

Avoid contact with foliage, green bark or stems, canes, laterals, suckers, fresh wounds, exposed non-woody roots,
flowers or fruit of crops, desirable plants and trees, since severe injury or destruction may result.

DO NOT apply under weather conditions, or from spraying equipment, that may cause spray to drift onto nearby

susceptible plants/crops, cropping lands or pastures.

P ROTECTION OF W ILDLIFE, FISHC RUSTACEA AND ENVIRONMENT

DO NOT contaminate dams, rivers or streams with the product or used container. DO NOT apply to weeds
growing in or over water. DO NOT spray across open bodies of water.

N (Nufarm logo)
Distributed by

Nufarm Australia Limited ACN 004 377 780

103-105 Pipe Road, Laverton North, VIC 3026
Tel: (03) 9282 1000 Fax: (03) 9282 1001

®/ ™ Registered / trademark of Monsanto Technology LLC used under licence by Nufarm Australia Limited, Copyright Monsanto Australia

Limited, August 2003. Ally, Express, Glean and Oust are registered trademarks of El. Dupont de Nemours and Co. USA. Eclipse, Flandor,
Garlon, Lontrel, Lorsban, Starane, Surflan and Yield are registered trademarks of Dow AgroSciences LLC. Stomp and Flame are registered
trademarks of BASF Agro B.V. Logran, Nugran and Solicam are registered trademarks of Syngenta Participations AG. Imidan is a registered
trademark of Gowan Internacional Comercio E Servicos LDA. Perfekthion is a registered trademark of BASF Aktiengesellschaft. Sumithion is a
registered trademark of Sumitomo Chemical Ltd. Karate is a registered trademark of Syngenta Ltd. Harvade is a trademark of Uniroyal Co. Inc.
Dropp is a registered trademark of Aventis CropScience GmbH. Affinity is a registered trademark of FMC Corporation. Hammer is a registered
trademark of FMC Chemicals Pty Ltd. Avadex and Striker are registered trademarks of Nufarm Technologies USA Pty Ltd. Associate, Estercide,
Invader, Kamba, Nufarm Surpass, Pirate, and Rifle are registered trademarks of Nufarm Australia Limited.

19/07/2005 Page 15 of 15 ANNEX 109

Brazil Roundup Label ANNEX 109

- Do not allow minors to work in application.

[…]
ROUNDUP WG - Do not wash packaging or equipment in lakes,
– TOXICOLOGICAL springs, rivers or other bodies of water. […]

CLASSIFICATION IV
– SLIGHTLY TOXIC

ROUNDUP ORIGINAL
AND ROUNDUP
TRANSORB

– TOXICOLOGICAL
CLASSIFICATION III
– MODERATELY

TOXIC

▯ ANNEX 109

Mapa do site

Home Meu cadastro Fale conosco Envie seu currícuÁrea restrita - Portal

Roundup

Roundup : Roundup

Há 30 anos com você no campo. Isso é mais que tradição. É confiança.

O herbicida Roundup, que revolucionou a agricultura e se tornou ferramenta fundamental no dia-a-dia dos
agricultores, está completando 30 anos. Com registro em 120 países, ele é o mais vendido no mundo para o
controle de plantas daninhas em pré-plantio das lavouras e o maior parceiro do Plantio Direto.

O surgimento de Roundup se deu em 1970, com a síntese do glifosato, ingrediente ativo do herbicida. Em 1974
Roundup foi registrado pela primeira vez para uso na Malásia e no Reino Unido e dois anos depois nos Estados
Unidos. O Brasil recebeu sua primeira amostra para testes em 1972 e em 1978 o produto, ainda importado,
chegava ao País para ser comercializado. Ele passou a ser produzido no Brasil em 1984.

No Brasil a marca Roundup se transformou numa família de produtos. São eles Roundup Original, o produto
pioneiro que passou a ser designado desta forma em 1999; Roundup WG, tecnologia granulada lançada em
1997; e Roundup Transorb, que com a sua inovadora tecnologia Transorb permite que o produto chegue mais

rápido e em maior quantidade à raiz da planta daninha.

Os herbicidas da linha Roundup são largamente aceitos pelos agricultores por possuírem uma excelente eficácia
agronômica, baixa toxicidade para o ser humano e reduzido impacto ambiental, em conformidade com avaliações

feitas pelas autoridades de registro no Brasil, Ministério da Agricultura, Abastecimento e Pecuária (MAPA),
Agência Nacional de Vigilância Sanitária (ANVISA) e Instituto Brasileiro do Meio Ambiente e dos Recursos
Naturais Renovávies (IBAMA) e órgãos internacionais, como a Organização Mundial da Saúde (OMS), a Agência
de Proteção Ambiental dos Estados Unidos (EPA) e pela comunidade científica internacional ao longo desses

últimos 30 anos.

Nos Estados Unidos e em outros países, herbicidas à base de glifosato estão entre os poucos autorizados para
uso em jardinagem, assim como ocorre na internacionalmente conhecida reserva ecológica de Galápagos e nas

ruínas de Pompéia, na Itália.

http://www.monsanto.com.br/roundup/roundup/roundup.asprlANNEX 109

Copyright © 2007 Monsanto Company | Legal Notice | Privacy Policy
Produtos para agricultura - sementes de soja, milho, algodão, hortaliças e sorgo. Biotecnologia para o campo e transgênicos.

http://www.monsanto.com.br/roundup/roundup/roundup.asprl ANNEX 110

Canada Roundup Original LabelANNEX 110ANNEX 110ANNEX 110ANNEX 110ANNEX 110ANNEX 110ANNEX 110ANNEX 110ANNEX 110 ANNEX 111

Canada Vision Silviculture Herbicide LabelANNEX 111ANNEX 111ANNEX 111ANNEX 111ANNEX 111ANNEX 111 ANNEX 112

Cosmoagro, S.A., Cosmo-Flux 411F ANNEX 112

A non-ionic stereospecific adjuvant ACTION
It is a non-ionic stereospecific adjuvant that substantially modifies the biological activity
composed of a non-phytotoxic
paraffinic oil and stereospecific of agrochemicals and permits emulsions and dispersions to remain stable for a longer
surfactant mixture period.
It improves the adherence and uniformity of the emulsified mixture, controlling
evaporation and hydrolysis of the active ingredient by completely covering it, which

guarantees a uniform concentration of the active ingredient per area unit. Adding the
adjuvant COSMO-FLUX 411F to the application of insecticides, fungicides and
herbicides prepared in mixtures of mineral or vegetable oil has been shown to have the
ability to increase the efficiency of these products. Its effectiveness is four (4) times

greater than conventional spraying oils due to synergism between the paraffinic oil and
the stereospecific surfactant.
Its molecules are biodegradable in accordance with international standards of the
Agencies (FDA) that regulate the use of pesticides in food and its release into the
environment (EPA).

REASONS FOR USING COSMO-FLUX 411 F
x Better adherence, reduces being washed away by the rain.

x Reduces evaporation and being blown away by the wind (drift).
Guaranteed composition x Maintains the size of a microdrop with each active component
Alcohol ethoxylate (linea17.00% x Helps extend the biological activity spectrum of agrochemicals
alcohol) + aryl ethoxylate

Liquid isoparaffin83.00% PREPARATION OF THE MIXTURE
Total 100% For liquid EC agrochemicals, add the amount of COSMOFLUX 411F [sic] per total
Contains 1000g of Active Ingredients pervolume of the mixture to the pre-mixture. Next, add the pre-mixture to the tank with the
liter of commercial product required amount of water for application and stir well to mix the components together.

With powder agrochemicals, first mix them with water and then add the required dose of
COSMO-FLUX 411F per total volume of the mixture to the tank, stir well.ANNEX 112 ANNEX 113

Colombia Cosmo-Flux 411F Label ANNEX 113

[P. 1]

LOT (illegible) NOV 2007 EXP. NOV 2009
IMPORTED BY TRIADA EMA S.A. ECUADOR BRANCH MAG

3199076

COSMOAGRO £
Creative Technology with Ecological Sense

£

COSMO-FLUX 411F

NON-IONIC ADJUVANT,
EMULSIFIABLE CONCENTRATE

FOR AGRICULTURAL USE
ICA Sales Registration No. 2186
For COSMOAGRO S.A.
GUARANTEED COMPOSITION

ACTIVE INGREDIENTS: Grams per liter
at 20° C

Alcohol ethoxylate (linear alcohol) + aryl 170.0 g/l
ethoxylate
ADDITIVE INGREDIENTS:
Liquid isoparaffins 83%
Total 100.00%
LOT No.:

FORMULATION DATE:
EXPIRATION DATE:

Net Content: 1 LiterANNEX 113

Manufactured by: TRIADA EMA S.A.
Ciudadela Internacional del Pacífico, B 15. Km. 6, Via Airport Yumbo,
Palmira

Tel.: +57 (2) 280 0660, Fax: +57 (2) 280 0670
Webpage: www.cosmoagro.com
MADE IN COLOMBIA
08-03-2007

TOXICOLOGICAL CATEGORY IV
SLIGHTLY TOXIC

“PRECAUTION” ANNEX 113

[PAGE 2]

“READ LABEL BEFORE INSTRUCTIONS FOR USE AND
USING THIS PRODUCT” HANDLING:
£
KEEP OUT OF REACH OF COSMO-FLUX 411F is a non-ionic adjuvant
CHILDREN intended for use in mixtures with fungicide
products used to control the black sigatoka
PRECAUTIONS AND
(Mycosphaerella Fijiensis var difformis) on
WARNINGS FOR USE banana and plantain plants, also with
insecticides for the control of the coffee borer
COSMO-FLUX £ 411F is the beetle ( Hypothenemus Hampei, ferrari ), and

mixture of a non-phytotoxic with herbicides in the control of weeds
paraffinic oil with advanced according to the technical criteria of an
non-ionic tensoactives. Agricultural Engineer.

First Aid: PREPARATION OF THE MIXTURE:
Immediately take off - For liquid agrochemicals, directly add the
contaminated clothing, wash required amount of COSMO-FLUX 411F

with plenty of water and soap, per total volume of the mixture. Next, add
and follow these instructions: to the mixing tank the required amount of
water for the application and agitate well to
Symptoms Follow
mix the components together.
of instructions on - With powder agrochemicals, first mix them
poisoning the agrochemical with water and then add to the tank the
label used in the £
required dose of COSMO-FLUX 411F
mixture, since per total volume of the mixture, agitating
COSMO- the mixture well.
FLUX £ 411F is - COSMO-FLUX £ 411F is soluble in
not a pesticide
mineral and vegetable oils, dispersible in
but an adjuvant. water, forming a good emulsion.
Ingestion Do not induce
vomiting.

Skin Wash with
contact plenty of water
and soap.

Inhalation Symptomatic
treatment
Eye Rinse with
contact plenty of clean

water or with
eye solution for
15 minutes.ANNEX 113

Medical Follow DOSE: Banana Coffee Herbicide
attention symptomatic and (Borer

treatment. Plantain Beetle)
(Black
Sigatoka)

IN CASE OF POISOINING, Product Volume L/Ha L/Ha
IMMEDIATELY CALL A (%) of
DOCTOR OR TAKE PATIENT total
TO THE DOCTOR AND mixture

SHOW HIM THIS LABEL COSMO- £ 0.9 0.75 0.5 – 1.0
FLUX 1.0
Measures for environmental 411F
protection:
Liquid 44
Absorb any spill with lime, isoparaffins
sawdust, sand or any other Active (*)
absorbent material. Then bury Ingredient
the contaminated material and
Water Until volume is completed
the empty containers in an area (*) Prescribed by an Agricultural Engineer
where there is no risk of water
contamination.
COMPATIBILITY: £
COSMO-FLUX 411F is compatible with
most agrochemicals such as Propiconazole,
Product Storage and Handling: Tridemorf, Mancozeb, Benomyl, Melathion,
The product must be stored in a
Fenthion, Pirimiphos, Fenitrothion,
safe, cool and dry place, far Clorpyriphos, Permethrin, among others.
from food and medicines. It However, it is recommended that compatibility
should be kept tightly closed tests be done before use
and in its original packaging.

GUARANTEE:
After using the contents, rinse “The manufacturer guarantees that the physico-
this container three times and chemical characteristics of the product
pour the water in the application
correspond to those listed on the label, and that
mixture, and then destroy it. through the official sales registration, it was
verified that it is suitable for the purposes
WARNING: “No container
used to hold pesticides should recommended herein in accordance with the
specifications for use”.
be used to hold food or drinking
water”. ANNEX 113

IMPORTANT: Verify the Sales Registration
imprint, dotted letters in ink,Colombia ICA Venezuela MAC 1116
the lot number and expiration 2186
date, on the container.
Bolivia MAG 208 Ecuador MAG
3199076

£
COSMOAGRO
Creative Technology with Ecological SenseANNEX 113ANNEX 113 ANNEX 114

Cosmo-Flux 411F Safety Data Sheet ANNEX 114

[PAGE 1]

[logo] COSMOAGRO
Quality 14-
Safety Data Sheet May-
System 2003
Commercial Name
COSMO-FLUX 411F £

1. Chemical Product and Company Identification
Commercial Name: COSMO-FLUX 411F

Formulation Code: 07102
Company
Identification
Producer Triada EMA S.A.

Palmira, Valle del Cauca,
Colombia
Zona Franca del pacífico,
Bodega 15B
Tel.: +(092)272

3232
Fax: +(092)271
9977
DistributorSosm. oagro

Palmira, Valle del Cauca,
Colombia
Calle 42 #30-39
Tel.: +(092)271

4995
Fax: +(092)271
9576
2. Composition: Information about the Ingredients

Chemical Characteristics

Mixture of mineral oil and non-ionic surfactants with
Type of formulation coupling agents

Use Non-ionic adjuvant for agricultural UseANNEX 114

Active Ingredient(s) Linear alcohol ethoxylate
Aryl ethoxylate
Additive
Liquid isoparaffins
Ingredient(s)
The active ingredients comply with EPA regulations and are exempt from
tolerance under 40 CFR 180.1001 (c), (e)

3. Hazard Identifications

Health Risks
Slight

Environmental risk in case of accident (spills/leaks)
Harmful to aquatic organisms, fish and algae

4. First-Aid Measures

In any event, please consult a Doctor!

Eye contact: Wash with clean, purified water until irritation disappears or

use an eye solution. If irritation persists, seek medical attention. ANNEX 114

[PAGE 2]

[logo] COSMOAGRO
14-
Quality
System Safety Data Sheet May-
2003
Commercial Name
COSMO-FLUX 411F £
Skin Contact: Wash with plenty of water; use soap if available. Remove

heavily contaminated clothing, including shoes, and wash well before using.

Inhalation: Using appropriate breathing apparatus, remove the person from
the site into fresh air and call a doctor.

Ingestion: Do not induce vomiting, keep the person at rest. Get immediate
medical attention.

5. Measures for extinguishing Fires

Flash Point: Above 149°C

Self-ignition temperature: approximately 420°F / 120°C

Means of extinguishing
Appropriate Means of extinguishing: Water spray, dry chemical, CO
2
foam

Fire-fighting
Special hazards during fire-fighting: Combustion products are toxic and

irritating.

Protective equipment for Fire-fighting

In a fire, use a self-contained breathing apparatus

PRODUCT NOT CLASSIFIED AS FLAMMABLE, ITS
DECOMPOSITION PRODUCTS UNDER FIRE CONDITIONS ARE CO

AND CO 2ANNEX 114

6. Accidental Release
Measures

Personal Precautions For personal protection see section 8

Methods for Cleaning Absorb with sand, earth or with a similar
up absorbent

7. Handling and Storage

Electrostatic Accumulation Hazard: Yes, there is danger of it, use proper

procedure for ground connection
Storage Temperature, °F / °C: Room temperature
Loading / Unloading Temperature, °F / °C: Room temperature
Storage / Transportation, mmHg: Atmospheric

Handling Information

Safety Category according
Not Applicable
to I.S.G (International
Shipping of Goods):
Personal Precaution Use breathing apparatus, gloves, eye
Measures: protection

Technical Precautions: Those recommended for agrochemical use

Spills: Absorb with sand, earth or with a similar
absorbent ANNEX 114

[PAGE 3]

COSMOAGRO
Quality 14-
Safety Data Sheet May-
System 2003
Commercial Name
COSMO-FLUX 411F £

8. Exposure controls, personal protection

Personal Protection
Hand Protection:
Disposable gloves

Eye Protection:
Safety goggles
9. Physico-Chemical

Properties
Appearance at 25° C Liquid
Color Yellowish
Flash Point 149° C

Specific weight at 20° C 0.84 g/ml
Solubility in water at 25° C Dispersible, forming a quick emulsion
Solubility
Mineral oils Soluble
Vegetable oils Soluble

Organic solvents (used
in agrochemical soluble
formulations)
Viscosity at 25° C 35 cP

Superficial tension 25 – 28 Din/cm
pH 6.0 – 8.0
10. Stability and Reactivity

Homogeneity
Excellent.ANNEX 114

Persistence
Over 24 hours.

Compatibility with Active Ingredients
Compatible.

Speed of Mixture
Fast.

Adherence
Excellent. ANNEX 114

[PAGE 4]

[logo] COSMOAGRO
14-
Quality May-
System Safety Data Sheet 2003
Commercial Name
COSMO-FLUX 411F £

11. Toxicological information

Ministry of Health (Republic of Colombia) Classification
TOXICOLOGICAL CATEGORY IV

SLIGHTLY TOXIC (Green band)

Classification as a Poison
Not classified

Eye irritation in rabbits (according to the application of Kay D. Calandra)
Slight irritation after being applied for 24 hours without diluting.

Human Skin Sensitization
Low degree of toxicity, frequent or prolonged contact may cause irritation
and produce dermatitis. Control measures are to be observed for the
handling of this type of product.

12. Ecological information

Ecotoxicity
Toxic for fish, algae and daphnia. If proper handling conditions are

maintained, there should not be any ecological problems.

13. Product Disposal Considerations
Exposure to liquid, vapors, mists or smoke should be minimized. Do not

store or mix with strong oxidizing agents such as liquid chlorine or
concentrated oxygen.
In the event of a spill, pay attention to measures specified in section 6.
Product Disposal: Place product in airtight and properly labeled bags.ANNEX 114

14. Transport information
Special conditions for transport
Use resistant and properly labeled containers.

15. Regulatory
information
Classification Does not require classification

Risk Phrases (R36/37) Wear suitable protective clothing and
gloves
(R61) Follow special instructions / safety data

sheets
(R52) Harmful to aquatic organisms
(S2) Keep out of the reach of children
(D01) Wash immediately substances from skin

and eyes
16. Other information:
The information in this safety data sheet is provided in good faith and
represents what is known about the product at the time of publishing.

Recommendations for its use and application are based on trials ANNEX 114

[PAGE 5]

[logo] COSMOAGRO
14-
Quality May-
System Safety Data Sheet
Commercial Name 2003
£
COSMO-FLUX 411F
conducted by COSMOAGRO, but its use and application in each specific
case must be evaluated to determine the appropriateness of its use.

COSMOAGRO guarantees that the physico-chemical characteristics of the
product correspond to those listed on the label, and that through opinion on
efficacy No. 2186 of 19 April 1993, issued by ICA (Colombian Agricultural
Institute), it was verified that it is suitable for the purposes recommended

therein, in accordance with the specifications for use, but assumes no
responsibility for how it may be used, since its handling is beyond its
control.

This product must be used with the recommendation of an Agricultural

Engineer or a Technical Assistant.

COSMOAGRO and COSMO-FLUX 411F are registered trademarks of
COSMOAGRO.ANNEX 114ANNEX 114ANNEX 114ANNEX 114ANNEX 114 ANNEX 115

Colombia Roundup SL Label ANNEX 115

NET CONTENTS: Formulated by: x SYSTEMIC
Approx. 1 Litre C.A.C Ltd. and HERBICIDE
NET WEIGHT: S.C.A. Co. x NON-SELECTIVE

Approx. 1.24 kg Calle 100 No. 7-33 x CONCENTRATED,
LOT No.: 0804002 Torre A piso19 WATER SOLUBLE
DATE OF A.A.: 56014 – x AGRICULTURAL
FORMULATION: Telephone: 650 0650
APRIL 2008 Bogota, D.C., USE

EXPIRY DATE: 5 Colombia GUARANTEED
years after the COMPOSITION:
formulation date SALE
MAXIMUM SALE REGISTRATION Active Ingredient
Isopropylamine Salt of N-
PRICE: ICA No. 0756 phosphonomethyl glycine:
LABEL APPROVAL 480 grams per liter of
DATE: 24 July 2001 MONSANTO
formulation at 20°C
(equivalent to 360 grams
per liter of acid
glyphosate)

Additive Ingredients
Surfactant and water to
complete the litre.ANNEX 115

PRECAUTIONS AND USAGE WARNINGS
KEEP OUT OF REACH OF CHILDREN.

Do not store or transport with seeds and food for human or animal
consumption. Do not store in living areas. Keep locked in a dry and
ventilated place in the original packaging. Use glasses, gloves, rubber

boots and protective clothing during use and application. Do not smoke,
eat or drink while preparing or applying this product. Rinse empty
containers three times and empty them into the spray tank. Puncture and
destroy the containers. No container which has held pesticides should

be used to store food or drinking water. Apply under calm wind
conditions. Avoid contact with eyes and skin. Causes irritation. Upon
completion of work, change clothes and wash with plenty of soap and
water. Do not contaminate water sources. Do not apply to or pour surplus

product directly over water bodies. During application, avoid allowing
the product to fall on leaves or green parts of the stems of crops. Suspend
the application if rain is imminent.
FIRST AID:

x In the event of contact with eyes, wash them immediately with
plenty of water for 15 minutes.
x If it falls on the skin, wash with plenty soap and water.

x If ingested, drink water to dilute it. Call a doctor immediately or
bring the patient to a doctor and show them a copy of this
label.
ANTIDOTE:

There is no specific antidote. Apply a gastric wash, avoiding pulmonary
aspiration and administer symptomatic treatment. Possible damage to
mucus membranes.

TOXICOLOGICAL
CATEGORY IV
SLIGHTLY TOXIC
CAUTION ANNEX 115

RECOMMENDATIONS FOR AERIAL APPLICATION

- Volume / ha: 50-75 L/ha
- Size of droplets: 250-400 microns
- Number of drops: For a systemic product such as Roundup, a few
large drops are preferable, roughly 20 per cm 2(square centimeter)

- Nozzles and micronairs should not exceed 75% of the wingspan to
avoid displacement of droplets by the wing vortex.
- Equipment pressure: With Roundup, pressures of 20 and 30 psi
should be used.

- Environmental conditions
Outside temperature: No greater than 29° Centigrade.
Relative humidity: >60%

Windspeed: <7 Km/hour. – 1.94 m/s
Apply after ensuring that there are no thermal inversions
(temperature differences between the ground and the air).
- Flight altitude: 2 m. above the crop.

- Higher altitudes increase the risk of drift, and increase the
evaporation of the mixture applied.
- Width of pass: Depends on the aircraft and the equipment used
(between 14 and 18 m)

- Nozzles: D-12 diffuser 45 or 56 at an angle of 135° toward the
back or fan nozzles: 6504 – 8004 – 1104 (Spraying system)

COMPATIBILITY

Do not mix ROUNDUP SL with contact herbicides. The tank mixtures
of residual herbicides formulated as soluble powders or concentrated
suspensions can reduce the efficacy on perennial weeds.

RESPONSIBILITY INFORMATION
*The manufacturer guarantees the that physio-chemical properties of the
product correspond to what is listed, as noted on this label and that

through the Official Sales Registry it has been verified to be suitable for
the purposes recommended here, according to the indications for use.ANNEX 115ANNEX 115 ANNEX 116

Ecuador Ranger 480 Label ANNEX 116

RANGER 480 – Herbicide by MONSANTO

“READ THE LABEL BEFORE USING THE PRODUCT”
“KEEP IN A CLOSED PLACE OUT OF THE REACH OF
CHILDREN”

NON-SELECTIVE, POST-EMERGENT, SYSTEMIC HERBICIDE
WATER-SOLUABLE CONCENTRATE (SL) – AGRICULTURAL
USE

Active Ingredient:
Glyphosate………………………………………………….480 g/L

RANGER 480 is a non-selective herbicide with post-emergent
application and systemic action for the control of most annual and
perennial weeds.

PRECAUTIONS: This product is harmful in the case of inhalation or
ingestion. Prolonged contact with the eyes or skin causes irritation.
During the preparation and use of the product, DO NOT SMOKE,

EAT or DRINK. Avoid: Inhalation or ingestion and direct contact with
clothes, skin, eyes and mouth. Wear: Proper protective clothing, such as
overalls, gloves, rubber boots, and a mask. BEFORE EATING,
DRINKING or SMOKING: Remove contaminated clothes, wash

exposed skin well with plenty of water.

WARNINGS: Do not contaminate with the product, its waste or empty
containers: lakes, rivers, ponds, streams and other water sources. StoreANNEX 116

the product in the original, labeled package, and keep it hermetically
sealed. Do not use this package for any other purpose. Do not re-package

or deposit the contents in other packages. Store the product in a safe place,
away from food, children, and animals. Avoid allowing the spray to be
carried by the wind into neighboring areas or crops. Before destroying the
package, rinse it with water (quarter part of the contents) at least three

times, and then deposit the rest in the application equipment. Bury the
empty, destroyed package in a pit designed for that purpose.

FIRST AID INSTRUCTIONS AND ADVICE FOR DOCTORS: In

the event of inhalation, keep the person in a ventilated place away from
the application site. In the event of ingestion, make the patient drink two
glasses of water, and do not induce vomiting. In the event of
contamination to the skin or clothing, remove contaminated clothing and

wash the affected part with plenty of soap and water. In case of contact
with the eyes, wash them thoroughly with water for at least 15 minutes
and under a continuous flow. Consult a doctor and show this label.
SYMPTOMS: External contact causes burning or irritation of the eyes,

mucous membranes, mouth or throat. If ingested, the early symptoms can
include nausea and an upset stomach. DIAGNOSIS: A blood and urine
exam can help to confirm the absorption of the product. The results can
be confirmed by analytic methods. TREATMENT: There is no specific

antidote. Treatment is symptomatic. Do not induce vomiting, and do not
give an unconscious person anything to drink.

For more information, contact: BBR Representaciones Co. Ltd. Quito.

Telephone: (593-2) 2562680

FORMULATING MANUFACTURER:
C.A.C. Ltd. and S.C.A. Co.

Calle 100 No. 7-33 Torre A Piso 19
Bogota D.C., Colombia
Telephone: (57-1)-650-0650 A.A. No. 56-014

NET CONTENTS: 1 LITER
Registered trademark of Monsanto

IMPORTER AND DISTRIBUTOR

EQUAQUIMICA
GUAYAQUIL: Av. J.S. Castillo and Av. Juan Tanca Marengo, km. 1.8

REGISTERED IMPORTER: ANNEX 116

BBR Representaciones Co. Ltd.
Av. Patria and Amazonas, Edificio Patria 640,

5 Piso, Quito, Ecuador
Telephone: (593-2) 256-2680

METHOD OF USE:

Calibrate spraying equipment before application to achieve a uniform
distribution of the recommended dose. Spray weeds while they are in a
vigorous state of growth. RANGER 480 herbicide can be applied using a

full range of nozzles, such as the TJ-8001, TJ-8003, or TJ 8004 or
equivalents, which give a volume of water between 100 and 400 L/ha.
The application of RANGER 480 is recommended for:

General weed control before the planting of annual or perennial
crops: For planting without soil preparation, wait for 2 to 3 days after
application. For planting with preparation of the soil, wait between three
and seven days after the treatment to begin soil preparation.

Weed management control in perennial, established crops such as
banana (musa sapientum), African palm (elaeis guineensis), coffee
(coffea Arabica) and citrus fruits (citrus spp.): Apply using a protective

screen to avoid contact with green foliage of crops.

General weed control in non-cultivated areas, such as field borders,
irrigation channels, etc.

PREPARATION OF MIXES: Fill the spray tank halfway to capacity,
add the required quantity of RANGER 480, and continue adding water
until the tank is full.

WEED CONTROL AND DOSES: Annual weeds: 1.2 to 2 liters of
RANGER 480 per hectare. Wild Oats (Avena fatua), Cortadera (Cyperus
diffuses), golodrina (boerhaavia erecta), botoncillo (Borreria laevis),

cadillo (Canchrus brownii), guardarocio (Digitaria sanguinalis), pata de
gallina (eleusine indica), paja de patillo (Echinochloa colonum), arrocillo
(Fimbrystilis annua), caminadora (Rottboellia exaltata), falsa caminadora
(ischaemum rugosum), paja mona (Leptochloa filiformis), red rice (Oryza

sativa), bledo (Amarantilus spp), pegador (Bidens pilosa), siempreviva
(Commelina diffusa), lechosa (Euphorbia spp), clavo de agua (Jussiaea
linifolia), verdolaga (Portulaca oleracea), totora (Typha augustfolia).ANNEX 116

Perrenial weeds: 3 to 4 liters of RANGER 480 per hectare. Cortaderas

(cyperus spp), pasto para (Brachiaria mutica), batatilla (Ipomoea spp),
pasto Argentina (Cynodon dactylon), cabazonillo (Cyperus ferax), coquito
(Cyperus rotundus), pasto guinea (Panicum maximum), gramalote
(Paspalum fascicultarum), kikuyo (Pennisetum), escoba (Sida app), pasto

Johnson (Sorghum halepense): for localized applications, use solutions of
RANGER 480 of 1% to 2% with spray nozzles TJ-8001 and TJ-8002,
respectively.

Frequency of application: RANGER 480 can be applied at any time of
cultivation and as many times as necessary; therefore, there is no
restriction. Interval between last application and harvest: 7 days.
Period of reentry for people and animals into the treated areas: 2

hours after the product has been applied, when it has penetrated the
foliage.

COMPATIBILITY: Do not mix RANGER 480 with contact herbicides.

Mixtures with residual herbicides, such as substitute urea, triazines, etc,
can reduce their activity. Do not add surfactant, as the appropriate
quantity is already contained in this product.

Registration MAG: 039-H

Lot No. 17 05 03

Date of formulation: May 2007

Expiry Date: May 2012

This herbicide is subject to the requirements outlined in Law No. 073,
Official Registry 442 of 1990 – 05 – 22

CONSUMER ADVISORY: The manufacturer guarantees the

composition and quality of the product. The manufacturer is not
responsible for imprudent, excessive or unnecessary use of the product on
the part of the consumer.

CATEGORY IVANNEX 116ANNEX 116 ANNEX 117

Germany Roundup TURBO Label ANNEX 117

[PAGE 29]

¾ 680 g/kg glyphosate
¾ Water soluble granular formulation
¾ Ammonium salt formulated on the basis of
patented Transorb technology

[…]

[PAGE 30]

[…]

Warning Xi

Risk of serious eye

damage
irritant
Keep away from food,
N
drinks and animal feed.

Hazardous to the environment ANNEX 117

D OSIERUNGSTABELLE F ÜRDEENINSATZ VORoundupp UltraMax IN GETRAGENE SPRITZGER ÄTEN

› Bei Anw®ndungen mit der Rückenspritze ist i. d. R. eine 3%i ge Spritzlösung ausreichend, d. h. 30 ml
Roundup UltraMax pro Liter Spritzbrühe.
Die Aufwandmenge ändert sich entsprechend der Unkrautzusammensetzung .
› ®
› Bei schwerbekäm pfbaren Unkräutern kann entweder die Roundu p UltraMax Aufwandmen ge erhöht
oder die Spritzgeschwindigkeit muss reduziert werden.

Aufwandmenge 4L/ha entsprechen 0 ,4mL/m2 Aufwandmenge 8 L/ha entsprechen 0 ,8mL/m
z. B. gegen ein- und zweikeimblättrige gegen schwerbekämpfbare Unkräuter z. B.

Unkräuter (s. a. Wirkungsspektrum) Winde-Arten

Wasser- Roundup® Zu behandelnde Wasser- Roundup® Zu behandelnde
aufwandmenge UltraMax Fläche aufwandmenge UltraMax Fläche
[L] [mL] m 2 [L] [mL] m 2 H ERBIZID ZUR ANWENDUNG AUF DEM A CKER - UND

015 3 7 1 30 37,5 G RÜNLAND , AUF S TILLLEGUNGSFLÄ CHEN , IM W EIN -

0 025 6 1 025 6 7 UND KERNOBSTBAU , AUF N ICHTKULTURLAND UND
3 90 225 3 90 112,5
4 120 300 0 0 5 2 41 1 AUF W EGEN UND P LÄTZEN .

5 150 375 5 150 187,5
10 300 750 10 300 375
680 g/kg Glyphosat

wasserlösliche Granulatformulierung

Ammoniumsalz, auf Basis der patentierten
® › Transorb™ Technologie formuliert
D OSIERUNGSTABELLE FÜRDEEINSATZ VORoundupp UltraMax IN HANDGETRAGENESTREI CHGERÄTEN
Regenfest nach 1 Stunde
® ›
Alternativ zur Spritzanwendung kann Roundup UltraMax im Streichverfahren mit einer 33%igen Lösung Umbruch bei Quecke nach 5 Tagen möglich
› genutzt werden. ›
› Wirksamkeit bis in die Wurzelspitzen
› Dies empfiehlt sich besonders bei schwerbekämpfbaren Unkrägehölzen oder zur Stock - Keine Abstandsauflagen zu Oberflächen-
ausschlagbehandlung. ›
Die maximal zugelassene Aufwandmenge beträgt 0,8mL Roundup UltraMax/m . gewässern (Ländervorgaben beachten)

Keine Abstandsauflage zu Nichtzielpflanzen.
Wasser- Roundup® Gesamtlösung ›
aufwandmenge UltraMax In Gebieten ohne ausreichenden Anteil an
[mL] [mL] [mL] Kleinstrukturen für Saumstrukturen > 3 m

50% Antidrift, sonst 20m Abstand
Streichstabfüllung 0,4L 260 130 390
Streichstabfüllung 0,6L 400 200 600
1L Vorratslösung 666 333 999

28 29 ANNEX 117

Wirkstoff
680 g/kg Glyphosat Ein Herbizid von Monsanto A UFWANDMENGEN BODENBEARBEITUNG
als Glyphosat Salz (747 g/kg)
®
Die Produkt-Aufwandmengen richten sic h Ab 1 Tag beieinjährigen Unkräuter n bis
Formulierung Roundup TURBO › nach Art und Größe der zu bekäm pfenden› zum 4-Blatt-Stadium mö glich.
wasserlösliches Gra(SG)t
I. A LLGEMEINE S Unkräuter. Ab 5 Tagen z. B. beiQuecke oder aus-
Niedrige Wasser-Aufwandmengen bis › dauernden Unkräutern möglich, auch wenn
Packungsgrößen ›
max. 200 l/ha beg ünstigen die Wirkung. Symptome noch nicht sichtbar sind.
10 kg W IRKUNGSWEISE Ab 7 Tagen bei ungünstigen Bedingunge n
Hinweise ® › (z.B. kühle Witterung) möglich.
Roundup TURBO ist ein nichtselektise
Gefahr ernster Augensch äden Blattherbizid m it system ischer W irkung. W IRKUNGSGESCHWINDIGKEIT
› Giftig für Wasseror ganismen, kann in Ge wässern
› längerfristig schädliche Wirkung haben. Es wird über die gr ünen Teile der Pflanz e Je aktiver die P flanzen wachsen , umSCHÜTTGEWICH T
Darf nicht in die Hände von Kindern gelangen . aufgenommen und mit Hil fe des Saft- ®
› Bei der Arbeit nicht essen , trinken, rauchen. stromes in der gesamten Pflanze, ein - schneller wird der Wirkstoff in der Pflanz1 kg Roundup TURBO = ca. 1,70 l
› Von Nahrungsmitteln, Getränken Xi verteilt. Bei normalw üchsiger Witterun g (nach einmaligem Aufklopfen des Messbechers)
› und Futtermitteln fernhalten. schließlich der unterirdischen P flanzen- ®
Bei Berührun g mit den Au gen teile (Rh izome), verte ilt. D aher w erden tritt inn erhalb v on ca. e®ner W oche die1 l = ca. 590 g Roun dup TURBO
› gründlich mit Wasser abspülen  sichtbare W irkung von Roundu p TURBO
und Arzt konsult ieren. neben einj ährigen Unkraut- und Ungras - ein. Die Pflanzen welken, werden gelb und
Abfälle und Behälter müssen in reizend arten auch mehrjährige Unkraut- und
› gesicherter Weise beseiti gt werden. Ungrasarten nachhaltig bek ämpft. vertrocknen später vollständi g. Ein witte -
rungsbedingt langsamer Eintritt vo- Wir
› Schutzbrille/Gesichtsschutz tragen. kungssymptomen hat auf die Nachhalti g-
› Bei Verschlucken sofort ärztlichen ANWENDUNGSBEDIN GUNGEN
Rat einholen und Verpackun g oder keit der Wirkung keinen Einfluss .
Etikett vorzeigen. Roundup ® TURBO k ann w ährend der
› Zur Vermeidung einer Kontaminationeltgefährlic h
der Umwelt geeigneten Behälter verwenden. gesamten Ve getationsperiode e ingesetzt N ÜTZLIN GE
› Jeden unn ötigen Kontakt mit dem Mittel vermeiden. werden. Der Einsatz kann sogar vor oder
Missbrauch kann zu Gesundheitsschäden führen. nach kurzen Nachtfrösten bis -4°C e-fol NB6641 Das Mittel wird bis zu der höchste n
› Dicht abschließende Schutzbgen beim Um gang
mit dem unverd ünnten Mittel. gen. durch die Zulassung festgelegten Aufwand-
Es ist darauf zu achten, dass die zu be- menge oder Anwendun gskonzentration,
Zulassungsinhaber und Vertrieb kämpfenden Unkrautarten gen ügend auf- falls eine Aufwandmenge nicht vorgesehen

Monsanto A grar Deutschland Gmb H nahmefähige Blattmassegebildet habe n ist, als nicht bienenge fährlich eingestuft
Vogelsanger Weg 9 1 müssen und ausreichend benetzt werden . (B4).
D-40470 Düsseldorf
Tel.: 0211-36 75 - 0 Zur nachhaltigen Bekämpfung von har-
NNrr. 44996600-0000 näckigen, breitblättri gen Unkräutern wird NN165 Das Mittel wird als nicht schädi gend
Notfallnummer die Anwendung im Bl ühstadium empfoh- für Populationen derPoecilus cupreus

Telefon: (Deutschland ) 0211-36 75 - 0 len. Bei anhaltender Trockenheit oder bei (Laufkäfer) eingestuft.
Telefon: (Belgien) 0032- 3 -5 68.512 3 hohen Tem peraturen, verbunden mit ex-
trem niedri ger Luftfeuchti gkeit, können NN170 Das Mittel wird als nicht schädigend für

Entsorgung Wirkstoffaufnahme und -ableitun g beein- Populationen der AChrysoperla carnea
Leere Verpackun gen nicht weiterverwenden. Leere und trächtigt werden. Bei diesen, wie huc (Florfliege) eingestuft.
sorgfältig gereinigte Verpackungen an den autorisierten
Sammelstellen im Rahmen des IVA-Entsorgungskonzeptes anderen n icht opt imalen Anwendun gs-
PAMIRA ab geben. Informationen zu Zeitpunkt und Ort bedingungen sind Verringerungen de r NN1842 Das Mittel wird als nicht sch ädigend
der Sammlungen erhalten Sie vonändler.H empfohlenen Aufwandmen ge nicht an ge- für Populationen der Aphidius rhopa-
Produktreste nicht dem Hausmüll beigeben, sondern in
raten. Anwendung nach Regen oder bei losiphiBrackwespe) eingestu ft.
Originalverpackun gen bei den entsor gungspflichti gen Tau auf feuchtem, aber nicht trop fnassen
Körperschaften anliefern. Weitere Ausk ünfte erhalten Sie Unkrautbestand möglich!
bei der Stadt- oder Kreisverwaltung.

30 31 ANNEX 118

Germany Roundup UltraMax Label ANNEX 118

[PAGE 5]

The new standard. Roundup® UltraMax belongs to
the latest Roundup® generation.

[…]
¾ 450 g/L glyphosate
¾ Liquid formulation
¾ Isopropylamine salt with a new highly concentrated surfactant

[…]

[PAGE 6]

[…]

Warning

Toxic to water organisms; can have long-term toxic effects on
bodies of water.

[…]

Avoid all unnecessary contact with the agent. Misuse can lead to

health problems. ANNEX 118

®
Der neue Maßstab. Roundup UltraMax gehört zur
neuesten Roun dup - Generation.

H ERBIZID ZUR ANWENDUNG IM FREILAND AUF DEM
ACKER - UND G RÜNLAND ,IM G EMÜSEBAU , AUF STILL-

LEGUNGSFLÄCHEN , IM FORST , WEIN- UND OBSTBAU ,
AUF W EGEN UND P LÄTZEN, AUF N ICHTKULTURLAND ,

IN BAUMSCHULEN UND IM Z IERPFLANZENBAU .

› 450 g/l Glyphosat
Flüssigformulierung
› Isopropylaminsalz mit neuem hochkonzentrierten Netzmittel

› Regenfest nach 1 Stunde
› Wirksamkeit bis in die Wurzelspitzen
Hohe Anwendersicherheit,
› weder haut- noch augenreizend

› Nicht bienengefährlich und nicht fischgiftig
› Keine Abstandsauflage zu Oberflächengewässern
(Ländervorgaben beachten!)
Keine Abstandsauflage zu Nichtzielpflanzen.

In Gebieten ohne ausreichenden Anteil an Klein-
strukturen für Saumstrukturen > 3m 50% Antidrift,
sonst 20m Abstand

4 5 ANNEX 118

Wirkstoff
Ein Herbizid von Monsanto
450 g/l Glyphosat AUFWANDMENGEN NÜTZLING E
als Glyphosat Salz (607 g/l )
® NB6641
Die Produkttt-Aufwandmengen richten sich
Formulierung Roundup UltraMax › nach Art und Größe der zu bekäm pfenden Das Mittel wird bis zu der höchsten durch
wasserlösliches Konzentrat (SL) die Zulassung festgelegten Aufwandmenge
I. A LLGEMEINE S Unkräuter. bzw. Anwendungskonzentration als nicht
NiedrigeWasserr-Aufwandmengen bis max.
Packungsgrößen › bienengefährlicheingestuft (B4).
200 I/ha begünstigen die Wirkung .
1 L, 5 L, 20 L, 120 L, 640 L W IRKUNGSWEISE
W IRKUNGSGESCHWINDI GKEIT NN165
Hinweise ® Das Mittel wird als nicht sädigend f ür
Roundup UltraMax ist ein nichtselektives Populationen der ArtPoecilus cupreus
› Schädlich f ür Wasserorganismen, kanässernew Blattherbizid mit systemischer Wirkung. Es Je aktiver die Pflanzen wachse, um so
längerfristi g schädliche Wirkun gen haben. (Laufkäfer) eingestuft.
Abfälle und Behälter müssgesicherter Weis e wird über die grünen Teile der Pflanze auf- schneller wird der Wirksff in der P flanze
› beseitigt werden. genommen und mit Hilfe des Saftstrome s verteilt. Bei normalwüchsger Witterun g
Jeden unnöti gen Kontakt mit dem Mittel vermeiden. in der gesamten Pflanze, einschließlich der tritt innerhalb von ca. einer Woche die NN17 0
› Missbrauch kann zu Gesundheitsschäden .ühren ® Das Mittel wird als nicht sädigend f ür
Für Kinder unzug änglich aufbewahren. unterirdischen Pflanzenteile(Rhizome ), sichtbare Wirkung von Roundp UltraMax
› Zur Vermeidun g von Risiken für Mensch und Umwelt verteilt. Daher werden neben einj ährigen ein. Die Pflanzen welken, werden gelb und Populationen der ArChrysoperla carnea
› ist die Gebrauchsanleitun g einzuhalten . (Florfliege) eingestuft.
Universal-Schutzhandschuhflanzenschutz) trage n Unkraut- und Ungrasarten auch mehrjähri - vertrocknen später vollständig. Ein witte -
› beim Um gang mit dem unverdünnten .ittel ge Unkraut- und Un grasarten nachhalt ig rungsbedingt langsamer E intritt von W ir-
Standardschutzanzu g (Pflanzenschutz) und festes bekämpft. kungssymptomen hat au f die Nachhaltig -ODENBEARBEIT UNG

Schuhwerk (z. B. Gummistie fel) tragen bei der keit der Wirkung keinen Einfluss .
Ausbringung/Handhabung des anwendufertige n ANWENDUNGSBEDIN GUNGEN › Ab 1 Ta g bei einj. Unkr äutern bis 4-Blatt-
Mittels. stadium möglich.
› Frostfrei lagern . Ab 7 Ta ge z. B. bei Quecke oder aus -
› Hohe Anwenders icherheit, nicht haut- und augenre izend Roundup UltraMax kann während der ge- ›
› Keine Bodenwirkun g dauernden Unkräutern möglich.
Nicht sch ädlich f ür viele n ützliche Insekte n samten Vegetationsperiode eingesetz t Ab 10 Ta ge bei un günstigen Bedingungen
› Nicht bienengef ährlich werden. Der E insatz kann so gar vor oder ›
› Keine Wasserschutz gebietsaufla ge nach kurzen Nachtfrösten bis -4 °C erfol- (z. B. kühle Witterung) m öglich.

gen. Es ist darauf zu achten, dass die zu be-
Zulassungsinhaber und Vertrieb kämpfenden Unkrautarten gen ügend auf-
Monsanto Agrar DeutschlGmbH
Vogelsanger Weg 91 nahmefähige Blattmasse gebildet haben
D-40470 D üsseldorf müssen und ausreichend benetzt werden .
Tel.: 0211-36 75 - 0 Zur nachhaltigen Bekämpfung von hart - II. A NWENDUNGSGEBIETE
NNrr. 55119911-0000
näckigen, breitblättri gen Unkräutern wird
Notfallnummer die Anwendung im Bl ühstadium empfoh- VON DER Z ULASSUNGSBEHÖRDE FESTGESETZT E A NWENDUNGSGEBIETE

Telefon: (Deutschland ) 0211-36 75 - 0 len. Bei anhaltender Trockenheit oder bei
Telefon: (Bel gien) 0032- 3 -5 68.512 3 hohen Temperaturen, verbunden mit extrem
Schadorganismus/Zweck
Entsorgung niedriger Luftfeuchti gkeit, können Wirk - Kultur/Objekt
stoffaufnahme und -ableitun g beeinträch-
Leere Verpackungen n icht weiterverwenden. Leere und sorg - tigt werden. Bei diesen, wie auch andere n
fältig gespülte Verpackun gen an den autorisierten Sammel- Ackerbaukulturen Ein- und zweikeimblättrige Unkräuter
stellen im Rahmen des IVA-Egungskonzeptes PAMIR A nicht optimalen Anwendungsbedingungen Baumschulgehölzpflanzen Ein- und zweikeimblättrige Unkräuter
abgeben. In formationen zu Zeitpunkt und Ort der Samm- sind Verringerungen der emp fohlenen Futtererbse, Ackerbohne Sikkation
lungen erhalten Sie von Ihrem Händler. Produktreste nicht
dem Hausmüll bei geben, sondern ginalverpackun gen Aufwandmenge nicht an geraten. Anwen- Gemüsekulturen Ein- und zweikeimblättrige Unkräuter
bei den entsorgungspflichtiörperschaften anliefern. dung nach Regen oder bei Tau au f feuch- Lagergetreide (Gerste, Hafer, Roggen, TriEin- und zweikeimbl ättrige Unkräuter, Sikkatio n
Weitere A uskünfte erhalten Si e bei der St adt- oder Kr eis-tem, aber nicht trop fnassen Unkraut -
verwaltun g. Getreide (Gerste, Hafer, Ro ggen, TriticaEin- und zweikeimblättrige Unkräuter
bestand möglich!

6 7 ANNEX 119

Italy Roundup 450 Plus ANNEX 119

Roundup 450Plus

[...]

Classification: R52-53 (harmful to aquatic organisms, it can cause

negative effects for the aquatic environment in the long term)

[…]

15 MINUTES 30 MINUTES 60 MINUTES

After 60 minutes, the lethal dose of Roundup

is already inside the plant. ANNEX 119

Roundup 450Plus

La Differenza Inizia Dall’etichetta
In Questa Sezione

-- -

11418 del 23 luglio 2002

-

25% PIU’ CONCENTRTO RISPETTO AI COMUNI 360 g/l

NUOVA FORMULA:

BENEFICI E VANTAGGI DELLA TECNOLOGIA TRANSORB II:

„ANNEX 119

„

„

„

„

„

„

„

„

- ANNEX 120

Japan Roundup Agrochemical Registration ANNEX 120



Ministry of Agriculture, Forestry and Fisheries, Agrochemical Registration

Content
2. Roundup (sold only in Hokkaido): Agrochemical Registration Number, Ministry of
Agriculture, Forestry and Fisheries Registration No. 14360 (As of April 2005)

Cautions on effects and chemical damage

16) Serious chemical damage arises when the chemical solution is placed in contact
with crops or useful plants, so be careful that they are not exposed.
(18) Be careful not to make errors in the usage amount, usage period, usage method, etc.
when using this product and in the case of first-time use, in particular, it is best to
have guidance from affiliated institutions, such as a pest control office.
(21) Sufficient caution is to be exercised so that this product is not dispersed or allowed

to flow into a water supply or culturing pond.

 ANNEX 120

㪉㪅䊤䉡䊮䊄䉝䉾䊒䋨ർᶏ㆏䈱䉂䈪⽼ᄁ䋩 㪑ㄘ⮎⊓㍳⇟ภ㩷ㄘᨋ᳓↥⋭⊓㍳╙㪈’㪊㪍㪇ภᚑ㪈㪎ᐕ㪇’⃻࿷䋩㩷


㩷 ᢔᏓಣℂ㩷

૶↪㊂ 䉫䊥䊖䉰
૞‛ฬ෶䈲㩷 ᧄ೷䈱 ૶↪ᣇ 䊷䊃䉕฽
ㆡ↪㔀⨲ฬ ૶↪ᤨᦼ ૶↪࿁ 䉃ㄘ⮎
ㆡ↪႐ᚲ ⮎㊂ Ꮧ㉼᳓㊂ ᢙ㩷 ᴺ 䈱✚૶
↪࿁ᢙ

㔀⨲↢⢒⋓ᦼ㩷 ዋ㊂ᢔᏓ
䉴䉩䊅 㩷 ‘䈚෼ⓠ㪎ᣣ೨䉁 㪉㪇㪇㪇㫄㪣㪆㪈㪇㪉㪌䌾
䈪㩷 㪌㪇㪣㪆㪈㪇㪸
㪉㪌㪇䌾
৻ᐕ↢㔀⨲ 㔀⨲↢⢒ᦼ㩷
ᨐ᮸㘃㩷 ‘䈚෼ⓠ㪎ᣣ೨䉁 㪌㪇㪇㫄㪣㪆㪈㪇㪸
䋨䊌䉟䊅䉾䊒䊦 䈪 㪌㪇㪇䌾 㪊࿁એౝ 㪊࿁એౝ㩷
䉕㒰䈒䋩㩷 ᄙᐕ↢㔀⨲ 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸
䈧䉎ᕈᄙᐕ↢ ↢⢒⋓ᦼએ㒠㩷 ㅢᏱᢔᏓ
㪌㪇䌾
㔀⨲㩷 䋨ᄐ䌾⑺ᦼ䋩㩷㩷 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸㪇㪣㪆㪈㪇㪸
䉰䉰㘃㩷 ‘䈚෼ⓠ㪎ᣣ೨䉁 ዋ㊂ᢔᏓ
⪭⪲㔀䈎䉖ᧁ 䈪㩷 㪉㪌䌾
㔀⨲↢⢒ᦼ㩷
৻ᐕ↢㔀⨲ 㪉㪌㪇䌾 㪌㪇㪣㪆㪈㪇㪸
᳓↰⠹⿠೨ 㩷 䋨⠹⿠೨䈪䈲⠹⿠ 㪌㪇㪇㫄㪣㪆㪈㪇㪸 ᳓↰⇜ ᳓↰⇜
᳓↰⇜⇎㩷 䈱㪈㪇ᣣએ೨䋩䋨᳓ ⇎㪑㪉࿁એ ⇎㪑㪉࿁એ
᳓↰ಿ〔㩷㩷 ᄙᐕ↢㔀⨲ ↰⇜⇎䈲෼ⓠ㪈’ 㪌㪇㪇䌾
ᣣ೨䉁䈪䋩 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸 ౝ㩷 ౝ㩷
⒖ᬀ᳓Ⓑ㩷 䈠䈱ઁ 䈠䈱ઁ㩷
㪑㪈࿁ 㪑㪈࿁
䋨ਇ⠹⿠ᩱ Ḗ᳓೨㪊㪇䌾㪌ᣣ 㪌㪇㪣㪆㪈㪇㪸
ၭ䋩
⋥᠞᳓Ⓑ㩷 㔀⨲↢⢒ᦼ㩷
䋨ੇ↰㩷 ৻ᐕ↢෸䈶㩷 䋨⠹⿠⋥ᓟ䌾಴⧘ 㪌㪇㪇㫄㪣㪆㪈㪇㪸
ᄙᐕ↢㔀⨲ ዋ㊂ᢔᏓ
⠹⿠ᩱၭ䋩 㩷 ೨䋩㩷 㪉㪌䌾 䋱࿁
⋥᠞᳓Ⓑ㩷 㔀⨲↢⢒ᦼ㩷 㪌㪇㪣㪆㪈㪇㪸 㪉࿁એౝ
䋨ੇ↰㩷 䋨䈲⒳㪊㪇ᣣ೨䌾಴
ਇ⠹⿠ᩱၭ䋩 ⧘೨䋩 㔀⨲ᧁ
⪲㩷
䈣䈇䈝 㪉࿁એౝ ᢔᏓ
⼺㘃䋨⒳ታ䇮㩷
䈢䈣䈚䈣䈇 㔀⨲↢⢒ᦼ㩷
䈝䇮䉌䈦䈎⁄ 䋨䈲⒳㪈㪇ᣣએ೨䋩

䈇䉕㒰䈒䋩㩷
䉨ƒ䊔¤㩷 ⇌࿾৻ᐕ↢㩷 㪉㪌㪇䌾
䈲䈒'䈇㩷 㔀⨲㩷 㪌㪇㪇㫄㪣㪆㪈㪇㪸
㔀⨲↢⢒ᦼ㩷
䈣䈇“䉖㩷 䋨⠹⿠㪎ᣣએ೨䋩
䈎䉖䈚䉊 㩷
‹㘃㩷 ㅢᏱᢔᏓ 䋱࿁ 䋱࿁

䋨›‹䉕㒰䈒䋩 㔀⨲↢⢒ᦼ㩷 㪌㪇䌾
›‹㩷 䋨⠹⿠㪈㪇ᣣએ೨䋩 㪈㪇㪇㪣㪆㪈㪇㪸
'fifl䈐䈶㩷 ⇌࿾㩷 㪌㪇㪇䌾 ዋ㊂ᢔᏓ
䋨–ᬀ†䋩㩷 ᄙᐕ↢㔀⨲ 㩷 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸㪌䌾

㔀⨲↢⢒ᦼ㩷 㪌㪇㪣㪆㪈㪇㪸
‡ 䋨–䌾ᄐᦼ·‘䈚䇮
៰ណ㪎ᣣ೨䉁䈪䋩 㪉㪌㪇䌾
৻ᐕ↢㔀⨲ 㪌㪇㪇㫄㪣㪆㪈㪇㪸 ભ⠹↰㪑㪉 ભ⠹↰㪑㪉
•ᧁ 㔀⨲↢⢒ᦼ㩷
‚…ભ⠹↰ 㩷 䋨‘䈚‚䈪䈲„⧘ ࿁એౝ ࿁એౝ㩷
೨෶䈲ᄐ”ᓟ„ ‚…• ‚…•
㪌㪇㪇䌾 ᧁ㪑’࿁એ ᧁ㪑’࿁એ
‚…ભ⠹↰ 㩷 ᄙᐕ↢㔀⨲ 㩷 ⧘೨䋩 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸 ౝ ౝ

৻ᐕ↢㔀⨲ ⠹⿠‰ᚑ೨㩷 㪉㪌㪇䌾
㔀⨲↢⢒ᦼ㩷 㪌㪇㪇㫄㪣㪆㪈㪇㪸ANNEX 120

䋨˜¯…‰ᚑ䈱㪈㪇 㪌㪇㪇䌾
ᄙᐕ↢㔀⨲ 㩷
ᣣએ೨䋩㩷 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸
´ˆ䇮⨲࿾㩷 ⠹⿠˘࿾ᓟ㩷
䋨˜¯…‰ᚑ䋩 ৻ᐕ↢෸䈶㩷 䋨㔀⨲„↢˙ᦼ䋩㩷 㪉㪌㪇䌾 㪈࿁ 㪈࿁
ᄙᐕ↢㔀⨲ 䈲⒳㪈㪇ᣣ೨䌾䈲 㪌㪇㪇㫄㪣㪆㪈㪇㪸

⒳¨ᣣ
ዋ㊂ᢔᏓ
䈜˚…¸䈱䈐㩷 䉴䉴䉨䇮㩷䉰䉰 㔀⨲↢⢒ᦼ㩷 㪌㪇㪇㫄㪣㪆㪈㪇㪈㪌䌾
䋨ਅಿ˝˛↪䋩㩷㘃䇮ˇ—╬䈱 䋨㪌䌾㪍᦬䋩 㪉㪇㪣㪆㪈㪇㪸
㪊࿁એౝ 㪊࿁એౝ
‰ᨋ࿾㩷 ᄙᐕ↢㔀⨲㩷 ↢⢒⋓ᦼએ㒠㩷 ዋ㊂ᢔᏓ
䋨࿾䈗䈚䉌†䋩㩷⪭⪲㔀䈎䉖ᧁ 䋨ᄐ䌾⑺ᦼ䋩㩷 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸䌾
㪊㪇㪣㪆㪈㪇㪸


㩷 ႣᏓಣℂ㩷㩷
䉫䊥䊖䉰

૞‛ฬ෶䈲㩷 ᧄ೷䈱 ૶↪ᣇ 䊷䊃䉕฽
ㆡ↪႐ᚲ ㆡ↪㔀⨲ฬ ૶↪ᤨᦼ Ꮧ㉼୚ᢙ ૶↪ᶧ㊂ ૶↪࿁ ᴺ 䉃ㄘ⮎
ᢙ 䈱✚૶
↪࿁ᢙ

䈎䉖䈐䈧䇮㩷 㔀⨲↢⢒ᦼ㩷
˝䉖䈗䇮䈭䈚䇮㩷 ‘䈚෼ⓠ㪎ᣣ೨䉁 㪊࿁એౝ 㪊࿁એౝ 㩷
䈎䈐䇮䈹䈬fl䇮㩷 䈪㩷
䈒˝䇮䉅䉅㩷
৻ᐕ↢෸䈶㩷 㪊䌾
ᄙᐕ↢㔀⨲ 㔀⨲↢⢒ᦼ㩷 㪊䌾㪍୚ 㪍㪣㪆㪈㪇㪸
᳓↰⇜⇎ ‘䈚෼ⓠ㪈’ᣣ೨䉁 㪉࿁એౝ 㔀⨲ᧁ 㪉࿁એౝ
䈪 ⪲㩷
‚ ’࿁એౝ ႣᏓ ’࿁એౝ

⦼䋨䊤䊐╬䋩
䉴䉴䉨䇮㩷䉰䉰 㔀⨲↢⢒ᦼ
䈜˚…¸䈱䈐㩷 㘃䇮ˇ—╬䈱 㪊࿁એౝ 㪊࿁એౝ
䋨ਅಿ˝˛↪䋩 ᄙᐕ↢㔀⨲㩷 㪊୚ 㪊㪣㪆㪈㪇㪸

⪭⪲㔀䈎䉖ᧁ

㩷 ᵈ౉ಣℂ㩷㩷

䉫䊥䊖䉰
૞‛ฬ෶ ᧄ೷䈱 䊷䊃䉕฽
䈲㩷 ㆡ↪㔀⨲ฬ ૶↪ᤨᦼ Ꮧ㉼୚ ૶↪ᶧ㊂ ૶↪࿁ ૶↪ᣇ 䉃ㄘ⮎
ㆡ↪႐ᚲ ᢙ ᢙ ᴺ 䈱✚૶

↪࿁ᢙ
–ᦼ෶䈲⑺ ᩣ㗡ᵈ
ˇ— ᦼ 㩷 㪈䌾㪉㫄㪣㪆ᩣ ౉ಣℂ

䈧䉎Æ㩷
૶↪㊂䋨㫄㪣㪆ᩣ䋩㩷
ˇ—…䊐䉳╬㩷 䋨㪉㪅㪇㪺㫄એਅ㩷㪇㪅㪌ª㩷 䈧䉎ᵈ
䈱䈧䉎㘃㩷 –ᦼ䌾⑺ᦼ ේᶧ෶ 㪉㪅㪈䌾㪊㪅㪇㪺㫄㩷㪈㪅㪇㩷 ౉ಣℂ
ᨋ࿾㩷 䈲㩷 㪊㪅㪈䌾’㪅㪇㪺㫄㩷㪈㪅㪄㩷 㪄

㪉୚ᶧ ’㪅㪈䌾㪌㪅㪇㪺㫄㩷㪉㪅㪇㩷䋩㩷
㪈㫄㪣㪆䊱ᢙ㩷
⪭⪲㔀䈎䉖ᧁ㩷 䋨᮸Æ㩷 䊱ᚲᢙ䋩㩷
㑆બ䈜䉎㩷 㪊᦬䌾㪈㪇᦬ 䋨㪈㪇㪺㫄એਅ㩷㪉䌾㪊ª Øᧁᵈ
౉ಣℂ
䈜˚䇮¸䈱䈐 㩷 㪈㪇䌾㪉㪇㪺㫄㩷’䌾㪏ª㩷
㪉㪇㪺㫄એŁ㩷 㪈㪇㩷䋩㩷

㩷 ㄘ⠹࿾એ`䈪䈱ᢔᏓಣℂ㩷㩷
䉫䊥䊖䉰
૶↪㊂ ᧄ೷䈱 䊷䊃䉕฽
૞‛ฬ෶䈲㩷 ㆡ↪㔀⨲ฬ ૶↪ᤨᦼ ૶↪࿁ ૶↪ᣇ 䉃ㄘ⮎
ㆡ↪႐ᚲ ᴺ
⮎㊂ Ꮧ㉼᳓㊂ ᢙ 䈱✚૶
↪࿁ᢙ ANNEX 120

৻ᐕ↢㔀⨲ 㩷 㔀⨲↢⢒ᦼ 㩷 㪌㪇㪇㫄㪣㪆㪈㪇㪸㩷
ᄙᐕ↢㔀⨲ 㪈㪇㪇㪇㫄㪣㪆㪈㪇㪸ᢔᏓ
º࿦䇮ႇfifl䇮㩷 㪌㪇䌾
㚢ゞ႐䇮㆏ ˇ—╬䈱䈧䉎 㪈㪇㪇㪣㪆㪈㪇㪸
〝䇮㩷 ᕈ㩷 㪈㪇㪇㪇䌾 㔀⨲ᧁ
æേ႐䇮ቛ ᄙᐕ↢㔀⨲㩷 ↢⢒⋓ᦼએ㒠 㪉㪇㪇㪇㫄㪣㪆㪈㪇㪸ᢔᏓ 㪊࿁એౝ ⪲㩷 㪊࿁એౝ 㩷
࿾䇮㩷 䉰䉰㘃㩷 㪉㪌䌾 ᢔᏓ
⪭⪲㔀䈎䉖ᧁ 㪌㪇㪣㪆㪈㪇㪸
䈱˝㕙䇮ı㆏ ዋ㊂ᢔᏓ

䉴䉩䊅 ↢⢒⋓ᦼ 㪉㪇㪇㪇㫄㪣㪆㪈㪇㪉㪌䌾
㪌㪇㪣㪆㪈㪇㪸

㩷 ㄘ⠹࿾એ`䈪䈱ႣᏓಣℂ㩷㩷
䉫䊥䊖䉰
ᧄ೷䈱 䊷䊃䉕฽
૞‛ฬ෶䈲㩷 ㆡ↪㔀⨲ฬ ૶↪ᤨᦼ Ꮧ㉼୚ᢙ ૶↪ᶧ㊂ ૶↪࿁ ૶↪ᣇ 䉃ㄘ⮎
ㆡ↪႐ᚲ ᢙ ᴺ 䈱✚૶

↪࿁ᢙ
º࿦䇮ႇfifl䇮㩷
㚢ゞ႐䇮㆏
〝䇮㩷
æേ႐䇮ቛ ৻ᐕ↢෸䈶㩷 㔀⨲↢⢒ᦼ 㩷 㪊୚ 㪊䌾 㪊࿁એౝ 㔀⨲⨍ 㪊࿁એౝ㩷
࿾䇮㩷 ᄙᐕ↢㔀⨲ 㪍㪣㪆㪈㪇㪸 ⪲ႣᏓ

䈱˝㕙䇮ı㆏
╬ 㩷

㩷 Œዋ᳓㊂ಣℂ㩷㩷
䉫䊥䊖䉰
૶↪㊂ ᧄ೷䈱 䊷䊃䉕฽
૞‛ฬ෶䈲㩷 ㆡ↪㔀⨲ฬ ૶↪ᤨᦼ ૶↪࿁ ૶↪ᣇ 䉃ㄘ⮎
ㆡ↪႐ᚲ ᢙ 㩷 ᴺ
⮎㊂ Ꮧ㉼᳓㊂ 䈱✚૶
↪࿁ᢙ
䈎䉖䈐䈧䇮㩷 㔀⨲↢⢒ᦼ㩷
˝䉖䈗䇮㩷 ‘䈚෼ⓠ㪎ᣣ೨䉁 㪊࿁એౝ 㪊࿁એౝ㩷
䈭䈚㩷 䈪㩷

㔀⨲↢⢒ᦼ㩷
᳓↰⇜⇎ ‘䈚෼ⓠ㪈’ᣣ೨䉁 㪉࿁એౝ 㔀⨲ᧁ 㪉࿁એౝ
৻ᐕ↢෸䈶㩷 䈪 ’㪇㪇䌾 ’䌾 ⨍⪲ᢔ
º࿦䇮ႇfifl䇮㩷 ᄙᐕ↢㔀⨲ 㩷 㪍㪇㪇㫄㪣㪆㪈㪍㪣㪆㪈㪇㪸
㚢ゞ႐䇮㆏ Ꮣ 㩷

〝䇮㩷 㔀⨲↢⢒ᦼ 㪊࿁એౝ 㪊࿁એౝ
æേ႐䇮ቛ
࿾䇮㩷
䈱˝㕙╬


ലᨐ…⮎ł䈱ᵈø

œ㪈ß ᧄ೷䈲䉫䊥䊖䉰䊷䊃䉕฽䉃ㄘ⮎䈪䈅䉎䈱䈪䇮ઁ䈱䉫䊥䊖䉰䊷䊃䉕฽䉃ㄘ⮎䈱૶

↪࿁ᢙfiว䉒⁄䇮૞‛䈗fi䈱✚૶↪࿁ᢙ䈱▸࿐ౝ䈪૶↪䈜䉎“fi·

œ㪉ß ᵆ䈭䈬䈪Ộ䈦䈢᳓䈲ലᨐ䉕ૐਅ'⁄䉎䈱䈪ᧄ೷䈱⺞⵾䈮䈲↪䈇䈭䈇“fi·
œ㪊ß ዷ⌕೷䈱ട↪䈱ᔅⷐ䈲䈭䈇·

œ’ß ᧄ೷䈲࿯ფਛ䈪ㅦ䉇䈎䈮ਇᵴᕈൻ䈜䉎䈱䈪䇮㔀⨲䈱„↢೨ಣℂലᨐ䈲䈭䈇·

œ㪌ß ᧄ೷䈲ᢔᏓᤨ䈱㔀⨲䈱⨲ਂ䉇⨍⪲㕙Ⓧ䈏ᄢ䈐䈇⒟䇮ലᨐ䈏⏕ታfi䈭䉎䈱䈪䇮
ᢔᏓ೨䈮㔀⨲䈱࿾Łㇱ䉕ಿ˝ᛄ䉒䈭䈇“fi·

œ㪍ß ᧄ೷䈲ㅢᏱ㪉䌾㪈’ᣣ䈪ലᨐ䈏„⃻䈚䇮ലᨐቢᚑ䉁䈪'䉌䈮ᣣᢙ䉕ⷐ䈜䉎䈱䈪䇮
⺋䈦䈩ౣᢔᏓ䈚䈭䈇“fi·

œ㪎ß ࿯ფ䈏ᵹ੢䈚䈢˝䇮䈒䈝䉏䈢˝䈜䉎ᕟ䉏䈱䈅䉎ᚲ䋨䊉䊥㕙䈭䈬䋩䈪䈲ႣᏓಣℂ䈏’ANNEX 120

䉁䈚䈇·

œ㪏ß 䉴䉩䊅㒐㒰䈮㓙䈚䈩䈲䇮䉴䉩䊅䈱↢⢒ᦼ䉕ㆊ˚䈢ᤨᦼ䈪䈱ᢔᏓ෸䈶䉴䉩䊅䈏
ઁ㔀⨲䈱ਛ䈮ၒᴚ䈚䈩䈇䉎䉋fl䈭᧦ઙ䈪䈲ലᨐ䈏ഠ䉎“fi䈏䈅䉎䈱䈪䇮ㆡᦼ䈮
䉴䉩䊅䈮䈎䈎䉎䉋fl䈮ᵈø䈚䈩ᢔᏓ䈜䉎“fi·

œ㪐ß ৻ᐕ↢ᐢ⪲㔀⨲䇮䉁䈢䈲ᄙᐕ↢㔀⨲䈱fl䈤䉴䉴䉨䇮䉴䉩䊅䇮䉶䉟䉺䉦䉝䊪䉻䉼䉸
䉡╬䉕ਥኻ⽎䈮૶↪䈜䉎႐ว䇮ᚲቯ▸࿐䈱ᄙ䉄䈱⮎㊂䉕૶↪䈜䉎“fi·
œ㪈㪇ß ಣℂᓟ䋶ᤨ㑆એౝ䈱㒠㔎䈲ലᨐ䉕ૐਅ'⁄䉎“fi䈏䈅䉎䈱䈪䇮ᄤ୥䉕⦟䈒⷗Œ
䉄䈩䈎䉌ᢔᏓ䈜䉎“fi·

œ㪈㪈ß ㅢᏱᢔᏓ䈱႐ว䈲䇮ਅ⸥䈱Ꮧ㉼୚₸䈱ᢔᏓᶧ䉕⺞⵾䈚䈩ᢔᏓ䈜䉎fiଢ೑䈪䈅
䉎·৻ᐕ↢㔀⨲㩷œ㪉㪇㪇䌾’㪇㪇㩷୚ß㩷䇮ᄙᐕ↢㔀⨲㩷œ㪈㪇㪇㩷୚ß㩷䇮䈧䉎ᕈ䈱ᄙᐕ↢㔀⨲䇮
䉰䉰㘃䇮⪭⪲㔀䈎䉖ᧁ㘃㩷œ㪌㪇୚ß㩷䇮䉴䉩䊅œ㪈㪉㪅㪌䌾㪉㪌୚ß·
œ㪈㪉ß ⋥᠞᳓Ⓑ䈮૶↪䈜䉎႐ว䈲䇮Ⓑ䈱಴⧘ᓟ䈮ᢔᏓ䈜䉎fi⮎ł䈱ᕟ䉏䈏䈅䉎䈱

䈪䇮ᔅ䈝಴⧘೨䉁䈪䈮ᢔᏓ䈜䉎“fi·
œ㪈㪊ß ዋ㊂ᢔᏓ䇮Œዋ᳓㊂ಣℂ䈱႐ว䈲䇮䈠䉏䈡䉏ኾ↪䈱䊉 —䊦䉕↪䈇 䈩䇮㔀⨲ᧁ
䈱⪲㕙䈮ဋ৻䈮ᢔᏓ䈜䉎“fi·

œ㪈’ß ႣᏓಣℂ䈮䈍䈔䉎ᵈø੐㗄㩷
㪈ßᧄಣℂ䈪䈲㔀⨲䈱⪲㕙䈮ႣᏓౕེ䈪シ䈒䈭䈪䉎䉋fl䈮⋥ធႣᏓ䈜䉎“fi·
㪉ß⦼↢䈪ᢔᏓಣℂ䉕䈜䉎႐ว䇮㔀⨲fi⦼↢䈱㜞ૐ䈱Ꮕ╬䉕೑↪䈚䈩㔀⨲⨍⪲
ㇱ䈮䈱䉂ႣᏓ䈜䉎“fi·⺋䈦䈩⦼↢䈮ઃ⌕䈜䉎fi⮎ł䉕↢䈝䉎䈱䈪චಽ䈮ᵈ
ø䈜䉎“fi·

œ㪈㪌ß ᵈ౉ಣℂ䈮䈍䈔䉎ᵈø੐㗄㩷
㪈ߡ—䈮䈲ᩣ㗡䈮䊅䉺䈭䈬䈪்䉕䈧䈔䇮⮎ᶧ䈏䉋䈒䈚䉂ㄟ䉃䉋fl䈮ᵈ౉ಣℂ䈜
䉎·

㪉ߡ—䍃䊐䉳╬䈧䉎㘃䈱䈧䉎ᵈ౉ಣℂ䈮૶↪䈜䉎႐ว䈲䇮࿾㓙ㄭ䈒œ㪌㪇䌣䌭⒟‘ß
䈱㪈䌾㪊䊰ᚲ䈮䊅䉺╬䈪䈧䉎䈮்䉕䈧䈔䈩䈎䉌”ญ䈮⮎ᶧ䈏චಽઃ⌕䈜䉎䉋fl
䈮ಣℂ䈜䉎“fi·
㪊ß⪭⪲㔀䈎䉖ᧁ䈮䈲䇮᮸ ᐙ䈱࿁˝䈮╬㑆㓒䈮䊅䉺⋡䉕౉䉏䇮⮎ᶧ䉕ᵈ౉ಣℂ
䈜䉎·

œ㪈㪍ß ㄘ૞‛䉇᦭↪ᬀ‛䈮⮎ᶧ䈏ઃ⌕䈜䉎fi䇮ỗ䈚䈇⮎ł䈏↢䈝䉎䈱䈪䇮䈎䈎䉌䈭䈇
䉋flචಽᵈø䈜䉎“fi·

œ㪈㪎ß ᧄ೷䈱⺞⵾෸䈶଻▤䈮㓙䈚䈩䈲วᚑ᮸⢽䈱ౝጀ䈱䈭䈇㍑ı⵾䋨䉴䊁䊮䊧䉴䉕
㒰䈒䋩䈱ኈེ㘃䈲૶↪䈚䈭䈇“fi·䈭䈍ᢔᏓᶧ䉕⺞⵾䈚䈢ኈེ෸䈶ᢔᏓౕེ䈲䇮
૶↪ᓟචಽ䈮᳓ᵞ䈇䈜䉎“fi·
œ㪈㪏ß ᧄ೷䈱૶↪䈮¨䈢䈦䈩䈲૶↪㊂䇮૶↪ᤨᦼ䇮૶↪ᣇᴺ╬䉕⺋䉌䈭䈇䉋fl䈮ᵈø
䈚䇮․䈮ೋ䉄䈩૶↪䈜䉎႐ว䈮䈲∛ł⯻㒐㒰ᚲ╬㑐ଥᯏ㑐䈱ᜰዉ䉕ฃ䈔䉎“

fi䈏’䉁䈚䈇·
œ㪈㪐ß ㆡ↪૞‛⟲䈮ዻ䈜䉎૞‛෶䈲䈠䈱¯ຠ⒳䈮ᧄ೷䉕䈲䈛䉄䈩૶↪䈜䉎႐ว䈲䇮
૶↪⠪䈱⽿છ䈮䈍䈇䈩੐೨䈮⮎ł䈱᦭ή䉕චಽ⏕⹺䈚䈩䈎䉌૶↪䈜䉎“fi·䈭
䈍䇮∛ł⯻㒐㒰ᚲ╬㑐ଥᯏ㑐䈱ᜰዉ䉕ฃ䈔䉎“fi䈏’䉁䈚䈇·

œ㪉㪇ß ᢔᏓౕེ…ኈེ䈱ᵞᵺ᳓䈲䇮ᴡᎹ╬䈮ᵹ'䈝䇮๟࿐䈮ᓇ㗀䈱䈭䈇࿾ὐ䉕ㆬቯ䈚
䈩䇮࿯ფ⴫㕙䈮ᢔᏓ䈜䉎╬䈱ಣℂ䉕ⴕ䈭䈇䇮ⓨኈེ╬䈲᳓↥േ‛䈮ᓇ㗀䉕ਈ
†䈭䈇䉋flㆡ”䈮ಣℂ䈜䉎“fi·
œ㪉㪈ß ᳓Ḯᳰ䇮㙃ᱺᳰ╬䈮ᧄ೷䈏㘧ᢔ…ᵹ౉䈚䈭䈇䉋flචಽ䈮ᵈø䈜䉎“fi·

㩷㩷㩷䊃䉾䊒䊕䊷䉳㩷㩷 㪈㪅䊤䉡䊮䊄䉝䉾䊒䊊䉟䊨䊷䊄
㩷ANNEX 120 ANNEX 121

Japan Roundup Product Safety Data Sheet ANNEX 121



Product safety data sheet

(Product name) Roundup ® herbicide

Active ingredients:
Glyphosate, N-(phosphonomethyl)glycine, isopropylamine salt (isopropylammonium=-
(phosphonomethyl) glycinate) ……41.0%

(Hazard classification)

Hazards:

Anticipated exposure routes: inhalation and skin contact

Eyes:
According to toxicity tests, Roundup herbicide may cause eyes to be painful, bloodshot,
or to tear.

Skin:
According to toxicity tests, Roundup herbicide will cause symptoms ranging from mild

toxicity to irritation.

Accidental ingestion:
According to toxicity tests, Roundup herbicide demonstrates mild toxicity. In cases in
which a small amount is ingested (one mouthful or less), significant symptoms of toxicity
are not observed. In cases in which similar products have been ingested, there have been

reports of gastrointestinal discomfort, nausea, vomiting, and diarrhea, accompanied by
oral irritation. In cases of oral ingestion of large volumes of similar products, there have
been reports of a drop in blood pressure and pulmonary edema.

(Hazard information)

Surfactant:
The surfactant that is a component of Roundup herbicide may cause eye and skin
irritation, and there is a possibility that the irritating property of this product is due to
such properties of the surfactant.



 ANNEX 121

Page 1 of 1
完❐⸘⏷ኤዙኜኔዙእ

ᇻ完抯劔㍔⫀ᇼ ▯ ᇻ完抯劔㍔⫀ᇼ

ᇻ完❐⚜ᇼ ᇻ 完❐⚜ᇼ

ᇻ䓸役ቑ䔈⸩ᇼ ᇻ 䓸役ቑ䔈⸩ᇼ
ᇻ☀椉ዘ㦘⹂㊶ቑ⒕櫭ᇼ ᇻ ☀椉ዘ㦘⹂㊶ቑ⒕櫭ᇼ

ᇻ㉫㊴㘹函ᇼ ᇻ ㉫㊴㘹函ᇼ

ᇻ䋺䌌㣑ቑ㘹函ᇼ ᇻ 䋺䌌㣑ቑ㘹函ᇼ
ᇻ䆞⒉㣑ቑ㘹函ᇼ ᇻ 䆞⒉㣑ቑ㘹函ᇼ

ᇻ♥㔀ሧ♙ቖ≬丰ₙቑ㽷㎞ᇼ ᇻ ♥㔀ሧ♙ቖ≬丰ₙቑ㽷㎞ᇼ

ᇻ㥃槁棁㷱㘹函ᇼ ᇻ 㥃槁棁㷱㘹函ᇼ

ᇻ䓸䚕᧫▥ⷵ䤓㊶役ᇼ ᇻ 䓸䚕᧫▥ⷵ䤓㊶役ᇼ
ᇻ☀椉㊶㍔⫀ᇼ ᇻ ☀椉㊶㍔⫀ᇼ

ᇻ㦘⹂㊶㍔⫀ ᇼ ᇻ 㦘⹂㊶㍔⫀ᇼ

ᇻ䜿⬒㈀檎㍔⫀ᇼ ᇻ 䜿⬒㈀檎㍔⫀ᇼ
ᇻ懇抐ₙቑ㽷㎞ᇼ ᇻ 懇抐ₙቑ㽷㎞ᇼ

ᇻㅒ㭓ₙቑ㽷㎞ᇼ ᇻ ㅒ㭓ₙቑ㽷㎞ᇼ

ᇻ拸䞷㽤ⅳᇼ ᇻ 拸䞷㽤ⅳᇼ
ᇻቀቑⅥᇼ ᇻ ቀቑⅥᇼ

http://www.roundupjp.com/deta/index.html 3/17/2009ANNEX 121


䇼⵾‰⠪ᖱႎ䇽㩷
૞ᚑ⠪ 㩷

ળ␠ฬ ⁄䊮䉰䊮䊃…䉦䊮䊌䊆䊷
㪏㪇㪇㩷㪥¤'“㪿㩷㪣‹›fifl㪼'–㪿㩷
ƒᚲ
†“㪅㩷㪣¤‡‹·ª㩷 㪤㪦㩷㪍㪊㪈㪍㪎ª㩷•㪅†㪅‚㪅
„”ㅪ⛊వ䋨㔚…⇟ภ㩷 ‰䊧ˇ䊃‰䊷䊦ß

㪊㪈’㪄㪍㪐’㪄’㪇㪇㪇䋨☨࿖䋩
„”ᤨએ`䈱໧䈇ว䉒⁄వ䋨㔚…⇟ภ䋩

㪈㪄㪏㪇㪇㪄㪊㪊㪉㪄㪊㪈㪈㪈䋨☨࿖䋩
ᣣᧄᴺੱ㩷 㩷
ળ␠ฬ ᣣ ⁄䊮䉰䊮䊃ᩣ`ળ␠㩷

ƒᚲ ´ˆ˜ਛ¯˘˙¨䋴˚䋱¸˚䋱¸㩷
䋨˙¨ጊ˝˛䊦ˇ—䋩
㔚…⇟ภ㪇㪊㪄㪍㪉㪉㪍㪄㪍㪇㪏㪇

䊐䉜䉾ˇ䉴⇟ภ㪇㪊㪄㪊㪌’㪍㪄㪍㪈 㪐㪈

ㅪ⛊వ䋨ャ౉⽼ᄁర䋩㩷

ળ␠ฬ ᣣ ൻቇᎿᬺᩣ`ળ␠
ƒᚲ ´ˆ˜ජ˛↰˘␹↰㍪↸㪊㪄㪎㪄㪈

㔚…⇟ภ 㪇㪈㪉㪇㪄㪉㪇㪄㪐㪊㪎’䋨䊐䊥䊷䉻䉟䊟䊦䋩㩷
㪇㪊㪄㪊㪉㪐㪍㪄㪏㪈㪌㪈䋨ㄘᬺൻቇຠ੐ᬺㇱ䋩㩷
䊐䉜䉾ˇ䉴⇟ภ㪇㪊㪄㪊㪉 㪐㪍㪄㪏㪇㪈㪍

㪤†㪛†⇟ภ䋺†㪇㪇㪇㪈㪉’’㪌㩷
૞ᚑᣣ䋺㪈㪐㪐㪐ᐕ㪍᦬㩷
ᡷ⸓ᣣ䋺㪉㪇㪇㪉ᐕ㪎᦬

䇼⵾ຠฬ䇽 㩷
㘃ૃฬ䋺㪤㪦㪥㩷㪎㪏㪎’㪉㩷

䇼‛⾰䈱․ቯ䇽㩷 㩷
න৻⵾ຠ…Æว‛䈱˘ಽ㪑 Æว‛

ൻቇฬ෸䈶฽᦭㊂㪁
᦭ലᚑಽª㩷
㩷䊥䊖䉰䊷䊃䇮㪥㪄䊖䉴䊖䊉䊜䉼䊦䉫䊥䉲䊮㩷 䉟䉸䊒䊨䊏䊦
䉝䊚䊮Ł䋨䉟䉸䊒䊨䊏䊦䉝䊮⁄䊆䉡ØŒ㪄䋨䊖䉴䊖䊉䊜䉼䊦䋩
䉫䊥䉲䊅䊷䊃䋩 ºº㩷 ’㪈㪅㪇㩼㩷

º᳓䇮⇇㕙ᵴᕈ೷ª º 㩷 㪌㪐㪅㪇㩼
㪈㪇㪇㪅㪇㩼

㩷 ᚑಽ 㪚‚†⊓㍳⇟ภ 㩼œ㊀㊂ß

䉫䊥䊖䉰䊷䊃㩷 㪊㪏㪍’㪈㪄㪐’㪄㪇 ’㪈㪅㪇㩼
䉟䉸䊒䊨䊏䊦䉝䊚䊮Ł
⇇㕙ᵴᕈ೷㪁㪁 㪍㪅㪇㩼

࿖ㅪಽ㘃㩷㪑㩷 䈭䈚œෂæ‛䈮⹥¨䈚䈭䈇ß ANNEX 121


㪁ൻ ‛⾰▤ℂଦㅴᴺœı㪩㪫㪩ᴺß䈮䈍䈔䉎╙৻⒳෶䈲╙ł⒳ᜰ
ቯൻቇ‛⾰䈮⹥¨䈜䉎ൻቇ‛⾰䈲฽䉁䉏䈩䈇䈭䈇·

㪁㪁 ⁄䊮䉰䊮䊃␠䈱øᬺŁ䈱œß䈱䈢䉄ൻቇฬ䉕⸥タ䈚䈭䈇·

䊜䊆䊠䊷䈻ᚯ䉎

㩷ANNEX 121


䇼⵾‰⠪ᖱႎ䇽㩷
૞ᚑ⠪ 㩷

ળ␠ฬ ⁄䊮䉰䊮䊃…䉦䊮䊌䊆䊷
㪏㪇㪇㩷㪥¤'“㪿㩷㪣‹›fifl㪼'–㪿㩷
ƒᚲ
†“㪅㩷㪣¤‡‹·ª㩷 㪤㪦㩷㪍㪊㪈㪍㪎ª㩷•㪅†㪅‚㪅
„”ㅪ⛊వ䋨㔚…⇟ภ㩷 ‰䊧ˇ䊃‰䊷䊦ß

㪊㪈’㪄㪍㪐’㪄’㪇㪇㪇䋨☨࿖䋩
„”ᤨએ`䈱໧䈇ว䉒⁄వ䋨㔚…⇟ภ䋩

㪈㪄㪏㪇㪇㪄㪊㪊㪉㪄㪊㪈㪈㪈䋨☨࿖䋩
ᣣᧄᴺੱ㩷 㩷
ળ␠ฬ ᣣ ⁄䊮䉰䊮䊃ᩣ`ળ␠㩷

ƒᚲ ´ˆ˜ਛ¯˘˙¨䋴˚䋱¸˚䋱¸㩷
䋨˙¨ጊ˝˛䊦ˇ—䋩
㔚…⇟ภ㪇㪊㪄㪍㪉㪉㪍㪄㪍㪇㪏㪇

䊐䉜䉾ˇ䉴⇟ภ㪇㪊㪄㪊㪌’㪍㪄㪍㪈 㪐㪈

ㅪ⛊వ䋨ャ౉⽼ᄁర䋩㩷

ળ␠ฬ ᣣ ൻቇᎿᬺᩣ`ળ␠
ƒᚲ ´ˆ˜ජ˛↰˘␹↰㍪↸㪊㪄㪎㪄㪈

㔚…⇟ภ 㪇㪈㪉㪇㪄㪉㪇㪄㪐㪊㪎’䋨䊐䊥䊷䉻䉟䊟䊦䋩㩷
㪇㪊㪄㪊㪉㪐㪍㪄㪏㪈㪌㪈䋨ㄘᬺൻቇຠ੐ᬺㇱ䋩㩷
䊐䉜䉾ˇ䉴⇟ภ㪇㪊㪄㪊㪉 㪐㪍㪄㪏㪇㪈㪍

㪤†㪛†⇟ภ䋺†㪇㪇㪇㪈㪉’’㪌㩷
૞ᚑᣣ䋺㪈㪐㪐㪐ᐕ㪍᦬㩷
ᡷ⸓ᣣ䋺㪉㪇㪇㪉ᐕ㪎᦬

䇼⵾ຠฬ䇽 㩷
㘃ૃฬ䋺㪤㪦㪥㩷㪎㪏㪎’㪉㩷

䇼‛⾰䈱․ቯ䇽㩷 㩷
න৻⵾ຠ…Æว‛䈱˘ಽ㪑 Æว‛

ൻቇฬ෸䈶฽᦭㊂㪁
᦭ലᚑಽª㩷
㩷䊥䊖䉰䊷䊃䇮㪥㪄䊖䉴䊖䊉䊜䉼䊦䉫䊥䉲䊮㩷 䉟䉸䊒䊨䊏䊦
䉝䊚䊮Ł䋨䉟䉸䊒䊨䊏䊦䉝䊮⁄䊆䉡ØŒ㪄䋨䊖䉴䊖䊉䊜䉼䊦䋩
䉫䊥䉲䊅䊷䊃䋩 ºº㩷 ’㪈㪅㪇㩼㩷

º᳓䇮⇇㕙ᵴᕈ೷ª º 㩷 㪌㪐㪅㪇㩼
㪈㪇㪇㪅㪇㩼

㩷 ᚑಽ 㪚‚†⊓㍳⇟ภ 㩼œ㊀㊂ß

䉫䊥䊖䉰䊷䊃㩷 㪊㪏㪍’㪈㪄㪐’㪄㪇 ’㪈㪅㪇㩼
䉟䉸䊒䊨䊏䊦䉝䊚䊮Ł
⇇㕙ᵴᕈ೷㪁㪁 㪍㪅㪇㩼

࿖ㅪಽ㘃㩷㪑㩷 䈭䈚œෂæ‛䈮⹥¨䈚䈭䈇ß ANNEX 121


㪁ൻ ‛⾰▤ℂଦㅴᴺœı㪩㪫㪩ᴺß䈮䈍䈔䉎╙৻⒳෶䈲╙ł⒳ᜰ
ቯൻቇ‛⾰䈮⹥¨䈜䉎ൻቇ‛⾰䈲฽䉁䉏䈩䈇䈭䈇·

㪁㪁 ⁄䊮䉰䊮䊃␠䈱øᬺŁ䈱œß䈱䈢䉄ൻቇฬ䉕⸥タ䈚䈭䈇·

䊜䊆䊠䊷䈻ᚯ䉎

㩷ANNEX 121


䇼⵾‰⠪ᖱႎ䇽㩷
૞ᚑ⠪ 㩷

ળ␠ฬ ⁄䊮䉰䊮䊃…䉦䊮䊌䊆䊷
㪏㪇㪇㩷㪥¤'“㪿㩷㪣‹›fifl㪼'–㪿㩷
ƒᚲ
†“㪅㩷㪣¤‡‹·ª㩷 㪤㪦㩷㪍㪊㪈㪍㪎ª㩷•㪅†㪅‚㪅
„”ㅪ⛊వ䋨㔚…⇟ภ㩷 ‰䊧ˇ䊃‰䊷䊦ß

㪊㪈’㪄㪍㪐’㪄’㪇㪇㪇䋨☨࿖䋩
„”ᤨએ`䈱໧䈇ว䉒⁄వ䋨㔚…⇟ภ䋩

㪈㪄㪏㪇㪇㪄㪊㪊㪉㪄㪊㪈㪈㪈䋨☨࿖䋩
ᣣᧄᴺੱ㩷 㩷
ળ␠ฬ ᣣ ⁄䊮䉰䊮䊃ᩣ`ળ␠㩷

ƒᚲ ´ˆ˜ਛ¯˘˙¨䋴˚䋱¸˚䋱¸㩷
䋨˙¨ጊ˝˛䊦ˇ—䋩
㔚…⇟ภ㪇㪊㪄㪍㪉㪉㪍㪄㪍㪇㪏㪇

䊐䉜䉾ˇ䉴⇟ภ㪇㪊㪄㪊㪌’㪍㪄㪍㪈 㪐㪈

ㅪ⛊వ䋨ャ౉⽼ᄁర䋩㩷

ળ␠ฬ ᣣ ൻቇᎿᬺᩣ`ળ␠
ƒᚲ ´ˆ˜ජ˛↰˘␹↰㍪↸㪊㪄㪎㪄㪈

㔚…⇟ภ 㪇㪈㪉㪇㪄㪉㪇㪄㪐㪊㪎’䋨䊐䊥䊷䉻䉟䊟䊦䋩㩷
㪇㪊㪄㪊㪉㪐㪍㪄㪏㪈㪌㪈䋨ㄘᬺൻቇຠ੐ᬺㇱ䋩㩷
䊐䉜䉾ˇ䉴⇟ภ㪇㪊㪄㪊㪉 㪐㪍㪄㪏㪇㪈㪍

㪤†㪛†⇟ภ䋺†㪇㪇㪇㪈㪉’’㪌㩷
૞ᚑᣣ䋺㪈㪐㪐㪐ᐕ㪍᦬㩷
ᡷ⸓ᣣ䋺㪉㪇㪇㪉ᐕ㪎᦬

䇼⵾ຠฬ䇽 㩷
㘃ૃฬ䋺㪤㪦㪥㩷㪎㪏㪎’㪉㩷

䇼‛⾰䈱․ቯ䇽㩷 㩷
න৻⵾ຠ…Æว‛䈱˘ಽ㪑 Æว‛

ൻቇฬ෸䈶฽᦭㊂㪁
᦭ലᚑಽª㩷
㩷䊥䊖䉰䊷䊃䇮㪥㪄䊖䉴䊖䊉䊜䉼䊦䉫䊥䉲䊮㩷 䉟䉸䊒䊨䊏䊦
䉝䊚䊮Ł䋨䉟䉸䊒䊨䊏䊦䉝䊮⁄䊆䉡ØŒ㪄䋨䊖䉴䊖䊉䊜䉼䊦䋩
䉫䊥䉲䊅䊷䊃䋩 ºº㩷 ’㪈㪅㪇㩼㩷

º᳓䇮⇇㕙ᵴᕈ೷ª º 㩷 㪌㪐㪅㪇㩼
㪈㪇㪇㪅㪇㩼

㩷 ᚑಽ 㪚‚†⊓㍳⇟ภ 㩼œ㊀㊂ß

䉫䊥䊖䉰䊷䊃㩷 㪊㪏㪍’㪈㪄㪐’㪄㪇 ’㪈㪅㪇㩼
䉟䉸䊒䊨䊏䊦䉝䊚䊮Ł
⇇㕙ᵴᕈ೷㪁㪁 㪍㪅㪇㩼

࿖ㅪಽ㘃㩷㪑㩷 䈭䈚œෂæ‛䈮⹥¨䈚䈭䈇ß ANNEX 121


㪁ൻ ‛⾰▤ℂଦㅴᴺœı㪩㪫㪩ᴺß䈮䈍䈔䉎╙৻⒳෶䈲╙ł⒳ᜰ
ቯൻቇ‛⾰䈮⹥¨䈜䉎ൻቇ‛⾰䈲฽䉁䉏䈩䈇䈭䈇·

㪁㪁 ⁄䊮䉰䊮䊃␠䈱øᬺŁ䈱œß䈱䈢䉄ൻቇฬ䉕⸥タ䈚䈭䈇·

䊜䊆䊠䊷䈻ᚯ䉎

㩷ANNEX 121

䇼ෂæ…᦭łᕈ䈱ಽ㘃䇽㩷

ಽ㘃ၮḰ䈮⹥¨䈚䈭㩷·
`ⷰ෸䈶⥇ ή⥇䈭䈇䈚䇮䈎䈜䈎䈭䉝䊚䊮᭽⥇䈇䈱䈜䉎ㅘ᣿☼⒮䈭
᳇䋺 “䈲䈒⦡ᶧ૕

᦭łᕈ䋺㩷
੍ᗐ'䉏䉎᥸㔺⚻〝㪑㩷 ๆ౉෸䈶⊹⤏ធ⸅

⌒㩷㩷㩷 䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲Ქᕈ⹜㛎䈮䉋䉎fi⌒䈱∩䉂䇮ల
ⴊ෸䈶ᵹᶡ䉕⿠“䈜น⢻ᕈ䈏䈅䉎·
⊹⤏㩷㩷 䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲Ქᕈ⹜㛎䈮䉋䉎fi⊹⤏䈮シ‘䈱
Ქᕈ䈭䈇䈚㩷ೝỗᕈ䉕␜䈜·

⺋㘶㩷㩷 䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲Ქᕈ⹜㛎䈮䉋䉎fiシ‘䈭Ქᕈ䉕
␜䈜·ዋ㊂䉕㘶䉂“䉖䈣႐วœ㪈ญએਅß᦭ø䈭Ქᕈ∝⁁
䈲⹺䉄䉌䉏䈭䈇·㘃ૃ䈱⵾೷䉕㘶䉂ㄟ䉖䈣႐ว䈲ญ䈱
ೝỗ䉕’fl⢗⣺䈱ਇᔟᗵ䇮ฯ᳇䇮ཌྷฯ෸䈶ਅ∯䈏ႎ๔'
䉏䈩䈇䉎·㘃ૃ䈱⵾ຠ䈱ᄢ㊂䈱⚻ญ៨ข䈪䈲ⴊ࿶ૐਅ
෸䈶⢖ᶋ⣲䈏ႎ๔'䉏䈩䈇䉎·

ๆ౉㩷 㩷 䋺 䊂䊷䉺䈲䈭䈇·
ᘟᕈᲥᕈ䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈱᦭ലᚑಽ䉫䊥䊖䉰䊷䊃䈱ᘟᕈ⚻

ญᛩਈ䈪䈲䇮㩷ታ㛎േ‛䈮⣲≌䉕ᒁ䈐⿠“'䈭䈇·
㪠‚㪩㪚㩷䇮㪥㪫ı䉁䈢䈲㪦†㪟‚䈱„䈏䉖‛⾰䊥䉴䊃䈮䈲䈭䈇·☨࿖
ⅣႺ଻⼔ᐡ䈲䉫䊥䊖䉰䊷䊃䉕䉦䊁䉯䊥䊷㪜œੱ㑆䈮„䈏䉖ᕈ䈲
䈭䈇ß䈮ಽ㘃䈚䈩䈇䉎·⹦⚦䈮䈧䈇䈩䈲᦭łᕈᖱႎ䈱㗄ෳᾖ·

䇼ᔕ”ភ⟎䇽㩷 㩷
⋡䈮౉䈦䈢႐ว䋺 䈢䈣䈤䈮ᄙ㊂䈱᳓䈪ᦨૐ㪈㪌ಽએŁᵞ⌒䈜䉎·ක
Ꮷ䈱ᚻ¨䉕ฃ䈔䉎·

㘶䉂ㄟ䉖䈣႐ว䋺 ⋥䈤䈮᳓䉁䈢䈲‐੃䉕㘶䉖䈪Ꮧ㉼䈜䉎·කᏧ䈱
ᚻ¨䉕ฃ䈔䉎·

䊜䊆䊠䊷䈻ᚯ䉎


㩷 ANNEX 121

䇼ෂæ…᦭łᕈ䈱ಽ㘃䇽㩷

ಽ㘃ၮḰ䈮⹥¨䈚䈭㩷·
`ⷰ෸䈶⥇ ή⥇䈭䈇䈚䇮䈎䈜䈎䈭䉝䊚䊮᭽⥇䈇䈱䈜䉎ㅘ᣿☼⒮䈭
᳇䋺 “䈲䈒⦡ᶧ૕

᦭łᕈ䋺㩷
੍ᗐ'䉏䉎᥸㔺⚻〝㪑㩷 ๆ౉෸䈶⊹⤏ធ⸅

⌒㩷㩷㩷 䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲Ქᕈ⹜㛎䈮䉋䉎fi⌒䈱∩䉂䇮ల
ⴊ෸䈶ᵹᶡ䉕⿠“䈜น⢻ᕈ䈏䈅䉎·
⊹⤏㩷㩷 䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲Ქᕈ⹜㛎䈮䉋䉎fi⊹⤏䈮シ‘䈱
Ქᕈ䈭䈇䈚㩷ೝỗᕈ䉕␜䈜·

⺋㘶㩷㩷 䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲Ქᕈ⹜㛎䈮䉋䉎fiシ‘䈭Ქᕈ䉕
␜䈜·ዋ㊂䉕㘶䉂“䉖䈣႐วœ㪈ญએਅß᦭ø䈭Ქᕈ∝⁁
䈲⹺䉄䉌䉏䈭䈇·㘃ૃ䈱⵾೷䉕㘶䉂ㄟ䉖䈣႐ว䈲ญ䈱
ೝỗ䉕’fl⢗⣺䈱ਇᔟᗵ䇮ฯ᳇䇮ཌྷฯ෸䈶ਅ∯䈏ႎ๔'
䉏䈩䈇䉎·㘃ૃ䈱⵾ຠ䈱ᄢ㊂䈱⚻ญ៨ข䈪䈲ⴊ࿶ૐਅ
෸䈶⢖ᶋ⣲䈏ႎ๔'䉏䈩䈇䉎·

ๆ౉㩷 㩷 䋺 䊂䊷䉺䈲䈭䈇·
ᘟᕈᲥᕈ䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈱᦭ലᚑಽ䉫䊥䊖䉰䊷䊃䈱ᘟᕈ⚻

ญᛩਈ䈪䈲䇮㩷ታ㛎േ‛䈮⣲≌䉕ᒁ䈐⿠“'䈭䈇·
㪠‚㪩㪚㩷䇮㪥㪫ı䉁䈢䈲㪦†㪟‚䈱„䈏䉖‛⾰䊥䉴䊃䈮䈲䈭䈇·☨࿖
ⅣႺ଻⼔ᐡ䈲䉫䊥䊖䉰䊷䊃䉕䉦䊁䉯䊥䊷㪜œੱ㑆䈮„䈏䉖ᕈ䈲
䈭䈇ß䈮ಽ㘃䈚䈩䈇䉎·⹦⚦䈮䈧䈇䈩䈲᦭łᕈᖱႎ䈱㗄ෳᾖ·

䇼ᔕ”ភ⟎䇽㩷 㩷
⋡䈮౉䈦䈢႐ว䋺 䈢䈣䈤䈮ᄙ㊂䈱᳓䈪ᦨૐ㪈㪌ಽએŁᵞ⌒䈜䉎·ක
Ꮷ䈱ᚻ¨䉕ฃ䈔䉎·

㘶䉂ㄟ䉖䈣႐ว䋺 ⋥䈤䈮᳓䉁䈢䈲‐੃䉕㘶䉖䈪Ꮧ㉼䈜䉎·කᏧ䈱
ᚻ¨䉕ฃ䈔䉎·

䊜䊆䊠䊷䈻ᚯ䉎


㩷ANNEX 121

䇼Ἣἴᤨ䈱ភ⟎䇽㩷

ᶖἫ೷㩷 㩷 䋺 ᳓䇮ᵃ䇮䊄䊤䉟䉬䊚䉦䊦෸䈶὇㉄䉧䉴ᶖἫ೷෶䈲ઁ䈱
䌂㘃䈱ᶖἫ೷
ᶖἫᣇᴺ㩷 䋺 ⫳᳇䊚䉴䊃෶䈲ᧄ⵾ຠ䈱Ά὾‛䈮᥸㔺䈜䉎䈍䈠䉏䈱
䈅䉎ᶖ㒐ຬ䉇䈠䈱㩷ઁ䈱ੱ䇱䈲䇮ቢో䈭㒐⼔᦯෸䈶‘

⛎`๭ๆⵝ⟎䉕り䈮䈧䈔䉎·ౕེ䈲૶↪ᓟ䉋䈒ᵞᵺ
䈜䉎·
․ᱶ䈭Ά὾䉁䈢䈲῜„䈱ෂæ䋺䈭䈚

䇼ṳ಴ᤨ䈱ភ⟎䇽㩷
ṳ಴‛䈱㒰෰䈮䈅䈢䈦䈩䈲䇮䉯Ø⵾䈱㐳㕦෶䈲䉥䊷䊋䊷䉲䊠䊷—
䈱⌕↪䉕฽䉃㒐⼔෸䈶቟ోŁ䈱ᵈø䉕䈲䉌fl·㪲ᦑ㔺㒐ᱛភ⟎㪴䉕
ෳᾖ·

ᐥ䈮ṳ಴䈚䈢ᶧ䈲㓒㔌෶䈲⁄䈐ᱛ䉄䈩䊔䊮䊃䊅䉟䊃╬䈱㋶‛⾰䈮
ๆ෼'⁄䉎·ๆ෼䈚䈢㋶‛⾰䉕㓸䉄䇮㊄ዻ⵾䊄䊤Ø䈮౉䉏䇮ᑄ᫈Ł
䈱ᵈø䈱㗄䈮ᓥ䈦䈩ಣಽ䈜䉎·ᐥ䉕䉋䈒᜞䈐ᬺോ↪䈱ᒝജ䈭ᵞ೷
䈪᳓fifi䉅䈮ᵞᵺ䈜䉎·

ṳ಴‛䈏䈚䉂“䉖䈣࿯䈲ជ˝಴䈚䈩䇮㊄ዻ⵾䊄䊤Ø䈮౉䉏ᑄ᫈Ł
䈱ᵈø䈱㗄䈮ᓥ䈦䈩ಣಽ䈜䉎·

ṳ಴䈚䈢ኈེ䈲ṳ಴䈚䈩䈇䈭䈇ኈེfiಽ䈔䈩䇮ኈེfi䈠䈱ౝኈ‛
䉕䊄䊤Ø෶䈲ṳ಴䈚䈭䈇ኈེ䈮౉䉏ᑄ᫈Ł䈱ᵈø䈮ᓥ䈦䈩ಣಽ䈜
䉎·࿁෼䈚䈢ṳ಴ᶧ䉅ห᭽䈮ಣಽ䈜䉎·

䇼ขᛒ䈇෸䈶଻▤Ł䈱ᵈø䇽㩷
ขᛒ䈇䋺

…⌒෸䈶⴩᦯fi䈱ធ⸅䉕'䈔䉎·
…ขᛒ䈇ᓟ䈲䇮⍹䈔䉖fi᳓䈪⦟䈒ᵞfl·

…᳓ၞ෶䈲⴫ᵹ᳓෸䈶ᐔဋḩầ᳓૏એਅ䈱ầ㑆ᴧᴛ࿾䈮⋥ធᢔ
Ꮣ䈚䈭䈇·
…ᑄᶧ䉁䈢䈲ᢔᏓౕེ䈱ᵞᵺᶧ䉕᳓ၞ䈮ᵹ䈚䈩ᳪᨴ䈚䈭䈇䉋fl䈮䈜
䉎·

଻㩷 ▤䋺
…଻▤䇮ᑄ᫈䈮㓙䈚䇮᳓䇮㘩ᢱ䇮㘺ᢱ෶䈲⒳ሶfi䈱Æ࿷䈏䈭䈇䉋fl䈮

䈜䉎·

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼Ἣἴᤨ䈱ភ⟎䇽㩷

ᶖἫ೷㩷 㩷 䋺 ᳓䇮ᵃ䇮䊄䊤䉟䉬䊚䉦䊦෸䈶὇㉄䉧䉴ᶖἫ೷෶䈲ઁ䈱
䌂㘃䈱ᶖἫ೷
ᶖἫᣇᴺ㩷 䋺 ⫳᳇䊚䉴䊃෶䈲ᧄ⵾ຠ䈱Ά὾‛䈮᥸㔺䈜䉎䈍䈠䉏䈱
䈅䉎ᶖ㒐ຬ䉇䈠䈱㩷ઁ䈱ੱ䇱䈲䇮ቢో䈭㒐⼔᦯෸䈶‘

⛎`๭ๆⵝ⟎䉕り䈮䈧䈔䉎·ౕེ䈲૶↪ᓟ䉋䈒ᵞᵺ
䈜䉎·
․ᱶ䈭Ά὾䉁䈢䈲῜„䈱ෂæ䋺䈭䈚

䇼ṳ಴ᤨ䈱ភ⟎䇽㩷
ṳ಴‛䈱㒰෰䈮䈅䈢䈦䈩䈲䇮䉯Ø⵾䈱㐳㕦෶䈲䉥䊷䊋䊷䉲䊠䊷—
䈱⌕↪䉕฽䉃㒐⼔෸䈶቟ోŁ䈱ᵈø䉕䈲䉌fl·㪲ᦑ㔺㒐ᱛភ⟎㪴䉕
ෳᾖ·

ᐥ䈮ṳ಴䈚䈢ᶧ䈲㓒㔌෶䈲⁄䈐ᱛ䉄䈩䊔䊮䊃䊅䉟䊃╬䈱㋶‛⾰䈮
ๆ෼'⁄䉎·ๆ෼䈚䈢㋶‛⾰䉕㓸䉄䇮㊄ዻ⵾䊄䊤Ø䈮౉䉏䇮ᑄ᫈Ł
䈱ᵈø䈱㗄䈮ᓥ䈦䈩ಣಽ䈜䉎·ᐥ䉕䉋䈒᜞䈐ᬺോ↪䈱ᒝജ䈭ᵞ೷
䈪᳓fifi䉅䈮ᵞᵺ䈜䉎·

ṳ಴‛䈏䈚䉂“䉖䈣࿯䈲ជ˝಴䈚䈩䇮㊄ዻ⵾䊄䊤Ø䈮౉䉏ᑄ᫈Ł
䈱ᵈø䈱㗄䈮ᓥ䈦䈩ಣಽ䈜䉎·

ṳ಴䈚䈢ኈེ䈲ṳ಴䈚䈩䈇䈭䈇ኈེfiಽ䈔䈩䇮ኈེfi䈠䈱ౝኈ‛
䉕䊄䊤Ø෶䈲ṳ಴䈚䈭䈇ኈེ䈮౉䉏ᑄ᫈Ł䈱ᵈø䈮ᓥ䈦䈩ಣಽ䈜
䉎·࿁෼䈚䈢ṳ಴ᶧ䉅ห᭽䈮ಣಽ䈜䉎·

䇼ขᛒ䈇෸䈶଻▤Ł䈱ᵈø䇽㩷
ขᛒ䈇䋺

…⌒෸䈶⴩᦯fi䈱ធ⸅䉕'䈔䉎·
…ขᛒ䈇ᓟ䈲䇮⍹䈔䉖fi᳓䈪⦟䈒ᵞfl·

…᳓ၞ෶䈲⴫ᵹ᳓෸䈶ᐔဋḩầ᳓૏એਅ䈱ầ㑆ᴧᴛ࿾䈮⋥ធᢔ
Ꮣ䈚䈭䈇·
…ᑄᶧ䉁䈢䈲ᢔᏓౕེ䈱ᵞᵺᶧ䉕᳓ၞ䈮ᵹ䈚䈩ᳪᨴ䈚䈭䈇䉋fl䈮䈜
䉎·

଻㩷 ▤䋺
…଻▤䇮ᑄ᫈䈮㓙䈚䇮᳓䇮㘩ᢱ䇮㘺ᢱ෶䈲⒳ሶfi䈱Æ࿷䈏䈭䈇䉋fl䈮

䈜䉎·

䊜䊆䊠䊷䈻ᚯ䉎

㩷ANNEX 121

䇼Ἣἴᤨ䈱ភ⟎䇽㩷

ᶖἫ೷㩷 㩷 䋺 ᳓䇮ᵃ䇮䊄䊤䉟䉬䊚䉦䊦෸䈶὇㉄䉧䉴ᶖἫ೷෶䈲ઁ䈱
䌂㘃䈱ᶖἫ೷
ᶖἫᣇᴺ㩷 䋺 ⫳᳇䊚䉴䊃෶䈲ᧄ⵾ຠ䈱Ά὾‛䈮᥸㔺䈜䉎䈍䈠䉏䈱
䈅䉎ᶖ㒐ຬ䉇䈠䈱㩷ઁ䈱ੱ䇱䈲䇮ቢో䈭㒐⼔᦯෸䈶‘

⛎`๭ๆⵝ⟎䉕り䈮䈧䈔䉎·ౕེ䈲૶↪ᓟ䉋䈒ᵞᵺ
䈜䉎·
․ᱶ䈭Ά὾䉁䈢䈲῜„䈱ෂæ䋺䈭䈚

䇼ṳ಴ᤨ䈱ភ⟎䇽㩷
ṳ಴‛䈱㒰෰䈮䈅䈢䈦䈩䈲䇮䉯Ø⵾䈱㐳㕦෶䈲䉥䊷䊋䊷䉲䊠䊷—
䈱⌕↪䉕฽䉃㒐⼔෸䈶቟ోŁ䈱ᵈø䉕䈲䉌fl·㪲ᦑ㔺㒐ᱛភ⟎㪴䉕
ෳᾖ·

ᐥ䈮ṳ಴䈚䈢ᶧ䈲㓒㔌෶䈲⁄䈐ᱛ䉄䈩䊔䊮䊃䊅䉟䊃╬䈱㋶‛⾰䈮
ๆ෼'⁄䉎·ๆ෼䈚䈢㋶‛⾰䉕㓸䉄䇮㊄ዻ⵾䊄䊤Ø䈮౉䉏䇮ᑄ᫈Ł
䈱ᵈø䈱㗄䈮ᓥ䈦䈩ಣಽ䈜䉎·ᐥ䉕䉋䈒᜞䈐ᬺോ↪䈱ᒝജ䈭ᵞ೷
䈪᳓fifi䉅䈮ᵞᵺ䈜䉎·

ṳ಴‛䈏䈚䉂“䉖䈣࿯䈲ជ˝಴䈚䈩䇮㊄ዻ⵾䊄䊤Ø䈮౉䉏ᑄ᫈Ł
䈱ᵈø䈱㗄䈮ᓥ䈦䈩ಣಽ䈜䉎·

ṳ಴䈚䈢ኈེ䈲ṳ಴䈚䈩䈇䈭䈇ኈེfiಽ䈔䈩䇮ኈེfi䈠䈱ౝኈ‛
䉕䊄䊤Ø෶䈲ṳ಴䈚䈭䈇ኈེ䈮౉䉏ᑄ᫈Ł䈱ᵈø䈮ᓥ䈦䈩ಣಽ䈜
䉎·࿁෼䈚䈢ṳ಴ᶧ䉅ห᭽䈮ಣಽ䈜䉎·

䇼ขᛒ䈇෸䈶଻▤Ł䈱ᵈø䇽㩷
ขᛒ䈇䋺

…⌒෸䈶⴩᦯fi䈱ធ⸅䉕'䈔䉎·
…ขᛒ䈇ᓟ䈲䇮⍹䈔䉖fi᳓䈪⦟䈒ᵞfl·

…᳓ၞ෶䈲⴫ᵹ᳓෸䈶ᐔဋḩầ᳓૏એਅ䈱ầ㑆ᴧᴛ࿾䈮⋥ធᢔ
Ꮣ䈚䈭䈇·
…ᑄᶧ䉁䈢䈲ᢔᏓౕེ䈱ᵞᵺᶧ䉕᳓ၞ䈮ᵹ䈚䈩ᳪᨴ䈚䈭䈇䉋fl䈮䈜
䉎·

଻㩷 ▤䋺
…଻▤䇮ᑄ᫈䈮㓙䈚䇮᳓䇮㘩ᢱ䇮㘺ᢱ෶䈲⒳ሶfi䈱Æ࿷䈏䈭䈇䉋fl䈮

䈜䉎·

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼᥸㔺㒐ᱛភ⟎䇽㩷

᥸㔺㒐ᱛᯏེ㪑
⌒䈱଻⼔㪑 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲⌒䈱଻⼔䈱䈢䉄䈱․೎
䈭଻⼔ౕ䉕ᔅⷐfi䈚䈭䈇·⌒䈮ធ⸅䈚䈭䈇䈢䉄
䈱ㆡ”䈭ភ⟎䉕ข䉎“fi·

⊹⤏䈱଻⼔䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲䇮⊹⤏䈱଻⼔䈱䈢䉄䈱
․೎䈭଻⼔ౕ䉕ᔅⷐfi䈚䈭䈇·

๭ๆ䈮䉋䉎᥸㔺㒐 Ꮧ㉼䈚䈭䈇⵾ຠ䈱ขᛒ䈇䋺㩷Ꮧ㉼䈚 䈩䈇䈭䈇䊤䉡
ᱛ䋺 䊮䊄䉝䉾䊒䉕ㅢᏱ䈱ᣇᴺ䈪ขᛒ䈦䈩䉅᳇ਛ᥸㔺
䈱น⢻ᕈ䈲ૐ䈇·⵾‰ᤨ䈮ᄙ㊂䈱⵾ຠ䈏㔺಴
䈚䈢႐ว䈅䉎䈇䈲Ớෘ䈭⫳᳇䉇䊚䉴䊃䉕„↢䈜
䉎䉋fl䈭૞ᬺ䈮ᓥ੐䈜䉎fi䈐䈲๭ๆེ䈱଻⼔ౕ
䉕⌕↪䈜䉎“fi·ㆡ”䈭଻⼔ౕ䈱ㆬᛯ䈮䈅䈢䈦
䈩䈲䊧䉴䊏䊧䊷䉺䊷䈱⵾‰䊜䊷䉦䊷䈮⋧⺣䈜䉎·
㪥㪠㪦†㪟㪆㪦†㪟‚䈅䉎䈇䈲䊧䉴䊏䊧䊷䉺䊷䈱⵾‰䊜

䊷䉦䊷䈱ᜰቯ䈚䈢૶↪▸࿐ౝ䈪૶↪䈱“fi·㩷

⵾ຠ䊤䊔䊦䈮ᓥ䈦䈢Ꮧ㉼ᶧ䈱ᢔᏓ㪑㩷 䊤䉡䊮䊄䉝
䉾䊒䈱ᢔᏓ↪Ꮧ㉼ᶧ䈱ᢔᏓ䈮䈅䈢䈦䈩䈲䇮䊧䉴
䊏䊧䊷䉺䊷䈲ᔅⷐ䈪䈲䈭䈇·

឵᳇⸳஻ኻ╷䋺 ․ ೎䈭ኻ╷䈲ᔅⷐfi䈚䈭䈇·
㩷᥸㔺ᜰ㊎㪑

᥸㔺ၮḰ 㩷
↥ᬺⴡ↢ቇળ 㩷 㪦†㪟‚㩷ı㪜㪣㩷‚㪚㪞㪠㪟㩷㪫㪣㪭㩷
㩷 㩷
䉫䊥䊖䉰䊷䊃 䈭䈚 䈭䈚 䈭䈚
⇇㕙ᵴᕈ೷ 䈭䈚 䈭䈚 䈭䈚

䇼‛ℂ䋯ൻ㩷⊛ᕈ⾰䇽㪁㩷
`ⷰ 䋺ㅘ᣿☼⒮⦡ᶧ૕

⥇᳇ 䋺䈾fi䉖䈬ή⥇䈭䈇䈚䇮䉒䈝䈎䈮䉝䊚䊮᭽⥇
㫇㪟 䋺’㪅㪍㩷 œ㪈㩼ᶧß

Ყ㊀䋺 㪈㪅㩷㪎
㪁䋺 “䉏䉌䈱୯䈲ᬌ⁄䈮ၮ䈨䈒ᢙ୯䈪䈅䈦䈩䇮ƒ䉌䈧䈐䈱䈅䉎
น⢻ᕈ䈏䈅䉎·㩷
“䉏䉌䈱୯䈲଻⸽୯䈅䉎䈇䈲䇮¤'୯䈪䈲䈭䈇·

䊜䊆䊠䊷䈻ᚯ䉎

㩷ANNEX 121

䇼᥸㔺㒐ᱛភ⟎䇽㩷

᥸㔺㒐ᱛᯏེ㪑
⌒䈱଻⼔㪑 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲⌒䈱଻⼔䈱䈢䉄䈱․೎
䈭଻⼔ౕ䉕ᔅⷐfi䈚䈭䈇·⌒䈮ធ⸅䈚䈭䈇䈢䉄
䈱ㆡ”䈭ភ⟎䉕ข䉎“fi·

⊹⤏䈱଻⼔䋺 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈲䇮⊹⤏䈱଻⼔䈱䈢䉄䈱
․೎䈭଻⼔ౕ䉕ᔅⷐfi䈚䈭䈇·

๭ๆ䈮䉋䉎᥸㔺㒐 Ꮧ㉼䈚䈭䈇⵾ຠ䈱ขᛒ䈇䋺㩷Ꮧ㉼䈚 䈩䈇䈭䈇䊤䉡
ᱛ䋺 䊮䊄䉝䉾䊒䉕ㅢᏱ䈱ᣇᴺ䈪ขᛒ䈦䈩䉅᳇ਛ᥸㔺
䈱น⢻ᕈ䈲ૐ䈇·⵾‰ᤨ䈮ᄙ㊂䈱⵾ຠ䈏㔺಴
䈚䈢႐ว䈅䉎䈇䈲Ớෘ䈭⫳᳇䉇䊚䉴䊃䉕„↢䈜
䉎䉋fl䈭૞ᬺ䈮ᓥ੐䈜䉎fi䈐䈲๭ๆེ䈱଻⼔ౕ
䉕⌕↪䈜䉎“fi·ㆡ”䈭଻⼔ౕ䈱ㆬᛯ䈮䈅䈢䈦
䈩䈲䊧䉴䊏䊧䊷䉺䊷䈱⵾‰䊜䊷䉦䊷䈮⋧⺣䈜䉎·
㪥㪠㪦†㪟㪆㪦†㪟‚䈅䉎䈇䈲䊧䉴䊏䊧䊷䉺䊷䈱⵾‰䊜

䊷䉦䊷䈱ᜰቯ䈚䈢૶↪▸࿐ౝ䈪૶↪䈱“fi·㩷

⵾ຠ䊤䊔䊦䈮ᓥ䈦䈢Ꮧ㉼ᶧ䈱ᢔᏓ㪑㩷 䊤䉡䊮䊄䉝
䉾䊒䈱ᢔᏓ↪Ꮧ㉼ᶧ䈱ᢔᏓ䈮䈅䈢䈦䈩䈲䇮䊧䉴
䊏䊧䊷䉺䊷䈲ᔅⷐ䈪䈲䈭䈇·

឵᳇⸳஻ኻ╷䋺 ․ ೎䈭ኻ╷䈲ᔅⷐfi䈚䈭䈇·
㩷᥸㔺ᜰ㊎㪑

᥸㔺ၮḰ 㩷
↥ᬺⴡ↢ቇળ 㩷 㪦†㪟‚㩷ı㪜㪣‚㪚㪞㪠㪟㩷㪫㪣㪭㩷
㩷 㩷
䉫䊥䊖䉰䊷䊃 䈭䈚 䈭䈚 䈭䈚
⇇㕙ᵴᕈ೷ 䈭䈚 䈭䈚 䈭䈚

䇼‛ℂ䋯ൻቇ㩷ᕈ⾰䇽㪁㩷
`ⷰ 䋺ㅘ᣿☼⒮⦡ᶧ૕

⥇᳇ 䋺䈾fi䉖䈬ή⥇䈭䈇䈚䇮䉒䈝䈎䈮䉝䊚䊮᭽⥇
㫇㪟 䋺’㪅㪍㩷 œ㪈㩼ᶧß

Ყ㊀䋺 㪈㪅㩷㪎
㪁䋺 “䉏䉌䈱୯䈲ᬌ⁄䈮ၮ䈨䈒ᢙ୯䈪䈅䈦䈩䇮ƒ䉌䈧䈐䈱䈅䉎
น⢻ᕈ䈏䈅䉎·㩷
“䉏䉌䈱୯䈲଻⸽୯䈅䉎䈇䈲䇮¤'୯䈪䈲䈭䈇·

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼ෂæᕈᖱႎ䇽䋨቟ቯᕈ…“ᔕᕈ䋩㩷

ᒁἫὐ㪑 㪐㪊㪅㪊㷄㩷œ㪉㪇㪇‹—ßએŁ㩷 ᣇᴺ㪑㩷 㪫㪚㪚
„Ἣὐ䋺 ›ቯ⁄䈝

ൻቇ⊛቟ቯᕈ䋺 ᧄ⵾ຠ䈲䇮ㅢᏱ䈱଻▤᧦ઙ䈮䈍䈇䈩ዋ䈭䈒fi䉅㪌
ᐕ㑆቟ቯ䈪䈅䉎·
fi䈔䉎fl䈐᧦ઙ䋺 䈭䈚

ઁ䈱‛⾰fi䈱㩷 ᧄ⵾ຠ䈍䉋䈶ṁᶧ䈱Æว䇮଻–෶䈲ᢔᏓ䈱䈢䉄
Æว቟ቯᕈ䋺 䈮䈲䇮䉴䊁䊮䊧䉴䉴䉼䊷䊦䇮䉝䊦䊚䊆䉡Ø䇮䊐䉜䉟
䊋䊷䉫䊤䉴䇮䊒䊤䉴䉼䉾ˇ෶䈲䊒䊤䉴䉼䉾ˇ䈱ౝጀ
䈱ኈེౝ䈪ⴕfl“fi·㩷

䊜䉾䉨䉕䈚䈢෶䈲ౝጀ䈱䈭䈇㍑ı⵾䈱ኈེ෶䈲

ᢔᏓౕེ䋨䉴䊁䊮䊧䉴䉴䉼䊷䊦䉕㒰䈒䋩䉕↪䈇䈩Æ
ว䇮଻▤෶䈲ᢔᏓ䈚䈭䈇“fi·“䉏䉌䈱ኈེ䈮䇮ᧄ
⵾ຠ䉕౉䉏䉎fiᒁἫᕈ䈱᳓†䉧䉴䈱Æว᳇૕䉕
↢䈝䉎“fi䈏䈅䉎·“䈱Æว᳇૕䈲ᒁἫ䇮῜„䈱
น⢻ᕈ䈏䈅˝䇮‡Ἣ䇮䉴䊌䊷ˇ䇮ṁធἫ•䇮·⨲䇮
䈠䈱ઁ䈱Ἣ᳇䈮䉋˝ੱり੐᡿䈱ⷐ࿃fi䈭˝fl䉎·

ಽ•‛䈱ෂæᕈ㪑 䈭䈚·
㊀ว䈮䉋䉎ෂæᕈ㪑 䈭䈚·ᧄ⵾ຠ䈲䉝䊦䉦䊥‛⾰fi“ᔕ䈚䇮„‚䈜䉎
น⢻ᕈ䈏䈅䉎·㊀ว䈱น⢻ᕈ䈲䈭䈇䈏䇮㉄䉝䊦䉦
䊥“ᔕ䈮䉋䉎ਛ„‚䉕„↢䈜䉎“fi䈲䈅˝fl䉎·

䇼᦭łᕈᖱႎ䇽㩷
න࿁ᛩਈ䋨”ᕈ䋩Ქᕈ䋺

⚻㩷㩷 ญ㩷㩷 䋺 䊤䉾䊃㪣㪛㪌㪇㩷 ”㩷 㪌ª㪇㪇㪇㩷㫄–䋯㫂–㩷
…䉡䉴㪣㪛㪌㪇㩷 ”㩷 㪌ª㪇㪇㪇㩷㫄–䋯㫂–
⚻㩷㩷 ⊹㩷㩷 䋺 䊤䉾䊃㪣㪛㪌㪇㩷 ”㩷 㪉ª㪇㪇㪇㩷㫄–䋯㫂–

⌒৻‰ೝỗᕈ䋺 ਛ ╬‘䈱ೝỗ
⊹⤏৻‰ೝỗᕈ䋺シ‘ 䈱ೝỗ

⊹⤏ᗵ૞ᕈ㩷㪑㩷 ⁄䊦⁄䉾䊃䉕↪䈇䈢“ᓳᛩਈ䈮䉋䉎⹜㛎䈪䈲䇮⊹
⤏ᗵ૞ᕈ䈲⹺䉄䉌䉏䈭䈎䈦䈢·
ๆ౉Ქᕈ㩷㪑 䉒䈝䈎䈭Ქᕈœ䊤䉾䊃’ᤨ㑆㩷㪣㪚㪌㪇㩷㪕㩷㪉㪅㪉㩷㫄–㪆㪣㩷೔`

น⢻䈭ᦨ㜞᳇ਛỚ‘ß

䊤䉡䊮䊄䉝䉾䊒䈱ᚑಽ䈮䈧䈇䈩⁄䊮䉰䊮䊃␠䈏ታ´䈚䈢⹜㛎䊂䊷䉺㪑

䉫䊥䊖䉰䊷䊃䉟䉸䊒䊨䊏䊦䉝䊚䊮Łœ㪍㪉㩼ß䈜䈭䉒䈤㪤㪦㪥㪇㪈㪊㪐䉕↪䈇䈢Ქ
ᕈ⹜㛎䈱䊂䊷䉺㪑
㩷 㪤㪦㪥㪇㪈㪊㪐䈱“ᓳ⚻ญᛩਈœ㪍䉬᦬ß䈮䉋˝ˆ䈮䉒䈝䈎䈭૕㊀˜ട¯˘
䈏⹺䉄䉌䉏䈢·㪤㪦㪥㪇㪈㪊㪐䈱“ᓳ⚻⊹ᛩਈœ㪊˙㑆ß䈮䉋˝䉡䉰䉩䈮䈍䈇

䈩⹺䉄䉌䉏䈢ᓇ㗀䈲⊹⤏৻‰ೝỗᕈ䈣䈔䈪䈅䈦䈢·
㩷 䉫䊥䊖䉰䊷䊃䈜䈭䉒䈤䊤䉡䊮䊄䉝䉾䊒䈱᦭ലᚑಽ䈮䈧䈇䈩䈱Ქᕈ䈮㑐
䈜䉎ᖱႎ䈲એਅ䈱ㅢ˝౉ᚻน⢻䈪䈅䉎·

㩷 䉫䊥䊖䉰䊷䊃䈱“ᓳᛩਈœ㪐㪇ᣣ㑆ß䈱¨ᨐ…䉡䉴䈮䈍䈇䈩૕㊀˜ട䈱
¯˘䈏⹺䉄䉌䉏䈢䈏䇮䊤䉾䊃䈮䈍䈇䈩䈲䇮૗╬ᛩਈ䈮㑐ㅪ䈜䉎૞↪䈲ANNEX 121

⹺䉄䉌䉏䈭䈎䈦䈢·⊹⤏䈮ኻ䈜䉎“ᓳᛩਈœ㪊˙㑆ß䈱¨ᨐ䇮䉡䉰䉩䈮
䈍䈔䉎ਥⷐ䈭૞↪䈲シ˚䈭⊹⤏ೝỗ䈮fi䈬䉁䈦䈢·⊹⤏䈮ኻ䈜䉎“ᓳ
ᛩਈ䈮䉅䈎䈎䉒䉌䈝⁄䊦⁄䉾䊃䈮䈍䈔䉎⊹⤏ᗵ૞ᕈ䈲䇮⹺䉄䉌䉏䈭䈎
䈦䈢·␹⚻¸䈮ኻ䈜䉎૞↪䈲䇮䊆䊪䊃䊥䈮ኻ䈜䉎ㆃ˝␹⚻Ქᕈ䋨“ᓳ
⚻ญᛩਈ䋩䈅䉎䈇䈲䊤䉾䊃䈮䈍䈔䉎‰䊥䊮˛䉴䊁䊤䊷ˇ—ł䋨න࿁⚻ญ
ᛩਈ䋩䉕฽䉄⹺䉄䉌䉏䈩䈇䈭䈇·㐳ᦼ䈮䉒䈢䉎䉫䊥䊖䉰䊷䊃䈱䋨䋲䉬ᐕ䋩

Æ㙄ᛩਈ⹜㛎䈱¨ᨐ…䉡䉴䈱૕㊀˜ട䈱ᷫዋ෸䈶⢄⚵❱䈮ኻ䈜䉎
ᓇ㗀䈏㜞↪㊂⟲䈮䈍䈇䈩⷗䉌䉏䈢·
㩷䊤䉾䊃 䈮䈍䈔䉎䋱䈧䈱㐳ᦼ䋨䋲䉬ᐕ䋩Æ㙄ᛩਈ⹜㛎䈮䈍䈇䈩૕㊀˜ട
䈱ᷫዋ෸䈶⌒䈱∛ᄌ䈏㜞↪㊂⟲䈮䈍䈇䈩⹺䉄䉌䉏䈢䈏䇮䋲࿁⋡䈱⹜
㛎䈪䈲⹺䉄䉌䉏䈭䈎䈦䈢·“䉏䉌䈱⹜㛎䈮䈍䈇䈩䉫䊥䊖䉰䊷䊃䈮䉋䉎⣲

≌䈱„↢䈲⹺䉄䉌䉏䈭䈎䈦䈢·“䉏䉌䈱ᘟᕈᲥᕈ⹜㛎䈱¨ᨐ䈎䉌☨
࿖ⅣႺ଻⼔ᐡœ㪜ı‚ß䈲䇮䉫䊥䊖䉰䊷䊃䉕௅⣲≌ᕈ䈮䈧䈐䉦䊁䉯䊥䊷㪜œੱ
㑆䈮ኻ䈜䉎„䈏䉖ᕈ䈏䈭䈇ß䈮ಽ㘃䈚䈢·䉫䊥䊖䉰䊷䊃䉕䊤䉾䊃෸䈶䉡
䉰䉩䈱ᅧᆼᦼ䈮Უ₞䈮ኻ䈜䉎Ქᕈ䉕↢䈝䉎↪㊂䈪⚻ญᛩਈ䈚䈩䉅ᄸ
ᒻ䈱„↢䈲⹺䉄䉌䉏䈭䈎䈦䈢·䉫䊥䊖䉰䊷䊃䉕䊤䉾䊃䈱㪉਎˛䈮䉒䈢˝
Œ䉄䈩㜞↪㊂䈪Æ㙄ᛩਈ䈚䈢·Უ₞䈮Ქᕈ䉕↢䈛䈢㜞↪㊂䈪䇮੿േ‛
䈮Ქᕈ䈏⹺䉄䉌䉏䈢·“䉏䉋˝䉅ૐ䈇↪㊂䈪ታ´'䉏䈢䊤䉾䊃䈮䈍䈔䉎
㪊਎˛Æᱺ⹜㛎䈪䈲䊤䉾䊃䈱㓽ª䈱Æᱺ⢻ജ䈮ᓇ㗀䉕ਈ†䈭䈇“fi䈏
᣿䉌䈎䈮䈭䈦䈢·േ‛…േ‛⚦⢩䈅䉎䈇䈲䊋ˇ䊁䊥䉝䈱⚦⢩䉕↪䈇䈢

ᮡḰ⊛⹜㛎¸㩷䈍䈇䈩䉫䊥䊖䉰䊷䊃䈲ㆮવᲥᕈ䉕↢䈛䈭䈎䈦䈢·
⇇㕙ᵴᕈ 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈱ᚑಽ䈪䈅䉎⇇㕙ᵴᕈ೷䈲⌒෸䈶
೷㪑 ⊹⤏䈮ೝỗᕈ䉕↢䈝䉎น⢻ᕈ䈏䈅˝䇮ᧄ೷䈱ೝỗᕈ䈲
⇇㕙㩷ᵴᕈ೷䈱“fl䈚䈢ᕈ⾰䈮䉋䉎น⢻ᕈ䈏䈅䉎·

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼ෂæᕈᖱႎ䇽䋨቟ቯᕈ…“ᔕᕈ䋩㩷

ᒁἫὐ㪑 㪐㪊㪅㪊㷄㩷œ㪉㪇㪇‹—ßએŁ㩷 ᣇᴺ㪑㩷 㪫㪚㪚
„Ἣὐ䋺 ›ቯ⁄䈝

ൻቇ⊛቟ቯᕈ䋺 ᧄ⵾ຠ䈲䇮ㅢᏱ䈱଻▤᧦ઙ䈮䈍䈇䈩ዋ䈭䈒fi䉅㪌
ᐕ㑆቟ቯ䈪䈅䉎·
fi䈔䉎fl䈐᧦ઙ䋺 䈭䈚

ઁ䈱‛⾰fi䈱㩷 ᧄ⵾ຠ䈍䉋䈶ṁᶧ䈱Æว䇮଻–෶䈲ᢔᏓ䈱䈢䉄
Æว቟ቯᕈ䋺 䈮䈲䇮䉴䊁䊮䊧䉴䉴䉼䊷䊦䇮䉝䊦䊚䊆䉡Ø䇮䊐䉜䉟
䊋䊷䉫䊤䉴䇮䊒䊤䉴䉼䉾ˇ෶䈲䊒䊤䉴䉼䉾ˇ䈱ౝጀ
䈱ኈེౝ䈪ⴕfl“fi·㩷

䊜䉾䉨䉕䈚䈢෶䈲ౝጀ䈱䈭䈇㍑ı⵾䈱ኈེ෶䈲

ᢔᏓౕེ䋨䉴䊁䊮䊧䉴䉴䉼䊷䊦䉕㒰䈒䋩䉕↪䈇䈩Æ
ว䇮଻▤෶䈲ᢔᏓ䈚䈭䈇“fi·“䉏䉌䈱ኈེ䈮䇮ᧄ
⵾ຠ䉕౉䉏䉎fiᒁἫᕈ䈱᳓†䉧䉴䈱Æว᳇૕䉕
↢䈝䉎“fi䈏䈅䉎·“䈱Æว᳇૕䈲ᒁἫ䇮῜„䈱
น⢻ᕈ䈏䈅˝䇮‡Ἣ䇮䉴䊌䊷ˇ䇮ṁធἫ•䇮·⨲䇮
䈠䈱ઁ䈱Ἣ᳇䈮䉋˝ੱり੐᡿䈱ⷐ࿃fi䈭˝fl䉎·

ಽ•‛䈱ෂæᕈ㪑 䈭䈚·
㊀ว䈮䉋䉎ෂæᕈ㪑 䈭䈚·ᧄ⵾ຠ䈲䉝䊦䉦䊥‛⾰fi“ᔕ䈚䇮„‚䈜䉎
น⢻ᕈ䈏䈅䉎·㊀ว䈱น⢻ᕈ䈲䈭䈇䈏䇮㉄䉝䊦䉦
䊥“ᔕ䈮䉋䉎ਛ„‚䉕„↢䈜䉎“fi䈲䈅˝fl䉎·

䇼᦭łᕈᖱႎ䇽㩷
න࿁ᛩਈ䋨”ᕈ䋩Ქᕈ䋺

⚻㩷㩷 ญ㩷㩷 䋺 䊤䉾䊃㪣㪛㪌㪇㩷 ”㩷 㪌ª㪇㪇㪇㩷㫄–䋯㫂–㩷
…䉡䉴㪣㪛㪌㪇㩷 ”㩷 㪌ª㪇㪇㪇㩷㫄–䋯㫂–
⚻㩷㩷 ⊹㩷㩷 䋺 䊤䉾䊃㪣㪛㪌㪇㩷 ”㩷 㪉ª㪇㪇㪇㩷㫄–䋯㫂–

⌒৻‰ೝỗᕈ䋺 ਛ ╬‘䈱ೝỗ
⊹⤏৻‰ೝỗᕈ䋺シ‘ 䈱ೝỗ

⊹⤏ᗵ૞ᕈ㩷㪑㩷 ⁄䊦⁄䉾䊃䉕↪䈇䈢“ᓳᛩਈ䈮䉋䉎⹜㛎䈪䈲䇮⊹
⤏ᗵ૞ᕈ䈲⹺䉄䉌䉏䈭䈎䈦䈢·
ๆ౉Ქᕈ㩷㪑 䉒䈝䈎䈭Ქᕈœ䊤䉾䊃’ᤨ㑆㩷㪣㪚㪌㪇㩷㪕㩷㪉㪅㪉㩷㫄–㪆㪣㩷೔`

น⢻䈭ᦨ㜞᳇ਛỚ‘ß

䊤䉡䊮䊄䉝䉾䊒䈱ᚑಽ䈮䈧䈇䈩⁄䊮䉰䊮䊃␠䈏ታ´䈚䈢⹜㛎䊂䊷䉺㪑

䉫䊥䊖䉰䊷䊃䉟䉸䊒䊨䊏䊦䉝䊚䊮Łœ㪍㪉㩼ß䈜䈭䉒䈤㪤㪦㪥㪇㪈㪊㪐䉕↪䈇䈢Ქ
ᕈ⹜㛎䈱䊂䊷䉺㪑
㩷 㪤㪦㪥㪇㪈㪊㪐䈱“ᓳ⚻ญᛩਈœ㪍䉬᦬ß䈮䉋˝ˆ䈮䉒䈝䈎䈭૕㊀˜ട¯˘
䈏⹺䉄䉌䉏䈢·㪤㪦㪥㪇㪈㪊㪐䈱“ᓳ⚻⊹ᛩਈœ㪊˙㑆ß䈮䉋˝䉡䉰䉩䈮䈍䈇

䈩⹺䉄䉌䉏䈢ᓇ㗀䈲⊹⤏৻‰ೝỗᕈ䈣䈔䈪䈅䈦䈢·
㩷 䉫䊥䊖䉰䊷䊃䈜䈭䉒䈤䊤䉡䊮䊄䉝䉾䊒䈱᦭ലᚑಽ䈮䈧䈇䈩䈱Ქᕈ䈮㑐
䈜䉎ᖱႎ䈲એਅ䈱ㅢ˝౉ᚻน⢻䈪䈅䉎·

㩷 䉫䊥䊖䉰䊷䊃䈱“ᓳᛩਈœ㪐㪇ᣣ㑆ß䈱¨ᨐ…䉡䉴䈮䈍䈇䈩૕㊀˜ട䈱
¯˘䈏⹺䉄䉌䉏䈢䈏䇮䊤䉾䊃䈮䈍䈇䈩䈲䇮૗╬ᛩਈ䈮㑐ㅪ䈜䉎૞↪䈲ANNEX 121

⹺䉄䉌䉏䈭䈎䈦䈢·⊹⤏䈮ኻ䈜䉎“ᓳᛩਈœ㪊˙㑆ß䈱¨ᨐ䇮䉡䉰䉩䈮
䈍䈔䉎ਥⷐ䈭૞↪䈲シ˚䈭⊹⤏ೝỗ䈮fi䈬䉁䈦䈢·⊹⤏䈮ኻ䈜䉎“ᓳ
ᛩਈ䈮䉅䈎䈎䉒䉌䈝⁄䊦⁄䉾䊃䈮䈍䈔䉎⊹⤏ᗵ૞ᕈ䈲䇮⹺䉄䉌䉏䈭䈎
䈦䈢·␹⚻¸䈮ኻ䈜䉎૞↪䈲䇮䊆䊪䊃䊥䈮ኻ䈜䉎ㆃ˝␹⚻Ქᕈ䋨“ᓳ
⚻ญᛩਈ䋩䈅䉎䈇䈲䊤䉾䊃䈮䈍䈔䉎‰䊥䊮˛䉴䊁䊤䊷ˇ—ł䋨න࿁⚻ญ
ᛩਈ䋩䉕฽䉄⹺䉄䉌䉏䈩䈇䈭䈇·㐳ᦼ䈮䉒䈢䉎䉫䊥䊖䉰䊷䊃䈱䋨䋲䉬ᐕ䋩

Æ㙄ᛩਈ⹜㛎䈱¨ᨐ…䉡䉴䈱૕㊀˜ട䈱ᷫዋ෸䈶⢄⚵❱䈮ኻ䈜䉎
ᓇ㗀䈏㜞↪㊂⟲䈮䈍䈇䈩⷗䉌䉏䈢·
㩷䊤䉾䊃 䈮䈍䈔䉎䋱䈧䈱㐳ᦼ䋨䋲䉬ᐕ䋩Æ㙄ᛩਈ⹜㛎䈮䈍䈇䈩૕㊀˜ട
䈱ᷫዋ෸䈶⌒䈱∛ᄌ䈏㜞↪㊂⟲䈮䈍䈇䈩⹺䉄䉌䉏䈢䈏䇮䋲࿁⋡䈱⹜
㛎䈪䈲⹺䉄䉌䉏䈭䈎䈦䈢·“䉏䉌䈱⹜㛎䈮䈍䈇䈩䉫䊥䊖䉰䊷䊃䈮䉋䉎⣲

≌䈱„↢䈲⹺䉄䉌䉏䈭䈎䈦䈢·“䉏䉌䈱ᘟᕈᲥᕈ⹜㛎䈱¨ᨐ䈎䉌☨
࿖ⅣႺ଻⼔ᐡœ㪜ı‚ß䈲䇮䉫䊥䊖䉰䊷䊃䉕௅⣲≌ᕈ䈮䈧䈐䉦䊁䉯䊥䊷㪜œੱ
㑆䈮ኻ䈜䉎„䈏䉖ᕈ䈏䈭䈇ß䈮ಽ㘃䈚䈢·䉫䊥䊖䉰䊷䊃䉕䊤䉾䊃෸䈶䉡
䉰䉩䈱ᅧᆼᦼ䈮Უ₞䈮ኻ䈜䉎Ქᕈ䉕↢䈝䉎↪㊂䈪⚻ญᛩਈ䈚䈩䉅ᄸ
ᒻ䈱„↢䈲⹺䉄䉌䉏䈭䈎䈦䈢·䉫䊥䊖䉰䊷䊃䉕䊤䉾䊃䈱㪉਎˛䈮䉒䈢˝
Œ䉄䈩㜞↪㊂䈪Æ㙄ᛩਈ䈚䈢·Უ₞䈮Ქᕈ䉕↢䈛䈢㜞↪㊂䈪䇮੿േ‛
䈮Ქᕈ䈏⹺䉄䉌䉏䈢·“䉏䉋˝䉅ૐ䈇↪㊂䈪ታ´'䉏䈢䊤䉾䊃䈮䈍䈔䉎
㪊਎˛Æᱺ⹜㛎䈪䈲䊤䉾䊃䈱㓽ª䈱Æᱺ⢻ജ䈮ᓇ㗀䉕ਈ†䈭䈇“fi䈏
᣿䉌䈎䈮䈭䈦䈢·േ‛…േ‛⚦⢩䈅䉎䈇䈲䊋ˇ䊁䊥䉝䈱⚦⢩䉕↪䈇䈢

ᮡḰ⊛⹜㛎¸㩷䈍䈇䈩䉫䊥䊖䉰䊷䊃䈲ㆮવᲥᕈ䉕↢䈛䈭䈎䈦䈢·
⇇㕙ᵴᕈ 䊤䉡䊮䊄䉝䉾䊒㒰⨲೷䈱ᚑಽ䈪䈅䉎⇇㕙ᵴᕈ೷䈲⌒෸䈶
೷㪑 ⊹⤏䈮ೝỗᕈ䉕↢䈝䉎น⢻ᕈ䈏䈅˝䇮ᧄ೷䈱ೝỗᕈ䈲
⇇㕙㩷ᵴᕈ೷䈱“fl䈚䈢ᕈ⾰䈮䉋䉎น⢻ᕈ䈏䈅䉎·

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼ⅣႺᓇ㗀ᖱႎ䇽㩷

㩷 㪤㪦㪥㪎㪏㪎’㪉䈲˛⴫⊛᳓↢↢‛䈮ኻ䈚䇮ૐᲥᕈ䉕␜䈚䈢·Łᦼ
⹜㛎䈪䈲䇮䉒䈝䈎䈭Ქᕈ䉕Ø㘃œ‰䉟’㪏Œ㩷㪐㪍ᤨ㑆㪣㪚㪌㪇㩷
㪉㪌㪅’㫄–㪆㪣ß෸䈶᳓↢ήºᬁേ‛œ䉥䉥䊚䉳䊮‰㩷㪛㪸㫇㪿›‹㪸㩷㫄㪸–›㪸㩷
㪉’ᤨ㑆㪣㪚㪌㪇㩷㪎㪅㪍’㫄–㪆㪣䇮ห䋳ᤨ㑆㪣㪚㪌㪇㩷㪈㪇㪇㪇㫄–㪆㪣ß䈮␜䈚䈢·

㩷 Ḗ᳓᳓↰᧦ઙ䈮䈍䈔䉎‰䉟䈱Ქᕈ⹜㛎䈪䈲ଏ⹜䈚䈢䈬䈱Ớ
‘䈪䉅ᱫ੢䈲⹺䉄䉌䉏䈭䈎䈦䈢·ଏ⹜Ớ‘䈲ㅢᏱ䈱ᢔᏓ䉋˝
↢䈝䉎Ớ‘fiห䈛䈎䉋˝㜞䈇Ớ‘䈪䈅䈦䈢·⹜㛎ᦼ㑆䈲㪐㪍ᤨ㑆
䈪䈅䈦䈢·

䇼ャㅍŁ䈱ᵈø䇽㩷

ขᛒ䈇଻▤䈱㗄䈱ᵈø੐㗄෸䈶㒰⨲೷䈱৻æ⊛ᵈø੐㗄䉕቞䉎
“fi·
࿖ㅪಽ㘃෸䈶࿖ㅪ⇟ภ㪑㩷 ᥉ㅢ‛䈮䈧䈐⹥¨⁄䈝·

䇼ᑄ᫈Ł䈱ᵈø䇽㩷
ᧄ⵾ຠ૶↪䈮’flᑄ᫈‛䈪૶↪䈮ㆡ'䈭䈇䈎䇮䉁䈢䈲ൻቇ⊛䈮ౣ
೑↪䈪䈐䈭䈇‛䈲ㄘ⮎䈱ᑄ᫈䈱⸵น'䉏䈩䈇䉎วᴺ⊛䈭ᣇᴺ䈪ㆡ
”䈮ಣℂ䈜䉎“fi·

㩷 ⓨኈེ䈮䈲⫳᳇fi⵾ຠ䈱ı⇐‛䈏ı䈦䈩䈇䉎·ኈེ䉕ᵞᵺ䈜䉎䈎
⎕᫈䈜䉎䉁䈪䈲⵾ຠ䊤䊔䊦䈱ᵈø੐㗄䉕቞䉎“fi·ᧄኈེ䈱ㄭ䈒䈪
”ł䇮䉁䈢䈲ṁធ૞ᬺ䉕ⴕ䉒䈭䈇“fi·

㩷 ኈེ㩷ౣ೑↪䈚䈭䈇“fi·ኈེ䉕㪊࿁ᵞᵺ䈚䇮
œ㪈ß ø↸œ䈏࿁෼…ಣಽ䈚䈩䈇䉎fi“ß䈪䈲䇮ቯ䉄䉌䉏䈢ᣇᴺ䈮䉋
˝ಣಽ䈜䉎·

œ㪉ß ㄘ⮎䈱ⓨኈེ䉕ㆡᱜ䈮࿁෼ಣಽ䈜䉎䉲䉴䊁Ø䈏⏕Ø䈚䈩䈇䉎
fi“ß䈪䈲䇮¨⹥䉲䉴䊁Ø䈮䉋˝ಣಽ䈜䉎·
œ㪊ß ㄘኅ╬ㄘ⮎ⓨኈེ䈱ឃ಴੐ᬺ⠪䈏䇮‘䉌↥ᬺᑄ᫈‛ᬺ⠪䈮
ಣℂ䉕ᆔ⸤䈜䉎·

䇼ㆡ↪ᴺ઎䇽㩷 㩷
ㄘ⮎ข✦ 㒰⨲೷䇮ㄘᨋ᳓↥⋭㩷 ⊓㍳㩷 ╙㪈’㪊㪍㪇ภ
ᴺ㪑

ൻ㩷 ክ㩷ᴺ㪑ᣢ–ൻቇ‛⾰㩷 䌎㪄œ䊖䉴䊖䊉䊜䉼䊦䋩䉫䊥䉲䊮

䇼䈠䈱ઁ䇽㩷

ᧄ቟ో䊂䊷䉺䉲䊷䊃䈲⵾ຠ䊤䊔䊦œ⵾ຠ䈱ኈེ䈮ᷝઃ'䉏䈩䈇䉎ßfi
䈲೎䈱⋡⊛䈪૞ᚑ'䉏䈢䉅䈱䈪䈅䉎·቟ో䊂䊷䉺䉲䊷䊃䈲䇮ஜᐽ䇮
቟ో䇮ⅣႺ䈱଻ో䈮㑐䈜䉎㊀ⷐ䈭ᖱႎ䉕ᄙ㊂䈱⵾ຠ䉕ᧄ೷䈱ᧄ᧪
⋡⊛fi䈜䉎૶↪fi䈲೎䈮ขᛒfl૞ᬺ⠪䇮䈠䈱㓹↪⠪෸䈶„”ኻ╷
ⷐຬ䈮ኻ䈚ឭଏ䈜䉎䈢䉄䈮↪ø'䉏䈩䈇䉎·

৻ᣇ䇮⵾ຠ䊤䊔䊦䈲ㅢᏱ䈮૶↪ᣇᴺ䉕ౕ૕⊛䈮␜䈜ᖱႎ䉕ឭଏ䈜
䉎䉅䈱䈪䈅䉎·
ㄘ⮎䈱૶↪䇮଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈲䇮⵾ຠ䊤䊔䊦䈮 ᓥfl“fi䇮䉁
䈢䇮૶↪଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈱ᔅⷐ䈮䈚䈩ㆡ”䈭ᵈø੐㗄䈲⵾

ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䉎·⵾ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䈭䈇ᣇᴺ䈮
䉋䉎૶↪䈲⣕ᴺⴕὑ䈪䈅䉎·ANNEX 121

““䈮⸥タ䈜䉎ᖱႎ෸䈶ᵈø੐㗄䋨એਅ䇸ᖱႎ䇹fi䈇fl䋩䈲䇮Ł⸥䈱ᣣ
ઃ䈱ᤨὐ䈪ᱜ⏕䈭䉅䈱fiା䈛ឭ␜䈚䈢䉅䈱䈪䈅䉎䈏䇮⁄䊮䉰䊮䊃␠䈲䇮
ᖱႎ䈱ቢోᕈ෶䈲ᱜ⏕ᕈ䉕ł⸒䈜䉎䉅䈱䈪䈲䈭䈇·ᖱႎ䈲䇮䈠䉏䉕
ฃ䈔ข䉎⠪䈏䇮䈠䉏䉕೑↪䈜䉎೨䈮‘Ꮖ䈱⋡⊛䈮ㆡ䈚䈩䈇䉎䈎䈬fl䈎
䉕‘ಽ䈪್ł䈜䉎fi䈇fl᧦ઙ䈮ၮ䈨䈇䈩ଏ⛎'䉏䉎䉅䈱䈪䈅䉎·ᖱႎ
䈱૶↪䈮䉋䈦䈩෶䈲“䉏䉕ା㗬䈚䈢䈢䉄䈮૗䉌䈎䈱ᕈ⾰䈱ⵍł䈏„

↢䈚䈩䉅䇮⁄䊮䉰䊮䊃␠䈲䈇䈎䈭䉎႐ว䉅ⵍł䈮ኻ䈜䉎⽿છ䉕⽶䉒䈭
䈇·ᧄᢥᦠ䈮ឝタ䈚䈢ᖱႎ෶䈲ᖱႎ䈏⸒෸䈚䈢⵾ຠ䈮㑐䈚䈩䇮䈠䈱ø
႐ᕈ䇮․ቯ䈱↪ㅜ䈻䈱ㆡวᕈ䇮෶䈲䈠䈱ઁ䈱ᕈ⾰䈮䈧䈇䈩䇮ᥧ␜⊛
䈮䉅䇮““䈮ł⸒෶䈲଻⸽䈜䉎䉅䈱䈪䈲䈭䈇·㩷


⽷࿅ᴺੱ㩷 ᣣᧄਛᲥᖱႎ䉶䊮䉺䊷㩷

ᢔᏓ૞ᬺਛ䉇ᢔᏓᓟ䈮⇣Ᏹ䉕ᗵ䈛䈢႐ว䈲䇮⋥䈤䈮කᏧ䈱ᚻ¨䉕
ฃ䈔䈩ਅ'䈇·㩷ಣ⟎ᴺ䈭䈬䈪ਇ᣿䈭“fi䈲䇮කᏧ䈎䉌ਅ⸥䈮㔚…䈚
䈩䈍዆䈰ਅ'䈇·㩷

㩷 䉻䉟䊟䊦䌑㪉㩷㩷 ක≮ᯏ㑐ኾ↪㩷
ਛᲥ㪈㪈㪇⇟ 䋨㪊ಽ㪊㪇㪇౞㩷 ᦭ᢱ㔚…㩷
䋨৻ઙ䈮䈧䈐㪉ª㪇㪇㪇౞䋩

ᄢ㩷 ’㩷 㪇㪐㪐㪇㪄㪌㪇㪄㪉’㪐㪐 㪇㪎㪉㪎㪄㪉㪍㪄㪐㪐㪉㪊
䋨㪊㪍㪌ᣣ…㪉’ᤨ㑆ኻᔕ䋩
䈧䈒ƒ㩷
䋨㪊㪍㪌ᣣ…㪐䌾㪉㪈ᤨኻᔕ䋩 㪇㪐㪐㪇㪄㪌㪉㪄㪐㪏㪐㪐 㪇㪉㪐㪏㪄㪌㪈㪄㪐㪐㪐㪐

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼ⅣႺᓇ㗀ᖱႎ䇽㩷

㩷 㪤㪦㪥㪎㪏㪎’㪉䈲˛⴫⊛᳓↢↢‛䈮ኻ䈚䇮ૐᲥᕈ䉕␜䈚䈢·Łᦼ
⹜㛎䈪䈲䇮䉒䈝䈎䈭Ქᕈ䉕Ø㘃œ‰䉟’㪏Œ㩷㪐㪍ᤨ㑆㪣㪚㪌㪇㩷
㪉㪌㪅’㫄–㪆㪣ß෸䈶᳓↢ήºᬁേ‛œ䉥䉥䊚䉳䊮‰㩷㪛㪸㫇㪿›‹㪸㩷㫄㪸–›㪸㩷
㪉’ᤨ㑆㪣㪚㪌㪇㩷㪎㪅㪍’㫄–㪆㪣䇮ห䋳ᤨ㑆㪣㪚㪌㪇㩷㪈㪇㪇㪇㫄–㪆㪣ß䈮␜䈚䈢·

㩷 Ḗ᳓᳓↰᧦ઙ䈮䈍䈔䉎‰䉟䈱Ქᕈ⹜㛎䈪䈲ଏ⹜䈚䈢䈬䈱Ớ
‘䈪䉅ᱫ੢䈲⹺䉄䉌䉏䈭䈎䈦䈢·ଏ⹜Ớ‘䈲ㅢᏱ䈱ᢔᏓ䉋˝
↢䈝䉎Ớ‘fiห䈛䈎䉋˝㜞䈇Ớ‘䈪䈅䈦䈢·⹜㛎ᦼ㑆䈲㪐㪍ᤨ㑆
䈪䈅䈦䈢·

䇼ャㅍŁ䈱ᵈø䇽㩷

ขᛒ䈇଻▤䈱㗄䈱ᵈø੐㗄෸䈶㒰⨲೷䈱৻æ⊛ᵈø੐㗄䉕቞䉎
“fi·
࿖ㅪಽ㘃෸䈶࿖ㅪ⇟ภ㪑㩷 ᥉ㅢ‛䈮䈧䈐⹥¨⁄䈝·

䇼ᑄ᫈Ł䈱ᵈø䇽㩷
ᧄ⵾ຠ૶↪䈮’flᑄ᫈‛䈪૶↪䈮ㆡ'䈭䈇䈎䇮䉁䈢䈲ൻቇ⊛䈮ౣ
೑↪䈪䈐䈭䈇‛䈲ㄘ⮎䈱ᑄ᫈䈱⸵น'䉏䈩䈇䉎วᴺ⊛䈭ᣇᴺ䈪ㆡ
”䈮ಣℂ䈜䉎“fi·

㩷 ⓨኈེ䈮䈲⫳᳇fi⵾ຠ䈱ı⇐‛䈏ı䈦䈩䈇䉎·ኈེ䉕ᵞᵺ䈜䉎䈎
⎕᫈䈜䉎䉁䈪䈲⵾ຠ䊤䊔䊦䈱ᵈø੐㗄䉕቞䉎“fi·ᧄኈེ䈱ㄭ䈒䈪
”ł䇮䉁䈢䈲ṁធ૞ᬺ䉕ⴕ䉒䈭䈇“fi·

㩷 ኈེ㩷ౣ೑↪䈚䈭䈇“fi·ኈེ䉕㪊࿁ᵞᵺ䈚䇮
œ㪈ß ø↸œ䈏࿁෼…ಣಽ䈚䈩䈇䉎fi“ß䈪䈲䇮ቯ䉄䉌䉏䈢ᣇᴺ䈮䉋
˝ಣಽ䈜䉎·

œ㪉ß ㄘ⮎䈱ⓨኈེ䉕ㆡᱜ䈮࿁෼ಣಽ䈜䉎䉲䉴䊁Ø䈏⏕Ø䈚䈩䈇䉎
fi“ß䈪䈲䇮¨⹥䉲䉴䊁Ø䈮䉋˝ಣಽ䈜䉎·
œ㪊ß ㄘኅ╬ㄘ⮎ⓨኈེ䈱ឃ಴੐ᬺ⠪䈏䇮‘䉌↥ᬺᑄ᫈‛ᬺ⠪䈮
ಣℂ䉕ᆔ⸤䈜䉎·

䇼ㆡ↪ᴺ઎䇽㩷 㩷
ㄘ⮎ข✦ 㒰⨲೷䇮ㄘᨋ᳓↥⋭㩷 ⊓㍳㩷 ╙㪈’㪊㪍㪇ภ
ᴺ㪑

ൻ㩷 ክ㩷ᴺ㪑ᣢ–ൻቇ‛⾰㩷 䌎㪄œ䊖䉴䊖䊉䊜䉼䊦䋩䉫䊥䉲䊮

䇼䈠䈱ઁ䇽㩷

ᧄ቟ో䊂䊷䉺䉲䊷䊃䈲⵾ຠ䊤䊔䊦œ⵾ຠ䈱ኈེ䈮ᷝઃ'䉏䈩䈇䉎ßfi
䈲೎䈱⋡⊛䈪૞ᚑ'䉏䈢䉅䈱䈪䈅䉎·቟ో䊂䊷䉺䉲䊷䊃䈲䇮ஜᐽ䇮
቟ో䇮ⅣႺ䈱଻ో䈮㑐䈜䉎㊀ⷐ䈭ᖱႎ䉕ᄙ㊂䈱⵾ຠ䉕ᧄ೷䈱ᧄ᧪
⋡⊛fi䈜䉎૶↪fi䈲೎䈮ขᛒfl૞ᬺ⠪䇮䈠䈱㓹↪⠪෸䈶„”ኻ╷
ⷐຬ䈮ኻ䈚ឭଏ䈜䉎䈢䉄䈮↪ø'䉏䈩䈇䉎·

৻ᣇ䇮⵾ຠ䊤䊔䊦䈲ㅢᏱ䈮૶↪ᣇᴺ䉕ౕ૕⊛䈮␜䈜ᖱႎ䉕ឭଏ䈜
䉎䉅䈱䈪䈅䉎·
ㄘ⮎䈱૶↪䇮଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈲䇮⵾ຠ䊤䊔䊦䈮 ᓥfl“fi䇮䉁
䈢䇮૶↪଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈱ᔅⷐ䈮䈚䈩ㆡ”䈭ᵈø੐㗄䈲⵾

ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䉎·⵾ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䈭䈇ᣇᴺ䈮
䉋䉎૶↪䈲⣕ᴺⴕὑ䈪䈅䉎·ANNEX 121

““䈮⸥タ䈜䉎ᖱႎ෸䈶ᵈø੐㗄䋨એਅ䇸ᖱႎ䇹fi䈇fl䋩䈲䇮Ł⸥䈱ᣣ
ઃ䈱ᤨὐ䈪ᱜ⏕䈭䉅䈱fiା䈛ឭ␜䈚䈢䉅䈱䈪䈅䉎䈏䇮⁄䊮䉰䊮䊃␠䈲䇮
ᖱႎ䈱ቢోᕈ෶䈲ᱜ⏕ᕈ䉕ł⸒䈜䉎䉅䈱䈪䈲䈭䈇·ᖱႎ䈲䇮䈠䉏䉕
ฃ䈔ข䉎⠪䈏䇮䈠䉏䉕೑↪䈜䉎೨䈮‘Ꮖ䈱⋡⊛䈮ㆡ䈚䈩䈇䉎䈎䈬fl䈎
䉕‘ಽ䈪್ł䈜䉎fi䈇fl᧦ઙ䈮ၮ䈨䈇䈩ଏ⛎'䉏䉎䉅䈱䈪䈅䉎·ᖱႎ
䈱૶↪䈮䉋䈦䈩෶䈲“䉏䉕ା㗬䈚䈢䈢䉄䈮૗䉌䈎䈱ᕈ⾰䈱ⵍł䈏„

↢䈚䈩䉅䇮⁄䊮䉰䊮䊃␠䈲䈇䈎䈭䉎႐ว䉅ⵍł䈮ኻ䈜䉎⽿છ䉕⽶䉒䈭
䈇·ᧄᢥᦠ䈮ឝタ䈚䈢ᖱႎ෶䈲ᖱႎ䈏⸒෸䈚䈢⵾ຠ䈮㑐䈚䈩䇮䈠䈱ø
႐ᕈ䇮․ቯ䈱↪ㅜ䈻䈱ㆡวᕈ䇮෶䈲䈠䈱ઁ䈱ᕈ⾰䈮䈧䈇䈩䇮ᥧ␜⊛
䈮䉅䇮““䈮ł⸒෶䈲଻⸽䈜䉎䉅䈱䈪䈲䈭䈇·㩷


⽷࿅ᴺੱ㩷 ᣣᧄਛᲥᖱႎ䉶䊮䉺䊷㩷

ᢔᏓ૞ᬺਛ䉇ᢔᏓᓟ䈮⇣Ᏹ䉕ᗵ䈛䈢႐ว䈲䇮⋥䈤䈮කᏧ䈱ᚻ¨䉕
ฃ䈔䈩ਅ'䈇·㩷ಣ⟎ᴺ䈭䈬䈪ਇ᣿䈭“fi䈲䇮කᏧ䈎䉌ਅ⸥䈮㔚…䈚
䈩䈍዆䈰ਅ'䈇·㩷

㩷 䉻䉟䊟䊦䌑㪉㩷㩷 ක≮ᯏ㑐ኾ↪㩷
ਛᲥ㪈㪈㪇⇟ 䋨㪊ಽ㪊㪇㪇౞㩷 ᦭ᢱ㔚…㩷
䋨৻ઙ䈮䈧䈐㪉ª㪇㪇㪇౞䋩

ᄢ㩷 ’㩷 㪇㪐㪐㪇㪄㪌㪇㪄㪉’㪐㪐 㪇㪎㪉㪎㪄㪉㪍㪄㪐㪐㪉㪊
䋨㪊㪍㪌ᣣ…㪉’ᤨ㑆ኻᔕ䋩
䈧䈒ƒ㩷
䋨㪊㪍㪌ᣣ…㪐䌾㪉㪈ᤨኻᔕ䋩 㪇㪐㪐㪇㪄㪌㪉㪄㪐㪏㪐㪐 㪇㪉㪐㪏㪄㪌㪈㪄㪐㪐㪐㪐

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼ⅣႺᓇ㗀ᖱႎ䇽㩷

㩷 㪤㪦㪥㪎㪏㪎’㪉䈲˛⴫⊛᳓↢↢‛䈮ኻ䈚䇮ૐᲥᕈ䉕␜䈚䈢·Łᦼ
⹜㛎䈪䈲䇮䉒䈝䈎䈭Ქᕈ䉕Ø㘃œ‰䉟’㪏Œ㩷㪐㪍ᤨ㑆㪣㪚㪌㪇㩷
㪉㪌㪅’㫄–㪆㪣ß෸䈶᳓↢ήºᬁേ‛œ䉥䉥䊚䉳䊮‰㩷㪛㪸㫇㪿›‹㪸㩷㫄㪸–›㪸㩷
㪉’ᤨ㑆㪣㪚㪌㪇㩷㪎㪅㪍’㫄–㪆㪣䇮ห䋳ᤨ㑆㪣㪚㪌㪇㩷㪈㪇㪇㪇㫄–㪆㪣ß䈮␜䈚䈢·

㩷 Ḗ᳓᳓↰᧦ઙ䈮䈍䈔䉎‰䉟䈱Ქᕈ⹜㛎䈪䈲ଏ⹜䈚䈢䈬䈱Ớ
‘䈪䉅ᱫ੢䈲⹺䉄䉌䉏䈭䈎䈦䈢·ଏ⹜Ớ‘䈲ㅢᏱ䈱ᢔᏓ䉋˝
↢䈝䉎Ớ‘fiห䈛䈎䉋˝㜞䈇Ớ‘䈪䈅䈦䈢·⹜㛎ᦼ㑆䈲㪐㪍ᤨ㑆
䈪䈅䈦䈢·

䇼ャㅍŁ䈱ᵈø䇽㩷

ขᛒ䈇଻▤䈱㗄䈱ᵈø੐㗄෸䈶㒰⨲೷䈱৻æ⊛ᵈø੐㗄䉕቞䉎
“fi·
࿖ㅪಽ㘃෸䈶࿖ㅪ⇟ภ㪑㩷 ᥉ㅢ‛䈮䈧䈐⹥¨⁄䈝·

䇼ᑄ᫈Ł䈱ᵈø䇽㩷
ᧄ⵾ຠ૶↪䈮’flᑄ᫈‛䈪૶↪䈮ㆡ'䈭䈇䈎䇮䉁䈢䈲ൻቇ⊛䈮ౣ
೑↪䈪䈐䈭䈇‛䈲ㄘ⮎䈱ᑄ᫈䈱⸵น'䉏䈩䈇䉎วᴺ⊛䈭ᣇᴺ䈪ㆡ
”䈮ಣℂ䈜䉎“fi·

㩷 ⓨኈེ䈮䈲⫳᳇fi⵾ຠ䈱ı⇐‛䈏ı䈦䈩䈇䉎·ኈེ䉕ᵞᵺ䈜䉎䈎
⎕᫈䈜䉎䉁䈪䈲⵾ຠ䊤䊔䊦䈱ᵈø੐㗄䉕቞䉎“fi·ᧄኈེ䈱ㄭ䈒䈪
”ł䇮䉁䈢䈲ṁធ૞ᬺ䉕ⴕ䉒䈭䈇“fi·

㩷 ኈེ㩷ౣ೑↪䈚䈭䈇“fi·ኈེ䉕㪊࿁ᵞᵺ䈚䇮
œ㪈ß ø↸œ䈏࿁෼…ಣಽ䈚䈩䈇䉎fi“ß䈪䈲䇮ቯ䉄䉌䉏䈢ᣇᴺ䈮䉋
˝ಣಽ䈜䉎·

œ㪉ß ㄘ⮎䈱ⓨኈེ䉕ㆡᱜ䈮࿁෼ಣಽ䈜䉎䉲䉴䊁Ø䈏⏕Ø䈚䈩䈇䉎
fi“ß䈪䈲䇮¨⹥䉲䉴䊁Ø䈮䉋˝ಣಽ䈜䉎·
œ㪊ß ㄘኅ╬ㄘ⮎ⓨኈེ䈱ឃ಴੐ᬺ⠪䈏䇮‘䉌↥ᬺᑄ᫈‛ᬺ⠪䈮
ಣℂ䉕ᆔ⸤䈜䉎·

䇼ㆡ↪ᴺ઎䇽㩷 㩷
ㄘ⮎ข✦ 㒰⨲೷䇮ㄘᨋ᳓↥⋭㩷 ⊓㍳㩷 ╙㪈’㪊㪍㪇ภ
ᴺ㪑

ൻ㩷 ክ㩷ᴺ㪑ᣢ–ൻቇ‛⾰㩷 䌎㪄œ䊖䉴䊖䊉䊜䉼䊦䋩䉫䊥䉲䊮

䇼䈠䈱ઁ䇽㩷

ᧄ቟ో䊂䊷䉺䉲䊷䊃䈲⵾ຠ䊤䊔䊦œ⵾ຠ䈱ኈེ䈮ᷝઃ'䉏䈩䈇䉎ßfi
䈲೎䈱⋡⊛䈪૞ᚑ'䉏䈢䉅䈱䈪䈅䉎·቟ో䊂䊷䉺䉲䊷䊃䈲䇮ஜᐽ䇮
቟ో䇮ⅣႺ䈱଻ో䈮㑐䈜䉎㊀ⷐ䈭ᖱႎ䉕ᄙ㊂䈱⵾ຠ䉕ᧄ೷䈱ᧄ᧪
⋡⊛fi䈜䉎૶↪fi䈲೎䈮ขᛒfl૞ᬺ⠪䇮䈠䈱㓹↪⠪෸䈶„”ኻ╷
ⷐຬ䈮ኻ䈚ឭଏ䈜䉎䈢䉄䈮↪ø'䉏䈩䈇䉎·

৻ᣇ䇮⵾ຠ䊤䊔䊦䈲ㅢᏱ䈮૶↪ᣇᴺ䉕ౕ૕⊛䈮␜䈜ᖱႎ䉕ឭଏ䈜
䉎䉅䈱䈪䈅䉎·
ㄘ⮎䈱૶↪䇮଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈲䇮⵾ຠ䊤䊔䊦䈮 ᓥfl“fi䇮䉁
䈢䇮૶↪଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈱ᔅⷐ䈮䈚䈩ㆡ”䈭ᵈø੐㗄䈲⵾

ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䉎·⵾ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䈭䈇ᣇᴺ䈮
䉋䉎૶↪䈲⣕ᴺⴕὑ䈪䈅䉎·ANNEX 121

““䈮⸥タ䈜䉎ᖱႎ෸䈶ᵈø੐㗄䋨એਅ䇸ᖱႎ䇹fi䈇fl䋩䈲䇮Ł⸥䈱ᣣ
ઃ䈱ᤨὐ䈪ᱜ⏕䈭䉅䈱fiା䈛ឭ␜䈚䈢䉅䈱䈪䈅䉎䈏䇮⁄䊮䉰䊮䊃␠䈲䇮
ᖱႎ䈱ቢోᕈ෶䈲ᱜ⏕ᕈ䉕ł⸒䈜䉎䉅䈱䈪䈲䈭䈇·ᖱႎ䈲䇮䈠䉏䉕
ฃ䈔ข䉎⠪䈏䇮䈠䉏䉕೑↪䈜䉎೨䈮‘Ꮖ䈱⋡⊛䈮ㆡ䈚䈩䈇䉎䈎䈬fl䈎
䉕‘ಽ䈪್ł䈜䉎fi䈇fl᧦ઙ䈮ၮ䈨䈇䈩ଏ⛎'䉏䉎䉅䈱䈪䈅䉎·ᖱႎ
䈱૶↪䈮䉋䈦䈩෶䈲“䉏䉕ା㗬䈚䈢䈢䉄䈮૗䉌䈎䈱ᕈ⾰䈱ⵍł䈏„

↢䈚䈩䉅䇮⁄䊮䉰䊮䊃␠䈲䈇䈎䈭䉎႐ว䉅ⵍł䈮ኻ䈜䉎⽿છ䉕⽶䉒䈭
䈇·ᧄᢥᦠ䈮ឝタ䈚䈢ᖱႎ෶䈲ᖱႎ䈏⸒෸䈚䈢⵾ຠ䈮㑐䈚䈩䇮䈠䈱ø
႐ᕈ䇮․ቯ䈱↪ㅜ䈻䈱ㆡวᕈ䇮෶䈲䈠䈱ઁ䈱ᕈ⾰䈮䈧䈇䈩䇮ᥧ␜⊛
䈮䉅䇮““䈮ł⸒෶䈲଻⸽䈜䉎䉅䈱䈪䈲䈭䈇·㩷


⽷࿅ᴺੱ㩷 ᣣᧄਛᲥᖱႎ䉶䊮䉺䊷㩷

ᢔᏓ૞ᬺਛ䉇ᢔᏓᓟ䈮⇣Ᏹ䉕ᗵ䈛䈢႐ว䈲䇮⋥䈤䈮කᏧ䈱ᚻ¨䉕
ฃ䈔䈩ਅ'䈇·㩷ಣ⟎ᴺ䈭䈬䈪ਇ᣿䈭“fi䈲䇮කᏧ䈎䉌ਅ⸥䈮㔚…䈚
䈩䈍዆䈰ਅ'䈇·㩷

㩷 䉻䉟䊟䊦䌑㪉㩷㩷 ක≮ᯏ㑐ኾ↪㩷
ਛᲥ㪈㪈㪇⇟ 䋨㪊ಽ㪊㪇㪇౞㩷 ᦭ᢱ㔚…㩷
䋨৻ઙ䈮䈧䈐㪉ª㪇㪇㪇౞䋩

ᄢ㩷 ’㩷 㪇㪐㪐㪇㪄㪌㪇㪄㪉’㪐㪐 㪇㪎㪉㪎㪄㪉㪍㪄㪐㪐㪉㪊
䋨㪊㪍㪌ᣣ…㪉’ᤨ㑆ኻᔕ䋩
䈧䈒ƒ㩷
䋨㪊㪍㪌ᣣ…㪐䌾㪉㪈ᤨኻᔕ䋩 㪇㪐㪐㪇㪄㪌㪉㪄㪐㪏㪐㪐 㪇㪉㪐㪏㪄㪌㪈㪄㪐㪐㪐㪐

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼ⅣႺᓇ㗀ᖱႎ䇽㩷

㩷 㪤㪦㪥㪎㪏㪎’㪉䈲˛⴫⊛᳓↢↢‛䈮ኻ䈚䇮ૐᲥᕈ䉕␜䈚䈢·Łᦼ
⹜㛎䈪䈲䇮䉒䈝䈎䈭Ქᕈ䉕Ø㘃œ‰䉟’㪏Œ㩷㪐㪍ᤨ㑆㪣㪚㪌㪇㩷
㪉㪌㪅’㫄–㪆㪣ß෸䈶᳓↢ήºᬁേ‛œ䉥䉥䊚䉳䊮‰㩷㪛㪸㫇㪿›‹㪸㩷㫄㪸–›㪸㩷
㪉’ᤨ㑆㪣㪚㪌㪇㩷㪎㪅㪍’㫄–㪆㪣䇮ห䋳ᤨ㑆㪣㪚㪌㪇㩷㪈㪇㪇㪇㫄–㪆㪣ß䈮␜䈚䈢·

㩷 Ḗ᳓᳓↰᧦ઙ䈮䈍䈔䉎‰䉟䈱Ქᕈ⹜㛎䈪䈲ଏ⹜䈚䈢䈬䈱Ớ
‘䈪䉅ᱫ੢䈲⹺䉄䉌䉏䈭䈎䈦䈢·ଏ⹜Ớ‘䈲ㅢᏱ䈱ᢔᏓ䉋˝
↢䈝䉎Ớ‘fiห䈛䈎䉋˝㜞䈇Ớ‘䈪䈅䈦䈢·⹜㛎ᦼ㑆䈲㪐㪍ᤨ㑆
䈪䈅䈦䈢·

䇼ャㅍŁ䈱ᵈø䇽㩷

ขᛒ䈇଻▤䈱㗄䈱ᵈø੐㗄෸䈶㒰⨲೷䈱৻æ⊛ᵈø੐㗄䉕቞䉎
“fi·
࿖ㅪಽ㘃෸䈶࿖ㅪ⇟ภ㪑㩷 ᥉ㅢ‛䈮䈧䈐⹥¨⁄䈝·

䇼ᑄ᫈Ł䈱ᵈø䇽㩷
ᧄ⵾ຠ૶↪䈮’flᑄ᫈‛䈪૶↪䈮ㆡ'䈭䈇䈎䇮䉁䈢䈲ൻቇ⊛䈮ౣ
೑↪䈪䈐䈭䈇‛䈲ㄘ⮎䈱ᑄ᫈䈱⸵น'䉏䈩䈇䉎วᴺ⊛䈭ᣇᴺ䈪ㆡ
”䈮ಣℂ䈜䉎“fi·

㩷 ⓨኈེ䈮䈲⫳᳇fi⵾ຠ䈱ı⇐‛䈏ı䈦䈩䈇䉎·ኈེ䉕ᵞᵺ䈜䉎䈎
⎕᫈䈜䉎䉁䈪䈲⵾ຠ䊤䊔䊦䈱ᵈø੐㗄䉕቞䉎“fi·ᧄኈེ䈱ㄭ䈒䈪
”ł䇮䉁䈢䈲ṁធ૞ᬺ䉕ⴕ䉒䈭䈇“fi·

㩷 ኈེ㩷ౣ೑↪䈚䈭䈇“fi·ኈེ䉕㪊࿁ᵞᵺ䈚䇮
œ㪈ß ø↸œ䈏࿁෼…ಣಽ䈚䈩䈇䉎fi“ß䈪䈲䇮ቯ䉄䉌䉏䈢ᣇᴺ䈮䉋
˝ಣಽ䈜䉎·

œ㪉ß ㄘ⮎䈱ⓨኈེ䉕ㆡᱜ䈮࿁෼ಣಽ䈜䉎䉲䉴䊁Ø䈏⏕Ø䈚䈩䈇䉎
fi“ß䈪䈲䇮¨⹥䉲䉴䊁Ø䈮䉋˝ಣಽ䈜䉎·
œ㪊ß ㄘኅ╬ㄘ⮎ⓨኈེ䈱ឃ಴੐ᬺ⠪䈏䇮‘䉌↥ᬺᑄ᫈‛ᬺ⠪䈮
ಣℂ䉕ᆔ⸤䈜䉎·

䇼ㆡ↪ᴺ઎䇽㩷 㩷
ㄘ⮎ข✦ 㒰⨲೷䇮ㄘᨋ᳓↥⋭㩷 ⊓㍳㩷 ╙㪈’㪊㪍㪇ภ
ᴺ㪑

ൻ㩷 ክ㩷ᴺ㪑ᣢ–ൻቇ‛⾰㩷 䌎㪄œ䊖䉴䊖䊉䊜䉼䊦䋩䉫䊥䉲䊮

䇼䈠䈱ઁ䇽㩷

ᧄ቟ో䊂䊷䉺䉲䊷䊃䈲⵾ຠ䊤䊔䊦œ⵾ຠ䈱ኈེ䈮ᷝઃ'䉏䈩䈇䉎ßfi
䈲೎䈱⋡⊛䈪૞ᚑ'䉏䈢䉅䈱䈪䈅䉎·቟ో䊂䊷䉺䉲䊷䊃䈲䇮ஜᐽ䇮
቟ో䇮ⅣႺ䈱଻ో䈮㑐䈜䉎㊀ⷐ䈭ᖱႎ䉕ᄙ㊂䈱⵾ຠ䉕ᧄ೷䈱ᧄ᧪
⋡⊛fi䈜䉎૶↪fi䈲೎䈮ขᛒfl૞ᬺ⠪䇮䈠䈱㓹↪⠪෸䈶„”ኻ╷
ⷐຬ䈮ኻ䈚ឭଏ䈜䉎䈢䉄䈮↪ø'䉏䈩䈇䉎·

৻ᣇ䇮⵾ຠ䊤䊔䊦䈲ㅢᏱ䈮૶↪ᣇᴺ䉕ౕ૕⊛䈮␜䈜ᖱႎ䉕ឭଏ䈜
䉎䉅䈱䈪䈅䉎·
ㄘ⮎䈱૶↪䇮଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈲䇮⵾ຠ䊤䊔䊦䈮 ᓥfl“fi䇮䉁
䈢䇮૶↪଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈱ᔅⷐ䈮䈚䈩ㆡ”䈭ᵈø੐㗄䈲⵾

ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䉎·⵾ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䈭䈇ᣇᴺ䈮
䉋䉎૶↪䈲⣕ᴺⴕὑ䈪䈅䉎·ANNEX 121

““䈮⸥タ䈜䉎ᖱႎ෸䈶ᵈø੐㗄䋨એਅ䇸ᖱႎ䇹fi䈇fl䋩䈲䇮Ł⸥䈱ᣣ
ઃ䈱ᤨὐ䈪ᱜ⏕䈭䉅䈱fiା䈛ឭ␜䈚䈢䉅䈱䈪䈅䉎䈏䇮⁄䊮䉰䊮䊃␠䈲䇮
ᖱႎ䈱ቢోᕈ෶䈲ᱜ⏕ᕈ䉕ł⸒䈜䉎䉅䈱䈪䈲䈭䈇·ᖱႎ䈲䇮䈠䉏䉕
ฃ䈔ข䉎⠪䈏䇮䈠䉏䉕೑↪䈜䉎೨䈮‘Ꮖ䈱⋡⊛䈮ㆡ䈚䈩䈇䉎䈎䈬fl䈎
䉕‘ಽ䈪್ł䈜䉎fi䈇fl᧦ઙ䈮ၮ䈨䈇䈩ଏ⛎'䉏䉎䉅䈱䈪䈅䉎·ᖱႎ
䈱૶↪䈮䉋䈦䈩෶䈲“䉏䉕ା㗬䈚䈢䈢䉄䈮૗䉌䈎䈱ᕈ⾰䈱ⵍł䈏„

↢䈚䈩䉅䇮⁄䊮䉰䊮䊃␠䈲䈇䈎䈭䉎႐ว䉅ⵍł䈮ኻ䈜䉎⽿છ䉕⽶䉒䈭
䈇·ᧄᢥᦠ䈮ឝタ䈚䈢ᖱႎ෶䈲ᖱႎ䈏⸒෸䈚䈢⵾ຠ䈮㑐䈚䈩䇮䈠䈱ø
႐ᕈ䇮․ቯ䈱↪ㅜ䈻䈱ㆡวᕈ䇮෶䈲䈠䈱ઁ䈱ᕈ⾰䈮䈧䈇䈩䇮ᥧ␜⊛
䈮䉅䇮““䈮ł⸒෶䈲଻⸽䈜䉎䉅䈱䈪䈲䈭䈇·㩷


⽷࿅ᴺੱ㩷 ᣣᧄਛᲥᖱႎ䉶䊮䉺䊷㩷

ᢔᏓ૞ᬺਛ䉇ᢔᏓᓟ䈮⇣Ᏹ䉕ᗵ䈛䈢႐ว䈲䇮⋥䈤䈮කᏧ䈱ᚻ¨䉕
ฃ䈔䈩ਅ'䈇·㩷ಣ⟎ᴺ䈭䈬䈪ਇ᣿䈭“fi䈲䇮කᏧ䈎䉌ਅ⸥䈮㔚…䈚
䈩䈍዆䈰ਅ'䈇·㩷

㩷 䉻䉟䊟䊦䌑㪉㩷㩷 ක≮ᯏ㑐ኾ↪㩷
ਛᲥ㪈㪈㪇⇟ 䋨㪊ಽ㪊㪇㪇౞㩷 ᦭ᢱ㔚…㩷
䋨৻ઙ䈮䈧䈐㪉ª㪇㪇㪇౞䋩

ᄢ㩷 ’㩷 㪇㪐㪐㪇㪄㪌㪇㪄㪉’㪐㪐 㪇㪎㪉㪎㪄㪉㪍㪄㪐㪐㪉㪊
䋨㪊㪍㪌ᣣ…㪉’ᤨ㑆ኻᔕ䋩
䈧䈒ƒ㩷
䋨㪊㪍㪌ᣣ…㪐䌾㪉㪈ᤨኻᔕ䋩 㪇㪐㪐㪇㪄㪌㪉㪄㪐㪏㪐㪐 㪇㪉㪐㪏㪄㪌㪈㪄㪐㪐㪐㪐

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 121

䇼ⅣႺᓇ㗀ᖱႎ䇽㩷

㩷 㪤㪦㪥㪎㪏㪎’㪉䈲˛⴫⊛᳓↢↢‛䈮ኻ䈚䇮ૐᲥᕈ䉕␜䈚䈢·Łᦼ
⹜㛎䈪䈲䇮䉒䈝䈎䈭Ქᕈ䉕Ø㘃œ‰䉟’㪏Œ㩷㪐㪍ᤨ㑆㪣㪚㪌㪇㩷
㪉㪌㪅’㫄–㪆㪣ß෸䈶᳓↢ήºᬁേ‛œ䉥䉥䊚䉳䊮‰㩷㪛㪸㫇㪿›‹㪸㩷㫄㪸–›㪸㩷
㪉’ᤨ㑆㪣㪚㪌㪇㩷㪎㪅㪍’㫄–㪆㪣䇮ห䋳ᤨ㑆㪣㪚㪌㪇㩷㪈㪇㪇㪇㫄–㪆㪣ß䈮␜䈚䈢·

㩷 Ḗ᳓᳓↰᧦ઙ䈮䈍䈔䉎‰䉟䈱Ქᕈ⹜㛎䈪䈲ଏ⹜䈚䈢䈬䈱Ớ
‘䈪䉅ᱫ੢䈲⹺䉄䉌䉏䈭䈎䈦䈢·ଏ⹜Ớ‘䈲ㅢᏱ䈱ᢔᏓ䉋˝
↢䈝䉎Ớ‘fiห䈛䈎䉋˝㜞䈇Ớ‘䈪䈅䈦䈢·⹜㛎ᦼ㑆䈲㪐㪍ᤨ㑆
䈪䈅䈦䈢·

䇼ャㅍŁ䈱ᵈø䇽㩷

ขᛒ䈇଻▤䈱㗄䈱ᵈø੐㗄෸䈶㒰⨲೷䈱৻æ⊛ᵈø੐㗄䉕቞䉎
“fi·
࿖ㅪಽ㘃෸䈶࿖ㅪ⇟ภ㪑㩷 ᥉ㅢ‛䈮䈧䈐⹥¨⁄䈝·

䇼ᑄ᫈Ł䈱ᵈø䇽㩷
ᧄ⵾ຠ૶↪䈮’flᑄ᫈‛䈪૶↪䈮ㆡ'䈭䈇䈎䇮䉁䈢䈲ൻቇ⊛䈮ౣ
೑↪䈪䈐䈭䈇‛䈲ㄘ⮎䈱ᑄ᫈䈱⸵น'䉏䈩䈇䉎วᴺ⊛䈭ᣇᴺ䈪ㆡ
”䈮ಣℂ䈜䉎“fi·

㩷 ⓨኈེ䈮䈲⫳᳇fi⵾ຠ䈱ı⇐‛䈏ı䈦䈩䈇䉎·ኈེ䉕ᵞᵺ䈜䉎䈎
⎕᫈䈜䉎䉁䈪䈲⵾ຠ䊤䊔䊦䈱ᵈø੐㗄䉕቞䉎“fi·ᧄኈེ䈱ㄭ䈒䈪
”ł䇮䉁䈢䈲ṁធ૞ᬺ䉕ⴕ䉒䈭䈇“fi·

㩷 ኈེ㩷ౣ೑↪䈚䈭䈇“fi·ኈེ䉕㪊࿁ᵞᵺ䈚䇮
œ㪈ß ø↸œ䈏࿁෼…ಣಽ䈚䈩䈇䉎fi“ß䈪䈲䇮ቯ䉄䉌䉏䈢ᣇᴺ䈮䉋
˝ಣಽ䈜䉎·

œ㪉ß ㄘ⮎䈱ⓨኈེ䉕ㆡᱜ䈮࿁෼ಣಽ䈜䉎䉲䉴䊁Ø䈏⏕Ø䈚䈩䈇䉎
fi“ß䈪䈲䇮¨⹥䉲䉴䊁Ø䈮䉋˝ಣಽ䈜䉎·
œ㪊ß ㄘኅ╬ㄘ⮎ⓨኈེ䈱ឃ಴੐ᬺ⠪䈏䇮‘䉌↥ᬺᑄ᫈‛ᬺ⠪䈮
ಣℂ䉕ᆔ⸤䈜䉎·

䇼ㆡ↪ᴺ઎䇽㩷 㩷
ㄘ⮎ข✦ 㒰⨲೷䇮ㄘᨋ᳓↥⋭㩷 ⊓㍳㩷 ╙㪈’㪊㪍㪇ภ
ᴺ㪑

ൻ㩷 ክ㩷ᴺ㪑ᣢ–ൻቇ‛⾰㩷 䌎㪄œ䊖䉴䊖䊉䊜䉼䊦䋩䉫䊥䉲䊮

䇼䈠䈱ઁ䇽㩷

ᧄ቟ో䊂䊷䉺䉲䊷䊃䈲⵾ຠ䊤䊔䊦œ⵾ຠ䈱ኈེ䈮ᷝઃ'䉏䈩䈇䉎ßfi
䈲೎䈱⋡⊛䈪૞ᚑ'䉏䈢䉅䈱䈪䈅䉎·቟ో䊂䊷䉺䉲䊷䊃䈲䇮ஜᐽ䇮
቟ో䇮ⅣႺ䈱଻ో䈮㑐䈜䉎㊀ⷐ䈭ᖱႎ䉕ᄙ㊂䈱⵾ຠ䉕ᧄ೷䈱ᧄ᧪
⋡⊛fi䈜䉎૶↪fi䈲೎䈮ขᛒfl૞ᬺ⠪䇮䈠䈱㓹↪⠪෸䈶„”ኻ╷
ⷐຬ䈮ኻ䈚ឭଏ䈜䉎䈢䉄䈮↪ø'䉏䈩䈇䉎·

৻ᣇ䇮⵾ຠ䊤䊔䊦䈲ㅢᏱ䈮૶↪ᣇᴺ䉕ౕ૕⊛䈮␜䈜ᖱႎ䉕ឭଏ䈜
䉎䉅䈱䈪䈅䉎·
ㄘ⮎䈱૶↪䇮଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈲䇮⵾ຠ䊤䊔䊦䈮 ᓥfl“fi䇮䉁
䈢䇮૶↪଻▤෸䈶ᑄ᫈䈮䈧䈇䈩䈱ᔅⷐ䈮䈚䈩ㆡ”䈭ᵈø੐㗄䈲⵾

ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䉎·⵾ຠ䊤䊔䊦䈮⴫␜'䉏䈩䈇䈭䈇ᣇᴺ䈮
䉋䉎૶↪䈲⣕ᴺⴕὑ䈪䈅䉎·ANNEX 121

““䈮⸥タ䈜䉎ᖱႎ෸䈶ᵈø੐㗄䋨એਅ䇸ᖱႎ䇹fi䈇fl䋩䈲䇮Ł⸥䈱ᣣ
ઃ䈱ᤨὐ䈪ᱜ⏕䈭䉅䈱fiା䈛ឭ␜䈚䈢䉅䈱䈪䈅䉎䈏䇮⁄䊮䉰䊮䊃␠䈲䇮
ᖱႎ䈱ቢోᕈ෶䈲ᱜ⏕ᕈ䉕ł⸒䈜䉎䉅䈱䈪䈲䈭䈇·ᖱႎ䈲䇮䈠䉏䉕
ฃ䈔ข䉎⠪䈏䇮䈠䉏䉕೑↪䈜䉎೨䈮‘Ꮖ䈱⋡⊛䈮ㆡ䈚䈩䈇䉎䈎䈬fl䈎
䉕‘ಽ䈪್ł䈜䉎fi䈇fl᧦ઙ䈮ၮ䈨䈇䈩ଏ⛎'䉏䉎䉅䈱䈪䈅䉎·ᖱႎ
䈱૶↪䈮䉋䈦䈩෶䈲“䉏䉕ା㗬䈚䈢䈢䉄䈮૗䉌䈎䈱ᕈ⾰䈱ⵍł䈏„

↢䈚䈩䉅䇮⁄䊮䉰䊮䊃␠䈲䈇䈎䈭䉎႐ว䉅ⵍł䈮ኻ䈜䉎⽿છ䉕⽶䉒䈭
䈇·ᧄᢥᦠ䈮ឝタ䈚䈢ᖱႎ෶䈲ᖱႎ䈏⸒෸䈚䈢⵾ຠ䈮㑐䈚䈩䇮䈠䈱ø
႐ᕈ䇮․ቯ䈱↪ㅜ䈻䈱ㆡวᕈ䇮෶䈲䈠䈱ઁ䈱ᕈ⾰䈮䈧䈇䈩䇮ᥧ␜⊛
䈮䉅䇮““䈮ł⸒෶䈲଻⸽䈜䉎䉅䈱䈪䈲䈭䈇·㩷


⽷࿅ᴺੱ㩷 ᣣᧄਛᲥᖱႎ䉶䊮䉺䊷㩷

ᢔᏓ૞ᬺਛ䉇ᢔᏓᓟ䈮⇣Ᏹ䉕ᗵ䈛䈢႐ว䈲䇮⋥䈤䈮කᏧ䈱ᚻ¨䉕
ฃ䈔䈩ਅ'䈇·㩷ಣ⟎ᴺ䈭䈬䈪ਇ᣿䈭“fi䈲䇮කᏧ䈎䉌ਅ⸥䈮㔚…䈚
䈩䈍዆䈰ਅ'䈇·㩷

㩷 䉻䉟䊟䊦䌑㪉㩷㩷 ක≮ᯏ㑐ኾ↪㩷
ਛᲥ㪈㪈㪇⇟ 䋨㪊ಽ㪊㪇㪇౞㩷 ᦭ᢱ㔚…㩷
䋨৻ઙ䈮䈧䈐㪉ª㪇㪇㪇౞䋩

ᄢ㩷 ’㩷 㪇㪐㪐㪇㪄㪌㪇㪄㪉’㪐㪐 㪇㪎㪉㪎㪄㪉㪍㪄㪐㪐㪉㪊
䋨㪊㪍㪌ᣣ…㪉’ᤨ㑆ኻᔕ䋩
䈧䈒ƒ㩷
䋨㪊㪍㪌ᣣ…㪐䌾㪉㪈ᤨኻᔕ䋩 㪇㪐㪐㪇㪄㪌㪉㪄㪐㪏㪐㪐 㪇㪉㪐㪏㪄㪌㪈㪄㪐㪐㪐㪐

䊜䊆䊠䊷䈻ᚯ䉎

㩷 ANNEX 122

South Africa Roundup LabelANNEX 122ANNEX 122ANNEX 122ANNEX 122ANNEX 122ANNEX 122 ANNEX 123

United Kingdom Glyphosate 360 LabelANNEX 123 ANNEX 124

United Kingdom Roundup Ultra ST LabelANNEX 124ANNEX 124ANNEX 124 ANNEX 125

United States Roundup Export Label, United States Pesticide Product Label
System, Registration No. 524-308 (9 July 1997)ANNEX 125ANNEX 125 ANNEX 126

United States Fuete SL Label, United States Pesticide Product Label System,
Registration No. 524-308 (19 Feb. 2002)ANNEX 126ANNEX 126ANNEX 126 ANNEX 127

United States Roundup Original Label ANNEX 127

This sample label is current as of 11 /20/2002.Theproduct descrp i tions and recommendationsprovided in this sample label are o f r

background information only. Always refer to the label on the product bfeore using Monsanto or any other agrichemical produc.t

21154B4-1/CG detalle. (If you do not understand the label, find someone to explain it to you in detail.)
CAUSES SUBSTANTIAL BUT TEMPORARY EYE INJURY.

HARMF UL IF SWALLOWED OR INHALED.
Do not get in eyes or on clothing.
Avoid breathing vapor or spray mist.

FIRST AID: Call apoison control center or doctor for treatment adv.ice

IF IN EYES • Hold eye open and rinse slowly and gently with water for 15 - 2 0
minutes.
• Remove contact lenses if present after the first 5 minutes then continue
rinsing eye.
IF INHALED • Remove individual tofresh air. fInot breathing, give arftiicial respiration,
ppreyferably mouth-to mouth. Get medical attenti.on
IF SWALLOWED• This product will cause gastrointestinal tract irritation. Immediately dilute
by swallowing water or milk.Get medical attention. NEVERGIVE ANY-
THING BY MOUTH TO AN UNCONSCIOUS PERSO. N

•Have the product container or label with you when calling a poison control centerro
doctor, or goingfor treatment.
•This product is identified as Roundup Original herbicide, EPA Registration No.
524-445.
•You may also contact(314) 694-4000, collect day or night,for emergency medical
Complete Directions for Use treatment information.

EPA Reg. No. 524-445 DOMESTIC ANIMALS: This product is considered to be relativel y nontoxic to dogs and
other domestic animals; however, ingestion o f this product or large amounts o f freshly
AVOID CONTACT OF HERBICIDE WITH FOLIAGE, GREEN STEMS, sprayed vegetation ma y result in temporar y gastrointestinal irritation (vomiting, diar -
EXPOSED NON-WOODY ROOTS OR FRUITOF CROPS (EXCEPT AS rhea, colic, etc.). If such symptoms are observed, provide the animal with plenty of flu-
SPECIFIED FOR INDIVIDUAL ROUNDUP READY Y CROPS), DESIR- ids to prevent deh ydration. Call a veterinarian if s ymptoms persist for more than 24
ABLE PLANTS AND TREES, BECAUSE SEVERE INJURY O R hours.
DESTRUCTION MAY RESULT.
2004-1 Personal Protective Equipment (PPE)
Applicators and other handlers must wear: long-sleeved shirt and long pants, shoes
Not all products recommended on this label are registered for use in Californiaplus socks, and protective e.
the registration status of each product in California before using. Discard clothing and other absorbent materials that have been drenched or heavily con-
Read the entire label before using this product. taminated with this product's concentrate. Do not reuse them. Follow manu facturer's
instructions for cleaning/maintaining PPE. If no such instructions for washables, use
Use only according to label instructions. detergent and hot water. Keep and wash PPE separately from other laundry.
It is a violation o f Federal law to use this product in an y manner inconsistent with its
labeling When handlers use closed sms, enclosed cabs, or aircraft in a manner that meet s
the requirements listed in Worker Protection Standard (WPS) for agricultural pesticides
Read the ''LIMIT OF WARRANTY AND LIABILITY'' statement at the end of the label [40 CFR 170.240 (d) (4-6)], the handler PPE requirements may be reduced or modified
buying or using. If terms are not acceptable, return at once unopened. as specified in the WPS.
THIS IS AN END-USE PRODUCT. THIS COMPANY DOES NOT INTEND AND HAS NOT REG-
ISTERED IT FOR REFORMULATION. SEE INDIVIDUAL CONTAINER LABEL FOR REPACK- User Safety Recommendations
AGING LIMITATIONS.
Users should:
•Wash hands before eating, drinking, chewing gum, using tobacco, or using the
.0 INGREDIENTS toilet.
1 • Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put
ACTIVE INGREDIENT: on clean clothing.
*Glyphosate, N-(phosphonomethyl)glycine,
in the form of its isopropylamine salt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41.0%
OTHER INGREDIENTS: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..2 .Environmental Hazards
100.0% 3
*Contains 480 grams per litre or 4 pounds per U.S. gallon of the active ingredien
glyphosate, in the form of its isopropylamine salt. Equivalent to 356 grams per litre orly directly to water, to areas where sur face water is present or to intertida l
3 pounds per U.S. gallon of the acid, glyphosate. areas below the mean high water mark. Do not contaminate water when cleaning equip-
ment or disposing of equipment washwaters.
No license granted under any non-U.S. patent(s).
.3 Physical or Chemical Hazards
.0 IMPORTANT PHONE NUMBERS 3
2 Spray solutions of this product should be mixed, stored and applied using only stainless
steel, aluminum, fiberglass, plastic or plastic-lined steel containers.
1. FOR PPRROODDUUCCMAATTIIOONN OR ASSISTANCE IN USING THIS DO NOT MIX, STORE OR APPLY THIS PRODUCT OR SPRAY SOLUTIONS OF THIS PRODUCT
PRODUCT, CALL TOLL-FREE,
1-800-332-3111. IN GALVANIZED STEEL OR UNLINED STEEL (EXCEPT STAINLESS STEEL) CONTAINERS OR
SPRAY TANKS. This product or spray solutions of this product react with such contain-
2. IN CASE OF ANEEMMEERRGGEENNCCYY INVOLVING THIS HERBICIOREDICALCT, OR FM ers and tanks to produce hydrogen gas which may form a highly combustible gas mix-
ASSISTANCE, CALLCOLLECT, DAY OR NIGHT, ture. This gas mixture could flash or explode, causing serious personal injury, if ignite d
(314)-694-4000. by open flame, spark, welder's torch, lighted cigarette or other ignition source .

.0 PRECAUTIONARY STATEMENTS DIRECTIONS FOR USE
3 It is a violation of Federal law to use this product in an y manner inconsistent with its
labeling. This product can only be used in accordance with the Directions for Use on this
.1 Hazards to Humans and Domestic Animals label or in separately published Supplemental Labeling.
3 Do not apply this product in a way that will contact workers or other persons, either

Keep out of reach of children. directly or through drift. Only protected handlers may be in the area during application.
For any requirements specific to your State or Tribe, consult the agency responsible for
WARNING! AVISO! pesticide regulations.
Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted e n

1ANNEX 127

.3 of many equipment and weather-related factors determine the potential for spyradrift. The
6 Mixing for Hand-Held Sprayers applicator and the grower is rpeosnsible for considering all these factors when making deci.sions

Prepare the desired volume o f spray solution by mixing the amount o f this product in .1 Aerial Equipment
water as shown in the following table: 7
Sppryay Solution
Desired Amount of Roundup Original DO NOT APPLY THIS PRODUCT USING AERIAL SPRAY EQUIPMENT EXCEPT UNDER CON-
Volume 0.5% 1% 1.5% 2% 5% 10% DITIONS AS SPECIFIED WITHIN THIS LABEL.
Use the recommended rates of this herbicide in 3 to 15 gallons of waterper acre unless
1 gal 0.7 oz 1.3 oz 2 oz 2.7 oz 6.5 oz 13oz otherwise specified on this label. Unless otherwise specified, do not exceed 1 quart per
25 gal 1 pt 1 qt 1.5 qt 2 qt 5 qt 10 qt
100 gal 2 qt 1 gal 1.5 gal 2 gal 5 gal 10 gal acre. Refer to the individual use area sections of this label for recommended volumes,
2 tablespoons = 1 fluid ounce application rates, and further instructions.
FOR AERIAL APPLI CATION IN CALIFORNIA OR SPE CIFIC COUNTIES THEREIN , O R
For use in knapsack spra yers, it is suggested that the recommended amount of this ARKANSAS, REFER TO THE FEDERAL SUPPLEMENTAL LABEL FOR AERIAL APPLICATIONS
product be mixed with water in a larger container. Fill sprayer with the mixed solutioIN THAT STATE ORCOUNTY FOR SPECIFIC INSTRUCTIONS, RESTRICTIONS AND REQUIRE-
MENTS
.4 Surfactants
6 This product plus dicamba tank mixtures may not be applied by air in California.
Nonionic surfactants (NIS) or wetting agents that are labeled for use with herbicides Ensure uniform application—To avoid streaked, uneven or overlapped application, use
be added to the spray solution. Do not reduce rates of this herbicide when adding sur-
appropriate marking devices.
factants. Read and carefull y observe cautionar y statements and other informatio n AERIAL SPRAY DRIFT MANAGEMENT
appearing on the additives label.
When adding additional surfactant, use 0.5 percent surfactant concentration (2 quarts The following drift management requirements must be followed to avoid off-target drif t
per 100 gallons of spray solution) when using surfactants that contain at least 70 per-ovement from aerial applications to agricultural field crops.
cent active surfactant, or a 1 percent surfactant concentration (4 quarts per 100 gal-1. The distance of the outermost nozzles on the boom must not exceed
lons of spray solution) for those surfactants containing less than 70 percent active sur- 3/4 the length of the wingspan or rotor.

factant. 2. Nozzles must always point backward, parallel with the air stream and never b
pointed downwards more than 45 degrees. Where states have more stringent regu-
.5 Ammonium Sulfate lations, they should be observed.
6 Importance of Droplet Size
The addition of 1 to 2 percent dry ammonium sulfate by weight or 8.5 to 17 pounds per
100 gallons of water may increase the per formance of this product, particularly underThe most effective way to reduce drift potential is to apply large droplets. The best drift
hard water conditions, drought conditions or when tank mixed with certain residual her-anagement strategy is to apply the largest droplets that provide su fficient coverage
and control. Applying larger droplets reduces drift potential, but will not prevent dri ft if
bicides, on annual and perennial weeds. The equivalent rate of ammonium sulfate in a applications are made improperly, or under unfavorable environmental conditions (see
liquid formulation may also be used. Ensure that dry ammonium sul fate is completely the “Wind”, “Temperature and Humidity”, and “Temperature Inversions” sections
dissolved in the spray tank before adding herbicides or surfactants. Thoroughly rinse of this label).
spray system with clean water after use to reduce corrosion. Controlling Droplet Size
NOTE: When using ammonium sulfate, apply this product at rates recommended in this
label. Lower rates will result in reduced performance. The use of ammonium sulfate as • Volume: Use high-flow-rate nozzles to appl y the highest practical spra y volume.
Nozzles with the higher rated flows produce larger droplets.
an additive does not preclude the need for additional surfactant. • Pressure: Use the lower spray pressures recommended for the nozzle. Higher pres-
.6 sure reduces droplet size and does not improve canopy penetration. When higher flow
Colorants or Dyes
6 rates are needed, use higher-flow-rate nozzles instead of increasing pressure.
Agriculturally approved colorants or marking dyes may be added to this product. • Number of nozzles: Use the minimum number of nozzles that provide uniform cov-
Colorants or dyes used in spray solutions of this product may reduce perf,rmance erage.
especially at lower rates or dilutions. Use colorants or dyes according to the manufac -
turer's recommendations. • Nozzle orientation: Orienting nozzles so that the spray is released backwards, par-
allel to the airstream, will produce larger droplets than other orientations. Significant
.7 Drift Reduction Additives deflection from the horizontal will reduce droplet size and increase drift potential.
6 • Nozzle type: Use a nozzle t ype that is designed for the intended application. Wit h
most nozzle t ypes, narrower spra y angles produce larger droplets. Consider using
Drift reduction additives may be used with all equipment t ypes, except wiper applica-
tors, sponge bars and Controlled Droplet Applicator (CDA) equipment. Whenta drif low-drift nozzles. Solid stream nozzles oriented straight back produce larger droplets
reduction additive is used, read and carefully observe the cautionary statements and allthan other nozzle types.
other information appearing on the additive label. The use of drift reduction additive• Boom length: For some use patterns, reducing the effective boom length to less than
can affect spray coverage which may result in reduced performance. 3/4 of the wingspan or rotor length ma y further reduce drift without reducing swath
width.
.0
7 APPLICATION EQUIPMENT AND TECHNIQUES • Application height: Applications should not be made at a height greater than 10 feet
above the top of the largest plants unless a greater height is required for aircraft safe-
Do not apply this product through any type of irrigation system. ty. Making applications at the lowest height that is safe reduces the exposure of the
This product may be applied with the following application equipment: droplets to evaporation and wind.
Aerial—Fixed Wing and Helicopter
Swath Adjustment
Ground Broadcast S pray—Boom or boomless systems, pull-type sprayer, floaters , When applications are made with a crosswind, the swath will be displaced downwind.
pick-up sprayers, spray coupes and other ground broadcast equipment. Therefore, on the up and downwind edges of the field, the applicator must compensate
Hand-Held or Hi gh-Volume Spray Equipment—Knapsack and backpack sprayers, for this displacement by adjusting the path of the aircraft upwind. Swath adjustment
pump-up pressure sprayers, handguns, handwands, mistblowers*, lances and other distance should increase, with increasing drift potential (higher wind, smaller droplets,
hand-held and motorized spray equipment used to direct the spray onto weed foliage.
etc.).
*This product is not registered in California or Arizona for use in mistblowers. Wind
Selective Equipment—Recirculating sprayers, shielded and hooded sprayers, wiper Drift potential is lowest between wind speeds of 2 to 10 miles per hour. However, many
applicators and sponge bars. factors, including droplet size and equipment type determine drift potential at any given
Injection Systems—Aerial or ground injection sprayers.
speed. Application should be avoided below 2 milesper hour due to variable wind direc-
Controlled Droplet Applicator(CDA)—Hand-held or boom-mounted app licators tion and high inversion potential. NOTE: Local terrain can influence wind patterns. Every
which produce a spray consisting of a narrow range of droplet sizes. applicator should be familiar with local wind patterns and how they affect drift.
APPLY THESE SPRAY SOLUTIONS IN PROPERLY MAINTAINED AND CALIBRATED EQUIP- Temperature and Humidity
MENT CAPABLE OF DELIVERING DESIRED VOLUMES.
When making applications in low relative humidity, set up equipment to produce large r
SPRAY DRIFT MANAGEMENT droplets to compensate for evaporation. Droplet evaporation is most severe when con-
AVOID DRIFT. EXTREME CARE MUST BE USED WHEN APPLYING THIS PRODUCT TO PRE- ditions are both hot and dry.
VENT INJURY TO DESIRABLE PLANTS AND CROPS. Temperature Inversions

Do not allow the herbicide solution to mist, dri p, drift or splash onto desirable vegApplications should not occur during a temperature inversion because drift potential is
tion since minute quantities of this product can cause severe damage or destruction tohigh. Temperature inversions restrict vertical air mixing, which causes small suspended
the crop, plants or other areas on which treatment was not intended. droplets to remain in a concentrated cloud. This cloud can move in unpredictable direc-
Avoiding spray drift at the application site is the responsibyiloitf the applicator. The interactniohe light variable winds common during inversions. Temperature inversions

3 ANNEX 127

are characterized by increasing temperatures with altitude and are common on nights and come into contact with the crop, causing damage or destruction of the crop. Avoi d
with limited cloud cover and light to no wind. The y begin to form as the sun sets and operation on rough or sloping ground where the spryahoods might be raised off the ground.
often continue into the morning. Their presence can be indicated by ground fog; howev-
er, if fog is not present, inversions can also be identified by the movement of smoke from hoods designed to minimize excessive dripping or run-o ff down the insides of the
a ground source or an aircraft smoke generator. Smoke that layers and moves laterally hoods. A single, low pressure/ low drift flat-fan nozzle with an 80 to 95 degree spra y
in a concentrated cloud(under low wind conditions) indicates an inversion, while smoke angle positioned at the top center of the hood is recommended.Spray volume should be
20 to 30 gallons per acre.
that moves upward and rapidly dissipates indicates good vertical air mixing. These procedures will reduce the potential for crop injury:
Sensitive Areas
The product should only be applied when the potenfor drift to adjacent sensitive • The spray hoods must be operated on the ground or skimming across the ground .
•Leave at least an 8-inch untreated strip over the drill row. For example, i f the crop
areas (e.g., residential areas, bodies of water, known habitat for threatened or endan- row width is 38 inches, the maximum width of the spray hood should be 30 inches.
gered species, non-target crops) is minimal (e.g., when wind is blowing away from the
sensitive areas). • Maximum tractor speed: 5 miles per hour to avoid bouncing of the spray hoods.
Avoid direct application to any body of water. • Maximum wind speed: 10 miles per hour.

Aircraft Maintenance • Use low-drift nozzles that provide uniform coverage within the treated.area
Thoroughly wash aircraft, especially landing gear, after each day of spraying to remov Crop injury may occur when the foliage of treated weeds comes into direct contact with
residues of this product accumulated during spraying or from spills. PROLONGED EXPO-
SURE OF THIS PRODUCT TO UNCOATED STEEL SURFACES MAY RESULT IN CORROSION leaves of the crop. Do not apply this product when the leaves of the crop are growing in
direct contact with weeds to be treated. Droplets, mist, foam or splatter of the herbicide
AND POSSIBLE FAILURE OF THE PART. LANDIN G GEAR IS MOST SUS CEPTIBLE. The solution may contact the crop and cause discoloration, stunting or destruction.
maintenance of an organic coating (paint), which meets aerospace specification MIL-C- Wiper Applicators
38413, may prevent corrosion.
When applied under the conditions described in the following paragraphs, this product
.2 Ground Broadcast Equipment CONTROLS many weeds, including volunteer corn, Texas panicum, common rye, shatte-r
7 cane, sicklepod, spanishneedles and bristly starbur; and SUPPRESSES many weeds
Use the recommended rates o f this product in 3 to 40 gallons o f water per acre as a including Florida beggarweed, Bermudagrass, hem p dogbane, dogfennel, guineagrass,
broadcast spray unless otherwise specified. As density of weeds increases, spray vol- johnsongrass, milkweed, silverleaf nightshade, redroot pigweed, giant ragweed, smut-
grass, sunflower,Canada thistle, musk thistle, vaseygrass, velvetleaf.
ume should be increased within the recommended range to ensure complete coverage.
Carefully select proper nozzles to avoid spraying a fine mist. For best results with grWiper applicators are devices that physically wipe appropriate amounts of this product
application equipment, use flat spray nozzles. Check for even distributionyof spra directly onto the weed.
droplets. Equipment must be designed, maintained and operated to prevent the herbicide solution
from contacting desirable vegetation. O perate this e quipment at ground s peeds no
.3 Hand-Held or High-Volume Equipment greater than 5 miles per hour. Performance may be improved by reducing speed in areas
7
Apply to foliage of vegetation to be controlled. For applications made on a spray-to-wetf heavy weed infestations to ensure adequate wiper saturation. Better results may be
basis, spray coverage should be uni form and complete. Do not spray to the point o f obtained if two applications are made in opposite directions.
runoff. Use coarse sprays only. For recommended rates and timing, refer to the “ANNU- Avoid leakage or dripping onto desirable vegetation. Adjust height of applicator to ensure
adequate contact with weeds. Kee p wiping surfaces clean. Be aware that, on slo ping
AL WEEDS—Hand-Held or High-Volume Equipment” section of this product label. ground, the herbicide solution may migrate, causing dripping on the lower end and dry-

.4 Selective Equipment ing of the wicks on the upper end of a wiper applicator.
7 Do not use wiper equipment when weeds are wet.

This product may be applied through recirculating spray systems, shielded applicators, Mix only the amount of solution to be used during a 1-day period, as reduced activity may
hooded sprayers, wiper applicators or sponge bars, after dilution and thorough mixin g result from use of leftover solutionsC.lean wiper parts immediately after using this produtc
with water, to listed weeds growing in any non-crop site specified on this label. by thoroughlyflushing with water.
In cropping systems, hooded sprayers, shielded sprayers, and wipers may be used in Do not add surfactant to the herbicide solution.
row middles(in between rows of crop plants) where any dripping or leaking will not con-
For Rope or Sponge Wick Applicators—Solutions ranging from 33 to 75 percent of
tact crop foliage, when listed under "TYPES OF APPLICATION" in the crop sections of thithis product in water may be used. Apply this solution to weeds listed in this section.
product's labeling. Such equipment must be capable of preventing all crop contact with For Panel Applicators—Solutions ranging from 33 to 100 percent of this product in
herbicide solutions and operated without leakage of spray mists or dripping onto crop. water may be used in panel wiper applicators.
Wipers over-the-top of crops may be used only when specifically recommended in thi s
product's labeling.
.5 Injection Systems
AVOID CONTACT OF HERBICIDE WITH DESIRABLE VEGETATION. 7
Contact of the herbicide solution with desirable vegetation may result in damage or This product may be used in aerial or ground injection spra y systems. It may be used
destruction. Applicators used above desirable vegetation should be adjusted so that theas a liquid concentrate or diluted prior to injecting into the spray stream. Do not mix this
lowest spray stream or wiper contact point is at least2 inches above the desirable veg-
product with the concentrate of other products when using injection systems.
etation. Droplets, mist, foam or splatter of the herbicide solution settling on desirabl e
vegetation may result in discoloration, stunting or destruction. .6 CDA Equipment
Applications made above the crops should be made when the weeds are a minimum of 7
6 inches above the desirable vegetation. Better results ma y be obtained when more of The rate of this product applied per acre b y vehicle-mounted CDA equipment must not
be less than the amount recommen ded in this label when applied by conventional
the weed is exposed to the herbicide solution. Weeds not contacted by the herbicide
solution will not be affected. This ma y occur in dense clumps, severe infestations or broadcast equipment. For vehicle-mounted CDA equipment, appl y 2 to 15 gallons o f
when the height of the weeds varies so thnot all weeds are contacted. In these water per acre.
instances, repeat treatment may be necessary. For the control of annual weeds with hand-held CDA units, appl y a 20 percent solution
of this product at a flow rate of 2 fluid ounces per minute and a walking speed of 1.5
Recirculating Spray System miles per hour (1 quart per acre). For the control of perennial weeds, appl y a 20 to 40
A recirculating spray system directs the spray solution onto weeds growing above desir-percent solution of this product at a flow rate of 2 fluid ounces per minute and a walk -
able vegetation, while spray solution not intercepted by weeds is collected and returned
to the spray tank for reuse. ing speed of 0.75 miles per hour (2 to 4 quarts per acre).
Controlled droplet application equipment produces a spray pattern that is not easily vis-
Shielded and Hooded Applicators ible. Extreme care must be exercised to avoid spray or drift contacting the foliage or any
When applied under the conditions described in the followingparagraphs for shielded andother green tissue of desirable vegetation, as damage or destruction may result.
hooded applications, this product at recommended rates will control those weeds listed
in the “ANNUAL WEEDS RATE TABLE” and “PERENNIAL WEEDS RATE TABLE” sections of .0
this label. A hooded sprayer is a type of shielded applicator where the spray pattern is ANNUAL AND PERENNIAL CROPS
fully enclosed including top, sides, front and back, thereby shielding the crop from th e (Alphabetical)

spray solution. Keep shields on these sprayers adjusted to protect desirable vegetationNOTE:THISSECTIONGIVESGENERAL DIRCETIONSTHAT APPLYOTALL LSITEDCROPSWITHINSEC-
When applying to crops grown on raised beds, ensure that the hood is designed to com- TION8 GROUPED ALPHABETCIALLY BELOW.SEE THE INDIVIUDALCROPCATEGORIESFORSPECIFIC
pletely enclose the spray solution. I f necessary, extend the front and rear flaps of tINSTRUCTION,SPREHARVEST INTERVA,LSAND ADDITIONAL PRECAUTIONS AND RESTRICTIONS.
hoods to reach the ground in dee p furrows. EXTREME CARE MUST BE EXER CISED TO
AVOID CONTACT OF HERBICIDE WITH DESIRABLE VEGETATION. See the “ROUNDUP READY CROPS” section of this label or separately publidhe
This equipment must be set up and operated in a manner that avoids bouncing or raising Supplemental Labeling for instructions for treating Roundup Ready crops.
TYPES OF APPLICATIONS: Chemical Fallow, Preplant Fallow Beds, Pre plant, Preemer-
the hoods off the ground in any way. If the hoods are raised, spray particles may escape
gence, At-Planting, Hooded Sprayers in Row-Middles, Shielded Sprayers in R-w
4ANNEX 127

include all applications which can be made onto the specified Roundup Read y crops
.4 Pastures
10 during the complete cropping season. Do N OT combine these instructions with other
LABELED CROPS: Any grass (Gramineae family) except Corn, Sorghum, Sugarcane and recommendations made for crop varieties that do not contain the Roundup Ready gene,
in the “ANNUAL AND PERENNIAL CROPS (Alphabetical)” section of this label.
those listed in thisproduct’s label booklet under“Cereal and Grain Crops”. Grasses that THIS COMPANY RECOMMENDS USE OF THIS PRODU CT FOR POSTEMERGENCE APPLI-
may be treate d include Bahiagrass, Bermudagrass, Bluegrass, Brome, Fescue,
Guineagrass, Kikuyugrass, Orchardgrass, Pangola grass, Ryegrass, Timothy, CATION ONLY ON CROP VARIETIES DESIGNATED AS CONTAINING THE ROUNDUP READY
Wheatgrass. GENE.
Applying this product to crop varieties that are not designated as Roundup Ready wil l
TYPES OF APPLICATIONS: Preplant, Preemergence, Spot Treatment, Over-the-Top Wiper result in severe crop injury and yield loss. Avoid contact with foliage, green stems, or fruit
Applications, Pasture Renovation, Postemergent Weed Control (Broadcast Treatments).
Preplant, Preemergence, Pasture Renovation of crops, or any desirable plants that do not contain the Roundup Ready gene, sinc e
severe injury or destruction will result.
USE INSTRUCTIONS: This product may be applied prior to planting or emergence of for- The Roundup Ready designation indicates that the crop variety contains a patented gene
age grasses. In addition, this product may be used to control perennial pasture species that provides tolerance to this product. In formation on Roundup Read y crop varieties
listed on this label prior to replanting.
may be obtained from your seed supplier , Roundup Ready crop varieties must be pur-
PRECAUTIONS, RESTRICTIONS: If application rates total 3 quarts per acre or less, n o chased from an authorized licensed seed supplier.
waiting period between treatment andfeeding or livestock grazing is required. If the rate NOTE: Roundup Ready seed, and the method of selectively controlling weeds using
is greater than 3quarts per acre, remove domestic livestock before application and wait
8 weeks after application before grazing or harvesting. Crops listed for treatment in this glyphosate on a Roundup Ready crop, are protected under several U.S. Patents,
label booklet may be planted into the treated area at any time; for other crops, wait 30 including 5,352,605 and 5,633,435. A license to use Roundup Ready seed must be
obtainedprior to use.Monsanto retains ownershpi of the gene andprocess technologies,
days between application and planting. and the Purchaser of the seed receives the right to use the licensed genes and technolo-
Spot Treatment, Over-the-Top Wiper Applications gies subject to the limited use license conditions. Seed containing the Roundup Ready trait
cannot be usedfor research and demonstration, reverse engineering or in connection with
USE INSTRUCTIONS: This product may be applied as a spot treatment or with wipr herbicide registration. Progeny seed containing the Roundup Ready trait cannot be saved
applicators in pastures. Applications may be made in the same area at 3 0-day inter-
vals. for replanting or transferred to others for replanting. Contact your Authorized Retailer for
PRECAUTIONS, RESTRICTIONS: For spot treatments or wiper application methods using information on obtaining a limited use license.
For ground applications with broadcast equipment, apply this product in 5 to 20 gal-
rates of 3 quarts per acre or less, the entire field or any portion o f it may be treated .
When spot treatments or wiper application are made using rates abov3 quarts per lons of spray solution per acre. Carefull y select proper nozzle and spra y pressure to
acre, no more than 10 percent o f the total pasture may be treated at any one time. To avoid spraying a fine mist. For best results with ground application equipment use flat
achieve maximum performance, remove domestic livestock before application and wait spray nozzles. Check for even distribution of spray droplets.
7 days after application before grazing livestock or harvesting. For aerial applications apply this product in 3 to 15 gallons of water per acre. See the

Postemergent Weed Control (Broadcast Treatments) “APPLICATION EQUIPMENT AND TECHNIQUES” section of this label for procedures to
USE INSTRUCTIONS: This product may be used to suppress competitive growth and avoid spray drift that may cause injury to any vegetation not intended for treatment. Use
of appropriate buffer zones will help prevent injury to adjacent vegetation.
seed production of annual weeds and undesirable vegetation in pastures. For selective ATTENTION: AVOID DRIFT. EXTREMECARE MUST BE USED WHEN APPLYING THIS PROD-
applications with broadcast spray equipment, apply 12 to 16 fluid ounces of this prod-
uct per acre in early spring before desirable perennial grasses break dormancy and ini- UCT TO PREVENT INJURY TO DESIRABLE PLANTS AND CROPS WHICH DO NOT CONTAIN
tiate green growth. Late fall applications can be made after desirable perennial grass- THE ROUNDUP READY GENE.
es have reached dormancy. See the “MIXING” and “APPLICATION E QUIPMENT AND TECHNIQUES” sections of this

PRECAUTIONS, RESTRICTIONS: Some stunting of perennial grasses will occur if broad- label for additional directions and restrictions on the application of this product.
cast applications are made when plants are not dormant. No waiting period is required Tank mixtures with other herbicides, insecticides, fungicides, micronutrients or foliar
between application and grazing or harvesting for feed. Use of higher application rates fertilizers may result in reduced weed control or crop injury and are NOT recommende d
will cause stand reductions. Do not apply more than 3 quarts per acre per year ont o for over-the-top applications o f this product unless otherwise noted in this troduc

pasture grasses exce pt for renovation uses (see instructions above). If re planting is label, supplemental labeling or fact sheets published separately.
needed due to severe stand reduction, applications must be made at least 30 days prior Unless otherwise directed, nonionic surfactant may be added to the spray solution for
to planting any crop not listed for treatment in this product’s label booklet. applications to Roundup Ready crops. The addition o f certain surfactants to this prod-

. .5 Rangelands uct may result in some crop response including lea f necrosis, lea f chlorosis or lea f
10 speckling due to the surfactant added to the spray mixture. Read and carefully observe
cautionary statements and other information appearing on the surfactant label.
TYPES OF APPLICATIONS: Postemergence.
Ammonium sulfate may be mixed with this product for applications to Roundup Ready
This product will control or suppress many annual weeds growing in perennial cool and crops. Refer to the “MIXING” section for use instructions for ammonium sulfate.
warm-seasongrass rangelands. Sprayer Preparation: It is important that spra yer and mixing equipment be clean and
Preventing viable seed production is key to the successful control and invasion of annu- free of pesticide residue before making applications of this product. Follow the cleaning
al grassy weeds in rangelands. Follow-up applications in sequential years should elim-
inate most of the viable seeds. procedures specified on the label of the product(s) previousyl used. THOROUGHLY CLEAN
THE SPRAY TANK AND ALL LINES AND FILTERS TO ELIMINATE POTENTIAL CONTAMINA-
Grazing of treated areas should be delayed to encourage growth of desirable perennials. TION FROM OTHER HERBICIDES PRIOR TO MIXING AND APPLYING THIS PRODUCT.
Allowing desirable perennials to flower and reseed in the treated area will encourag e NOTE: The following recommendations are based on a clean start at planting b y using
successful transition.
a burndown application or tillage to control existing weeds be fore crop emergence. I n
USE INSTRUCTIONS: Apply 12 to 16 fluid ounces of this product per acre to control or no-till and stale seedbed s ystems, a preplant burn-down treatment of this product is
suppress many weeds, including downy brome, cheatgrass, cereal rye and jointed goat- recommended to control existing weeds prior to crop emergence. Some weeds, such as
grass in rangelands. Apply when most brome plants are in earl y flower and before the black nightshade, broadleaf signalgrass, sicklepod, Texas panicum, sandbur, annual
plants, including seedheads, turn color. Allowing for secondary weed flushes to occur in morningglory, woolly cupgrass, shattercane, wild proso millet, burcucumber, and giant
the spring following rain events further depletes the seed reserve and encourages ragweed with multiple germination times or suppressed (stunted) weeds may require a
perennial grass conversion on weedy sites. Fall applications are possible, and recom-
second application of this product for complete control. The second application should
mended, where spring moisture is usually limited and fall germination allows for good be made after some regrowth has occurred and at least 10 days after a previous appli-
weed growth. cation of this product.
For medusahead, apply 16 fluid ounces of this product per acre at the 3-leaf stage.
Delaying applications beyond this stage will result in reduced or unacceptable control . .1 Canola with the Roundup Ready Gene
Controlled burning ma y be useful in eliminating the thatcyer produced b y slow 11

decaying culms prior to application. Allow new growth to occur before spraying after a TYPES OF APPLICATIONS: Preplant, At-Planting, Preemergence, Postemergence
burn. Repeat applications in subsequentyears may be necessary to eliminate the seed- DO NOT USE THIS PRODUCT ON CANOLA WITH THE ROUNDUP READY GENE PLANTED
bank before reestablishing desirablperennial grasses in medusahead-dominated IN THE FOLLOWIN G STATES: ALABAMA , DELAWARE, FLORIDA, GEORGIA, KENTUCKY,
rangelands. MARYLAND, NEW JERSEY, NORTH CAROLINA, SOUTH CAROLINA, TENNESSEE, VIRGINIA
PRECAUTIONS, RESTRICTIONS: Slight discoloration of the desirable grasses may occur, AND WEST VIRGINIA.

but they will regreen and regrow under moist soil conditions as e ffects of this product Maximum Allowable Combined
wear off. Do not use ammonium sul fate when spra ying rangeland grasses with thi s Apppplication QQuantities Per Season
product. No waiting period between treatment and feeding of livestock grazingsi
required. Do not apply more than 3 quarts per acre per year. Preplant, At-Planting,
Preemergence applications 2 quarts per acre
.0 ROUNDUP READY CROPS Total in-crop applications from
11
emergence to 6-leaf stage 1 quart per acre
The following instructions or those separately published on Supplemental labeling

12 ANNEX 128

United States Roundup Pro Label ANNEX 128

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VYFFIV SV RMXVMPI VYFFIV WLSIW TPYW WSGOW 6EMRJEWXRIWW ,IEZ] VEMRJEPP WSSR EJXIV ETTPMGEXMSR QE] [EWL XLMW TVS’YGX SJJ SJ XLI

JSPMEKI ER’ E VITIEX ETTPMGEXMSR QE] FI VIUYMVI’ JSV E’IUYEXI GSRXVSP
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8LI VIUYMVIQIRXW MR XLMW FS\ ETTP] XS YWIW SJ XLMW TVS’YGX XLEX EVI 238 [MXLMR XLI 9RIQIVKI’ TPERXW EVMWMRK JVSQ YREXXEGLI’ YR’IVKVSYR’ VLM^SQIW SV VSSXWXSGOW SJ
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8ERO 1M\MRK8LMW TVS’YGX ’SIW RSX TVSZM’I VIWM’YEP [II’ GSRXVSP *SV WYFWIUYIRX VIWM’
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/IIT TISTPI ER’ TIXW SJJ XVIEXI’ EVIEW YRXMP WTVE] WSPYXMSR LEW ’VMI’ XLI GEYXMSREV] WXEXIQIRXW ER’ EPP SXLIV MRJSVQEXMSR ETTIEVMRK SR XLI PEFIPW SJ EPP LIVFM

GM’IW YWI’ 9WI EGGSV’MRK XS XLI QSWX VIWXVMGXMZI TVIGEYXMSREV] WXEXIQIRXW JSV IEGL
TVS’YGX MR XLI QM\XYVI
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EW ’MYVSR ( SV ’MGEQFE XLI YWIV MW VIWTSRWMFPI JSV IRWYVMRK XLEX XLI QM\XYVI TVS’
4)78-'-() 7836%+)(S RSX GSRXEQMREXI [EXIV JSS’WXYJJW JII’ SV WII’ F] WXSVEKI SV YGXvWPEFIPEPPS[WXLIWTIGMJMGETTPMGEXMSR
’MWTSWEP /IIT GSRXEMRIV GPSWI’ XS TVIZIRX WTMPPW ER’ GSRXEQMREXMSR &Y]IV ER’ EPP YWIVW EVI VIWTSRWMFPI JSV EPP PSWW SV ’EQEKI MR GSRRIGXMSR [MXL XLI YWI SV
4)78-'-() (-7437%0 ;EWXIW VIWYPXMRK JVSQ XLI YWI SJ XLMW TVS’YGX XLEX GERRSX FI LER’PMRK SJ QM\XYVIW SJ XLMW TVS’YGX [MXL LIVFMGM’IW SV SXLIV QEXIVMEPW XLEX EVI RSX

YWI’ SV GLIQMGEPP] VITVSGIWWI’ WLSYP’ FI ’MWTSWI’ SJ MR E PER’JMPP ETTVSZI’ JSV TIWXMGM’I I\TVIWWP] VIGSQQIR’I’ MR XLMW PEFIP 1M\MRK XLMW TVS’YGX [MXL LIVFMGM’IW SV SXLIV QEXI
’MWTSWEP SV MR EGGSV’ERGI [MXL ETTPMGEFPI *I’IVEP WXEXI SV PSGEP TVSGI’YVIW VMEPW RSX VIGSQQIR’I’ SR XLMW PEFIP QE] VIWYPX MR VI’YGI’ TIVJSVQERGI
'328%-2)6 (-7437%0 )QTXMI’ GSRXEMRIV VIXEMRW ZETSV ER’ TVS’YGX VIWM’YI 3FWIVZI %RRYEP 1E\MQYQ 9WI 6EXI 8LI GSQFMRI’ XSXEP SJ EPP XVIEXQIRXW QYWX RSX I\GII’

EPP PEFIPI’ WEJIKYEV’W YRXMP GSRXEMRIV MW GPIERI’ VIGSR’MXMSRI’ SV ’IWXVS]I’  UYEVXW SJ XLMW TVS’YGX TIV EGVI TIV ]IEV 8LI QE\MQYQ YWI VEXIW WXEXI’ XLVSYKL
*36 40%78-' ;%= '328%-2)67
&3880)7 SYXXLMWTVS’YGXvWPEFIPMRKETTP]XSXLMWTVS’YGXGSQFMRI’[MXLXLIYWISJEPPSXLIVLIV
(S RSX VIYWI GSRXEMRIV 8VMTPI VMRWI GSRXEMRIV XLIR TYRGXYVI ER’ ’MWTSWI SJ MR E WERM FMGM’IW GSRXEMRMRK KP]TLSWEXI EW XLI EGXMZI MRKVI’MIRX [LIXLIV ETTPMI’ EW QM\XYVIW SV
XEV] PER’JMPP SV F] MRGMRIVEXMSR SV MJ EPPS[I’ F] WXEXI ER’ PSGEP EYXLSVMXMIW F] FYVRMRKITEVEXIP] 'EPGYPEXI XLI ETTPMGEXMSR VEXIW ER’ IRWYVI XLEX XLI XSXEP YWI SJ XLMW ER’
SXLIV KP]TLSWEXI GSRXEMRMRK TVS’YGXW ’SIW RSX I\GII’ WXEXI’ QE\MQYQ YWI VEXIW
-J FYVRI’ WXE] SYX SJ WQSOI
*36 32);%= (6917 %88)28-32
(S RSX VIYWI GSRXEMRIV 6IXYVR GSRXEMRIV TIV XLI 1SRWERXS GSRXEMRIV VIXYVR TVSKVEQ -J %:3-( '328%'8 3* ,)6&-'-() ;-8, *30-%+) +6))2 78)17 )<437)( 232;33(=
RSX VIXYVRI’ XVMTPI VMRWI GSRXEMRIV XLIR TYRGXYVI ER’ ’MWTSWI SJ MR E WERMXEV] PER’JMPP 63387 36 *69-8 3* '6347 ()7-6%&0) 40%287 %2( 86))7 &)'%97) 7):)6) -2.96=

SV F] MRGMRIVEXMSR SV MJ EPPS[I’ F] WXEXI ER’ PSGEP EYXLSVMXMIW F] FYVRMRK -J FYVRI’ WXE] ()7869'8-32 1%= 6)7908
SYX SJ WQSOI %:3-( (6-*8 )<86)1) '%6) 1978 &) 97)( ;,)2 %440=-2+ 8,-7 463(9'8 83 46)
*36 6)*-00%&0) 4368%&0) 1-2-&90/
'328%-2)67 :)28 -2.96= 83 ()7-6%&0) 40%287 %2( '6347

8LMW GSRXEMRIV QYWX SRP] FI VIJMPPI’ [MXL TIWXMGM’I TVS’YGX (S RSXVIYWI LXMW ’SR (S RSX EPPS[ XLI LIVFMGM’I WSPYXMSR XS QMWX ’VMT ’VMJX SV WTPEWL SRXS ’IWMVEFPI ZIK
XEMRIV JSV ER] SXLIV TYVTSWI IXEXMSR WMRGI QMRYXI UYERXMXMIW SJ XLMW TVS’YGX GER GEYWI WIZIVI ’EQEKI SV
*MREP ’MWTSWEP QYWX FI MR GSQTPMERGI [MXL WXEXI ER’ PSGEP VIKYPEXMSRW -J RSX VIJMPPI’ ’IWXVYGXMSR XS XLI GVST TPERXW SV SXLIV EVIEW SR [LMGL XVIEXQIRX [EW RSX MRXIR’
VIXYVRI’ SV VIG]GPI’ XVMTPI VMRWI SV TVIWWYVI VMRWI TYRGXYVI ER’ ’MWTSWI SJ MR E WERM I’ 8LI PMOIPMLSS’ SJ MRNYV] SGGYVVMRK JVSQ XLI YWI SJ XLMW TVS’YGX MRGVIEWIW [LIR

XEV] PER’JMPP SV F] MRGMRIVEXMSR SV MJ EPPS[I’ F] WXEXI ER’ PSGEP EYXLSVMXMIW F] FYVRMRKMR’W EVI KYWX] EW [MR’ ZIPSGMX] MRGVIEWIW [LIR [MR’ ’MVIGXMSR MW GSRWXERXP]
-J FYVRI’ WXE] SYX SJ WQSOI GLERKMRK SV [LIR XLIVI EVI SXLIV QIXISVSPSKMGEP GSR’MXMSRW XLEX JEZSV WTVE] ’VMJX
(S RSX XVERWTSVX XLMW GSRXEMRIV MJ MX MW ’EQEKI’ SV PIEOMRK -J XLI GSRXEMRIV MW ’EQ ;LIR WTVE]MRK EZSM’ GSQFMREXMSRW SJ TVIWWYVI ER’ RS^^PI X]TI XLEX [MPP VIWYPX MR
WTPEXXIV SV JMRI TEVXMGPIW QMWX
XLEX EVI PMOIP] XS ’VMJX %:3-( %440=-2+ %8 )<')7
EKI’ PIEOMRK SV SFWSPIXI SV XS SFXEMR MRJSV QEXMSR EFSYX VIG]GPMRK TSVXEFPI VIJMPPEFPI 7-:) 74))( 36 46)7796) 
GSRXEMRIVW GSRXEGX 1SRWERXS 'SQTER] EX 6392(94 

9WIVW ;LIR XLI GSRXEMRIV MW IQTX] VITPEGI XLI GET ER’ WIEP EPP STIRMRKW XLEX LEZI 238) 9WI SJ XLMW TVS’YGX MR ER] QERRIV RSX GSRWMWXIRX [MXL XLMW PEFIP QE] VIWYPX MR
FIIR QE’I ’YVMRK YWEKI ER’ VIXYVR XLI GSRXEMRIV XS XLI TSMRX SJ TYVGLEWI SV XS ER MRNYV] XS TIVWSRW ERMQEPW SV GVSTW SV LEZI SXLIV YRMRXIR’I’ GSRWIUYIRGIW

EPXIVREXI PSGEXMSR ’IWMKREXI’ F] XLI QERYJEGXYVIV EX XLI XMQI SJ TYVGLEWI SJ XLMW  ;IIH 6IWMWXER’I 1EREKIQIRX
TVS’YGX -J RSX VIXYVRI’ XVMTPI VMRWI SV TVIWWYVI VMRWI XLI IQTX] GSRXEMRIV ER’ SJJIV 
MX JSV VIG]GPMRK MJ EZEMPEFPI

6IJMPPIVW (S RSX VIYWI XLMW QMRMFYPO GSRXEMRIV I\GITX JSV VIJMPP MR EGGSV’ERGI [MXL E
ZEPM’ 1SRWERXS 6ITEGOEKMRK SV 8SPP 6ITEGOEKMRK %KVIIQIRX 4VMSV XS VIJMPPMRK MRWTIGX
GEVIJYPP] JSV ’EQEKI WYGL EW GVEGOW TYRGXYVIW EFVEWMSRW [SVRSYX XLVIE’W ER’ GPS +P]TLSWEXI XLI EGXMZI MRKVI’MIRX MR XLMW TVS’YGX MW E +VSYT  LIVFMGM’I FEWI’ SR XLI QS’I
WYVI ’IZMGIW 'LIGO JSV PIEOW EJXIV VIJMPPMRK ER’ FIJSVI XVERWTSVXMRK
SJ EGXMSR GPEWWMJMGEXMSR W]WXIQ SJ XLI ;II’ 7GMIRGI 7SGMIX] SJ %QIVMGE %R] [II’ TSTYPE
*36 6)*-00%&0) 78%8-32%6= &90/ '328%-2)67 XMSR QE] GSRXEMR TPERXW REXYVEPP] VIWMWXERX XS +VSYT  LIVFMGM’IW ;II’ WTIGMIW VIWMWXERX
8LMW GSRXEMRIV QYWX SRP] FI VIJMPPI’ [MXL TIWXMGM’I TVS’YGX (S RSXVIYWI LXMW ’SR XS +VSYT  LIVFMGM’IW QE] FI IJJIGXMZIP] QEREKI’ YXMPM^MRK ERSXLIV LIVFMGM’I JVSQ E ’MJ
XEMRIV JSV ER] SXLIV TYVTSWI JIVIRX +VSYT SV YWMRK SXLIV GYPXYVEP SV QIGLERMGEP TVEGXMGIW

 ANNEX 128

8S QMRMQM^I XLI SGGYVVIRGI SJ KP]TLSWEXIVIWMWXERX FMSX]TIW SFWIVZI XLI JSPPS[MRK KIRI7TVE] 7SPYXMSR
[II’ QEREKIQIRX VIGSQQIR’EXMSRW
(IWMVI’ %QSYRX SJ 6SYR’YT 463 LIVFMGM’I
e 7GSYX]SYVETTPMGEXMSRWMXIFIJSVIER’EJXIVLIVFMGM’IETTPMGEXMSRW :SPYQI       
e 'SRXVSP[II’WIEVP][LIRXLI]EVIVIPEXMZIP]WQEPP KEP S^ S^  S^   S^ S^  S^
KEP  TX  UX  X  UX UX  UX
e -RGSVTSVEXISXLIVLIVFMGM’IWER’GYPXYVEPSVQIGLERMGEPTVEGXMGIWEWTEVXSJ]SYV  KEP  UX  KEP KEP  KEP KEP  KEP
[II’ GSRXVSP W]WXIQ [LIVI ETTVSTVMEXI
XEFPIWTSSRW!JPYM’SYRGI
e 9XMPM^IXLIVIGSQQIR’I’PEFIPVEXIJSVXLIQSWX’MJJMGYPX[II’MRXLIWMXI%ZSM’XE*SV YWI MR FEGOTEGO ORETWEGO SV TYQTYTWTVE]IVW MX MW VIGSQQIR’I’ XLEX XLI ETTVS
QM\XYVIW[MXLSXLIVLIVFMGM’IWXLEXVI’YGIXLMWTVS’YGXvWIJJMGEG] XLVSYKLERXEKS TVMEXI EQSYRX SJ XLMW TVS’YGX FI QM\I’ [MXL [EXIV MR E PEVKIV GSRXEMRIV ER’ XLIR JMPPMRK
RMWQ
SV XERO QM\XYVI VIGSQQIR’EXMSRW [LMGL IRGSYVEKI VEXIW SJ XLMW TVS’YGX FIPS[
XLI PEFIP VIGSQQIR’EXMSRW XLI WTVE]IV [MXL XLI QM\I’ WSPYXMSR
e 'SRXVSP[II’IWGETIWER’TVIZIRX[II’WJVSQWIXXMRKWII’W
 'SPSVERXW SV (]IW
e 'PIERIUYMTQIRXFIJSVIQSZMRKJVSQWMXIXSWMXIXSQMRMQM^IWTVIE’SJ[II’WII’ 
e 9WIRI[GSQQIVGMEPWII’EWJVIISJ[II’WII’EWTSWWMFPI
'SPSVERXW SV QEVOMRK ’]IW QE] FI E’’I’ XS WTVE] WSPYXMSRW SJ XLMW TVS’YGX LS[IZIV XLI]
e 6ITSVXER]MRGM’IRGISJVITIEXI’RSRTIVJSVQERGISJXLMWTVS’YGXSRETEVXMGYPEV QE] VI’YGITVS’YGX TIVJSVQERGI EX PS[IV VEXIW SV ’MPYXMSR 9WI GSPSVERXW SV ’]IW EGGSV’
[II’ XS ]SYV 1SRWERXS VITVIWIRXEXMZI PSGEP VIXEMPIV SV GSYRX] I\XIRWMSR EKIRX MRKXSXLIQERYJEGXYVIVvWVIGSQQIR’EXMSRW

 1EREKIQIRX 6I’SQQIRHEXMSRW JSV +P]TLSWEXI  %440-'%8-32 )59-41)28 %2( 8)',2-59)7
 
6IWMWXERX ;IIH &MSX]TIW
(S RSX ETTP] XLMW TVS’YGX XLVSYKL ER] X]TI SJ MVVMKEXMSR W]WXIQ
238) %TTVSTVMEXI XIWXMRK MW GVMXMGEP MR SV’IVXS GSRJMVQ [II’ VIWMWXERGIXS KP]TLSWEXI
'SRXEGX]SYV1SRWERXSVITVIWIRXEXMZIXS’IXIVQMRIMJVIWMWXERGILEWFIIR GSRJMVQI’XS ER] %440= 8,)7) 746%= 73098-327 -2 4634)60= 1%-28%-2)( %2( '%0-&6%8)( )59-4
TEVXMGYPEV [II’ FMSX]TI MR ]SYV EVIE 'SRXVSP VIGSQQIR’EXMSRW JSV FMSX]TIW GSRJMVQI’ EW)28 '%4%&0) 3* ()0-:)6-2+ ()7-6)( :3091)7
VIWMWXERX XS KP]TLSWEXI EVI QE’I EZEMPEFPI SR WITEVEXIP] TYFPMWLI’ WYTTPIQIRXEP PEFIP
 %IVMEP )UYMTQIRX
MRK SV JEGX WLIIXW JSV XLMW TVS’YGX ER’ QE] FI SFXEMRI’ JVSQ ]SYV PSGEP VIXEMPIV SV 
1SRWERXS VITVIWIRXEXMZI
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FMSX]TIW (-8-327 74)'-*-)( -2 8,-7 0%&)0 SV MR WITEVEXIP] TYFPMWLI’ 1SRWERXS 7YTTPIQIRXEP
0EFIPMRK
e -J E REXYVEPP] SGGYVVMRK VIWMWXERX FMSX]TI MW TVIWIRX EX ]SYV WMXI XLMW TVS’YGX QE] FI
XEROQM\I’ SV ETTPMI’ WIUYIRXMEPP] [MXL ER ETTVSTVMEXIP] PEFIPI’ LIVFMGM’I [MXL E ’MJI XLI VIGSQQIR’I’ VEXIW SJ XLMW LIVFMGM’I MR  XS KEPPSRW SJ [EXIV TIV EGVI ;LIR
JIVIRX QS’I SJ EGXMSR XS EGLMIZI GSRXVSP YWI’ EGGSV’MRK XS PEFIP ’MVIGXMSRW XLMW TVS’YGX [MPP KMZI GSRXVSP SV TEVXMEP GSRXVSP SJ
LIVFEGISYW [II’W [SS’] FVYWL ER’ XVIIW PMWXI’ MR XLI ;))(7 '3286300)( WIGXMSR
e 'YPXYVEPER’QIGLERMGEPGSRXVSPTVEGXMGIWQE]EPWSFIYWI’EWETTVSTVMEXI SJ XLMW PEFIP
e 7GSYXXVIEXI’WMXIWEJXIVLIVFMGM’IETTPMGEXMSRWER’GSRXVSPIWGETIWSJVIWMWXERXFMS
X]TIW FIJSVI XLI] WIX WII’ 'SEVWI WTVE]W EVI PIWW PMOIP] XS ’VMJX XLIVIJSVI ’S RSX YWI RS^^PIW SV RS^^PI GSRJMKYVE
XMSRW XLEX ’MWTIRWI WTVE] EW JMRI WTVE] ’VSTPIXW (S RSX ERKPI RS^^PIW JSV[EV’ MRXS XLI
e 8LSVSYKLP]GPIERIUYMTQIRXFIJSVIPIEZMRKWMXIWORS[RXSGSRXEMRVIWMWXERXFMSX]TIWEMVWXVIEQ ER’ ’S RSX MRGVIEWI WTVE] ZSPYQI F] MRGVIEWMRK RS^^PI TVIWWYVI (VMJX GSRXVSP
E’’MXMZIW QE] FI YWI’ ;LIR E ’VMJX GSRXVSP E’’MXMZI MW YWI’ VIE’ ER’ GEVIJYPP] SFWIVZI
 1-<-2+ XLI GEYXMSREV] WXEXIQIRXW ER’ EPP SXLIV MRJSVQEXMSR ETTIEVMRK SR XLI E’’MXMZI PEFIP

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'PIER WTVE]IV TEVXW MQQI’MEXIP] EJXIV YWMRK XLMW TVS’YGX F] XLSVSYKLP] JPYWLMRK [MXL 79440)1)28%0 0%&)0 *36 %)6-%0 %440-'%8-327 -2 8,%8 78%8) *36 74)'-*-'
[EXIV -27869'8-327 6)786-'8-327 %2( 6)59-6)1)287
%ZSM’ ’MVIGX ETTPMGEXMSR XS ER] FS’] SJ [EXIV
238) 6)(9')( 6)79087 1%= 3''96 -* ;%8)6 '328%-2-2+ 73-0 -7 97)( 79', %7
:-7-&0= 19((= ;%8)6 36 ;%8)6 *631 432(7 %2( (-8',)7 8,%8 -7 238 '0)%6 )RWYVI YRMJSVQ ETTPMGEXMSR 8S EZSM’ WXVIEOI’ YRIZIR SV SZIVPETTI’ ETTPMGEXMSR YWI
ETTVSTVMEXI QEVOMRK ’IZMGIW
 1M\MRK [MXL ;EXIV %MV’VEJX1EMRIXRER’I 463032+)( )<43796) 3* 8,-7 463(9'8 83 92'3%8)(
 78))0 796*%')7 1%= 6)7908 -2 '36637-32 %2( 4377-&0) *%-096) 3* 8,) 4%68

8LMW TVS’YGX QM\IW VIE’MP] [MXL [EXIV 1M\ WTVE] WSPYXMSRW SJ XLMW TVS’YGX EW JSPPS[W8LI QEMRXIRERGI SJ ER SVKERMG GSEXMRK TEMRX
[LMGL QIIXW EIVSWTEGI WTIGMJMGEXMSR
&IKMR JMPPMRK XLI QM\MRK XERO SV WTVE] XERO [MXL XLI VIUYMVI’ EQSYRX SJ GPIER [EXIV %’’0' QE] TVIZIRX GSVVSWMSR 8S TVIZIRX GSVVSWMSR SJ I\TSWI’ TEVXW XLSVSYKLP]
XLI VIGSQQIR’I’ EQSYRX SJ XLMW TVS’YGX RIEV XLI IR’ SJ XLI JMPPMRK TVSGIWW ER’ QM\ [EWL EMVGVEJX EJXIV IEGL ’E] SJ WTVE]MRK XS VIQSZI VIWM’YIW SJ XLMW TVS’YGX EGGYQYPEXI’
[IPP 9WI GEYXMSR XS EZSM’ WMTLSRMRK FEGO MRXS XLI GEVVMIV WSYVGI 9WI ETTVSZI’ ERXM ’YVMRK WTVE]MRK SV JVSQ WTMPPW 0ER’MRK KIEV MW QSWX WYWGITXMFPI
FEGOWMTLSRMRK ’IZMGIW [LIVI VIUYMVI’ F] WXEXI SV PSGEP VIKYPEXMSRW (YVMRK QM\MRK ER’ 746%= (6-*8 1%2%+)1)28
ETTPMGEXMSR JSEQMRK SJ XLI WTVE] WSPYXMSR QE] SGGYV 8S TVIZIRX SV QMRMQM^I JSEQ
EZSM’ XLI YWI SJ QIGLERMGEP EKMXEXSVW XIVQMREXI F]TEWW ER’ VIXYVR PMRIW EX XLI FSXXSQ:3-( (6-*8 )<86)1) '%6) 1978 &) 97)( ;,)2 %440=-2+ 8,-7 463(9'8 83 46)
:)28 -2.96= 83 ()7-6%&0) 40%287 %2( '6347
SJ XLI XERO ER’ MJ RII’I’ YWI ER ETTVSZI’ ERXMJSEQ SV ’IJSEQMRK EKIRX
(S RSX EPPS[ XLI LIVFMGM’I WSPYXMSR XS QMWX ’VMT ’VMJX SV WTPEWL SRXS ’IWMVEFPI ZIKIXE
 8ERO 1M\MRK 4VS’IHYVI XMSR WMRGI QMRYXI UYERXMXMIW SJ XLMW TVS’YGX GER GEYWI WIZIVI ’EQEKI SV ’IWXVYGXMSR XS
 XLI GVST TPERXW SV SXLIV EVIEW SR [LMGL XVIEXQIRX [EW RSX MRXIR’I’
%ZSM’MRK WTVE] ’VMJX EX XLI ETTPMGEXMSR WMXI MW XLI VIWTSRWMFMPMX] SJ XLI ETTPMGEXSV 8LI MRXIV
;LIR XERO QM\MRK VIE’ ER’ GEVIJYPP] SFWIVZI PEFIP ’MVIGXMSRW GEYXMSREV] WXEXIQIRXW EGXMSR SJ QER] IUYMTQIRX ER’ [IEXLIVVIPEXI’ JEGXSVW ’IXIVQMRIW XLI TSXIRXMEP JSV WTVE]
ER’ EPP MRJSVQEXMSR SR XLI PEFIPW SJ EPP TVS’YGXW YWI’ %’’ XLI XEROQM\ TVS’YGX XS XL’VMJX8LIETTPMGEXSVER’XLIKVS[IVEVIMWVIWTSRWMFPIJSVGSRWM’IVMRKEPPXLIWIJEGXSVW[LIR
XERO EW ’MVIGXI’ F] XLI PEFIP 1EMRXEMR EKMXEXMSR ER’ E’’ XLI VIGSQQIR’I’ EQSYRX SJ
XLMW TVS’YGX QEOMRK ’IGMWMSRW
%)6-%0 746%= (6-*8 1%2%+)1)28
1EMRXEMR KSS’ EKMXEXMSR EX EPP XMQIW YRXMP XLI GSRXIRXW SJ XLI XERO EVI WTVE]I’ -J XLI
WTVE] QM\XYVI MW EPPS[I’ XS WIXXPI XLSVSYKL EKMXEXMSR QE] FI VIUYMVI’ XS VIWYWTIR’ XLILI JSPPS[MRK ’VMJX QEREKIQIRX VIUYMVIQIRXW QYWX FI JSPPS[I’ XS EZSM’ SJJXEVKIX ’VMJX
QM\XYVI FIJSVI WTVE]MRK MW VIWYQI’ QSZIQIRX JVSQ EIVMEP ETTPMGEXMSRW XS EKVMGYPXYVEP JMIP’ GVSTW
/IIT F]TEWW PMRI SR SV RIEV XLI FSXXSQ SJ XLI XERO XS QMRMQM^I JSEQMRK 7GVIIR WM^I MR 8LI ’MWXERGI SJ XLI SYXIVQSWX RS^^PIW SR XLI FSSQ QYWX RSX I\GII’  XLI PIRKXL
SJ XLI [MRKWTER SV VSXSV
RS^^PI SV PMRI WXVEMRIVW WLSYP’ FI RS JMRIV XLER QIWL
%P[E]W TVI’IXIVQMRI XLI GSQTEXMFMPMX] SJ PEFIPI’ XERO QM\XYVIW SJ XLMW TVS’YGX [MXL  2S^^PIW QYWX EP[E]W TSMRX FEGO[EV’ TEVEPPIP [MXL XLI EMVWXVIEQ ER’ RIZIV FI TSMRX
[EXIV GEVVMIV F] QM\MRK WQEPP TVSTSVXMSREP UYERXMXMIW MR E’ZERGI )RWYVI XLEX XLI WTI I’ ’S[R[EV’W QSVI XLER ’IKVIIW ;LIVI WXEXIW LEZI QSVI WXVMRKIRX VIKYPEXMSRW
GMJMG XERO QM\XYVI TVS’YGX MW VIKMWXIVI’ JSV ETTPMGEXMSR EX XLI ’IWMVI’ WMXI XLI] WLSYP’ FI SFWIVZI’

6IJIV XS XLI8ERO 1M\MRKWIGXMSR JSV E’’MXMSREP TVIGEYXMSRW -QTSVXER’I SJ HVSTPIX WM^I
8LI QSWX IJJIGXMZI [E] XS VI’YGI ’VMJX TSXIRXMEP MW XS ETTP] PEVKI ’VSTPIXW 8LI FIWX ’VMJX
 1M\MRK JSV ,ERH,IPH 7TVE]IVW QEREKIQIRX WXVEXIK] MW XS ETTP] XLI PEVKIWX ’VSTPIXW XLEX TVSZM’I WYJJMGMIRX GSZIVEKI ER’
 GSRXVSP %TTP]MRK PEVKIV ’VSTPIXW VI’YGIW ’VMJX TSXIRXMEP FYX [MPP RSX TVIZIRX ’VMJX MJ ETTPM
GEXMSRW EVI QE’I MQTVSTIVP] SV YR’IV YRJEZSVEFPI IRZMVSRQIRXEP GSR’MXMSRW WII XLI
4VITEVI XLI ’IWMVI’ ZSPYQI SJ WTVE] WSPYXMSR F] QM\MRK XLI EQSYRX SJ XLMW TVS’YGX EW
MR’MGEXI’ MR XLI JSPPS[MRK XEFPI [MXL [EXIV ;MRH 8IQTIVEXYVI ERH ,YQMHMX]ER’ 8IQTIVEXYVI -RZIVWMSRWIGXMSRW SJ XLMW PEFIP


ANNEX 128

'SRXVSPPMRK HVSTPIX WM^I % VIGMVGYPEXMRK WTVE] W]WXIQ ’MVIGXW XLI WTVE] WSPYXMSR SRXS [II’W KVS[MRK EFSZI ’IWMV
e:SPYQI 9WI LMKL JPS[ VEXI RS^^PIW XS ETTP] XLI LMKLIWX TVEGXMGEP WTVE] ZSPYQI EFPI ZIKIXEXMSR [LMPI WTVE] WSPYXMSR RSX MRXIVGITXI’ F] [II’W MW GSPPIGXI’ ER’ VIXYVRI’
2S^^PIW [MXL XLI LMKLIV VEXI’ JPS[W TVS’YGI PEVKIV ’VSTPIXW XS XLI WTVE] XERO JSV VIYWI
%:3-( '328%'8 3* ,)6&-'-() ;-8, ()7-6%&0) :)+)8%8-32 'SRXEGX SJ XLMW TVS’
e 4VIWWYVI9WI XLI PS[IV WTVE] TVIWWYVIW VIGSQQIR’I’ JSV XLI RS^^PI ,MKLIV TVIW YGX [MXL ’IWMVEFPI ZIKIXEXMSR QE] VIWYPX MR YR[ERXI’ TPERX ’EQEKI SV ’IWXVYGXMSR
WYVI VI’YGIW ’VSTPIX WM^I ER’ ’SIW RSX MQTVSZI GERST] TIRIXVEXMSR ;LIR LMKLIV JPS[
VEXIW EVI RII’I’ YWI LMKLIV JPS[ VEXI RS^^PIW MRWXIE’ SJ MRGVIEWMRK TVIWWYVI %TTPMGEXMSR IUYMTQIRX YWI’ EFSZI ’IWMVI’ ZIKIXEXMSR WLSYP’ FI E’NYWXI’ WS XLEX XLI
PS[IWX WTVE] WXVIEQ SV [MTIV GSRXEGX TSMRX MW EX PIEWX  MRGLIW EFSZI XLI ’IWMVEFPI
e 2YQFIV SJ RS^^PIW 9WI XLI QMRMQYQ RYQFIV SJ RS^^PIW XLEX TVSZM’I YRMJSVQ ZIKIXEXMSR (VSTPIXW QMWX JSEQ SV WTPEXXIV SJ XLI LIVFMGM’I WSPYXMSR WIXXPMRK SR ’IWMV
GSZIVEKI EFPI ZIKIXEXMSR MW PMOIP] XS VIWYPX MR ’MWGSPSVEXMSR WXYRXMRK SV ’IWXVYGXMSR
e 2S^^PI SVMIRXEXMSR 3VMIRXMRK RS^^PIW WS XLEX XLI WTVE] MW VIPIEWI’ FEGO[EV’W TEV
EPPIP XS XLI EMVWXVIEQ [MPP TVS’YGI PEVKIV ’VSTPIXW XLER SXLIV SVMIRXEXMSRW 7MKRMJMGERXIXXIV VIWYPXW QE] FI SFXEMRI’ [LIR QSVI SJ XLI [II’ MW I\TSWI’ XS XLI LIVFMGM’I WSPY
’IJPIGXMSR JVSQ XLI LSVM^SRXEP [MPP VI’YGI ’VSTPIX WM^I ER’ MRGVIEWI ’VMJX TSXIRXMEP XMSR ;II’W RSX GSRXEGXI’ F] XLI LIVFMGM’I WSPYXMSR [MPP RSX FI EJJIGXI’ 8LMW QE] SGGYV
MR ’IRWI GPYQTW WIZIVI MRJIWXEXMSRW SV [LIR XLI LIMKLX SJ XLI [II’W ZEVMIW WS XLEX RSX
e 2S^^PI X]TI 9WI E RS^^PI X]TI XLEX MW ’IWMKRI’ JSV XLI MRXIR’I’ ETTPMGEXMSR ;MXL EPP [II’W EVI GSRXEGXI’ -R XLIWI MRWXERGIW VITIEX XVIEXQIRX QE] FI RIGIWWEV]
QSWX RS^^PI X]TIW REVVS[IV WTVE] ERKPIW TVS’YGI PEVKIV ’VSTPIXW 'SRWM’IV YWMRK
PS[’VMJX RS^^PIW 7SPM’ WXVIEQ RS^^PIW SVMIRXI’ WXVEMKLX FEGO TVS’YGI PEVKIV ’VSTPIXW 7LMIPHIH ERH ,SSHIH %TTPM’EXSVW
XLER SXLIV RS^^PI X]TIW % WLMIP’I’ SV LSS’I’ ETTPMGEXSV ’MVIGXW XLI LIVFMGM’I WSPYXMSR SRXS [II’W [LMPI WLMIP’MRK

e &SSQ PIRKXL *SV WSQI YWI TEXXIVRW VI’YGMRK XLI IJJIGXMZI FSSQ PIRKXL XS PIWW XLER ’IWMVEFPI ZIKIXEXMSR JVSQ XLI LIVFMGM’I 9WI RS^^PIW XLEX TVSZM’I YRMJSVQ GSZIVEKI [MXLMR
 SJ XLI [MRKWTER SV VSXSV PIRKXL QE] JYVXLIV VI’YGI ’VMJX [MXLSYX VI’YGMRK W[EXL XLI XVIEXI’ EVIE /IIT WLMIP’W SR XLIWI WTVE]IVW E’NYWXI’ XS TVSXIGX ’IWMVEFPI ZIKIXEXMSR
[M’XL )<86)1) '%6) 1978 &) )<)6'-7)( 83 %:3-( '328%'8 3* ,)6&-'-() ;-8, ()7-6%&0)
:)+)8%8-32
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JIIX EFSZI XLI XST SJ XLI PEVKIWX TPERXW YRPIWW E KVIEXIV LIMKLX MW VIUYMVI’ JSV EMV
GVEJX WEJIX] 1EOMRK ETTPMGEXMSRW EX XLI PS[IWX LIMKLX XLEX MW WEJI VI’YGIW XLI % [MTIV SV WTSRKI ETTPMGEXSV ETTPMIW XLI LIVFMGM’I WSPYXMSR SRXS [II’W F] VYFFMRK XLI
I\TSWYVI SJ XLI ’VSTPIXW XS IZETSVEXMSR ER’ [MR’ [II’ [MXL ER EFWSVFIRX QEXIVMEP GSRXEMRMRK XLI LIVFMGM’I WSPYXMSR )UYMTQIRX QYWX FI
’IWMKRI’ QEMRXEMRI’ ER’ STIVEXI’ XS TVIZIRX XLI LIVFMGM’I WSPYXMSR JVSQ GSRXEGXMRK
7[EXL %HNYWXQIRX ’IWMVEFPI ZIKIXEXMSR 3TIVEXI XLMW IUYMTQIRX EX KVSYR’ WTII’W RS KVIEXIV XLER QMPIW
;LIR ETTPMGEXMSRW EVI QE’I [MXL E GVSWW[MR’ XLI W[EXL [MPP FI ’MWTPEGI’ ’S[R[MR’ TIV LSYV 4IVJSVQERGI QE] FI MQTVSZI’ F] VI’YGMRK WTII’ MR EVIEW SJ LIEZ] [II’
8LIVIJSVI SR XLI YT ER’ ’S[R[MR’ I’KIW SJ XLI JMIP’ XLI ETTPMGEXSV QYWX GSQTIRWEXI
JSV XLMW ’MWTPEGIQIRX F] E’NYWXMRK XLI TEXL SJ XLI EMVGVEJX YT[MR’ 7[EXL E’NYWXQIRX MRJIWXEXMSRW XS IRWYVI E’IUYEXI [MTIV WEXYVEXMSR &IXXIV VIWYPXW QE] FI SFXEMRI’ MJ X[S

ETTPMGEXMSRW EVI QE’I MR STTSWMXI ’MVIGXMSRW
’MWXERGI WLSYP’ MRGVIEWI [MXL MRGVIEWMRK ’VMJX TSXIRXMEP LMKLIV [MR’ WTII ’ WQEPPIV %ZSM’PIEOEKI SV ’VMTTMRK SRXS ’IWMVEFPI ZIKIXEXMSR %’NYWX LIMKLX SJ ETTPMGEXSV XS IRWYVI
’VSTPIXW IXG
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;MRH
KVSYR’ XLI LIVFMGM’I WSPYXMSR QE] QMKVEXI GEYWMRK ’VMTTMRK SR XLI PS[IV IR’ ER’ ’V]
(VMJX TSXIRXMEP MW PS[IWX FIX[IIR [MR’ WTII’W SJ  XS  QMPIW TIV LSYV ,S[IZIV QER] MRK SJ XLI [MGOW SR XLI YTTIV IR’ SJ E [MTIV ETTPMGEXSV
JEGXSVW MRGPY’MRK ’VSTPIX WM^I ER’ IUYMTQIRX X]TI ’IXIVQMRI ’VMJX TSXIRXMEP EX ER] KMZIR (S RSX YWI [MTIV ETTPMGEXSVW [LIR [II’W EVI [IX
[MR’ WTII’ %TTPMGEXMSR WLSYP’ FI EZSM’I’ [LIR [MR’ WTII’W EVI FIPS[  QMPIW TIV
LSYV ’YI XS ZEVMEFPI [MR’ ’MVIGXMSR ER’ LMKL MRZIVWMSR TSXIRXMEP 238) 0SGEP XIVVEMR GER 1M\SRP] XLI EQSYRX SJ WSPYXMSR XS FI YWI’’YVMRK E’E] TIVMS’ EW VI’YGI’EGXMZMX] QE]
MRJPYIRGI [MR’ TEXXIVRW )ZIV] ETTPMGEXSV WLSYP’ FI JEQMPMEV [MXL PSGEP [MR’ TEXXIVRW VIWYPX JVSQ YWI SJ PIJXSZIV WSPYXMSRW 'PIER [MTIV TEVXW MQQI’MEXIP] EJXIV YWMRK XLMW TVS’
ER’ LS[ XLI] EJJIGX ’VMJX YGX F] XLSVSYKLP] JPYWLMRK [MXL [EXIV
*SV 6STI SV 7TSRKI ;M’O %TTPM’EXSVW 9WI WSPYXMSRW VERKMRK JVSQ  XS TIVGIRX SJ
8IQTIVEXYVI ERH ,YQMHMX]
;LIR QEOMRK ETTPMGEXMSRW MR PS[ VIPEXMZI LYQM’MX] E’NYWX IUYMTQIRX XS TVS’YGI PEVKIV XLMW TVS’YGX MR [EXIV
*SV 4ERIP %TTPM’EXSVW ERH 4VIWWYVI*IIH 7]WXIQW 9WI WSPYXMSRW VERKMRK JVSQ 
’VSTPIXW XS GSQTIRWEXI JSV IZETSVEXMSR (VSTPIX IZETSVEXMSR MW QSWX WIZIVI [LIR GSR XS  TIVGIRX SJ XLMW TVS’YGX MR [EXIV
’MXMSRW EVI FSXL LSX ER’ ’V]
8IQTIVEXYVI -RZIVWMSRW ;LIR ETTPMI’ EW VIGSQQIR’I’ EFSZI XLMW TVS’YGX '3286307 XLI JSPPS[MRK
[II’W
%TTPMGEXMSRW WLSYP’ RSX FI QE’I ’YVMRK E XIQTIVEXYVI MRZIVWMSR FIGEYWI ’VMJX TSXIRXMEP MW 'SVR ZSPYRXIIV 7MGOPITS’
LMKL 8IQTIVEXYVI MRZIVWMSRW VIWXVMGX ZIVXMGEP EMV QM\MRK [LMGL GEYWIW WQEPP WYWTIR’I’
’VSTPIXW XS VIQEMR MR E GSRGIRXVEXI’ GPSY’ 8LMW GPSY’ GER QSZI MR YRTVI’MGXEFPI ’MVIG 4ERMGYQ 8I\EW 7TERMWLRII’PIW
XMSRW ’YI XS XLI PMKLX ZEVMEFPI [MR’W GSQQSR ’YVMRK MRZIVWMSRW 8IQTIVEXYVI MRZIVWMSRW 6]I GSQQSR 7XEVFYV FVMWXP]
EVI GLEVEGXIVM^I’ F] MRGVIEWMRK XIQTIVEXYVIW [MXL EPXMXY’I ER’ EVI GSQQSR SR RMKLXW 7LEXXIVGERI
[MXL PMQMXI’ GPSY’ GSZIV ER’ PMKLX XS RS [MR’ 8LI] FIKMR XS JSVQ EW XLI WYR WIXW ER’ SJXIRLIR ETTPMI’ EW VIGSQQIR’I’ EFSZI XLMW TVS’YGX 79446)77)7 XLI JSPPS[MRK
GSRXMRYI MRXS XLI QSVRMRK 8LIMV TVIWIRGI GER FI MR’MGEXI’ F] KVSYR’ JSK LS[IZIV MJ JSK [II’W

MWRSXTVIWIRXQSZIQIRXSJWQSOITVS’YGI’F] EKVSYR’WSYVGISVEREMVGVEJX WQSOIKIR &IKKEV[II’ *PSVM’E 6EK[II’ GSQQSR
IVEXSV GER EPWS M’IRXMJ] XIQTIVEXYVI MRZIVWMSRW 7QSOI XLEX PE]IVW ER’ QSZIW PEXIVEPP] MR &IVQY’EKVEWW 6EK[II’ KMERX
E GSRGIRXVEXI’GPSY’ YR’IV PS[[MR’GSR’MXMSRW
MR’MGEXIWERMRZIVWMSR [LMPIWQSOIXLEX (SKFERI LIQT 7QYXKVEWW
QSZIW YT[EV’ ER’ VETM’P] ’MWWMTEXIW MR’MGEXIW KSS’ ZIVXMGEPEMV QM\MRK (SKJIRRIP 7YRJPS[IV

7IRWMXMZI %VIEW +YMRIEKVEWW 8LMWXPI 'ERE’E
%TTP] XLMW TVS’YGX SRP] [LIR XLI TSXIRXMEP JSV ’VMJX XS WIRWMXMZI EVIEW IK VIWM’IRXMEP.SLRWSRKVEWW 8LMWXPI QYWO
EVIEW FS’MIW SJ [EXIV ORS[R LEFMXEX JSV XLVIEXIRI’ SV IR’ERKIVI’ WTIGMIW RSRXEVKIX 1MPO[II’ :EWI]KVEWW
GVSTW
MW QMRMQEP IK [LIR [MR’ MW FPS[MRK E[E] JVSQ XLI WIRWMXMZI EVIEW
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4MK[II’ VI’VSSX

 +VSYRH &VSEH’EWX)UYMTQIRX  -RNI’XMSR 7]WXIQW
 

9WI XLI VIGSQQIR’I’ VEXIW SJ XLMW TVS’YGX MR  XS  KEPPSRW SJ [EXIV TIV EGVI EW E 8LMW TVS’YGX QE] FI YWI’ MR EIVMEP SV KVSYR’ MRNIGXMSR WTVE] W]WXIQW -X QE] FI YWI’ EW
FVSE’GEWX WTVE] YRPIWW SXLIV[MWI WTIGMJMI’ %W ’IRWMX] SJ [II’W MRGVIEWIW WTVE] ZSP E PMUYM’ GSRGIRXVEXI SV ’MPYXI’ TVMSV XS MRNIGXMRK MRXS XLI WTVE] WXVIEQ (S RSX QM\ XLMW
YQI WLSYP’ FI MRGVIEWI’ [MXLMR XLI VIGSQQIR’I’ VERKI XS IRWYVI GSQTPIXI GSZIVEKI
'EVIJYPP]WIPIGX TVSTIV RS^^PIWXS EZSM’WTVE]MRKEJMRI QMWX*SVFIWXVIWYPXW [MXLKVSYR’ TVS’YGX [MXL XLI YR’MPYXI’ GSRGIRXVEXI SJ SXLIV TVS’YGXW [LIR YWMRK MRNIGXMSR W]WXIQW
ETTPMGEXMSR IUYMTQIRX YWI JPEXJER RS^^PIW 'LIGO JSV IZIR ’MWXVMFYXMSR SJ WTVE] YRPIWW WTIGMJMGEPP] VIGSQQIR’I’
’VSTPIXW
 '(% )UYMTQIRX

 &E’OTE’O SV ,ERH,IPH )UYMTQIRX
 8LI VEXI SJ XLMW TVS’YGX ETTPMI’ TIV EGVI F] GSRXVSPPI’ ’VSTPIX ETTPMGEXMSR '(%
IUYMT
QIRX QYWX RSX FI PIWW XLER XLI EQSYRX VIGSQQIR’I’ MR XLMW PEFIP [LIR ETTPMI’ F]
%TTP] XS JSPMEKI SJ ZIKIXEXMSR XS FI GSRXVSPPI’ SR E WTVE]XS[IX FEWMW ’S RSX WTVE] XS GSRZIRXMSREP FVSE’GEWX IUYMTQIRX *SV ZILMGPIQSYRXI’ '(% IUYMTQIRX ETTP] MR  XS
XLI TSMRX SJ VYRSJJ 7TVE] GSZIVEKI WLSYP’ FI YRMJSVQ ER’ GSQTPIXI 9WI GSEVWI WTVE]W KEPPSRW SJ [EXIV TIV EGVI
SRP]
'(% IUYMTQIRX TVS’YGIW E WTVE] TEXXIVR XLEX MW RSX IEWMP] ZMWMFPI )\XVIQI GEVI QYWX
 7IPI’XMZI )UYMTQIRX FI I\IVGMWI’ XS EZSM’ WTVE] SV ’VMJX GSRXEGXMRK XLI JSPMEKI SV ER] SXLIV KVIIR XMWWYI SJ
 ’IWMVEFPI ZIKIXEXMSR EW ’EQEKI SV ’IWXVYGXMSR MW PMOIP] XS VIWYPX

8LMW TVS’YGX QE] FI ’MPYXI’[MXL [EXIV ER’ ETTPMI’ XLVSYKL VIGMVGYPEXMRK WTVE]W]WXIQW
WLMIP’I’ ETTPMGEXSVWLSS’I’ WTVE]IVW[MTIV ETTPMGEXSVW SV WTSRKI FEVW XS PMWXI’ [II’W
KVS[MRK MR ER] RSRGVST WMXI WTIGMJMI’ SR XLMW PEFIP

 ANNEX 129

United States Roundup SL Label, United States Pesticide Product Label System,
Registration No. 524-308 (15 Nov. 2001)ANNEX 129ANNEX 129ANNEX 129 ANNEX 130

(DOCUMENT INTENTIONALLY OMITTED) ANNEX 131

C. André Lévesque & James E. Rahe,

Herbicide Interactions with Fungal Root Pathogens,
with Special Reference to Glyphosate, Annu. Rev. Phytopathol., Vol. 30 (1992) ANNEX 131

Annual Reviews
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by Joanne Blinn on 03/03/09. For personal use only.

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United States Environmental Protection Agency,
Glyphosate Reregistration Eligibility Decision Fact Sheet (Sep. 1993) ANNEX 132

United States Prevention, Pesticides EPA-738-F-93-011
Environmental ProtectioAnd Toxic Substances September 1993
Agency (7508W)

R.E.D. F ACTS

Glyphosate

Pesticide All pesticides sold or distributed in the United States must be registered
Reregistration by EPA, based on scientific studies showing that they can be used without
posing unreasonable risks to people or the environment. Because of advances
in scientific knowledge, the law requires that pesticides which were first
registered years ago be reered to ensure that they meet today's more
stringent standards.

In evaluating pesticides for reregistration, EPA obtains and reviews a
complete set of studies from pesticide producers, describing the human health
and environmental effects of each pesticide. The Agency imposes any
regulatory controls that are needed to effectively manage each pesticide's

risks. EPA then reregisters pesticides that can be used without posing
unreasonable risks to human health or the environment.
When a pesticide is eligible for reregistration, EPA announces this and
explains why in a Reregistration Eligibility Decision (RED) document. This
fact sheet summarizes the information in the RED document for glyphosate.

Use Profile Glyphosate is a non-selective herbicide registered for use on many food
and non-food field crops as well as non-crop areas where total vegetation
control is desired. When applied at lower rates, glyphosate also is a plant
growth regulator.

Glyphosate is among the most widely used pesticides by volume. It
ranked eleventh among conventional pesticides used in the U.S. during 1990-
91. In recent years, approximately 13 to 20 million acres were treated with
18.7 million pounds of glyphosate annually. The largest use sites include
hay/pasture, soybeans and field corn.

Three salts of glyphosate are used as active ingredients in registered
pesticide products. Two of these active ingredients, plus technical grade
glyphosate, are contained in the 56 products that are subject to this RED.

The isopropylamine salt, an active ingredient in 53 registered products,
is used as a herbicide to control broadleaf weeds and grasses in many food
and non-food crops and a variety of other sites including ornamentals, lawns
and turf, residential areas, greenhouses, forest plantings and industrial rights-
of-way. It is formulated as a liquid, solid or pellet/tablet, and is applied using
ground or aerial equipment.ANNEX 132

The sodium salt of glyphosate, an active ingredient in two registered
pesticide products, is used as a plant growth regulator for peanuts and

sugarcane, to modify plant growth and hasten the ripening of fruit. It is
applied as a ground spray to peanut fields and as an aerial spray to sugarcane.

Preharvest intervals are established for both crops.
The monoammonium salt of glyphosate is an active ingredient in an
additional seven herbicide/growth regulator products. This form of

glyphosate was initially registered after November 1984, so it is not subject to
reregistration or included in this RED. However, in reassessing the existing
glyphosate tolerances (maximum residue limits in or on food and feed), EPA

included those for the monoammonium salt.

Regulatory EPA issued a Registration Standard for glyphosate in June 1986 (NTIS
PB87-103214). The Registration Standard required additional phytotoxicity,
History environmental fate, toxicology, product chemistry and residue chemistry

studies. All of the data required have been submitted and reviewed, or were
waived.

Human Health Toxicity

Assessment Glyphosate is of relatively low oral and dermal acute toxicity. It has
been placed in Toxicity Category III for these effects (Toxicity Category I
indicates the highest degree of acute toxicity, and Category IV the lowest).

The acute inhalation toxicity study was waived because glyphosate is non-
volatile and because adequate inhalation studies with end-use products exist
showing low toxicity.

A subchronic feeding study using rats showed blood and pancreatic
effects. A similar study with mice showed reduced body weight gains in both

sexes at the highest dose levels. A dermal study with rabbits showed slight
reddening and swelling of the skin, decreased food consumption in males and
decreased enzyme production, at the highest dose levels.

Several chronic toxicity/carcinogenicity studies using rats, mice and
beagle dogs resulted in no effects based on the parameters examined, or
resulted in findings that glyphosate was not carcinogenic in the study. In June

1991, EPA classified glyphosate as a Group E oncogen--one that shows
evidence of non-carcinogenicity for humans--based on the lack of convincing

evidence of carcinogenicity in adequate studies.
In developmental toxicity studies using pregnant rats and rabbits,
glyphosate caused treatment-related effects in the high dose groups including

diarrhea, decreased body weight gain, nasal discharge and death.
One reproductive toxicity study using rats showed kidney effects in the

high dose male pups; another study showed digestive effects and decreased
body weight gain. Glyphosate does not cause mutations.

2 ANNEX 132

In one metabolism study with rats, most of the glyphosate administered
(97.5 percent) was excreted in urine and feces as the parent compound; less
than one percent of the absorbed dose remained in tissues and organs,

primarily in bone tissue. Aminomethyl phosphonic acid (AMPA) was the
only metabolite excreted. A second study using rats showed that very little
glyphosate reaches bone marrow, that it is rapidly eliminated from bone

marrow, and that it is even more rapidly eliminated from plasma.
Dietary Exposure

The nature of glyphosate residue in plants and animals is adequately
understood. Studies with a variety of plants indicate that uptake of glyphosate

or AMPA from soil is limited. The material which is taken up is readily
translocated throughout the plant and into its fruit. In animals, most
glyphosate is eliminated in urine and feces. Enforcement methods are

available to detect residues of glyphosate and AMPA in or on plant
commodities, in water and in animal commodities.

85 tolerances have been established for residues of glyphosate and its
metabolite, AMPA, in or on a wide variety of crops and crop groups, as well

as in many processed foods, animal feed and animal tissues (please see 40
CFR 180.364, 40 CFR 185.3500 and 40 CFR 186.3500). EPA has reassessed
the existing and proposed tolerances for glyphosate. Though some

adjustments will be needed, no major changes in existing tolerances are
required. EPA also has compared the U.S. tolerances with international
Codex maximum residue limits (MRLs), and is recommending certain

adjustments to achieve greater compatibility.
EPA conducted a dietary risk assessment for glyphosate based on a

worst-case risk scenario, that is, assuming that 100 percent of all possible
commodities/acreage were treated, and assuming that tolerance-level residues
remained in/on all treated commodities. The Agency concluded that the

chronic dietary risk posed by glyphosate food uses is minimal.
A reference dose (RfD), or estimate of daily exposure that would not

cause adverse effects throughout a lifetime, of 2 mg/kg/day has been proposed
for glyphosate, based on the developmental toxicity studies described above.

Occupational and Residential Exposure
Occupational and residential exposure to glyphosate can be expected

based on its currently registered uses. However, due to glyphosate's low acute
toxicity and the absence of other toxicological concerns (especially

carcinogenicity), occupational and residential exposure data are not required
for reregistration.

Some glyphosate end-use products are in Toxicity Categories I or II for
primary eye irritation or skin irritation. In California, glyphosate ranks high
among pesticides causing illness or injury to workers, who report numerous

incidents of eye and skin irritation from splashes during mixing and loading.

3ANNEX 132

EPA is not adding any personal protective equipment (PPE) requirements at

this time, but any existing PPE label requirements must be retained.
The Worker Protection Standard (WPS) for Agricultural Pesticides

(please see 40 CFR 156 and 170) established an interim restricted entry
interval (REI) of 12 hours for glyphosate. The Agency has decided to retain
this REI as a prudent measure to mitigate risks to workers. During the REI,

workers may reenter areas treated with glyphosate only in the few, narrow
exceptions allowed in the WPS. The REI applies only to glyphosate uses
within the scope of the WPS, so homeowner and commercial uses are not

included.
Human Risk Assessment

EPA's worst case risk assessment of glyphosate's many registered food
uses concludes that human dietary exposure and risk are minimal. Existing

and proposed tolerances have been reassessed, and no significant changes are
needed to protect the public.

Exposure to workers and other applicators generally is not expected to
pose undue risks, due to glyphosate's low acute toxicity. However, splashes
during mixing and loading of some products can cause injury, primarily eye

and skin irritation. EPA is continuing to recommend PPE, including
protective eye wear, for workers using end-use products that are in Toxicity
Categories I or II for eye and skin irritation. To mitigate potential risks

associated with reentering treated agricultural areas, EPA is retaining the 12
hour REI set by the WPS.

Environmental Environmental Fate

Assessment Glyphosate adsorbs strongly to soil and is not expected to move
vertically below the six inch soil layer; residues are expected to be immobile
in soil. Glyphosate is readily degraded by soil microbes to AMPA, which is

degraded to carbon dioxide. Glyphosate and AMPA are not likely to move to
ground water due to their strong adsorptive characteristics. However,
glyphosate does have the potential to contaminate surface waters due to its

aquatic use patterns and through erosion, as it adsorbs to soil particles
suspended in runoff. If glyphosate reached surface water, it would not be

broken down readily by water or sunlight.
Ecological Effects

Glyphosate is no more than slightly toxic to birds and is practically non-
toxic to fish, aquatic invertebrates and honeybees. Due to the presence of a

toxic inert ingredient, some glyphosate end-use products must be labeled,
"Toxic to fish," if they may be applied directly to aquatic environments.
Product labeling does not preclude off-target movement of glyphosate by

drift. EPA therefore is requiring three additional terrestrial plant studies to
assess potential risks to nontarget plants.

EPA does not expect that most endangered terrestrial or aquatic
organisms will be affected by the registered uses of glyphosate. However,

4 ANNEX 132

many endangered plants as well as the Houston toad (due to its habitat) may
be at risk. EPA is deferring any use modifications or labeling amendments

until it has published the Endangered Species Protection Plan and has given
registrants guidance regarding endangered species precautionary labeling.

Ecological Effects Risk Assessment

Based on current data, EPA has determined that the effects of
glyphosate on birds, mammals, fish and invertebrates are minimal. Under

certain use conditions, glyphosate may cause adverse effects to nontarget
aquatic plants. Additional data are needed to fully evaluate the effects of
glyphosate on nontarget terrestrial plants. Risk reduction measures will be

developed if needed, once the data from these studies are submitted and
evaluated.

Additional Data EPA is requiring three generic studies (Tier II Vegetative Vigor,
Droplet Size Spectrum, and Drift Field Evaluation) which are not part of the
Required target data base and do not affect the reregistration eligibility of glyphosate.

The Agency also is requiring product-specific data including product
chemistry and acute toxicity studies, as well as revised Confidential
Statements of Formula and revised labeling.

Product Labeling All end-use glyphosate products must comply with EPA's current
pesticide product labeling requirements. In addition:
Changes Required
Protection of Aquatic Organisms

Non-Aquatic Uses - End-use products that are not registered for aquatic
uses must bear the following label statement:
Do not apply directly to water, to areas where surface water is present

or to intertidal areas below the mean high water mark. Do not
contaminate water when disposing of equipment washwaters and
rinsate.

Aquatic Uses - End-use products registered for aquatic uses must bear
the following label statement:

Do not contaminate water when disposing of equipment washwaters and
rinsate. Treatment of aquatic weeds can result in oxygen loss from

decomposition for dead plants. This loss can cause fish kills.

Worker Protection Standard (WPS) Requirements

Any product whose labeling permits use in the production of an
agricultural plant on any farm, forest, nursery or greenhouse must comply

with the labeling requirements of:
• PR Notice 93-7, "Labeling Revisions Required by the Worker

Protection Standard (WPS)," and

5ANNEX 132

• PR Notice 93-11, "Supplemental Guidance for PR Notice 93-7."

Unless specifically directed in the RED, all statements required by these two
PR Notices must appear on product labeling exactly as instructed in the

Notices. Labels must be revised by April 21, 1994, for products distributed or
sold by the primary registrant or supplementally registered distributors, and
by October 23, 1995, for products distributed or sold by anyone.

Personal Protective Equipment (PPE)

No new PPE requirements must be added to glyphosate labels.
However, any existing PPE requirements on labels must be retained.
Entry Restrictions

Products Not Primarily Intended for Home Use :

Uses Within the Scope of the WPS - A 12-hour restricted entry
interval (REI) is required for all products with uses within the scope of
the WPS, except products intended primarily for home use. The PPE

for early entry should be that required for applicators of glyphosate,
except any applicator requirement for an apron or respirator is waived.
This REI and PPE should be inserted into the standardized statements

required by PR Notice 93-7.
• Sole Active Ingredient End-Use Products - Labels must be

revised to adopt the entry restrictions set forth in this section.
Any conflicting entry restrictions on current labeling must be
removed.

• Multiple Active Ingredient Products - Registrants must compare
the entry restrictions set forth in this section to those on their

current labeling and retain the more protective. A specific time
period in hours or days is considered more protective than "until
sprays have dried" or "dusts have settled."

Uses Not Within the Scope of the WPS - No new entry restrictions
must be added. However, any entry restrictions on current product
labeling with these uses must be retained.

Products Primarily Intended for Home Use :
No new entry restrictions must be added. However, any entry

restrictions on current product labeling must be retained.

Regulatory The use of currently registered pesticide products containing the
isopropylamine and sodium salts of glyphosate in accordance with the
Conclusion
labeling specified in this RED will not pose unreasonable risks or adverse
effects to humans or the environment. Therefore, all uses of these products
are eligible for reregistration.

These glyphosate products will be reregistered once the required
product-specific data, revised Confidential Statements of Formula and revised

labeling are received and accepted by EPA.

6 ANNEX 132

Products which contain active ingredients in addition to glyphosate will

not be reregistered until all their other active ingredients also are eligible for
reregistration.

For More EPA is requesting public comments on the Reregistration Eligibility
Decision (RED) document for glyphosate during a 60-day time period, as
Information announced in a Notice of Availability published in the Federalegister. To

obtain a copy of the RED document or to submit written comments, please
contact the Pesticide Docket, Public Response and Program Resources

Branch, Field Operations Division (7506C), Office of Pesticide Programs
(OPP), US EPA, Washington, DC 20460, telephone 703- 305-5805.
Following the comment period, the glyphosate RED document will be

available from the National Technical Information Service (NTIS), 5285 Port
Royal Road, Springfield, VA 22161, telephone 703-487-4650.

For more information about EPA's pesticide reregistration program, the
glyphosate RED, or reregistration of individual products containing
glyphosate, please contact the Special Review and Reregistration Division

(7508W), OPP, US EPA, Washington, DC 20460, telephone 703-
308-8000.

For information about the health effects of pesticides, or for assistance
in recognizing and managing pesticide poisoning symptoms, please contact
the National Pesticides Telecommunications Network (NPTN). Call toll-free

1-800-858-7378, between 8:00 am and 6:00 pm Central Time, Monday
through Friday.

7 ANNEX 133

D.C. Sands et al., Characterization of a Vascular Wilt of Erythroxylum coca

Caused by Fusarium oxyspurum f. sp. Erythrowyli Forma Specialis Nova,
Plant Disease, Vol. 81, No. 5 (May 1997) ANNEX 133

Characterization of a Vascular Wilt of Erythroxylum coca

Caused by Fusarium oxysporum f. sp. erythroxyli Forma Specialis Nova

D. C. Sands, E. J. Ford, R. V. Miller, B. K. Sally, M. K. McCarthy, T. W. Anderson, M. B. Weaver, C. T. Morgan,
and A. L. Pilgeram, Department of Plant Pathology, Montana State University, Bozeman 59717; andL. C. Darlington,
Biocontrol of Plant Diseases Laboratory, USDA, ARS, Beltsville, MD 20705

The objectives of this study were to char-

ABSTRACT acterize the F. oxysporum isolates, deter-
Sands, D. C., Ford, E. J., Miller, R. V., Sally, B. K., McCarthy, M. K., Anderson, T. W., Weaver,mine their pathogenicity to Erythroxylum
M. B., Morgan, C. T., Pilgeram, A. L., and Darlington, L. C. 1997. Characterization of a vas- and selected crop species, and analyze ge-
cular wilt of Erythroxylum coca caused by Fusarium oxysporum f. sp. erythroxyli forma speci- netic variation within the group by arbitrar-
alis nova. Plant Dis. 81:501-504. ily primed polymerase chain reaction (PCR).

A new forma specialis of Fusarium oxysporum (F. oxysporum f. sp. erythroxyli) pathogenic to
Erythroxylum coca and E. novogranatense is described. The pathogen was isolated from the MATERIALS AND METHODS
Isolation of fungi from diseased tissue.
vascular tissue of diseased plants from anErythroxylumplantation in Hawaii. This pathogen causes In 1988, isolations were made from dis-
vascular wilt symptoms and death in both E. coca and E. novogranatense plants as soon as 7 colored vascular tissue from symptomatic
weeks after soil infestation. The pathogenicity of seven isolates from the affected field was
determined in field and growth-chamber studies. Genetic variation was not detected among the E. coca and E. novogranatense plants col-
seven Hawaiian isolates, using arbitrarily primed polymerase chain reaction. The seven isolates lected from the field and from symptomat-
could be differentiated from a strain isolated from a diseased E. coca plant from South America. ic seedlings of E. novogranatense grown in
All Hawaiian isolates and the South American isolate belonged to a single vegetative compati- shade houses at the experiment station.
bility group. Shade-house seedlings were started from

seeds collected from mature plants within
Additional keywords: DNA, mycoherbicide, RAPD the infested area and planted in a commer-
cial potting mix. Stem tissue was cross-
sectioned into 1- to 2-mm-thick slices and
surface-sterilized in a 0.8% solution of

Erythroxylum cocaand E. novogranatense damping-off disease characterized by chlor- sodium hypochlorite for 60 s. The tissue
plants showing symptoms of vascular wilt osis, abscission of healthy leaves, and se- sections were rinsed in sterile distilled water
were observed at a tropical research site on vere wilting. Seedling loss was initially be- and placed on 2% water agar supplemented
the Hawaiian island of Kauai in 1988. Symp- lieved to be due to the potting mixture or with 50 μg of streptomycin and 15 μg of
tetracycline per ml and incubated at ambi-
toms included chlorosis, leaf drop, and vas- water supply. The next year, 8,000 addi-
cular discoloration, eventually resulting in tional seeds were received from Cuzco, Peru. ent temperature for a minimum of 24 h.
death. Frequently, the external symptoms Fewer than 300 of these developed into The predominant fungi that grew out in-
were apparent first on a single branch or mature Erythroxylum plants. to the agar from each section of diseased
single side of an affected plant. In the early The incidence of wilt at the plantation tissue were transferred to potato dextrose
agar (PDA) (Difco Laboratories, Detroit),
stages of the disease, symptoms were more increased throughout the 1970s (7). During
apparent after water stress. Cross-sections this time, dead plants were removed from Komada’s medium (11), or Nash-Snyder me-
of stems and twigs from the wilted side of the field and immediately replaced with dium (14). Morphologically similar isolates
diseased plants revealed darkening of xy- healthy seedlings. Dissection of the branches of Fusarium were recovered from all dis-
lem tissue. Vascular discoloration extended of dead plants showed brown discoloration eased tissue tested and were identified asF.
oxysporum (1,2,15). Single-spore subcul-
from the root tissue through the crown and of the vascular bundles and cambial layer.
into the stem tissue of diseased plants. In The disease was observed in both seedlings tures of seven isolates of F. oxysporum
the initial observations, disease symptoms and mature plants and was suspected to be (strains Ec1, Ec2, Ec3, En1, En2, En3, and
were more prevalent in E. coca plants than caused by a fungus or bacterium that clogged En4) were arbitrarily selected for pathoge-
in E. novogranatense. the vascular system. Fusarium oxysporum nicity and molecular studies. Strains Ec1,
Ec2, and Ec3 were isolated from E. coca.
The Erythroxylumresearch plantation on was identified as the wilt organism during
the island of Kauai was originally estab- the 1980s, and its dispersal throughout the Strains En1, En2, En3, and En4 were iso-
lished by a major soft drink manufacturer research plots eventually resulted in termi- lated from E. novogranatense. F. oxyspor-
during the 1960s with 11 coca plants ob- nation of the breeding project. um strain SA1 was isolated from the crown
tained from the Lyon Arboretum, Foster Gar- The U.S. Department of Agriculture con- of a diseased E. coca plant from South

dens, and Marks Estates, Honolulu, HI (7). tinued to use this secure site for herbicide America.
Next, 8,000 seeds were obtained from Tru- studies on E. coca and E. novogranatense. Preservation of fungi. Cultures of each
jillo, Peru, but only about 20% germinated. Research was continually hindered by high F. oxysporum isolate were transferred to
Many of these seedlings succumbed to a disease incidence. In 1987, E. coca plants PDA and incubated at 28°C for 48 to 72 h.
grown from Peruvian seed and E. novo- Sterile birch-wood toothpicks were placed

granatense plants grown from Venezuelan on the expanding colony, and the cultures
Corresponding author: D. C. Sands seed were transplanted into the research site were incubated further at 28°C until the
E-mail: [email protected] (7). From this planting, 153 of 852 E. coca toothpicks were completely colonized by
plants and 1 of 370E. novogranatenseplants fungal mycelia (72 to 96 h). Approximately
Accepted for publication 3 February 1997. died within 3 months. F. oxysporum was 20 colonized toothpicks were placed in a

again isolated from the diseased plants, con- sterilized No. 2 dram screw-cap vial (Whea-
Publication no. D-1997-0312-04R firming its potential as a mycoherbicide for ton Scientific, Milleville, NJ). The tooth-
© 1997 The American Phytopathological Society control of coca. picks were dried by placing the uncapped

Plant Disease / May 1997 501ANNEX 133

tubes in a laminar flow hood for 12 to 24 h. Plants in infested and noninfested soil Due to slow seed germination, Erythroxy-
The tubes were capped and stored at 4 to were evaluated for disease after 4, 7, 8, 9, lum seedlings were wounded by cutting off
5°C for up to 5 years. Cultures were re- 10, and 15 months. Individual plants were approximately 30% of the root tissue and

covered readily from storage by placing a rated for disease severity on a scale of 0 to transplanted into pots containing infested
single toothpick on a plate of PDA and 2, where 0 = no disease, 1 = wilt, and 2 = soil. Wounded and nonwounded control plants
incubating for 24 to 72 h. plant death. Vascular tissue from both symp- were transplanted into soil amended with
Production of fungal inocula and soil tomatic and asymptomatic plants was cul- sterile rice grains. Tomato seeds andE. coca
infestation.Colonized millet seed was used tured directly on Komada’s medium. seedlings also were planted in soil that had

to infest soil in both field and growth-cham- Growth-chamber inoculations and host- been infested previously with F. oxysporum
ber virulence studies. Millet seed was moist- range experiments. Millet formulations of f. sp. lycopersici
ened with distilled water (1:1, wt/vol) and each strain of F. oxysporum also were used Hosts were randomized within treatments,
sterilized with a minimum of three auto- to infest soil in environmental growth-cham- with some limitations due to plant growth
claving cycles (60 min, 120°C). The sterile ber studies (12 h of light per 12 h of dark patterns. Treatments consisted of five plants

millet was inoculated with agar plugs from photoperiod; 30°C day, 28°C night). Thirty- of each species replicated twice. Conditions
a PDA culture of F. oxysporum and incu- centimeter pots of pasteurized greenhouse in the growth chambers and disease evalua-
bated at 28°C for 5 to 7 days. After the soil containing 6-month- to 1-year-old plants tions were as previously described. At the
fungus had colonized the seed completely, were infested by drilling three 10-cm holes termination of the experiment, one arbi-
the millet formulation was air-dried and stored in the soil equidistant from the base of each trary plant from each treatment was assessed

at 5°C. Control formulations consisted of plant and placing 10 colonized millet seeds for the presence of Fusarium by plating
colonized millet autoclaved prior to soil in- in each hole. Six pots containing Eryth- crown tissue on Komada’s medium.
festation. roxylum plants and six pots containing to- Determination of vegetative compati-
Host-range studies were done in soil in- mato plants were infested with each of the bility groups. Nitrogen nonutilizing auxo-
fested with a rice formulation of F. oxy- F. oxysporum isolates from Hawaii (strains trophs were selected from wild-type strains

sporum. Strains of F. oxysporum were cul- Ec1-3 and En1-4) and with strain SA1 from of En4, En3, En1, Ec2, Ec3, and SA1 (4).
tured in potato dextrose broth (PDB) at a diseased Erythroxylum plant from South Auxotrophs were paired in all combina-
ambient temperature, with agitation for 72 h, America. Control treatments consisted of tions to determine vegetative compatibility
and primarily yielded microconidia. The soil infested with sterilized millet formula- among the Erythroxylum isolates.
concentration of conidia in the culture was tions, nontreated soil, and soil infested with DNA extraction and PCR amplifica-

estimated with a hemacytometer and was a millet formulation of F. oxysporum f. sp. tion. DNA was isolated from fresh my-
mixed with sterilized, dehulled, milled rice lycopersic.i Each plant received 80 to 100 ml celial cultures of F. oxysporum , using a
grains at a rate of 3.3 × 10 conidia per g of of water per day dispensed by an automatic modification of the method of Doyle and
rice. The control consisted of noninoculated sprinkle watering system and was fertilized Doyle (9). Specifically, mycelia were har-
PDB poured over sterile rice. The treated with Peter’s general purpose fertilizer (Pe- vested from a 50-ml culture of PDB, trans-

rice was air-dried in a laminar flow hood ter’s Fertilizer Products, Fogelsville, PA) ferred to a sterile 50-ml centrifuge tube,
for 12 to 24 h and was mixed uniformly when leaves showed signs of chlorosis. Plants and lyophilized overnight. The dried myce-
with steamed greenhouse soil (1:100, wt/wt). were evaluated visually for disease weekly lia were ground and resuspended in 3 ml of
The rice/soil mixture was moistened, and and were maintained for a period of 3.5 DNA extraction buffer (2% cetyltrimethyl-
months. Stem tissue from 5 cm above the ammoniumbromide, 20 mM EDTA, 0.1 M
the fungus was allowed to ramify through-
out the soil for 1 to 3 weeks. soil line was collected from all plants at the Tris [pH 8.0], 1.4 M NaCl without 2-mer-
Field inoculations.Six- to twelve-month- termination of the test and cultured on Ko- captoethanol). The extractions were incu-
old E. coca and E. novogranatense seed- mada’s medium. bated at 65°C for 4 to 24 h and extracted
lings were transplanted to the field from an The host ranges of strains En4, Ec2, and twice with an equal volume of chloroform/
isoamyl alcohol (24:1, vol/vol). DNA was
on-site nursery during the fall of 1988. SA1 were evaluated on 26 plant species in
Individual research plots contained two E. environmental growth chambers. Host spe- precipitated with a 0.67 volume of isopro-
coca and two E. novogranatensetransplants cies included Hordeum vulgare (cv. Galla- panol, air-dried, and resuspended in 1 ml
at 60-cm intervals. Plots were separated by 4 tin),Phaseolus vulgaris(cv. Bush Blue Lake), of dH 2O.
m. During the spring of 1989, plots were Beta vulgaris (cv. Burpee’s Red Ball), Cu- The DNA was amplified in a 50-μl reac-

infested with millet formulations of the cumis melo var. cantalupensis(cv. Burpee’s tion mixture containing 1 × Promega reac-
seven Hawaiian isolates of F. oxysporumor Hybrid), Daucus carota subsp. sativus (cv. tion buffer (without MgCl)2 3.0 mM MgCl , 2
with control formulations. Two methods of Toudo Hybrid), Capsicum annuum (cv. Su- 0.2 mM each dNTP, 5 pM primer, 5 to 50 ng
field infestation were compared. In the first per Chile), Zea mays (cv. Sakota), Gos- of genomic DNA, and 1 unit of Taqpoly-
method, a 2-cm-deep, V-shaped trench was sypium barbadense (cv. LA860518), Vigna merase (Promega, Madison, WI) overlaid

formed in the soil 10 cm from one side of unguiculata (cv. Mississippi Silver), Cucu- with mineral oil. Amplifications were per-
each Erythroxylumplant; millet inoculum mis sativus (cv. Burpee’s Hybrid II), Lac- formed in a Perkin Elmer/Cetus (Norwalk,
(5.0 g per plot) was added to the trench and tuca sativa (cv. Tango), Abelmoschus escu- CT) thermocycler model 480 programmed
covered with 2 to 3 cm of soil. Four plots lentus(cv. Clemson Spineless), Allium cepa for 45 cycles of 94°C for 1 min, 35°C for 1
were infested with millet formulations of (cv. Yellow Sweet Spanish), Pisum sativum min, and 72°C for 1 min, followed by a

each fungal isolate, and seven control plots (cv. Alaska), Arachis hypogaea(variety not final extension at 72°C for 10 min. DNA
were infested with the sterilized millet for- specified), Cucurbita moschata (cv. Triple from isolates En1, En3, En4, Ec2, Ec3, and
mulation. In the second infestation method, Treat), Raphanus sativus(cv. Plum Purple), SA1 was amplified with six 10-base ran-
millet inoculum was applied directly to the Oryza sativa(cv. Lemont), Carthamus tinc- dom amplified polymorphic DNA primers
soil surface of each research plot approxi- torius (variety not specified), Sorghum bi- (AC08, AC17, AD04, AD08, AD14, and

mately 10 cm from one side of each row of color (cv. 1210), Glycine max (cv. Hartz AD18) (5,6,13). In addition, DNA was am-
plants (5.0 g per plot). The millet inoculum Variety H4464),Helianthus annuus(cv. Sun- plified with two primers derived from mini-
was protected from predation with a mesh spot), Lycopersici esculentum(cv. Burpee’s satellite sequences (primer (GACA) 4[5 ′-
screen. Fungal treatments were replicated Early Pick), Citrullus lanatus(cv. BushSu- GACA GACA GACA GACA] and primer
twice, and control treatments were replicated gar Baby), Triticum aestivum (cv. Neeley), (GTG) [5 ′-GTG GTG GTG GTG GTG
5
three times using this infestation protocol. and E. coca. All test species, except Eryth- GTG]) (10). Primers were obtained from
After soil infestation, plants were watered roxylum, were exposed to the pathogens by Operon Technologies (Alameda, CA). PCR
with trickle irrigation. planting pregerminated seeds in infested soil. products were visualized by UV-fluorescent

502 Plant Disease / Vol. 81 No. 5 ANNEX 133

staining with ethidium bromide (16). Am- nificantly higher than the disease ratings of control E. coca plants and 38% of the

plification reactions were repeated a mini- the control plants in both field experiments control E. novogranatense plants had died.
mum of three times. (Table 1). The mean disease rating from The percentage of treated plants that had
the subsurface and surface infestations were died increased to 63% for E. coca and 50%

RESULTS not significantly different. Strain En4 was for E. novogranatense. At the final disease
Field inoculations. The first symptoms the most virulent isolate in both studies. F. evaluation, 94% of all E. coca plants had
of disease on Erythroxylumplants were leaf oxysporum was recovered routinely from died, whereas only 49% of all E. novo-
drop and the deaths of a few lower stems. both symptomatic and asymptomatic plants granatense had died.

Plant death was recorded 7 weeks after soil from infested plots, as well as from symp- Growth-chamber inoculations. In con-
infestation. The period of time between in- tomatic plants from control plots. trast to field results, severe disease was not
itial symptoms and plant death was vari- The mean disease rating ofE. cocaplants observed in the growth-chamber pathoge-

able, ranging from days to months. The av- was significantly higher than the mean dis- nicity studies. For example, in initial stud-
erage disease ratings of plants grown in ease rating of E. novogranatense (Table 2). ies in which Erythroxylum seedlings were
soil infested with F. oxysporum were sig- The disease ratings ofE. coca plants treated exposed to the pathogen after transplan-
with F. oxysporumwere significantly higher tation, only two of six E. coca plants died

than the disease ratings of nontreated plants, after treatment with strain En4 (data not
Table 1.Comparison of the effects of surface indicating that all seven isolates were path- shown). External wilt symptoms were not
and subsurface field infestations on the patho- ogenic to E. coca. The average disease rat- observed on the remaining plants. How-

genicity of seven isolates of Fusarium oxyspor- ings of E. novogranatense plants treated ever, at the termination of the experiment,
um f. sp. erythroxyli to Erythroxylum spp. with six of the seven F. oxysporum strains discoloration was observed in the vascular
z were significantly higher than the control tissues. Similar results were obtained for
Disease severity
Isolate Subsurface Surface Mean (Table 2). The disease rating of E. novo- the other strains. Wilt or vascular discol-
granatense plants treated with strain Ec3 oration was not observed in Erythroxylum
Control 0.74 0.65 0.71 a was not significantly different from the dis- plants grown in noninfested soil.
Ec3 0.84 1.23 0.97 b ease rating of the control. For four of the Transplantation into infested soil was a
En2 1.00 1.15 1.05 bc
En3 1.08 1.08 1.08 b–d six strains that were virulent on both Eryth- more effective means of inoculating Eryth-
En1 1.44 0.68 1.18 cd roxylum species, the average disease rating roxylum plants in growth-chamber studies.
Ec1 1.35 1.05 1.25 de on E. coca was higher than the average Erythroxylum plants began showing char-

Ec2 1.26 1.28 1.27 de disease rating on E. novogranatense. The acteristic wilt symptoms 3 weeks after trans-
En4 1.46 1.30 1.41 e average disease rating of control E. coca plantation. Early symptoms rapidly devel-
Mean A 1.10 A A 1.03 A plants in the naturally infested field was oped into severe wilt and death. Disease
higher than the average disease rating of symptoms were observed in Erythroxylum
zAverage disease ratings of Erythroxylum plants
in soil infested with a subsurface application control E. novogranatenseplants. plants transplanted into soil infested with
Differences in the progression of the dis- strains En4, Ec2, and SA1 but were not
(four replications per fungal treatment and eightease on E. coca and E. novogranatense observed in transplants in noninfested soil.
replications per control treatment) or a surface
application (two replications per fungal treat- also were apparent (Fig. 1). At the 7-month The symptoms observed in these diseased
ment and four replications per control treat- evaluation, 43% of theE. cocaplants treated Erythroxylum plants were identical to the
ment) of F. oxysporum. Disease ratings are aver- with F. oxysporum had died, whereas only wilt symptoms observed in the field.F. oxy-
ages of 7-, 8-, 9-, 10-, and 15-month readings. sporum was recovered from all diseased
Disease was rated on a scale of 0 to 2, where 30% of the E. novogranatense plants had
died. Dead Erythroxylum plants were not tissue and was morphologically indistin-
0 = no symptoms, 1 = wilt symptoms, and 2 = observed in any of the control plots at this guishable from strains of F. oxysporum re-
death. Numbers in columns or rows followed time. Disease progression remained con- covered from field isolations.
by the same letter are not significantly differ-
ent according to Student’s least significant dif-stant in the treated plots over the next three Host range.With the exception ofEryth-
ference test (LSD = 0.1931) at P = 0.05. evaluations (at 8, 9, and 10 months). How- roxylum, symptoms of Fusarium wilt were
ever, during this time, disease incidence not observed on any of the host plants in-

rapidly progressed within the control plots. fested with F. oxysporum strain En4, Ec2,
At the 10-month evaluation, 43% of the or SA1. F. oxysporum was recovered from
Table 2.Disease severity in Erythroxylum coca
and E. novogranatense plants grown in field soil
infested with Fusarium oxysporum f. sp. eryth-
roxyli isolates

Disease ratingz
Treatment E. coca E. novogranatense

Control 0.86 b 0.56 a
Ec3 1.12 c–e 0.81 ab
En1 1.17 de 1.20 de
En2 1.22 e 0.88 bc

En3 1.22 e 0.93 b–d
Ec1 1.25 e 1.25 e
Ec2 1.57 f 0.97 b–e
En4 1.67 f 1.15 c–e

Mean 1.22 A 0.93 B
z
Average disease ratings of E. coca or E. nova-
granatense plants at 7, 8, 9, 10, and 15 months
after soil infestation withF. oxysporum. Disease
was rated on a scale of 0 to 2, where 0 = no
symptoms, 1 = wilt symptoms, and 2 = death.
Numbers in columns or rows followed by the
same letter are not significantly different accord-
ing to Student’s least significant difference test
Fig. 1. Progression of Fusarium wilt disease in treated and control plots of Erythroxylum coca and E.
(LSD = 0.2720) at P = 0.05. novogranatense.

Plant Disease / May 1997 503ANNEX 133

from the South American transplants used
to establish the Hawaiian plantation.

ACKNOWLEDGMENTS
We thank J. Antognini and L. Christy, formerly
of the Weed Science Laboratory, BARC, for their
encouragement in the early stages of this research
and J. Jessell and R. Hohne for their contributions
in the preparation of the manuscript.

LITERATURE CITED
1. Barnett, H. L., and Hunter, B. B. 1987. Illus-
trated Genera of Imperfect Fungi. Macmillan
Publishing Company, New York.

2. Brayford, D. 1993. The identification ofFu-
sariumspecies. Pages 1-119 in: Workshop Man-
ual. International Mycological Institute. CAB
International, Wallingford, England.
3. Burgess, L. W. 1981. General ecology of the
fusaria. Pages 225-235 in: Fusarium: Dis-
eases, Biology, and Taxonomy. P. E. Nelson,
T. A. Toussoun, and R. J. Cook, eds. The
Pennsylvania State University Press, Uni-
versity Park, PA.
4. Correll, J. C., Klittich, C. J. R., and Leslie, J. F.
1987. Nitrate nonutilizing mutants ofFusar-
Fig. 2. Arbitrarily primed polymerase chain reaction fingerprints for isolates of Fusarium oxysporum ium oxysporum and their use in vegetative
compatibility tests. Phytopathology 77:1640-
f. sp. erythroxyli (Hawaiian strains Ec2-3, En1, and En3-4 and South American strain SA1), F. oxy-
sporum f. sp. capsici (strain 0-934), and F. oxysporum f. sp. niveum (strain 0-1722) primed with ran- 1646.
dom amplified polymorphic DNAprimer AD14 (5′-GAACGAGGGT). DNA size markers (lambda DNA 5. Crowhurst, R. N., Hawthorne, B. T., Rikkerink,
cut with restriction enzymes HindIII and EcoRI) are indicated in kilobase pairs to the right. E. H. A., and Templeton, M. D. 1991. Differ-
entiation of Fusarium solani f. sp. cucurbitae
races 1 and 2 by random amplified polymor-
the crown of most plants seeded in infested ferred to as F. oxysporum f. sp. erythroxyli. phic DNA. Curr. Genet.20:391-396.
soil. Wilt symptoms were observed in to- Significant differences in the field path- 6. Crowhurst, R. N., King, F. Y., Hawthorne, B. T.,
Sanderson, F. R., and Choi-Pheng, Y. 1995.
mato plants seeded in soil infested with F. ogenicity of the Hawaiian strains to E. coca RAPD characterization of Fusarium oxyspor-
oxysporum f. sp. lycopersici but were not and E. novogranatensewere observed. South um associated with wilt of angsana ( Pterocar-
observed in Erythroxylum transplants in F. American isolate SA1 was not tested in pus indicus) in Singapore. Mycol. Res. 99:14-
oxysporum f. sp. lycopersici-infested soil. field experiments. The fungus was highly 18.
7. Darlington, L. 1996. History of Erythroxylum
Vegetative compatibility and DNA anal- aggressive and was disseminated rapidly
ysis. Strains of F. oxysporum from Hawaii throughout the original infested field. The and notes on diseases and pests at Kauai Field
were vegetatively compatible with each other initial progression of the disease was more Site. Page 43 in: 1st Int.FusariumBiocon. Work-
shop. USDA-ARS, Beltsville, MD.
and with South American strain SA1. Ar- pronounced in infested plots than in the 8. de Segura, C. B. 1959. Principales Enferme-
bitrarily primed-PCR with any of the eight control plots. However, containment of the dades de las Plantas en el Perú. Fitopatógia de
selected primers did not discriminate be- fungus proved challenging, as evidenced las Estaciones Experimentales Agricolas de las
tween the Hawaiian isolates and the South by late development of disease in control Asociaciones de Agriculturas de Cañete e I.
C. A. y del Comité de Defensa Técnica del Al-
American isolate (Fig. 2; data not shown). plots (Fig. 1). These late infections could godonero de la Sociedad Nacional Agraria, Ca-
The Erythroxylum isolates of F. oxysporum have resulted from resident F. oxysporum f. ñete, Perú.
could be distinguished from F. oxysporum sp. erythroxylipopulations or from the move- 9. Doyle, J. J., and Doyle, J. L. 1987. A rapid
DNA isolation procedure for small quantities
f. sp. capsici strain 0-1722 and F. oxyspor- ment of the introduced pathogen through- of fresh tissue. Phytochem. Bull. 19:11-15.
um f. sp. niveum strain 0-934 by seven of out the field. 10. Freeman, S., and Rodriguez, R. J. 1995. Dif-
the eight arbitrary primers. Koch’s postulates were confirmed in
growth-chamber studies. Disease incidence ferentiation of Colletotrichum species re-
sponsible for anthracnose of strawberry by
DISCUSSION was higher under field conditions than arbitrarily primed PCR. Mycol. Res.
Few diseases of Erythroxylum have been under growth-chamber conditions. Envi- 99:501-504.
described (12). However, Fusarium spp. ronmental factors, such as temperature fluc- 11. Komada, H. 1975. Development of a selective
medium for quantitative isolation of Fusar-
were listed as a cause of wilt in Eryth- tuations, water stress, soil type, and inter- ium oxysporum from natural soil. Rev. Plant
roxylum in a report on major diseases of actions with other soil organisms, may Prot. Res. 8:114-124.
plants in Peru (8). In our study, F. oxy- influence the activity and survival of the 12. Lentz, P. L., Lipscomb, B. R., and Farr, D. F.
sporum was isolated from Erythroxylum pathogen or disease progress and severity. 1975. Fungi and diseases of Erythroxylum.
Phytologia 30:350-368.
plants showing severe wilt symptoms at a For example, wilt symptoms were more 13. Manulis, S., Kogan, N., Reuven, M., and Ben-
research station in Hawaii. The pathoge- pronounced in the field after a period of Yephet, Y. 1994. Use of the RAPD technique
nicity of the isolates of F. oxysporum to E. drought. Drought conditions were not ex- for identification ofFusarium oxysporum f.
coca and E. novogranatense was verified perienced under growth-chamber conditions.
sp. dianthi from carnation. Phytopathology 84:
in field and growth-chamber studies. Host- Molecular analyses and vegetative com- 98-101.
specificity studies did not reveal any path- patibility studies of the F. oxysporum f. sp. 14. Nash, S. M., and Snyder, W. C. 1962. Quan-
ogenicity outside the host genus, although erythroxyli strains indicated that the Ha- titative estimations by plate counts of propa-
gules of the bean root rotFusarium in field
the fungus could grow as a saprophyte on waiian and South American isolates were soils. Phytopathology 52:567-572.
many nonhost plants. Saprophytic survival closely related. The most apparent differ- 15. Nelson, P. E., Toussoun, T. A., and Marasas,
of these pathogens on nonhost plants is a ence between the Hawaiian strains and the W. F. O. 1983. Fusarium Species: An Illus-
well-documented phenomenon and contrib- South American strain was colony pigmen- trated Manual for Identification. Pennsylvania
State University Press, University Park, PA.
utes to the soil longevity of the pathogen tation on PDA. The vegetative compati- 16. Sambrook, J., Fritsch, E. F., and Maniatis, T.
(3). The pathogenicity and novel host range bility and genetic similarity of the Hawaiian 1989. Molecular Cloning: A Laboratory Man-
indicate that the pathogen is a distinct for- isolates and strain SA1 suggest that the ual. Cold Spring Harbor Laboratory Press, Cold
Spring Harbor, NY.
ma specialis of F. oxysporum, hereafter re- Hawaiian pathogens may have originated

504 Plant Disease / Vol. 81 No. 5 ANNEX 133

ERRATUM / Volume 81, Number 5, 1997

In the article “Characterization of a vascular wilt of Erythroxylum coca caused by Fusarium
oxysporum f. sp. erythroxyli forma specialis nova” by D. C. Sands, E. J. Ford, R. V. Miller,
B. K. Sally, M. K. McCarthy, T. W. Anderson, M. B. Weaver, C. T. Morgan, A. L. Pilgeram,
and L. C. Darlington, the affiliation for L. C. Darlington should be: Weed Science Laboratory,

USDA, ARS, Beltsville, MD 20705. ANNEX 134

United States Environmental Protection Agency,

GLYPHOSATE – Report of the
Hazard Identification Review Committee (20 Apr. 1998)ANNEX 134ANNEX 134ANNEX 134ANNEX 134ANNEX 134ANNEX 134ANNEX 134ANNEX 134ANNEX 134ANNEX 134 ANNEX 135

(DOCUMENT INTENTIONALLY OMITTED) ANNEX 136

United States Department of Agriculture, Agricultural Research Service,

Discovery and Development and Mechanism of Action of Biocontrol Agents for
Perennial and Annual Weeds (1 Oct. 1993 – 30 Sep. 1998)ANNEX 136ANNEX 136ANNEX 136ANNEX 136ANNEX 136ANNEX 136 ANNEX 137

United States Department of Agriculture, Agricultural Research Service,

Mechanisms of Microbial-Plant Interactions Related to Biocontrol of Weeds and
Narcotic Plants (1 Oct. 1993 – 30 Sep. 1998)ANNEX 137ANNEX 137ANNEX 137ANNEX 137ANNEX 137ANNEX 137ANNEX 137 ANNEX 138

Ron Collins, Agronomist, Weed Science Laboratory,
Agricultural Research Service, United States Department of Agriculture,
Glyphosate Aerial Application to Control Erythroxylum sp. In Colombia: Spray

Droplet Evaluation, Draft (23 Dec. 1998)ANNEX 138ANNEX 138ANNEX 138ANNEX 138 ANNEX 139

United States Department of Agriculture, Agricultural Research Service,

Strategies for Controlling Narcotic Plant Production
(30 Sep. 1995 – 29 Sep. 2000)ANNEX 139ANNEX 139ANNEX 139ANNEX 139ANNEX 139ANNEX 139ANNEX 139 ANNEX 140

United States Department of Agriculture,
April 2001 Colombia Coca Eradication Verification Mission Trip Report
(13 June 2001)

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.

Document obtained bEcuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act. ANNEX 140

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act.ANNEX 140

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act. ANNEX 141

Ronald T. Collins & Charles S. Helling,

Surfactant-Enhanced Control of Two Erythroxylum Species by Glyphosate,
Weed Technology, Vol. 16 (2002) ANNEX 141

Weed Technology. 2002. Volume 16:851–859

Commentary

Surfactant-Enhanced Control of Two Erythroxylum Species by Glyphosate 1

RONALD T. COLLINS and CHARLES S. HELLING 2

Abstract: Glyphosate is the only herbicide used for controlling illicit coca (Erythroxylum coca and
E. novogranatense), a source of cocaine. Because commercially available formulations of glyphosate

were inconsistent in controlling coca, research was conducted in a large-scale aerial eradication
program, greenhouse (in Maryland) and field (Hawaii), to develop more effective control systems.
Sixteen surfactants (cationic, nonionic, or mixed) were tested with two commercial glyphosate her-
bicide formulations, in aqueous or oil-based carrier systems, for coca control. Ultimately, two gly-

phosate–surfactant systems (COC/OSI-U [a mixture of crop-oil concentrate, Agri-Dex威 and organo-
silicone, Silwet L-77威] and CAT/ANA [cationic surfactant/anionic surfactant, Optima威]) were found
that increased glyphosate phytotoxicity fourfold: 1.1 kg ae/ha of glyphosate ⫹ surfactant was equiv-
alent to 4.4 kg ae/ha glyphosate without added surfactant, for both species. In consequence, the

glyphosate mixture used in Colombia for coca eradication was modified with substantially improved
results.
Nomenclature: Glyphosate; coca, selected taxa of the genus Erythroxylum, especially E. coca var.
coca Lam, E. novogranatense var. novogranatense (Morris) Hieron, E. coca var. ipadu Plowman,

and E. novogranatense var. truxillense (Rusby) Plowman.
Additional index words: Adjuvants, coca control, herbicide carrier system, herbicide efficacy, nar-
cotic plants, surfactants.

Abbreviations: ANA, anionic surfactant; CAT, cationic surfactant; COC, crop-oil concentrate; ECC,
E. coca var. coca; ECI, E. coca var. ipadu; ENN, E. novogranatense var. novogranatense; ENT, E.
novogranatense var. truxillense; Gly, glyphosate (isopropylamine salt); MSO, methylated seed oil;
NIS, nonionic surfactant; OSI, organosilicone surfactant; VO, vegetable oil.

INTRODUCTION production: E. coca var. ipadu (ECI), E. novogranatense
var. novogranatense (ENN), and E. novogranatense var.
Illicit drug use was estimated to cost the U.S. society
$143 billion in 1998, and the projected loss for 2000 truxillense (ENT). Their taxonomy (Plowman 1979) and
leaf surface morphology (McWhorter and Ouzts 1994)
was over $160 billion (ONDCP 2001). Cocaine remains have been documented. In more recent years, progress
a major substance of abuse. One facet of U.S. and in- has been achieved in describing coca alkaloid (Johnson
ternational strategy to solve this immense problem is to
break the supply source. The U.S. supply-reduction ef- and Emche 1994) and flavonoid (Johnson et al. 1997,
1998) composition, the latter offering potential for che-
forts place major emphasis on eliminating illegal culti- motaxonomic identification of individual taxa.
vation of the coca plant and processing of its leaves to
extract cocaine. Coca is produced almost entirely in three Andean
Erythroxylum coca var. coca (ECC) is the primary countries, Peru, Bolivia, and Colombia. The net area
(i.e., adjusted for eradication) under illicit coca produc-
coca species used for production of cocaine (Plowman tion estimated in 2000 was 184,900 ha; 136,200 ha of
1979). But three other taxa besides ECC produce cocaine
in sufficient quantities to be considered for commercial this was in Colombia, which since 1997 supplanted Peru
as the leading coca producer (Anonymous 2002). Envi-
1 ronmentally sound eradication of coca is indispensable
Received for publication October 4, 2001, and in revised ffor successful cocaine supply reduction; as a goal, this
202Agronomist and Soil Scientist, Alternate Crops and Systems Laboratory,
Agricultural Research Service, United States Department of Agriculture,ked with alternative cropping or other devel-
BARC-W, 10300 Baltimore Avenue, Beltsville, MD 20705. Corresponding plans, but the barriers to successful voluntary
author’s E-mail: [email protected]. crop substitution (especially in Colombia) remain for-

851ANNEX 141

COLLINS AND HELLING: CONTROL OF TWO ERYTHROXYLUM SPECIES BY GLYPHOSATE

midable. Approximately 84,250 ha of the Colombian In 1993, ARS assisted the U.S. Department of State
coca was sprayed (with glyphosate) in 2001, in efforts and Government of Panama in testing Gly/CAT on illicit

to reduce the coca leaf and cocaine supply (Anonymous coca discovered in Panama (Helling 1993). This was the
2002). first large-scale aerial testing or eradication ever done
Although herbicides are a logical tool for suppressing with Gly/CAT against coca. Gly/CAT at 4.5 kg/ha gave
coca and other illicit narcotic crops, there are other ap- acceptable control (90 to 95% 3 mo after application) in

proaches that, in theory, can be used. Manual eradication fields that had not received rainfall within an estimated
of coca has been done, as in Peru, but it is extremely 8 to 12 h after application, but treatments failed where
labor-intensive, is not always effective, and exposes the rainfall occurred earlier. It was determined that the plants
worker to substantial risk in areas where growers oppose were ENN (Helling 1993), which by greenhouse (R. T.

eradication. Biocontrol of coca received intensive re- Collins, personal communication; Ferreira et al. 1997)
search focus from the Agricultural Research Service and field (C. G. McWhorter, personal communication)
(ARS) and collaborators throughout the 1990s. Although studies proved easier to control by glyphosate than did
disclosure was originally restricted because of security the ECC plants. A recent study (Ferreira and Reddy
concerns, recent publications now describe the use of a 14
2000) confirms that [ C]glyphosate is absorbed and
selective, naturally occurring soil pathogen to induce translocated faster and more completely in ENN than in
coca wilt (Bailey et al. 1997, 1998; Hebbar et al. 1998; ECC, at least for mature plants.
Sands et al. 1997). Mycoherbicides remain unimple- Largely because of the Panama test results, the Gov-
mented as tools for coca eradication, pending additional
ernment of Colombia began using Gly/CAT in 1994 for
testing and host government approval. their coca eradication program. Since 1996, most of our
A narcotics research program has existed within ARS, foliar-applied herbicide research focused on improving
United States Department of Agriculture (USDA), main- glyphosate performance.
ly at Beltsville, MD, since 1972. From the late 1980s
Assuming that product delivery to target is not an is-
until ca. 1994, by ARS policy, research on narcotic crop sue, still at least four potential problems confront suc-
eradication was considered especially sensitive; the ex- cessful coca control by Gly/CAT application: species
tensive research on herbicide efficacy was generally pub- sensitivity differences, rainfall, plant pruning, and defo-
lished only in internal technical reports. Accordingly,
most background research is necessarily cited as person- liation. Field observations of Gly/CAT (applied in water
at 65 and 94 L/ha, respectively) in Panama (Helling
al communications. 1993) and Hawaii (R. W. Bovey, unpublished data) con-
This report focuses only on glyphosate. As a nonse- firmed that rainfall after application was an important
lective herbicide, glyphosate’s worldwide uses have in-
cluded many noncropland and forestry applications. For factor limiting glyphosate’s effectiveness. Furthermore,
growers of illicit coca have used at least two techniques
this reason, and because of its minimal environmental to reduce the herbicide effect, i.e., hand-defoliation or
impact, including on humans (Williams et al. 2000), gly- pruning (to ca. 10- to 15-cm height) of treated plants
phosate represented a logical candidate for possible coca
control. shortly after application (C. S. Helling, personal com-
munication).
In 1985, ARS examined methods to control coca in a The logical approach, to solve the problems of Gly/
small-scale field study in Colombia, South America CAT application on coca, was to develop an adjuvant
(Anonymous 1990); Gly/CAT (glyphosate/cationic sur-
factant, Roundup Original ) , at rates of 2.2 and 4.5 kg system that increased the speed of glyphosate penetration
ae/ha, was ineffective in these early experiments. In and uptake. As an example, surfactant CAT-I (Frigate ) 威
at 0.5% (v/v) greatly accelerated uptake, translocation,
1987, Gly/CAT was reevaluated for coca control in Peru, and distribution of [ C]glyphosate isopropylamine salt
but again it was found to be ineffective (Anonymous
1990). In 1989, a renewed, aggressive program was be- by several grassy species and improved their control (Ku
gun by ARS, USDA to evaluate foliar-applied herbicides et al. 1989). Surfactants have been widely studied to im-
prove Gly/CAT performance, but general predictions of
for control of coca. Ultimately, systems were found in effect by species, chemical, and other variables (Franz
which Gly/CAT proved effective in controlling coca (R.
W. Bovey, personal communication). et al. 1997) seem highly complicated. In general, tertiary
polyoxyethylene alkylamine surfactants are thought to
3 increase glyphosate efficacy by enhancing spray droplet
juvants are found in Table 1.nd sources of supply for herbiciretention on foliage (de Ruiter et al. 1990) and foliar

852 Volume 16, Issue 4 (October–December) 2002 ANNEX 141

WEED TECHNOLOGY

absorption (Gaskin and Holloway 1992; Sherrick et al. next phase (as with phases 1 and 2) were begun even
1986). A polyoxyethene (10) alkylamine surfactant was before complete results from the preceding testing were
thought to enhance hydration of the leaf cuticle, thereby available. Although this at times led to seemingly con-

facilitating transfer of polar glyphosate through the non- tradictory evidence, it did not alter the final results and
polar barrier (Coret and Chamel 1993). Similarly, a po- conclusions.
lyethoxyethylene tallow amine surfactant lessened the
negative impact of water stress on glyphosate efficacy Phase 1: Initial Surfactant Selection. The initial sur-
factant evaluation was conducted in a greenhouse at the
by increasing herbicide absorption but could not over- USDA Beltsville Agricultural Research Center in 1995.
come the reduced translocation caused by this stress (de
Ruiter and Meinen 1998). In some cases, additional non- Two-year-old coca plants (grown from seed), ca. 76 cm
ionic surfactant (NIS) added to a commercial glyphosate tall, were used. Most coca leaves were 6 mo old at the
time of treatment, but the plants had never been pruned
product actually reduced the absorption of the herbicide
in four test weed species (Norsworthy et al. 2001). or deleafed. The plants were grown in 15-cm-diam pots,
This paper reports the results of experiments con- in a greenhouse potting mixture (loam soil ⫹ Pro-Mix 威4
[1:1 by wt], pH 艐 5.5). No supplemental lighting was
ducted in three phases, designed first to evaluate a large used; maximum light was ca. 900 ␮mol/m 2/s (summer
number of adjuvants in greenhouse studies and then to 2
select the most promising systems for detailed green- [shading used]) and 600 ␮mol/m /s (winter). Tempera-
house and field research. Given the limited resources, as ture ranges were from 41 to 21 C (summer) and from
32 to 18 C (winter).
wide a variety of adjuvant types as possible was studied, Two commercial formulations of glyphosate were
but which certainly included CAT-M (the surfactant used
in the original commercial glyphosate, MON 0818) and used in the experiment: Gly/CAT and Gly/N. Both Gly/
other alkylamine-type products. CAT and Gly/N were applied at 0.6 kg ae/ha. Gly/CAT
(without additional surfactant) was included in the ex-
To be considered successful, the surfactant–glyphosate
system needed to meet the following criteria: (1) it must periment as a standard; it was applied in water only. The
be effective on both ECC and ENN, (2) it must work Gly/N tank mixture contained surfactant(s) with either
equally well on leaves of varying ages (within the ap- an aqueous (H 2O) or a nonaqueous (oil ) carrier. These
herbicide solutions were applied at 47 L/ha.
proximate range of 60 to 120 d), (3) it must provide
excellent control of coca under natural field conditions, Thirteen surfactants and two additives were evaluated
and (4) the surfactant system components must be read- in phase 1. Eight surfactants were used with the aqueous
system: CAT-M, COC-H1 (crop-oil concentrate, Agri-
ily commercially available. If the above criteria are met, Dex威), COC/OSI-U (AL-77: COC-H1 ⫹ organosilicone
the research will have resulted in the successful devel-
opment of a glyphosate herbicide system to control illicit surfactant [OSI, Silwet L-77威]), MSO (methylated seed
coca. As described subsequently, these criteria were met. oil), MSO/OSI-H1 (Dyne-Amic威), NIS-L (X-77威), NIS-
M (Sterox NJ威), and OSI; two additives, vinegar and
sucrose (as a postherbicide treatment), were also includ-
MATERIALS AND METHODS
ed. Five surfactants were used with the nonaqueous sys-
In phase 1, a representative selection of commercially tem: COC-B (JLB Oil Plus威), COC-H2 (Penetrator威),
available surfactants was evaluated to determine their ef- NIS-B1 (Cide-Kick II威), NIS-B2 (Improved Cide-Kick

fect on Gly/N (Rodeo ) activity against ECC. In phase II威), and VO-B (vegetable oil, Improved JLB Oil Plus威).
2, the best surfactants from phase 1 were evaluated at The surfactant or vinegar concentration was always 0.5%
four surfactant concentrations and two glyphosate rates. (v/v). The concentration of sucrose (sugar) was 70 g/L.
Several surfactants, not available during phase 1, also The sugar–water solution was applied at a rate of 187

were added to phase 2 testing. For phase 3, the best L/ha 15 min after the glyphosate application.
surfactants from phase 2 were applied with 1.1, 2.2, and To ensure a stable and uniform mixture of glyphosate
4.4 kg ae/ha Gly/N in field experiments in Hawaii. phase in the nonaqueous carrier system, special steps were tak-
en: (1) emulsifier #1 (1% [v/v]) was added to Gly/N and
3 testing included both ECC and ENN coca species.
There was an urgent requirement for rapid feedback thoroughly blended; (2) emulsifier #2 (1% [v/v]) was
from these greenhouse and small–field-plot experiments
because initial monitoring of the ongoing Colombia 4Pro-Mix BX威, a mixture of sphagnum peat moss (75 to 85%, v/v), perlite,
vermiculite, dolomitic and calcitic limestone, macro- and micronutrients, and
eradication program had shown lower than the desired a wetting agent; Premier Horticulture, 326 Main Street, Red Hill, PA 18076.
coca control. To achieve speed, the first replicates of the 5Orchex 692威,aC21paraffinic oil.

Volume 16, Issue 4 (October–December) 2002 853ANNEX 141

COLLINS AND HELLING: CONTROL OF TWO ERYTHROXYLUM SPECIES BY GLYPHOSATE

added to a C-21 paraffinic oil and blended; (3) finally, rainfall at the site is ca. 2,500 mm; mean air temperature

these two solutions were mixed together to form a stable is 20.5 C. Both soil and meteorological conditions at the
emulsion. field research site resemble those encountered in typical
The herbicide treatments were made in an automated locations where illicit coca is grown (Helling 1997).
spray chamber. 6The herbicide solution was applied with In phase 3, the most effective (in increasing coca con-
7
a TeeJet 8001E flat-fan nozzle at 276 kPa. The speed trol by glyphosate) cationic and noncationic adjuvants
of the spray head assembly during application was 6.4 from phase 2, plus surfactants in nonaqueous carriers
km/h. from phase 1, were evaluated for coca control in systems
Treated plants were visually rated for growth, as a with 1.1 kg ae glyphosate/ha. The most efficacious of

percentage of untreated plants, 6 mo after application. A these were further evaluated at glyphosate rates of 2.2
dead plant was evaluated as 0% growth of control; a and 4.4 kg ae/ha. In all field testing, the surfactant con-
healthy plant with no symptoms of herbicide effect was centration was 2% (v/v). Both ECC and ENN coca were
evaluated as 100% growth of control. The percent con- used in phase 3. The plants, 2 yr old (ca. 120 cm tall)

trol was then calculated by subtracting percent growth at application, had been pruned to ca. 75-cm height 90
from 100%. This procedure was used for phases 1, 2, d before glyphosate treatment. For the first full experi-
and 3 testing, except that phase 3 field ratings were taken ment, coca was grown in 1-m rows, with 46-cm inter-
4 mo after treatment. plant spacing; crop density was 21,740 plants/ha. In the

Phase 1 used a completely randomized design. Each repeat experiment, density was increased to 44,445
treatment was replicated three times, one plant per rep- plants/ha by reducing row spacing to 0.75 m and plant
lication. Each experiment was repeated. The data were spacing to 30 cm.
analyzed by the SAS Proc Mix program (SAS 1997), Carrier volume was 47 L/ha, applied to the plants with

with the replicated experiments included as a variable in a two-nozzle hand-held boom. Other conditions of spray-
the random statement. The experiments were not signif- ing were nozzle type, TJ80005; nozzle separation, 51
icantly different (␣ was set at the 5% level), so results cm; nozzle height, 46 cm above mean plant height; pres-
were pooled in the data presentations. This pooling was sure, 276 kPa; and boom speed, 4.8 km/h. To protect
the case for all three phases. nontarget plants, a plastic shield (1.5 m high, 1.1 m

Phase 2: Evaluation of Selected Surfactants. Phase 2 wide, and 1.2 to 1.8 m long) was placed around the
target plants at the time of herbicide application.
consisted of two greenhouse experiments, one dealing Each treatment in phase 3 was replicated three times;
exclusively with cationic surfactants and the other with each replication consisted of five plants. Each experi-
noncationic surfactants. It was conducted at Beltsville,
MD, in 1995, using 2-yr-old ECC plants (ca. 70 cm tall). ment was repeated but with the changes described above
(there were two experiments). Statistical analysis was as
Most leaves were 5 to 6 mo old. Other growing condi- previously described for phases 1 and 2.
tions were as described for phase 1.
Gly/N was applied at 0.6 kg ae/ha for both cationic
and noncationic experiments. The three cationic surfac- RESULTS AND DISCUSSION

tants were CAT/anionic surfactant (ANA) (Optima ), Phase I: Initial Surfactant Selection. In phase 1, con-
CAT-I, and CAT-M. The noncationic surfactants were trol was significantly different among the glyphosate–
COC/OSI-U, MSO/OSI-H2 (Aero Dyne-Amic 威), and adjuvant systems evaluated. The results of the experi-
NIS-L. Concentrations of surfactants evaluated were 0.5,
ment and the statistical relationships among treatments
1.0, 2.0, and 4.0% (v/v). are listed in Table 2. Five treatments were statistically
Each treatment in phase 2 was replicated three times, similar to that with the highest percent control, NIS-L.
and each experiment, twice. A treatment replication con- These six most effective treatments were NIS-L (84%),
sisted of one plant. Statistical analysis was as in phase 1.
COC/OSI-U (75%), NIS-B1 (70%), COC-B (65%), no
Phase 3: Field Evaluation of Surfactants. During 1996 surfactant or oil carrier (64%), and NIS-B2 (62%). The
to 1997, phase 3 was conducted in Hawaii, on Halii coca control for each of the remaining 11 treatments was
statistically different from the treatment with the highest
sandy clay loam, a Typic Gibbshumox soil. Mean annual
6 control. The use of glyphosate emulsified in oil was ex-
Model #RC-5000-100EP; Mandel Scientific Co., 2 Admiral Placetremely effective in controlling ECC: four of the six best
O7TeeJet 8001E and TJ 80005 nozzle tips; Spraying Systems Co., P.O. Box (NIS-B1, COC-B, no surfactant, and NIS-B2)
7900, Wheaton, IL 60189-7900. used an oil carrier.

854 Volume 16, Issue 4 (October–December) 2002 ANNEX 141

WEED TECHNOLOGY

Louis, MO 6316phis, TN 3811FL 32961-6006emDrive, Parsippany, NJ 07054-449280632-1289559ris)o599TX 77252-2180s77nding Road, P.O.

Helena Chemical CHelena Chemical HelenaHelena Chemical Co.oveland Industries, Inc., P.O. Box 1289, Greeley,

polye-
alkyl po- ⫹ polyol alkyl po- nonyl-
⫹ ⫹ ⫹
] polyalkylene-⫹ free fatty acids
18 sorbitan ester-meth⫹lated soy-
8C ⫹ ⫹ ⫹

organic acids methylated soybean oil -limonene emulsifiers Brewer International
⫹ D-limonene emulsifiers Brewer⫹International, P.O. Box 6D06, Vero Beach,
⫹ polyethoxylated derivatives ⫹
ethoxylated tallo⫹ amines Monsanto Co.
terpene hydrocarbon
⫹ nony⫹phenol polyethyleneglycol
⫹ Silwet L-77 (1:1) —

ethoxylated alcohols Vista Chemical Co. (now Sasol Chemical Indus-
ethoxylated tallow amines Monsanto Co., 800 North Lindbergh Boulevard, St12
⫹ isopropanol
lyoxyethylene glycolbasedftyuliderebeanoxilyox-Limo,neneglycolsylsilox10eglycol ether
Gly Gly, w/o sPolyMixture oPetrHeavy-rLight-range parEthoxylated alkyl phosphate estersAmerican Cyanamid Co. (now BASF), One Campus.., One American Lane, Greenwich, CT 2180, Houston,

威 威

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威 威 威 1012–51012–3 C Ethoxylated alcohol Vista Chemical Co.
威 威 威 威
威 威 威

Name

Common name Trade name Composition Source

Herbicide–adjuvant systems: their coding, nomenclature, and sources of supply.

GlyGly/Gly/N ANCATAT/CAT-ICACOCCOC-BOC-H1COC-H2OroMSO/OSMSO/OSININIS-B1ated —eed oNo—nionic surfactantsro Dy—Cide-Kick IIrfSteSroetJL—77ved JLB —il Plus2 —‘AL-77’’
Table 1.CodeHerbicides Adjuvants, generic and commercial Adjuvants, custom mixtures (this study)

Volume 16, Issue 4 (October–December) 2002 855ANNEX 141

COLLINS AND HELLING: CONTROL OF TWO ERYTHROXYLUM SPECIES BY GLYPHOSATE

Table 2. Glyphosate control of Erythroxylum coca var. coca as influenced byble 3. Control of Erythroxylum coca var. coca by Gly/N at 0.6 kg ae/ha

surfactants (0.5% v/v) and formulation: phase 1 evaluation of surfactant sys-ueous carrier, as influenced by surfactant concentration: phase 2 evalu-
tems. Treatments are ranked in decreasing order of efficacy, at the 0.6-kg ae/ of selected surfactants.
ha glyphosate rate.
Formulation Surfactant Concentration Control
Glyphosate
formulation Treatment Control % v/v %
Cationic CAT-I 0.5 57
%
c CAT-I 1 60
Gly/N NIS-L 84 a CAT-I 2 75
Gly/N c COC/OSI-U 75 ab CAT-I 4 70
Gly/N d NIS-B1 70 abc CAT-M 0.5 65
Gly/N d COC-B 65 abc CAT-M 1 57
Gly/N d None 64 abc CAT-M 2 62
d
Gly/N d NIS-B2 62 abc CAT-M 4 80
Gly/N VO 60 bc CAT/ANA 0.5 57
Gly/N d COC-H2 58 bc CAT/ANA 1 53
Gly/CAT Vinegar 55 bc CAT/ANA 2 70
Gly/N c MSO 54 bc CAT/ANA 4 55
Gly/N c COC-H1 51 bc
c Noncationic
Gly/N c MSO/OSI-H1 49 cd MSO/OSI-H2 0.5 55
Gly/CAT None 48 cd
Gly/N c OSI 47 cd MSO/OSI-H2 1 76
Gly/N c CAT-M 33 d MSO/OSI-H2 2 72
Gly/CAT c Sucrosee 31 d MSO/OSI-H2 4 60
Gly/N c NIS-M 29 d COC/OSI-U 0.5 54
COC/OSI-U 1 67
COC/OSI-U 2 53
a Surfactant concentration was 0.5% v/v.
b Means within a column not followed by the same letter are significantly COC/OSI-U 4 56
NIS-L 0.5 76
different (P ⫽ 0.05). NIS-L 1 88
c Carrier is water. NIS-L 2 79
d Carrier is oil. NIS-L 4 74

e Sucrose solution (70 g/L) was sprayed onto plants 15 min after glyphosate
treatment.

(51% control) is combined with OSI (47% control), the
Sucrose and vinegar are not normally considered as new adjuvant mixture COC/OSI-U is formed; glyphosate

additives. But reports from Colombia stated that (1) vin- in this tertiary COC/OSI-U system gave superior coca

egar increased the activity of glyphosate in controlling control (75%) to that obtained from the corresponding
binary systems. The higher OSI concentration in MSO/
coca, and (2) coca growers were applying sugar water
to coca plants shortly after glyphosate application to ne- OSI-H2 is similar to that in COC/OSI-U. One goal of

gate its activity (C. S. Helling, personal communication). the phase 2 research was therefore to determine if in-
creased organosilicone content enhances coca injury and
The phase 1 experiment showed that coca control by
Gly/CAT was not significantly increased with (55%) vs. death.

without (48%), vinegar (Table 2). Second, spraying sug- 8
Phase 2: Evaluation of Selected Surfactants . Cationic
ar water onto plants treated 15 min earlier with gly- surfactants. Two additional cationic surfactants (CAT-I
phosate did not significantly decrease Gly/CAT control
and CAT/ANA) were included in phase 2; they had been
of coca: unsprayed (48%) vs. sprayed (31%). The spray
unavailable for research in phase 1. Percent control as
volume dose of the sugar water, although four times that
of glyphosate, was insufficient to cause runoff. affected by surfactant (P ⬎ 0.09), surfactant rate (P ⬎
0.07), or the interaction between surfactant and surfac-
As a result of phase 1, three surfactants used with
tant rate (P ⬎ 0.39) was not significantly different
aqueous carriers were further evaluated in phase 2: NIS-
L, COC/OSI-U, and CAT-M. CAT-M was included (al- among treatments. Concentration-pooled efficacy ratings
for the three cationic surfactants were CAT-I (61%),
though not among the six best surfactants) because it is
CAT-M (58%), and CAT/ANA (53%) (Table 3). The
used in Gly/CAT at ca. 7 to 8 wt% (Franz et al. 1997).
The MSO/OSI-H1–glyphosate system was not included overall control efficacies for the four surfactant rates—
0.05, 1, 2, and 4% v/v—were 54, 52, 61, and 62%, re-
in the phase 2 test as a result of its poor control of coca.
spectively.
Surfactant MSO/OSI-H2 was added to phase 2 instead.
All three cationic surfactants were selected for further
OSI by itself did not increase the percent control of
ECC; when added to a surfactant that increases penetra- 8
Because of limited plant resources, further evaluation of glyphosate in an
tion, there was a synergistic effect. Thus, when COC-H1 oil carrier was deferred until phase 3 field testing.

856 Volume 16, Issue 4 (October–December) 2002 ANNEX 141

WEED TECHNOLOGY

Table 4. Control of Erythroxylum coca var. coca (ECC) and E. novograna-
tense var. novogranatense (ENN) by glyphosate at 1.1 kg ae/ha, as influencedrom that with the highest coca control, COC/OSI-
by surfactant–carrier combinations: phase 3 Hawaii field evaluation.U (91%).
b
Control The percent control means for the surfactant-by-spe-
Surfactant Carrier ECC/ENN ECC ENN cies interaction are listed in the individual ECC and ENN

% columns (Table 4). COC/OSI-U, CAT/ANA, and CAT-
M control were not significantly different between spe-
COC/OSI-U Water 91 a 98 a 84 ab
CAT/ANA Water 90 ab 98 a 81 abc cies. COC/OSO-U and CAT/ANA were further evaluated
NIS-L Water 84 abc 67 bc 100 a in the 2.2- or 4.4-kg/ha experiment. CAT-M was dropped
CAT-M Water 82 abc 85 ab 78 abc for two reasons: (1) it controlled less ECC, and (2) it is
MSO/OSI-H2 Water 80 abcd 91 ab 69 bc
Gly/N c Water 76 abcd 88 ab 65 bc not commercially available. Treatments NIS-L, MSO/
Gly/CAT Water 71 bcde 52 c 89 a OSI-H2, Gly/N, Gly/CAT, and COC-H1 gave inconsis-
COC-H1 Water 67 de 33 c 100 a
CAT-d Water 54 ef 33 c 76 abc tent control (Table 4) depending on the species. NIS-L
None Oil 47 f 85 ab 8d and Gly/CAT were further evaluated in the 2.2- and 4.4-
NIS-B1 Oil 45 f 56 c 33 c
COC-H2 Oil 45 f 58 c 32 c kg/ha experiments. NIS-L was selected to include an
NIS; Gly/CAT was included because it was the com-
aSurfactant concentration was 2% v/v.
bMeans within a column not followed by the same letter are significantlyl glyphosate formulation. Of the remaining treat-
different (P ⫽ 0.05). ments shown in Table 4, only NIS-B1 was used; it was
cGly/CAT treatment contained no additional surfactant besides those in the
original formulation. included as a representative of treatments with oil car-
d riers.
Gly/N was used without surfactants.
The results from the 2.2- and 4.4-kg/ha glyphosate
experiments showed that coca control was different for

evaluation in phase 3 field testing. Although surfactant herbicide rates (P ⬎ 0.001) and for surfactants (P ⬎
concentration was not a significant (P ⱕ 0.05) overall 0.0001) but not for species (P ⬎ 0.07). Percent control

factor that affected coca control by glyphosate, within of ENN and ECC coca, pooled for surfactant and her-
individual surfactant tests there were differences be- bicide rate, was 96 and 93%, respectively. The glypho-

tween rates. The lowest rate (based on all tested surfac- sate rate giving the best control was 4.4 kg/ha (97%),
tants) common to all three cationic surfactants was 2%. whereas the 2.2-kg/ha rate controlled 92%, averaged

over all systems. COC/OSI-U (100%), CAT/ANA
Noncationic surfactants. The percent coca control for the (96%), and NIS-L (96%) were not different from each
noncationic surfactant–glyphosate systems (Table 3) was
other; CAT/ANA, NIS/L, Gly/CAT w/o surfactant
significantly different (P ⬎ 0.001) among treatments. (90%), and NIS-B1 (91%) were not different from each
NIS-L (79%) gave better control than both MSO/OSI-
H2 (66%) and COC/OSI-U (58%). Neither surfactant other (Table 5, surfactant percent control column).
Control was not different for the species by surfactants
rate (P ⬎ 0.09) nor the interaction between surfactants interaction (P ⬎ 0.35), but it was different for the inter-
and surfactant rates (P ⬎ 0.95) was significantly differ-
action between species and herbicide rate (P ⬎ 0.0001).
ent for percent control. All three noncationic surfactants There was no difference between the ENN–2.2 kg/ha
were selected for field evaluation. The noncationic sur-
(96%), ENN–4.4 kg/ha (95%), and ECC–4.4 kg/ha
factants were subsequently applied in phase 3 at the (99%) treatments; ECC–2.2 kg/ha (87%) control was
same rate as were the cationic surfactants, 2% v/v.
significantly lower than that of the other treatments. The
interaction between surfactant and herbicide rate was dif-
Phase 3: Field Evaluation of Selected Surfactants.
The results of the 1.1 kg/ha glyphosate evaluations are ferent (P ⬎ 0.03; Table 5). The two interactions with
different percent control were NIS-B1 (87%) and Gly/
listed in Table 4. Control was not different for species
(ECC ⫽ 70% and ENN ⫽ 68%). Surfactant (P ⬎ CAT (with no additional surfactant) (83%).
0.0001) and surfactant-by-species interactions (P ⬎ The percent control for the interaction between sur-

0.0001) were different. factant, herbicide rate, and species was different (P ⬎
The overall mean coca control for the 12 glyphosate– 0.02). Of the 20 possible interactions (data in the last

adjuvant systems tested in phase 3 is listed in Table 4 in four columns of Table 5), only four had lower control:
the ECC/ENN column. Five treatments (CAT/ANA ECC–2.2 kg/ha–Gly/CAT, ECC–2.2 kg/ha–NIS-B1,

[90%], NIS-L [84%], CAT-M [82%], MSO/OSI-H2 ENN–2.2 kg/ha–Gly/CAT, and ENN–4.4 kg/ha–NIS-B1.
[80%], and Gly/N w/o surfactant [76%]) were not dif- All the remaining treatments gave excellent control (93

Volume 16, Issue 4 (October–December) 2002 857ANNEX 141

COLLINS AND HELLING: CONTROL OF TWO ERYTHROXYLUM SPECIES BY GLYPHOSATE

Table 5. Control of Erythroxylum coca var. coca (ECC) and E. novogranatense var. novogranatense (ENN) by glyphosate at 2.2 and 4.4 kg ae/ha, as influenced
by surfactant–carrier combinations and herbicide rate: phase 3 Hawaii field evaluation.
b
Control at 2.2 or 4.4 kg ae glyphosate/ha
Coca species

Surfactants, independent of coca species ECC ENN
Surfactant All rates 2.2 4.4 2.2 4.4 2.2 4.4

%
COC/OSI-U 100 a 99 a 100 a 99 a 99 a 100 a 100 a
CAT/ANA 96 ab 95 ab 97 a 91 ab 100 a 99 a 93 a
NIS-L 96 ab 95 ab 97 a 93 a 98 a 97 a 97 a
None c 90 b 83 b 97 a 77 b 94 a 90 b 99 a
NIS-B1d 91 b 87 b 94 ab 77 b 100 a 97 a 88 b

a
Surfactant concentration was 2% v/v.
bMeans within a column not followed by the same letter are significantly different (P ⫽ 0.05).
cHerbicide used was Gly/CAT; all other treatments used Gly/N.
dCarrier is oil; all others are water.

to 100%) of ECC and ENN. Just as with the percent ed surfactants, COC/OSI-U and CAT/ANA were supe-

control data pooled for surfactants, and with the inter- rior. These adjuvants, or their equivalent, are now rec-
action between surfactant and herbicide rates, Gly/CAT ommended as additives to glyphosate for coca eradica-

and NIS-B1 systems had the poorest control. Poor con- tion in Colombia or elsewhere.
trol was consistent with findings from the three-way in- The greenhouse experiments were useful for predict-
teractions mentioned above. ing which herbicide–adjuvant treatments would fail.

Testing of glyphosate–adjuvant applied in an oil car- Only the field research demonstrated conclusively those
rier was conducted in phases 1 and 3 in comparison with that would work. Field-grown coca responded rather dif-

water-as-carrier systems. Glyphosate in water proved ferently from those plants grown in the greenhouse.
more efficacious. Three examples can be cited. Whereas NIS-L was the

In the three experimental phases, no single surfactant best noncationic surfactant in greenhouse studies on
was superior to all the others. Selection of a preferred ECC, in the field it did not control ECC as well. COS/

system was therefore based on consideration of various OSI-U ⫹ glyphosate was only marginally effective in
factors related to the adjuvants tested. Gly/CAT (w/o ad- the greenhouse but gave exceptional control in the field.
ditional surfactant) and NIS-B1 were eliminated because Glyphosate with CAT-I controlled ECC in a similar way

coca control in phase 3 experiments, at 2.2 and 4.4 kg/ as did glyphosate with the other two cationic surfactants
ha glyphosate, proved unsatisfactory. The elimination of in the greenhouse. But in the field, CAT-I provided poor-

Gly/CAT was very important because, at the time our er control than did the other surfactants. Whether asso-
research began, this was the only commercial formula- ciated with environmental variables or plant character-

tion of glyphosate available and apparently suitable for istics, the variability in testing results were a reminder
coca eradication. Gly/CAT was, in fact, the product ini- that the most accurate way to predict surfactant perfor-

tially used against coca in Colombia. mance is to incorporate field evaluations in the research
The remaining three field-tested surfactants (COC/ scheme.
OSI-U, CAT/ANA, and NIS-L) gave better control than In this research the best glyphosate–surfactant systems

did the commercial glyphosate formulation. Because a for ECC and ENN control were COC/OSI-U and CAT/
desirable glyphosate–surfactant system must be equally ANA. The chemistry of these two surfactants is so dif-

effective against both ECC and ENN species, these three ferent that it appears impossible to predict which surfac-
systems (at both 2.2- and 4.4-kg/ha rates) fulfilled this tant properties are necessary for improving glyphosate

criterion. But in the 1.1-kg/ha experiment, only surfac- control of both ECC and ENN. It seems likely, however,
tants COC/OSI-U and CAT/ANA controlled both ECC that systems that (1) increase glyphosate penetration

and ENN. Considering herbicidal performance at the through the epicuticular wax of coca leaves, and then (2)
suboptimal rate (1.1 kg/ha) is relevant because in the facilitate subsequent translocation will optimize the her-
actual spray application of glyphosate relatively high bicide’s performance. McWhorter and Ouzts (1994)

above coca fields, coca within the spray swath may not found that water droplets containing 0.1% OSI Silwet L-
receive the full target dose. Consequently, of all the test- 77 did spread better on coca leaves than did water with

858 Volume 16, Issue 4 (October–December) 2002 ANNEX 141

WEED TECHNOLOGY

a COC (Agri-Dex) or NIS-M adjuvant. But enhanced J. Connick Jr., and D. J. Daigle. 1998. Formulations of Fusarium oxys-
porum f. sp. erythroxyli for biocontrol of Erythroxylum coca var. coca.
spray droplet distribution was certainly not the major Weed Sci. 46:682–689.
discriminating factor for the glyphosate–adjuvant sys- Coret, J. M. and A. R. Chamel. 1993. Influence of some nonionic surfactants
on water sorption by isolated tomato fruit cuticles in relation to cuticular
tems in our study. If this characteristic was important, penetration of glyphosate. Pestic. Sci. 38:27–32.
then oil carrier systems should have surpassed water- de Ruiter, H. and E. Meinen. 1998. Influence of water stress and surfactant
on the efficacy, absorption, and translocation of glyphosate. Weed Sci.
based mixtures because spread coefficients on coca 46:289–296.
leaves were much higher for nearly all nonaqueous car- de Ruiter, H., A.J.M. Uffing, E. Meinen, and A. Prins. 1990. Influence of
surfactants and plant species on the retention of spray solutions. Weed
riers (McWhorter and Ouzts 1994).
Sci. 38:567–572.
In the evolving process of optimizing herbicide per- Ferreira, J.F.S. and K. N. Reddy. 2000. Absorption and translocation of gly-
formance through spray system modification, it is im- phosate in Erythroxylum coca and E. novogranatense. Weed Sci. 48:193–
199.
portant to recognize that adjuvants may function differ- Ferreira, J.F.S., R. J. Smeda, and S. O. Duke. 1997. Control of coca plants
ently with newer or modified commercial formulations (Erythroxylum coca and E. novogranatense) with glyphosate. Weed Sci.
45:551–556.
of the herbicide. Nevertheless, in the series of experi- Franz, J. E., M. K. Mao, and J. A. Sikorski. 1997. Glyphosate: A Unique
ments described herein, we have shown substantial im- Global Herbicide. ACS Monograph 189. Washington, DC: American
Chemical Society. 653 p.
provement in coca control by the addition of selected Gaskin, R. E. and P. J. Holloway. 1992. Some physicochemical factors influencing
foliar uptake enhancement of glyphosate-mono(isopropylammonium) by po-
surfactants to a commercial glyphosate formulation. lyoxyethylene surfactants. Pestic. Sci. 34:195–206.
The technological improvements developed through
Hebbar, K. P., R. D. Lumsden, J. A. Lewis, S. M. Poch, and B. A. Bailey.
this research were integrated in the Colombia coca erad- 1998. Formulation of mycoherbicidal strains of Fusarium oxysporum.
ication program. We recommended adding a Colombia- Weed Sci. 46:501–507.
Helling, C. S. 1993. Coca Eradication in Panama: Final Technical Rep. Belts-
manufactured agricultural adjuvant with properties sim- ville, MD: U.S. Department of Agriculture, Agricultural Research Ser-
ilar to one of the most effective surfactants tested in this vice. 42 p.
Helling, C. S. 1997. Environmental fate of herbicides in Hawaii, Peru and
research. Largely, as a result of the modified spray tank Panama. In Environmental Behavior of Crop Protection Chemicals, STI/
mixture, the mean swath control of coca increased from PUB/1003. Vienna: International Atomic Energy Agency. pp. 389–406.
Johnson, E. L. and S. D. Emche. 1994. Variation of alkaloid content in Ery-
ca. 70% in 1997 to ca. 90% or higher thereafter. throxylum coca leaves from leaf bud to leaf drop. Ann. Bot. 73:645–
650.
Johnson, E. L., W. L. Schmidt, and H. A. Norman. 1997. Leaf flavonoids as

ACKNOWLEDGMENTS chemotaxonomic markers for two Erythroxylum taxa. Z. Naturforsch.
52c:577–585.
This research could not have been completed without Johnson, E. L., W. L. Schmidt, and H. A. Norman. 1998. Flavonoids as mark-
ers for Erythroxylum taxa: E. coca var. ipadu and E. novogranatense var.
the assistance of Rembert Shaw in phases 1 and 2, and truxillense. Biochem. Syst. Ecol. 26:743–759.
John Iwan in phase 3. We also acknowledge the method Ku, H. S., G. J. Misich, L. E. Limpel, and D. C. Findak. 1989. Enhancement
of glyphosate activity by a fatty amine ethoxylate adjuvant: a physiolog-
suggested by Dr. Chester G. McWhorter (ARS, USDA, ical investigation..N.P. Chow, C. A. Grant, and A. M. Hinshalwood,
eds. Adjuvants and Agrochemicals. Vol. I. Mode of Action and Physi-
retired) for preparing glyphosate formulations in non- ological Activity. Boca Raton, FL: CRC Press. pp. 167–174.
aqueous carrier systems. Mention of commercial or pro- McWhorter, C. G. and C. Ouzts. 1994. Leaf surface morphology of Erythrox-
ylum sp. and droplet spread. Weed Sci. 42:18–26.
prietary products is for the reader’s convenience and Norsworthy, J. K., N. R. Burgos, and L. R. Oliver. 2001. Differences in weed
does not constitute endorsement by the ARS, USDA tolerance to glyphosate involve different mechanism. Weed Technol. 15:
725–731.
over other suitable products.
[ONDCP] Office of National Drug Control Policy. 2001. The Economic Costs
of Drug Abuse in the United States, 1992–1998. Publ. No. NCJ-190636.
Washington, DC: Executive Office of the President. 104 p.
LITERATURE CITED Plowman, T. 1979. The identity of Amazonian and Trujillo coca. Bot. Mus.
Leafl. 27:45–68.
Anonymous. 1990. U.S. Department of State, Bureau of International Nar- Sands, D. C., E. J. Ford, R. V. Miller, B. K. Sally, M. McCarthy, T. W.
cotics Matters. Environmental Assessment of the Use of Herbicides to Anderson, M. B. Weaver, C. T. Morgan, and L. C. Darlington. 1997.
Eradicate Illicit Coca Overseas (Revised). September 7, 1990. Washing- Characterization of a vascular wilt of Erythroxylum coca caused by Fu-
ton, DC: U.S. Department of State, International Narcotics Matters. sarium oxysporum f. sp. erythroxyli forma specialis nova. Plant Dis. 81:
134 p. 501–504.
Anonymous. 2002. U.S. Department of State, Bureau of International Nar- [SAS] Statistical Analysis Systems. 1997. SAS/STAT Software; Changes and
cotics Law Enforcement Affairs (INL). International Narcotics Control Enhancements Through Release 6.12. Cary, NC: Statistical Analysis Sys-
Strategy Report: March 2002. Washington, DC: U.S. Department of tems Institute. pp. 571–702.
State, International Narcotics Law Enforcement Affairs: Web page: httSherrick, S. L., H. A. Holt, and F. D. Hess. 1986. Effects of adjuvants and
//www.state.gov/g/inl/rls/nrcrpt/2001. Accessed: March 6, 2002. environment during plant development on glyphosate absorption and
Bailey, B. A., K. P. Hebbar, M. Strem, L. C. Darlington, and R. D. Lumsden.
translocation in field bindweed (Convolvulus arvensis). Weed Sci. 34:
1997. An alginate prill formulation of Fusarium oxysporum Schlechtend: 811–816.
Fr. f. sp. erythroxyli for biocontrol of Erythroxylum coca var. coca.Williams, G. M., R. Kroes, and I. C. Munroe. 2000. Safety evaluation and
control Sci. Technol. 7:423–435. risk assessment of the herbicide Roundup and its active ingredient, gly-
Bailey, B. A., K. P. Hebbar, M. Strem, R. D. Lumsden, L. C. Darlington, W. phosate, for humans. Regul. Toxicol. Pharmacol. 31:117–165.

Volume 16, Issue 4 (October–December) 2002 859 ANNEX 142

United States Environmental Protection Agency,

GLYPHOSATE – 2nd Report of the
Hazard Identification Assessment Review Committee (22 Jan. 2002)ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142ANNEX 142 ANNEX 143

United States Environmental Protection Agency,
Office of Prevention, Pesticides and Toxic Substances, Report on Issues Related
to the Aerial Eradication of Illicit Coca in Colombia, Response from EPA

Assistant Administrator Johnson to Secretary of State (19 Aug. 2002) ANNEX 143

1

Response from EPA Assistant Administrator Johnson to Secretary of State, August 19,

2002

Report on Issues Related to the Aerial Eradication of Illicit Coca in Colombia

September 2002

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

-

-

-

U.S. Environmental Protection Agency Office of Pesticide Programs Details of the Consultation for Department of State Use
of Pesticide for Coca Eradication Program in Colombia, August 2002

Table of ContentsANNEX 143

2

-

-

EXECUTIVE SUMMARY

CONSULTATION REVIEW OF THE USE OF PESTICIDE FOR COCA ERADICATION IN COLOMBIA

BACKGROUND

FINDINGS

--

--

-

per se ANNEX 143

3

- -

-

-

SECTION 1. Description of Glyphosate Use in the U.S. for Comparison to Use in Colombia for Coca Eradication

INTRODUCTION:

SUMMARY:
-

-

- -

- -

-
-

-

- -

-

USE OF GLYPHOSATE IN THE UNITED STATES

-

- - - - - ANNEX 143

4

- -

-

AGRICULTURAL SITES:
-

- -

-
-

-

-

NON-AGRICULTURAL USES INCLUDING FORESTRY:

- -

-

-

- -

-

- - -
-

- - -

- - - ANNEX 143

5

PROPERTIES OF GLY - PHOSATE:

-

-

- -

-

FORMULATIONS OF GLYPHOSATE:

-

GLYPHOSATE USED WITH SURFACTANT FOR FOLIAR ABSORPTION:

-
-
- -

-

REFERENCES:

-

-

-

-ANNEX 143

6

- -

-

REFERENCES:

-

-

SECTION 2. Human Health Risk Assessment for the Use of Glyphosate Herbicide as Part of the Aerial Eradication Program of

Coca in Colombia, S.A.

I INTRODUCTION

- ANNEX 143

7

II EXECUTIVE SUMMARY

USE PATTERN

-

HAZARD ASSESSMENT

Cosmo-Flux 411F

- (information not included as it may be entitled to confidential treatment)
(information not included as it may be entitled to confidential treatment)

Glyphosate

- - -
-

in utero -

- - -
- -

EXPOSURE

- -

dietary exposure

Handler (e.g., individuals mixing the concentrated formulated product to prepare the tank mix and loading the tank mix in

the aircraft) exposure - - - -

- post-application exposures

- -

- - -

--

- ANNEX 143

8

spray drift

incident reports

-

glyphosate formulated product
glyphosate technical

formulated
formulated

-

- -

eye exposure

III BACKGROUND

- ANNEX 143

9

In finalizing the current document, FEAD and HED
consulted with OPP's Information Resources and Services Division/Public Information and Records Integrity Branch

regarding CBI. It was determined that the document did contain some CBI and therefore, some sections have been
adapted

-

in u-tero

-

- -
-

-

-

-

-ANNEX 143

10

IV HISTORICAL REGULATORY INFORMATION

-

- -

V HAZARD IDENTIFICATION

Glyphosate

- - - -

in utero -
-

Components of the Glyphosate Product

1. Polyoxyethylene alkylamine (POEA)
et al.

et al.

et al.

2. (information not included as it may be entitled to confidential treatment)
(information not included as it may
be entitled to confidential treatment) (study citation not included as it may be entitled to confidential

treatment) (information not included as it may be entitled to confidential treatment)
(information not included as it may be entitled to confidential treatment)
- (information not included as it may be entitled to confidential treatment)

(information not included as it
may be entitled to confidential treatment) (study citation not included as it may be entitled to
confidential treatment) (information not included as it may be entitled to confidential treatment)

(study citation not included as it may be entitled to

confidential treatment) (information not included as it may be entitled to confidential treatment)
(study citation not included as it may be entitled to confidential treatment)

Cosmo - Flux 411F Adjuvant)

-
- ANNEX 143

11

-
- (information not included as it may be entitled

to confidential treatment) (information not included as it may be entitled to
confidential treatment)

Components of Cosmflux

1. (information not included as it may be entitled to confidential treatment) (information not included as it may be entitled to
confidential treatment)

2. (information not included as it may be entitled to confidential treatment) -

(information not included as it may be entitled to confidential treatment)
(information not included as it may be entitled to confidential treatment)

(information not
included as it may be entitled to confidential treatment)

VI DOSE RESPONSE ASSESSMENT

-

Glyphosate

March 26, 1998 and, again, on November 20 2001
-
- -

-
- -
- -

Table 1. Glyphosate Endpoint Selection Table

-ANNEX 143

31

-
-

-

III Ecological Risk Assessment

Glyphosate

Terrestrial

- ANNEX 143

32

-

Aquatic

- -

Daphnia magna

-- -
- -

-
-

- -

Selenastrum capricornatum) Lemna gibba)

Navicula pelliculosa

Risk Specific to Formulations of Glyphosate

-

-
- ANNEX 144

United States Department of State,
Bureau for International Narcotics and Law Enforcement Affairs,

Report on Issues Related to the Aerial Eradication of Illicit Coca in Colombia:
Chemicals Used in the Aerial Eradication of Illicit Coca in Colombia and
Conditions of Application (Sep. 2002) ANNEX 144

1

Chemicals Used for the Aerial Eradication of Illicit Coca in Colombia and Conditions of
Application

Report on Issues Related to the Aerial Eradication of Illicit Coca in Colombia

September 2002

-
- -

-

--

Commercial glyphosate formulation:

-

Surfactant:

-ANNEX 144

2

-

-

-

-

-

-

-

Cosmo -Flux 411F:

-

- - -
-
- -

-

-
- -

- -

-

-

-
-

-

Spray mixing and handling: ANNEX 144

3

-

-

Storage and disposal of spray mixture:

-
-

-

Aircraft and spray equipment:

- -

- -
- -
-

-

-
-

--

Spray pilots:

-

Reconnaissance:

-

-

Spray parameters:

-ANNEX 144

4

-

Spraying and human and environmental health:

-

-

-

- -

Eradication oversight:

-
-

- ANNEX 145

(DOCUMENT INTENTIONALLY OMITTED) ANNEX 146

United States Environmental Protection Agency, Office of Pesticide Programs,

Details of the 2003 Consultation for the Department of State: Use of Pesticide
for Coca and Poppy Eradication Program in Colombia (June 2003) ANNEX 146

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF PESTICIDE PROGRAMS

DETAILS OF THE 2003 CONSULTATION
FOR THE DEPARTMENT OF STATE

USE OF PESTICIDE FOR COCA AND POPPY

ERADICATION PROGRAM IN COLOMBIA

JUNE 2003ANNEX 146

-1-

I. PESTICIDE USE ASSESSMENT

A. Introduction

The Biological and Economic Analysis Division (BEAD) in the Office of Pesticide Programs
within the Environmental Protection Agency (EPA) has augmented the 2002 EPA assessment

and description of the use of glyphosate in the United States (1) as a basis for comparison to
glyphosate use in Colombia for coca eradication with a discussion of changes in the program for
2003. This request has come from the Department of State (DoS) which is required to consult

with the EPA before reporting to Congress on the use of glyphosate for the Andean counter drug
initiative. This year DoS is required to include glyphosate for control of opium poppy in its
consultation. This document compares the described use on opium poppy and coca to use
within the US.

B. Summary

The use of glyphosate for control of opium poppy is conducted at 1 lb ai/acre (0.8 lb a.e/acre)
and at a spray mixture (product + water diluent + Cosmoflux 411F surfactant) volume of about
5.5 gallons per acre (50 liters/hectare). This application rate is within the label recommendations

for the amount of concentrated formulation per acre and the amount of total spray volume per
acre for application for glyphosate products registered for use in the US.

C. Background

Glyphosate is the most widely used herbicide in the US (1). It is non-selective in action and is
used where total vegetation control is desired. It is used on a variety of sites including

agricultural crops, lawns, gardens, forests and utility grounds. Application is made to the target
plant’s foliage, and after being absorbed, glyphosate circulates within the plant, exerting
herbicidal activity systemically. Glyphosate and its use within the US were described in the

2002 EPA assessment. In its assessment report, EPA described the use of glyphosate in the US
in the following paragraph:

“Glyphosate may be used on over 400 crop and non-crop sites. The largest agricultural use sites include
soybeans, cotton and field corn. In addition to agricultural use, EPA estimates that 16-22 million pounds of
the technical grade active ingredient were applied to non-agricultural sites in 1999 (this is the most recent
year for which adequate data are available). This estimate includes both home owner and professional

applications as well as use on forested lands. Based on EPA data for 1999, an estimated 1-2 million pounds
of glyphosate was applied to forest acres, with more than 650,000 forest acres treated.”

In 2002, a description of glyphosate use in forestry sites in the US was included since use for
coca eradication would be most similar to the US labeled use for broad-spectrum post-emergence

weed control for forestry site preparation and utility rights-of-way. For coca eradication,
glyphosate is sprayed from fixed wing aircraft at speeds around 165 mph at 4.4 pounds active
ingredient (isopropylamine salt) per acre in about two gallons of spray mixture per acre. ANNEX 146

-2-

Aerial application of the glyphosate product to non-crop, non-timber, industrial and rights-of-
way areas in the US is allowed using fixed wing aircraft and helicopter to control annual and

perennial weeds and woody brush and trees. Although application may be made at up to 10 lb
ai/year per acre in the US, the typical use rate per application is much lower, averaging less than
one pound per acre on major agricultural sites (EPA has no data on average application rate to

forest sites). In addition, product labeling recommends application at 3 to 15 gallons of total
spray mixture volume per acre for aerial application to forestry sites.

D. Opium Poppy Eradication

Glyphosate used for the opium poppy eradication program is also applied aerially, however its

use differs in several ways from the coca eradication program:

1. Total area sprayed is much smaller for poppy eradication. The State Department explains
that:

“Because Colombia cultivates much less opium poppy than coca and spray resources are limited, aircraft
spray much more coca than poppy, therefore expending more spray chemicals in coca growing areas than in
areas where opium poppy is cultivated. For example, in 2002, eradication aircraft sprayed totals of 122,700
hectares of coca [about 303,000 acres] and 3,000 hectares [about 7400 acres] of opium poppy.”

2. Individual poppy spray sites are smaller and located at higher elevations. The State
Department states:

“While difficult to quantify precisely, opium poppy fields generally range from 0.5 to 5 hectares. Opium
poppy is ordinarily cultivated at a higher altitude than coca, and thus opium poppy often is cultivated and
sprayed in hilly to mountainous terrain.”

3. The rate (or dose) of glyphosate for poppy eradication is lower than that for coca eradication.

The State Department states:

“Because the opium poppy is not a woody, hard-to-control species like the coca bush, opium poppy
eradication uses a spray mixture with a substantially lower glyphosate content than the spray mixture used
for coca eradication.”

The Department of State described the concentrate formulation for use in 2003 as containing 41
percent glyphosate salt and 59 percent inert ingredients. The same concentrate formulation is

being used for both coca and opium poppy eradication (1). Other similar products with this
proportion of active to inert ingredients are registered with the US Environmental Protection
Agency for use in the US on forestry and utility rights-of-way sites. A surfactant is added to the
diluted spray mixture prior to spraying. This practice improves absorption of the herbicide by

the plant and is standard practice for applying glyphosate to forestry sites in the US.

For opium poppy spraying, water, formulated glyphosate, and surfactant are combined in a spray

mixture in the following percentages: 94 percent water, 5 percent glyphosate formulation, and 1
percent surfactant. This diluted spray mixture is applied to opium poppy at the rate of 50.0ANNEX 146

-13-

battery of assays. Based on the lack of evidence for carcinogenicity in two acceptable studies in

mice and rats, glyphosate is classified as a “Group E” chemical (no evidence of carcinogenicity
to humans).

Components of the Glyphosate Product

1. Polyoxyethylene alkylamine (POEA). POEA is a compound that is used as a surfactant
with many glyphosate formulations. In a safety evaluation and risk assessment of glyphosate,

the Roundup formulation and the surfactant POEA, Williams et al. (2000) reported that POEA
can cause severe skin irritation and be corrosive to the eyes. In subchronic oral studies, POEA
was mainly a gastrointestinal irritant in rats at high doses (~ 100 mg/kg/day) and in dogs at lower
doses (30 mg/kg/day). In a developmental toxicity study in rats, POEA did not cause any

developmental effects up to 300 mg/kg/day, but did induce maternal toxicity at 100 and 300
mg/kg/day (Farmer et al., 2000). The concentrated formulated Roundup product can also be
strongly irritating to the eyes and slightly irritating to the skin (Williams et al., 2000).

2. (information not included as it may be entitled to confidential treatment). (information not
included as it may be entitled to confidential treatment) are substances that are not highly toxic
by oral or dermal routes and are not irritating to the skin. They may cause mild, transient eye

irritation. Many (information not included as it may be entitled to confidential treatment) are
known not to be sensitizers (information not included as it may be entitled to confidential
treatment). The molecular weight of a (information not included as it may be entitled to
confidential treatment) determines its biological properties, and, thus, its toxicity. The lower

molecular weight (information not included as it may be entitled to confidential treatment) tend
to be more toxic than the higher-weighted (information not included as it may be entitled to
confidential treatment) and are absorbed by the digestive tract and excreted in the urine and
feces, while the higher molecular weight (information not included as it may be entitled to

confidential treatment) are absorbed more slowly or not at all (information not included as it
may be entitled to confidential treatment). (information not included as it may be entitled to
confidential treatment) have low acute and chronic toxicity in animal studies. No significant

adverse effects have been noted in inhalation toxicology studies, carcinogen testing, or mutagen
assays. High oral doses have resulted in toxic effects to the kidneys and loose feces (information
not included as it may be entitled to confidential treatment). Topical dermal application of
(information not included as it may be entitled to confidential treatment) to burn patients with

injured skin has resulted in toxicity. (information not included as it may be entitled to
confidential treatment).

Cosmo - Flux 411F (Adjuvant)

The Cosmo-Flux 411F adjuvant product used in the glyphosate tank mix is produced by a
Colombian company and is not sold in the U.S. The Agency is not in possession of toxicity data

from direct dosing of test animals with Cosmo-Flux 411F. However, the Agency has made
safety findings based on the toxicity of the individual components. As stated above, sale or use
of spray adjuvant products in the U.S. are generally not regulated by EPA. However, the DoS ANNEX 146

-14-

has provided the EPA with a copy of this product’s label and a description of the product

ingredients. To be able to provide an opinion on hazard characterization of the Cosmoflux
ingredients, the EPA relied on available technical information from various sources. Cosmo-
Flux 411F consists mainly of (information not included as it may be entitled to confidential

treatment) with a nonionic surfactant blend primarily composed of (information not included as
it may be entitled to confidential treatment). All ingredients of this product are substances that
are not highly toxic by oral or dermal routes. They may cause mild eye and skin irritation. All
components of the adjuvant have been approved for use in/on food by EPA (40 CFR 180.1001.

Components of CosmoFlux (Considered as CBI)

1. (information not included as it may be entitled to confidential treatment). The (information

not included as it may be entitled to confidential treatment) can cause dermal and ocular
irritation and, in high doses orally, can cause significant toxicity. However, small amounts are
not a concern and these substances have been approved as food additives by the FDA and are

exempt from tolerances by EPA on certain commodities.

2. (information not included as it may be entitled to confidential treatment). The other major
component of Cosmo-Flux 411F, (information not included as it may be entitled to confidential

treatment), is not considered highly toxic. It may cause mild eye and skin irritation. The
corresponding monoester, (information not included as it may be entitled to confidential
treatment), has low subacute, subchronic and chronic oral toxicity and is used as a direct food
additive and a component in cosmetics. The higher molecular weight triester is less likely to be

absorbed orally or dermally and most likely of less toxicological concern. The other minor
components, are not known to be highly toxic compounds and would not be of toxicological
concern at the concentrations and conditions in which they are used.

E. Dose Response Assessment

Dose response analysis is the second step in the risk assessment process i.e.; characterization of

the quantitative relationship between exposure (dose) and response based on studies in which
adverse health effects have been observed. The objective is to identify endpoints of concern
which correspond to the route and duration of exposure based on the exposure patterns.

HED selects doses and endpoints (effects of concern) for risk assessment via an internal peer
review process. HED uses a standing Committee - the Hazard Identification Assessment Review
Committee (HIARC), to consider the available hazard data (studies required to be submitted by
registrants in 40 CFR part 158 and open peer reviewed literature) to identify endpoints for use in

risk assessment.

Ideally, each safety study identifies a dose level that does not produce a biological or statistically

significant increased incidence of an adverse effect or no observable adverse effect level
(NOAEL). The threshold dose is the smallest dose required to produce a detectable effect.
Below this dose, there is no detectable response.ANNEX 146

-34-

III. ECOLOGICAL RISK ASSESSMENT

A. Introduction

At the request of the Department of State (DoS), the Office of Pesticide Programs (OPP) of the U.S.
Environmental Protection Agency (EPA) provides here an ecological risk assessment for the aerial coca
and poppy eradication programs in Colombia. The Environmental Fate and Effects Division (EFED)
performed a risk assessment for coca eradication in response to a similar request by DoS in 2002. That

assessment concluded that the active ingredient glyphosate itself would likely pose little risk to non-target
terrestrial and aquatic animals, but that non-target terrestrial plants would likely be damaged some
distance from the intended spray area due to spray drift of glyphosate.

The proposed use of glyphosate on coca will be little changed from that described in 2002, with the
exception of the use of a different glyphosate product in 2003. This will reduce the potential for eye
irritation, and therefore may provide some benefit to people and terrestrial animals exposed to the spray.

Other aspects of the proposed use remain the same, including the use of adjuvant CosmoFlux 411F.
Therefore, as detailed below, the expected risks and uncertainties in EPA’s environmental risk assessment
remain essentially the same as described the previous year.

The request for a risk assessment for the use of glyphosate to control poppy production is new for 2003.
However, as described below, the expected risks and uncertainties corresponding to this use are nearly
identical to those for the coca use. The application rate of glyphosate is less for poppies than for coca, and
therefore the risk to terrestrial animals is expected to be low. The potential for glyphosate runoff may be

much greater for poppies, since the sprayed fields can be located on mountainsides. However, as detailed
in the 2002 assessment for coca eradication, the concentration of active ingredient glyphosate that might
be derived even from direct application to a small pond should not result in significant risk to non-target
aquatic animals or plants. Therefore, runoff from the poppy or coca sprays would not be expected to pose

a significant risk to non-target aquatic organisms.

The primary risk that might be associated with the poppy eradication program is that from spray drift to

non-target terrestrial plants. As with coca applications, application to poppy fields will require application
at speeds and application heights greater than might be desirable for drift control, due to the safety
precautions needed for eradication sprays down a potentially forested mountainside. The added factor of
steep slopes make it likely that spray drift from the lower rate poppy sprays could extend a greater

distance than that from the coca eradication sprays which are understood to occur on more level terrain.

B. Ecological Risk Characterization

The following risk characterization for the coca eradication use is adapted from the 2002 ecological risk
assessment for the use of glyphosate herbicide as part of the U.S. supported aerial eradication program of
coca in Colombia:

The use of a glyphosate spray for coca and poppy eradication is unlikely to cause adverse effects to ANNEX 146

-35-

terrestrial or aquatic animals but is likely to pose a substantial risk to nearby non-target plants. Vegetative

vigor toxicity laboratory tests performed using a formulated glyphosate product (glyphosate acid WP
48.3%) on North American crops indicated toxicity to terrestrial plants with applications of less than 1.0
lb of the isopropylamine salt of glyphosate per acre, which corresponds to 0.75 lb acid equivalents (a.e.)

per acre. The coca use rate is 1.11 gallons glyphosate/acre (3.34 lb acid equivalents/acre) for direct, aerial
application to coca. A second application is possible if fields are replanted, or the first is determined after

3 to 6 months to have been inadequate. Because poppies are reportedly more sensitive to glyphosate, a
lower application rate of 0.27 gallon/acre (0.8 lb a.e./acre) is used in spraying for poppy eradication. The
DoS reports that the spray mixture for poppy eradication would include 5% formulated glyphosate, 1%

Cosmo-Flux 411F, and 95% water (as opposed to 44%, 1% and 55%, respectively for the coca spray). The
product claimed by the DoS to be used ib Colombia is widely used in the US on a variety of agricultural
commodities and non-agricultural sites.

EPA used the AgDRIFT model to estimate potential spray drift. The model suggests that non-target plants

hundreds of feet away may be exposed to a fraction of glyphosate applied to coca or poppy fields. Some
of the important application parameters for estimating spray drift levels from coca and poppy eradication
application are shown in Table 1.

Table 1. Important application parameters for defining off-target spray drift levels in coca and poppy
eradication.

Application parameter Coca spraying Poppy spraying Effect on off-target exposure

Application rate 3.34 lb a.e./acre 0.8 lb a.e./acre Lower application rates result in lower off-
target exposure

Flight speed during 200 mph 135-145 mph Lower flight speeds result in less secondary

application droplet break up, larger droplets, less drift,
and lower off-target exposure

Estimate wind speed 0-10 mph 0-4 mph Lower wind speeds results in less movement
range of spray droplets off-target (i.e. lower drift)

Estimated droplet size 300-1500 mm 300-1000 mm Larger droplets are less prone to be blown
range off-target

Estimated release <100 feet 30 -120 feet Lower release heights result in shorter fall
heights times for droplets and less opportunity to
be blown off-target

Boom width not available 70% of wingspan Narrow boom widths result in fewer droplet
being caught in wing tip vortices and lower

drift levels

Slope not available not available Drift can be carried farther when winds are
blowing down steeper slopesANNEX 146

-36-

Figure 1.

Downwind Herbicide Deposition
Varying Droplet Size and Wind Speed

1.1
1.0
extremely coarse-very coarse spray, 3 mph wind
0.9
medium spray, 3 mph wind
0.8
0.7
extremely coarse-very coarse spray,
0.6 10 mph wind adverse effect

0.5 level for 50% of
0.4 young plants:
medium spray, 10 mph wind poppy spraying
0.3
0.2 coca spraying
(fracionpoofitiopnlication rate)
0.1

0.0
0 200 400 600 800 1000

Downwind distance (ft)

Figure 1 shows the lowest levels of drift are associated with applications using the extremely coarse to

very coarse sprays at a 3 mph wind speed. The highest levels of drift are associated medium sprays at
wind speeds of 10 mph. Downwind deposition levels from coca and poppy spraying is likely to be
bounded by these estimates. The “effect level for 50% of young plants” is based of glyphosate toxicity
studies on ten young crop plants. Older plants are generally less sensitive to herbicides than young,

rapidly growing plants. At the level corresponding to approximately 11% and 44% of the coca and poppy
application rates, respectively, 50% of plants species would be expected to show measurable reductions in
dry weight. With a 10 mph wind, plants would be expected to be exposed at this 50% affect level up to

200 feet downwind of poppy spraying and 550 feet downwind of coca spraying. Of the affected plants
some would likely recover while more sensitive plants may die, have reduced reproductive success, or
reduced yields (crop plants).

There is uncertainty whether crops or other plants in Colombia, whether similar to crops tested in the US
or not, would be affected similarly at the same exposure levels. However, since glyphosate is an effective,

broad spectrum herbicide, risk to non-target plants outside of the application zone would be expected. The
Agency’s Ecological Incidents Information Sytem (EIIS) database includes several hundred reports of
possible non-target plant incidents in the US attributed to use of glyphosate.

The use of the active ingredient glyphosate itself in poppy and coca eradication would not pose a
significant direct risk to terrestrial or aquatic animals, although secondary adverse effects from the loss of

habitat in the spray area are likely. Neither acute nor chronic adverse effects were observed in mammalian
and avian laboratory toxicity tests submitted to the EPA by US industry, using the active ingredient alone. ANNEX 146

-37-

Mortality was observed in fish and aquatic invertebrate studies. However, the resulting acute LC 50values
(concentrations at which half the test animals died), and lowest effect levels for chronic effects, were in
parts-per-million. Toxicity endpoints for aquatic plants also ranged from 0.85 to 39.9 ppm. Considerably

lower surface-water exposure, in the parts-per-billion, could be expected from the use on coca or poppy
using runoff simulations from Agency exposure models PRZM and EXAMS. The Agency considered an
even more conservative scenario, estimating the concentration that would result from the direct
application of 3.75 lb acid eq./acre of glyphosate to a 1-acre, 6-foot deep pond. The calculated maximum

concentration of 230 ppb is well below the toxicity values measured for aquatic organisms in the
laboratory.

It is possible that much greater exposure could occur from direct overspray of water bodies much smaller
than a 1-acre, 6-foot deep pond, but such simulation is not a standard component of Agency risk
assessments. The product label for glyphosate prohibits such direct overspray of water bodies, but it is
possible that some ecologically important water bodies too small or ephemeral to appear on maps could be

sprayed directly in a project as large as the coca eradication program.

Although the measured toxicity and estimated exposure indicate that only non-target terrestrial plants are

likely to be adversely affected by the use on coca and poppy, there are important uncertainties that should
be considered. One of these is the extrapolation of North American data to the conditions and wildlife
found in Colombia. The toxicity of a pesticide to different classes of animals and plants can vary widely
among species within an individual ecosystem. The Agency uses the test species as surrogates for other

North American species not tested, but has little experience with tropical flora and fauna. Similarly,
laboratory and field estimates of the environmental fate of pesticides, including potential surface-water
contamination, are performed with North American soils, hydrology and climate data. The uncertainty of
extrapolating North American exposure and effects data to this risk assessment would most effectively be

reduced by identification of characteristics which define sensitive tropical ecosystems.

An important uncertainty in this risk assessment concerns differences in the tank mix used in Colombia

from those used in the US. The Agency does not have ecological toxicity information on adjuvant Cosmo-
Flux 411F, which is neither manufactured nor sold in the US. However, all of the individual components
(surfactants) which comprise the adjuvant are substances with low oral and dermal mammalian toxicity.
The toxicity of the blend of these surfactants is not known; although the Agency often requires

formulation toxicity data for non-target plants and aquatic organisms, tank-mix adjuvants are not required
to be included in these studies. ANNEX 147

United States Department of Agriculture, Agricultural Research Service,

Pathogens of Narcotic Crops and Their Use in Biological Control Strategies to
Reduce Narcotics (1 Oct. 1998 – 30 Sep. 2003)ANNEX 147ANNEX 147ANNEX 147ANNEX 147ANNEX 147 ANNEX 148

United States Department of State, Bureau for International Narcotics and Law
Enforcement Affairs, Report on Issues Related to the Aerial Eradication of Illicit
Coca in Colombia: Updated Report on Chemicals Used in the Aerial Eradication

Program (Dec. 2003) ANNEX 148

1

Updated Report on Chemicals Used in the Colombian Aerial Eradication Program

Report on Issues Related to the Aerial Eradication of Illicit Coca in Colombia

December 2003

On September 4, 2002, the Department of State submitted to Congress the Secretary of State's determination and report to Congres s on issues related to the
eradication of illicit coca in Colombia in accordance with the FY 2002 Foreign Operations, Export Financing, and Related Programs Appropriations Act (P.L.
107-115). That document contained an explanation of the chemicals and methods used for the eradication of coca in Colombia and the safeguards in place to

minimize the risk of harm to human health and the environment. It also contained the results of the Department of State's consul tations with the United States
Environmental Protection Agency (EPA), including EPA's analysis of the risks to human health and the environment that might be posed by coca eradication.

The Government of Colombia and the Department of State have implemented several changes in the program to address concerns rais ed by the EPA
analysis. The first section of this document reviews the Department of State response to EPA's 2002 recommendation for addition al controls for the spray

program. Sections two and three explain the changes introduced by the Government of Colombia and the Department of State to respond to EPA and
Congressional concerns about other aspects of aerial eradication in Colombia. A fourth section describes the changes in chemica l composition and spraying
methods since the Department of State's 2002 report. The final section reviews the chemicals and methods used for opium poppy eradication in Colombia, a

part of the program that Congress did not ask the Department of State or EPA to address in FY 2002.

1. EPA Recommendation to Change Glyphosate Product Used by the Program

The EPA made one direct recommendation to the Department of State related to spray program controls in its "Office of Pesticide Programs Details of the

Consultation for Department of State: Use of Pesticide for Coca Eradication Program in Colombia." On page 12 of that document, EPA recommended that
" due to the acute eye irritation caused by the concentrated glyphosate formulated product and the lack of acute toxicity data on the tank mixture, the Agency

recommends that DoS consider using an alternative glyphosate product (with lower potential for acute toxicity) in future coca a nd/or poppy aerial eradication
programs." This was addressed to the possible risk of splashing the full-strength glyphosate into the eyes or onto the skin of p ersons filling the spray tanks on
the airplane. It was not directed at potential risk to persons exposed to the spray mixture as actually applied by the planes.

At the time that EPA made this recommendation, there were no suitable replacement glyphosate formulations registered for sale and use in Colombia that
offered lower potential for acute eye irritation. The Department of State worked with the program's glyphosate supplier to iden tify and to register for sale and

use in Colombia a formulation of glyphosate with reduced potential for eye irritation. As soon as that product could be register ed for sale and use in Colombia,
the Department of State began to purchase it for use in the spray program and it remains the formulation used today.

Like the previous formulation, the new formulation is also registered with the EPA for sale in the United States for non-agricultural use. It also contains 41
percent glyphosate salt and 59 percent inert ingredients. Like the previous formulation, the formulation now used is made from a base material (glyphosate

technical) that is produced by a manufacturing plant that is registered in the United States even though the formulation is produced and sold in Colombia. The
glyphosate formulation now used is mixed with water and surfactant in the same proportions as the previous formulation to form the coca spray mixture.

The difference between the formulations is that the current product has an overall category III toxicological rating ("mildly t oxic") on the scale used by the
EPA, whereas the previously used glyphosate formulation was rated category I ("highly toxic"). The toxicity reduction is due to a change in the surfactant

used in the glyphosate formulation. Of course, these ratings refer to the toxicological profile of the glyphosate formulationsin their point of sale, undiluted
form, and not the spray mixture (water, glyphosate formulation, and surfactant) that exits the spray aircraft.

The Department of State took these steps in part to address public concerns about the toxicity of the spray mixture and allegat ions that the combination of
glyphosate and surfactant would pose a threat to human and environmental health. In that regard, the Department of State also contracted with an

independent United States laboratory to determine the toxicity of the spray mixture (e.g., the glyphosate formulation with water and surfactant added), exactly
as it is mixed in the field. Because final drafts of those toxicology tests were not completed in time for EPA's assessment in2002, copies of the toxicology
tests on the spray mixture currently used for coca eradication are enclosed as Attachment A. These tests show that the spray mi xture rates a category III

("mildly toxic") for eye irritation and category IV, or "slightly toxic," in all other categories (e.g., acute oral, acute derm al, acute inhalation, skin irritation,
sensitization).

2. EPA Advice Regarding Tracking Reported Health Complaints

EPA's "Office of Pesticide Programs Details of the Consultation for Department of State: Use of Pesticide for Coca Eradication Program in Colombia" also
advised (on page 32) that: "(p)rospective tracking of reports of health complaints, documenting times of exposure and onset of symptoms, are recommended

during future spray operations to evaluate any potential health effects and ameliorate or prevent their occurrence." Although t his recommendation is not
related to spray program controls, the Department of State has increased its efforts to track reported health complaints and to investigate any possible
connection between any such complaints and the eradication of illicit crops.

The spray program tracks human health complaints in two ways. The first is to initiate an immediate investigation, often including clinical evaluation of the
patient(s), upon notice to the U.S. Embassy of a problem. The Embassy's Narcotics Affairs Section (NAS) learns about cases through letters directed to the

Embassy or GOC entities, from local counternarcotics base commanders, and from the members of the media. To investigate complai nts of toxic exposure
allegedly caused by spraying, NAS retains the services of two of Colombia's leading toxicologists, including the director of Colombia's national poison control

center, the Uribe Cualla Centro de Asesoramiento Toxicológico.ANNEX 148

2

Since submission to Congress of the FY2002 "Report on Issues Related to the Eradication of Illicit Coca in Colombia," two such complaints have been
reported to the U.S. Embassy. In September 2002, the Embassy received a complaint of multiple cases of poisoning from spraying of coca in Puerto Asís
(Putumayo department). A visit to the hospital and interviews with doctors there revealed no cases of poisoning or illness attr ibutable to spray chemicals. The

toxicologist learned of two hospitalized children who could have been the source of the complaint, and he reviewed their cases. One of those children was
suffering from poisoning by an organophosphate insecticide. The other child was suffering from asthma. An English language version of the toxicologist's
report from this investigation is enclosed as Attachment B.

In February 2003, a news report in the Bogotá daily "El Tiempo" attributed the spread of tuberculosis and cases of harelip and cleft palate in newborns to

aerial spraying of coca in Tibú (Norte de Santander department). A toxicological review showed cleft palate and harelip to be a genetically inherited defect
that has never been reported in humans as a result of exposure to any chemical substance. Tuberculosis is an infectious disease passed from person to
person, and is also unrelated to any potential exposure to spray chemicals.

The Government of Colombia and the U.S. Embassy Bogotá have also taken a proactive approach to investigating any human health c oncerns manifest in

areas where the spraying takes place. Both governments have collaborated to create a robust Medical Civic Action Program (Medcap) to search out cases of
harm to health allegedly caused by the spraying. During these public health interventions that are timed to take place in areaswhere coca eradication has
recently taken place, U.S. Embassy-contracted toxicologists talk to patients and talk to local medical personnel, looking for s pray-related cases. As outlined in

the chart below, a total of 1,029 patients made themselves available for Medcap medical personnel, had their medical conditions assessed, and received
complimentary health care. Although Medcap personnel have encountered cases that were claimed to be spray-related, reviews of t hese cases have
determined that events unrelated to eradication spraying had caused them. Through Medcap and other medical investigations, the U.S. Embassy has never

found an instance of spray-related harm to human health. This is an ongoing program and the next Medcap is planned for the end of April in Caquetá, a few
weeks into the spray campaign in that region.

Place and Date Patients

Assessed
Cartagena del Chairá 250

(Caquetá)
May 11, 2002

Solano (Caquetá) 120
August 7, 2002

Santa Ana (Putumayo) 260
September 21, 2002
Puerto Asís (Putumayo)250

November 9, 2002

San Vicente del Caguán149
(Caquetá)
February 1, 2003

To further address public and Congressional concerns about the possibility of human health and environmental harm potentially c aused by spraying, the

Department of State is working with the Government of Colombia and Garzon Ingenieros Asociados Ltda, an accredited Colombian laboratory, to analyze
water taken from areas where the spray program operates. Technology for monitoring soil is not available in Colombia, so the De partment of State is working

with the Government of Colombia and the U.S. Department of Agriculture Agricultural Research Service to analyze soil samples atthe USDA/ARS laboratory
at the University of Mississippi. The Department of State is paying for technicians from two Colombian government laboratories and the Ministry of the
Environment to travel to Mississippi in April to learn how to perform the analysis. The soil and water analyses will determine the degree of persistence of

glyphosate and its byproducts in Colombian soil and water, in the unlikely event there is something unique about Colombian soil and water that would
invalidate the many studies done on the residual effects of glyphosate in other parts of the world. The Department of State, th e Government of Colombia and
a private Colombian university (Universidad de Los Andes) are developing demonstration plots in the five distinct environmental regions of the country to

study glyphosate persistence and the regeneration of natural vegetation and other ecological dynamics following aerial eradicat ion of illicit crops.

3. EPA Comment Regarding Spray Drift

Although not addressed to the Department of State as a recommendation, EPA also noted in its consultation with the Department of State some concern for

spray drift and the potential for non-targeted, desirable vegetation to suffer from the spraying of nearby coca (or opium poppy ). Informed of EPA's and
Congressional concern, the Department of State and the Government of Colombia have incorporated several measures into the spray program to assist us

with evaluation and control of spray drift.

The first of these steps was to reinforce the environmental safety component of spray pilot training. All pilots, both fixed wi ng spray pilots and rotary wing

escort helicopter pilots, will receive briefings on the potential negative impact that spraying may have on the environment and techniques to minimize
potential collateral damage to legal crops and the environment. These briefings will be conducted semi-annually, will emphasize the unique aspects of the
Colombian operational theatre, and will solicit feedback from pilots on techniques to maximize application effectiveness and av oid damage to non-target

vegetation. An outline of this briefing is included as Attachment C. Search and rescue helicopter crews that accompany each spr ay flight have also been
directed to monitor drift patterns from above. They now assist in ensuring that spray does not drift beyond target crops and no tify the spray aircraft flight lead

when conditions might merit canceling a spray flight. A copy of the directive from the Department of State's Bureau of Internat ional Narcotics and Law
Enforcement Affairs (INL) Office of Aviation to the eradication contractor that formalizes these new spray regulations is inclu ded as Attachment D.

The Department of State's Assistant Secretary for INL also directed the team of United States Department of Agriculture (USDA) and Government of
Colombia scientists, responsible for the ground truth verification missions, to incorporate an analysis and quantification of overspray into ground truth
verification exercises. While past verification missions sought out and noted cases of overspray, documenting the existence and extent of any damage to ANNEX 148

3

crops or foliage not targeted for eradication, this is now a formal component of the ground truthing exercise. The most recent ground truth verification mission

(December 9-20, 2002) found that incidences of overspray were minor. The USDA Agricultural Research Service report from this ve rification exercise has not
yet been completed, and INL will forward a complete copy to EPA as soon as the Department of State receives the report.

4. Changes in Chemical Composition and Spraying Methods Since 2002 Report

Apart from changing to a more benign formulation of glyphosate spray mixture, as discussed earlier, there have been no changes t o any of the components
of the spray mixture. For some time in 2002, the Government of Colombia lowered the application rate of glyphosate for coca eradication from the traditional
application rate of 10.4 liters per hectare to 8.0 liters per hectare. After extensive ground truth evaluation, it was determine d that the lower rate was ineffective

for killing coca. Thus the application rate was returned to its former rate of 10.4 liters per hectare, which was the rate repo rted in the Department's Report on
Issues Related to the Eradication of Illicit Coca in Colombia in 2002 -- the rate that EPA evaluated when analyzing the potenti al for risks of adverse effects on
human health and the environment posed by the coca eradication program.

The only changes in the methodology used to spray coca since the time of the last report is the addition of a new type of sprayaircraft to the spray fleet. Four

Air Tractor Model 802 (AT-802) aircraft are currently being used to spray coca, and another four will be delivered this year. Th ese aircraft are manufactured in
the United States for agricultural crop spraying and utilize the identical nozzles (same brand and diameter) in the identical co nfiguration (nozzle angle, droplet
size, calibration methods) as the OV-10 and T-65 spray aircraft. AT-802 flight speed during eradication operations is 165 m.p.h .

5. Differences Between Opium Poppy Spraying and Coca Spraying

The Secretary of State was not required to determine and report to Congress on any aspects of the opium poppy eradication progr am in FY2002, and thus
the Department did not provide information to EPA on the chemicals and methodology of poppy spraying. Like the coca spray mixtu re described in the

"Report on Issues Related to the Eradication of Illicit Coca in Colombia," the opium poppy spray mixture contains three compone nts: water, an EPA-
registered formulation of the herbicide glyphosate, and a surfactant (Cosmo-Flux 411F). Because the opium poppy is not a woody, hard-to-control species
like the coca bush, opium poppy eradication uses a spray mixture with a substantially lower glyphosate content than the spray m ixture used for coca

eradication (see Attachment E). For opium poppy spraying, water, formulated glyphosate, and surfactant are combined into a spray mixture in the following
percentages: 94 percent water, 5 percent glyphosate formulation, and 1 percent Cosmo-Flux 411F. This diluted mixture is applied to opium poppy at the rate
of 50.0 liters/hectare (or 5.46 gallons per acre). This application rate is within the glyphosate manufacturer's label recommendations for both the amount of

concentrated formulation per acre and the amount of total spray volume per acre.

Opium poppy spraying differs from coca spraying in several ways. Because Colombia cultivates much less opium poppy than coca an d spray program
resources are limited, aircraft spray much more coca than opium poppy, therefore expending more spray chemicals in coca growing areas than in areas
where opium poppy is cultivated. For example, in 2002, eradication aircraft sprayed totals of 122,700 hectares of coca and 3,00 0 hectares of opium poppy.

Opium poppy is generally cultivated in plots that are smaller than the average coca field. While difficult to quantify precisel y, opium poppy fields generally
range from 0.5 to 5 hectares. Opium poppy is ordinarily cultivated at a higher altitude than coca, and thus opium poppy often i s cultivated and sprayed in hilly
to mountainous terrain. For these reasons, the T-65 is the only aircraft used to spray opium poppy because it has a smaller wingspan (and spray swath) than

the OV-10 or AT-802 and because it is a more agile aircraft capable of staying close to the ground in more steeply graded, rugg ed terrain.

Because of the challenges of mountain spraying, pilots undergo an extended training program before they are qualified to perfor m actual opium poppy spray
operations in Colombia. As the Department of State reported in 2002, coca eradication pilots must have approximately 3,000 total flight hours before they are
considered for the spray program and can receive preliminary training in illicit crop eradication. Most of these pilots also ha ve at least 1,500 hours of

commercial aerial application (crop dusting) experience. In addition to these requirements, opium poppy spray pilots must undergo 40 hours of follow-on
training specific to the topography, wind conditions, and cloud cover that they will experience in their area of operations.

Attachments

Toxicological testing results for coca spray mixture (Purity Analysis for Glyphosate, Acute Oral Toxicity Study, Acute Dermal T oxicity Study, Acute
Nose-Only Inhalation Toxicity Study, Primary Eye Irritation Study, Primary Skin Irritation Study, Dermal Sensitization Study).

"Investigative Report on Cases of Possible Human Health Effects in Puerto Asís," Jorge Hernán Botero Tobón, M.D. Bogotá, Colomb ia, September 19,
2002.

Outline of Spray Pilot Semi-Annual Briefing.

Memo from INL Office of Aviation Director of Operations to DynCorp Operations Manager re: Aerial Eradication Procedures, December 13, 2002.

Coca and Opium Poppy Spray Mixtures Comparison Graph. ANNEX 149

United States Environmental Protection Agency, Office of Pesticide Programs,
Letter and Consultation Report from Administrator Leavitt (17 Nov. 2004) ANNEX 149

Letter and Consultation Report from EPA Administrator Leavitt

Washington, DC
November 17, 2004

United States Environmental Protection Agency Washington, D.C. 20460

Nov. 17, 2004

The Honorable Colin L. Powell
Secretary
U.S. Department of State

Washington, D.C. 20520

Dear Secretary Powell:

I am pleased to inform you that the U.S. Environmental Protection Agency has completed its consultation review of the potentialhuman health and

environmental effects concerning the U.S.-supported aerial coca and poppy eradication program in Colombia.

In your letter of September 27, 2004, you asked the Agency to provide you with written confirmation that the Department of Stat e and EPA have consulted in

preparing a certification required by the Consolidated Appropriations Act, 2004. Specifically, you asked EPA to confirm: (1) that the Department of State and
EPA have consulted concerning the U.S.-supported aerial coca eradication program in Columbia; (2) that the herbicide mixture em ployed by the U.S.--

supported program of aerial eradication of coca and opium poppy in Colombia is being used in accordance with EPA label requirements for comparable use
in the United States and any additional controls recommended by the EPA for this program, as well as with the Colombian Environ mental Management Plan
for aerial fumigation; and (3) that this herbicide mixture, in the manner it is being used, does not pose unreasonable risks to or have adverse effects upon

humans or the environment.

EPA conducted its assessments based on information provided to us by the Department of State's Bureau of International Narcotic s and Law Enforcement

Affairs. As you know, INL has consulted with EPA's Office of Pesticide Programs, and as part of this effort, EPA has previously provided reviews of the
Department of State's eradication spray program activities in 2002 and 2003. EPA has compared coca and poppy eradication practices with the closest

approximate use in the United States, reviewed potential human health concerns, and evaluated toxicity testing conducted on thespray mixture that INL has
indicated is being applied in Colombia. In this consultation review, we have also reviewed progress of the Colombian government 's efforts to evaluate the
effects of the spray program on human health and the environment in areas where it has been used to eradicate illicit crops.

I have attached the consultation review document that we trust will assist you in preparing the certification that must be subm itted to Congress. Please let me
know if you have additional questions concerning our consultation review.

Sincerely,

Michael O. Leavitt

Enclosure

U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF PESTICIDE PROGRAMS
DETAILS OF THE 2004 CONSULTATION FOR THE DEPARTMENT OF STATE

USE OF A HERBICIDE FOR COCA AND POPPY ERADICATION PROGRAM IN COLOMBIA
OCTOBER 2004

EXECUTIVE SUMMARY

CONSULTATION REVIEW OF THE USE OF A HERBICIDE FOR COCA AND POPPY ERADICATION IN COLOMBIA, 2004

The Department of State (DoS) assists the Government of Colombia with training, contractor support, financial assistance, and t echnical and scientific advice

for aerial pesticide spraying activities designed to eradicate the illicit crops coca and poppy in Colombia. The U.S. Environmental Protection Agency (EPA)
has completed an assessment at the request of DoS, on whether the herbicide mixture, in the manner it is being used in Colombiafor coca and poppy

eradication, does not pose unreasonable risks or adverse effects to human health or the environment. The Agency has reviewed information provided to us
by the DoS to confirm that the herbicide mixture is being used according to EPA label requirements for comparable use in the United States, any additional
controls recommended by EPA for this program, and with the Colombian Environmental Management Plan for aerial fumigation.ANNEX 148

EPA concludes from its assessment of the submitted and available information on the spray program and the herbicide glyphosate that there does not appear
to be any evidence that glyphosate aerial spraying of coca or poppy has resulted in any adverse human health effects among the population where this
spraying occurs in Colombia. There have been no substantive changes to the eradication program's method of aerial glyphosate ap plication or the spray

formulation. Although the measured toxicity and estimated exposure indicate that only nontarget terrestrial plants are likely t o be adversely affected by the
use on coca and poppy, important uncertainties should be considered. The Agency findings from 2002 and 2003 remain relevant tothe current coca and
poppy eradication activities in Colombia. The DoS and the Government of Colombia made modifications and enhancements to the spr ay program as EPA

recommended in its prior assessments. This is an interim finding that may change as new information becomes available and follo wup is performed. Details
of EPA findings are provided in the attached document.

I. BACKGROUND

The Department of State (DoS) assists the Government of Colombia with training, contractor support, financial assistance, and technical and scientific advice
for an aerial pesticide spraying program designed to eradicate the illicit crops coca and poppy. The eradication program include s the use of a spray mixture of

a glyphosate formulation, an adjuvant (Cosmo-Flux 411F), and water. The glyphosate tank mixture is applied aerially as a foliar application in certain
provinces of Colombia. As required by the Consolidated Appropriations Act, 2004 (H.R.2673), DoS has consulted with the U.S. Env ironmental Protection
Agency (EPA) to ensure that the herbicide mixture, in the manner it is being used, does not pose unreasonable risks or adverse e ffects to human health or

the environment. As part of this effort, EPA has previously reviewed DoS eradication spray program activities in 2002 and 2003. This review updates and
comments on the progress of the Colombian government to evaluate the effects of the glyphosate spray program on human health an d the environment in
areas where it has been used to eradicate illicit crops, as requested by DoS, in a letter dated September 27, 2004.

II. SUMMARY OF PREVIOUS ASSESSMENTS

In 2002, EPA reviewed the coca eradication program in Colombia and concluded that there was no evidence of significant human he alth or environmental
risks from the spraying. EPA did recommend that DoS switch to a herbicide product with lower toxicity due to a potential hazard to the eyes of pesticide

mixers/loaders. EPA also asked DoS to conduct field investigations of health complaints associated with coca eradication. The Agency further concluded that
spray drift was likely to cause phytotoxicity downwind of sprayed coca fields. The Agency reached its conclusions from a thorough review and assessment of
the available scientific studies on glyphosate and glyphosate-containing formulated products and their use in the United Statesand in conjunction with

information on the spray program in Colombia. The final conclusion was that EPA could not verify the product formulation becaus e the product was
manufactured outside the United States and not registered by the EPA.

In 2003, DoS adopted EPA's recommendation and began using a lower-toxicity glyphosate product in its coca and poppy eradication programs, and
implemented a program to investigate health complaints. Based on a comparison of the glyphosate use pattern in Colombia and app roved use patterns of

glyphosate products in the United States, EPA determined that application rates for both coca and poppy eradication in Colombiawere within the parameters
listed on U.S. labels. The Agency could not verify the quality of the product since it is formulated outside of the Unitedt s, but a review of toxicity testing

on the spray mixture solution did not uncover any irregularities.

EPA concluded in 2003 that there were no risks of concern from dietary exposures or from exposures to mixer/loader/applicators or field workers, including

bystanders. The concerns for mixer/loader eye irritation discussed in EPA's 2002 review were mitigated in 2003 by switching to a lower-toxicity glyphosate
product registered by both EPA and the Government of Colombia.

The DoS and the Government of Colombia initiated two programs to investigate health complaints. Regarding potential environment al effects from the
eradication programs, EPA concluded that the switch to a lower-toxicity product would present less risk of acute poisoning to wildlife, while potential

phytotoxicity due to spray drift could still be a factor in both coca and poppy spraying. EPA recommended that DoS continue pro grams for investigating health
complaints, and the Agency also asked DoS to develop a case definition for what would constitute a glyphosate-related adverse e ffects exposure, provide
further documentation of its investigations and how they are conducted, and standardize data collection.

In February 2004, in response to a request from DoS, EPA reviewed the Environmental Management Plan for the Illicit Crop Eradication Program in Colombia

(EMP). DoS asked EPA to assess whether use of the herbicide mixture in Colombia is in accordance with the EMP. The Plan describ ed general descriptions
of many activities related to the spray program including references to Colombian laws that were to be followed. EPA concluded that the Plan contained
appropriate types of activities for a pesticide spray program. These activities include spray application requirements and rest rictions, training and safety

precautions for personnel who handle and apply the pesticide, handling of waste resulting from program operations, training public health workers to
recognize and treat pesticide poisoning, handling of health and environmental complaints, environmental monitoring, and conting ency plans for emergencies.
EPA recognized that these types of activities were appropriate for pesticide spray programs and generally reflect similar activ ities that can be included on

pesticide spray programs in the United States, depending on the specific pesticide, use conditions, known potential risks, andfederal, state, or local laws.

EPA offered comments on two specific sections of the EMP. First, the Agency urged DoS to investigate methods for properly dispo sing of pesticide
containers rather than reusing them. The second comment was regarding the statement in the EMP that there were no significant impacts to plants that
surrounded the illicit crops being sprayed. EPA reiterated its position previously stated in the consultations - that glyphosate is highly toxic to many plants and

that some level of adverse effects is likely to occur to some nontarget plants as a result of spray drift, as can be expected w ith herbicide applications. The
Agency suggested an appropriate revision of the wording in the EMP.

III. ASSESSMENT OF THE AERIAL SPRAY PROGRAM IN 2004

In a letter dated September 27, 2004, to Michael O. Leavitt, Administrator of EPA, the Secretary of State formally asked EPA fora written response to confirm
that the DoS and EPA have consulted concerning the U.S.-supported coca and poppy eradication program in Colombia. The Secretary asked EPA help
certify that the herbicide mixture is being used in accordance with EPA label requirements for comparable use in the United Sta tes, any additional controls

recommended by EPA for this program, and the Colombian Environmental Management Plan for aerial fumigation. The Secretary also asked EPA to confirm
that the herbicide mixture, in the manner it is being used, does not pose unreasonable risks or adverse effects to humans or th e environment. ANNEX 150

Rick A. Relyea,

The Impact of Insecticides and Herbicides on the Biodiversity and Productivity of
Aquatic Communities, Ecological Applications, Vol. 15, No. 2 (2005) ANNEX 150

Ecological Applicati15(2), 2005, pp. 618–627
䉷 2005 by the Ecological Society of America

THE IMPACT OF INSECTICIDES AND HERBICIDES ON THE

BIODIVERSITY AND PRODUCTIVITY OF AQUATIC COMMUNITIES

RICK A. R ELYEA 1

Department of Biological Sciences, 101 Clapp Hall, University of Pittsburgh, Pittsburgh, Pennsylvania 15260 USA

Abstract. Pesticides constitute a major anthropogenic addition to natural communities.
In aquatic communities, a great majority of pesticide impacts are determined from single-
species experiments conducted under laboratory conditions. Although this is an essential

protocol to rapidly identify the direct impacts of pesticides on organisms, it prevents an
assessment of direct and indirect pesticide effects on organisms embedded in their natural
ecological contexts. In this study, I examined the impact of four globally common pesticides
(two insecticides, carbaryl [Sevin] and malathion; two herbicides, glyphosate [Roundup]
and 2,4-D) on the biodiversity of aquatic communities containing algae and 25 species of

animals.
Species richness was reduced by 15% with Sevin, 30% with malathion, and 22% with
Roundup, whereas 2,4-D had no effect. Both insecticides reduced zooplankton diversity
by eliminating cladocerans but not copepods (the latter increased in abundance). The in-

secticides also reduced the diversity and biomass of predatory insects and had an apparent
indirect positive effect on several species of tadpoles, but had no effect on snails. The two
herbicides had no effects on zooplankton, insect predators, or snails. Moreover, the herbicide
2,4-D had no effect on tadpoles. However, Roundup completely eliminated two species of
tadpoles and nearly exterminated a third species, resulting in a 70% decline in the species

richness of tadpoles. This study represents one of the most extensive experimental inves-
tigations of pesticide effects on aquatic communities and offers a comprehensiveperspective
on the impacts of pesticides when nontarget organisms are examined under ecologically
relevant conditions.

Key words: amphibian decline; Anax junius; Bufo americanus; Daphnia; Dytiscus; frogs; Hyla
versicolor; Lestes; Pseudacris crucifer; Rana pipiens; Rana sylvatica; Trame.

INTRODUCTION trast, experimental efforts to understand community ef-

A central goal of ecology is to understand patterns fects have primarily used single pesticides and have
focused on a narrow range of taxonomic groups in-
of species abundance and diversity in communities and cluding zooplankton (Hanazato and Yasuno 1987,
ecosystems. A great deal of research has documented
the patterns of biodiversity and productivity using rel- 1989, 1990, Havens 1994, 1995) and larval amphibians
(e.g., Boone and Semlitsch 2001, 2002; but see Boone
atively pristine systems or experimental mesocosms and James 2003). The challenge is to combine the best
that approximate natural systems (Tilman et al. 2001,
Chase and Leibold 2002, Downing and Leibold 2002, of both approaches by examining the impact of differ-
ent pesticides on a broad diversity of taxa while taking
Naeem 2002). However, many ecosystems are far from advantage of the power that comes from experimental
pristine due to a variety of anthropogenic influences,
including exposure to a plethora of pesticides (Harris replication.
Aquatic communities are particularly well suited to
et al. 1998, McConnell et al. 1998, LeNoir et al. 1999, experimental investigations of pesticide effects. There
Sparling et al. 2001, Davidson et al. 2002). Herbicides
and insecticides have the potential to cause dramatic is a long history of using outdoor aquatic mesocosms
to create experimental communities that can be repli-
changes in natural communities, yet our knowledge of cated and manipulated (Morin 1981, Werner and An-
pesticide effects on natural communities is largely lim-
ited to cases in which pesticides have been intentionally holt 1996, Relyea and Yurewicz 2002, Downing and
Leibold 2002). Mesocosms offer the potential to as-
or accidentally applied to natural sites with subsequent semble diverse communities of predators, herbivores,
floral and faunal surveys (e.g., reptiles and amphibians,
Lambert [1997]; macroinvertebrates, Leonard et al. and producers and make testable predictions about the
impact of pesticides based on single-species laboratory
[1999]; plankton and fish, Favari et al. [2002]). In con- tests (i.e., LC50 tests that estimate the lethal concen-

tration necessary to kill 50% of a test population). For
example, in pond communities, one would predict that
the application of insecticides at realistic concentra-

1E-mail: [email protected] tions should have a direct lethal impact on aquatic in-

618ANNEX 150

April 2005 PESTICIDES AND BIODIVERSITY 619

sect predators, but no direct impact on herbivores or herbicide that kills plants by inhibiting the synthesis

producers. However, insecticides may cause trophic of essential amino acids. The most popular formulation,
cascades including indirect positive effects on the her- Roundup, actually is a combination of the active in-
bivores and indirect negative effects on the resources. gredient (glyphosate) and a surfactant that helps the

In contrast, herbicides might have a direct negative herbicide to penetrate plant leaves (polyehtoxylatedtal-
impact on producers but no direct impact on herbivores lowamine; POEA). It is the second most commonly
or predators. However, herbicides may cause trophic applied herbicide in the United States, with 38–43 ⫻10 6

cascades including indirect negative effects on herbi- kg of active ingredient applied to homes, gardens, for-
vore biomass and predator biomass (Diana et al. 2000). ests, wetlands, and 8.2 ⫻10 ha of cropland in the Unit-
In summary, mesocosms allow investigators to ex- ed States (Donaldson et al. 2002, National Pesticide

amine the impacts of relevant pesticide concentrations Use Database). The half-life of roundup is 7–70 days
using realistic population densities, reasonable time (Giesy et al. 2000). The herbicide 2,4-D is a broadleaf
scales, and relatively natural conditions. herbicide that operates as a growth regulator by altering

In this study, I assembled diverse communities in proper cell division in plants. It is widely used in ag-
outdoor aquatic mesocosms and then examined the im- riculture, with 24–28 ⫻10 kg applied to nearly 33
pact of two insecticides and two herbicides (applied ⫻10 ha (Donaldson et al. 2002, National Pesticide Use

separately) on the diversity of the communities as well Database). The half-life of 2,4-D is from 10 to ⬎50
as the survival and biomass of each taxon in the com- days, according to NIH data ( available online ). These
munity. Based on the known impact of these pesticides, four pesticides are among the top 10 pesticides used

I tested the following hypotheses. (1) All of the pes- in the United States for agriculture and home use (Don-
ticides will reduce overall biodiversity. (2) The insec- aldson et al. 2002), and all of them are either applied
ticides will reduce the diversity and abundance of in- directly to aquatic habitats or can make their way into

sects (USDI [U.S. Fish and Wildlife Service] 1980) aquatic habitats via unintentional overspray, aerial
and zooplankton (Havens 1994, 1995), but will have drift, or runoff.
no direct impact on the snails and tadpoles (Relyea
M ETHODS
2003 b, 2004). (3) Because of the reduction of insect
predators, the insecticides will have an indirect positive The experiment was a completely randomized design
effect on the biomass of herbivores and an indirect
with five pesticide treatments that were each replicated
negative effect on the biomass of producers (i.e., pe- six times for a total of 30 experimental units. The ex-
riphyton). (4) The herbicides will reduce the biomass perimental units were 1200-L polyethylene tanks that
of producers but will have no direct impact on the snails
were filled with 1000 L of well water during 26–28
and tadpoles. (5) Because of the reduction of producers, April 2002. On 6 May, I added 300 g of dry leaves
the herbicides will have an indirect negative effect on (Quercus spp.) and 25 g of rabbit chow to serve as
the biomass of herbivores and predators.
habitat structure and an initial nutrient source. I also
added an aliquot of zooplankton and phytoplankton that
Pesticide background was a mixture from six local ponds. On 23 May, I

The four pesticides used in the experiment were two placed two 10 ⫻ 10 cm ceramic tiles in each tank
insecticides (carbaryl and malathion) and two herbi- (oriented vertically) to serve as future estimates of pe-
cides (2,4-D and glyphosate). Carbaryl and malathion riphyton growth in each tank.

are both broad-spectrum insecticides that kill by in- Five days later, I began adding macro-organisms that
hibiting acetylcholine esterase. In the United States, 1– I collected from natural habitats, either as mixtures of
2 ⫻10 kg of carbaryl (commercial name: Sevin) are ⱖ10 egg masses that were previously hatched in wad-

applied to rangelands, forests, oceans, homes, gardens, ing pools (four of the five tadpole species), or as larvae
and 1.3 ⫻10 ha of crops (Donaldson et al. 2002); see and adults dip-netted from ponds and wetlands (Table
the online National Pesticide Use Database. 2The half- 1). On 28 May, I added five species of larval anurans,

life for carbaryl depends on pH and ranges from 0.1 two species of snails, and one species of larval dam-
days to 4 years (Aly and El-Dib 1971, Wauchope and selfly (predators on zooplankton). The following day,
Haque 1973). Malathion is applied to ⬎800000 ha of I added a third snail species. On 30 May, I added the

cropland including fruits, vegetables, and cotton at an remaining predators: larval Anax and Tramea drag-
annual amount of 14–16 ⫻10 kg (Donaldson et al. onflies (predators on both tadpoles and snails), larval
2002, National Pesticide Use Database [footnote 2]), Dytiscus and Acilius beetles (predators on tadpoles and

and is a preferred insecticide for combating the mos- zooplankton, respectively), Notonecta and Belostoma
quitoes that carry malaria and West Nile virus. The hemipterans (predators on both tadpoles and snails),
half-life of malathion is 2–26 days, depending on pH and recently hatched spotted salamander larvae (pred-

(Guerrant et al. 1970, Wang 1991). Glyphosate (com- ators on zooplankton). All of these species naturally
mercial names: Roundup, Rodeo) is a broad-spectrum coexist and, for each species, I used densities that were

2 3
http://www.ncfap.org 典 具http://toxnet.nlm.nih.gov 典 ANNEX 150

Ecological Applications
620 RICK A. RELYEA Vol. 15, No. 2

TABLE 1. A list of the taxa used in the experiment.

Common name Species Size Density† Trophic level

Spotted salamander‡ Ambystoma maculatum 49 ⫾ 3 mg 2 predator
Diving beetle‡ Dytiscus sp. 28 ⫾ 1.1 mm 1 predator
Diving beetle‡ Acilius semisulcatus 21 ⫾ 0.4 mm 1 predator
Dragonfly‡ Anax junius 39 ⫾ 0.9 mm 1 predator
Dragonfly‡ Tramea sp. 23 ⫾ 0.6 mm 1 predator

Damselfly‡ Lestes sp. 15 ⫾ 0.3 mm 1 predator
Backswimmer Notonecta undulata 10 ⫾ 0.3 mm 3 predator
Water bug Belostoma flumineum 20 ⫾ 0.2 mm 1 predator
Wood frog‡ Rana sylvatica 104 ⫾ 10 mg 10 herbivore
Leopard frog‡ Rana pipiens 42 ⫾ 8 mg 10 herbivore
American toad‡ Bufo americanus 45 ⫾ 5 mg 10 herbivore
Gray tree frog‡ Hyla versicolor 4 ⫾ 0 mg 10 herbivore
Spring peeper‡ Pseudacris crucifer 214 ⫾ 16 mg 10 herbivore
Snail Physa integra 62 ⫾ 4 mg 10 herbivore

Snail Helisoma trivolvis 434 ⫾ 31 mg 10 herbivore
Snail Stagnicola elodes 177 ⫾ 20 mg 10 herbivore
Cladoceran Daphnia pulex ··· ··· zooplankton
Cladoceran Daphnia ambigua ··· ··· zooplankton
Cladoceran Daphnia longiremis ··· ··· zooplankton
Cladoceran Ceriodaphnia sp. ··· ··· zooplankton
Cladoceran Scapholebris sp. ··· ··· zooplankton
Copepod Eurytemora affinis ··· ··· zooplankton
Copepod Eurycyclops agilis ··· ··· zooplankton

Copepod Mesocyclops edax ··· ··· zooplankton
Copepod Leptochaptumorus siciloides ··· ··· zooplankton
Notes: Standard length was used as an initial size measure for the aquatic insects, whereas mass was used as an initial

size measure for amphibians and snails. Values are means ⫾ 1 SE. The tadpoles and snails are herbivores on periphyton,
whereas the zooplankton are herbivores on phytoplankton.
† Density is the number of individuals per 1000-L experimental tank.
‡ Larval stages were used in the experiment.

within the range of natural densities based on seven samples were combined and filtered through 62- ␮m

years of quantitative surveys of natural aquatic habitats Nitex screening (Small Parts, Miami, Florida, USA).
(R. A. Relyea, E. E. Werner, D. K. Skelly, and K. L. All zooplankton were preserved in 70% ethanol and

Yurewicz, unpublished data ). subsequently counted and identified to species. Next,
There were five pesticide treatments: controls (250 the ceramic tiles were removed and the periphyton was
mL of water added), carbaryl, malathion, glyphosate, scrubbed (using toothbrushes) onto oven-dried, pre-

or 2,4-D. For all four chemicals, I wanted to simulate weighed filter paper. The algae-covered filters were
the impact of a direct overspray on a wetland. Thus, I oven-dried again for 15 h at 80 ⬚C and then weighed to

purchased commercial forms of each chemical and had determine the dry mass of algae on each tile. Finally,
the concentrations of each chemical’s active ingredient the tanks were drained and all macro-organisms were

independently confirmed by the Mississippi State Lab- sorted from the leaves, counted, and weighed. Am-
oratory (Mississippi State, Mississippi, USA) using phibians were preserved in 10% formalin and inver-

high-pressure liquid chromatography (carbaryl, 22.3%; tebrates were preserved in 70% ethanol.
malathion, 50.6%; 2,4-D, 44.5%; glyphosate, 25.2%).
Based on the surface area of the cattle tanks (2.41 m ), Statistical analyses

I applied each chemical at the manufacturer’s recom- I analyzed the data using ANOVAs. The first analysis
mended maximum application rates (Sevin, 0.955 mL/ examined the impact of the pesticides on total species
2 2 2
m ; malathion, 0.234 mL/m ; 2,4-D, 0.117 mL/m ; richness of the animals in the community using a one-
Roundup, 6.4 mL/m 2). Thus, I added 2.3 mL of Sevin, way ANOVA. The second analysis examined species

0.6 mL of malathion, 0.3 mL of 2,4-D, and 15.3 mL richness and biomass of the four major functional
of Roundup. Because the tanks contained 1000 L of groups: predators (insects and salamanders), large her-
water, these application rates translated to 0.51 mg car- bivores (snails and tadpoles), zooplankton, and periph-

baryl/L, 0.32 mg malathion/L, 0.12 mg 2,4-D/L, and yton algae (algae was not separated into species). The
3.8 mg glyphosate/L. The pesticides were added im- third set of analyses examined the abundance of indi-

mediately after all taxa had been added to the tanks vidual species within each of the three animal groups
(30 May). (predators, large herbivores, and zooplankton). Because

On 12 June, the experiment was terminated. I began much of these latter data contained heterogeneous errors
by first sampling the zooplankton using a 0.2-L tube (some treatments had 0% survival), I first ranked the

sampler that was plunged into the tanks in the center data and then conducted a MANOVA on the ranked
and at each of the four cardinal directions. The five values. When I found a significant multivariate effect,ANNEX 150

April 2005 PESTICIDES AND BIODIVERSITY 621

I conducted univariate analyses. When I found signifi-
cant univariate effects, I conducted mean comparison
tests using Fisher’s test. I weighed all animals coming

out of the tanks at the end of the experiment and found
no significant treatment effects on mass for any of the
taxa (P ⬎ 0.05), so I chose to not include the mass data

in the analysis. Thus any differences in biomass among
treatments simply reflect differential survival across
treatments. Two of the tanks developed an unusual red

periphyton that was not present in any other tanks in
the experiment (and had not been observed in dozens
of previous mesocosm experiments). Both tanks had

been randomly assigned the control treatment and both
were removed from the analysis.

R ESULTS

The first analysis examined the impact of the pes-
ticides on the species richness of all animal taxa in the

communities (Fig. 1). There was a significant impact
of pesticides on total animal richness ( F 4,23 10.1, P
⬍ 0.001). Compared to the control tanks, species rich-

ness was 15% lower with Sevin ( P ⫽ 0.041), 30% lower
with malathion ( P ⬍ 0.001), and 22% lower with
Roundup ( P ⫽ 0.005). The addition of 2,4-D had no
effect (P ⫽ 0.543).

The analysis of species richness and biomass by
functional group produced a significant multivariate ef-
fect (Wilks’ F ⫽ 5.5, P ⬍ 0.001; Fig. 1). The rich-
28,63
ness of predators, large herbivores (tadpoles and
snails), and zooplankton were all affected by the treat-
ments ( P ⬍ 0.001). Predator richness declined with

Sevin and malathion ( P ⬍ 0.03), but not with 2,4-D or
Roundup ( P ⬎ 0.35). Large-herbivore richness de-
creased with Roundup ( P ⬍ 0.001), but was not af-

fected by the other three pesticides ( P ⬎ 0.7). The
richness of zooplankton declined significantly with
Sevin ( P ⫽ 0.044) and malathion ( P ⫽ 0.008), but not

with 2,4-D or Roundup ( P ⬎ 0.3).
The biomass of predators, large herbivores, zoo- F I. 1. The impact of four different pesticides on the
plankton, and periphyton also differed among treat- species richness of predators (insects and spotted salaman-
ders), large herbivores (tadpoles and snails), and zooplankton
ments (univariate tests; P ⬍ 0.03; Fig. 2). Predator in aquatic mesocosm communities. Data are means ⫾ 1 SE .
biomass was lower with Sevin, malathion, and Round-
up ( P ⬍ 0.001), but not with 2,4-D ( P ⫽ 0.406). The

biomass of the large herbivores was higher with Sevin or damselflies ( Lestes sp.) (univariate test,P ⬎ 0.25);
(P ⫽ 0.039), unaffected by malathion and 2,4-D ( P ⬎ marginally significant effects on the survival of Dytis-
0.25), and lower with Roundup ( P ⫽ 0.024). The abun- cus beetles (univariate test,P ⫽ 0.081); and significant
dance of zooplankton was not different between the effects on the survival of Tramea dragonflies, back-

control tanks and the four pesticide treatments ( P ⬎ swimmers ( Neonecta undulata ), and spotted salaman-
0.09). Periphyton biomass was unaffected by Sevin, ders ( Ambystoma maculatum ) (univariate test, P ⱕ
malathion, and 2,4-D ( P, ⬎ 0.15), but was 40% greater 0.03). Dytiscus beetles were eliminated with Sevin and

with Roundup ( P ⫽ 0.028). malathion ( P ⫽ 0.054), whereas Tramea dragonfly sur-
In the remaining analyses, I examined the impact of vival was reduced with malathion ( P ⫽ 0.016) and
pesticides on the survival of each species in the three nearly reduced with 2,4-D ( P ⫽ 0.065). Backswimmer

functional groups. In the MANOVA on predator spe- survival was increased with 2,4-D ( P ⫽ 0.035), where-
cies, I found a significant multivariate effect of the as spotted salamander survival was marginally higher
pesticides (Wilks’ F ⫽ 2.5, P ⫽ 0.002; Fig. 3). with Sevin ( P ⫽ 0.075) and significantly higher with
28,63
There were no pesticide effects on the survival of Anax 2,4-D ( P ⫽ 0.011). No diving beetle ( Acilius semisul-
junius dragonflies, water bugs ( Belostoma flumineum ), catus) larvae survived in any of the tanks. ANNEX 150

Ecological Applications
622 RICK A. RELYEA Vol. 15, No. 2

In the MANOVA on the large herbivores, I found a

significant multivariate effect of the pesticides (Wilks’
F 32,61 2.9, P ⬍ 0.001). There was no effect of pes-
ticides on any of the three snail species (univariate

tests,P ⬎ 0.1). Across all treatments, the mean survival
(⫾1 SE ) was 3 ⫾ 1% for Physa integra ,24 ⫾ 4% for

Stagnicola elodes , and 61 ⫾ 3% for Helisoma trivolvis .
Among the tadpoles, there were significant impacts of
pesticides on leopard frogs ( Rana pipiens ), wood frogs

F IG. 2. The impact of four different pesticides on the

biomass (or abundance) of predators (insects and spotted sal-
amanders), large herbivores (tadpoles and snails), zooplank-
ton, and periphyton in aquatic mesocosm communities. Data
are means ⫾ 1 SE.

In the MANOVA on zooplankton species, there was
a significant multivariate effect of pesticides (Wilks’

F 36,58 3.4, P ⬍ 0.001). In univariate tests, there was
no effect of the pesticides on Daphnia longiremis , Cer-

iodaphnia sp., Scapholebris sp., Eurycyclops sp., or
Leptochaptumorus sp. (P ⬎ 0.1). However, there were
significant impacts on Daphnia pulex , Daphnia am-

bigua , Eurytemora sp., and Mesocyclops sp. (P ⱕ 0.02;
Fig. 4). Daphnia pulex was completely absent from

tanks with Sevin or malathion ( P ⬍ 0.001). Daphnia
ambigua showed a similar pattern, although the effects
of Sevin and malathion were not significantly different

from the controls ( P ⫽ 0.063 and P ⫽ 0.136, respec-
tively).Eurytemora was more abundant with Sevin and

malathion ( P ⱕ 0.03), but nearly absent with Roundup
(P ⫽ 0.028). Mesocyclops was more abundant with F IG. 3. The impact of four different pesticides on the
Sevin ( P ⫽ 0.021), but was unaffected by the other
survival of individual species of predators (insects and spot-
pesticides. ted salamanders). Data are means ⫾ 1 SE.ANNEX 150

April 2005 PESTICIDES AND BIODIVERSITY 623

ity of aquatic communities over relatively short time
scales (two weeks). However, the impacts on the com-

munities were very pesticide specific. As expected, the
two insecticides reduced the diversity and biomass of
the insect predators, completely exterminating Dytiscus

beetles and reducing the abundance of Tramea and
backswimmers (the latter was only reduced with mal-
athion). This effect was predictable from the large lit-

erature on the susceptibility of aquatic insects and crus-
taceans to carbaryl and malathion. The LC50 72–96 hl-

ues range from 0.005 to 0.026 mg/L for carbaryl (USDI
1980) and 0.005 to 0.18 mg/L for malathion (USDI
1980, Key et al. 1998, Leight and Van Dolah 1999).

FIG. 4. The impact of four different pesticides on the
abundance of individual species of zooplankton. Data are
means ⫾ 1 SE.

(R. sylvatica ), and gray tree frogs ( Hyla versicolor )
(univariate tests,P ⬍ 0.01; Fig. 5) but no impacts on
toads (Bufo americanus ) or spring peepers ( Pseudacris

crucifer)( P ⱖ 0.09). Leopard frog survival improved
from 28% to 58% with Sevin ( P ⫽ 0.037) and 28% to

43% with malathion, but the latter effect was not sig-
nificant (P ⫽ 0.391). Leopard frogs were completely
exterminated with Roundup ( P ⫽ 0.004). Gray tree frog

survival was unaffected by the insecticides, but gray
tree frogs were eliminated with Roundup ( P ⫽ 0.003).
Wood frog survival improved from 50% to 72% with

Sevin ( P ⫽ 0.054) and 50% to 67% with malathion,
although the latter effect was not significant ( P ⫽
0.194). Wood frog survival was reduced to only 2%

with Roundup ( P ⫽ 0.012). None of the species was
affected by 2,4-D ( P ⬎ 0.5).

D ISCUSSION
FIG. 5. The impact of four different pesticides on the
The results of this study indicate that pesticides can survival of individual species of herbivorous tadpoles. Data
have profound impacts on the diversity and productiv- are means ⫾ 1 SE. ANNEX 150

624 RICK A. RELYEA Ecological Applications
Vol. 15, No. 2

Interestingly, the two insecticides had no effect on two (0.51 and 0.32 mg/L, respectively), there should have

of the insect species (Anax dragonflies and water bugs; been minor negative impacts of insecticides on tadpole
few damselflies survived in any of the treatments, mak- survival and this is what I observed.
ing it difficult to draw any firm conclusions), suggest- Interestingly, the survival of tadpoles actually in-

ing that insects vary in their susceptibility to the in- creased with the addition of insecticides; this was prob-
secticides (when applied at these recommended rates). ably an indirect effect of high predator mortality. The
In other words, the insecticides did not eliminate the addition of Sevin reduced the biomass of the insect
entire insect community. Thus, although predation predators by 44%, increased tadpole (wood frog and

from aquatic insects can be reduced with the applica- leopard frog) survival by 22–30%, and increased total
tion of insecticides, major predators such as Anax drag- tadpole biomass by 85%. Similarly, the salamander lar-
onflies (Relyea 2001, 2003 a) will continue to consume vae (which were small and susceptible to insect pre-

prey (although pesticide effects on the foraging be- dation) experienced a 37% increase in survival when
havior of these predators are unknown). Sevin was added. While the addition of malathion re-
In addition to the effects on insects, the insecticides duced the biomass of the insect predators by a similar

also affected the zooplankton by eliminating cladoc- amount as Sevin (48%), the 15–17% increase in wood
erans while favoring copepods. The change in zoo- frog and leopard frog survival was not significant and
plankton community composition with acetylcholine the salamander survival was unchanged. Thus, changes
esterase-inhibiting insecticides is in accord with a num- in predator biomass do not completely explain changes

ber of previous studies. At higher concentrations ( ⬎1 in herbivore survival, suggesting that we also need to
mg/L), carbaryl (the active ingredient of Sevin) can examine how the different pesticides affectthe foraging
completely wipe out nearly all species of zooplankton. behavior of the surviving predators. For example,

However, under lower concentrations, such as those Boone and Semlitsch (2001, 2002) found that carbaryl
used in the current study, carbaryl only eliminates cla- (in the absence of insect predators) can have both pos-
doceran zooplankton. As a result, the phytoplankton itive and negative effects on tadpole survival. In con-

resource can increase and provide an indirect, positive trast to the tadpoles, snails did not experience a positive
effect on the abundance of grazing copepods (copepod indirect effect on their biomass because the specialist
body size also may have increased, but this was not snail predator ( Belostoma ) was not killed by the in-
measured). However, copepods typically cannot graze secticides. This suggests that although higher concen-

the smallest algae that are consumed by the cladoc- trations of carbaryl and malathion certainly can kill
erans; hence, the copepod populations are unable to many amphibians ( ⬎5 mg/L; Boone and Semlitsch
completely compensate for the decrease in cladoceran 2001, 2002, Relyea 2003 b, 2004), under lower con-

abundance (Hanazato and Yasuno 1990, Hanazato centrations these insecticides, and perhaps other insec-
1991, Havens and Hanazato 1993, Havens 1994, 1995, ticides that share the same mode of action, actually can
Wong et al. 1995). Thus, it appears that these two in- have positive indirect effects on the survival and bio-

secticides can have both direct and indirect effects on mass of tadpoles. Thus, in assessing the impacts of
zooplankton. insecticides on amphibians, it is critical that we con-
At the concentrations used, the insecticides were pre- sider both relevant concentrations and relevant ecolog-
dicted to have no direct negative effects on the survival ical contexts.

of the large herbivores (snails and tadpoles). There ap- The two herbicides had very different effects on the
pear to be very few comparative data addressing the community than the two insecticides. Although gly-
impacts of carbaryl and malathion on snails (Martinez- phosate and 2,4-D are designed to kill plants, they did

Tabche et al. 2002), but the current study suggests min- not reduce the biomass of periphyton in the experiment.
imal impacts. In contrast, we have a large number of In fact, 2,4-D had few effects on any species or trophic
studies on the impacts of carbaryl and malathion on group in the entire community during the 14-day ex-
periment (only backswimmers and spotted salamanders
tadpoles. The LC50 for carbaryl ranges from 1 to 18
mg/L (Marchal-Segault 1976, Marian et al. 1983, increased survival with 2,4-D, although the causes are
Bridges 1997, Zaga et al. 1998, Relyea and Mills 2001, unclear). This general lack of impact from 2,4-D is
Relyea 2003 b) for all amphibians and from 1.2 to 3.4 consistent with past toxicity studies that have found

mg/L for the populations of wood frogs, leopard frogs, relatively high LC50 96-hvalues for 2,4-D, including 45
toads, and gray tree frogs used in the current study mg/L for lake trout ( Salvelinus namaycush ), 301 mg/
(Relyea [2003b]; including LC50 estimates when Sevin L for American eels ( Anguilla rostrata ), and 363–389

is combined with predator chemical cues). The LC50 mg/L for cladocerans ( Daphnia magna ; USDI 1980,
values for malathion range from 1.2 to 5.9 across all Verschueren 1983). In this system, 2,4-D appeared to
amphibians, including the populations of wood frogs, have no substantial impact on a diverse aquatic com-
leopard frogs, toads, and gray tree frogs used in the munity.

current study (Fordham et al. 2001, Relyea 2004). Be- In stark contrast, Roundup had a major effect on the
cause the current study used concentrations of carbaryl community. Roundup reduced tadpole richness by 70%
and malathion that were well under these LC50 values by completely exterminating two species (leopardfrogsANNEX 150

April 2005 PESTICIDES AND BIODIVERSITY 625

and gray tree frogs) and nearly exterminated a third different species of tadpoles under a range of Roundup
species (wood frogs). Roundup did not have a signif- concentrations to estimate the LC50 values. The esti-
icant effect on toads, spring peepers, and the spotted mated LC50 16-dvalues for these North American spe-

salamanders, although few toads survived even in the cies were lower than previously observed for most am-
control treatments, making it difficult to assess the ef- phibian species (Mann and Bidwell 1999, Perkins et
fects of Roundup on survival. These reductions in tad- al. 2000), ranging from 0.5 to 2.5 mg AI/L (Relyea, in
pole survival were concomitant with a decrease in pred- press). This suggests that a direct overspray at the man-

ator biomass, suggesting that Roundup also caused a ufacturer’s recommended rate (a realized pond con-
trophic cascade from the herbivores to the predators. centration of 3.8 mg/L) should be highly lethal to these
In comparison to the 3.8 mg/L of glyphosate used in amphibians. The current study is consistent with this

the mesocosm study (based on the manufacturer’s rec- prediction.
ommended application rate; AI ⫽ active ingredient), I have also conducted a second outdoor mesocosm
concentrations of glyphosate in nature have been ob- experiment in the absence of predators (to eliminate

served up to 2.3 mg AI/L and are capable of being as this source of mortality) and with the addition of either
high as 3.7 mg AI/L (Giesy et al. 2000). no soil, sand, or loam (because soil is known to absorb
Giesy et al. (2000) recently reviewed the toxicity of the two components of Roundup (glyphosate and the

glyphosate and found that its toxicity (expressed as mg POEA surfactant) and remove them from the water
of active ingredient per liter) to invertebrates can be column; Giesy et al. 2000). I exposed communities of
quite high, ranging from 3.5 mg AI/L in crayfish ( Or- three tadpoles species to 3.8 mg AI/L of glyphosate (in
conectes nais ; LC50 ) to 5600 mg AI/L in midge the form of Roundup, similar to the current experiment)
96-h
larvae ( Chironomus riparius ; LC50 48-h. As expected and found that it reduced tree frog tadpole survival
from these previous studies, glyphosate had no effect from 75% to 2%, toad tadpole survival from 97% to
on the insect predators and snails in the mesocosm 0%, and leopard frog tadpole survival from 98% to 4%

experiment. Glyphosate also has a wide range of toxic (R. A. Relyea, unpublished manuscript ). Moreover, the
effects on fish, ranging from 3.5 mg AI/L in Tilapia addition of soil did not diminish the toxic effect. Col-
sp. (LC50 )to ⬎1300 mg AI/L in sheepshead min- lectively, the available data indicate that, contrary to
96-h
nows ( Cyprinodon variegatus ; LC50 96-h. Prior tests of conventional wisdom, current application rates of
glyphosate on amphibians have been rare. In four spe- Roundup can be highly lethal to many species of am-
cies of Australian tadpoles ( Crinia insignifera , Heleio- phibians. This result is of particular interest in light of

porus eyrei , Limnodynastes dorsalis , and Litoria moor- the global decline of amphibians (Wake 1998, Alford
ei), Mann and Bidwell (1999) found that LC50 48-hal- and Richards 1999, Houlihan et al. 2001, Blaustein and
ues in the laboratory ranged from 3.9 to 15.5 mg AI/ Kiesecker 2002) which, in some cases, is correlated
L for Roundup (glyphosate plus POEA surfactant), 108 with a proximity to agricultural areas that usepesticides

to 161 mg AI/L for technical grade glyphosate acid, (Bishop et al. 1999, Davidson et al. 2001, 2002, Spar-
and ⬎450 mg AI/L for glyphosate isopropylamine salt ling et al. 2001).
(the latter two formulations lack the POEA surfactant). Although Roundup is an herbicide, two lines of ev-

Perkins et al. (2000) conducted laboratory experiments idence suggest that the widespread tadpole mortality
on Xenopus laevis tadpoles and found LC50 96-hvalues was directly due to toxicity and not to the destruction
of 12.4 mg AI/L for Roundup, 6.8 mg/L for the POEA of the tadpoles’ algal food source. First, much of the

surfactant alone, and 9729 mg AI/L for Rodeo (an mortality occurred within the first 24 hours ( personal
aquatic form of glyphosate that lacks the POEA sur- observations ). This mortality rate was much faster than
factant). Smith (2001) examined the impact of Kleer- would be expected to occur with a lack of food (Audo

away (another form of glyphosate that includes the et al. 1995) and was consistent with our single-species
POEA surfactant) and found that nearly half of western laboratory experiments that did not use algal food
chorus frog tadpoles ( Pseudacris triseriata ) died at sources (Relyea, in press ). Second, the biomass of pe-
0.75 mg AI/L; plains leopard frog larvae ( Rana blairi ) riphyton did not decrease with Roundup. Roundup ac-

experienced 0% and 100% survival at 0.75 mg AI/L tually caused a 40% increase in periphyton by remov-
in two separate experiments. All tadpoles of both spe- ing a large fraction of the herbivores and allowing pe-
cies died at higher concentrations (7.5, 750, and 7500 riphyton to attain a higher standing crop. Thus, there

mg AI/L). These studies suggest that the high mortality was a positive, indirect effect of Roundup on periph-
associated with commercial forms of Roundup is ac- yton. This indicates that Roundup directly kills am-
tually due to the POEA surfactant and not to glyphosate phibians rather than indirectly causing amphibians to

itself. starve to death.
The high mortality rates of tadpoles associated with
Roundup are in agreement with those of several other Conclusions

experiments that I have recently completed on tadpole This study highlights the importance of examining
species from the midwestern United States. Using static the impact of pesticides within the natural ecological
exposure experiments in the laboratory, I reared six context in which the taxa live. Single-species toxicity ANNEX 150

626 RICK A. RELYEA Ecological Applications
Vol. 15, No. 2

studies are invaluable to assess the relative lethality of community mesocosms. Ecological Applications 13:829–
841.
different chemicals on both target and nontarget spe-
cies. However, when toxicity studies are embedded in Boone, M. D., and R. D. Semlitsch. 2001. Interactions of an
insecticide with larval density and predation in experi-
the nexus of interactions that compose natural food mental amphibian communities. Conservation Biology 15:
webs, we can arrive at very different interpretations 228–238.
Boone, M. D., and R. D. Semlitsch. 2002. Interactions of an
due to the prevalence of both direct and indirect effects.
At realistic concentrations, the two insecticides had insecticide with competition and pond drying in amphibian
communities. Ecological Applications 12:307–316.
substantial negative effects on the predatory insectsand Bridges, C. M. 1997. Tadpole swimming performance and
cladocerans, but they had substantial indirect positive activity affected by acute exposure to sublethal levels of
carbaryl. Environmental Toxicology and Chemistry 16:
effects on the copepods and tadpoles. The two herbi-
cides had quite contrasting effects; 2,4-D had no impact 1935–1939.
on the community, whereas Roundup caused a major Chase, J. M., and M. A. Leibold. 2002. Spatial scale dictates
the productivity–biodiversity relationship. Nature 416:
reduction in amphibian diversity, an indirect, positive 427–430.
impact on the periphyton that the tadpoles consume, Davidson, C., H. B. Shafer, and M. R. Jennings. 2001. De-

and an indirect, negative effect on the biomass of insect clines of the California red-legged frog: climate, UV-B,
predators. It is important to note that these impacts habitat, and pesticides hypotheses. Ecological Applications
11:464–479.
occurred over relatively short time scales (two weeks). Davidson, C., H. B. Shafer, and M. R. Jennings. 2002. Spatial
Over longer time scales (months to years, depending tests of the pesticide drift, habitat destruction, UV-B, and

on the species), many of the taxa have the potential to climate-change hypotheses for California amphibian de-
recover their population sizes, provided that the pes- clines. Conservation Biology 16:1588–1601.
Diana, S. G., W. J. Resetarits, Jr., D. J. Shaeffer, K. B. Beck-
ticide exposure is not a recurring event. man, and V. R. Beasley. 2000. Effects of atrazine on am-
Although there is currently a strong empirical and
phibian growth and survival in artificial aquatic commu-
theoretical push to understand the factors that deter- nities. Environmental Toxicology and Chemistry 19:2961–
mine species diversity and abundance in relatively pris- 2967.
tine systems (Tilman et al. 2001, Chase and Leibold Donaldson, D., T. Kiely, and A. Grube. 2002. Pesticides in-
dustry sales and usage: 1998 and 1999 market estimates.
2002, Downing and Leibold 2002, Naeem 2002), few
habitats are untouched by anthropogenic effects, in- USEPA Report Number 733-R-02-001, U.S. Environmen-
tal Protection Agency, Washington, D.C., USA.
cluding the direct application or drift of pesticides Downing, A. L., and M. A. Leibold. 2002. Ecosystem con-
(Lambert 1997, LeNoir et al. 1999, Leonard et al. 1999, sequences of species richness and composition in pond food
webs. Nature 416:837–841.
Favari et al. 2002). We need to understand how these
effects impact natural systems and whether they con- Favari, L., E. Lopez, L. Martinez-Tabche, and E. Diaz-Pardo.
2002. Effect of insecticides on plankton and fish of Ignacio
tribute to the global decline in biodiversity. Ramirez reservoir (Mexico): a biochemical and biomag-
nification study. Ecotoxicology and Environmental Safety
A CKNOWLEDGMENTS 51:177–186.

My thanks to Josh Auld, Jason Hoverman, Laura Howell, Fordham, C. L., J. D. Tessari, H. S. Ramsdell, and T. J. Keefe.
Adam Marko, and Nancy Schoeppner for assisting with the 2001. Effects of malathion on survival, growth, develop-
experiments. I thank Josh Auld, Jason Hoverman, April Ran- ment, and equilibrium posture on bullfrog tadpoles ( Rana
dle, and Nancy Schoeppner for reviewing the manuscript.The catesbeiana ). Environmental Toxicology and Chemistry
research was supported by the National Science Foundation. 20:179–184.

Giesy, J. P., S. Dobson, and K. R. Solomon. 2000. Ecotox-
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ence 212:1284–1286. icology and Chemistry 17:2543–2553. ANNEX 151

Keith R. Solomon et al.,
Environmental and Human Health Assessment of the Aerial Spray Program for

Coca and Poppy Control in Colombia, prepared for the Inter-American Drug
Abuse Control Commission (CICAD) section of the Organization of American
States (OAS) (31 Mar. 2005)ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151ANNEX 151 ANNEX 152

National University of Colombia, Institute of Environmental Studies,
Observations on the “Study of the effects of the Program for the Eradication of
Unlawful Crops by aerial spraying with glyphosate herbicide (PECIG) and of

unlawful crops on human health and the environment (10 May 2005) ANNEX 152

[seal]
UNIVERSIDAD NACIONAL DE COLOMBIA

BOGOTA CAMPUS
INSTITUTE FOR ENVIRONMENTAL STUDIES – IDEA

Remarks on the “Study of the Effects of the Illegal Crop Eradication

Program by Aerial Spraying of the Herbicide Glyphosate (PECIG) and on
Illegal Crops on Human Health and the Environment”

Tomás León Sicard

Agronomist PhD
Director Research Program on Impacts of Illegal Crops (PIAC) IDEA – UN
Director (e) Institute for Environmental Studies IDEA – Universidad Nacional

Javier Burgos Salcedo
Biologist candidate PhD.
Researcher – Professor Masters in Environment and Development Program IDEA
– UN

Catalina Toro Pérez
Architect candidate PhD.
Researcher – Professor Masters in Environment and Development Program

(PIAC) IDEA – UN

César Luengas Baquero
Zootechnician Esp.

Researcher – Professor Masters in Environment and Development Program
(PIAC) IDEA – UN

Claudia Natalia Ruiz Rojas

Civil Engineer MS
Researcher – Professor Masters in Environment and Development Program
(PIAC) IDEA – UN

Claudia Patricia Romero Hernández
Topographical Engineer MS
Researcher – Professor Masters in Environment and Development Program
(PIAC) IDEA – UN

Bogota, 11 May 2005ANNEX 152

[PAGE 2]

INTRODUCTION

The aforementioned document, which was prepared by Drs. Keith Solomon,
Arturo Anadón, Antonio Luiz Cerdeira, Jon Marshall, and Luis Helena Sanín

(hereinafter Solomon and collaborators), constitutes an important national
reference for the future research work that is done on the subject. It is
accompanies by abundant bibliographic references and valuable information on
some topics, with broad arguments on the selected topics.

The document, which was prepared under the auspices of CICAD (Inter-
American Commission for the Control of Drug Abuse), a division of the
Organization of American States, has deficiencies in how it is structured, given

that it lacks the desired order in this type of scientific document. It lacks a
unifying narrative which, starting from a clear definition of the problems to be
evaluated and the starting hypotheses, presents the procedures used
(methodology), the results found and a final discussion thereof. Those items are

mixed throughout the text, making reading it difficult.

The central thesis of the study is to prove that, “i) … exposure to glyphosate and
its adjuvants as used in the poppy and coca eradication program do not give rise

to acute or chronic adverse effects in non-target organisms, exposed by different
routes; and … ii) that such exposure does not give rise to acute or chronic adverse
effects in non-target organisms exposed by different routes….” In this effort
Solomon and collaborators essentially appeal to a review of the existing literature

and, on occasions, experimental tests performed in a laboratory.

Based on the text presented, the following remarks can be made:

1. On the Preface (page 2)

In the first place we must call attention to the starting arguments of the study: the
authors acknowledge that, “…the Illegal Crop Eradication Program is the subject

of intense debates for political, social and other reasons...,” and therefore, “…all
social, political, and economic matters are specifically excluded from the study
and the final report is based strictly on science and on arguments based on
science… (the italics is ours).”

That asseveration by the authors is very polemical, at least for three reasons:
first, because it excludes the social, human and economic sciences from the
environmental analysis; second, because it accentuates only explanations that ANNEX 152

come from the natural or “hard” sciences in a phenomenon which, in reality,
touches upon many more of the aspects considered by them, and third because it

is unavoidable that in this study, or any other of the same nature undertaken either
by researchers in the country or, as in the present case, by an expressly selected
international group, will be used for political purposes.

Science cannot remain neutral with respect to society by claiming that its method
is pure and impartial, when its motivations and results are added to the social
debate. Moreover when it is a matter of subjects as socially, economically,
politically, and

[PAGE 3]

militarily sensitive, such as the one discussed in the study, that are at the center of

polemics with worldwide repercussions, and are related to fundamental human
rights such as the right to life, a healthy environment, and the health of
Colombians.

Insofar as the first matter indicated, we must insist that, for more than thirty
years, the world has acknowledged that the environmental dimension is,
precisely, the conjuncture of complex society – nature or ecosystem – culture
dynamic, and that has been stated in a vast amount of literature from the

ecological to the anthropological, sociopolitical, and economic [see original for
references].

Despite their good intention of delimiting the field of study, which in and of itself

is a legitimate position, the authors cannot forget the complexity of the matter,
especially because it has effects both on their methodology and on their
conclusions.

On their methodology, because they forgot to include the economic, institutional,
political, or social effects that spraying with herbicides on producers’ fields has
(loss or reduction in the yields of legal crops, affecting pets, displacements of the
population, changes in the family relations of the affected farmers, or sharpening

of the armed conflict in Colombia, just to cite five examples).

On their conclusions because, as can be seen on page 107, the authors state that,
“the additional risks associated with the spraying program are small,” when the

study did not consider, or if did so tangentially, the direct or indirect risks on
nearby ecosystems or agroecosystems, losses of biodiversity, displacements of
populations or an increase in erosive processes as a result of the use of the
herbicide.ANNEX 152

In the second place, total trust in science is also relative. The arguments against
glyphosate are also abundant in worldwide literature; however, they were not
sufficiently explored by the authors. This means that science faces problems

when it seeks to be objective, because it is a human exercise. Here it is
worthwhile to note the famous example of the glass filled halfway with water:
for some observers it is half-full and for others it is half-empty. The claimed

scientific objectivity of the positive sciences, is also in doubt.

In relation to the third point it is sufficient to indicate that, from the very day on

which the authors publicly stated their results, the reactions from civil society and
from the government could not wait, some in favor and others against the study,
certifiable evidence of its undeniable political importance. a

[PAGE 4]

2 On the focus of the work

The project has a serious deficiency: it was based on secondary studies to

estimate the effects of the herbicide on human health, accepting most of what is
in its favor, but rejecting any that indicate risk. Moreover: not only that,
Solomon and collaborators did not consult the complaint list (currently containing
b
more than 8000 in the Public Advocate’s Office) that have been filed by
different players in Colombian society on the environmental effects of the
spraying. There they would certainly have found a large amount of data to verify.

Work in this direction was performed by Luengas (2005) who examined the
databases of the Public Advocate’s Office and the National Narcotics Department

(DNE), finding that 87% of the complaints filed correspond to damage to plant
life,cand 6.9% to human health and the rest to animals and bodies of water.

Furthermore, we believe that the variable selected to estimate the effects of
Glyphosate on human health (Human Fertility, in particular Time to get Pregnant)

is insufficient to evaluate the effect of the herbicide, because:

a See press releases, letter from the network of students abroad, public statements by the Minister
of the Interior and the more than 3500 communications sent to presidents Uribe and Bush
rejecting the imminent spraying in the National Parks of Colombia.
b Personal communications from officials at the Public Advocate’s Office (April 2005).
c
This result is to be expected due to the fact that glyphosate is an herbicide and its initial action
occurs on the plant component. ANNEX 152

i Those effects are evident in time periods greater than those contemplated
in that study.

i The effects of chemical compounds of the type that are used in
agriculture, are evident at the chromosome level in the exposed
populations and by an increase in the proportion of genetic diseases in

their descendents, which variable were not considered in the study by
Solomón and collaborators.

It is for these reasons that the operators who handle these substances are obligated
to use special clothing and additional safety measures, something that does not
occur in people who, in one way or another, are exposed in the crop fields at the
time of the aerial spraying of the herbicide.

On the studies that indicate health risks we must note the one that was recently
performed by Maldonado (2003) which shows evidence of genetic damage in

36% of the cells of all women who were exposed to spraying of the herbicide on
the Colombian – Ecuadorian border. Other evidence along the same line should
have been consulted [see source for references]. d

[PAGE 5]

Likewise, Richard et al, in recent research on the differential effects of glyphosate
and Round-Up, prove that glyphosate is toxic to JEG3 human placenta cells
within 18 hours after exposure in concentrations lower than those used in

agriculture and that this effect increases when the concentration and exposure
time are increased or in the presence of the Round-Up coadjuvants.

A final reflection in this regard: human health is not only physical. It is also

mental. It would have been interesting to explore what psychological affects
aerial spraying has on the perceptions of children, men, and women who are
affected by these actions in which, as admitted by the team of experts, combat

aircraft and armed helicopters participate.

d“The toxicity of commercial glyphosate at a concentration of 48% shows a minimum average
lethal dose (amount required, in a single dose, to kill half of the individuals in an experiment on a
homogeneous group), orally of 4,900 to 5,000 milligrams per kilogram of live weight in female
rats and it has been classified as Category IV toxicity (assigned by the FEDERAL,
INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT, FIFRA), Category III for inhalation

toxicity, and Category IV for dermal toxicity. The Environmental Protection Agency, using the
FIFRA criteria under identical conditions, assigned it Category II because of the eye irritation
effect and corneal opacity in rabbits, these latter effects according to the manufacturer are caused
by the tallow amine ethoxylate that is used as a surfactant which also has the ability to cause
gastrointestinal irritation, nausea, vomiting, and diarrhea (…).” [see source for references]ANNEX 152

Let us now move on to the general observations on the scientific procedures used:

3 In relation to the definition of the problem (pages 22 and 23).

The research problem is not clearly delimited in the text. Traditionally the
definition of the research problems are stated in short paragraphs or in specific

questions that must be answered (which include the variables to be studies as well
as time and space references), which is not specified anywhere. A deduction is
made, however, form that stated on page 23 of the document, that it is a question
of “…evaluating the risk of using glyphosate and adjuvants to control illegal

crops….” Because it is not clearly explained who will do the evaluation, under
what conditions, nor based on what procedures … the document enters into the
field of ambiguity, as shall be demonstrated in the following pages.

4 On the Methodology

The final text does not contain a specific chapter on the methodology and readers
must look for the procedures used throughout the length of the text, which makes

it difficult to read and understand. However, the principal methodological
deficiency refers to the same general conception of the study.

For example, in relation to the ecosystemic components for which the effects of

glyphosate are sought (which forms part of the methodological decisions), the
authors did not hit the target: they sought effects where there might not be any
or where minimum risks might be found, that also because of the deficient
delimitation of the problem to be investigated.

Indeed, it is known that herbicides are principally toxic to plants and not to
animals (as the authors indicate on page 25). Therefore, the effects to seek,
estimate, and/or measure should have been as a priority those that are caused by

its direct spraying on legal crops or on natural vegetation. We are certain that if
that had been done, the study would have had other conclusions, because spraying
the herbicide directly affects the plant biodiversity in these areas.

[PAGE 6]

One of the main criticisms in this regard is related to the fact that, according to
the results of Solomon and collaborators, the glyphosate would specifically affect

only the coca crops and in no way other plant species. However, as best we
know, the principal active ingredient of glyphosate (isopropylamine) does not
have species-specific effects, as can be seen from the results of the
aforementioned work. Indeed, in the document: “Report on Matters Related to ANNEX 152

the Aerial Eradication of Illegal Coca in Colombia,” published by the Office of
International Narcotics Affairs and Law Enforcement (INL) of the Department of
State (September 2005), eit is acknowledged that “glyphosate is an effective
broad-spectrum herbicide, and therefore a risk for non-target plants outside the

area of application is expected.”

Moreover, in relation to the soil, it was not urgent to detail the adsorption process

of glyphosate molecules in the clay-humus complexes of the edaphic medium. It
was sufficient to make estimates or take measurements on the erosion of the
resource which, for humid tropical forest areas under clean cultivation has been
estimated at amounts in excess of 25 tons / hectare / year. Mosquera (1985) from

that time already stated that erosion greater than 25 t / ha / year was considered
severe. Morgan (1986) states that on deforested surfaces in percentages near 35%
then the erosion reaches in humid tropical forests rates as high as 15 t / ha.

It would have been very interesting for Colombia to see estimates on the loss of
soil as a direct result of removing the plant coverage caused both by the spraying
of Round-Up and by the introduction of the coca crop. We are also certain that

the work her would have increased its usefulness for the country.

5 On the receiving environment

On page 33 of the report debatable information is given: the authors state that
“…given that the critical points of diversity are associated directly with the
highlands of the Andes and that coca is mostly grown at lower altitudes, there is

only a little superimposition (the italics are ours) between the coca production
areas and the regions of large biodiversity….”

Up to the point indicated by worldwide literature, the humid tropical forests that

are the areas where coca is mostly grown, also represent the most sensitive areas
(hotspots) of biodiversity, and therefore it’s not that there is only a little
superimposition, but entirely the opposite: spraying is being done in the most
sensitive biodiversity areas on the planet (Sisk et al, 1994).

Humid tropical forests are characterized as being the ecosystems with the most
complex structure, stratification, and species-diversity in the world. Around 50%

of the world’s described diversity of flora species is concentrated in these
ecosystems (Gentry, 1993).

[PAGE 7]

ehttp://bogota.usembassy.gov/wwwfepag.pdfANNEX 152

There is extensive work in Colombia on biodiversity and it has been done by
various entities: The National Parks Unit of the Ministry of the Environment,

Housing, and Territorial Development, the Alexander von Humboldt Institute, the
Institute for Amazonian Research “Sinchi,” Nongovernmental Organizations such
as Prosierra, Natura, Tropenbos and several Universities (Nacional, Javeriana,
Andes, Antioquia, Valle, among others) that have generated significant

information from several disciplines on the subject of biodiversity and the
pressures that exist on it, without mentioning international institutions such as the
WWF, Conservation International, or National Toxic Network, entities and works
that we suggest be consulted by researchers in future studies.

6 Deposits beyond the target

On page 38, information is presented that is attention-getting, concerning the

spray that does not hit the targets (coca plants) and that winds up in other areas.
Professor Solomon and his colleagues, citing Payne et al (1990), state that the
effect is minimum although they agree that “…this estimation is based on visual
observations of a relatively small number of crops…,” which in the end means

that this effect was not measured.

In all, the datum presented of 625.7 hectares affected by off-target deposits of
glyphosate for 2002 is worrisome, as is the information given by the authors

about 22 non-target areas that were affected with the herbicide of a total of 86
sites visited (that is to say, 25.6%). This implies that at least 1 in every four spray
operations affects areas near the coca crops, which is no longer a minimum effect
as suggested by Payne et al (op. cit.).

This 25.6%, calculated by us based on the data presented in the Solomon report,
contrasts with the low surface percentages that are indicated in the report
(“…between 0.25% and 0.48% of the areas for coca production were damaged by

deposits sprayed off the target site…”), which information we do not know how it
was obtained given that the authors agree that there was no field proof.

Then, professor Solomon and his colleagues compare these areas with the entire

surface area of Colombia and they conclude that they are small, which does not
seem valid to us, because for the same reason it could be stated that the
approximately 80,000 current hectares of coca in the country are also small if
compared to the total surface area of Colombia (7.1%).

7 On the reference framework for evaluating risk (page 39 and
subsequent) ANNEX 152

The method chosen to rate the risk to human health is not adequately described.
We do not know what ranges were adopted or the criteria for the 0 to 5 score that
was used. Were they adopted in consensus in the group? What does in each case
f
a rating of 1, of 0.5, or 3, mean, for example?

[PAGE 8]

In Table 11 it is noted that 5 points were awarded (maximum effect on human
health) to the slash and burn process. We ask: What are the effects of felling and
burning a forest? Weren’t the authors confused and wouldn’t they classify the

risk to biodiversity of that is in fact 5? In accordance with the foregoing, how
were the recovery scores obtained? Why put the impacts of sowing and using
fertilizers if their intensity scores are equal to zero?

Something similar occurs with the ecological risks (Table 12). Here the low
scores assigned to sowing (1) and the use of pesticides (2) is noteworthy.
Because the procedure for assigning these scores was not specified, we believe

that they are overvalued. The sowing of coca as clean cultivation must have
significant erosion effects on the soil in humid tropical forests., where the
gradients and the high amount of precipitation drag large amount of edaphic

material. The same thing happens with the use of pesticides. The authors
presented lists of agrotoxins used by the coca farmers, which include category 1a
and 1b substances which are highly toxic to non-target species. Then, why give
such low risk intensities?

The conceptual model mentions that the toxicity data for glyphosate were
obtained from the literature and on acute intoxication tests on laboratory animals

performed with the glyphosate – Cosmoflux mixture, but the protocols were not
present. Nor do they present how the processes of exposure via the food chain
and drinking water were estimated. Likewise the protocols followed in the

epidemiological studies and the toxicity tests on standard organisms were omitted
(page 42).

The discussion on the effects of the POEA, which the authors acknowledge as

important, were diluted in the text and were not presented as adjuvants that have
toxic effects greater than technical glyphosate. The discussion thereof goes

f
In this regard, it must be stressed that one of the recommendations from the study on the
supposed effects of glyphosate on human health prepared by the Uribe Cualla toxicology clinic
and requested by the United States Embassy is that, “to be able to determine whether there is an
increase in the frequency of health problems and disease after aerial spraying with glyphosate and
whether this supposed increase is related to that exposure, a prospective-type epidemiological-
environmental study is required in practice. However, this was not possible given that the design
and execution of this study was five (5) months after the aerial spraying.”ANNEX 152

unnoticed. The amounts of POEA used are not mentioned, when the DNE
admitted, at least until 2002, that this coadjuvant was part of the mixture used.

Nor is the appearance of Dioxane molecules mentioned, which are highly
carcinogenic to animals, which commonly appear as impurities in the mixture.

8 In relation to the characterization of the exposure (chapter 3, page 44

and subsequent)

We are not certain that the group of sprayers has a greater probability of exposure
to glyphosate as stated on page 44, given the safety measures that they take. We

believe that the most vulnerable group are the coca producers (persons present in
the area).

[PAGE 9]

In relation to the exposure of those in the area ([Tr.: circunstantes =] name given
in the study to those who are exposed in the crop field or areas surrounding the
crop), the extrapolation of the information from the bibliography to reality is

worrisome (pages 46 to 50).

The authors state that, “…it is uncommon for there to be people present among a
coca crop during the application of the pesticide and it is possible that one person

might be directly in the spray corridor and that he receives a direct
application…,” but that is pure speculation. No one has counted the number of
people present at the time of spraying in Colombia nor how they are exposed to
the herbicides (naked torsos). Nor have the real conditions under which

Colombian coca farmers work been evaluated: heat and humidity influence the
human metabolism and could substantially change the cutaneous adsorption
patterns for coca farmers through sweat and with pores open wider. To that must
be added the nutrition conditions (which is assumed to be low in these areas) and

the immunological defense of these workers, which variables are unknown.

In this regard, it is good to cite the recommendations made by the United States
EPA (Environmental Protection Agency) to the then-Secretary of State Colin

Powel, regarding spraying in Colombia: “…Detailed information on the time of
application, the history of exposure, and the medical documentation of the
symptoms related to exposure to the glyphosate mixture was not available (page
17)….” “…During those spray operations it is recommended that there be

monitoring of health complaints, documentation of the exposure times, and the
start of symptoms to be able to evaluate the health effects and be able to reduce or
prevent their occurrence” (EPA, 2002). These recommendations by the EPA
were not followed, in the study by Solomon and collaborators. ANNEX 152

For exposure to glyphosate through diet an drinking water there is speculation

with data from several parts of the world (using examples from North American
and Denmark), but here equality of conditions can also not be assumed, because
the Colombian fields that have coca are located in tropical rainforests (with rain
precipitation near 3000 mm /year, relative humidity of 100%, air temperature

greater than 28º C and oxisol-type soil, among other factors) where the dynamics
of the chemical molecules are certainly very different from those that occur in
temperate regions.

Therefore, it is not pertinent, to say the least, to ascribe exposure values to coca
farmers by direct spraying, reentry or inhalation, estimated just from a review of
the literature.

Given the importance of the study and its undeniable consequences on decision-
making, the authors thousand have considered the possibility of studying the
many complaints filed by affected producers (more than 8 thousand at present),
which are in the files of the National Narcotics Department and the Public

Advocate’s Office and from that design a methodology that could establish, in
vivo, the parameters that were found in the bibliography. Colombia is, perhaps,
the only country in the world that can offer “science” real testimony from
thousands of people affected by spraying and it is the duty of science to base

itself on that testimony to verify or discard it. The rest is speculation.

[PAGE 10]

Then, as shall be seen later, the authors did not describe the “experimental”
conditions for justifying the statement on page 50 that literally states,
“…exposures from consumption from untreated surface water are considered low
and infrequent, in areas where spraying is done for eradication.”

9 In relation to environmental exposures (page 50 and subsequent)

The authors prevent bibliographic evidence that tends to show that the

concentrations of glyphosate in surface waters “…are relatively small…” but they
acknowledge that that has not been measured in Colombia. They propose, as a
result, a monitoring study to measure the concentrations of glyphosate, AMPA,
and other pesticides in surface waters.

Unfortunately they did not describe the general conditions under which the study
was performed, although they cite individual reports where further details are
found on temperature, rain precipitation, and soil characteristics. In the absenceANNEX 152

of greater information and only in relation to that contained in the report of
Solomon and his collaborators it is possible, therefore, to ask the following

questions (page 54):

i What were the criteria for selecting the five areas (Valle de Cauca,

Boyacá, Sierra Nevada, Putumayo and Nariño), so dissimilar from each
other, not only in terms of geology and geomorphology, soils, climate,
vegetation, but also in relation to the production unit management
systems?

i What were the internal soil parameters (morphology of the modal profile,
texture, hydraulic conductivity, permeability, water table, mineralogy, and
organic matter) that were used to differentiate the selected areas? Where
these parameters characterized?

i What where the external parameters (drainage, slope) of the soil under
study? What is its taxonomy?
i From what specific time after the glyphosate applications where the
samples started?

i What doses of herbicide were used? Applied to what type of crops?
i What was the size of the areas sprayed with glyphosate in relation to the
plant coverage of the microbasins studied?

i Where were the microbasins near the selected areas not used as controls?
i How far from or how near to the sprayed areas from the sample areas?
What obstacles prevented or what factors favored the glyphosate’s
reaching the surface water?

i What were the criteria used to define the sampling frequencies?
i What were the baselines for the time and space comparison?

The preceding questions are important because the variable selected affect the
interpretation of the results obtained.

[PAGE 11]

Therefore, it is inappropriate to state that, “…little or no glyphosate
contamination of the surface water has occurred, in large concentrations, from the
use of glyphosate in agricultural spraying or eradication in Colombia….” This

statement, which is and of itself is a conclusion, cannot be obtained from studying
five locations, with limited sampling and with so many uncertainties such as
those noted. It goes beyond what can be proved in the field with the selected
stations and it exaggerates the magnitude of the data obtained, that is to say, it is

not consistent with the methodology employed. ANNEX 152

In relation to the effects on the soil (number 3.1.4.3), the authors present Table 15
which contains some data that are not supported in the text. They agree,

furthermore, that “there are no direct measurements of glyphosate and AMPA
concentrations in the coca and poppy crops” and right there they conclude that the
recolonization of plants is rapid and that “no adverse effects have been observed
in terms of recolonization or resowing of the sprayed crops….

Such statements contradict others in the same text that speak of “reviews” once or
twice a year of the coca fields.

But beyond these effects, the members of the IDEA insist that the direct effect of
the herbicide on the soil should be sought more in the erosion rights than in their
biological persistence. However, in this same regard, the literature offers
examples that show that glyphosate can persist in the soil for months and even

years and that the results of its alteration can be more toxic than the original
molecule.

10 On the characterization of the effects

The document shows a varied sample of articles in favor and against the effects
that glyphosate does or does not cause on mammals and humans. Almost all of
the ones that show some link between glyphosate and negative effects on human

health are strongly criticized and then discarded as invalid evidence. There is
even a footnote (page 58) that discards two articles by Post (1999) and Cox
(1998) as pamphleteers and as being fraudulent scientific publications.

What is curious is that almost half the citations the authors use to demonstrate the
innocuousness of glyphosate refer to Williams (2000) and Williams et al. (2002)
who are researchers whose work was done under the auspices of Monsanto, the
company that produces glyphosate.

After each review of specific subjects, the authors wind up concluding that
glyphosate is not toxic in any case, which is not consistent with the work that is
cited (see second paragraph of page 63). Note that Solomon and collaborators

here mention POEA as possible responsible for toxicity in suicides.

We celebrate, however, that the OEA experts admit that, “…exposures in the
population studied is never measured directly and the use of substitutes is

common … which is subject to significant errors … the consequences of this
supposition could be a high rate of false positives in the classification of

[PAGE 12]ANNEX 152

exposure…the impact of this error can be significant and only rarely has it been

quantified. Until classification of exposure to pesticides in epidemiological
studies has been improved, the results of the effects on health are subject to
erroneous classification biases…” (page 64).

This statement from the very authors of the OEA report summarizes the key to
the debate.

Thereafter the authors state several examples of studies that link cancer to

glyphosate but, in the same line as their analytical bias, they refute them to
conclude that that does not occur, the same with the likely neurological effects or
the effects on human reproduction.

11 On the effects of glyphosate in non-target environmental organisms
(sic) (page 72 and subsequent)

Just as in the prior cases, the authors present evidence on the negative effects of

the herbicide, but all accompanied by their respective footnotes or criticisms, at
the end discrediting them for different reasons (unreal dosages studied,
inadequate methodologies, small samples or number of cases) and rejecting their
conclusions. This happens with soil invertebrates and microorganisms and with

land vertebrates and invertebrates. When any negative effect of glyphosate is
admitted (for example, on some birds) it states that those effects are relatively
small or that the affected organisms recover rapidly (p. 76). At the end they
admit some negative effects on frogs.

It would be recommendable for the authors to consider more seriously the reports
that criticize both technical glyphosate and the coadjuvants and the commercial
products (Round-Up). Because it is deemed of interest, Appendix A is attached

which contains the analysis of the consultant Jerry Bigwood contracted by the
Ecuadorian government in 2002 on the noxious youths [Tr.: efebos = youths ;
perhaps efectos = effects] of glyphosate and a bibliographic list of 207 references
which the author himself compiled on the subject.

Although it is not the intention of this document to perform a detailed analysis of
the existing bibliography (work that was given to the OEA experts) we transcribe
the Abstract of a recent study performed by Relyea (2005) that describes

deleterious effects of glyphosate on some aquatic species:

[PAGE 13] ANNEX 152

[…]

The full document of this article can be obtained in the journal and at the email
address indicated. We transcribe it because it is a good example of a serious
work on the negative effects of glyphosate. Works such as these could also have
been used during the review of the literature that the authors performed.

[PAGE 14]

12 On the effect of glyphosate and Cosmo-Flux on mammals

The authors set out a series of well-designed and -controlled experiments with
rats for acute oral toxicity, in a single dose, finding clinical abnormalities (p. 87)
in some cases but not in others; for acute toxicity by inhalation in different times

(with different results); for acute thermal toxicity (record of clinical
abnormalities). Rabbits were used for skin irritation tests (contrasting results) and
the eyes (contrasting results although it is accepted that the formulation studied is
a skin and eye irritant to rabbits).

What is noteworthy is that, based on these tests performed on rats, rabbits and
guinea pigs, the authors extrapolate the results and state that “…the risk to people
from the application of glyphosate or from its presence in the spray target area is

considered minimal….” With the data obtained, what they can indeed properly
state is that those effects did or did not occur in rabbits, rats, and guinea
pigs…but nothing further! It is not even proper to extrapolate that information
for all mammals (page 100) or wild birds (page 104).

Even so, the authors accept “slight or moderate irritation of the skin and eyes….”
Is that or is it not a risk to human health?

13 summarize

i Several of the conclusions that the authors reach cannot be obtained from
the very data presented by them, especially because they are suppositions

and not actual field measurements. That is especially important insofar as
human health.

i The OEA experts dismissed several studies and did not consult others in

the abundant bibliography on the matter, which could have influenced
their own conclusions.ANNEX 152

i The authors focused their efforts on seeking effects in ecosystem

compartments where it is assumed that they are smaller and not in the
ecosystem compartments where those effects are direct and easy to study:
destruction of biodiversity, elimination of legal plants, and soil erosion.

i By discarding the study of the economic and social effects, it is not proper
for the authors to use the term “environmental,” because the people have
deliberately been excluded, who are the most important players in the
environment. It is suggested, as a result, that the authors change the title

of their study.

Colombia is perhaps the only country in the world where there are more than
8,000 people who have complained about the diverse effects of the

spraying. It is with them and for them that studies on the noxious effects
on health, pets, legal plants and ecosystems. The databases of the Public
Advocate’s Office and the National Narcotics Department contain

[PAGE 15]

abundant information that could be used in this case. Also, future studies
should count on their participation, only in the definition and

characterization of environmental impacts, but also in the joint search for
solutions to this complex problem caused by illegal crops.

[…]

[PAGE 18]

A BRIEF SUMMARY OF THE SCIENTIFIC LITERATURE

REGARDING THE
NOXIOUS EFFECTS OF FORMULATIONS THAT CONTAIN
GLYPHOSATE IN
AQUATIC BIOTA AND SOIL

To the Ministry of the Environment of Ecuador

6 March 2002

Jeremy Bigwood, Technical Consultant

Background: ANNEX 152

The Government of Ecuador has requested that the government of

Colombia implement a 10 kilometer buffer zone next to the border in Colombian
territory to protect Ecuador from the possible ecological damage that might result
from the spraying (chemical sprays) under the eradication program that is
currently being conducted by the governments of Colombia and the United States

against illegal crops. The request by the Ecuadorian Government comes after a
series of articles published in the press, individual and community complaints by
citizens in the border area (and including a lawsuit in a United States federal
court) that state that the Republic of Colombia’s and the United States’ air forces

had sprayed in Ecuadorian territory or in areas very close. Among the reports of
damages caused by the spraying in Colombia there are reports of the death of
fishes and other aquatic life, as well as damages to legal crops, virgin forests and

fauna, including, although still not proved, damage to human health. Give the
fact that may rivers flow from Colombia to Ecuador, and that there are reports of
spraying above bodies of water in Colombia, the Ecuadorian Government has
stated its due concern about the possible noxious effects that could be caused in

the Ecuadorian environment and the Ecuadorian people.

Members of the Ecuadorian government are also alarmed about that fact
that before starting the spraying, neither the Government of Colombia nor the

Government of the United States (which supplies the equipment and has a very
active role in these operations) have done research on the environmental effects
of the various formulations that have been used on the most diverse biosystems in
Colombia. That massive unresearched use of herbicide formulations and the

continuous replacing of one formulation with another would not be allowed in the
United States nor in the majority of the countries in the world. AS a result of this
massive use of an unstudied formulation and in the absence of research, Ecuador
could be facing a danger of unknown proportions.

Although there have been no studies of the current formulations that are
being used in the ecosystems and biota shared between the south of Colombia and

the northern border region of Ecuador, there is a wide range of research in the
scientific literature with respect to the toxicity of SOME of the compounds
present in the formulations that the governments of Colombia and the United
States tell us that they are using. This literature is divided into three sections: 1)

the effects on the aquatic biota such as rivers; 2) the soil; and 3) insects. In this
report we are not going to consider the possible noxious effects on human
beings 39, 187, given that Ecuador hopes that the governments of Colombia and
the United States are going to

[PAGE 19]ANNEX 152

refrain from spraying within Ecuadorian territory and in areas near the border.

It must be stressed that there has been no scientific research in Colombia
with respect to the formulations that they have been using in the past or the
formulations they are currently using. We also know that they intend to change
the current formulation in a few months and use another one that has also not

been investigated. Given this situation, we can only analyze the effects of SOME
of the ingredients of the formulations used today. Also, we must stress that, with
the exception of a few studies, such as one in Nigeria, 128most of the research has

occurred in temperate regions such as northern Europe, Canada, and the United
States. Even so, these studies show that some of the ingredients in the
formulations that are currently being sprayed in Colombia can cause significant

noxious effects on aquatic life, including fish, amphibians, in the content of soil,
and in insects. Until impartial research has also been done by neutral agents on
the current formulations (and those of the past, as well as the ones that have been

proposed for the future), we can only conclude that the spraying represents a clear
and present danger to the Ecuadorian environment.

Effects on aquatic systems

While the persistence of glyphosate in water is less than its persistence in
soil, it has been extracted from soil some 12 up to 60 days after its application. 39,
67, 68
But formulations such as “Round-Up” which contains glyphosate – that also
contain a surfactant – are more dangerous than glyphosate alone in aquatic
systems. The effects of Round-Up (glyphosate and surfactant) in the aquatic

biota are so serious that Monsant itself – the company that produces Round-Up –
prohibits its use near or above bodies of water. In Colombia incidents have been
recorded of pisciculture operations in lakes and ponds, projects that were

undertaken with the support of the GTZ that were completely destroyed by
spraying with glyphosate formulations. The toxicity of these glyphosate
formulations in rivers is not only limited to fish, but to amphibians, insects,

invertebrates (including crustaceans)2, 4, 19, 39, 205, 206, 207pecies found in
rivers and other bodies of water. One of the most serious
problems with the glyphosate formulations used in Colombia is that some of the
ingredients are in and of themselves more toxic to aquatic life than glyphosate

itself. Also, in the combination they are used in spraying, the sum of them has
the effect of increased toxicity. 2 Here we must cite the summary of Abdelghani
et al.:

“The acute toxicity of three herbicides alone and in mixtures (2,4-D,
Garlon-3A, and Roundup) and a chemical additive (the surfactant Syndets) was

evaluated using three freshwater aquatic organisms (“channel” catfish [catfish], ANNEX 152

“bluegill,” and freshwater river crab [crab]). Among the three herbicides,
Roundup was the most toxic to catfish and bluegill than Garlon-3A and 2,4-D.

The order of toxicity in fish (Roundup Garlon-3A 2,4-D) was reversed in biotests
with freshwater river crabs (crab), respectively. For the surfactant “Syndets,” the
CL 50 levels of 1.9 mg/L (bluegill), 2.3 mg/L (catfish), and 15.2 mg/L (freshwater

river crab) were noted, indicating t2 g this chemical additive was much more
toxic than the three herbicides…”

[PAGE 20]

Different species of fish have different degrees of vulnerability to glyphosate
185
(and, of c206se, the other additives), 205nd the amount of minerals dissolved in
the water, and the water temperature also play a role in their toxicity.

Research conducted in Australia has demonstrated that the Roundup
formulation is very toxic to amphibians. In a study commissioned in 1995 by the
Western Australia Department of Environmental Protection (DEP) led by Dr.

Joseph Bidwell of the Curtin Exotoxicology Program, concluded that Roundup
360 (another Roundup formulation that contains glyphosate and surfactants) may
be acutely toxic to adult frogs and tadpoles at the recommended application rates

(1.8 to 5.4 kg/ha). Roundup 360 was more toxic to frogs and tadpoles than the
technical grade of glyphosate alone. It was assumed that the Roundup surfactant,
and not glyphosate itself, had caused the increase in toxicity. 4, 1It must be noted

that it is the same surfactant (POEA) as is found in the Roundup used in
Colombia.

The toxicity of glyphosate formulations to the aquatic biota is very well
established, and this is the most important matter for Ecuador because many
rivers originating in Colombia flow south, entering Ecuadorian territory. In the

absence of scientific research on, among other things, the concentrations and the
effects of the glyphosate formulations in such a variety of ecosystems, the
Republic of Ecuador must continue its cautious and moderate focus and continue

requesting a 10-kilometer buffer zone within the Republic of Colombia.

Effects on the soil:

Soil is comprised of thousands of microbes and invertebrate organisms
with more complex forms of animal life. Plant and tree roots, seeds, and several
fungi are a large part of these microhabitats.

g
We include the information on the surfactant Syndets because in the case of spraying in
Colombia, there have been many changes in the formulations used, including changes in
surfactants.ANNEX 152

The microorganisms in the soil play an extensive role in the
decomposition of organic material and the production of humus, the

recycling of nutrients and energy and element fixation, the metabolism of
the soil and the production of compounds that cause the formation of
aggregates. Many microorganisms are in symbiotic relations with plants
and animals, fixing nitrogen for them in the first case and microbes of the

intestines in the second. They function as a substantial part of the food
network.

Among the microorganisms that are found in the ground are bacteria ,
actinomycetes, fungus, microalgae, protozoa, nematodes, and other
invertebrates (mostly arthropods). 51

The effects of the surfactants and other additives used in the spray
formulations apparently have not been investigated in soil, nor have the effects of

Currently it is stated that they are using one or two additional surfactants added to

Roundup (which already contains a surfactant). One of these is called Cosmoflux
IND. We do not precisely know the chemical nature of Cosmoflux, but we hope
that it is not the same ingredient as is found in Syndets.

[PAGE 21]

the formulations well known as “Roundup.” But glyphosate as a separate

chemical has in fact been investigated. Glyphosate was manufactured to be
applied directly to the leaves of plants, but “although glyphosate is not directly
applied to the soil, a significant concentration of the compound can reach the soil
74
during an application.” The studies on the effects of glyphosate in soil can be
divided into four categories: 1) nematodes (all sizes of worms); 2) an increase in
pathogenic fungus; 3) interference with the mycorrhizal relationships among the
funguses, nutrients, and plants; and 4) the effects on microbes.

Glyphosate has negative effects on nematodes and other invertebrate
worms. 48, 156Research in New Zealand shoed the glyphosate had significant
39, 200
effects on the growth and survival of common ground worms.

Glyphosate increases the growth of pathogenic fungi according to much
research published in the scientific literature. As a result, these mushrooms

predominate in an area to release their own toxins (micotoxins), which are toxic ANNEX 152

to many other forms of life nearby, including mammals. That is, in this case, we
are talking about a secondary effect of toxicity. One of the genera that tends to
47, 82, 101, 102, 103, 144,
157, 183, 186he presence of glyphosate is the genus Fusarium,
which until September 2002 was going to be used by the government of
the United States as a bioherbicide (mycoherbicide) in Colombia in order to

eradicate the coca, but the proposal was rejected by the Andean Committee of
Environmental Authorities (CAAAM) and President Clinton. Species of the
Fusarium genus have been responsible throughout the world for serious damage

to many crops, poisoned soil, birth defects in human beings, and in one
documented case, the deaths of thousands of people caused by it micotoxins when
they ate contaminated cereals during the last years of the Second World War. 199

The interference of glyphosate in mycorrhizal relations among fungi,
nutrients and plants was recently published in 1998. A mycorrhizal relationship

is a symbiotic association between the mycelium (the cell body) of a fungus,
especially a basidiomycete (mushroom) with the roots of some plants and trees
where the fungus’s mycelium forms a tight woven cover wrapping around the

small roots or even penetrating the roots. This relationship provides an exchange
of nutrients and water that benefits both the plant and the fungus. In research
performed by a Canadian team led by the scientist M.T. Wan, 183, the noxious

effect of glyphosate was almost as toxic in the symbiotic fungus Glomus
intraradices in carrot roots as the recognized by now prohibited toxic fungicide
benomyl (which was the subject of a successful lawsuit by an Ecuadorian

company against the multinational DuPont). Given that many plants cannot grow
without this mycorrhizal relationship, this is one possible effect of spraying with
glyphosate that we must consider.

Glyphosate also has effects on microbes in the soil. Wan et al., working
at Texas A&M University, reported that “the evolution of CO 2increased when

the rate of glyphosate was increased. The glyphosate significantly stimulated the74, 165
microbial activity measured by the mineralization of Carbon and Nitrogen.”
It has also been shown that glyphosate can reduce the ability of certain bacteria to
39, 201
fix nitrogen.

In sum, there is a lot of documentation on the clear effects of glyphosate

[PAGE 22]

in the biota and ecology of the soil that comes from studies already known in

other parts of the world, and it is likely that more noxious effects are going to be
presented while the matter continues to be studied.ANNEX 152

Effects on beneficial insects:

One of the complaints that was presented with respect to the Roundup

(plus surfactants) spraying program that the United States government undertook
to eliminate poppy crops in Guatemala, was that the apiculture in the areas near
the spraying was destroyed. “Although the spraying program had a minimum
effect on the poppy crop, according to local peasants, the traditional basis of
202, 203
production in the region was destroyed, in particular tomatoes and bees.”
As a result of pressure by environmentalists and others, the spraying program was
suspended and now the poppy crop in Guatemala is being controlled thanks to

manual eradication. Research performed by the International Organization for
Biological Control agrees with the effects reported in Guatemala on bees; it also
shows that there are effects on other beneficial insects.

According to these studies, it was demonstrated that exposure by insects
to one commercial formulation of Roundup (glyphosate plus surfactants) caused
mortality rates in excess of 50% in beneficial insects, including parasitoid wasps,

lacewings, and butterflies. The mortality level was even higher for one type of
predator beetle.204

Monitoring and chemical analysis

Although there are several methodologies for collecting and analyzing
SOME of the components in the formulations that are being sprayed in Colombia,

in freshwater or on the soil, all need relatively advanced scientific equipment in
combination with well-trained personnel. Also, this would require a system of
monitoring stations throughout the border area, especially in the rivers that have
1, 2, 3, 7, 8, 16, 22, 23, 25, 27, 28, 30, 31, 37, 54, 59, 63, 67, 69, 70, 73, 79, 85, 86,
92, 107, 108, 109, 111, 124, 125, 126, 127, 132, 135, 136, 138, 139, 165, 166, 167, 171, 174, 178, 180, 181, 184, 185, 187

To develop a system of this nature would require significant funds, and under

current conditions this seems to be an unfeasible proposal. But, in the ideal case
that financial support could be obtain for monitoring, apart from everything
implied by doing the analyses of the water and soil, it would be necessary that the
following “indicator organisms” be monitored:

Indicator organisms

Aquatic plants, such as green algae
Aquatic invertebrates, such as water bugs
Fish, such as Tilapia or catfish
Amphibians, such as frogs

Nitrogen-fixing soil bacteria ANNEX 152

Soil invertebrates, such as worms

Land plants
Birds
Mammals

[PAGE 23]

Summary:

Based on the studies cited above, it is very likely that at least some of the
ingredients in the formulations used in Colombia cause noxious effects on the
aquatic biota, including fish, amphibians, and insects, as well as on the content

and function of soil. Given that science has not yet been able to catalog most of
the species or even a small percentage of the Colombian or Ecuadorian
ecosystems, spraying pesticides can easily eliminate an entire new species
without us even knowing that it ever existed. This fact can clearly threaten the

future exploitation by Ecuador of its own wealth, in biota and biodiversity. Until
there is irrefutable proof based on impartial scientific research by neutral players
that proves beyond doubt that the massive aerial spraying currently used is
innocuous to our shared ecosystems – not a very likely proposal – according to

the research consulted – we can only conclude that there is a true possibility of
noxious effects from spraying in the Ecuadorian environment. That said, Ecuador
must protect itself with a buffer zone of at least ten kilometers to guarantee its
citizens that the possible noxious effects generated as a result of the chemical

herbicides massively sprayed by air dissipate in the Colombian territory.

[…]ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152ANNEX 152 ANNEX 153

Ecuadorian Scientific-Technical Commission,
Technical Report from the CCTE on the CICAD Document on the Study of the

Effects Produced by Spraying Glyphosate (within the coca crop eradication
program) on the Border Between Ecuador and Colombia (2 June 2005) ANNEX 153

General Department of Border Relations with Colombia

From: ECOTOXICOLOGY[[email protected]]
Sent: Thursday, 02 June 2005 16:34
To: General Department of Border Relations with Colombia
Subject: Re: Circular Note No. 076/05-SSNDF-DGRFC

Dear Messrs. General Department of Border Relations with Colombia

Attached review of the document sent by you.

Sincerely,

Ramiro Castro

Ecuadorian Atomic Energy Commission

03/06/2005

[PAGE 2]

TECHNICAL REPORT FROM THE CCTE ON THE CICAD
DOCUMENT ON THE STUDY OF THE EFFECTS PRODUCED BY
SPRAYING GLYPHOSATE (Within the coca crop eradication program)
ON THE BORDER BETWEEN ECUADOR AND COLOMBIA.

1 Background

The Ministry of Foreign Relations Department of National Sovereignty

and Border Development – DGRFC issued to the CCTE, through Circular Note
16375 of 17 May 2005, the CICAD study called “Study of the effect of the
Program to Eradicate Illegal Crops by Aerial Spraying with the herbicide
Glyphosate (PECIG) and illegal crops on human health and in the environment.”

Likewise the Chancellery of Ecuador – SSNDF-DGRFC sent to the CCTE,
through Circular Note 074-05, of 23 May 2005, as an additional reference, a
study performed by the National University of Colombia on the same subject,
called “Report by the National University of Colombia Institute of Environmental

Studies (IDEA), Remarks on the ‘Study of the effect of the Program to Eradicate
Illegal Crops by Aerial Spraying with the herbicide Glyphosate (PECIG) and
illegal crops on human health and in the environment.’” On the latter, the CCTE
will issue a separate document.ANNEX 153

The Document was prepared by a panel of international experts in human,

animal, and environmental toxicology; in epidemiology in agronomy and ecology
which was called the Scientific Evaluation Team – ECE. The members of this
team were Drs. Keith R. Solomón, Arturo Anadón, Antonio Luiz Cerdeira, Jon
Marshal, Luz Helena Sanin (hereinafter the “panel of experts”). This report was

prepared for the Inter-American Commission for the Control of Drug Abuse
(CICAD) a Division of the Organization of States (OEA).

In general, the report contains valuable information with supporting

documents on the selected subjects and abundant bibliography citations. It will
unquestionably constitute an important reference for future research work related
to risk evaluation in the program to eradicate illegal crops by spraying glyphosate
formulations and other pesticides. However, the document lacks adequate

ordering which affects its order but not its content.

2. Objectives

The CCTE analyzed the text of the study prepared by CICAD, in its
entirety and especially the partial and total results, as well as the methodology
applied, sources, and practical experiments, and data collection performed to
prepare that report.

The comments and remarks issued by the CCTE are institutional in nature
as a function of the representation their members have of their respective national
and international institutions. This technical report was reviewed by each of the

members of the CCTE and duly signed.

3. Summary of the characterization of exposure and effects on human
health and the environment.

The document indicates the definition of the problem as a key step in the
risk-evaluation process. Initially, it takes into account all the activities and
consequences related to spraying, coca production, and

[PAGE 3]

coca processing. It acknowledges that the growth in crops as well as the coca

refining process implies significant repercussions on health and the environment,
from the felling of forests, the use of chemicals to care for the crops, and
processing the drug. However, it acknowledges that the risks cannot be estimated
given that the logistics of collecting data on exposure to persons and the ANNEX 153

environment is very difficult. With this fact, the “panel of experts” performs the
risk evaluation focusing on human health and the environment of the effects

caused by the aerial spraying of glyphosate and the adjuvants used in controlling
illegal crops.

To evaluate the risk of using glyphosate “the conceptual model applied” is

the one used in the agricultural application of pesticides wherein the danger and
the risk are directly related to the toxicity and exposure to the pesticide.
Therefore for human health, the toxicity data are compared to the estimated
exposure for the worst-case data and also for the most realistic data obtained in

other uses of glyphosate.

For acute Exposures, the risks are compared with the acute intoxication
data. The toxicity data for the active ingredient glyphosate is obtained from the

literate and from acute intoxication tests of laboratory animals undertaken with a
mixture of glyphosate and cosmoflux such as the one used in the spraying
program.

It is also acknowledged that the glyphosate used in the eradication
program can contribute to exposure through the food chain and drinking water;
these are estimated and compared with the toxicity data and exposure guidelines
based on chronic intoxication by glyphosate.

When evaluating the ecological risks a similar farming-based mechanism
is used. The exposures are estimated from the worst-case models, the measures
made in other locations and measurements based on samples collected in the

Colombian environment. Due to the frequency of application in the eradication
program (prolonged periods between applications), the ecological exposures
resulting from the spraying operations are acute and are compared with acute
intoxication data.

The toxicity data were obtained from the literature and from tests
performed in the laboratory on standard organisms.

As a human health risk hypothesis it is stated that “Exposures to

glyphosate and its adjuvants do not cause acute adverse effects on persons
exposed by different routes.”

For effects in ecological environments, the hypothesis is that “Exposures

to glyphosate and its adjuvants as employed in the poppy and coca eradication
programs do not cause acute or chronic adverse effects in non-target organisms
exposed by different routes.”ANNEX 153

To characterize exposure in the risk evaluation, the risk behaviors
identified in general are related to the frequency of use of pesticides in

agriculture, washing the equipment in water sources used by people, improper
disposal of empty containers, consumption of food during application, and the
improper use of protection suits. This behavior is different from the aerial
application of glyphosate.

[PAGE 4]

There are two human groups exposed: Sprayers (Applicators) and those

present. “The panel of experts” indicates that in Colombia there were no
available measurements of the exposure of sprayers; however, they estimate that
it is similar to that of sprayers in other situations (forestry and agriculture).
According to the document, the maximum estimated exposure in applicators

through all routes is 0.056 mg/kg body weight. For those present, body exposure
in the worst of cases would be 0.08 mg/kg of body weight approximately. All the
measurements of these exposures are considerably below those estimated as
rational values in the case.

For environmental exposures, the chemical glyphosate is important to
determine its use in the environment. Its presence in the air is unlikely due to the
physiochemical properties duly documented and established in the literature,

glyphosate is not very volatile. In the ground it is absorbed significantly by
organic matter therefore it possesses little motility. It is very soluble in water.

In Colombia a study was performed to monitor surface water in five locations to

characterize the concentrations of glyphosate and AMPA in a 24-week period.
The samples were sent to Canada for analysis, the results obtained indicated that
only two samples had limits in excess of the quantification limit of the analysis
method which was 25 ug/L. These data suggest that little or no contamination

with glyphosate has occurred in surface waters, the concentrations found were for
the most part below the method’s detection limit.

In the characterization of effects, there is little epidemiological evidence

that associates glyphosate with any specific illness in humans. The effect of
glyphosate on non-target environmental organisms, on aquatic animals, shows
zero risk for glyphosate. However the risk on fish and other aquatic organisms is
increased with the presence of the surfactant in the formulation more than with

the glyphosate itself.

4.0 Summary of the Conclusions Proposed by “The panel of experts” ANNEX 153

Relevance for human health: According to the report, the risks for people
and for human health from the use of glyphosate and Cosma-flux are minimal.

The acute toxicity of the formulated product and Cosmo-flux for experimental
animals is very low, the likely exposures are low and the frequency of exposure is
low. When these risks are compared with other risks associated with the
production and processing of cocaine raw material, they are essentially negligible.

EcoloRgilalance : The risks of the direct effects on ground wildlife
such as mammals and birds was deemed negligible as well as for beneficial
insects such as bees. However, they note that there could be moderate risks for

some wild aquatic animals in some locations where there are static bodies of
surface water located near coca crops when they are sprayed accidentally. When
taken within the context of the environmental risks of other activities associated
with the production of cocaine, the risks associated with the spraying program are

slight.

According to the report, the applications of glyphosate are well characterized.
Latest-generation equipment is used. The application sites and areas are well

documented. The mixture and application rates are well characterized and the

[PAGE 5]

likelihood that greater quantities of glyphosate and Cosmo-flux than those
specified is slight. The resulting concentration in the soil and water which may
result from accidental spraying is also very certain. The environmental behavior
of glyphosate is well characterized and under the usage conditions in the

eradication program in Colombia the glyphosate is not persistent, it will not
accumulate, nor biomagnify in the environment. The analyses of the surface
waters and sediments did not disclose the presence of significant concentrations
of the compound, which confirms the conclusion based on its properties that it is

immobile in the environments where it is applied, regardless of the pattern of
usage.

The lack of information on the characterization of exposure rests on the

lack of precise measurements in the fields sprayed near the surface waters.

Exposure by people : The exposures of people to glyphosate in the studies
performed in other countries was estimated and it is believed that they are

accurate with respect to the persons present who were sprayed directly. It was
assumed that the exposures were slight and that in all cases they were
considerably below the threshold of importance.ANNEX 153

The glyphosate application rates used to eradicate coca are slightly higher than
those used in conventional agriculture, which suggests that the exposures

measured under these conditions might not be applicable to the exposures of
those present in the eradication operations in Colombia. There is less information
available on the likelihood of exposure in returning to the coca crops immediately
after spraying. Exposures under these conditions have not been measured.

Environme effeclts : According to the toxicity data provided by the
literature glyphosate is in and of itself of low toxicity for non-target organisms;
however, there are a certain number of formulations on the market that contain

different surfactants and/or adjuvants that are more toxic. Due to this, the panel
performed several toxicity tests with the formulated glyphosate product plus
Cosmo.Flux® as used in the eradication program in Colombia. The recent
studies have reported that amphibians such as frogs are among the aquatic

organisms most sensitive to the glyphosate formulations such as Roundup and
Vision. Toxicity studies have not been performed in amphibians with the
glyphosate plus Cosmo-flux mixture and this is a source of some uncertainty on
the ecological risks for frogs.

Effects on humans : There is significant evidence and data on the effects
of glyphosate and its risks for humans. In all cases glyphosate has been deemed
low-risk. However, some of these studies on which these evaluations were made

were performed before the refining of the test guidelines and the availability of
new and more sensitive methods of analyzing and characterizing effects, such as
those based on changes in the concentrations of neurotransmitters and their
metabolites in the central nervous system. Changes in the regulator state of

glyphosate must be supervised and any new effect identified must be included in
the update of the risk evaluation.

There is abundant literature on the epidemiology of pesticides and the

possible effects on human health. As a result of the recent work, it is clear that
many epidemiological studies are confounded by the use of improper, inexact
studies of exposures to pesticides. The panel also performed a preliminary

[PAGE 6]

epidemiological study to evaluate the possible associations between the use of
glyphosate and the adverse effects on human health and it acknowledges that, for

clear logistical reasons, there are no exposure measurements available for the
different groups involved in the study other than those for using glyphosate for
eradication operations in the region. The results of this study do not suggest that ANNEX 153

there is any association between the use of glyphosate in the spraying program
and the time to get pregnant as a result in reproduction.

Risk evaluation and confounding factors : The panel acknowledges that
the substances used in the production and processing of cocaine represent a
significantly greater hazard both for people and for the environment that the

mixture of glyphosate and Cosmo-flux used in the eradication program in
Colombia. The lack of information on these usage conditions for these
substances exacerbated these dangers.

5.0 Conclusions of the members of the CCTE

This document is important in the field of science because it has contributions
that should serve as a basis to continue with the more specific studies to evaluate

the risks of using formulations of glyphosate in the spraying program taking into
account other types of effects of exposure on human health (effects on
chromosomes) and on aquatic organisms.

There is a contradiction in the presentation of CICAD’s conclusions because
when defining the problem the “panel of experts” indicates that is not possible to
do a risk evaluation in planting and processing activities due to the inability to
gather data. However, they conclude that the risks associated with the use of

glyphosate and Cosmo-flux in the coca eradication program in Colombia are
related to the total impact of coca product according to the definition of the
problem stated in this study.

Mechanisms must be found that allow measurements to be taken of the
formulation concentration of glyphosate and Cosmoflux near the fields where the
spraying is done to characterize the degree of exposure both of people and in the
surface waters.

In terms of the analysis of the effects of using glyphosate and Cosmo-flux, a
question arises, it is that the actual concentration of the formulation in the spray
application to eradicate the crop is not known. According to the conceptual risk-

evaluation model, the degree of exposure is in relation to the formulation
concentration, therefore the estimates of exposures of people in the studies
performed in other countries lack validity in relation to the actual place of
application.

The CICAD researchers recommend “performing more specific studies,” which
supports our asseveration that the aforementioned study must not in any mannerANNEX 153

be deemed “conclusive.” Moreover when parameters such as Genotoxicity have
hardly been mentioned, without further analysis.

It would be very useful also to monitor in the northern Ecuador border area
affected by the spraying that might serve as a reference for Ecuadorian
authorities.

[PAGE 7]

An effect on crops from spraying is also evident with rapid recovery of the coca

crops sprayed by successful replanting of coca, however the affected crops in
Ecuador are not coca crops, but rather crops that are the daily food of the border
population, which are not recovered.

Therefore we recommend performing studies in the directly affected populated
areas, and whenever there is an effect on health, the risk analysis must be studied
and proved scientifically.

Quito, 2 June 2005

Ecuadorian Atomic Energy Ministry of Public Health
Commission. Pesticide analysis Inquieta Pérez Institute

Laboratory.
Dr. Marcelo Chiriboga U.
Ramiro Castro Palacios
Chemist Dr. Beatriz Vargas P.

Central University of Ecuador Ministry of the Environment

Dr. Luis Reinoso Garzón Santiago Salazar

Dr. Leonardo Lovato Carlos Valencia, Engineer

Dr. Angelo Nicolalde

PS: This report does not contain contributions from the CCTE members
representing the OMS-OPOS, or the SESA.ANNEX 153ANNEX 153ANNEX 153ANNEX 153ANNEX 153ANNEX 153ANNEX 153 ANNEX 154

United States Environmental Protection Agency, Office of Pesticide Programs,
CICAD Environmental and Human Health Assessment of the Aerial Spray
Program for Coca and Poppy Control in Colombia (Ecological Effects

Assessment) (26 Oct. 2005)ANNEX 154ANNEX 154ANNEX 154ANNEX 154 ANNEX 155

Inter-American Drug Abuse Control Commission (CICAD),
Interim Report on Follow-Up Studies: Environmental and Human Health
Assessment of the Aerial Spray Program for Coca and Poppy Control in

Colombia (July 2006)ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155ANNEX 155 ANNEX 156

United States Department of State,
Report to Congress: A Preliminary Evaluation of the Risk Posed to Colombia’s
Amphibians and Threatened Species by the Government of Colombia’s U.S.-

Supported Program of Aerial Eradication of Illicit Crops (Aug. 2006)ANNEX 156ANNEX 156ANNEX 156ANNEX 156ANNEX 156ANNEX 156ANNEX 156 ANNEX 158

Charles A. Menzie, PhD, Pieter N. Booth, MS & Susan B. Kane Driscoll, PhD,

with contributions/advice from Angelina J. Duggan, PhD,
Charlotte H. Edinboro, DVM, PhD, Anne Fairbrother, DVM, PhD,
Marion Joseph Fedoruk, MD, CIH, DABT, FACMT, Janci Chunn Lindsay, PhD,
Katherine Palmquist, PhD & Brian J. Prince, MRQA,

Evaluation of Chemicals Used in Colombia's Aerial Spraying Program and
Hazards Presented to People, Plants, Animals, and the Environment in Ecuador
(Apr. 2009) ANNEX 158

Evaluation of Chemicals Used

in Colombia’s Aerial Spraying
Program, and Hazards
Presented to People, Plants,
Animals, and the Environment
in EcuadorANNEX 158

Evaluation of Chemicals Used in
Colombia’s Aerial Spraying

Program, and Risks Presented to
People, Plants, Animals, and the
Environment in Ecuador

Prepared for

Government of Ecuador

Prepared by

Charles A. Menzie, Ph.D.; Pieter N. Booth, MS; and Susan B. Kane Driscoll, Ph.D.

with contributions and advice from:

Angelina J. Duggan, Ph.D.; Charlotte H. Edinboro, DVM, Ph.D.; Anne Fairbrother, DVM,
Ph.D.; Marion Joseph Fedoruk, MD, CIH, DABT, FACMT; Janci Chunn Lindsay, Ph.D.;
Katherine Palmquist, Ph.D.; and Brian J. Prince, MRQA

Exponent
1800 Diagonal Road, Suite 300
Alexandria, Virginia 22314

April 2009

” Exponent, Inc.

Doc. no. MY03197.000 0210 0409 CM07 ANNEX 158

April 14, 2009

Contents

Page

List of Figures iv

Acronyms and Abbreviations v

Executive Summary vi

1 Authors and Qualifications 1

2 Approach 3

3 Overview of Chemicals Used in Colombia’s Aerial Spraying Program 4

3.1 Glyphosate 4

3.2 Surfactants 5

3.3 OthPeortealgredients 6

4 Potential for Spray Drift 9

4.1 Spray Operation Parameters 10

4.2 Off-Target Release of Spray 12

4.3 Ground-BasHeostilities 13

4.4 Localizedeaternditions 13
4.4.1 ThermaIlnversions 14

4.4.2 Local inCirculation 14
4.4.3 Variations in Wind Speed between the Airport and Mission

Locations 15
4.4.4 Temperature 15

4.5 EyewitneAccounts 15

5 Hazards to Health, Agriculture, and the Biologically Diverse Ecosystems of

Ecuador Associated with Exposures to Chemicals in the Aerial Spray Mix 17
5.1.1 Health Hazards to Humans 17

5.1.2 Conclusions 20

5.2 HazaAogsriculture 20
5.2.1 Direct Effects on Non-target Crops 20

5.2.2 Chronic Effects on Nontarget Crops 23

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5.2.3 Direct Effects on Domestic Animals 25
5.2.4 Effects on Aquaculture (Fish) 26

5.3 Hazards to Ecuador’s Biodiverse Ecosystems 27

5.3.1 Hazards to Native Vegetation 28
5.3.2 HazardtsInsects 28

5.3.3 Hazards to Aquatic Biota, with Emphasis on Frogs 31

5.4 Hazards Associated with Misuse of Herbicide Products 38

6 Bibliography of Relevant Literature 41

Attachment A Resumes

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List of Figures

Page

Figure 1. Photo of AT-65 spray plane, from Solomon et al. 2005 10

Figure 1. From Solomon et al. 2005. 11

Figure 3. Intensity of aerial spraying conducted in Putamayo along the northwest

Ecuador border during 2001–2004 28

Figure 5. Adult poison dart frogs with tadpoles on their backs 35

Figure 6. Bromeliads plants provide habitat and water for certain tree frogs 36

Figure 7. Eggs laid on plant surfaces and guarded by adults 37

Figure 8. Section 5.0 of label from Roundup Pro as sold in U.S. 40

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Acronyms and Abbreviations

ae/ha acid equivalents per hectare
ATSDR Agency for Toxic Substances and Disease Registry
EPA U.S. Environmental Protection Agency

EPSP 5-enolpyruvylshikimate-3-phosphate
GHS Globally Harmonized System
GOC Government of Colombia
LC50 exposure concentration at which 50% of the exposed organisms

would die
MSDS material safety data sheet
POEA polyoxyethyleneamine

USDA U.S. Department of Agriculture
diameerMean volume

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Executive Summary

This document provides Exponent’s evaluation of the potential hazards to Ecuador associated
with the Government of Colombia’s (GOC’s) application of herbicide spray on illicit crops in
Colombia near the border with Ecuador. Our approach involved:

1. Identifying the chemical constituents (generic categories and/or specific
compounds) in the herbicide spray mixture used by Colombia

2. Examining factors that could result in spray or spray drift entering Ecuador

3. Assessing the potential hazards associated with the spray program.

Our evaluation indicates that the program is atypical of spray programs used elsewhere for weed

control in agricultural settings. Both the customized herbicide formulations used by Colombia
and the enhanced risk of spray drift presented by Colombia’s aerial spraying operations led to
hazards to Ecuador. The following lines of evidence all point toward the potential for hazards
associated with the spray program.

Colombia’s efforts to enhance the efficacy of the herbicide formulation heightens the
potential for adverse effects

x While the active agent in the formulation—glyphosate—is well known and
commonly used safely in numerous agricultural applications, Colombia
engaged in an experimental program to heighten the efficacy of their

formulations.

x The compositions of these formulations changed over time, and there is
considerable uncertainty regarding what was added to the formulation.
Government reports indicate that additives, including formaldehyde and

various surfactants, were included; further additives have been tested as
possible constituents.

x There has been a concerted effort to improve the efficacy of the formulation
to kill coca plants, and this has entailed the addition of surfactants and/or

other additives that are not currently used in U.S. formulations. While the
exact composition and amounts of the various surfactants and other additives
are unknown, the addition of these chemicals brings with it increased hazards
to non-target plants, agriculture, agriculture, the environment, and potentially

to people.

Numerous factors increase the likelihood of spray drift

x The likelihood of spray drift is increased when pilots fail to recognize or
adhere to operational and environmental constraints for spraying.

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x Thermal inversions and variable wind speeds would lead to increased drift.

Both occur along the Ecuador-Colombia border. In particular, thermal
inversions would not be recognized by pilots.

x The area that receives spray drift increases as release height is increased.
Several lines of evidence indicate that pilots would release spray at heights in

excess of the forest canopy and well above the uneven terrain. The presence
of hostile ground fire would also raise the heights of release.

x The area affected by spray drift increases with decreasing droplet size.
Evidence indicates that conditions could lead to smaller droplets and thus an

increase in spray drift.

x Studies of spray drift conducted in the United States have shown that
depending on environmental factors, a substantial portion of the spray can
leave the target area as spray drift and can be carried for miles beyond the

target.

Chemicals in the spray drift would pose a hazard to people

x Irritation of the eyes, skin, and throat are among the most common and
consistent effects reported by people in Ecuador and Colombia who claim
they have been exposed to spray. These effects are associated with the types
of chemicals known to be included in the spray, particularly the surfactants

that are common to glyphosate formulations.

x Reports of nasal and throat irritation and breathing difficulty are consistent
with the effects that could occur from inhalation of glyphosate formulations.

x Nausea, vomiting, and diarrhea have been reported by a number of people
following spray events. These types of effects are consistent with those that

could occur from ingestion of Roundup formulations or one or more chemical
constituents added to the spray mix. Exposure could occur from ingestion of
local exposed water or food or from inhalation of foul-smelling spray.

x Many of the reports of adverse effects following spray events have involved

children. Ecuadorian children may be vulnerable to certain effects of the
herbicide formulations by virtue of either greater exposure potential and/or
possibly greater sensitivity to one or more of the chemicals in the
formulation.

x Children with underlying nutritional deficiencies and malnutrition may be
particularly vulnerable to diarrhea, should this occur as a result of exposure to
the herbicide formulation. Diarrhea is a concern, because it causes
dehydration and could lead to other health effects.

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Chemicals in the spray drift would pose a hazard to agricultural crops, domestic
animals, and fish

x Spray drift that falls upon non-target crops can kill or damage those plants.

The drift associated with Colombia’s customized formulation includes
additives that increase the effectiveness of the herbicide. Therefore, this drift
would be more toxic to non-target crops than would comparable exposure to
more standard formulations.

x The reported long-term lowered or impaired productivity of crops such as

coffee, yucca, and plantains are consistent with potential effects of the
formulation. These long-term effects could arise from weakening of the
plants and rendering them more susceptible to infections by fungi,

nematodes, and other parasites. Formulations have also been reported to
result in diminished soil productivity by adversely affecting nitrogen-fixing
plants and their symbiotic fungi.

x Reported effects on domestic animals are consistent with potential hazards

associated with the types of chemicals in the formulation. These include the
direct effects that lead to irritation of eyes, skin, and throat. Exposure to
additives that cause eye, skin, and systemic conditions would reduce the
productivity of food-producing animals (decreased weight gain or

reproductive performance). In general, young animals are more susceptible
to these types of stress-related effects than are adults. Spraying with
glyphosate-based herbicides may also reduce the local food supply for
domesticated animals, which may lead to decreased body condition and

performance in livestock and other farm animals.

x Reports of fish kills in fish aquaculture ponds and other water bodies
following spray events are consistent with direct and indirect effects of
chemicals in spray drift. Some of the additives are recognized as toxic to

fish. In addition, spray can result in the death of aquatic plants and algae that
grow densely in fish ponds. The death of these plants increases the
biochemical oxygen demand, which can lead to loss of oxygen and
asphyxiation of fish.

Chemicals in the spray drift would pose a hazard to Ecuador’s biologically diverse

ecosystems

x Biologically diverse ecosystems within Ecuador near the border with
Colombia would experience exposure to spray drift that crosses the border.

x Plant communities are a critical component of Ecuador’s biologically diverse
ecosystems. As already noted, plants are especially susceptible to the toxic
effects of herbicide formulations. Many of the native plant species are

expected to be much more sensitive than coca to the effects of the spray.

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x Insects are recognized as emblematic of Ecuador’s biodiversity. These

animals are especially susceptible to the toxic effects of surfactants and other
additives in herbicide formulations.

x Amphibians are also recognized as indicative of Ecuador’s biodiversity.
These animals are especially vulnerable to spray drift for three reasons. First,

frogs are especially sensitive to the toxic effects of the chemicals in the
formulation. Second, numerous frog species in Ecuador live a primarily
terrestrial existence among the vegetation. The terrestrial environments that
they inhabit would receive spray drift, either directly or indirectly, from

droplets that accumulate on vegetation. Third, amphibians would be
susceptible at multiple life stages. The young tadpoles of terrestrial frogs
may live and grow in small pockets of water. These pockets are substantially
smaller than those typically assumed for the purpose of evaluating sprayed

biocides. An adequate assessment of the risk presented to amphibians must
consider these ecological factors.

Conclusion

We have visited the border region and interviewed villagers who have been exposed to spray
drift and/or who have experienced adverse effects following spray events. We find the reports
of effects to be credible based on the factors presented above. In particular, we considered the

potential for spray drift to enter Ecuador; whether there is a complete exposure pathway that
links spray events in Colombia to exposures of people, plants, animals, and the environment in
Ecuador; the degree of consistency between the reported effects and the chemicals in the spray
mixture; the sensitivity of human and ecological receptors; and whether the reported effects can

be correlated over time and by location with the areas most likely to be affected by the spray.
When these factors are considered together with the reports of effects and the potential for
chemicals in the spray to cause those effects, the collective information is coherent and supports

the conclusion that spraying along the border poses hazards to the people, agriculture, and
ecosystems of Ecuador.

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1 Autha onudalifications

This report was prepared by scientists at Exponent. The assessment covered a broad range of
subject areas, so the review team comprised a number of individuals with the specific expertise
needed to review the various aspects of the assessment and render their views on the nature of
exposures and effects. The expertise of these scientists is described in Attachment A. The
authors of this report include:

x Charles Menzie, Ph.D.—Dr. Menzie was responsible for overall evaluation
of potential risks associated with spray practices. Dr. Menzie is an expert in
the areas of risk assessment and environmental fate and transport of
hazardous chemicals, with a strong background in biology.

x Pieter Booth, M.S.—Mr. Booth was responsible for direct observations in
Ecuador and assessment of ecological effects. Mr. Booth is an expert in

ecotoxicology, risk assessment and determination of the causes of ecological
damage, with a strong background in biology, ecology, and marine issues

x Susan Kane-Driscoll, Ph.D.—Dr. Kane Driscoll was responsible for
assessing ecotoxicity of the spray mixture to aquatic biota and plants. Dr.
Driscoll is an expert in aquatic toxicology, with special expertise in
environmental chemistry and sediment toxicity, and a background in natural
resources and environmental sciences.

The authors were assisted by the following contributors and advisors:

x Marion J. Fedoruk, M.D., C.I.H., D.A.B.T., FACMT—Dr. Fedoruk was a
contributor and advisor on the direct and secondary effects of the chemicals

in the mixture. Dr. Fedoruk is a medical toxicologist with special expertise in
exposure and effects assessment following environmental and occupational
exposures to hazardous chemicals.

x Angelina Duggan, Ph.D.—Dr. Duggan considered issues related to toxicity
of glyphosate as amended with various surfactants, with emphasis on human
health effects. She integrates toxicology, biomonitoring, exposure,
physicochemical, and epidemiology data to address regulatory requirements
and conduct human health environmental risk assessments. She is also

experienced in the application of Structure Activity Relationships (SAR) and
cluster analysis.

x Janci Chunn Lindsay, Ph.D.—Dr. Chunn Lindsay considered issues related
to mammalian toxicity data for herbicide mixtures. Dr. Lindsay specializes in
the evaluation of complex dynamics of toxicity, including exposure routes,
pharmacokinentics, and dose-response relationships, and has a background in
biochemistry and biology.

x Brian Prince, B.Sc., MRQA—Mr. Prince was a contributor and advisor on
the secondary effects on plants and the significance of labeling. Mr. Price

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specializes in pesticide effects and efficacy, and the regulatory process of
agrochemicals, and has a background in agricultural sciences.

x Charlotte H. Edinboro, D.V.M., Ph.D.—Dr. Edinboro’s experience in
epidemiology includes cancer epidemiology, nutritional epidemiology,

exposure assessment, and pharmacoepidemiology. Her research interests
include potential impacts of dietary and environmental exposures on the
thyroid, small-animal population disease control, and companion animals as
sentinels for human health.

x Anne Fairbrother, D.V.M., Ph.D.—Dr. Fairbrother has more than 30 years
of experience in ecotoxicology, wildlife toxicology, contaminated site
assessment, and regulatory science for existing and emerging chemicals in
the U.S. and Europe. She has conducted large-area (>100 sq mile) risk

assessments in tropical, desert, and mountain ecosystems, determining risk
thresholds for plants and wildlife.

x Katherine Palmquist, Ph.D.—Dr. Palmquist has a strong interdisciplinary

background in insect biology/physiology, toxicology, integrated pest
management, and communications. She has experience in aquatic
entomology and aquatic toxicology concerning the sublethal effects of
insecticide exposure to aquatic invertebrates, specifically aquatic insects.

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2 Approach

This document provides Exponent’s evaluation of the potential hazards to Ecuador associated
with the Government of Colombia’s (GOC’s) application of herbicide spray on illicit crops in
Colombia along the border with Ecuador. The method involves:

1. Identifying the chemical constituents (generic categories and/or specific
compounds) in the herbicide spray mixture used by Colombia

2. Examining factors that could result in spray or spray drift entering Ecuador.

3. Assessing the potential hazards associated with the spray program.

The factors that we considered in arriving at our conclusions include the potential for spray drift
to enter Ecuador; whether there is a complete exposure pathway that links spray events in

Colombia to exposures of people, plants, animals, and the environment in Ecuador; the degree
of consistency between the reported effects and the chemicals in the spray mixture; the
sensitivity of human and ecological receptors; and whether the reported effects can be correlated
over time and by location with the areas most likely to be affected by the spray.

Using these factors, we reviewed the available information to determine whether they
constitute an overall, coherent weight of evidence with respect to potential hazards posed
to Ecuador from spray drift that crosses the border from Colombia. Consistent with

recent U.S. Environmental Protection Agency (U.S. EPA 2003a) cumulative risk
approaches, we recognize the importance of beginning with the potentially affected
communities. These include the individuals who have reported various health effects
and damages to agriculture. These individuals either experienced spray drift or observed

consequences following spray events to their crops, domestic animals, and in some
cases, native species. Our technical analysis serves as a means of assessing the
connection between the reported effects in Ecuador and the effects that could be caused
by the spray.

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3 Overview of Chemicals Used in Colombia’s Aerial

Spraying Program

Under its aerial spraying program, the GOC has conducted large-scale coca (Erythroxyllum
coca) eradication activities near Ecuadorian territory, using aerially applied herbicides. The
herbicide reportedly used is composed of a customized mixture containing glyphosate

(commonly formulated as Roundup) and other chemicals that include surfactants and possibly
other additives. The exact mixture used by GOC is unknown—it has been kept confidential,
and we are not aware of any independent chemical analyses, other than an analysis of the
percent glyphosate in various formulations (Springborn 2003). The addition of various
surfactants and additives to enhance the effectiveness of the herbicide formulation has been the

subject of research by the U.S. Department of Agriculture (USDA) (Collins and Helling 2002),
and the composition of the formulation used in Colombia changed several times between 1994
and 2002 (Helling and Camp, date unknown). The composition of this mixture was modified at
least once to address concerns regarding eye irritation (U.S. Department of State 2002a). In the

following subsection, we describe the characteristics of glyphosate, surfactants (a class of
chemicals added to glyphosate to increase its effectiveness), and other possible additives. This
section includes a brief discussion of the health and environmental effects of these compounds;
Section 5 contains a more detailed discussion.

3.1 Glyphosate

Glyphosate is a post-emergent, systemic, non-selective herbicide that is used widely for weed
control in agricultural and non-agricultural applications. Non-agricultural applications include

forestry, roadways, and other non-crop sites where total vegetation control is desired.
Glyphosate is a highly effective herbicide. With the exception of genetically-modified
glyphosate-resistant crops, glyphosate is a highly effective herbicide that affects most species of
plants.

Glyphosate disrupts the function of plant cells. It is an analogue of the amino acid glycine, and
it inhibits production of the aromatic amino acids phenylalanine, tyrosine, and tryptophan. This
is achieved by competitive inhibition of the enzyme 5-enolpyruvylshikimate-3-phosphate
(EPSP) synthase. EPSP is a key enzyme in the shikimic acid pathway for the synthesis of

chorismate, a precursor for the amino acids phenylalanine, tyrosine, and tryptophan (Grossbard
and Atkinson 1985; Giesy et al. 2000). The shikimic acid pathway occurs in all plants, bacteria,
and fungi. Inhibition of the synthesis of these amino acids arrests protein and enzyme
formation. The shikimic acid pathway does not exist in animals, which obtain amino acids from
the diet.

Glyphosate has also been shown to interrupt the synthesis of the photosynthetic pigment
chlorophyll, inhibit the production of phenolic compounds (e.g., indole acetic acid, a plant
growth hormone that stimulates mainstem growth), and can lead to a buildup of ammonia in
various tissues because of the disruption to protein synthesis (Kearney and Kaufman 1976;

Grossbard and Atkinson 1985). These effects are either results of or are considered secondary

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toxic effects of the inhibition of aromatic amino acid production (Grossbard and Atkinson

1985).

A plant treated with glyphosate will initially stop growing. Cessation of growth can be followed
by yellowing of tissue (chlorosis), drying of leaves, leaf drop, scorching or curling of leaves,
retardation of shoots, leaf deformation, bud proliferation, and finally necrosis (death). Unlike

the acute effects of many other herbicides, glyphosate can also cause chronic toxic effects that
can persist for many years in perennial plants and crops (Grossbard and Atkinson 1985). As
discussed in more detail in Section 5, research indicates that glyphosate use may cause long-

term impacts to soil conditions, microorganism communities in the soil, and nutrient uptake by
plants.

3.2 Surfactants

The spray used by GOC includes surfactants in addition to the glyphosate described above. The
purpose of adding surfactants to the glyphosate is to increase the uptake of glyphosate by plants
and thus increase the effectiveness of glyphosate at killing plants. Surfactants increase the

efficacy of the herbicide by improving adherence to the plant, enhancing the spread, dispersion,
and penetration of the herbicide into plant tissues by disrupting the waxy cuticle on the foliage,
and reducing the surface tension of the formulation on the surface of the plant (Solomon et al.

2005; Franz et al. 1997). Various types of surfactant compounds are available, including
anionic, cationic, amphoteric, and nonionic surfactants, and many different types of surfactants
have been used to enhance the effectiveness of glyphosate as an herbicide. In short, an aerial
spraying program could use any one of a number of surfactants, each with different chemical

compositions and effects.

Generally, because it is Confidential Business Information, the specific surfactants used are not
publically available; however, the spray used by GOC is reported to include at least two:
polyoxyethyleneamine (POEA) and Cosmo-Flux 411F, which are discussed briefly below.

The commercial Roundup product used by Colombia contains POEA, which is also known as
tallow amine ethoxylate (CAS RN 61791-26-2). POEA is a mixture of alkyl amine ethoxylates.
This compound has been reported in animal tests to cause severe skin irritation, be corrosive to

the eyes, and an irritant to the gastrointestinal tract (U.S. EPA 2003B).

U.S. EPA (2003) also describes another component of the glyphosate product is described in an
EPA report, but does not identify the specific chemical. This second component of the

glyphosate product is described as potentially causing mild, transient eye irritation (U.S. EPA
2003B).

Cosmo-Flux 411F, which is produced in Colombia, but not manufactured or used in the U.S., is
an additional surfactant used in the glyphosate formulation for the eradication of coca. The

complete chemical composition of Cosmo-Flux 411F is not publically available. The U.S.
Department of State (2002b) reports that it is composed of polyol fatty acid esters and
polyexothylated derivatives (17%) and inert liquid isoparaffins (83%).

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The health and environmental effects of the surfactants, either alone or in combination with
glyphosate, are described in more detail in Section 5.

3.3 Oth PeortentIiagl redients

Herbicide mixtures often contain a complex combination of chemicals. To our knowledge, the
specific formulation of the herbicide spray used in Colombia’s aerial spraying program has not
been disclosed. We do know, however, that a number of chemicals have been specifically

evaluated for inclusion in the herbicide spray for coca eradication, and it is possible that one or
more have been included.

According to the U.S. State Department audit reports, agricultural scientists from USDA have
assisted in evaluating and guiding the herbicide application program in Colombia. USDA

scientists also have been conducting research to identify herbicide formulations that would be
especially effective at eradicating coca (Collins 2000; Collins and Helling 2002). The results of
that research provide insights into the likely additives to the herbicide formulation used in
Colombia. The 2002 study examined the effectiveness of 16 additives to the herbicide
formulation, including cationic, nonionic, or mixed surfactants, in aqueous or oil-based carrier

systems. Several of the additives listed below were identified as enhancing the efficacy of
glyphosate for controlling coca. Ultimately, two glyphosate/surfactant mixtures were found to
effectively increase the phytotoxicity to coca: a mixture labeled COC/OSI-U (a combination of
crop-oil concentrate, Agri-Dex, and organosilicone [Silwet L-77]) and another called

CAT/ANA (a cationic surfactant/anionic surfactant [Optima]). The authors report that, as a
consequence of these studies, the glyphosate mixture used in Colombia for coca eradication was
modified, and the efficacy of the mixture at killing coca plants was improved. Formaldehyde
has also been mentioned as an additive in the Colombia aerial spraying program (USDA 2001).

Thus, although we have no confirmation, it is entirely possible that the spray mixture has
included one or more of the following chemicals or similar additives:

x Silwet-77

x Other organosilicone surfactants

x Crop oil concentrate

x Agri-Dex

x Optima

x Atplus 300F

x Defoaming agents (Cosmo-In-D)

x Formaldehyde.

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Each of these chemicals can cause human health or environmental effects. A summary of the
types of effects associated with these chemicals was derived from their labels and Material
Safety Data Sheets (MSDSs) and other sources and is provided as follows.

Silicone-based surfactants are included in glyphosate-based herbicides to prevent the loss of

herbicide from leaf surfaces during rain events, and are therefore suitable for use in high-
precipitation climates (Franz et al. 1997). As a class of compounds, organosilicone surfactants
are noted to cause eye and skin irritation.

Silwet L-77 is an organosilicone surfactant that has the potential to harm the human reproductive
system, as stated on its label. Repeated ingestion may lead to liver and thyroid injury, as well as
injury to reproductive systems. The carcinogenicity of the substance is not known, because it is

a proprietary blend of substances. It may also cause irritation to the mouth and throat,
abdominal discomfort, nausea, vomiting, and diarrhea. Prolonged or widespread skin exposure
may result in absorption of potentially harmful amounts. Prolonged skin contact may cause
itching, with redness and slight swelling. Repeated ingestion may cause liver, kidney, thyroid

damage, and harm to the male and female reproductive system and blood system. Skin contact
may aggravate existing dermatitis. Prolonged exposure to the eyes may cause discomfort, with
swelling of conjunctiva. It is highly toxic to fish and introduction to water bodies should be
avoided. The chemical is persistent and may cause long-term effects on aquatic systems.

Crop oil concentrate causes eye irritation.

Agri-Dex can cause mild to moderate irritation to eyes, skin, and throat. A precautionary

statement notes that is that it is hazardous to humans and domestic animals. Over-exposure may
result in formation of granulomas.

Optima can cause potential severe eye irritation, and direct contact can damage the eye. It is a
slight skin irritant but can be a skin sensitizer. According to the Optima brand label, it is

harmful if inhaled.

Atplus 300F can cause eye and skin irritation.

Defoaming agents can cause eye irritation. The labels for defoamers often require those
engaged in their application to wear full personal protective equipment and warn against
allowing the chemical to contaminate foodstuffs, feed, or fertilizer.

Formaldehyde is very hazardous in case of eye contact (irritant), or ingestion, and is hazardous

in case of skin contact (corrosive, irritant, sensitizer, permeator), or eye contact. It is a mutagen
and carcinogen.

In addition to the additives described above that enhance the herbicide’s toxicity to plants,

glyphosate formulations can also contain other herbicides. A combination of herbicides can
increase the toxicity to exposed plants. For example, some glyphosate formulations include a
2,4-D IPA salt (Nalewaja and Matysiak 1992). Herbicide mixtures containing glyphosate and

2,4-D are toxic, but in some cases, the toxicity progresses slowly, so poisoned plants may not
exhibit symptoms for several weeks (Baylis 2000). Fungal plant pathogens, such as Alternaria,

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Colletotrichum, and Fusarium, have also been used to enhance he herbicidal action of
glyphosate (Franz et al. 1997).

The possibility that the spray applied by Colombia has contained various potentially toxic
constituents is supported by the extensive literature documenting field applications of
glyphosate in combination with many adjuvants and other herbicides. For example, Franz et al.

(1997) discuss glyphosate compositions, additives, and mixtures in detail. The authors
document field applications that have enhanced the effectiveness of glyphosate, including a
wide range of surfactants, oils and emulsions, ammonium sulfate, quaternary ammonium
compounds, urea, humectants (e.g., glycerol, sorbitol, and polyethylene glycol), and other

herbicides such as 2,4-D, dicamba, diphenyl ether herbicides, surfonylureas and imidazolinone
herbicides, and chloroacetimide herbicides (alachlor and metoachlor). In the absence of
definitive chemical analysis of the spray material, these and other potential additives cannot be

ruled out as being present in the spray mixture and are potentially responsible for additional
adverse effects in Ecuador.

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4 Potential for Spray Drift

Exposures of the people, plants, animals, and the environment of Ecuador to the spray mixture
may occur if there is direct overspray or when the spray drifts over the Colombia/Ecuador
border. There is no doubt that aerially applied herbicides drift, or spread laterally, from the
point of intended application. Drift leaving the target area can represent a substantial amount of

the applied herbicide (U.S. Congressional Office of Technology Assessment, 1990). Under
optimal conditions, most of the spray deposits on or near the target. However, studies have also
shown that pesticides delierved through aerial spraying can be transported miles in the drift
(Currier et al, 1982; Murray and Vaughn, 1970; Westra and Schwartz, 1989; Robinson and Fox,

1978); these studies have indicated that spray drift may extend as far as to four to ten miles.

In this section of the report, we describe some of the factors that would tend to increase the
atmospheric transport of spray into Ecuador. Factors that affect spray drift include those

associated with the spray operation itself and those associated with environmental conditions
during spray events. The following operational factors are important in determining the extent
and severity of spray drift:

x Spray operation parameters

 Meteorological conditions (wind speed, humidity, temperature,
inversions)

 Elevation above ground of the aircraft flight path

 Airspeed during spraying

 Size distribution of droplets

x Off-target release of spray.

The following environmental conditions exacerbate the areal extent and severity of spray drift:

x Ground-based hostilities

x Localized weather conditions.

In each case, the information we have obtained about the spray events suggests that the
conditions are conducive to drift that would extend considerably farther than would otherwise

occur during spray applications in temperate climates, on flat land, and under more controlled
conditions.

We also summarize eyewitness accounts of spray events that corroborate the intrusion of the
spray into Ecuador.

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4.1 Spray Operation Parameters

The manner in which the spray mixture is released can significantly affect the amount of drift.
Variations in spray operations can include changes in the heights at which spray is released, the
precision with which the application system is turned on and off, the amount of spray used, and

the ambient conditions present during spray events.

Herbicide product documentation typically includes recommendations for application, in large
part to minimize drift. For example, the product label for the commercial product Roundup SL
in Colombia provides the following guidance and recommendations for aerial application:

x Only apply under the following atmospheric conditions

 Air temperature below 29q C

 Relative humidity greater than 60%

 Wind speed less than 7 kph

 Absence of thermal inversion

x Release spray at a height of 2 m above crop.

These instructions are in contrast with operational parameters that are described for Colombia’s
aerial spraying program. There are several documents that refer to operational parameters for
Colombia’s aerial spraying activities, but it is not clear which set of parameters is supposed to

be followed. The operational parameters that have been documented differ considerably from
the parameters recommended on the product label, and each of these differences will tend to
favor extended spray drift.

Atmospheric conditions. Operational parameters restrict the atmospheric conditions under

which spray operations may be carried out. According to U.S. Department of State (2002a),
spraying guidelines are less strict than those indicated on the product label for the commercially
available Roundup SL. For example, U.S. Department of State (2002a) asserts that missions are
cancelled if wind speed at the airport is greater than 10 mph (16 kph), as compared to the limit

of 7 kph specified on the product label. Colombia’s Environmental Management Plan (GOC
2003) specifies a maximum ambient temperature for aerial application of 35° C (as compared to
29° C for the product label). Similar spray-mission parameters are documented by Solomon et
al. (2005).

Aircraft speed. In addition to the parameters described above, operational parameters are also
defined for aircraft speed. Although application rate is apparently automatically calibrated to
compensate for variations in ground speed, elevated flight speeds will likely result in an increase
in drift due to increase turbulence. Turbulence can cause spray droplets to break apart, and

these smaller, lighter droplets have a potential to be carried further by wind currents.

The U.S. Department of State (2003) has reported that aircraft flight speed during eradication
operations is 165 miles per hour. A U.S. Department of Agriculture report (USDA 2001)

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indicates that spray planes operate at speeds of over 200 miles per hour. Further evidence that
maximum flight speeds are exceeded is provided in at least one reported accident (reported in
the U.S. Department of State Audit [USDA 2001] Document 188262548):

The crash investigation report revealed two significant factors that may have

contributed to the crash. First, the speed of the aircraft was in excess of normal spray
operations. Second, the coca field being sprayed had a slightly rising terrain in the
direction of travel. This would make it more difficult for the pilot to notice a tree that

was above the normal tree line.

Application altitude. The height at which the spray is released strongly influences spray-drift
distances and deposition rates. The closer to the ground, the more likely that drift is reduced.

Mission parameters call for spray to be released at altitudes not to exceed 30 m above coca or
poppy fields, which is 15 times higher than the application height indicated on the product label.
It appears that the application is sometimes made at even higher altitudes. For example, the
GOC’s Environmental Management Plan (GOC 2003) states, “The highest application altitude

will be 50 m; notwithstanding, the operation will be conditioned to the height of the obstacles
present in the target spraying zones.” Additionally, as we discuss below, conditions along the
Colombia/Ecuador border would lead pilots to release spray at higher rather than lower heights.
We believe it is likely that these conditions would result in releases of spray at heights even

above those specified in the protocols described above.

In actual application, the release, or boom, height is likely to be highly variable due to the
conditions that occur along the Colombia/Ecuador border, including complex topography that

includes hills, valleys, gulleys, and forest canopy of varying height. Figure 1, taken from the
Solomon et al. (2005) assessment of the aerial spray program, shows a plane flying over the
uneven terrain while releasing spray.

Figure 1. From Solomon et al. 2005.

As the picture illustrates, the height above the ground at which spray is released will vary with
the terrain. For this one example, winds passing through the valleys could move the spray drift

greater distances because of the greater height of spray release. Pilots applying spray to fields
located within the forests will necessarily have to fly above the canopy to safely apply the spray.
In such cases, the spray height is affected by tree height, which in this region is considerable.

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There are also many accounts from residents in Ecuador placing the release height well in
excess of 30 m based on their personal observations.

Droplet size. Smaller drops of the herbicide mixture are more prone to drift than larger ones.
Colombia’s Environmental Management Plan (GOC 2003) states that the nozzles specified for
the aircraft deliver droplets with volume mean diameter (VMD) between 300 and 1,000 microns
(▯m). According to tests conducted by Collins (1998), who evaluated droplet size distribution

in 18 field tests conducted in Colombia, 79% of the dispersed volume was of a droplet size less
than 500 ▯m. This suggests that a considerable portion of the sprayed amount is in the lower
droplet size range of the target VMD, and thus is more susceptible to spray drift than larger
droplets.

4.2 Off-Target Release of Spray

The extent of off-target spray drift is also influenced by the pilot’s actions. Timing of spray
release is controlled by the pilot. Spray is initiated and terminated at the pilot’s discretion,
depending on his/her judgment regarding the airplane’s trajectory, elevation, speed, and wind
direction and speed. The degree to which off-target overspray can occur due to topography and

timing of release is illustrated in a graphic taken from the UNODC 2006 coca survey (Figure 1).

The parallel yellow lines in the figure are actual flight lines recorded using GPS within the flight
recorder of the spray plane. The coca fields are shown in cyan. The purple coloring represents
forests surrounding the fields. This graphic confirms that planes began spraying when they

were still over the forest and before they traveled over the fields. Spraying continued as they
exited the field and passed again over the forest. This demonstrates that the release of spray
occurred at a height greater than the height of the forest canopy. It also shows that spray did
reach the forest canopy. Spraying over an area broader than the target area increases the

probability that non-target biota will be exposed to the spray. As noted above, spraying over a
forest also requires the planes to fly at greater heights.

Figure 2. Spray flight lines

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4.3 Ground-Based Hostilities

The spray missions are often conducted under highly adverse and violent conditions. This is
perhaps best exemplified by the fact that spray areas are commonly patrolled by helicopter
gunships prior to the arrival of spray planes. Despite these precautions, spray planes have
received hostile fire. This field condition is acknowledged by the U.S. State Department in
numerous documents. For example, U.S. State Department (2003) includes a section titled,

“Response Procedure for Attending Disasters during Spraying,” which primarily addresses
ground hostilities. The following are excerpts from that report:

The program operates in a hostile environment------eradication aircraft are often
shot at from the ground------that requires helicopter gunships and a search and
rescue helicopter to accompany each eradication mission. In August 2003, the

Director of the Office of Aviation expressed his concern that the increased
operational tempo had strained the resources and staffing available and he could
not continue to ensure the operational safety of the aerial eradication program.

But in late 2002 and during 2003, the number of ground-fire hits reported
increased significantly a-v---aging more than 26 per month------and in 2003, for the
first time, two spray aircraft crashed and two were forced to land because of

ground fire. Moreover, the operational tempo more than doubled------frombaout
5,450 flying hours for spray aircraft in 2001 to over 11,300 hours in 2003. In
general, this meant the spray aircraft and accompanying helicopters were exposed
more frequently to the threat of ground fire; although other factors also came into
play, such as the proximity of eradication target areas to insurgent locations.
According to U.S. Embassy/Bogotá officials, the increased number of ground-fire
hits occurred, at least in part, because the illicit drug producers were responding
more vigorously to the success of the increased aerial eradication program.

In an October 2003 report, DynCorp noted that the threat to the program’s aircraft
and pilots was causing increasing concern about pilot safety and personnel
morale.

It is reasonable to expect that the hostility would be a reason why pilots would fly higher and
faster than they would during normal agricultural crop-spraying. Under those circumstances,

the released spray would be prone to greater drift. In addition, the presence of hostility can
create the need for evasive maneuvers or distractions from spraying, all of which can decrease
the accuracy of the spraying and increase the amount of non-target areas directly affected or
affected by drift.

4.4 Localized Weather Conditions

Local meteorological conditions favor the formation and persistence of thermal inversions and

localized wind patterns that can increase spray drift.

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4.4.1 ThermIa nlversions

The label for Roundup SL cautions against aerial spraying in the presence of thermal inversions.

A thermal inversion is a condition where warmer air is positioned above colder air. Thermal
inversions are common in the tropics and are expected to be a frequent occurrence in the
Ecuador/Colombia border area. In equatorial areas such as the Colombia/Ecuador border
region, there are no cold or warm frontal systems, such as are found in the temperate latitudes.

Thus, there is little daily variation in the weather. Overall, the barometric pressure in this area
tends to be lower than that in more temperate zones, and wind speeds tend to be lower. All of
these conditions favor formation of temperature inversions.

In an inversion, there is little vertical mixing and, typically, low wind speeds. Therefore, if the

aircraft flies within a shallow inversion, the droplets will be trapped within the inversion and
will not fall to the ground as readily. This limitation on the ability of the droplets to descend
will allow for greater horizontal movement of the spray particles. Thus, the downwind
concentration of the spray may be increased. Another scenario in which a thermal inversion

increases the downwind spray concentration occurs if the aircraft flies above the inversion.
Droplets could then be carried in the wind above an inversion, falling through the inversion
farther downwind than intended. Either scenario could result in high concentrations of droplets
at greater distance from the spray point, because small droplets are blown downwind while

above the inversion, but larger droplets fall into and through the inversion.

4.4.2 Local Wind Circulation

Wind is one of the most important factors influencing spray drift. Both wind direction and

velocity are important. In general, strong winds favor increased drift, and winds perpendicular
to flight paths will result in greater drift than weak winds parallel to flight paths.

However, spray drift can also be increased under light wind conditions by contributing to
localized circulation patterns. When light wind conditions occur in areas where there is no

dominant meteorological system, local circulation can control the air flow, and spray can be
carried in unexpected directions and in ways not easily predicted. Three circulation patterns are
discussed below:

x A small patch of cleared land, surrounded by jungle trees In this
situation, the thermal characteristics of the cleared land may be quite
different from those of the surrounding jungle. The cleared patch will absorb
sunlight in a manner different from that of the surrounding jungle. In light

wind or calm conditions, this temperature difference can create a small-scale
circulation that could cause the spray to disperse in a pattern different from
what would happen under more typical conditions.

x Mountain-valley breezeThis is a well-known phenomenon in which the
daily heating and cooling of mountain slopes is different in adjacent valleys.

The difference can create upslope winds in the morning and downslope winds
in the evening, which can carry spray drift long distances—longer than what
is typically encountered in “flat land” agricultural situations.

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x River-related circulationsThis phenomenon is again related to the
thermal conditions in the air over a river, compared to those over adjacent
land. The result can be a pair of vortices that move along the river, carrying
spray down- or up-river, and depositing droplets farther from the release

point than what would otherwise occur in the absence of the river.

The complex meteorological conditions described above could alter spray-drift patterns in
unpredictable ways and could extend the drift farther than what would be expected absent these
conditions.

4.4.3 Variations in Wind Speed between the Airport and Mission

Locations

As just described, wind conditions may be highly local; they may also change rapidly, even in a
single location. While the protocol calls for cancelling flights “at the airport,” it is likely that
winds at distance from the airport could at times be significantly stronger or weaker than those
at the airport. This is especially the case in Ecuador/Colombia border area, where the terrain is

uneven. Therefore, acceptable wind speeds “at the airport” do not necessarily represent
acceptable wind speeds at spray locations. The spray locations can be a considerable distance
from airports and air bases where the spray planes initiate their missions, and the differences in
topography, times of day, and local wind circulation (as described above) can result in very

different winds at the locations to which the planes are directed.

4.4.4 Temperature

Air temperature and relative humidity affect the volatilization rate of droplets as they fall
through the atmosphere. Under hot and relatively dry conditions, more volatilization will occur

than under cooler, humid conditions. Excessive volatilization will result in smaller droplets that
will be carried farther in spray drift. Excessive volatilization will also result in more
concentrated active ingredients, which could produce greater exposures to non-target organisms.

4.5 EyewitneA ssccounts

Eyewitness accounts within Ecuador indicate that spray applied in Colombia did cross the
border and enter into Ecuador. Communities in border regions of the Sucumbíos, Esmeraldas,
and Carchi provinces are located immediately adjacent to areas in Colombia that were targeted

for aerial spraying during the period 2000–2007. Several groups, including Ecuadorian NGOs,
Ecuador’s Office of the Public Defender, and U.N. Special Rapporteurs, participated in several
verification missions to the border regions of both Ecuador and Colombia to document reports
of effects from spraying (UN Special Rapporteur 2007; Impacto de las Fumigaciones en la Zona
de Frontera Colombia-Ecuador, 2007, p. 2 [6.10]). In addition to these verification missions,

dozens of witness statements have been gathered from several representative border
communities, including Salinas and Puerto Escondido, Sucumbíos; several indigenous villages
located across the border region; and Mataje, Esmeraldas. Witness accounts from these various

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and isolated communities are very similar. In some cases, witnesses state that airplanes crossed

over into Ecuador and released spray over their communities. In other cases, witnesses have
stated that they were exposed to spray drift carried by the wind. Many witnesses reported
feeling the spray droplets contact their skin and reported a strong odor and immediate irritation

of mucosal membranes, including eyes and throat. These reports provide a separate and direct
line of evidence that aerial spraying intended for illicit crops in Colombia entered Ecuador,
where people and their crops, domesticated animals, soil, water, and native flora and fauna were

directly exposed.

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5 Hazards to Health, Agriculture, and the Biologically

Diverse Ecosystems of Ecuador Associated with
Exposures to Chemicals in the Aerial Spray Mix

In Section 4, we described factors that would lead to increased spray drift associated with

Colombia’s aerial spray program. In this section, we describe the hazards associated with
exposures to the chemicals in the spray mix. We discuss the potential hazards presented to
humans, agriculture (crops, farm animals and fish), and the biologically diverse ecosystems.

This section is limited to chemicals for which there is firm evidence of their presence in the
spray. As noted in Section 3, many different chemicals could have been present in the spray

during the course of the spray program. A few of these, such as formaldehyde, were revealed
through references in U.S. government reports. Also, changes in formulation were shown to
have occurred over time based on USDA and State Department records. The evidence of
ongoing experimentation with the spray formulation and the lack of concrete information from

Colombia indicate that formulations may have been created for and applied in the aerial spray
program that were atypical of those in common use for agricultural purposes. Thus, there is
considerable uncertainty about the full range of toxicity and effects associated with the various
formulations. Specific testing data available for review are very limited

We do know that there was a concerted effort to improve the efficacy of the formulation to kill

coca plants and that this required the addition of surfactants and other additives. While the exact
composition and amounts of the various surfactants and other additives are unknown, the
addition of these chemicals to improve the efficacy of the formulation to kill coca can bring
with it an increased hazard associated with the presence of surfactants in the formulation.
Because the formulation used in Colombia has been customized to target a resistant plant

species in locations that are not conducive to normal spray applications, ecological hazards
associated with the spray are likely much greater than those associated with normal and
controlled agricultural applications elsewhere.

5.1.1 Health Hazards to Humans

People within Ecuador who reported experiencing spray and/or who live in areas adjacent to
where spraying has occurred have reported a variety of health ailments, including eye, skin, and
throat irritation, cough, shortness of breath, dizziness, nausea, vomiting, and diarrhea. In this
section of the report, we examine the hazards associated with exposures to the chemicals in the
spray mix. Our review of these chemicals indicates that the symptoms being reported are

consistent with effects that can be associated with exposures to chemicals in the various spray
formulations.

5.1.1.1 Acute Effects on Eyes and Skin

Irritation of the eyes and skin are among the most common and consistent effects reported by
people in Ecuador and Colombia who claim they have been exposed to spray. Irritant effects

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have also been reported with commercial formations of Roundup that include a combination of
glyphosate and surfactants. Adverse effects from dermal contact that have been reported for
glyphosate formulations include skin irritation and occasional reports of contact dermatitis
(Maibach 1986). Periorbital edema (swelling around the eyes) has been reported when the

herbicide is transferred from the hands to face, and symptoms can include paresthesia
(i.e., tingling sensation) (Temple and Smith 1992).

Reports of accidental exposure to glyphosate formulations in California are maintained by the

EPA Pesticide Illness Surveillance Program (CA DPR 2007). Most cases reported topical
effects (e.g., eye or skin irritation) or respiratory effects, with fewer cases of possible systemic
effects (e.g., nausea/vomiting, dizziness, fever, and diarrhea) (Goldstein et al. 2002).

The following is a summary of publically available hazard information for adjuvants
(surfactants and other chemicals) that may be included with glyphosate in the coca eradication
formulation.

POEA, also known as tallow amine ethoxylate, (CAS RN 61791-26-2), is a surfactant that is

used in the aerial spraying program. POEA is a mixture of ethoxylated linear saturated and
unsaturated C14-C18 alkyl amines. Publically available information on the exact chemical
composition and toxicology of POEA is limited. MSDSs were reviewed as sources of general

information on hazard and product use, although their usefulness is limited by the lack of ®
detailed information in toxicological studies. An MSDS for a tallow amine product (Ethomeen
T/25) and literature searches indicate that this surfactant is moderately irritating to the skin but
severely irritating to the eyes and can also irritate the throat.

Cosmo-Flux 411F is an additional surfactant that is reportedly in current use in the spray
formulation used in Colombia. Cosmo-Flux is produced in Colombia, and limited information is
available on its exact formulation. However, the U.S. Department of State (2002b) reports that

Cosmo-Flux is composed of polyol fatty acid esters and polyexothylated derivatives (17%) and
inert liquid isoparaffins (83%). The MSDS and product use information for Cosmo-Flux do not
provide specific toxicity data. An MSDS for another paraffin-based surfactant (Agri-Dex) states
that excessive exposure may result in eye or skin irritation.

While the MSDS and product use information for Cosmo-Flux does not provide detailed
toxicity data, it does contain a description of first aid suggesting some of the potential hazards
associated with the product (Cosmo-Flux Safety Data Sheet):

Eye contact: Wash with clean drinking water until irritation disappears or use a solution
for rinsing eyes. If irritation persists, seek medical attention.
Skin Contact: Wash with plenty of water; use soap if available. Remove strongly
contaminated clothing, including shoes, and wash well before using.
Inhalation: Using appropriate breathing apparatus, remove the person from the site

into fresh air and call a doctor.
Ingestion: Do not induce vomiting, keep the person at rest. Get immediate medical
attention.

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5.1.1.2 Respiratory Effects from Inhalation

Inhalation is not considered a major route of exposure to typical glyphosate formulations during
normal aerial applications, and data concerning adverse effects of exposure by inhalation are

limited, with little detail on the absorbed dose or duration of exposure. Inhalation of the
glyphosate formulations is thought to generally lead to symptoms of oral and nasal discomfort,
and there have been reports of unpleasant taste, throat irritation, and tingling. However, it is
difficult to determine whether the reported adverse effects are due to any one constituent

(herbicide or adjuvants) in the glyphosate formulation. One case, involved a firefighter who was
exposed to glyphosate formulation spray drift from a nearby field and experienced burning eyes,
skin irritation, and headache (Goldstein et al. 2002).

Inhalation toxicity data for Cosmo-Flux are not available. However inhalation of isoparrafins,
the main constituent of Cosmo-Flux, has caused respiratory effects. Inhalation of a spray mist at
significant levels would be expected to produce respiratory tract irritation. Persons with
preexisting respiratory conditions, such as persons with asthma, would be expected to be more

sensitive to the effects of such an irritant.

5.1.1.3 Acute Gastrointestinal Effects

A number of people who reported being exposed to spray also reported experiencing nausea,
vomiting, and diarrhea. The people in the villages depend on local water and food supplies. If
these resources are heavily impacted, people that consume them could be exposed by an oral

route. Nausea and vomiting are reported to result from ingestion of significant quantities of
glyphosate formulations, with diarrhea reported less commonly. Thus, some of the
gastrointestinal complaints are consistent with those that could occur from ingestion of
glyphosate-containing formulations or chemical constituents added to the spray mix. Nausea

and even vomiting have also been reported to occur as a result of exposure to noxious odors.

5.1.1.4 PotentiallVyulnerablPeopulations

Many of the reports of adverse effects following spraying have involved children. Ecuadorian
children may represent a vulnerable population to certain effects of the herbicide formulation.
The likelihood of exposure to this population could be increased, because they are expected to

spend considerable time outdoors and to wear less clothing than adults (e.g., shirtless or short
pants).

Diarrhea has been reported following spraying events. One possible explanation for the diarrhea
and other gastrointestinal symptoms is inadvertent ingestion of retained residue, although

diarrhea is more commonly reported with ingestion of large doses. Children with underlying
nutritional deficiencies, malnutrition, and underlying gastrointestinal disorders, including those
associated with contaminated water supplies, may represent a potentially vulnerable population

to diarrhea. Diarrhea is a concern, because it can lead to other health effects, especially for
individuals whose health is compromised. Diarrhea causes dehydration, and children are more
likely than adults to die from it because they become dehydrated more quickly (Chen et al.
1983; Basch 1999; Semba et al. 2000). Such effects may be exacerbated for people in Ecuador,

where tropical temperatures may lead to increased dehydration, and many communities have

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limited access to the type of medical facilities where rehydration and other appropriate
treatments are available.

The impact of potential environmental stressors interacting with poverty has been recognized as

being of special concern to children. The World Health Organization has also expressed concern
that children may be exposed to health risks from environmental hazards, stating, “Over 40% of
the global burden of disease attributed to environmental factors falls on children less than five
years of age, who account for only about 10% of the world’s population. Environmental risk

factors often act in concert, and their effects are exacerbated by adverse social and economic
conditions, particularly conflict, poverty, and malnutrition” (WHO 2009).

The potential sensitivity of children to some chemical agents is recognized and, of course,
depends on both the nature of the chemical agent or mixture and the exposure incurred. In 1997,

the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) published a report that
included more than 10 years of public health assessments, toxicological investigations,
epidemiologic studies, and reviews by expert workgroups (ATDSR 1997). ATSDR concluded
that children may have greater risk of adverse health effects when exposed to toxic substances.

In their regulation of pesticide products, the U.S. EPA takes into account that children may be
more vulnerable to environmental exposures than adults. Reasons for increased susceptibility
can include:

x They eat more, drink more, and breathe more in proportion to their body size

x Their behavior (hand-to-mouth contact) may expose them more to chemicals
and organisms.

x Organ systems are not fully developed and may be more susceptible to select
toxicants.

5.1.2 Conclusions

Some of the symptoms reported in the Ecuadorian population have also been reported following

exposure to commercial formulations of glyphosate. These include skin, eye, and respiratory
irritation; nausea; and diarrhea, which raises concern that these people might have been exposed
to levels of herbicide formulations of glyphosate with surfactants and other additives that
account for their symptoms. As explained in Section 3, other potential ingredients in the spray
that are not present in U.S. formulations present additional human health concerns.

5.2 Hazards to Agriculture

5.2.1 Direct Effects on Non-target Crops

We reviewed the reports made by people in Ecuador of damage to crops following spray events.
We also visited agricultural areas along the border and held discussions with villagers. We
learned that damage of crops followed spray events. Here we consider whether the conditions

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reported by villagers are consistent with the potential effects associated with exposure to

glyphosate and other chemicals in the spray mixture. We conclude that the effects to
agricultural plants described by people in Ecuador who have been affected by aerial spraying
are consistent with the known effects of glyphosate-based sprays.

Spray drift that falls upon nontarget crops can kill or damage those plants. In Section 4, we

described the factors that could contribute to an increase in spray drift along the Ecuador/
Colombia border. In this section, we describe the effects of the spray mix on nontarget plants.
We point out that the hazards to nontarget plants are increased, because the customized mixture

used in Colombia is much more potent than the typical glyphosate formulation used elsewhere.
The adjuvants included in the spray mixture increase its effectiveness at penetrating plant tissues
and thereby enhance its ability to kill plants by 400%. Increasing the efficacy of the mixture for
eradication of coca is necessary because of the physiology of the coca planta bush with

woody bark and thick, waxy cuticles. We conclude that many crop plants grown in Ecuador are
much more susceptible to the spray used in the aerial eradication program, because they do not
have the same thick, waxy leaf cuticles and other resistant properties as the coca plant.

As discussed earlier, surfactants are commonly combined with glyphosate to increase
phytotoxicity (i.e., the chemicals’ ability to kill a plant). Surfactants are typically employed to
increase the absorption of glyphosate through the leaf cuticle and increase translocation via
phloem, transporting the herbicide to metabolic tissues faster. Some solubilized oil

formulations can facilitate uptake through the bark of woody tissues as well (Grossbard and
Atkinson 1985).

The physiology of a plant can affect its susceptibility to glyphosate-based herbicides. Because

glyphosate is a broad-spectrum herbicide that is toxic to almost all plants, differences in
sensitivity to glyphosate among different species are mostly due to differences in glyphosate
uptake and translocation rates. These rates are determined largely by anatomical features on the
outer surfaces of plants. Such features include leaf size, presence or absence of a waxy cuticle

(the outermost skin of a plant), cuticle thickness, composition of epicuticular wax, and the
presence or absence of bark. Once glyphosate has penetrated these surfaces, resistance to toxic
effects is highly unlikely in most species, and depending on the dose, phytotoxicity can be
expected. As noted in Section 3, some plants have also been genetically modified to resist

glyphosate.

The properties of the leaf cuticle are particularly important, because glyphosate enters plants
primarily through their leaves. The composition of the leaf cuticle can influence uptake rates of

glyphosate and appears to play an important role in species-specific sensitivity (Grossbard and
Atkinson 1985). The cuticle varies in thickness depending on species, as do the amount and
composition of epicuticular wax, both of which serve to retain moisture and solutes inside the
leaf and act as a barrier to pathogens. Glyphosate is generally formulated as an amine salt (such

as the isopropyl amine salt) that enters a plant as an anion and thus requires a hydrophilic
pathway through the cuticle. Cutin and carbohydrate fibers in the cuticle provide such a
pathway within the otherwise waxy, hydrophobic cuticle (Grossbard and Atkinson 1985).
Differences in the thickness and composition of the cuticle, and in the amount and composition

of epicuticular wax, can result in differences in glyphosate uptake rates and, ultimately,
phytotoxicity (Grossbard and Atkinson 1985; Gaskin and Holloway 1992). Coupland (1984)

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demonstrated that glyphosate applied to the adaxial surface of the leaf sheath of Apocynum
cannabinum, where there is no epicuticular wax, resulted in greater phytotoxicity compared to
application to the lamina base, which is protected by a dense coat of wax. This study
demonstrated the cuticle as a key factor in determining sensitivity to glyphosate. Gaskin and

Holloway (1992) observed different uptake rates between wheat (Triticum aestivum) and field
bean (Vicia faba). Wheat leaves have a cuticle with a microcrystalline layer of wax that is more
water repellent than the leaves of field bean, which have very little wax and no crystalline
deposits in the cuticle. These physiological differences were overcome by the addition of

surfactants, which resulted in a greater increase in the rate of uptake in wheat.

A drier cuticle will take up glyphosate more slowly than a well-hydrated cuticle. Hydration of
the plant cuticle can increase the uptake rate of hydrophilic compounds such as glyphosate.

A high level of plant hydration or increased ambient humidity, as is found in the Ecuador/
Colombia border region, can increase the water content of the cuticle and thus increase uptake
(Kearney and Kaufman 1976).

Once glyphosate has been taken up through the cuticle, it diffuses into mesophyll cells and then
diffuses into the phloem. This process appears to occur via passive transport and at a slower
rate than uptake through the cuticle. Once in the phloem, glyphosate is translocated in the sap to
target metabolic tissues, such as roots, rhizomes, and apical meristems (Kearney and Kaufman

1976; Grossbard and Atkinson 1985; Giesy et al. 2000). This process of diffusion throughout
the plant also differs among plants, and thus, may also contribute to differences in glyphosate
phytotoxicity.

We rely on the Collins and Helling (2002) research to provide an estimate of the toxicity of the
herbicide formulation used in Colombia relative to unenhanced Roundup for which glyphosate
is the active phytotoxic agent. Collins and Helling report that the addition of adjuvants to the

formulation resulted in a fourfold increase in glyphosate phytotoxicity: 1.1 kg acid equivalents
per hectare (ae/ha) of glyphosate with surfactant was equivalent to 4.4 kg ae/ha glyphosate
without added surfactant. This four-fold increase in toxicity can be found in various reports
related to the spray program. However, the basis for it appears to come from the USDA

research.

To understand how the degree to which the fourfold increase in toxicity can be applied to plants
in general, it is necessary to consider the mechanism by which the additives result in increased

toxicity. If this mechanism of enhancing toxicity is applicable to all plants, then it is reasonable
to expect that the presence of certain additives in the Colombian herbicide formulation not only
increases toxicity to coca and poppy by four times, but also increases toxicity to other plant
species to a similar degree. The evaluation presented in the following subsections supports the

following statements:

1. Glyphosate exerts its toxic action by being absorbed into the plant

2. Absorption of glyphosate into plants is influenced by the presence of a cuticle
on plant surfaces

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3. Plants vary in the degree to which this cuticle is developed, and this can

contribute to the differences in sensitivity to glyphosate that is observed
among plants

4. Surfactants can weaken the cuticle and increase the ability of glyphosate to
penetrate into the plant

5. Coca has a thick cuticle, and additives were used to penetrate this cuticle, to

enable penetration of glyphosate so that the plants could be killed

6. The additives used in the formulation enhanced the toxicity of glyphosate to
coca by four times

7. Because the mechanism of increasing the toxicity of glyphosate is related to
weakening of the cuticle and enhancing glyphosate penetration, a similar

degree of enhanced toxicity can be expected for other plant species.

Crops that lack the thick, waxy cuticle of coca will be most susceptible to the effects of the
spray. For this reason, spray drift associated with the program will be more toxic to plants than
drift from “normal” Roundup. Because the efficacy of the spray mixture needed to be enhanced
to make it effective on coca, it follows that many other species will be more sensitive to the

spray. These could include many of the crop species grown in Ecuador, such as yucca, plantain
corn, and fruit trees.

In sum, we conclude that many of the crop plants grown in the border region of Ecuador and

Colombia are more susceptible to glyphosate-based herbicides than the coca plant. The
increased potency of the spray used by Colombia makes it more likely that crop plants would be
affected, even in small quantities. The effects on agricultural plants that have been reported in
the border region of Ecuador and Colombia, including yellowing, withering and drying, and

rotting of roots and other plant tissues, are consistent with the known effects of glyphosate-
based herbicides.

5.2.2 Chronic Effects on Nontarget Crops

During our field visits to agricultural areas along the border, we were shown plantains, palms,
and coffee plants that exhibited weakened conditions and dwarfed fruits. We were informed
that these conditions began after the spray events and that they had persisted for one or more
years. Similar characteristics associated with long-term effects have been reported for crops in

Colombia. We examined the literature to determine whether these longer-term effects were
consistent with exposures to the chemicals present in the herbicide mix.

As mentioned earlier, the glyphosate mixture used in the aerial spraying program has been

documented to be four times more toxic than other typical commercial formulations used. This
increased potency increases the risk of toxicity to nontarget plants that may be exposed to spray
drift. In addition to direct mortality to nontarget plants, there are several ways in which spray
drift may result in chronic long-term effects, including loss of plant vigor for years following

exposure. In addition, glyphosate mixtures have been reported to result in diminished soil
productivity mediated by adverse effects on nitrogen-fixing plants and their symbiotic fungi.

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Finally, evidence indicates that glyphosate exposure weakens plants’ immunity to fungal
infections.

Exposures to herbicide mixtures below those that kill the plants can cause damage that persists.
Many species of plants are susceptible to being damaged and weakened by glyphosate, and

timing of exposure can be an important factor in determining sensitivity. Late-summer
exposures to glyphosate produced high mortality and reduced shoot and sucker growth in black
cottonwoods. Glyphosate exposure caused long-lasting damage to certain bush and shrub

species, including several berry-producing species, with reduced vigor observed three years
after exposure (Balfour 1989). The observations of long-term effects on perennial crops in
Ecuador are consistent with the potential for the herbicide formulations to cause those effects.
The literature suggests that some cultivated perennial plants may be very sensitive to glyphosate

spray drift, and that chemical damage may persist in individual plants for several years
following exposure. Severity of effects appears to be species dependent and may also vary with
seasonal timing of exposure. Although generally considered robust, conifers were much more

susceptible to exposures that occurred during periods of active growth, and high-potency
glyphosate adjuvants increased conifer damage (Balfour 1989).

Sublethal effects on plants can be manifested through disruption of the plant’s physiological
processes. On the individual level, there is significant evidence that glyphosate can interfere

with a number of important plant physiological processes. Sugar beets exposed to glyphosate
exhibited altered photosynthetic rates and carbon allocation. Significantly reduced foliar starch
was observed four hours after exposure, as was reduced stomatal conductance and diminished

leaf net carbon exchange (Geiger et al. 1986). These responses were similar to what was
observed following a reduction in available CO 2. Also, the exposure resulted in an
accumulation of shikimate at night, which further interfered with sucrose synthesis in the leaves.

Significant alterations in soil productivity and nitrogen fixation rates have also been linked to
glyphosate contamination. Glyphosate exposure was shown to reduce nodule formation in sub-
clover (Trifolium subterraneum), a nitrogen-fixing plant; growth of the symbiotic fungi
Rhizobium spp was also slowed following glyphosate application (Eberbach and Douglas 1989).

This suggests that glyphosate use may interfere with plant-fungus interactions that are vital to
soil health. Similarly, laboratory experiments indicate that glyphosate use may cause long-term
impacts to soil conditions and microorganism communities. Research indicates that
glyophosate can be translocated in target plants from foliage to roots and into the rhizosphere,

where is it more persistent (Neumann et al. 2006). Glyphosate contamination in the rhizosphere
was subsequently linked to decreased plant acquisition of micronutrients. Exposure to the
herbicide resulted in slowed mycelial growth and reduced mycelial dry weight of five important

soil fungal species: Hebeloma crustuliniforme, Laccaria laccata, Telephora americana,
Telephora terrestris, and Suillus tomentosus (Chakravarty and Sidhu 1987). Glyphosate was
also shown to be very toxic to the ectomycorrhizal fungus Pisolithus tinctorius, with a greater
than 45% reduction in growth following exposure to 1 ppm glyphosate (Estok et al. 1989).

Reductions in soil fungi responsible for nitrogen fixation or nutrient mobilization will lower the
productivity of soils, a significant negative impact in agricultural areas. Further, there is
evidence that plant mortality following glyphosate spraying will increase the rate of soil

denitrification 20 to 30 times that of untreated land (Tenuta and Beauchamp 1996). Nitrogen is

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essential for plant growth, and as it is diminished, the productivity of plants can decline.

Accelerated loss of nitrogen from the soil via denitrification can thus contribute to nutrient
limitation and reduced plant viability and productivity.

While some fungi are beneficial to plants and soil health, other fungal species can be pathogenic
to plants. Research suggests that glyphosate contamination can weaken plants’ defenses against

fungal infections. For example, glyphosate exposure altered the symbiosis between an orchid
species (Orchis morio) and a fungus species (Rhizoctonia spp.) to that of a parasitic relationship;
fungal growth in treated plants was haphazard and highly active, eventually resulting in orchid

protocorm death (Beyrle et al. 1995). Another study demonstrated that glyphosate exposure
reduced accumulation of phytoalexins (antibiotic and antifungal chemicals produced by plants)
in bean seedlings (Phaseolus vulgaris L.) parasitized by Colletotrichum lindemuthianum fungus
(Johal and Rahe 1988). This resulted in advanced mycelial growth and eventually in the death

of the plant. These studies suggest that sublethal glyphosate exposure is likely to interfere with
the plant defense mechanisms that prevent fungal infections.

These effects are largely sublethal, chronic impairments of plant vitality. While these impacts
are generally less immediate than direct mortality, they can ultimately result in inhibition of

plant reproductive cycles due to loss of plant vigor. Loss of vigor, poor fruiting, and reduced
crop yields were observed consistently in areas in Ecuador affected by spray drift, in crops
including coffee, yucca, rice, corn, plantains, pineapple, and cacao. These observations are

consistent with the chronic effects of glyphosate, including its secondary effects on soil and
plant health, documented above.

5.2.3 Direct Effects on Domestic Animals

We reviewed the reports made by people in Ecuador about effects on domestic animals

following spray events. This included holding discussions with villagers. We learned that the
reported effects followed spray events. Here we consider whether the conditions reported by
villagers are consistent with the potential effects associated with exposure to glyphosate and

other chemicals in the spray mixture. In addition to direct effects caused by exposure via
dermal or ocular routes or by ingestion, the chemicals in the spray mixture may have important
secondary effects. We conclude that many of the effects reported in animals are consistent with
the known risks of glyphosate-based sprays.

We reviewed available documentation regarding glyphosate and surfactants, including POEA
and Cosmo-Flux 411F. These included MSDSs and other product information. We have
summarized here the potential effects to livestock, poultry, and other domestic animals that may
result from exposure during an aerial spray event. In addition to this potential risk, even greater

concerns about effects on mammals and birds from aerial spraying of glyphosate relates to
compounds added to the tank mix to enhance foliar penetration and uptake (Bradberry et al.
2004). Primary hazards noted for several of the potentially added surfactants are eye irritation

(moderate to severe) and, to a lesser extent, skin irritation. Prolonged exposures to eye irritants
may lead to permanent eye damage, including corneal opacities.

In addition to direct irritation caused by surfactants, secondary irritation may occur when
animals remove topical compounds that have been deposited on their skin by preening, body

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and eye rubbing, and grooming, leading to dermal or ocular trauma as well as gastrointestinal

upset. Secondary infections may occur from abraded skin, either because of the irritation
caused by the spray mix or from self-inflicted wounds from excessive rubbing and grooming.

Short exposures (15 days) to formulated Roundup result in reduced growth rates and changes in
plasma testosterone levels (Oliveira et al. 2007). Toxic effects of POEA or Cosmo Flux 411F to

chickens are unknown, because they have not been tested on birds. However, given that these
chemicals cause irritation to eye, skin, and mucus membranes in all species that have been
tested, it is likely that similar effects would occur in poultry. When stressed, as would occur

following this type of irritation, chickens frequently curtail egg-laying for a period of time.

Still further effects may be caused by ethylene oxide, a potential contaminant of POEAs. Its
known hazards include carcinogenicity. At high concentrations, spontaneous abortions have
been reported (OSHA 29 CFR). Possible effects of inhalation of ethylene oxide are nausea,

vomiting, and breathing difficulties, including pulmonary edema. Our information regarding
compounds that may have been used with glyphosate is incomplete regarding the presence of
ethylene oxide.

Some product information also highlighted ingestion hazard (Monsanto product label for
Roundup Ultra). In particular, chronic dietary exposure to glyphosate formulations is associated
with temporary gastrointestinal irritation, resulting in vomiting, diarrhea, and colic. Campbell
and Chapman (2000, as cited by Solomon et al. 2005), reported severe gastrointestinal upset in

dogs acutely exposed to glyphosate, including salivation, vomiting, diarrhea, and irritation and
swelling of lips. Reduced weight gain also has been observed in mammalian studies, although
the cause of this is unclear and may be related to unpalatability of glyphosate-exposed diet
(Bradberry et al. 2004).

In addition to the risks presented by direct ingestion of the chemicals, spraying with glyphosate-
based herbicides may reduce the food supply for domesticated animals. The potential reduction
in available forage for browsing or grazing may lead to decreased body condition and

performance in livestock and other farm animals. In addition to compromised nutrition,
exposure to adjuvants that cause eye, skin, and systemic conditions would reduce the
productivity of food-producing animals (decreased weight gain or reproductive performance).
In general, young animals are more susceptible to these types of stress-related effects than are

adults.

It is inadvisable for people to let their animals consume contaminated feed, pasture etc. for
several days following spray events. In addition people should avoid consuming livestock or

other animal products (such as milk and eggs) following a spray event.

5.2.4 Effects on Aquaculture (Fish)

As discussed in Section 5.3.3 below, many of the chemicals present in the mix can be toxic to
fish. Fish kills have been reported in fish farm ponds in Ecuador following spray events. We

visited two locations where such effects were reported to occur and discussed the fish kill events
with the owners of those aquaculture ponds. We learned that the kills occurred shortly after a

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spray event. In addition, we learned that similar kills were reported in Colombia following spray
events. These included:

x Reports from municipal officials in La Hormiga and Valle de Guamez,
Putumayo, cited several hundred complaints of damage, including reports
that hundreds of fish had washed up on the banks of the Guamuez River

(Wilson 2001; Williams 2001; Municipality of Valle de Guamez 2001).

x An inspection and accounting by the municipal police in the single township
of Valle del Guamuez (population 4,289), in the Province of Putumayo,
found that 17,912 acres had been sprayed with herbicides as of February 21,
2001. Among the losses in the 59 settlements and neighborhoods that make

up the township were 128,980 fish (from aquaculture) (Municipal Police
Inspector, Valle de Guamuez 2001).

x In June, the Colombian government launched a spray campaign against the
northern Colombian community of El Catatumbo, in the State of Norte de

Santander, near the Venezuelan border. According to press reports, residents
reported the loss of thousands of fish. One community leader reported in an
interview that many fish have been appearing dead in the Catatumbo River
(El Tiempo 2002).

Fish kills could occur either because of direct effects of the toxic chemicals or indirectly through
the death of aquatic plants. The latter would result in a decrease in available oxygen in the

ponds, and this could result in asphyxiation of the fish. These mechanisms are described in
greater detail in Section 5.3.3.

5.3 Hazards to Ecuador’s Biodiverse Ecosystems

Our analyses indicate that herbicide spray drift from Colombia that enters Ecuador could have
adverse effects on ecological receptors in Ecuador. We focus our analyses on plants, insects,

and aquatic biota, with an emphasis on amphibians. These groups of biota are often identified
as representative of the biodiversity of Ecuador. Loss of biodiversity is of great concern to
Ecuador, because the country is recognized for its rich diversity of plant species, frog species,
and other assemblages of animals. Two regions in Ecuador are consistently listed as

biodiversity hot spots and conservation priorities: the western coastal areas of Ecuador, and the
tropical Andes of Ecuador (Myers 1988; Myers et al. 2000; Brooks et al. 2001). These regions
have extremely high biodiversity and endemism, and have also suffered tremendous loss of
habitat in recent years (Brooks et al. 2001).

Our analysis considers the threats that spraying within Ecuador poses to the country’s
rainforests along its northwest border. Figure 3 depicts the intensity of aerial spraying
conducted in the Colombia province of Putamayo along the northwest Ecuador border during
2001–2004. This region is collocated with Amazon rainforest within Ecuador.

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Figure 3. Intensity of aerial spraying conducted in Putamayo along the northwest Ecuador
border during 2001–2004

5.3.1 Hazards to Native Vegetation

We described earlier the potential impacts of spray drift on nontarget crop plants within
Ecuador. However, Roundup is toxic to all taxa of plants. Because the plant toxicity of the

customized formulation of Roundup applied in Colombia has been increased by the addition of
specialized surfactants, the herbicide spray is expected to have an even greater adverse effect on
nontarget native vegetation. As a result, the spray drift could affect nontarget native plant
species, along with the nontarget crops. Impacts on native plants have broad implications for

biodiversity, because the diverse assemblage of rainforest plants provides habitat and food for
the diverse assemblage of animals that live there. In short, the biodiversity within the rainforest
is related, in part, to the diverse habitats and food items provided by the plants. Therefore, loss
of components of the plant community will directly affect the components of the animal

community that rely on them. Ecologically significant losses of plants can occur even if large-
scale vegetation damage is not visually evident.

5.3.2 Hazards to Insects

We describe first the ecological importance of insects in the ecosystem and point out that they
are one of the groups of animals considered especially important to the biodiversity of the

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system. We then describe the potential toxic effects of spray drift on these animals. In particular,
we consider the hazards associated with the presence of surfactants in the spray mix. Our
evaluation indicates that spray drift would pose a hazard to the insect fauna.

5.3.2.1 Ecological Importance of Insects in Ecuador

It has been estimated that nearly half of Earth’s biological diversity exists in the tropics; this is

readily visible in the array of insect species that reside there. Tropical climates exhibited greater
past geological stability, as opposed to temperate areas, which promoted proliferation of insect
species. Ecosystems in tropical regions also appear to provide a large number of ecological
niches, promoting invertebrate propagation. High insect densities produced by stable climatic

conditions and large numbers of available niches resulted in heightened competition and
predation, which in turn led to increased insect biodiversity (Basset 2008). Estimates of tropical
insect species range from under 1.5 million, but the exact number is unknown; only a small

number of species have been appropriately identified and cataloged (Erwin 1982). Even less is
known about the ecological roles performed by individual species.

Biological surveys indicate that tropical insect communities are characterized by high species
richness with a low abundance per species (Price et al. 1995). This suggests that the diversity of

tropical insects is not necessarily indicative of large populations, and the low populations of
individual species may indicate that species may be susceptible to habitat loss or other
anthropogenic impact. Given these factors, and the sheer number of insect species in the

tropics, some of which are still being discovered, it is possible that species could decline or
disappear without human detection.

Beyond serving as an indicator of tropical biodiversity, insects play important roles in tropical

ecosystems. Insect species are also important decomposers in tropical ecosystems, and as such
are integral to nutrient and carbon cycles. Termite densities in the tropics of Cameroon have
been documented to reach up to 10,000 individuals/m 2 (Jones et al. 1998), signifying their
essential contribution to tropical decomposition. Similarly, herbivorous insects selectively feed

on young plants, helping to maintain proper plant age structure (Basset 2008). Tropical insect
species also provide a diverse and dense prey source for insectivorous organisms, including
many obligate insectivores. Bats, in particular, are voracious predators of tropical insects, and
their phenology and population structure may be driven in part by insect availability (Estrada

and Coates-Estrada 2001). In tropical systems, the terrestrial adults of semi-aquatic insect
species are estimated to account for an average of 21% of riparian insect biomass in the dry
season, and half of riparian insect biomass in the wet season (Chan et al. 2007).

The integral role of insects in ecosystems means that a disturbance to their populations may
have a cascading effect on plants and other species. Complex plant/insect relationships fostered
in tropical conditions have led to specialized nutrient cycling, pollination, and seed dispersal

mechanisms; in many cases, these interactions are highly specific, requiring certain species and
exact behaviors (Coley and Barone 1996; Basset 2008). Among the unique examples of this are
ant/plant mutualisms in which resident ants remove and kill herbivorous invertebrates, and
plants provide refuge and food in the form of nectar secretions (Levey and Byrne 1993).

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The pollination of fig trees, a tropical keystone species, is also dependent on species-specific
relationships with tiny wasp species (Agaonidae, Chalcidoidea). In the absence of the necessary
wasp species, fig trees will not bear fruit and reproduce (Nason et al. 1998). In a similar vein,
habitat disturbance was shown to disrupt pollination of the Amazonian tree Dinizia excelsa,

indicating that a highly localized pollinator is responsible for D. excelsa reproduction (Dick et
al. 2003). This supports the theory that tropical ecosystems are characterized by highly complex
and local species interactions, in which insects undoubtedly play integral roles.

5.3.2.2 Toxicity of Spray Mix to Insects
Although generally considered to be non-toxic to invertebrate species, pure glyphosate has been

shown to adversely affect populations of certain invertebrates, either through direct toxic effect
or through indirect effects on plant community diversity. Laboratory-determined toxicity of 40
different pesticides used regularly in orchards indicated that glyphosate was highly toxic to the

predatory mite Amblyseius fallacies. In fact, glyphosate toxicity was similar to that of paraquat,
diazinon, fenvalerate, and permethrin (Hislop and Prokopy 1981). Life spans of collembola,
isopods, and Carabidae beetles were reduced following laboratory glyphosate exposures
approximating field application rates (Cox 1995).

Customized formulations of glyphosate such as the one developed for and used in Colombia are
much more toxic than the active ingredient glyphosate. Even formulations that have not been
enhanced in the manner as that of Colombia can be toxic to insects. Newly applied formulated

RoundUp was found to be acutely toxic to beneficial insects, including parasitoid wasps,
lacewings, and predatory beetles (Cox 1995). Other insect species suffered population declines
following field applications of glyphosate, although it is unknown whether these declines
resulted from direct toxicity or from herbicide-mediated alteration in plant communities. For

instance, populations of the big eye bug (Geocoris puncti®es), an important natural enemy of
agricultural pests, declined in fields of Roundup Ready soybeans the weeks following
glyphosate applications (Jackson and Pitre 2004). The authors stated that density reductions

occurred either as a result of direct glyphosate toxicity or through a reduction of non-soybean
refugia plants. Similarly, a comparison of glyphosate-treated and non-treated loblolly pine
forests indicated that the herbicide had a significant effect on the populations of the Nantucket
pine tip moth (Rhyacionia frustrana), an important pest of a number of pine species, including

shortleaf, Virginia, loblolly, and scotch pines. Populations of R. frustrana in glyphosate-exposed
forests were prone to highly variable population fluctuations and experienced reduced pupal
weights (Guiseppe et al. 2006).

Surfactants are common adjuvants of commercial insecticide mixtures that promote the
penetration of insecticidal compounds through the insect exoskeleton, thereby increasing the
efficacy and potency of applied insecticides (Goodwin and McBrydie 2000). The surfactant
compounds used in these insecticide mixtures have the same mode of action as those used in

herbicide mixtures, and frequently, the same surfactant chemicals are used in both insecticide
and herbicide formulations. Although surfactants can greatly increase insecticide potency, there
is also significant evidence that surfactants alone are toxic to insects. The toxicity appears to

result from the surfactant-mediated alteration in the interaction of water and invertebrate cuticle
and tracheal system, causing the exposed individual to become waterlogged and drown (Cowles
et al. 2000). At sublethal surfactant exposures, this can result in disorientation and altered

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behavior, as exposed insects react to the injury to the exoskeleton and respiratory system
(Goodwin and McBrydie 2000). Because available moisture would be a strong determinant of
surfactant potency and effects, it is likely that surfactant toxicity would be enhanced in areas of
high humidity and moisture (Cowles et al. 2000).

Given that surfactants disrupt insect respiratory process and interfere with exoskeleton defenses,
population-level impacts are likely to be far-reaching and fairly unpredictable from laboratory
experiments. Significant sublethal effects, including behavioral changes, are probable, but

extrapolating these effects to the population and community level is difficult. Impacts on
different life stages are also likely to precipitate population-level effects, particularly in a
repeated exposure scenario.

The potential for surfactants to increase the toxicity of formulations is especially relevant to the
issues of concern in Ecuador. The above discussion indicates that, to the extent that toxicity to
insects is related to the strength of surfactants, the addition of special surfactants to the
Colombia formulation to kill coca could also result in increased toxicity to insects over and

above that observed for Roundup or glyphosate.

5.3.3 Hazards to Aquatic Biota, with Emphasis on Frogs

Based on results from laboratory bioassays, the surfactants added to the spray mixture are highly

toxic, and significantly more toxic to nontarget organisms than the glyphosate itself.

Researchers have determined that the Roundup surfactant POEA was primarily responsible for
the toxicity of the formulated compound to several freshwater invertebrates and fish. The

enhanced toxicity of formulations relative to glyphosate is seen through a comparison of basic
toxicity data. Glyphosate LC 50s (the exposure concentration at which 50% of the exposed
organisms would die) ranged between 97 and 150 mg/L for a number of aquatic organisms,
including rainbow trout, midge larvae, fathead minnows, catfish, and bluegills. In contrast, the

toxicity of POEA is much greater, as revealed by the lower LC50 values. POEA LC50s
(exposure concentrations at which 50% of the exposed organisms would die) for the same
organisms were determined to be between 1.4 and 18 mg/L (Folmar et al. 1979). Additionally,

Roundup surfactant POEA was also found to be toxic to a number of aquatic bacteria, algae, and
protozoa with IC50s and LC50s ranging between 0.57 and 10.2 mg/L (Tsui and Chu 2003).

Laboratory toxicity assays with different formulated products bolster the argument that
surfactants are the primary determinants of toxicity. Toxicity of glyphosate compounds to frogs

was found to be largely dependent on the formulations tested. Glyphosate-based herbicide
formulations were determined to be toxic to these species. This suggests that surfactant-
mediated toxicity is essential in determining the risk to nontarget organisms (Mann and Bidwell

1999).

There is significant evidence that commercial formulations of glyphosate are acutely toxic to
larval amphibians. Relyea (2005) reported that Roundup overspray was highly lethal to three

species of amphibians (Rana pipiens, Bufo americanus, and Hyla versicolor), with mortality
rates of 96% to 100% observed in larval amphibians. Mortality of post-metamorphic (juvenile)
amphibians was 68% to 86% within one day of Roundup application. Sediment composition of

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exposed mesocosms had no impact on the potency of Roundup, indicating that chemical
sequestration in sediment would not prevent toxic exposure. The rapid mortality observed in

larval and juvenile amphibians (e.g., within days of exposure) is a strong indication that
Roundup is directly and highly toxic to these species. Similarly, Smith (2001) concluded that
exposure to “relatively low concentrations for a short period of time, as might be
expected…with an application to clear aquatic vegetation, appears to induce high mortality in

tadpoles.” Larval Pseudacris triseriata survival was reduced to 45% following exposure to
1 ppb Kleeraway glyphosate product, and higher concentrations (e.g., 1 ppm and greater)
resulted in complete mortality of exposed larvae. In addition, toxicity of formulated products

was found to be strongly associated with glyphosa®e formulation and the po®ency of adjuvants;
formulations containing POEA (e.g., Kleeraway , Roundup, Touchdown ) were much more
toxic to aquatic amphibian life stages (Smith 2001).

Exposure to formulated glyphosate products also has been documented to cause a number of
sublethal effects in amphibian species. Rana pipiens larvae chronically exposed to both POEA
and commercial glyphosate formulations containing POEA exhibited tail damage, gonadal

abnormalities, and increased time to metamorphosis (Howe et al. 2004). Tail damage can
decrease swimming ability and increase availability to predators, while physical abnormalities
and delayed metamorphosis may prevent mating and reproduction.

Data presented in Solomon et al. (2005) concerning the toxicity of glyphosate, Roundup
formulations, and glyphosate + Cosmo Flux provide specific insight into the toxicity of the
formulation used in Colombia. These data indicate that the toxicity to aquatic biota of the

formulation used in Colombia is substantially greater than the toxicity of glyphosate alone, or
that of other formulations. Despite the toxicity of the spray, these data may actually
underestimate the toxicity of the formulation used in the aerial spraying program prior to 2003,
when a change was reported in the surfactant blend.

Figure 4 presents the distribution of toxicity values. The most toxic values are located on the
left side of the graph, because the lower the toxic concentration the higher the toxicity. The

lines running through the various data reflect the distribution in the sensitivity of species
exposed to the same types of materials. The most sensitive species are lower and to the left on
each of the lines. The figure shows three different lines. The one on the far right, in violet, is
for glyphosate alone. The units of toxicity are expressed as LC50s, which indicate the exposure

concentration at which 50 percent of the exposed organisms would die. Note that because an
LC50 is a mid-point and relates to lethality, toxic effects of the herbicides occur at even lower
concentrations. The figure clearly indicates that glyphosate alone is less toxic to aquatic

organisms than are the formulations.

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Figure 4. Reproduction of Figure 24 from Solomon et al. (2005), page 70

The dark line in the middle links toxicity data for species tested with herbicide formulations, but
not that used in Colombia. Because this line is further to the left of the violet line for glyphosate
alone, the line indicates that these formulations are more toxic to aquatic biota than glyphosate
alone. The formulations’ increased toxicity to aquatic biota is well known and is related to the

additives.

The line in the middle also shows that amphibians (larval frogs) are even more sensitive to the
formulations than are fish or aquatic arthropods (small crustaceans). This is revealed by the

presence of yellow circles on the left and lowest portion of the formulation line. Larval frogs
are at least 10 times as sensitive to the toxic effects of formulations as fish or arthropods.

The test data for glyphosate + Cosmo Flux are on the most left-hand side of the graph,

indicating that this formulation is the most toxic one tested on aquatic life. The test data shown
by Solomon et al. (2005) include fish, arthropods, and algae. This data set does not include
results for larval frogs. Based on the sensitivity distribution observed for other formulations,

had larval frogs been tested with glyphosate + Cosmo Flux, even lower lethal concentrations
would have been derived. It is unfortunate that data are not available for larval frogs, because
these are clearly the most sensitive species and are a group of special interest with respect to the
biodiversity of Colombia and Ecuador. If the toxicity of the glyphosate + Cosmo Flux

formulation to larval frogs is 10 times as great as that for fish such as the rainbow trout, then the
toxic values for these species would be in the range of 100 to 200 ▯g/L.

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Solomon et al. (2005) conclude, based on their experience, that Cosmo-Flux was the likely

cause of the increased toxicity of the glyphosate + Cosmo Flux formulation. The toxicity results
summarized by Solomon et al. (2005) are tied to dilution concepts and are expressed as
concentrations in water. As discussed later in this report, this exposure metric is appropriate for
aquatic environments, and those can include the small pockets of water used by many

neotropical frog species. However, as discussed later, the eggs, larvae, and adults of many
rainforest frogs could be exposed to full-strength herbicide when the animals are in terrestrial
habitats. This exposure would involve deposition of spray droplets on egg masses, developing
larvae being transported by adults, juvenile frogs undergoing metamorphosis, and adult frogs.

Those exposure concentrations would be orders of magnitude greater than the exposure amounts
that cause death in the studies presented by Solomon et al. (2005).

Frogs are also considered to reflect the biodiversity of the Amazonian rainforest. They are the

aquatic animal group considered by Solomon et al. to be most sensitive to herbicide spray
(Solomon et al. 2005, p. 71). For the assessment of potential ecological effects on aquatic
animals, Solomon et al. (2005) relied on a North American and European framework for
considering ecological effects on aquatic species such as frogs. However, this framework

misses important exposure pathways associated with the ecological characteristics of many frog
species in the tropics. Solomon et al. assume that effects to animals commonly thought of as
“aquatic” occur solely in open water bodies (Solomon et al. 2005, Section 3.1.4):

If water is directly over-sprayed during a spray operation, contamination of
surface waters will result. Some coca fields are located near to ponds and lakes
and some are near to streams and rivers (Helling 2003). While surface waters are
not deliberately sprayed by the pilots, some over-spray of small watercourses and

the edges of ponds, reservoirs, and lakes may occur. In the absence of measured
concentrations immediately after spraying in surface waters located close to the
fields, estimates of exposure were made using worst-case assumptions (Table10)
based on water depth assumptions used by U.S. EPA (Urban and Cook 1986) and

the EU (Riley et al. 1991).

Many neotropical frogs have life histories that are completed in whole or in part within
terrestrial systems. As a result, eggs, larvae, and adults of these species can experience

exposures associated with spraying that are much greater than those assumed by studies such as
Solomon et al. (2005), which assumed that worst-case exposures take place in shallow surface
waters where the chemicals are somewhat diluted. This can include direct contact of animals
with spray droplets (no dilution) and/or minimal dilution because of the small pockets of water

that can support frogs of the Amazonian rainforest.

The limitations of the conceptual exposure model applied by Solomon et al. (2005) have been
pointed out by others, including the Interamerican Association for Environmental Defense

(AIDA 2005). Solomon et al. (2005) missed ecologically important exposure pathways,
because a temperate climate exposure framework was applied to a tropical environment. Given
the complexity of tropical habitats, other exposure scenarios not explored in Solomon et al.
(2005) could be critical in determining the total impact of glyphosate-containing products on

amphibian populations. For instance, the larvae of several tropical frog species have been
documented inhabiting tree hollows and associated bromeliads (McDiarmid and Foster 1975;

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Savage 1968; Starrett 1960); it is possible that these tadpoles could be exposed to high
concentrations of glyphosate-containing compounds, either through direct dermal contact or by
concentration of sprayed compounds in the tiny pools they inhabit.

All frogs have an egg, larval (tadpole), and adult life stage. In North America and Europe, the
eggs and tadpoles occur primarily in ponds and other water bodies. They are typically
considered “aquatic.” However, in the tropics, many frogs complete their entire life in the

terrestrial environment, and the adults are entirely terrestrial. Examples include a diverse group
of frogs commonly known as the poison arrow frogs (subfamily Colostethinae; several members
of this subfamily have been found in the Ecuador/Colombia border region, including Ameerega
bilinguis, A. picta, A. trivittata, and E. boulengeri). These tiny frogs are basically black with

bright markings of red, green, orange, or yellow. Most poison arrow frogs live on the ground in
the leaf litter. The frog’s eggs are usually laid on a leaf, and when they have hatched, the
female allows the tadpoles to climb, one at a time, onto her back (Figure 5).

Figure 5. Adult poison dart frogs with tadpoles on their backs

The parent can let the larvae wriggle off into a pool of water, where they feed on mosquitoes

and insect eggs. However, some carry their tadpoles up into trees to protect them from danger.
There are a number of reports of frogs using small pockets of water present in trees. These
include the cavities provided by bromeliad plants that grow attached to trees (see Figure 6).
These bowl-shaped plants can hold water, and they play an important ecological role (Zahl

1975).

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Figure 6. Bromeliads plants provide habitat and water for certain tree frogs

Several subfamilies of neotropical frogs lay their eggs in terrestrial, rather than aquatic,
environments (Heying 2008; Lynch 2008; Cisneros-Heredia and McDiarmid 2007). In these
locations, the adults, eggs, and hatching larvae would be directly exposed to spray without the
benefit of dilution by water. One subfamily, the Leptodactylinae, is primarily terrestrial, foam-

nest-building frogs. The males secrete mucus from their skin and reproductive tracts, which
they then beat into foam with their legs. Mature individuals produce nests that protect the
young from desiccation and other physical risks. In several species, a parent remains with the

non-feeding tadpoles at the nest.

Another subfamily, the Centrolenidae, is composed of arboreal frogs endemic to America. They
occupy riverine, understory, and canopy layers of evergreen and semi-deciduous forest,
rainforests, cloud forests, and páramo habitats from southern Mexico to Panama and through the

Andes from Venezuela to Bolivia, with species in the Amazon basin (Cisneros-Heredia and
McDiarmid 2007). These frogs are commonly referred to as glass frogs, because many species
have a transparent ventral skin through which the internal organs are visible. As far as is

known, all species of this frog subfamily lay their egg clutches either on leaves overhanging
water or on stones next to streams or waterfalls. Furthermore, many of these frog species
exhibit parental care behaviors. For example, the male may remain nearby, next to, or even
straddling the egg clutches located on the upper or underside of leaves or on rocks (usually at

night but in some species during day and night), sometimes for considerable periods. Cisneros-
Heredia and McDiarmid (2007) note that the clutches are usually placed on exposed surfaces,
allowing hatching tadpoles direct access to water. If a male is successful in attracting females to

the site, he may continue to attend the clutches until all have hatched (see Figure 7). In some
instances, this may continue for a few weeks, depending on the periodicity of female arrival.
Under these conditions, guarding parents are subjected to extended stressful conditions
(i.e., high levels of solar radiation, dry air currents, high temperatures) that may provoke high

evaporative water loss (even in parents that retreat during the day, as they typically go to nearby
leaves also located in exposed areas of the vegetation).

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Figure 7. Eggs laid on plant surfaces and guarded by adults

Many neotropical frog species make use of puddles (including along roadsides) or man-made
structures such as cisterns to lay their eggs. Tadpoles of the frog sub-families Khinophrynidae,
Leptodactylidae, and Centkolenidae have been collected from these environs (Starrett 1960).

Puddle environments and other manmade or natural pockets of water can have water depths and
dilution volumes substantially smaller than those considered by Solomon et al. (2005).
Therefore, the “worst-case” exposure estimates assumed by Solomon et al. for evaluating
exposures to frog life stages, will underestimate actual exposures to sensitive frog life stages

using puddles in locations below the spray drift. The underestimate of exposure to frogs by
Solomon et al. (2005) is especially significant, because this group of animals appears to be
particularly sensitive to the glyphosate + Cosmo-Flux formulation, as described above.

The toxicity results summarized by Solomon et al. (2005) are tied to dilution concepts and are
expressed as concentrations in water. This exposure metric is appropriate for aquatic
environments, which can include the small pockets of water used by many neotropical frog
species. However, as already noted, the exposure concentrations in these small pockets of water

can be greater than the worst-case assumption used by Solomon et al. (2005). Therefore,
exposures can be higher, and the formulation more toxic to larval frogs living in small pockets
of water, than assumed by Solomon et al. (2005).

Because many of the frogs species have one or more terrestrial life stages, there is also the
potential that they will be exposed to full-strength herbicide formulation delivered as droplets
falling directly upon them. And as they move across the plant surfaces, they would encounter
additional herbicide droplets that have fallen upon these. Even at lower deposition rates, there

could still be a large number of individual droplets falling upon surfaces.

Laboratory and field toxicity assays indicate that glyphosate-containing formulated products are
highly toxic to several life stages and species of amphibians. Acute toxicity was shown to arise

from concentrations similar to those following over-spray, and chronic effects on frog fitness
include physical deformities and delayed development. Given their unique life histories

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(e.g., development in bromeliads and tree hollows), it is likely that many tropical species may be
exposed to much higher concentrations than those tested on North American species. As such,

although tropical species have not been as thoroughly studied as temperate amphibians, it is
likely that tropical populations are much more sensitive to the effects of glyphosate poisoning.

5.4 Hazards Associated with Misuse of Herbicide Products

The previous sections describe the hazards that arise from exposures to the chemicals in the
herbicide mixture used in the Colombia aerial spray program. The likelihood of these hazards
increases when herbicide products are misused. Because of the inherent hazards associated with

herbicide and pesticide products, industry and government utilize labeling to communicate the
possible hazards. Labels also describe how the products should be applied so that these hazards
are reduced. In this section of the report, we first describe labeling guidelines. We then present
the labels for the common constituents in the spray mixture used in Colombia.

In the U.S. and most countries, including Colombia, pesticidesincluding glyphosate-based
herbicides and adjuvantsmust be registered and labeled before the pesticide can be sold or
distributed within the country. Pesticide labeling provides legally binding requirements to

control when and under what conditions a pesticide can be applied, mixed, stored, loaded or
used. Labels also prescribe when fields can be re-entered after application and when and how
crops can be harvested. Labeling requirements are also imposed to specify what type of product
containers must be used and how they should be disposed.

U.S. EPA pesticide legal labeling requirements are specified the Federal Insecticide, Fungicide,
and Rodenticide Act, Section 2(p)(2). These regulations also cover all other written, printed, or
graphic material accompanying a pesticide or application device. General pesticide labeling

requirements and example statements for pesticide labels are set forth in the Code of Federal
Regulations 40 CFR § 156.10 (http://www.epa.gov/oppfead1/labeling/lrm/2006-lrm-chap-
03.pdf). Labels must include certain mandatory statements to ensure proper use:

Mandatory statements generally relate to the actions that are necessary to ensure

the proper use of the pesticide and to prevent the occurrence of unreasonable
adverse effects on the environment, which is defined by statute. Mandatory
statements include directions for use and precautions that direct the user to take
or avoid specific actions. The directions and precautions specify where, when

and how a pesticide is to be applied. Mandatory statements are generally written
in imperative or directive sentences (e.g., “Wash application equipment...,” “Do
not use ...,” “Users must...,” “Apply to corn at a maximum rate of one to two
pounds per acre 30 days prior to harvest”). Either EPA or the registrant may

develop mandatory labeling statements. When writing mandatory statements,
both EPA and the registrant need to ensure that such statements meet the
criterion above that the statement is necessary to ensure proper use of a pesticide
and to prevent unreasonable adverse effects on the environment. The following

directions and precautions are examples of mandatory statements: “Wear chemical
resistant gloves.” …“Do not apply directly to water.” …“Do not enter into treated

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areas for 12 hours.” …“Do not apply when wind speed exceeds 15 mph.” (EPA
Label Review Manual p. 3-4.)

Many countries around the world have adopted similar regulations; some of them are modeled
on U.S. EPA labeling rules. To help ensure greater international consistency (harmonization) of

pesticide labels, U.S. EPA is supporting The Globally Harmonized System (GHS) of
Classification and Labelling of Chemicals. The GHS is a worldwide initiative to promote
standard criteria for classifying chemicals according to their health, physical, and environmental

hazards. It uses pictograms, hazard statements, and the signal words “Danger,” “Warning,” and
“Caution” to communicate hazard information on product labels and safety data sheets in a
logical and comprehensive way. The primary goal of GHS is better protection of human health
and the environment by providing chemical users and handlers with enhanced and consistent

information on chemical hazards. GHS will provide a harmonized basis for the first step in the
sound management of chemicals—identifying hazards and communicating them.
(http://www.epa.gov/oppfead1/labeling/lrm/chap-12).

Harmonized registration and labeling requirements have also been developed at the regional
level. The Andean Community has developed a common system for the registration and control
of pesticides (Andean Community 1998), and regional labeling requirements (Andean
Community 2002). The European Union (1991) has also developed a harmonized system for

the regulation of pesticides, including labeling requirements.

As an example, Roundup SL, a glyphosate-based herbicide sold in Colombia, includes
the following mandatory statements and pictograms:

Do not store or transport with seeds and food for human or animal consumption.
Do not store in living areas. Keep locked in a dry and ventilated place in the
original packaging. Use glasses, gloves, rubber boots and protective clothing

during use and application. Do not smoke, eat or drink while preparing or
applying this product. Rinse empty containers three times and empty them into
the spray tank. Puncture and destroy the containers. No container which has
held pesticides should be used to store food or drinking water. Apply under

calm wind conditions. Avoid contact with eyes and skin. Causes irritation.
Upon completion of work, change clothes and wash with plenty of soap and
water. Do not contaminate water sources. Do not apply to or pour surplus

product directly over water bodies. During application, avoid allowing the
product to fall on leaves or green parts of the stems of crops. Suspend the
application if rain is imminent.

As described in Section 4, some product labels provide specific guidance regarding
aerial spraying. For example, the label for Roundup Pro, a product marketed in the

United States, includes the following precautions regarding spray drift management:

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Figure 8. Section 5.0 of label from Roundup Pro as sold in U.S.

The Roundup Pro label (Section 5.0) also provides specific guidance regarding factors

that affect spray drift, including droplet size, wind, temperature, humidity, temperature
inversions, and swath adjustment.

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6 Bibliography of Relevant Literature

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MY03197.000 0210 0409 CM07 51 ANNEX 158

Attachment AANNEX 158

Pieter N. Booth

Principal

Professional Profile

Mr. Pieter Booth is a Principal in Exponent’s EcoSciences practice. He has 28 years of
experience as an environmental scientist and program manager specializing in ecotoxicology
and risk assessment, natural resource damage assessment (NRDA), and restoration of natural
systems. Mr. Booth is nationally recognized for his NRDA work, particularly his role in

technical negotiations on behalf of industry for favorable restoration-based settlement at several
of the largest NRDA cases in the country, including Saginaw River and Bay and Lake
Hartwell/Twelvemile Creek NRDAs. He has been the project manager or consulting expert on
NRDAs for industrial clients in several other high-profile natural resource damage cases. In

these roles, he has provided technical support to legal teams in the development of case strategy
and in the supervision and preparation of materials for litigation support under CERCLA,
RCRA, the Clean Water Act, and the regulatory programs of various states.

He has directed many complex multidisciplinary projects to assess ecological risks and impacts
from releases of hazardous substances, including oil. Mr. Booth has a particularly strong
background in managing and directing evaluations of the potential impacts of PCBs and metals
on fish, birds, and mammals; ecological risks posed by sediment contamination; and options for

sediment management. Mr. Booth has developed and managed a corporate program for a
Fortune 500 manufacturing company, to implement risk assessment guidance for program
managers in the remediation group and provide site-specific ecological risk assessments at

numerous sites nationwide.

For other industrial clients, Mr. Booth has assisted in developing overall strategies for
environmental issues, designing site-specific assessments, and negotiating risk-based response

actions with state and federal agencies. In addition, he has supervised the study design,
collection, and analysis of environmental data and the development of PC- and web-based data
management, analysis, and visualization tools. Mr. Booth has led numerous projects directed at
the characterization and remediation of contaminated sediments in the United States and South

America, and he has helped to create guidance and policy for regional sediment management
programs in Puget Sound and San Francisco Bay.

Academic Credentials and Professional Honors

M.M.A., Marine Affairs, University of Washington, 1984
I.P.A. Certificate, Integrative Program in Administration, University of Washington Graduate
School of Business, 1983

B.A., Biology, University of the Pacific, 1977

01/09 ANNEX 158

Licenses and Certifications

Hazardous Waste Operations and Emergency Response 40-hour training program; Hazardous
Waste Operations Management and Supervisor 8-hour training program

Publications

Booth PN, Salatas, JH, Kaetzel RS, Gard NW, Yost LJ, O'Boyle RA, Mackay CE. Risk
assessment as a decision-making tool for treatment of emissions at a new aluminum smelter in

Iceland: 1. Background and introduction. J Hum Ecol Risk Assess, 2009, in press.

Kaetzel RS, Yost LJ, O'Boyle RA, Booth PN. Risk assessment as a decision-making tool for

treatment of emissions at a new aluminum smelter in Iceland: 2. Human health risk
assessment. J Hum Ecol Risk Assess, 2009, in press.

Salatas JH, Booth PN, Gard NW, O'Boyle RA, Mackay CE. Risk assessment as a decision-

making tool for treatment of emissions at a new aluminum smelter in Iceland: 3. Ecological
assessment. J Hum Ecol Risk Assess, 2009, in press.

Menzie CA, Booth P, Law SA, von Stackelberg K. Use of decision support systems to address
contaminated coastal sediments: Experience in the United States. In: Decision Support
Systems for Risk-Based Management of Contaminated Sites. Marcomini A, Suter II GW, Critto
A (eds), Springer Verlag, 439 p, 2009.

Booth P, Gard N, Law S, Davis R. Sustainability: Considerations for including eco-assets in a
company’s bottom line. American Bar Association Climate Change, Sustainable Development,

and Ecosystems Committtee Newsletter 2007; 11(1):7–11.

Booth P, Gribben K. A review of the formation, environmental fate, and forensic methods for

PAHs from aluminum smelting processes. Environ Forens 2005; 6(2):133142.

Booth PN, Bigham G, Gasch, Jr. M. Natural resource damage looms as major liability issue.
Environ Corp Counsel Report 1994; 1(2):5–8.

Booth PN, Jacobson MA. Development of cleanup standards at Superfund sites: an evaluation
of consistency. J. Air Waste Manage Assoc 1992; 42:762–766.

Booth PN, Becker DS, Pastorok RA, Sampson JR, Graham WJ. Evaluation of restoration
alternatives for natural resources injured by oil spills. Prepared for the American Petroleum

Institute, Washington, DC, API Publication No. 304, 1991.

Jacobson MA, Booth PN. A review and evaluation of hazardous waste cleanup standards
implemented after the enactment of the Superfund Amendments and Reauthorization Act. In:

Proc. Haztech International ‘90. Institute for International Research, Inc., New York, NY, 1990.

Pieter N. Booth
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Booth PN, Becker DS, Barrick RC, et al. A screening-level approach to estimating natural
resource damages from contaminated marine sediments. In: Proc. Sixth Symposium on Coastal
and Ocean Management. American Society of Civil Engineers, New York, NY, 1989.

Pastorok RA, Booth PN, Williams LG. Estimating potential health risks of chemically
contaminated seafood. Puget Sound Notes, U.S. Environmental Protection Agency Region 10,

Seattle, WA, May 1986.

Presentations

Booth P, Salatas J, Gard N, Mackay C, O'Boyle, R. A predictive ecological risk assessment for
evaluating treatment options for aerial emissions at an aluminum smelter is Reyðarfjörður East

Iceland. Presented at Society of Toxicology, Charlotte, NC, March 25–29, 2007.

Salatas JH, Booth P, Gard N, Mackay C, O'Boyle R. Using predictive risk assessment to

evaluate aluminum smelter treatment options for protection of mammalian communitith in
Iceland. Presented at Society of Environmental Toxicology and Chemistry 27 Annual
Meeting, Montreal, Quebec, November 5–9, 2006.

Salatas JH, Booth P, Gard N, Mackay C, O'Boyle R. Using predictive risk assessment to
evaluate treatment options for aluminum smelter emissions. Session: Challenges and

Innovations in the Evaluation of Birds in Ecolothcal Risk Assessments. Presented at Society of
Environmental Toxicology and Chemistry 27 Annual Meeting, Montreal, Quebec, November
5–9, 2006.

Booth P, Harman W, Kirchof C. Dam removal as out-of-kind compensatory restoration for
CERCLA Releases: The case of Twelvemile Creek/Lake Hartwell, SC. SETAC, Interactive

Poster Presentation, Abstract Reference No. BOO-1117-819783, November 16, 2005.

Booth P, Gard N, Bodishbaugh R. Tools for Streamlining Ecological Risk Assessments at

RCRA Corrective Action Facilities. SETAC, Poster Session, Abstract Reference No: BOO-
1117-829805, TP20 Ecological Risk Assessment, November 15, 2004.

Booth P, Edwards M, Nielsen DL. Spthial and temporal trends of PCth in fish in response to
natural recovery in sediments. 4 SETAC World Congress 25 Annual Meeting in North
America, Portland, OR, November 1418, 2004.

Booth PN, Medved JB, Williams L. Wetland restoration under the Saginaw River and Bay
NRD settlement. Presented at SETAC 24 Annual Meeting, Austin, TX, November 913,

2003.

Mackay CE, Becker S, Law S, Booth P. Probabilistic assessment of the risk to terrestrial birds
rd
and mammals in a small urban lake; Harris Lake, MI. Presented at the 23 Annual Society of
Environmental Toxicology and Chemistry Meeting, Austin, TX, November 9–13, 2003.

Pieter N. Booth
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Medved JB, Booth PN, Moore M, Nielsen D, Goode D. Use of GIS with dynamically linked
database tools in quantitative ecological assessment—A case study. Interactive poster

presentation at the Society of Toxicology and Environmental Chemistry Annual Meeting and
Conference, Philadelphia, PA, November 14–18, 1999.

Booth P, Medved J, Moore M, Mackay C, et al. Estimated vs. measthed dietary exposure of
terrestrial wildlife to contaminants in soil. Presented at the 15Annual Conference on
Contaminated Soils, Amherst, MA, October 18–21, 1999.

Booth PN, Ecological risk assessment and management: updating the tools to provide more
value. General Motors Corporation Global Environmental Conference, Dearborn, MI, October
1999.

Booth PN, Henson KA. Multiuser sites for contaminated sediment disposal. In: Proc. ASCE
Specialty Conference, Water Forum ’92, Baltimore, MD, August 22–24, 1992.

Project Experience

Natural Resource Damage Assessment (NRDA)

Consulting restoration expert on behalf of Dow Chemical Company in the Tittabawasse River
and Saginaw River and Bay NRDA matter. Responsible for developing and negotiating
technical approaches for this cooperative NRDA and harmonizing these approaches with injury

quantification efforts. Focus is on identifying and scaling restoration projects to compensate the
public for alleged interim losses resulting from releases of dioxins, furans, and potentially other
substances.

Project manager and consulting expert on behalf of industry for restoration-based settlement
discussions in the Ottawa River NRDA matter. Primary issues include evaluation of alleged

injury due to releases of PCBs, PAH, and metals relative to general ecological degradation due
to baseline conditions, and identification and scaling of potential restoration projects to foster
cooperative, restoration-based settlement.

Managing and providing technical support as consulting expert to Alcoa and General Motors in
settlement negotiations in the St. Lawrence River environmental natural resource damage
matter. Technical issues center on PCBs and polycyclic aromatic hydrocarbons in sediment of

the Grasse, Raquette, and St. Lawrence rivers. Overseeing development and negotiation of all
technical aspects of the matter, including potential injury and service reductions to benthic
macroinvertebrates, fish, piscivorous and insectivorous birds, mammals, aquatic plants, and
herptiles. Have a lead role in identification, scaling, and development of compensatory

restoration projects for ecological services. Developed and presented technical positions and
exhibits during negotiations with the New York State Department of Environmental
Conservation, New York Attorney General’s office, U.S. Department of the Interior, National

Oceanic and Atmospheric Administration, and St. Regis Mohawk Indian Tribe.

Project manager on behalf of General Motors for all aspects of technical support on the Saginaw
River and Bay NRDA matter. Played a key role in the development and implementation of
Pieter N. Booth
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technical strategies that were implemented successfully to achieve a favorable settlement for
General Motors in this landmark natural resource damage case. The underlying technical issues
were related to developing realistic baseline conditions for allegedly injured resources, counter-

positions to the injuries alleged by the trustees, and an innovative and cost-effective restoration
package. Provided detailed evaluations of causation on a variety of injuries, including
bioaccumulation of PCBs by fish and reproductive effects of PCBs on fish and birds. General

Motors recognized the contribution by bestowing a Worldwide Facilities Group 1998 Crew
Award.

Managed and was lead consulting expert for Schlumberger in support of settlement negotiations

in the Lake Hartwell natural resource damage case. Key technical issues revolved around
allegations of fisheries-related impacts due to bioaccumulation of PCBs, and putative impacts of
PCBs on benthic macroinvertebrate communities, fish, insectivorous birds, and piscivorous
birds and mammals. Another key issue was the rate of recovery from alleged PCB-mediated

injury, given EPA’s selected remedy of monitored natural recovery. Directed the development
of technical positions regarding the likely extent of injury and reductions in ecological services,
if any, that were likely to have resulted from injuries. Presented technical positions during

negotiation sessions with federal trustees and trustees from the states of Georgia and South
Carolina, and provided technical assistance for selecting and determining the scale of the
preferred compensatory restoration projects. Was co-author and technical editor of the Lake
Hartwell restoration and compensation determination plan.

Managed a natural resource injury assessment for ARCO in support of settlement negotiations
in the Clark Fork River natural resource damage case. The injury assessment included modeling

past, present, and future water quality based on sediment/water interactions and provided critical
comments on the trustee’s case regarding sediment injury. The critique included a detailed
evaluation of available sediment quality criteria and an evaluation of ecological risks posed by
sediments with elevated concentrations of metals.

Managed tasks to quantify baseline injuries and project cumulative future injury for
groundwater, geologic, and surface-water resources at the Anaconda mining complex in the
Clark Fork River natural resource damage case. The analyses of injury provided the basis for

litigation support and support during settlement negotiations in a natural resource damage claim.

Managed technical support activities for a national-level NRDA program. Determined

contaminant transport and fate, habitat degradation, bioaccumulation, and resource injury.
Responsible for studies at more than 100 Superfund sites. Studies characterized risks to natural
resources, assessed injury and potential damages to natural resources, and offered
recommendations for future investigations, including restoration.

Managed a task to characterize historical activities at a large industrial site and evaluate regional
waste management activities in terms of potential effects to a lake environment. Regional waste

management activities were characterized to aid in apportioning injury and damages in
preparation for an NRDA. Developed materials balance calculations for more than 100 years of
activities at a soda ash plant and more than 50 years of activities at two chlor-alkali plants and a
chlorinated benzene plant.

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Managed tasks to develop technical memoranda describing economic theory for NRDAs, the
applications of the theory, and approaches to assessing damages to groundwater from hazardous
waste sites. Memoranda were used by the Washington State Department of Ecology to develop

a state program for NRDAs.

Managed NRDAs at five hazardous waste sites. Activities included biological and economic

assessment of damages to recreational fisheries and benthic infauna and strategic evaluation of
use and nonuse damage estimates. Developed an approach for assessing the decrease in
economic value associated with benthic community effects.

Ecological Risk Assessment

Managed novel comparative human health and ecological risk assessments for air emissions of
sulfur dioxide, hydrogen fluoride, PAH, and particulate material from a proposed aluminum

smelter in Reyðarfjörður, Fjarðabyggð, Iceland. The primary objective of this predictive risk
assessment was to determine whether there would be consequential differences in the level of
risk posed by air emissions from the smelter operation with and without seawater scrubbers.

A matrix of air modeling data was obtained for more than 10,000 receptor points under 99
discrete simulation scenarios to support the risk assessments. Spatially and temporally explicit
exposure modeling was used in a probabilistic framework to evaluate risks to plants, birds, and
mammals. The risk assessment resulted in a favorable outcome for the client who was able to

obtain a permit without having to install costly seawater scrubbers.

Managing and providing corporate support on all site-specific ecological risk assessments for

General Motors. Also developing corporate guidance for ecological risk assessment for General
Motors project and program managers. Responsibilities for this $7 million program include
overseeing development of corporate strategy on ecological risk assessment; participating in
negotiations with state and federal regulatory agencies on policy and regulatory issues, as well

as scope and direction of site-specific assessments; and ensuring consistency among all ongoing
site ecological risk assessments. Managed over 30 risk assessments under this program, ranging
from habitat characterization to multimillion dollar and multi-year investigations.

Managing a quantitative risk assessment to develop an ecologically based site remediation
strategy for a stream, associated wetlands, and abandoned stormwater detention basin in
Framingham, Massachusetts. This multi-phase risk assessment includes design and

implementation of a state-of-the-science, site-specific bioavailability study of PAH in
conjunction with 42-day Hyallela azteca sediment toxicity testing. Results of this novel
approach indicate that sediment toxicity is driven by metals (lead and zinc) rather than PAH,
despite PAH concentrations in the many hundreds of parts per million. Remedial design based

on the results of the risk assessment represents a cost savings of more than $2 million over a
remedy based on default cleanup levels.

Managed a quantitative probabilistic risk assessment to develop an ecologically based
remediation strategy for an urban lake and associated wetlands and uplands in Pontiac,
Michigan. Results of the risk assessment indicated that that no further action was needed to
address ecological risk from PCBs and metals in wetland and upland soils or to address risk to

piscivorous wildlife feeding in the lake. Surveys of benthic macroinvertebrates indicated
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significant population and community effects in the lake; however, a detailed limnological study
indicated that the major stressor was related to seasonal stratification and low dissolved oxygen.
These findings were used to negotiate and implement a limited sediment capping project saving

the client over $12 million compared to sediment removal.

Managed and conducted an ecological risk assessment to meet Michigan Part 201 requirements

at a site involved in settlement negotiations for a major natural resource damage case.
Developed innovative strategic approaches to ecological risk assessment and extensive
negotiation of technical and procedural issues with Michigan State agency representatives and
the federal trustee. Successfully demonstrated low bioavailability of elevated concentrations of

metals in soil.

Provided technical support to an industry client in negotiating the ecological risk assessment and
sediment assessment components of the Ohio Voluntary Action Program rule. Participated in

several negotiation meetings, and developed solid scientific positions on issues such as toxicity
testing, bioindicators, and use of reference area comparisons.

Contaminated Sediment Management

Managed a project investigating sediment contamination in access channels to the Port of
Buenos Aires, Argentina, in support of a navigation dredging project. Evaluated the

applicability of international sediment standards and contaminated-sediment management
practices to develop a suitable and economically viable disposal option. Designed,
implemented, and concluded a sediment sampling program within a 3-week period.

Geochemical analysis of metals contamination demonstrated no significant environmental
impacts, allowing the project to go forward in a timely and cost-effective manner using open-
water unconfined disposal for the majority of dredged material.

Managed a sediment investigation in the lower Hudson River at Sleepy Hollow, New York.
This work is being performed in anticipation of the demolition of a manufacturing complex and
the multimillion dollar redevelopment of waterfront property. The sediment investigation
focused on identifying spatial patterns of distribution of metals in sediment and the association

of the metals contamination with local point and nonpoint sources.

Managed a project providing technical assistance and oversight for field activities, data

evaluation and validation, community relations, enforcement support, and RI/FS support at a
naval installation. This complex site presented a wide range of contamination problems in soils,
groundwater, surface water, biota, and sediments.

Managed a project that evaluated the feasibility of implementing a multiuser disposal site
program for contaminated sediments in Puget Sound, Washington. Results indicated that a lack
of disposal capacity was threatening the Puget Sound sediment cleanup program, as well as

navigation maintenance and improvement projects. The greatest challenges to program
implementation were site selection (upland, nearshore, and aquatic sites) and liability
management. Document was used by the client to formulate recommendations for
implementing a regional program that was presented to state and federal agencies and the state

legislature.
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Managed a project evaluating disposal alternatives for dredged material in San Francisco Bay.

Alternatives were evaluated for aquatic disposal in dispersive and nondispersive sites with
material rehandling, disposal in diked baylands and other nearshore areas, and disposal in
upland sites.

Analyzed regulations and guidelines and documented the decision-making framework for open-
water unconfined disposal of dredged material in Puget Sound, Washington.

Evaluated mitigation actions and coordinated the preparation of an EIS on developing and
implementing numerical sediment quality standards. Standards focused on establishing
sediment impact and recovery zones and a sediment cleanup decision process for Puget Sound,

Washington. Evaluation included quantifying disproportionate effects to small business
enterprises.

Managed a project to assess the long-term bacteriological effects on freshwater sediments from

a spill of untreated sewage and storm water. Sediments were sampled from three combined
sewer overflows to compare indicators of human fecal contamination. Results of the $17,000
study were successfully used to save the client more than $250,000 in cleanup and restoration

costs.

Participated in developing numerical criteria based on sediment chemistry; amphipod,
Microtox ®, and oyster larvae bioassay; and benthic community structure for guiding sediment

remedial action at a Superfund site in Washington.

Environmental Impact Assessment and Policy Analysis

Managed the visual and avian impacts components of an environmental impact assessment for a
500-kV power line project in the Esteros del Iberá wetland area of northern Argentina. The

World Bank is currently using this work as the standard for projects of this type in Latin
America. The conclusions and recommendations developed by Exponent on these highly
controversial issues allowed the project to be completed ahead of schedule and below previously
projected costs for mitigation.

Managed and supervised the development of multijurisdictional action plans to control toxic
contaminant loading from point and nonpoint sources to five urban bays of Puget Sound,

Washington. Action plans represented the culmination of lengthy and complex negotiations
among source control programs of numerous federal, state, and local agencies and citizen
groups. In some cases, negotiations spanned 2 years.

Developed and implemented a conceptual model for performing marginal analyses to determine
optimal degrees of restoration following oil spills. Marginal analysis was designed to assess
natural resource damages based on restoration costs and residual damages in an economically

efficient manner. Results were used as an industry policy document for developing federal oil
spill damage assessment regulations.

Managed the review of more than 200 record of decision documents to compile information on
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cleanup standards, remedial actions, and applicable regulations in support of Washington State

Department of Ecology efforts to develop cleanup standards for uncontrolled hazardous waste
sites. Project was the first analytical documentation of cleanup standard development at federal
sites following the enactment of SARA.

Analyzed local, state, and federal government programs and policies to recommend institutional
mechanisms for managing a comprehensive environmental monitoring program for Puget

Sound, Washington.

Served as project manager for the compilation and synthesis of all existing Puget Sound data

relating to toxic and bacterial contamination, environmental impacts, and human health risks for
inclusion in a document for public distribution.

Professional Affiliations

x Society for Environmental Toxicology and Chemistry

x Ecological Society of America
x Society for Ecological Restoration

Pieter N. Booth
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01/09 ANNEX 158

Janci Chunn Lindsay, Ph.D.

Senior Scientist

Professional Profile

Dr. Lindsay is a Senior Scientist in Exponent’s Health Sciences Center for Toxicology and
Mechanistic Biology. Dr. Lindsay has 16 years of scientific experience, with an emphasis on
the study of pulmonary pathologies resulting from environmental, occupational, and
chemotherapeutic exposures. Her expertise within Exponent centers on evaluating the complex

dynamics of toxicity, such as toxicant pharmacology, exposure route, dose/response, host
metabolism, and subsequent cellular effects as they relate to the contribution of specific
substances to human disease.

Dr. Lindsay holds a doctorate in Biochemistry and Molecular Biology and has extensive
experience in analyzing the molecular profile of pharmacologic responses as they pertain to the
dose/response relationship, specifically in terms of analyzing and evaluating molecular markers
of disease, or “Toxicogenomics.” Additionally, she brings her expertise in evaluating toxicant

contributions to lung pathologies—such as asthma, reactive airway disease, chronic obstructive
pulmonary disease (COPD), bronchiolitis obliterans, organizing pneumonitis, interstitial
pneumonia, and pulmonary fibrosis—that may be claimed following chemical, drug, or
particulate exposure.

Academic Credentials and Professional Honors

Ph.D., Biochemistry and Molecular Biology, Graduate School of Biomedical Sciences,
University of Texas, 2006
B.S., Biological and Physical Sciences, University of Houston, Downtown, 1993

Dean’s Research Award, GSEC, University of Texas Medical School, Houston, Texas, 2005;
T.C. Hsu Scholarship in Genetics & Cell Biology, UT MD Anderson Cancer Center, Houston,
Texas, 2005; University of Texas Golf Scholarship, UTHSC-Houston, 2004, 2005; Excellence in
the Pre-Health Sciences Award, University of Houston-Downtown, 1993

04/08ANNEX 158

Publications

Mi T, Abbasi S, Zhang H, Uray K, Chunn JL, Xia LW, Molina JG, Weisbrodt NW,
Kellems RE, Blackburn MR, Xia Y. Excess adenosine in murine penile erectile tissue
contributes to priapism via A adenosine receptor signaling. J Clin Invest 2008; 118(4):1491–
2B
1501.

Chunn JL, Mohsenin A, Young HY, Lee CG, Elias JA, Kellems RE, Blackburn MR. Partially

adenosine deaminase deficient mice develop pulmonary fibrosis in association with adenosine
elevations. Am J Physiol Lung Cell Mol Physiol 2006; 290:579–587.

Willems L, Reichelt ME, Molina JG, Sun CX, Chunn JL, Ashton KJ, Schnermann J, Blackburn
MR, Headrick JP. Effects of genetic deletion of adenosine deaminase and A1 receptors in
normoxic and ischaemic hearts. Cardiovasc Res 2006; 1:71(1):79–87.

Sun CX, Zhong H, Molina JG, Belardinelli L, Zeng D, Mohsennin A, Chunn JL, Blackburn MR.
Role of A2B Receptor signaling in adenosine-dependent pulmonary inflammation and injury.
J Clin Invest 2006; 116(8):2173–2182.

Reichelt ME, Willems L, Molina JG, Sun CX, Chunn JC (Noble), Ashton KJ, Schnermann J,
Blackburn MR, Headrick JP. Genetic deletion of the A1 adenosine receptor limits myocardial

ischemic tolerance. Circ Res 2005; 18:96(3):363367.

Chunn J, Molina JG, Mei T, Xia Y, Kellems R, Blackburn MR. Adenosine dependant

pulmonary fibrosis in adenosine deaminase deficient mice. J Immunol 2005; 175:19371946.

Blackburn MR, Lee CG, Young HWJ, Chunn JL, Banerjee SK, Elias JA. Adenosine is an

important mediator of IL-13 induced inflammation in the lung: Evidence for an IL-13-adenosine
amplification pathway. J Clin Invest 2003; 112:332–343.

Chunn JL, Young WJ, Colasurdo GN, Banerjee SK, Blackburn MR. Adenosine-dependent
airway inflammation and hyperresponsiveness in partially adenosine deaminase deficient mice.
J Immunol 2001; 167:4676–4685.

Blackburn MR, Volmer JB, Chunn JL (Thrasher), Crosby JR, Lee JJ, Kellems RE. Metabolic
consequences of adenosine deaminase deficiency in mice are associated with defects in

alveogenesis, pulmonary inflammation and airway obstruction. J Exp Med 2000; 192:159170.

Zhong H, Chunn JL, Volmer JB, Fozard JL Blackburn MR. Adenosine mediated mast cell
degranulation in adenosine deaminase-deficient mice. J Pharmacol Exp Ther 2000;

298(2):433440.

Blackburn MR, Wubah JA Chunn JL, Thompson LF, Knudsen TB. Transitory expression of the

A2b adenosine receptor during implantation chamber development. Develop Dynam 1999;
216:127–136.

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04/08 ANNEX 158

Skinner SM, Kieback DG, Chunn JL, Jones LA, Metzger DA, Malinak LR, Dunbar BS.
Identification of a meiotically expressed carbohydrate antigen in ovarian carcinoma II.

Association with proteins in tumors and peritoneal fluid. Anticancer Res 1997; 17:901906.

Book Chapters

Dunbar BS, Chunn JL. Multimedia methods in molecular biology. In: Techniques in
Electrophoresis. Roultledge (ed), Chapman and Hall, Inc., Hampshire, U.K., 1997.

Wagner M, Chunn JL. Allergy. In: The Encyclopedia of Epidemiology, 2007.

Chunn JL. Asthma. In: The Encyclopedia of Epidemiology, 2007.

Published Abstracts

Fernandez P, Trzaska S, Chunn JL, Blackburn MR, Cronstein BN, Chan ESL. Adenosine
deaminase deficiency promotes dermal fibrosis. 8th International Symposium on Adenosine and
Adenine Nucleotides. Universita Degli Studi Di Ferrara, Italy, 2006.

Chunn Noble JL, Molina TM, Yang X, Rodney KJ, Blackburn MR. Adenosine induced
pulmonary fibrosis in adenosine deaminase-deficient mice. American Thoracic Society, San
Diego, CA, 2005.

Chunn Noble JL, Molina JG, Blackburn, MR. Examining the role of adenosine in an
experimental model of pulmonary fibrosis. International Purine Meeting, Chapel Hill, NC, 2004.

Chunn JL, Young HWJ, Blackburn MR. Examining the role of adenosine in bleomycin-induced
lung fibrosis. American Thoracic Society Annual Meeting, Atlanta, GA, 2002.

Chunn JL, Young HWJ, Colasurdo GN, Blackburn MR. Chronic elevations in adenosine are
associated with severe lung inflammation and fibrosis in partially adenosine deaminase deficient
mice. American Thoracic Society Annual Meeting, San Francisco, CA, 2001.

Blackburn MR, Zhong H, Chunn JL, Volmer JB. Adenosine deaminase deficient mice as models
of adenosine mediated lung inflammation. 96th American Thoracic Society Meeting, P209:D21,
2000.

Prasad SV, Chunn JL, Skinner SM, DeMayo F, Dunbar BS. Generation of mice transgenic for
the human homologue of the rabbit 55kd zonae pellucida sperm receptor protein. Mol Biol Cell

7:481a; Annual Meeting for the Society for the Study of Reproduction, Davis, CA, 1996.

Chunn JL, Skinner SM, Dunbar BS. Biological reproduction characterization of secretory
proteins of rabbit ovarian surface antigens. Annual Meeting for the Society for the Study of

Reproduction, Davis, CA, 1995.

Janci Chunn Lindsay, Ph.D.
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Prior Experience

Graduate Research Assistant, The University of Texas Medical School, UTHSC, Department of
Biochemistry and Molecular Biology, 2000–2006

Research Assistant II, The University of Texas Medical School, UTHSC, Department of
Biochemistry and Molecular Biology, 1998–2000
Research Assistant I, Baylor College of Medicine, The Children’s Nutrition Research Center,

Department of Pediatrics, Houston Medical Center, 1998
Research Technician III, Baylor College of Medicine, Department of Neonatology, Houston
Medical Center, 1997–1998

Research Technician II, Baylor College of Medicine, Cell Biology Department, 1993–1996

Professional Affiliations

x American Thoracic Society (member)
x American Chemical Society (member)

x Society of Toxicology (member)

Janci Chunn Lindsay, Ph.D.
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Susan B. Kane Driscoll, Ph.D.

Managing Scientist

Professional Profile

Dr. Susan Kane Driscoll is a Managing Scientist in Exponent’s EcoSciences practice. She is an
aquatic toxicologist, with 19 years experience in toxicology, specializing in ecological risk
assessment, environmental chemistry, sediment toxicity testing, and the toxicity and
bioavailability of sediment-associated contaminants to aquatic organisms and wildlife.

Dr. Driscoll has directed or participated in numerous ecological risk assessments for RCRA,
Superfund, and hazardous waste sites, serving a variety of industrial, utility, and governmental
clients. She has extensive experience in designing and conducting laboratory and field aquatic
toxicity and environmental fate studies in accordance with rigorous quality assurance practices.

She has designed and contributed to numerous environmental programs that were used to
develop technically defensible solutions to environmental problems and has negotiated their
acceptance with state and federal authorities.

Dr. Driscoll is a specialist in the field of sediment toxicology and her original research and
publications in the areas of bioavailability and toxicity of sediment-associated contaminants are
widely cited. She has extensive knowledge of sediment toxicity testing, the technical basis and
predictive ability of various sediment quality benchmarks, and has served as a reviewer for the

development of emerging benchmarks.

Academic Credentials and Professional Honors

Ph.D., Environmental Sciences, University of Massachusetts, 1994
B.S., Natural Resources, University of Rhode Island, 1981

Integrated Risk Assessment Paper of the Year for 2002 for “A Comparative Screening-Level
Ecological and Human Risk Assessment for Dredged Material Management Alternatives in
New York/New Jersey Harbor,” Human and Ecological Risk Assessment 8:603–626

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Publications

Kane Driscoll SB, Burgess RM. An overview of the development, status, and application of
equilibrium partitioning sediment benchmarks for PAH Mixtures. Hum Ecol Risk Assess 2007;
13:2:286–301.

Kane Driscoll SB, Amos CB, McArdle ME, Southworth B, Menzie CA, Coleman A. Use of
Equilibrium Partitioning Sediment Benchmarks (ESBs) to predict toxicity of PAH contaminated
sediments. Electric Power Research Institute (EPRI), Palo Alto, CA, 1010371, 2005.

Kane Driscoll SB, Amos CB, McArdle ME, Southworth B, Menzie CA, Coleman A. Sediment
biotoxicity at former MGP and coking sites. Electric Power Research Institute (EPRI), Palo

Alto, CA; New York State Electric & Gas Corporation, Binghamton, NY; Central Hudson,
Poughkeepsie, NY; and PSEG Services, LLC, Newark, NJ, 1011168, 2004.

Kane Driscoll SB, McArdle ME, M.S., Menzie CA, Thompson T, Mortensen L, Fitzpatrick A.

Using Polycyclic Aromatic Hydrocarbons in sediments for judging toxicity to aquatic life:
Volume I and II, EPRI Final Report. Electric Power Research Institute (EPRI), Palo Alto, CA,
1005280, 2003.

Kane Driscoll SB, Wickwire WT, Cura JJ, Vorhess DJ, Butler CL, Williams LW, Moore DW,
Bridges TS. A comparative screening-level ecological and human health risk assessment for
dredged material management alternatives in New York/New Jersey Harbor. Hum Ecol Risk

Assess 2002; 8(3):603626.

Vorhees DJ , Kane Driscoll SB, Von Stackelberg K, Cura JJ, Bridges TS. An evaluation of

sources of uncertainty in a dredged material assessment. Hum Ecol Risk Assess 2002;
8(2):369389.

Kane Driscoll SB, Menzie CA, Burton GA, Williams J, Coleman A. Review of toxicology of
PAHs in invertebrate aquatic organisms. EPRI Final Report. Electric Power Research Institute
(EPRI), Palo Alto, CA, 1006594, 2001.

Landrum PF, Tigue EA, Kane Driscoll SB, Gossiaux DC, Van Hoof PL, Gedeon ML, Adler M.
Bioaccumulation of PCB congeners by Diporeia spp.: Kinetics and factors affecting

bioavailability. J. Great Lakes Res 2001; 27(2):117133.

Kane Driscoll SB, Schaffner SC, Dickhut RM. Toxicokinetics of fluoranthene to the amphipod,
Leptocheirus plumulosus, in water-only and sediment exposures. Mar Environ Res 1998;

45(3):269284.

Kane Driscoll SB, Landrum PF. A comparison of equilibrium partitioning and critical body

residue approaches for predicting toxicity of sediment associated fluoranthene to freshwater
amphipods. Environ Toxicol Chem 1997; 16(10):21792186.

Susan B. Kane Driscoll, Ph.D.
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Kane Driscoll SB, Harkey GA, Landrum PF. Accumulation and toxicity of fluoranthene in
sediment bioassays with freshwater amphipods. Environ Toxicol Chem 1997; 16(4):742753.

Kane Driscoll SB, Landrum PF, Tigue EA. Accumulation and toxicity of fluoranthene in water
only bioassays with freshwater amphipods. Environ Toxicol Chem 1997; 16(4):754761.

Harkey GA, Kane Driscoll SB, Landrum PF. Effect of feeding in 30-day bioaccumulation
assays using Hyalella azteca in fluoranthene-dosed sediment. Environ Toxicol Chem 1997;

16(4):762769.

Kane Driscoll SB, McElroy AE. Elimination of sediment-associated benzo[a]pyrene and its

metabolites by polychaete worms exposed to 3-methylcholanthrene. Aquat Toxicol 1997;
39(1):7791.

Kane Driscoll SB, McElroy AE. Bioaccumulation and metabolism of benzo[a]pyrene in three
species of polychaete worms. Environ Toxicol Chem 1996; 15:14011410.

Published Abstracts of Presentations

Kane Driscoll S, McArdle M, Menzie C. Assessing risk of metals in sediment: Experience in

applying the weight-of-evidence approach to aquatic sites contaminated with heavy metals.
Sediment Management Work Group Spring Sponsor Forum, Kalamazoo, MI, April 29▯30,
2008.

Kane Driscoll SB. A methodology for deriving a dietary dose of PAHs that is protective of fish.
Platform presentation, International Conference on Remediation of Contaminated Sediments in

Savannah, GA, January 22–24, 2007. Session chair: “Bioavailability of Contaminants.”

Kane Driscoll SB, Reiss M, Steevens J. Development of a novel dose-based toxicity benchmark
th
for exposure of fish to PAHs. 26 Annual Meeting of SETAC North America, Baltimore, MD,
November 1620, 2005.

Kane Driscoll SB, Reiss M, Steevens J. Development of a database of toxic doses of PAHs to
fish. 18 Biennial Conference of the Estuarine Research Federation, Norfolk, VA, October

1620, 2005.

Kane Driscoll SB, Menzie CA, McArdle ME, Coleman A. Application of site-specific

equthibrium partitioning sediment benchmarks for PAH mixtures to manufactured gas plants.
25 Annual Meeting of SETAC North America, Portland, OR, November 1418, 2004.

Kane Driscoll SB, McArdle ME, Menzie CA, Thompson T, Coleman A. Applicndion of
sediment quality guidelines for PAHs to manufactured gas plants. 2 International Conference
on Remediation of Contaminated Sediments, Venice, Italy, 2003.

Susan B. Kane Driscoll, Ph.D.
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Kane Driscoll SB, T. Bridges, Cura JJ, M. McArdle, and M. Nelson. A review of comparative
risk assessment methods and their applicability to dredged material management decisions. 23 rd

Annual Meeting of SETAC North America, Salt Lake City, Utah, November 1620, 2002.

Kane Driscoll SB. Sediment accumulation and toxicity of Fluoranthene to freshwater

amphipods. Benthic Ecology Meeting, Columbia, SC, March 710, 1996.

Kane Driscoll SB, Landrum PF. Bioaccumulation and critical body burden of Fluoranthene in

estuarine amphipods. Society of Environmental Toxicology and Chemistry, Washington, DC,
1996.

Kane Driscoll SB, Landrum PF. Toxicokinetics and critical body burdens of Fluoranthene in

amphipod bioassays with Hyalella azteca and Diporeia sp. Invited talk, Society of
Environmental Toxicology and Chemistry, Vancouver, BC, 1995.

Kane Driscoll SB, McElroy AE. A comparison of bioaccumulation and biotransformation of
benzo[a]pyrene in three species of polychaete worms. Society of Environmental Toxicology
and Chemistry, Houston, TX, 1993.

Kane Driscoll SB, McElroy AE. Biotransformation of benzo[a]pyrene by three species of
polychaete. Society of Environmental Toxicology and Chemistry, Cincinnati, OH, 1992.

Prior Experience

Senior Managing Scientist, Menzie-Cura & Assoc., Inc., 1997–2006

Post-Doctoral Research Scientist, Bioavailability and Toxicity of Sediment-Associated Organic
Contaminants, Virginia Institute of Marine Science, 19961997
Post-Doctoral Research Scientist, Bioavailability and Critical Body Burdens of Sediment-
Associated PAHs, National Oceanic and Atmospheric Administration Great Lakes

Environmental Laboratory, 19941996

Project Experience

Developing a novel approach for EPA and the U.S. Army Corps of Engineers (the Corps) to
assess the toxic effects of dietary and water-borne doses of PAHs to fish. Reviewed literature,

summarized data, developed a cumulative distribution of doses, and estimated protective dose
levels.

Managed an ecological and human health risk assessment for a RCRA site in Taunton,

Massachusetts. Designed extensive sampling and sediment toxicity testing program that
demonstrated minimal impact to aquatic organisms and wildlife from exposure to PCBs,
mercury, and dichlorobenzenes in surficial sediments.

Conducted research for the Electric Power Research Institute and its utility members on the
application of the EPA equilibrium partitioning sediment benchmarks for PAH mixtures to

contaminated sediments at manufactured gas plant sites. Research examined influence of
Susan B. Kane Driscoll, Ph.D.
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various forms of “black carbon,” including coal tars and coke, on reducing bioavailability and
toxicity of PAHs in sediment to aquatic organisms.

Managed an ecological and human health risk assessment for a former automobile battery
manufacturing site in Connecticut. Characterized potential exposure of human and ecological
receptors to lead in surficial sediments of a tidal river. Designed field-sampling program, which

included analyses of lead in fecal samples and eggs from resident birds, for characterization of
site-specific exposure to lead. Used site-specific exposure information to back-calculate health-
protective concentrations of lead in sediment.

Managed an extensive review of the available information on the toxicity of dioxin-like
compounds to birds. Compiled a database of dose-response relationships that was used to
develop a species sensitivity distribution for effects to avian species.

Prepared a technical review for EPA and the Corps on approaches used to characterize the
toxicity of mixtures of organic contaminants to fish. Developed a cumulative distribution of
toxic tissue concentrations of chlorinated cyclodiene pesticides to fish.

Conducted effects assessment for the Hudson River baseline ecological risk assessment.
Reviewed literature on effects of PCBs and dioxin-like compounds on fish and aquatic wildlife.
Selected toxicity reference values for use in ecological risk assessment.

Developed a comparative risk assessment framework for the Corps. The framework identifies
characteristics of various placement and treatment alternatives for dredged materials that

contribute to potential environmental risk. The framework can be used by environmental
managers to identify important transport and fate mechanisms and routes of potential exposure,
and to illustrate the need for a comprehensive site assessment.

Examined environmental impacts associated with the release of a plume of high pH
groundwater from an industrial landfill. Assisted in the development of a sampling program to
demonstrate that high pH groundwater was not mobilizing naturally occurring metals in soil.

Advisory Boards

x Task Group Leader for review of American Society of Testing Materials (ASTM)

standard “Guide for Determination of the Bioaccumulation of Sediment Associated
Contaminants by Benthic Invertebrates.” Responsible for revision and updating of
standard bioaccumulation test method.

Peer Reviewer

x Environmental Toxicology and Chemistry

x Integrated Environmental Assessment and Management
x Journal of Human and Ecological Risk Assessment
x Archives of Environmental Contamination and Toxicology

Susan B. Kane Driscoll, Ph.D.
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Professional Affiliations

x American Chemical Society (member)

x Society of Environmental Toxicology and Chemistry (member, editorial reviewer and
former member of the Board of Directors for the North American Chapter)

Susan B. Kane Driscoll, Ph.D.
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Angelina J. Duggan, Ph.D.

Managing Scientist

Professional Profile

Dr. Angelina Duggan is a Managing Scientist in Exponent’s Health Sciences practice. She is an
organic chemist and toxicologist with more than 25 years experience in pharmaceutical and
agrochemical product development and global regulatory affairs that includes process
manufacturing chemistry and the organization and project management of multi-disciplinary

technical teams. Dr. Duggan integrates toxicology, biomonitoring, exposure, physicochemical
and epidemiology data to address FIFRA, TSCA, and REACH regulatory requirements and in
conducting human health environmental risk assessments. She is also experienced in the
application of Structure Activity Relationships (SAR) and cluster analysis and provides

regulatory support for FDA bulk pharmaceuticals and biocompatibility for medical devices.

Dr. Duggan has successfully addressed intellectual property and patent infringement for
chemical and pharmaceutical manufacturing and applied technology. She has also provided

project management, work plans, and timelines and negotiated intellectual property agreements
for university and industrial partner R&D contracts that included chemical and biotechnology
discovery research and applied pharmaceutical uses of agrochemicals. Dr. Duggan is also
experienced in providing services related to data compensation, and due diligence evaluations of

toxicology and product chemistry databases.

Before joining Exponent, Dr. Duggan provided scientific guidance for Washington DC trade

associations, pesticide and chemical manufacturers and formulators, regarding EPA and State
regulations and human health science and policy. EPA also appointed her to provide science
and policy expertise for endocrine disruption and children’s health, in serving on advisory
committees, the Endocrine Disruption Screening and Testing Advisory Committee (EDSTAC)

and the Children’s Health Protection Advisory Committees. She has also provided technical
leadership for task forces, and project teams to address endocrine disruption, cancer risk
assessment, farm family risk, worker exposure, pesticide human testing, and chemical surfactant
tolerance reassessment.

Dr. Duggan can effectively communicate risk assessment issues and policy to scientists and
non-scientists and is highly accomplished in addressing media relations, including providing
effective interviews to the trade and popular press. She has presented and provided written

public comments at EPA workshops and to Science Advisory Panels and Boards. Dr. Duggan
has also authored and organized the submission of numerous technical and regulatory science
policy papers to EPA’s Public Docket. Her project management experience includes multi-
disciplinary litigation teams, discovery Research and Development, process chemistry,

regulatory affairs, global product safety and stewardship. She has also presented safety product
profiles to EPA, Latin American, European, and Asian regulators and provided guidance for the
development and implementation of biotechnology and discovery strategic plans.

12/07ANNEX 158

Academic Credentials and Professional Honors

N.I.H Postdoctoral Fellow: Natural Products Synthesis, Isolation and Structure Elucidation,
Cornell University, 1976

Ph.D., Marine Natural Products, Synthetic Organic Chemistry, Rutgers University, 1974
N.I.H. Predoctoral Fellow, Rutgers University, 1972–1974
M.S., Organic Chemistry, Rutgers University, 1972
B.A., Biology and Chemistry Rutgers University (with honors), 1967

Patents

Duggan AJ, Engel JF, Lutomski KA. Benzoheterocyclyl ketone hydrazone insecticides. U.S.
Patent No. 4,895,871, 1989.

Duggan AJ. Pyrazoline insecticides. U.S. Patent No. 4,767,779, 1988.

Duggan AJ. Vinyl Phenylthiocarbonate. U.S. Patent No. 4,622,408, 1986.

Duggan AJ, Webb RL. New process for preparing hydroxyphenylpyridazinones. U.S. Patent
No. 4,272,440, 1978

Publications

Duggan A, Snedeker S, Zambrone F. Sessions on the toxicology of agricultural exposures and
cancer. Scandinavian J Work Environ Health 2005; 31:119.

Charnley G, Chukwudebe A, Chen W, Duggan A, Hawk R, Krieger RI, Ross J, Yarborough C.
Di-alkyl phosphate biomonitoring data: Assessing cumulative exposure to organophosphate

pesticides. Regul Toxicol Pharmacol 2003; 37:382.

Cardona R, Duggan A, Gordon E, Stevens E, Tobia A. ACPA perspective on EPA’s cancer risk
assessment policy in light of the proposed 1996 guidelines for carcinogen risk assessment. Risk

Policy Report, September 22, 2000.

Hughes PR, Wood HA, Breen JP, Simpson SF, Duggan AJ, Dybas JA. Enhanced bioactivity of

recombinant baculovirus expressing insect-specific spider toxins in lepidopteran crop pests.
J Invertebrate Pathol 1997; 69:112.

Duggan AJ, Grabowski EJJ, and Russ WK Jr. Phase—Transfer mediated heteroaromatic

nucleophilic substitution: introduction of a beta-adrenergic blocking moiety. Synthesis 1981;
573.

Adams MA, Duggan AJ, Smolanoff J, Meinwald J. The total synthesis of (+/-) pederamide.
J Am Chem Soc 1979; 101:5374.

Angelina J. Duggan, Ph.D.
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Duggan AJ, Roberts FE. A facile preparation of a VOC reagent, vinyl phenylthiocarbonate.
Tetrahedron Lett 1979; 595.

Adams MA, Duggan AJ, Meinwald J. Synthesis of ethyl 1 ,3,6-trioxaspiro-(4.5) decane-4-
carboxylate derivatives from delta - lactones (preparation of 2-methoxy-2- glycolamide-

tetrahydro-2H-pyran; elaboration of pederamide side chain). Tetrahedron Lett 1978; 4327.

Adams MA, Brynes PJ, Duggan AJ, Meinwald J. Reaction of enolate anions with lactones.
Tetrahedron Lett 1978; 4323.

Duggan AJ, Hall SS, Weber GF. Relative reactivity of substituted 2-alkoxy and 2-phenoxy-3,4-
dihydro-2H-pyrans with tert-butyl hypochlorite: Effect of substituents on reactivity and

products. J Org Chem 1978; 43:667.

Duggan AJ, Hall SS. Addition of tert-butyl hypohalites to 3,4-dihydro-2H-pyran and its 2-
alkoxy 6-methyl derivatives in hydroxylic solvents. J Org Chem 1977; 42:1057.

Duggan AJ, Eisner T, Kinnel R, Meinwald J, Miura I. Panacene: An aromatic bromoallene
from a sea hare (Aplysia brasiliana). Tetrahedron Lett 1977; 3913.

Adams MA, Duggan AJ, Meinwald J. An adventitious synthesis of pederolactone.
Heterocycles 1977; 7:989.

Duggan AJ, Hall SS. 3-Alkoxy-2-oxanorcarenes: synthesis of cyclopropanes from labile
olefins using an improved lithium ammonia reduction procedure on the dichlorocarbene
adducts. J Org Chem 1975; 40:2238.

Duggan AJ, Hall SS. The chemistry of 2-alkoxy-3 ,4-dihydro-2H-pyrans III: synthesis and
solvolysis of the dichiorocarbene adducts 3-alkoxy-2-oxa-7,7-dichloro-norcaranes. J Organ

Chem 1975; 40:2234.

Duggan AJ, Hall SS. The Chemistry of 2-aIkoxy~3,4-dihydro-2H-pyrans II: addition of
dimethyl acetylenedicarboxylate. J Org Chem 1974; 39:3432.

Borer R, Duggan AJ, Muller R, Rosenberger M, Saucy G. Steroid total synthesis part 8;
(+/-) - Estr4-ene-3,17-dione. Helvetica Chemica Acta 1972; 55:2663.

Duggan AJ, Rosenberger M, Saucy G. Steroid total synthesis part 7; (+/-) -Estr-4-ene-3, 17-
dione and (j) 1 3-ethyl-gon-4-ene-3, 1 7-dione. Helvetica Chemica Acta 1972; 55:1333.

Rosenberger M, Andrews D, DiMaria F, Duggan AJ, Saucy G. Synthesis of delta-lactones from
gluteraldehyde. Helvetica Chemica Acta 1972; 55:249.

Angelina J. Duggan, Ph.D.
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Book Chapters

Duggan A. Putting the toxicology and risk assessment of approved organic pesticides in
perspective. American Chemical Society Symposium Series 947: Crop Protection Products for
Organic Agriculture, Environmental Health and Efficacy Assessment, 2006.

Duggan AJ. Endocrine issues update: pesticide formulations and application systems. 18 th
Volume, ASTM STP 1347, Monograph of the proceedings American Society for Testing and

Materials, Pesticide Formulations and Application Systems San Diego, CA, October 1997.

Selected Published Abstracts

Duggan A. Regulatory science and risk assessment of endocrine-active substances. Presented
at the IUPAC–KSPS International Workshop on Pesticides 2003, Seoul, Korea, October 2003.

Duggan A. Putting the toxicology and risk assessment of approved organic pesticides in
perspective. American Chemical Society National Meeting, New Orleans, LA, March 2003.

rd
Duggan, A. To what extent have we known about endocrine disruption chemicals? 3
International Symposium on Environmental Endocrine Disrupters co-sponsored by the Japan
Society of Endocrine Disrupter Research (JSEDR) and the Japan Environment Agency (JEA)

Yokohama, Japan, December, 2000.

Selected Presentations

Duggan A. Biocompatibility: Risk analysis and safety evaluations, a risk assessor’s
perspective. Drexel University, Philadelphia, PA, May 2008.

Duggan A. Historical perspective of the endocrine disruption issue, EDSTAC and validation.
Chair Session One: Background on the Endocrine Screening (EPA’s EDSP Tier I),
International Society of Regulatory Toxicology and Pharmacology, NIH Bethesda, MD,

February 2008.

Duggan A. Consortia/Task Forces/SIEFS: Challenges in participation and organization.

Personal Care Products Council REACH Symposium, Washington, DC, February 2008.

Duggan A. Interpreting biomonitoring in the context of risk assessment and liability. NJ

Chapter of Society of Woman Environmental Professionals, Newark, NJ, January 2008.

Duggan A. Biocompatibility: Risk analysis and safety evaluations, a risk assessor’s
perspective. Drexel University, Philadelphia, PA, June 2007.

Duggan A. Interpreting biomonitoring in the context of risk assessment, introductory remarks.
Presented at Society of Risk Analysis, Baltimore, MD, December 2006.

Duggan A. Regulatory science and risk assessment of endocrine-active substances. Presented
at the IUPAC –KSPS International Workshop on Pesticides 2003, Seoul, Korea, October 2003.
Angelina J. Duggan, Ph.D.
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Duggan A. Putting the toxicology and risk assessment of approved organic pesticides in

perspective. Presented at the American Chemical Society National Meeting, New Orleans, LA,
March 2003.

Duggan A. Toxicology rappateur. International Symposium on Agricultural Exposures and
Cancer. Presented at Oxford University, Oxford, UK, November 2002.

Duggan A. The value of human data in conducting safety assessments. Presented at Chemicals

Manufacturers and Distributor Association (CPDA) Annual Meeting, Washington, D.C.,
February 2001.

Duggan A. What are the actual risks to children and EPA regulation of pesticides. Presented
and moderated expert panel discussion on children’s health issues at the Responsible Industry
for a Sound Environment (RISE) Annual Meeting, Palm Springs, FL, September 2001.

Duggan A. FQPA science and policy implications. Presented to the Agricultural Company and
Banana Company Task Force, San Jose, Costa Rica, May 2000.

Duggan A. Industry perspective: to what extent have we known rdout endocrine disruption
chemicals? Presented and participated on panel discussion, 3 International Symposium on
Environmental Endocrine Disrupters, co-sponsored by the Japan Society of Endocrine Disrupter
Research (JSEDR) and the Japan Environment Agency (JEA), Yokohama, Japan, December,

2000.

Duggan A. US and EU endocrine disruption policy—Implications for Japan and Children’s

health initiatives: Potential emerging global policy issue. Presented to the Japanese Chemical
Industry Association (JCIA) Tokyo, Japan, December 2000.

Duggan A. Endocrine Disruption Screening and Testing Committee (EDSTAC) update on
priority setting. Presented at Chemical Manufacturers Association (now known as the American
Chemistry Council, ACC) Endocrine Issues Science Forum, November 1999.

Duggan A. Evaluation of the endocrine disruption theory. Presented at University of Hawaii,
Honolulu, Hawaii, July 1998.

Duggan A. Evaluation of the endocrine disruption theory. Presented Rutgers University New
Brunswick, NJ, April 1998.

Duggan A. Progress report on the Endocrine Disruption Screening and Testing Committee

(EDSTAC). Presented to Illinois EPA and Illinois Chemical Manufacturers Association,
Chicago, IL, June 1997.

Duggan AJ. Endocrine issues update: pesticide formulations and application systems.
Presented at American Society for Testing and Materials, Pesticide Formulations and
Application Systems, San Diego, CA., October 1997.

Angelina J. Duggan, Ph.D.
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Duggan A. Industry perspective on the endocrine disruption theory. Presented and participated
in a panel discussion at the Responsible Industry for a Sound Environment (RISE) Annual
Meeting, Washington, D.C., September, 1997.

Duggan, A. Endocrine disruption screening and testing advisory committee update. Presented
at he American Crop Protection Association (now known as CropLife America, CLA) Spring

Conference, May 1997.

Academic Appointments

x Adjunct Chemistry Lecturer, Rutgers University Newark, NJ, 1974

Consulting and Advisory Appointments

x International Society of Regulatory Toxicology and Pharmacology Board Councilor
(Since 2005)

x ILSI International Biomonitoring Symposium (2004)
x International Life Sciences (ILSI) CARES Steering Committee (2004–2005)
x Children’s Health Protection Advisory Committee (2001–2005)

x Harvard Center for Risk Analysis Advisory Committee (2002)
x American Crop Protection Association (now CropLife America) Biotechnology Steering
Committee (1997)

x EPA Endocrine Disruption Screening and Testing Advisory Committee (1996–1998)

Peer Reviewer

x Journal of Organic Chemistry
x International Society of Exposure Assessment

x Regulatory Toxicology and Pharmacology
x Synthesis

Professional Affiliations

x American Chemical Society
x American College of Toxicology

x American Public Health Association (2004–2005)
x International Society of Regulatory Toxicology and Pharmacology
x CropLife America

x International Union of Pure and Applied Chemistry
x Phi Beta Kappa

x Sigma Xi
x Society of Risk Analysis
x Society of Toxicology

x Synthetic Organic Chemistry Manufacturers Association

Page 6na J. Duggan, Ph.D.
12/07 ANNEX 158

Project Experience

Currently serving as Technical Project Manager for the Joints Inerts Task Force that required
organizing 30 companies, registrants and suppliers in supporting more than 300 pesticide inerts
surfactants to address Food Quality Protection Act EPA tolerance reassessment requirements.

Experienced in developing chemical cluster groups and structure to activity analyses to support
data development plans for FIFRA, TSCA and REACH regulatory applications.

Provided intellectual property technology assessment evaluations and written expert
declarations for pharmaceutical and chemical process chemistry and manufacturing patents that
resulted in either successful defenses and or appeals.

Evaluated human health issues related to performance and biocompatibility of various medical
devices.

Serving on Exponent Institutional Review Board to evaluate protocols, ethical (informed
consent and questionnaires), and safety considerations, for observational studies involving
human participants.

Experienced in the preparation and issues management of chemical and pesticide registration
applications to gain approvals from EPA and international regulatory authorities. This has
included EPA Pre-manufacture Notices (PMNs) and application of Read Across strategy to

High Production Volume (HPV) testing.

Developed strategies and work plans to address regulatory issues for Toxic Substances Control

Act (TSCA) 5e PMN from EPA Office of Pollution Prevention and Toxics (OPPT).

Experienced in conducing FIFRA and TSCA regulatory support and human health risk

assessments for pesticide, industrial chemicals and fragrance chemical ingredients.

Experienced in preparing FDA applications to manufacture pesticide products as bulk
pharmaceuticals, and UK Veterinary Medicines Directorate (VMD) applications for animal

health use.

Provided Federal Insecticide and Fungicide and Rodenticide Act (FIFRA) human health risk

assessment science and policy guidance for Washington DC trade pesticide association
comprised of more than 50 member companies (basic and generic manufacturers), formulators,
and distributors regarding crop and non-crop uses of pesticide products at both the Federal and
State level.

Developed risk communications strategies and prepared documents on a broad array of EPA
science and risk assessment regulations and policy: Food Quality Protection Act; human testing;

cancer risk assessment,; endocrine issues; developmental neurotoxicity testing (DNT);
environmental exposure and disease links; children’s health; and farm family exposure issues.

Experienced in media relations including interviews to trade publications and the popular press.
Angelina J. Duggan, Ph.D.
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Managed science and regulatory projects related to human testing and cancer risk of chemicals

and pesticides.

Conducted due diligence for toxicology and product chemistry regulatory studies.

Provided chemical assessment expertise to support environmental forensics for 1,2,3 -
trichloropropane.

Provided technical support to prepare pharmaceutical/agrochemical discovery and process
chemistry patents.

Authored and organized numerous science policy and technical papers for US EPA Public
Docket relating to the use of human data in risk assessment, FQPA 99.9 percentile of regulation,
FQPA aggregate and cumulative risk assessment, children’s health, EPA’s aging initiative,
endocrine disruption (priority setting, screening and validation), biomonitoring, and cancer risk

assessment.

Experienced in developing and optimizing new chemical processes for pilot plant and

production manufacturing.

Experienced in pesticide data compensation regulations and registrations support including the
development of summary spreadsheets and costing of studies.

Managed Agency negotiations to address EPA Developmental Neurotoxicity Testing Data Call-
in for more than 30 organophosphate insecticides.

Completed MBA course work and provided technical regulatory and business management
support for agrochemical supplier and distributor contracts.

Presented oral and written public comments on EPA regulatory science and policy to the FIFRA
Science Advisory Panel, Federal Advisory Committees, EPA Science Advisory Board, and at
EPA technical briefings and workshops.

Represented pesticide and chemical industries, and provided presentations, at international
symposiums for endocrine disruption, children’s health, agrochemical cancer epidemiology and

biomonitoring.

Project manager for development of multi-million dollar FQPA risk assessment software, the
Cumulative Aggregate Risk Evaluation System (CARES).

Participated in global pesticide product stewardship and safety audits. Met with international
regulators to remediate product specific human health and environmental safety concerns. Also

authored the activity/conditions assessment checklist and criteria to audit US and international
formulation/manufacturing plants and product supply/distributor business partners.

Angelina J. Duggan, Ph.D.
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Provided project management for global regulatory affairs, product safety and development,
including FIFRA 6(A)(2) and international conventions such as FAO Code of Conduct, Prior
Informed Consent (PIC) Persistent Organic Pollutants (POPs) and CODEX.

Provided product-specific presentations and written communications to US EPA and
international government authorities in Australia, Canada, Latin America (Brazil, Costa Rica,

Guatemala, and Mexico), EU countries, and throughout Asia (including Korea, North Vietnam,
India, China, Pakistan, Philippines, Indonesia, and Thailand) that saved multi-million dollar
product registrations.

Provided project management, work plans, and timelines and negotiated intellectual property
agreements for university and industrial partner R&D contracts that included discovery research
and pharmaceutical uses of agrochemicals.

Managed strategic planning and implementation of agrochemical biotechnology and R&D
discovery screening projects for natural products and synthetic chemicals.

Collaborated with laboratory and field biologists, toxicologists, metabolism and environmental
scientists and business development staff to address field efficacy, toxicology and
environmental safety issues and the economic viability of insecticide, fungicide and herbicide
development candidates.

Secured and managed major contracts to acquire large blocks of chemicals from universities,
small companies and major pharmaceutical and agrochemical companies to support automated

high throughput screening laboratory.

Project manager for two $3 million dollar biotechnology discovery contracts, evaluating spider
venoms and fermentation broths. Directed research of multi-disciplinary teams of company and

external scientists, which resulted in patentable new leads and genetically engineered
(baculovirus) product candidates.

Managed and prepared budgets for more than two dozen scientists, involved in all phases of

agrochemical discovery research and product development, that included responsibility for
external research programs and robotic high throughput screening, microbiology, NMR, HPLC
analysis and chemical synthesis laboratories.

Experienced in the synthesis, isolation/structure elucidation and pharmaceutical and
agrochemical screening of natural products derived from marine plants and
animals (venoms) and microbial fermentation broths and plants (pharmacognosy).

Prior Experience

Human Health Science and Policy Leader and Director Science Policy, CropLife America
(formerly America Crop Protection Association), 1999–2005
Global R&D Development and Regulatory Affairs Manager, FMC Corporation Agricultural
Products Group, 1994–1999

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Discovery Manager External Resources and Screening, FMC Corporation Agricultural Products

Group, 1991–1994
New Leads Discovery Manager, FMC Corporation Agricultural Products Group, 1988–1991
Synthesis Manager, Insecticides, FMC Corporation Agricultural Products Group, 1985–1988

Senior Discovery Research Chemist, FMC Corporation Agricultural Products Group, 1983–1985
Process Research Senior Chemist, Merck, 1977–1983

Process and Medicinal Research Senior Chemist, Smith Kline French/Beecham, 1976–1977
Associate Chemist, Hoffmann-La Roche, 1967–1972

Angelina J. Duggan, Ph.D.
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Charlotte H. Edinboro, D.V.M., Ph.D.
Senior Scientist

Professional Profile

Dr. Charlene Edinboro is a Senior Scientist in Exponent’s Health Sciences Center for Public

Health and Industrial Hygiene. Dr. Edinboro has a diverse background in several disciplines
including epidemiology, veterinary medicine, and aerospace engineering.

Dr. Edinboro’s experience in epidemiology includes cancer epidemiology, nutritional

epidemiology, exposure assessment, and pharmacoepidemiology. At Exponent, Dr. Edinboro
has reviewed medical, epidemiologic, and toxicologic literature on numerous subjects, and
provided estimates of incidence or prevalence of specific diseases for epidemiologic evaluations
of environmental and occupational exposures. Dr. Edinboro has prepared state-of-the-art

reviews for reports and manuscripts on environmental perchlorate exposures and thyroid
function, as well as smoking, cardiovascular disease, and magnetic field exposure. Projects
have included an analysis of newborn screening data and potential perchlorate exposure in
drinking water, technical support to an expert panel and a manufacturer evaluating applicability

of a screening test for occupational beryllium exposure, and research support for a project
evaluating dietary supplements and potential adverse health outcomes. Dr. Edinboro reviewed
evidence in a case alleging PCB exposure associated with neonatal foal morbidity and mortality.
She used all facets of her education and experience in a dairy inspection where use of robotic

milking machines was associated with reportedly higher rates of mastitis than before their use.
Dr. Edinboro has participated in a safety evaluation of dog treat ingredients, in human food-
borne outbreak investigations, and in projects related to animal disease potentially due to feeds
or environmental exposures. Dr. Edinboro has provided a review of literature for potential

health effects of fiducial marker use in several new applications, and has participated in other
medical device projects. Her research has included studies of dietary and environmental risk
factors for feline hyperthyroidism, clinical trials of vaccines in dogs and cats at humane shelters
to evaluate effectiveness, and evaluation of the impact of repeated vaccination on the immune

status of Great Danes. Her research interests include potential impacts of dietary and
environmental exposures on the thyroid, small animal population disease control, and
companion animals as sentinels for human health. Dr. Edinboro is a member of the American
Thyroid Association’s Public Health Committee (2007–2010).

Dr. Edinboro holds an active California veterinary license. As a small animal veterinarian, she
has performed routine physical examinations and treatment, preventive care, routine surgeries,
emergency medicine, and shelter animal medicine, including population disease control,

forensics, zoonosis identification, and wildlife medicine. Dr. Edinboro is active with the
Peninsula Veterinary Medical Association, serving as the 2008 president, and she has been a
liaison with a local animal rescue group, a large humane society, and the local county health
department. She volunteers as a feral cat spay/neuter clinic veterinarian.

Dr. Edinboro has over 20 years of experience in aerospace engineering. She worked in
spacecraft control systems analysis, simulation software design and implementation, and
10/08ANNEX 158

systems engineering, including requirements analysis, implementation, integration and test,
documentation development, and on-site customer support for a variety of applications. As a
team member, team leader, and coordinator of teams from diverse subcontractors, Dr. Edinboro

has worked on several spacecraft programs and systems.

Academic Credentials and Professional Honors

Ph.D., Comparative Epidemiology, Purdue University, 2002
D.V.M., Veterinary Medicine, University of California, Davis, 1990
M.S., Aeronautics and Astronautics, Purdue University, 1976

B.S., Aeronautical and Astronautical Engineering, Purdue University, 1975

Veterinarian, California Veterinary Medical Board

Oxford Laboratories Award for Excellence in Advancing Knowledge of Small Animal
Endocrinology, Society for Comparative Endocrinology, 2005; Recipient of Kenneth Scott
Fellowship in Epidemiology and Animal Welfare, Purdue University, 1997–2001; Phi Zeta

Veterinary Medicine Honor Society; Who’s Who of American Women, 20th Edition,
19971998; Outstanding Young Women of America, 1986; TRW Certificate of Appreciation
for the IUS Avionics Software Project; NASA Group Achievement Award for Voyager
Spacecraft System Design and Development; NASA Group Achievement Award for Voyager

Flight Operations; American Institute of Aeronautics and Astronautics Outstanding Student
Branch Member, Purdue University, 1975–1976; Sigma Gamma Tau Aerospace Engineering
Honor Society; Purdue University Special Merit and Alumni Association Scholarships

Prior Experience

Epidemiology

Post-Doctoral Research Assistant, Purdue University, School of Veterinary Medicine,
Department of Veterinary Pathobiology, 2001–2002
Teaching Assistant, Purdue University, School of Veterinary Medicine, Department of

Veterinary Pathobiology, 1999
Graduate Research Assistant, Purdue University, School of Veterinary Medicine, Department of
Veterinary Pathobiology, 1997–2001

Veterinary Medicine
Small animal part-time and relief veterinarian at private practices and one large humane shelter
in the San Francisco Bay Area, 1990–1997

Aerospace Engineering
Systems Engineer, Scitor Corporation, 1984–1986, summers 1987, 1988, 1989, 1990–1997
Staff Engineer, Ultrasystems Defense and Space Systems, Inc., 1982–1984

Member of the Technical Staff, TRW Defense Systems Group, 1979–1982
Engineer R&D, Ford Aerospace and Communications Corporation, 1979
Engineer II, III, Computing Analyst III, Jet Propulsion Laboratory, California Institute of
Technology, 1976–1979

Charlotte H. Edinboro, D.V.M., Ph.D.
Page 2
10/08 ANNEX 158

Publications

Edinboro CH, Kelsh MA, Lau EC. Demographic comparisons of two- v. one-stage testing
results for primary congenital hypothyroidism screening in California, 1997–1998. (Abstract)
Thyroid 2008; 18(s1):S-53-S-54.

Goldkamp CE, Levy JK, Edinboro CH, Lachtara JL. Seroprevalences of feline leukemia virus
and feline immunodeficiency virus in cats with abscesses or bite wounds and rate of veterinarian
compliance with current guidelines for retrovirus testing. J Am Vet Med Assoc 2008; 232(8):

1152–1158.

Levy JK, Edinboro CH, Glotfelty CS, Dingman, PA, West AL, Kirkland-Cady KD.
Seroprevalence of Dirofilaria immitis, feline leukemia virus, and feline immunodeficiency virus

in dogs and cats rescued from the 2005 Gulf Coast hurricane disaster. J Am Vet Med Assoc
2007; 231(2):218–225.

Edinboro CH. Companion animals may serve as sentinels of health risk—A review of thyroid
diseases in three non-human species. (Abstract) Thyroid 2006; 16(9):908909.

Buffler PA, Kelsh MA, Lau EC, Edinboro CH, BarnardJC, Rutherford GW, Daaboul JJ, Palmer
L, Lorey FW. Thyroid function and perchlorate in drinking water: An evaluation among
California newborns, 1998. Environ Health Perspect 2006; 114(5):798804.

Mezei G, Cher D, Kelsh M, Edinboro C, Chapman P, Kavet R. Occupational magnetic field
exposure, cardiovascular disease: mortality, and potential confounding by smoking. Ann
Epidemiol 2005; 15(8):622629.

Edinboro CH, Scott-Moncrieff JC, Glickman LT. Review of iodine recommendations for
commercial cat foods and potential impacts of proposed changes. (Abstract) Thyroid 2004;

14(9):722.

Edinboro CH, Scott-Moncrieff JC, Glickman LT. Environmental risk factors for feline

hyperthyroidism: Pet cats as potential sentinels for public health. (Abstract) Thyroid 2004;
14(9):759.

Edinboro CH, Scott-Moncrieff JC, Janovitz EB, Thacker HL, Glickman LT. Epidemiologic

study of the relationships between commercial canned food consumption and the risk of
hyperthyroidism in cats. J Am Vet Med Assoc 2004; 224(6):879–886.

Edinboro CH, Ward MP, Glickman LT. A placebo-controlled trial of two intranasal vaccines to
prevent tracheobronchitis (kennel cough) in dogs entering a humane shelter. Prevent Vet Med
2004; 62(2):89–99.

Edinboro CH, Scott-Moncrieff JC, Tetrick M, Glickman LT. Dietary and environmental risk
factors for clinical hyperthyroidism in pet cats. Abstract, Ann Epidemiol 2002; 12(7):509.

Charlotte H. Edinboro, D.V.M., Ph.D.
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Edinboro CH. Dietary and environmental risk factors for feline hyperthyroidism. Dissertation.
Department of Veterinary Pathobiology, Purdue University, 2002.

Edinboro CH, Janowitz LK, Guptill-Yoran L, Glickman LT. A clinical trial of intranasal and
subcutaneous vaccines to prevent upper respiratory infection in cats at an animal shelter. Feline

Practice 1999; 27(6):7–11, 13.

Book Chapter

Edinboro CH. Veterinary epidemiology. In: Encyclopedia of Epidemiology. Boslaugh S (ed),
Thousand Oaks, CA: Sage Publications, pp. 1079–1083, 2007.

Presentations

Edinboro CH, Kelsh MA, Lau EC. Demographic comparisons of two- v. one-stage testing
results for primary congenital hypothyroidism screening in California, 1997-1998. Poster,

American Thyroid Association 79th Annual Meeting, Chicago, IL, October 2008.

Edinboro CH. Prevalence of feline leukemia and immunodeficiency viruses in feral cats on the

San Francisco peninsula. Epidemiology Graduate Seminar, University of California, Davis,
CA, November 2006.

Edinboro CH. Companion animals may serve as sentinels of health risk—A review of thyroid

diseases in three non-human species. Poster, American Thyroid Association 77th Annual
Meeting, Phoenix, AZ, October 2006.

Edinboro CH. Prevalence of feline leukemia and immunodeficiency viruses in feral cats on the
San Francisco peninsula. Poster, 8th International Feline Retrovirus Research Symposium,
Washington, DC, October 2006.

Edinboro CH. Prevalence of feline leukemia and immunodeficiency viruses in feral cats in San
Francisco Bay Area. 11th International Symposium for Veterinary Epidemiology and
Economics, Cairns, Queensland, Australia, August 2006.▯

Edinboro CH. Prevalence of obesity in dogs and obesity and asthma in cats presented to North
American veterinary school hospitals. Poster, 11th International Symposium for Veterinary
Epidemiology and Economics, Cairns, Queensland, Australia, August 2006.▯

Edinboro CH. Clinical trials of intranasal vaccines to prevent respiratory diseases in animal
shelters. Epidemiology Graduate Seminar, University of California, Davis, CA, May 2005.

Edinboro CH, Scott-Moncrieff JC, Glickman LT. Review of iodine recommendations for
commercial cat foods and potential impacts of proposed changes. Poster, American Thyroid
Association 76th Annual Meeting, Vancouver, BC, Canada, September-October 2004.

Charlotte H. Edinboro, D.V.M., Ph.D.
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Edinboro CH, Scott-Moncrieff JC, Glickman LT. Environmental risk factors for feline
hyperthyroidism: Pet cats as potential sentinels for public health. Poster, American Thyroid

Association 76th Annual Meeting, Vancouver, BC, Canada, SeptemberOctober 2004.

Edinboro CH. Dietary and environmental risk factors for feline hyperthyroidism, or “there and

back again.” Peninsula Veterinary Medical Association, Belmont, CA, March 2004.

Mezei G, Cher D, Kelsh M, Chapman P, Edinboro C, Kavet R. Cardiovascular deaths and
occupational exposure to magnetic fields in the national mortality followback survey. Poster,

Bioelectromagnetics Society Annual Meeting, Wailea, Maui, HI, June 2003.

Edinboro CH, Scott-Moncrieff JC, Tetrick M, Glickman LT: Dietary and environmental risk

factors for clinical hyperthyroidism in pet cats. Poster, American College of Epidemiology
Annual Meeting, Albuquerque, NM, September 2002.

Edinboro CH. Do endocrine disrupters in canned food linings cause hyperthyroidism?
Epidemiologic evidence from an animal model. Interdepartmental Nutrition Program Seminar
Series, Purdue University, September 2002.

Edinboro CH. Disease recognition, prevention, and shelter programming for animal health.
Indiana Association of Animal Control Personnel Conference, Indianapolis, IN, October 1999.

Academic Appointments

x Affiliate, University of Florida Maddie’s® Shelter Medicine Program

Teaching Experience

x Teaching Assistant, Small Animal Epidemiology for third-year veterinary

students, Purdue University, School of Veterinary Medicine, Department of
Veterinary Pathobiology (810/99)

Research Experience

x Post-Doctoral Research Assistant, Great Dane Health and Vaccine Study, Purdue

University, School of Veterinary Medicine, Department of Veterinary
Pathobiology (11/0110/02)
x Graduate Research Assistant, Purdue University, School of Veterinary Medicine,

Department of Veterinary Pathobiology (8/9711/01)
–Designed and conducted a controlled clinical trial to evaluate the efficacy of two
intranasal vaccines for the prevention of upper respiratory disease (Kennel Cough) in

dogs at a humane shelter
–Conducted case-control and cross-sectional studies to identify dietary and

environmental risk factors for feline hyperthyroidism (PhD Research)

Charlotte H. Edinboro, D.V.M., Ph.D.
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Peer Reviewer

x Journal of the American Animal Hospital Association – Section Editor for Study

Design and Epidemiology
x American Journal of Veterinary Research
x Preventive Veterinary Medicine

x Toxicological Sciences

Professional Affiliations

x American Veterinary Medical Association
x American Thyroid Association

– Public Health Committee Member, 2007–2010
x Association of Shelter Veterinarians
x American Association of Feline Practitioners

x Association for Veterinary Epidemiology and Preventive Medicine
x Society for Epidemiologic Research
x Peninsula Veterinary Medical Association (member, all executive offices held)

– President, 2008 (second occasion)
x San Mateo County Animal Population Trust Fund Committee
x Center for Animal Protection and Education, Santa Cruz, CA (Advisory Board Member,

former Board Member)
x Homeless Cat Network, San Carlos, CA (Veterinary Advisory Board Member)
x Peninsula Fix Our Ferals (Volunteer Veterinarian)

Charlotte H. Edinboro, D.V.M., Ph.D.
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Anne Fairbrother, D.V.M., Ph.D.

Senior Managing Scientist

Professional Profile

Dr. Anne Fairbrother is a Senior Managing Scientist in Exponent’s EcoSciences practice, with
more than 30 years of experience in ecotoxicology, wildlife toxicology, contaminated site
assessment, and regulatory science for existing and emerging chemicals in the U.S. and Europe.
She recently served on a Science Advisory Panel to the state of Utah and as a consultant to the

British Columbia (BC) Ministry of Environment to set site-specific water quality standards for
selenium that protect fish and wildlife. She has conducted large-area (>100 sq mile) risk
assessments at mines in tropical, desert, and mountain ecosystems, determining risk thresholds
for plants and wildlife. She provided consultation on future development of mine pit lakes,

assessed the risk to livestock from use of wastewater on irrigated pasture during mine closure
operations, and conducted an assessment of risk to terrestrial and aquatic organisms from an
abandoned mercury mine. Dr. Fairbrother conducted an assessment of the potential ecological
risks to aquatic life in San Francisco Bay and coastal southern California posed by use of copper

pipes. She also assessed risks to wildlife at sites contaminated with organic chemicals,
including DDT, PCBs, dioxins, and petroleum hydrocarbons in Delaware, Texas, Oregon, and
California, integrating ecological risks with human health risk assessments.

As a consultant, Dr. Fairbrother has supported various chemical industry groups in compiling
and reviewing data from the literature in support of both U.S. and European regulatory
processes. Historically, this included preparation of screening information data sets (SIDs) for

submission through EPA to the OECD’s High Production Volume (HPV) data call-in program.
More recently, she also has input the data into the IUCLID database for Europe-wide risk
assessments and the REACH chemical registration program.

Dr. Fairbrother has participated in or led the development of guidance documents for ecological
risk assessments. For example, she was co-author of the EPA’s Framework for Metals Risk
Assessment and for BC Ministry of Environment guidance for implementing Tier 1 ecological
risk assessments of contaminated sites and for setting soil clean-up values, and participated in

the development of Ecological Soil Screening Levels (Eco-SSLs) for EPA.

While a scientist at the EPA, Dr. Fairbrother led research into the ecological risks of
bioengineered crops, methods for assessing risks of nanomaterials, and some of the early

guidance for field assessments of Superfund sites and effects of pesticides on birds. She
researched and developed methods for assessment of chemical effects on bird immune and
endocrine systems.

Dr. Fairbrother has published more than 80 peer-reviewed articles and book chapters that reflect
her expertise in wildlife toxicology, immunotoxicology, endocrine-disrupting chemicals, and
ecological risk assessment. She serves on numerous scientific boards, expert panels, and

04/09ANNEX 158

editorial boards in support of scientific and regulator y issues. A veterinarian and Certified
Wildlife Biologist, Dr. Fairbrother served as President of the Society of Environmental

Toxicology and Chemistry, American Association of Wildlife Veterinarians, and Wildlife
Disease Association (WDA). She is the recipient of the WDA Distinguished Service Award
(2002), and a gold medal for Commendable Service from EPA. Dr. Fairbrother holds an

adjunct professorship at Oregon State University, Department of Environmental and Molecular
Toxicology.

Academic Credentials and Professional Honors

Ph.D., Veterinary Science, University of Wisconsin, Madison, 1985
M.S., Veterinary Science, University of Wisconsin, Madison, 1982

D.V.M., Veterinary Medicine, University of California, Davis, 1980
B.S., Wildlife and Fisheries Biology, University of California, Davis, 1976

Distinguished Service Award, Wildlife Disease Association, 2002

Gold Medal for Commendable Service, EPA, 2005
Bronze Medal for Commendable Service, EPA, 2006, 2008

Licenses and Certifications

Certified Wildlife Biologist, The Wildlife Society, 1995
40-hour Hazwoper Training and Certification

Publications

Fairbrother A, Wentsel R, Sappington K, Wood W. Framework for metals risk assessment.
Ecotox Environ Saf 2007; 68:145–227.

Nagy LR, Fairbrother A, Orme-Zavaleta J, Etterson M. The intersection of independent lies in
ecological risk assessment. Hum Ecol Risk Assess 2007; 13:355–369.

Gallagher K, Benson WH, Brody M, Fairbrother A, Hasan J, Klaper R, Lattier D, Lundquist S,

McCarroll N, Miller G, Preston J, Sayre P, Seed J, Smith B, Street A, Troast R, Vu V, Reiter L,
Farland W, Dearfield K. Genomics: Applications, challenges and opportunities for the U.S.
EPA. Hum Ecol Risk Assess 2006; 12(3):572–590.

Suter II GW, Norton SB, Fairbrother A. Individuals versus organisms versus populations in the
definition of ecological assessment endpoints. Integrated Environ Assess Mgmt 2005; 1:397–
400.

Fairbrother A, Turnley JG. Predicting risks of uncharacteristic wildfires: Application of the
risk assessment process. Forest Ecol Mgmt 2005; 211:28–35.

Bennett RS, Dewhurst I, Fairbrother A, Hart ADM, Hooper M, Leopold A, Mineau P,
Mortensen S, Shore RF, Springer TA. A new interpretation of avian and mammalian
reproduction toxicity test data in ecological risk assessment. Ecotoxicol 2005; 14(8):1–15.
Anne Fairbrother, DVM, Ph.D.
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Shore RF, Crocker DR, Akcakaya HR, Bennett RS, Chapman PF, Clook M, Crane M, Dewhurst

IC, Edwards PJ, Fairbrother A, Ferson S, Fischer D, Hart ADM, Holmes M, Hooper MJ,
Lavine M, Leopold A, Luttik R, Mineau P, Moore DRJ, Mortenson SR, Noble DG, O’Connor
RJ, Roelofs W, Sibly RM, Smith GC, Spendiff M, Springer TA, Thompson HM, Topping C.

Case Study Part 1: How to calculate appropriate deterministic long-term toxicity to exposure
ratios (TERs) for birds and mammals. Ecotoxicol 2005; 14(8):1–17.

Roelofs W, Crocker DR, Shore RF, Moore DRJ, Smith GC, Akcakaya HR, Bennett RS,

Chapman PF, Clook M, Crane M, Dewhurst I, Edwards PJ, Fairbrother A, Ferson S, Fischer D,
Hart ADM, Holmes M, Hooper MJ, Lavine M, Leopold A, Luttik R, Mineau P, Mortenson SR,
Noble DG, O’Connor RJ, Sibly RM, Spendiff M, Springer TA, Thompson HM, Topping C.

Case Study Part 2: Probabilistic modelling of long-term effects of pesticides on individual
breeding success in birds and mammals. Ecotoxicol 2005; 14(8):1–29.

Clark J, Oretgo L, Fairbrother A. Sources of variability in plant toxicity testing. Chemosphere:

Environ Toxicol Risk Assess 2004; 57:1599–1612.

Watrud LS, Lee Eh, Fairbrother A, Burdick C, Reichman JR, Bollman M, Storm M, King G,

Van de Water PK. Evidence for landscape-level, pollen-mediated gene flow from genetically
modified creeping bentgrass with CP4 EPSPS as a marker. Proc Natl Acad Sci 2004;
101(40):14533–14538.

Fairbrother A, Smits J, Grasman K. Avian immunotoxicology. J Toxicol Environ Health, Part
B 2004; 7:105–137.

Fairbrother A. Lines of evidence in ecological risk assessment. Human Ecol Risk Assess 2003;
9:1475–1491.

Sappington K, Fairbrother A, Wentsel R, Wood W. Development of a framework for risk
assessment of metals. J Environ Mgmt 2003; 5:122–132.

Brewer L, Fairbrother A, Clark J, Amick D. Acute toxicity of lead, steel, and an iron-tungsten-

nickel shot to mallard ducks (Anas platyrhynchos). J Wildl Dis 2003; 39(3):638–648.

Adams WA, Brix KV, Edwards M, Tear LM, DeForest DK, Fairbrother A. Analysis of field

and laboratory data to derive selenium toxicity thresholds for birds. Environ Toxicol Chem
2003; 22(9):2020–2029.

Phipps T, Tank SL, Brewer L, Wirtz J, Coyner A, Ortego LS, Fairbrother A. Essentiality of

nickel and homeostatic mechanisms for its regulation in terrestrial organisms. Environ
Rev./Dossiers Environ 2002; 10(4):209–261.

Stroo HF, Jensen R, Loehr RC, Nakles DV, Fairbrother A, Liban CB. Environmentally
acceptable endpoints for PAHs at a manufactured gas plant site. Environ Sci Technol 2000;
34(18):3831–3836.

Anne Fairbrother, DVM, Ph.D.
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Fairbrother A. Comparative aspects of estrogen functions and measurements in oviparous and
viviparous vertebrates. Human Ecol Risk Assess 2000; 6:73–102.

Fairbrother A, Brix KV, DeForest DK, Adams WJ. Egg selenium thresholds for birds: A
response to J. Skorupa’s critique of Fairbrother et al., 1999. Human Ecol Risk Assess 2000;

6:203–212.

Fairbrother A, Brix KV, Toll JE, McKay S, Adams WJ. Egg selenium concentrations as
predictors of avian toxicity. Human Ecol Risk Assess 1999; 5:1229–1253.

Fairbrother A, Bennett RS. Ecological risk assessment and the precautionary principal. Human
Ecol Risk Assess 1999; 5:943-950.

Glicken J, Fairbrother A. Environment and social values. Human Ecol Risk Assess 1998;
4:779–786.

Ozman M, Dominguez SE, Fairbrother A. Effects of dietary azinphos methyl on selected
plasma and tissue biomarkers of the gray-tailed vole. Bulletin of Environ Contam Toxicol
1998; 60:194–201.

Fairbrother A, Landis WG, Dominguez S, Shiroyama T, Buchholz P, Roze MJ, Matthews GB.
A novel nonmetric multivariate approach to the evaluation of biomarkers in terrestrial field
studies. EcoToxicol 1998; 7:1–10.

Chapman, P. M., Fairbrother A, Brown D. A critical evaluation of safety (uncertainty) factors
for ecological risk assessment. Environ Toxicol Chem 1998; 17(1):99–108.

Fowles JR, Fairbrother A, Kerkvliet NI. Effects of induced hypo and hyperthyroidism on
immune function and plasma biochemistry in mallards (Anas platyrhynchos). Comp BioChem

Physiol 1997; 118C:213–220.

Fowles JR, Fairbrother A, Trust KA, Kerkvliet NI. Effects of Aroclor-1254 on the thyroid
gland, immune function, and hepatic cytochrome P-450 activity in mallards. Environ Research

1997; 75:119–129.

Fairbrother A, Kapustka LA, Williams BA, Bennett RS. Effects-initiated assessments are not

risk assessments. Human Ecol Risk Assess 1997; 3:119–124.

Kapustka LA, Williams BA, Fairbrother A. Evaluating risk predictions at population and
community levels in pesticide registration--hypotheses to be tested. Environ Toxicol Chem

1996; 15:427–431.

Larson OR, Schwab RG, Fairbrother A. Seasonal occurrence of fleas (Siphonaptera) on deer

mice (Peromyscus maniculatus) in Northern California. J Vector Ecol 1996; 21:31–36.

Fairbrother A, Kapustka LA, Williams BA, Glicken J. Risk assessment in practice: Success and
failure. Human Ecol Risk Assess 1995; 1:367–375.
Anne Fairbrother, DVM, Ph.D.
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Fowles J, Fairbrother A, Baecher-Steppan L, Kerkvliet NI. Immunologic and endocrine effects

of the flame-retardant pentabromodiphenyl ether (DE-71) in C57B1/6J mice. Toxicol 1994;
86:49-61.

Marden B, Fairbrother A, Bennett J. Interlaboratory comparison of cholinesterase assay.
Environ Toxicol Chem 1994; 13:1761–1768.

Trust KA, Fowles JR, Hooper MJ, Fairbrother A. Cyclophosphamide effects on immune

function of European starlings. J Wildl Dis 1994; 30:328–334.

Fairbrother A, Fix M, O’Hara T, Ribic CA. Impairment of growth and immune function of

avocet chicks from sites with elevated selenium, arsenic, and boron. J Wildl Dis 1994; 30:222–
233.

Trust KA, Fairbrother A, Hooper MJ. Effects of 7,12-dimethylbenz[a]anthracene on immune

function and mixed-function oxygenase activity in the European starling. Environ Toxicol
Chem 1994; 13:821–830.

Fowles JR, Kerkvliet N, Fix M, Fairbrother A. Glucocorticoid effects on natural killer cell
activity, antibody response, and plasma chemistry in mallards. Comp Develop Immunol 1993;
17:165–177.

Dominguez SE, Mnkel JL, Fairbrother A, Williams BA, Tanner RW. Effect of 2,4-
dinitrophenol on metabolic rate of bobwhite quail. J Appl Toxicol Pharmacol 1993; 123:226–
233.

Buchholz P, Fairbrother A. Pathogenicity of Salmonella pullorum in northern bobwhite quail
and mallard ducks. Avian Dis 1992; 36:304–312.

Marden BT, Fowles JR, Fairbrother A. [3H]Nmethylscopolamine binding to heart atrium and
four brain regions from the mallard. Comp. BioChem and Physiol 1992; 103:115–120.

Fairbrother A, Fowles J. Subchronic effects of sodium selenite and selenomethionine on
immune functions of the mallard. Arch Environ Contam Toxicol Chem 1990; 19:836–844.

Fairbrother A, O’Loughlin D. Hematological values of the mallard (Anas platyrhynchos)
during different reproductive states. J Wildl Dis 1990; 26:78–82.

Fairbrother A, Craig MA, Walker K, O’Loughlin D. Changes in mallard (Anas platyrhynchos)

serum chemistries due to age, sex, or reproductive condition. J Wildl Dis 1990; 26:67–77.

Fairbrother A, Wagner SL, Welch S, Smith BB. Influence of menstrual cycle on serum

cholinesterase. Environ Health 1989; 49:181–189.

Fairbrother A, Bennett JK. The usefulness of cholinesterase measurements. J Wildl Dis 1988;
24(3):587–590.
Anne Fairbrother, DVM, Ph.D.
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Fairbrother A, Bennett RS, Bennett JK. Sequential sampling of plasma cholinesterase (ChE) in

mallards (Anas platyrhynchos). Environ Toxicol Chem 1987; 8:117–122.

Fairbrother A, Bennett RS. Changes in mallard hen behaviors in response to methyl parathion-

induced illness of ducklings. Environ Toxicol Contam 1987; 7:499–503.

Crawford JA, Cole PJ, Kilbride KM, Fairbrother A. Atypical plumage of a female California
quail. Cal Fish Game 1987; 73:244–247.

Knittel MD, Fairbrother A. Effect of either above optimum temperature or low pH on survival
of free virus of Autographa californica nuclear polyhedrosis virus. Appl Environ Microbiol

1987; 53: 2771–2773.

Fairbrother A, Yuill TM. Experimental infection and horizontal transmission of Modoc virus in
deer mice (Peromyscus maniculatus). J Wildl Dis 1987; 23:179–185.

Fairbrother A, Yuill TM, Olson LJ. Effects of three plant growth regulators on the immune
response of young and aged deer mice (Peromyscus maniculatus). Arch Environ Contam

Toxicol 1986; 15:265–275.

Paull JA, Fairbrother A. Vaginal lavage for pregnancy diagnosis in deer mice, Peromyscus
maniculatus. J Exp Zool 1985; 233:143–149.

Fairbrother A, Yuill TM. Experimental viral infections of deer mice (Peromyscus maniculatus).
J. Mammal. 1984; 65:499–503.

Fairbrother A, Yuill TM, Olson LJ. Effects of ingestion of chlorocholine chloride and
cyclophosphamide on Venezuelan equine encephalitis virus infections in deer mice

(Peromyscus maniculatus). Toxicol 1984; 31:67–71.

Porter WP, Hinsdill RD, Fairbrother A, Olson LJ, Jaeger J, Yuill TM, Bisgaard S, Hunter WG,
Nolan K. Toxicant-disease-environment interactions associated with suppression of immune

system, growth and reproduction. Science 1984; 224:1014–1017.

Glicken (Fairbrother) A, Schwab RG. Modes of ectoparasite reinfestations of deer mice

(Peromyscus maniculatus). J Wildl Dis 1980; 16:577–586.

Glicken (Fairbrother) A, Kendrick JW. Hoof overgrowth in Holstein Frisian dairy cattle.
J Heredity 1977; 68:386–390.

Books

Clark J, Fairbrother A, Kapustka LA. Adaptation and acclimation of terrestrial organisms to
metals in soil. International Copper Association Special Publication, SETAC Press, Pensacola,
FL, 2001.

Anne Fairbrother, DVM, Ph.D.
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Fairbrother A. Seminars in Avian and Exotic Pet Medicine—Toxicology. Guest Editor and
Introduction for Volume 8(1). WB Saunders Company, Philadelphia, PA, 1999.

Fairbrother A, Kapustka LA. Hazard classification of inorganic substances in terrestrial
systems. International Council on Metals and the Environment, Ottowa, Canada, 1997.

Glickman L, Fairbrother AA, Guarino M, Bergman HL, Buck WB, Cork LC, Hayes HM,
Legator SM, McConnell EE, Mcnelis DN, Temple SA. The use of animals as sentinels of
environmental health hazards. National Academy Press, Washington, DC, 1991.

Book Chapters

Fairbother A. Risk management safety factors. In: Encyclopedia of Ecology. Jorgensen SE
(ed), Elsevier: Oxford, 2008.

Lewis MA, Fairbrother A, Menzer RE. Methods in environmental toxicology. In: Principles

and Methods of Toxicology, Fifth Edition. Hayes AW (ed), Taylor and Francis: Philadelphia,
PA, 2007.

Fairbrother A, Hope B. Terrestrial ecotoxicology. pp. 138–142. In: Encyclopedia of
Toxicology, Second Edition. Wexler, P. (ed), Elsevier: Oxford, 2005.

Mount DR, Ankley GT, Brix KV, Clements WH, Dixon DG, Fairbrother A, Hickey CW,

Lanno RP, Lee CM, Munns WR, Ringer RK, Staveley JP, Wood CM, Erickson RJ, Hodson PV.
Effects assessment. pp. 53–118. In: Reevaluation of the State of the Science for Water-Quality
Criteria Development. Reiley MC, et al. (eds), SETAC Press: Pensacola, FL, 2003.

Fairbrother A, Kapustka LA. A historical perspective of environmental concerns to frame the
issues. pp. 1–17. In: High-Potency Herbicides Impact on Nontarget Plants. Ferenc SA (ed),

SETAC Press: Pensacola, FL, 2001.

Fairbrother A. Putting the impacts of environmental contamination in perspective. pp. 671–
689. In: Ecotoxicology of Wild Mammals. Shore RE, Rattner BA (eds), Ecological and

Environmental Toxicology Series, John Wiley and Sons: Chichester, UK, 2001.

Fairbrother A, Lewis MA, Menzer RE. Methods in environmental toxicology. In: Principals

and Methods of Toxicology, Fourth Edition. Hayes AW (ed), Taylor and Francis: Philadelphia,
PA, 2000.

Fairbrother A, Bennett RS. Multivariate statistical applications for addressing multiple stresses

in ecological risk assessments. pp. 69–115. In: Multiple Stressors in Ecological Risk and
Impact Assessment: Approaches in Risk Estimation. Ferenc SA, Foran JA (eds), SETAC
Press: Pensacola, FL, 2000.

Fairbrother A, Ankley GT, Birnbaum LS, Bradbury SP, Francis B, Gray LE, Hinton D, Johnson
LL, Peterson RE, Van Derkraak G. Reproductive and developmental toxicology of
contaminants in oviparous animals. pp 283–362. In: Reproductive and Developmental Effects
Anne Fairbrother, DVM, Ph.D.
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of Contaminants in Oviparous Vertebrates. In: DiGiulio RT, Tillit DE (eds), SETAC Press:
Pensacola, FL, 1999.

Klump JU, Adams WJ, Cardwell R, Fairbrother A, Harris HJ, Ingersoll CG, Power M, Reid
LM. Conceptual approaches to identify and assess multiple stressors. pp. 1–26. In: Multiple

Stressors in Ecological Risk and Impact Assessment. Foran JA, Ference SA (eds), SETAC
Press: Pensacola, FL, 1999.

Kelsch T, Powell RL, Dixon KR, Fairbrother A, Helgen JC, Klaine SJ, Mayer FL, Pascoe GA,

Shaw SL, Theriot RF. Regulatory issues and risk assessment. pp. 275–314. In: Ecotoxicology
and Risk Assessment for Wetlands. Lewis MA, Mayer FL, Powell RL, Nelson MK, Klaine SJ,
Henry MG, Dickson GW (eds), SETAC Press: Pensacola, FL, 1999.

Peakall DB, Fairbrother A. Biomarkers for monitoring and measuring effects. pp. 351–376.
In: Pollution Risk Assessment and Management. Douben PET (ed), John Wiley and Sons:
Chichester, UK, 1998.

Fairbrother A. Establishing the health of ecosystems. pp. 101–108. In: Multiple Stresses on
Ecosystems. Cech JJ, Wilson BA, Crosby DG (eds), Lewis Publishers: Boca Raton, FL, 1998.

Fairbrother A. Ecotoxicological principles for avian field studies. pp. 11–16. In:
Radiotelemetry for Avian Field Studies. Brewer LW, Fagerstone KA (eds), SETAC Press:
Pensacola, FL, 1998.

Kapustka LA, Fairbrother A, Williams BA, Glicken J, Bennett RS. Environmental risk
assessment for sustainable cities. Technical Publication Series [3], UNEP International

Environmental Technology Centre, Osaka, Japan, 1996. ISBN 92-807-1505-4.

Fairbrother A. Cholinesterase inhibitors. In: Non-Infectious Diseases of Wildlife, Second

Edition. Fairbrother A, Locke L, Hoff GL (eds), Iowa State University Press, Ames, IA, 1996.

Fairbrother A, Knapp CM. Ecological aspects of land spreading sewage sludge. pp. 75–80. In:
Sewage Sludge: Land Utilization and the Environment. Clapp CE (ed), ASA-CSSA-SSSA,

Madison, WI, 1994.

Menzer RE, Lewis MA, Fairbrother A. Methods in environmental toxicology. pp. 1391–1418.

In: Principles and Methods of Toxicology, Third Edition. Hayes AW (ed), Raven Press, New
York, NY, 1994.

Fairbrother A. Clinical enzymology. pp. 63–92. In: Nondestructive Biomarkers in

Vertebrates. Fosi C, Leonzio C (eds), Lewis Publishers: Boca Raton, FL, 1993.

Fairbrother A. Immunotoxicology of captive and wild birds. pp. 251–262. In: Wildlife

Toxicology and Population Modeling: Integrated Studies of Agroecosystems. Kendall R,
Lacher TE (eds), Lewis Publishers: Boca Raton, FL, 1993.

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Weeks BA, Anderson DP, DuFour AP, Fairbrother A, Goven AJ, Lahvis GP, Peters G.
Immunological biomarkers to assess environmental stress. pp. 212–234. In: Biomarkers:

Biochemical, Physiological, and Histological Markers of Anthropogenic Stress. Huggett RJ,
Kimerle RA, Mehrle PM, Bergman HL (eds), Lewis Publishers: Boca Raton, FL, 1992.

Fairbrother A. Decontamination and mitigation of baculoviruses. pp. 843–850. In: Microbial
Ecology: Principles, Methods, and Application to Environmental Biotechnology. Levin M,
Seidler R, Rogul M (eds), McGraw Hill: New York, NY, 1991.

Rattner BA, Fairbrother A. Sources of variability in cholinesterase measurements. pp. 89–108.
In: Cholinesterase-Inhibiting Insecticides—Their Impact on Wildlife and the Environment.
Mineau P (ed), Elsevier Science Publishers B.V., Amsterdam, Holland, 1990.

Fairbrother A, Bennett JK, Marden B, Hooper NJ. Methods of cholinesterase analysis, A
United States perspective. pp. 35–72. In: Cholinesterase-Inhibiting Insecticides—Their Impact
on Wildlife and the Environment. Mineau P (ed), Elsevier Science Publishers B. V.,

Amsterdam, Holland, 1990.

Books Edited

Fairbrother A (ed). Test Methods for Hazard Determination of Metals and Sparingly Soluble
Metal Compounds in Soils. SETAC Press: Pensacola, FL, 2002.

Fairbrother A, Locke L, Hoff, GL (eds). Non-Infectious Diseases of Wildlife, Second Edition.
Iowa State University Press: Ames, IA, 1996.

Selected Published Abstracts

International

Fairbrother A, Wentsel R, Wood W, Sappington K, Noyes P. Framework for inorganic metals
risk assessment. Presented at Society of Environmental Toxicology and Chemistry Annual
Meeting, Montreal, Canada, November 2006.

Gallagher K, Morris J Willis, J., Alwood A, Bauer D, Boethling R, Brody M, Burgin D,
Chow F, Dreher K, Fairbrother A, Henry T, Karn B, Libelo L, Lingle S, Nabholz J, Prothero S,

Savage N, Sayre P, Scalera J, Schoepf W, Street A, Utterback D, Williamson T, Zepp R.
Nanotechnology: environmental opportunities and challenges. Presented at Society of
Environmental Toxicology and Chemistry Annual Meeting, Montreal, Canada, November 2006;
and Society for Risk Analysis Meeting, Baltimore, MD, December 2006.

Schumaker N, Nagy L, Fairbrother A. PATCH: A spatically explicit wildlife population model
for assessing risks of pesticides to songbirds. Presented at the Wildlife Disease Association

World Congress, Cairns, Australia, June 2005.

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Fairbrother A, Wentsel R. Framework for inorganic metals risk assessment. Presented at
Society of Environmental Toxicology and Chemistry, European Annual Meeting, Lille, France,

May 2005.

Fairbrother A. Communicating probabilistic risk outcomes to risk managers. Presented at

Society of Environmental Toxicology and Chemistry, European Annual Meeting, Hamburg,
Germany, April 2003.

Clark J, Fairbrother A, Brewer L, Bennett RS. Effects of exogenous estrogen on mate selection

of house finches. Presented at Society of Environmental Toxicology and Chemistry, European
Annual Meeting, Vienna, Austria, May 2002.

Blanton ML, Driver CJ, Fairbrother A, Touart L. Detailed review paper for an avian two-
generation and partial life-cycle reproductive and developmental toxicity test. Presented at
Society of Environmental Toxicology and Chemistry, European Annual Meeting, Vienna,
Austria, May 2002.

Trust KA, Fairbrother A, Hooper MJ. Effects of 7,12-dimethylbenz[a]anthracene on immune
function and mixed-function oxygenase activity in the European starling. Society of Toxicology

Annual Meeting, New Orleans, LA, March 1993; and Wildlife Disease Association Annual
Meeting, Guelph, Canada, August 1993.

Fairbrother A. Biomarkers in wildlife. Society of Environmental Toxicology and Chemistry

Annual Meeting, Toronto, Canada, November, 1989.

Fairbrother A. Immunotoxicology of wild and laboratory birds. Wildlife Disease Association

6th International Meeting, East Berlin, GDR, August, 1990.

Yuill TM, Hinsdill RD, Porter WJ, Fairbrother A. The hidden challenge: determining sublethal

effects of wildlife diseases. Wildlife Disease Association 6th International Meeting, East
Berlin, GDR, August, 1990.

National

Fairbrother A, Dohmen P, Marchand M, McCarty LS, Solomon K. Use of (Eco) toxicity data as
screening criteria for the identification and classification of PBT / POP compounds. Presented

at the Society of Environmental Toxicology and Chemistry Annual Conference, Tampa, FL,
November 2007.

DeForest D, Fairbrother A, Adams BA. Selenium hormesis in birds—Implications for

developing dietary and egg-based toxicity thresholds. Presented at the Society of
Environmental Toxicology and Chemistry Annual Conference, Tampa, FL, November 2007.

Grim KC, Fairbrother A, Monfort S, Tan S, Rattner B, Gerould S, Beasley V, Aguirre A,

Rowles T. Results of a wildlife toxicology workshop held by the Smithsonian Institution—
Identification and prioritization of problem statements. National Presented at the Society of

Anne Fairbrother, DVM, Ph.D.
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Environmental Toxicology and Chemistry Annual Conference, Milwaukee, WI, November

2007.

Hope B, Allard P, Fairbrother A, Hull R, Johnson MS, Kapustka LA, McDonald B, Sample BE.

Representation and consequences of uncertainty in the toxicity reference value. Presented at the
Society of Environmental Toxicology and Chemistry Annual Conference, Milwaukee, WI,
November 2007.


Allard P, Hill R, Mann G, Mackintosh C, Hull R, Kapustka LA, Mcdonald B, Hope B, Sample
BE, Fairbrother A, Johnson MS. Using dose-response relationships for wildlife TRVs.
Presented at the Society for Risk Analysis Annual Conference, Milwaukee, WI, November

2007.

Kapustka L, Fairbrother A, Sample BE. Linking assessment endpoints and wildlife TRVs.
Presented at the Society for Risk Analysis Annual Conference, Milwaukee, WI, November

2007.

Hull RN, Allard P, Fairbrother A, Hope B, Johnson MS, Kapustka LA, McDonald B, Sample
BE. Summary of recommendations for wildlife TRV development and use. Presented at the

Society of Environmental Toxicology and Chemistry Annual Conference, Milwaukee, WI,
November 2007.

Fairbrother A. Environmental immunotoxicants: Human-wildlife relationships. Presented at

the Society of Environmental Toxicology and Chemistry Annual Conference, Milwaukee, WI,
November 2007.


Fairbrother A, Sappington K, Wentsel R, Menzie C, Bottimore D, Downey P, Haber L,
Harding-Barlow I, Nelson M, Thornton K. Principles for Metals Risk Assessment USEPA
Framework. Presented at the Society for Risk Analysis Annual Conference, Baltimore, MD,
December 2006.

Fairbrother A, Wentsel R, Sappington K, Wood W, P. Noyes. Framework for inorganic metals
risk assessment. Presented at Society of Environmental Toxicology and Chemistry Annual

Meeting, Montreal, Canada, November 2006.

Morzillo AT, Fairbrother A. Effects of human activities on resident mammals within urban

ecosystems. Presented at the 86th Annual Meeting of the American Society of Mammalogists
meeting, Amherst, MA, June 2006.

Smith C, Stubblefield W, Clark J, Fairbrother A, Allen H, Schoeters I, Dwyer R. Distribution of
soil bioavailability parameters throughout Europe and development of metalloregions. Major
Scientific/Technical Contributions. Presented at Society of Environmental Toxicology and

Chemistry Annual Meeting, Portland, OR, November 2004.

Wentsel R, Fairbrother A. Overview of the development of the Framework for Metals Risk

Assessment. Presented at Society of Environmental Toxicology and Chemistry Annual
Meeting, Portland, OR, November 2004.

Anne Fairbrother, DVM, Ph.D.
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Fairbrother A. Comparison of European and United States approaches to new and existing

substances regulation. Presented at Society of Environmental Toxicology and Chemistry
Annual Meeting, Portland, OR, November 2004.

Adams W, Brix K, DeForest D, Toll J, Fairbrother A, Kapustka L. Ecological risk assessment
at a copper smelter. Presented at Society of Environmental Toxicology and Chemistry Annual
Meeting, Portland, OR, November 2004.

Suter II GW, Fairbrother A, Munns Jr WR, Norton SB, Wentsel R, Kravitz MJ. Individuals
versus organisms versus populations in the definition of ecological assessment endpoints.
Presented at Society of Environmental Toxicology and Chemistry Annual Meeting, Portland,

OR, November 2004.

Smolders E, Fairbrother A, Hale B, Lombi E, McGrath S, McLaughlin M, Rutgers M, Van der
Vliet L. Hazard assessment of metals and metal compounds in terrestrial systems. Presented at

Society of Environmental Toxicology and Chemistry Annual Meeting, Austin, TX, November
2003.

Adams WJ, Tear LM, Edwards M, Fairbrother A, Brix KV. Re-analysis of field data used to
derive selenium toxicity thresholds for birds. Presented at Society of Environmental Toxicology
and Chemistry Annual Meeting, Nashville, TN, November 2000.

Fairbrother A. Values of constructed and natural ecosystems: Are they equivalent? Presented
at Society for Risk Analysis Annual Meeting, Arlington, VA, December 2000.

Fairbrother A, Tear L, Toll J. Probabilistic risk assessment of methiocarb in terrestrial
agroecosystems. Presented at Society of Environmental Toxicology and Chemistry Annual
Meeting, Nashville, TN, November 2000.

McQuillen H, Brewer L, Fairbrother A, Clark J, Bennett RS, Fry DM. Field deployable
techniques to monitor exposure to environmental estrogens throughout the reproductive cycle of
wild birds. Presented at Society of Environmental Toxicology and Chemistry Annual Meeting,

Nashville, TN, November 2000.

Fairbrother A. A critical review of avian test methods for endocrine disrupting activity of

environmental chemicals. Presented at Society of Environmental Toxicology and Chemistry
Annual Meeting, Philadelphia, PA, November 1999.

Fairbrother A, Bennett RS. Environmental risk assessment and the precautionary principle.

Presented at Society of Environmental Toxicology and Chemistry Annual Meeting, Charlotte,
NC, November 1998.

Fairbrother A, Bennett RS. Ecological risk assessment at the Mother Lode mercury mine,
Ochoco National Forest. The 47th Annual Meeting of the Wildlife Disease Association,
Madison, WI, August 1998.

Anne Fairbrother, DVM, Ph.D.
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O’Hara T, Franson C, Fairbrother A. Forensic investigations of wildlife: contaminants.

Presented at Society of Environmental Toxicology and Chemistry Annual Meeting, San
Francisco, CA, November 1997.

Clark J, Fairbrother A, Brewer L, McQuillen H, Bennett RS. Effects of exogenous estrogen on
mate selection of house finches. Presented at Society of Environmental Toxicology and
Chemistry Annual Meeting, Nashville, TN, November 2000.

Invited Presentations

International

Fairbrother A. Environmental effects of manufactured nanomaterials. Invited plenary

presentation at SETAC World Conference, Sydney, Australia August 2008.

Fairbrother A. Ecological risk assessment and wildlife toxicology. 1 stInternational Conference

on Environmental Issues, Hanoi, Vietnam, March 2004.

Fairbrother A. Genetically modified foods: Technological breakthrough or ecological

nightmare? Keynote address at SETAC Asia Pacific conference, Christchurch, New Zealand,
September 2003.

Fairbrother A, Turnley JG. Communication of probabilistic risk assessments. Invited
th
presentation in special symposium on Probabilistic Risk Assessment at SETAC Europe 13
annual conference, Hamburg, Germany, April 2003.

Clark J, Fairbrother A, Brewer L, Bennett RS. Effect of exogenous estrogen exposure on mate
selection by the female house finch. Invited presentation at SETAC Europe 12 thAnnual
Conference, Vienna, Austria, May 2002.

Robinson S, Fairbrother A. Human health risks from organotins in household products.
Proceedings of the Organotin Environmental Programme Association Meeting, Sardinia, Italy,

October 2000.

Fairbrother A, Brix KV, DeForest DK, Adams WJ. Critical review of tissue-based selenium

toxicity thresholds for fish and birds. Presented at Mine Reclamation Symposium, Williams
Lake, British Columbia, June 2000.

Fairbrother A. Fellow of the Crown Research Institute, Wellington, New Zealand. Invited
lectures to scientific staff, regulators and academics (University of NZ, Christchurch), October
2000.

Fairbrother A. Keynote speaker and invited lecturer, Zoo and Wildlife Veterinary Medicine,
Continuing Education. Western Plains Zoo, Dubbo, Australia. September 1999.

Fairbrother A. Tier 1 (Screening Level) risk assessments in British Columbia. Workshop
sponsored by the Ministry of the Environment, Vancouver, BC, November 1998.
Anne Fairbrother, DVM, Ph.D.
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National

Plenary: Federal environmental legislation in the U.S. for protection of wildlife and regulation

of environmental contaminants. Smithsonian Wildlife Toxicology Symposium, Washington DC
March 2007.

th
Keynote: History of development and use of bioindicators and biomarkers in the U.S. 14
International Conference on Bioindicators. Baltimore, MD April 2006.

Lecture: RCRA and CERCLA: Environmental containment, contamination, and clean up.
School of Veterinary Medicine, University of Illinois, March 2005.

Co-instructor: Introduction to Ecological Risk Assessment. Dept. of Fisheries and Wildlife and
Dept. of Environmental and Molecular Toxicology, Oregon State University, Corvallis, OR,
Winter 2003–2007.

Lectures: Risk assessment overview and introduction to TSCA and FIFRA. Presented in an
upper division graduate level course on environmental studies. Department of Environmental

Science, Oregon State University, Corvallis, OR, Fall 2002, Winter 2003, 2004.

Ecological Risk Assessment Guidelines in Oregon -- Case Study. Presentation at the
Environmental Law Education Center, 2 ndAnnual Meeting on Contaminated Sites Issues,

Portland, OR, March 1998.

Selenium toxicity in wetland birds. Selenium Symposium, Salt Lake City, UT, March, 1997.

Toxicity Extrapolations in Terrestrial Systems. Lead Instructor. A short-course workshop at the
Society of Environmental Toxicology and Chemistry 17 thAnnual Meeting, Washington, DC,

November, 1996.

Environmental Risk Assessment for Sustainable Development. Nevada Environmental

Conference, Reno, NV, September–October, 1996.

Ecological risk assessment benefits, environmental management. Invited presentation at

Ecological Risk Assessment Symposium, Corvallis, OR, November, 1994.

The biomedical paradigm applied to ecosystems. Ecosystem Health Meeting sponsored by

University of California, Davis, Sacramento, CA, October, 1993.

Ecological aspects of land spreading of sewage sludge. Land Application of Sewage Sludge

Symposium, Minneapolis, MN, August, 1993.

Seminar: Ecological risk assessment: from biomarkers to landscapes. Department of
Environmental and Molecular Toxicology, Oregon State University, Corvallis, OR, February

2003.

Anne Fairbrother, DVM, Ph.D.
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Lectures: Ecological Risk Assessment. Team-taught upper division/graduate level course at
Oregon State University, Corvallis, OR, Winter Quarter 2003.

Lectures: Wildlife Toxicology. Presented in an upper division graduate level course on wildlife
diseases. Department of Fisheries and Wildlife, Oregon State University, Corvallis, OR, March

1998 and 1999.

Lectures: Situational Ethics – the use of science in policy making. Oregon Junior Science and
Humanities Symposium, Oregon State University, Corvallis, OR, March 1996–1999.

Invited Weisse Lecturer: Ecological Risk Assessment and Wildlife Toxicology. Department of
Zoology, University of Oklahoma, Norman, OK, January 1998.

Seminar: Toxicity extrapolations in terrestrial systems. University of Nevada, Reno, NV, April
1997.

Lecture: Introduction to ecotoxicology. University of Nevada, Reno, NV, April 1997.

Lecture: Ecotoxicology and veterinary medicine. School of Veterinary Medicine, Oregon State

University, Corvallis, OR, August, 1995 and 1996.

Lecture: Ecological risk assessment practices. Envirovet Program, Duluth, MN, August, 1994.

Lecture: Current and future ecological risk assessment approaches in the EPA. Envirovet
Program, Duluth, MN, July, 1993.

Lecture: Environmental science and policy in the 21st century. Oregon Junior Science and
Humanities Symposium, Corvallis, OR, March, 1993.

Lecture: Wildlife veterinary medicine and conservation biology. School of Veterinary
Medicine, University of California, Davis, CA, February, 1992.

Seminar: Environmental toxicology: a growing concern? College of Veterinary Medicine,

Oregon State University, Corvallis, OR, November, 1990.

Lecture: Career opportunities in wildlife medicine. Keynote speaker at Phi Beta chapter

Annual Meeting, Oregon State University, Corvallis, OR, May, 1990.

Lecture: Wildlife immunotoxicology. Oregon State University, spring term of even years,
Corvallis, OR.

Lecture: The role of the USEPA in environmental toxicology. Institute of Wildlife Toxicology
and Chemistry, Western Washington University, Bellingham, WA, April, 1990.

Lecture: The Wildlife Toxicology Research Team at the USEPA Environmental Research
Laboratory in Corvallis. Institute of Wildlife Toxicology and Chemistry, Western Washington
University, Bellingham, WA, 1987.
Anne Fairbrother, DVM, Ph.D.
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Prior Experience

Sr. Consultant and Lead for Environmental Risk Assessment and Toxicology, Parametrix, Inc.,
2007–2008
Associate Director for Science, U.S. EPA, National Health and Environmental Effects Research

Laboratory, Western Ecology Division, 2006–2007
Chief, Risk Characterization Branch, (Supervisory Life Scientist, hired at the GS-15 level
[science promotion to Grade 15, 9/02]); U.S. EPA, National Health and Environmental
Effects Research Laboratory, Western Ecology Division, Corvallis, 2002–2006

Director and Senior Ecotoxicologist, Terrestrial Ecotoxicology; Parametrix, Inc., 1999–2002
Sr. Wildlife Ecotoxicologist; Ecological Planning and Toxicology, Inc.,1994–1999
Chief, Ecotoxicology Branch, (Supervisory Ecologist, detailed at the GM-15 level), USEPA
Environmental Research Laboratory, 1992–1994

Research Ecologist USEPA Environmental Research Laboratory (GS12 – GS14), 1986–1992
Courtesy Associate Professor, College of Veterinary Medicine, Oregon State University, 1987–
2003

Courtesy Professor, Department of Environmental and Molecular Toxicology, Oregon State
University, 2003–present

Selected Project Experience

Conducted an RI/FS for 150 miles of the upper Columbia River (Canadian border to the Grand
Coulee Dam) and surrounding uplands to assess potential ecological risks of smelter emissions

to aquatic life, plants, and wildlife. Studied contaminated sediments to ascertain bioavailable
metals, conducted food-chain analyses for fish and wildlife, and evaluated soil and uplands in
depositional areas to assess risks to plants and wildlife. Work was conducted under agreement
with EPA and participating parties.

Conducted a Detailed Ecological Risk Assessment of the tailings management system of the
Gratzburg mine, Irian Jaya, Indonesia. This included assessing risks to plants and wildlife in
jungles and estuarine mangrove ecosystems through food-chain analyses, ecological function

studies, and floristic composition analyses. Performed extensive plant phytotoxicity and metal
uptake studies to determine risk thresholds for tropical species. A detailed report was written
estimating current and future (until mine closure in 2034) risks.

Served as an Expert Advisor to Cominco and its contractors for design and conduct of a
terrestrial wide-area assessment under the Contaminated Site Regulations of British Columbia.
This included development of appropriate assessment endpoints, conceptual site models,

sampling and analysis plans, and final risk estimates. The area encompassed the upper
Columbia River Valley and associated side valleys that had been subject to past deposition from
the zinc-lead smelter plume.

Conducted an Ecological Risk Assessment for 165 square miles of property surrounding the
Bingham Canyon, Utah, gold mine. Work included a survey of plants and wildlife on the site,
food-chain analysis of potential metal contamination, field measurements of small-mammal

populations, nesting surveys of shorebirds, and development of management options for various
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04/09 ANNEX 158

portions of the site. Included a probabilistic risk assessment of effects of selenium on the local
populations of wading birds.

Conducted an assessment of risk to terrestrial and aquatic organisms from an abandoned
mercury mine in the Ochoco Mountains, Oregon, and determined risk-based cleanup levels.

This was the first risk assessment to follow the newly published Oregon Department of
Environmental Quality guidelines.

Assessed the potential for risk to livestock from use of wastewater on irrigated pasture during

mine closure. Selenium and thallium were identified as contaminants of concern. Plant uptake
studies were conducted to refine risk estimates for thallium, both in laboratory and field
situations.

Provided expert consultations on review comments relating to potential future development of
pit lakes at gold mines in Nevada. Included interpretation of information on contaminants of
concern, potential for bioaccumulation, and wildlife food-chain contamination.

Conducted an assessment of the potential ecological risks posed by use of copper pipes in
housing in California. Specific emphasis was on amount of copper discharged to San Francisco

Bay. Other areas, such as the Southern California Bight and San Diego Bay, also were assessed.
Endpoints included protection of aquatic life, achievement of water quality criteria, and methods
for establishing water effect ratios for specific locations.

Conducted a screening-level and Level II ecological risk assessment as part of a cleanup of
stormwater runoff from the bus yard of the Tri-Met transportation authority in Portland, Oregon.
Runoff into a bioswale had contaminated a small wetland and possibly a nearby creek.

Endangered species of concern included the red-legged frog. Human health risks also were
assessed for final cleanup.

Developed a probabilistic risk assessment model for determining risk of pesticides to birds using
agricultural fields, including both flowable and granular pesticides. The model was developed
using the Analytica ® decision-based software system. The model was developed for industry as
part of the ECOFRAM process sponsored by the EPA. The basic model is applicable to

exposure to any contaminant, and contains a fate module that allows input of degradation rates
over time.

Provided technical and managerial support to the organotin industry for submission of a
screening information data set (SID) of information on 27 chemicals to the OECD’s High
Production Volume (HPV) data call-in program. Reviewed the available literature on
physical/chemical properties, environmental fate, ecotoxicity, and human health effects for all

the chemicals, and entered appropriate data into the IUCLID database system. Tests were
placed with contract laboratories to fill data gaps. Structure-activity relationships and chemical
categories were developed to reduce the need for testing. Developed rest plans, SIARs, and

dossiers for submission to the regulatory authorities.

Collated all existing toxicity reference values for wildlife, plants, and soil invertebrates into a
user-friendly database. Information was accessible via an interface with Microsoft Access.
Anne Fairbrother, DVM, Ph.D.
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Included in the database were the endpoint, species tested, method of determining TRV/
benchmark, and jurisdiction. All values were rated on 20 criteria, and a desirability rating was
provided to guide the selection of an endpoint when multiple values (i.e., jurisdictions) were

available. The database is to be integrated into the Tri-Services web-based screening-level risk
assessment model.

Built a database of nickel toxicity and essentiality and mechanisms for maintaining homeostasis.
Retrieved and collated all available information on essentiality and toxicity of nickel to
terrestrial and aquatic receptors (other than humans). Reviewed papers for data quality and
entered information into a Microsoft Access database for easy retrieval (subsequently migrated

to IUCLID). Literature citations were entered into ProCite.

Reviewed entire literature for effects of zinc and phthalate esters on terrestrial organisms
(plants, wildlife, soil organisms). Qualified all studies for data quality and summarized the

extent of the database. Provided all information in written report and electronic database of
endpoints and data quality. Zinc data were used in the continent-wide ecological risk
assessment conducted by the European Union (EU) and subsequently were migrated to IUCLID

for use in REACH.

Wrote a Tier I assessment and supervised the conduct of toxicity and exposure studies for
registration with the U.S. Fish and Wildlife Service of a new non-toxic shot for waterfowl

hunting. Successfully completed the registration process under the new regulations, which
allow selected testing rather than a complete battery of tests. Information also was submitted to
Environment Canada for review. Shot has been registered and successfully marketed in the U.S.

for several years.

Co-author of the EPA’s Framework for Metals Risk Assessment. This guidance document
provides the basic concepts for conducting human health and ecological risk assessments on

inorganic metals, primarily at contaminated sites. It includes definitions and guidance for major
areas, including background, bioavailability, bioaccumulation, and environmental chemistry of
metals.

Wrote and produced the guidance document and checklist manual for British Columbia Ministry
of Environment, Land, and Parks for implementing Tier 1 ecological risk assessments of
contaminated sites. Presented the materials at training workshops in Vancouver.

Directed studies in a fully compliant GLP laboratory following FIFRA pesticide registration
guideline for mallard and bobwhite quail. Included acute, subchronic, and reproduction studies
with novel chemical and biological pesticides, conducted for most of the large agrichemical

companies. Additional studies included tests specifically tailored to address questions of
contaminant uptake from soil, potential food aversion from chemical-treated feed, and other
studies to address specific aspects of exposure of wildlife to pesticides.

Conducted and published laboratory studies with the rat as a model of the pica child to
determine the uptake efficiency of petroleum hydrocarbons from soils. Soil types included aged
soils, treated soils, and lampblack. Information from the study can be used in exposure

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04/09 ANNEX 158

equations in place of default values when estimating total uptake of PAHs from different soil
types during either human or ecological risk assessments of contaminated sites.

Researched effects of estrogen supplementation in house finch breeding behavior, including
mate selection, changes in plumage coloration, and reproductive output. Animals were
implanted with time-release devices for continual elevation of estrogen levels, and an ELISA

method for measurement of fecal/urate estrogens was adapted to the house finch to monitor
changes in hormones during the breeding cycle. Used videography to assess effects on nest
behaviors.

Academic Appointments

x Associate Professor (Adjunct), Department of Environmental and Molecular

Toxicology, Oregon State University, 2003
x Associate Professor (Adjunct), College of Veterinary Medicine, Oregon State
University, 1987–2003

Advisory Appointments

x The Institute of Environmental and Human Health, Texas Tech University, Science

Advisory Board, 2005–present
x British Columbia Science Advisory Board for Contaminated Sites, 2003–present
x International Metals Consortium Ecological Technical Advisory Panel, 1995–present

x USPEA, Endocrine Disruptor Methods Validation Committee, 2004–2006
x Utah Division of Water Quality, selenium standard development, Science Advisory
Panel, 2004–2008

x Novel Methods for Integrated Risk Assessment of Cumulative Stressors in the
Environment (NOMIRACLE), Expert Advisory Panel, 2005–2007
x USEPA Risk Assessment Forum member, 2004–2007

x USGS BRD National Wildlife Health Center (NWHC) and Forest and Rangeland
Ecology Science Center (FRESC), Peer Review Science Panel, 2005
x USEPA Office of Research and Development, Board of Scientific Counselors, 2001

x USEPA Science Advisory Panel (Pesticides), 2001
x Contaminated Soils Advisory Group, Society of Environment Toxicology and
Chemistry, 1996–present

x Science Advisory Committee, US Environmental Protection Agency, Center of
Excellence in Ecotoxicology, University of California, Davis, 1992–1998
x Science Advisory Panel for Soil Toxicity Criteria, British Columbia Ministry of

Environment, 1996
x Peer Review Panel for Ecotoxicity Threshold Values, Superfund Program, US
Environmental Protection Agency, 1995

x US Environmental Protection Agency Peer Review Panel, Ecological Risk Assessment
Guidelines, 1995
x Blue Ribbon Peer Review Panel, US Fish and Wildlife Service, Patuxent Wildlife

Research Center, 1990–1991

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04/09ANNEX 158

x National Research Council Committee Member, Use of Animals as Indicators of
Environmental Health Hazards, 1988–1991

Editorships and Editorial Review Boards

Editorial Boards

x Environmental Toxicology and Chemistry, 1995–1997
x Human and Ecological Risk Assessment, 2004–present

x Journal of Wildlife Diseases, 1998–present
x Risk Analysis, 2001–present

Associate Editor

x Journal of Wildlife Diseases, 1986–1991

x Journal of Wildlife Management, 1995–1996
x Chemosphere (Risk Assessment section), 2003–2005
x Ecotoxicology, 1995–present

Guest Editor

x Seminars in Avian and Exotic Pet Medicine Toxicology Vol 8, Jan 1999

x Fact Sheets on Environmental Risk Assessment, www.icmm.org , 2001–2002
x Ecological Applications special issue on mercury in Clear Lake, CA, 2006–2007

Peer Reviewer

x Archives of Environmental Contamination and Toxicology

x Bulletin of Environmental Contamination and Toxicology
x Comparative Physiology
x Ecological Applications

x Ecological Modelling
x Environmental Toxicology and Chemistry

x Human and Ecological Risk Assessment
x Integrated Environmental Assessment and Management
x Journal of Wildlife Diseases

x Journal of Wildlife Management
x Risk Analysis

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04/09 ANNEX 158

Professional Affiliations

x American Veterinary Medical Association—AVMA

– Committee on Environmental Issues, 2001-2003 (Chair, 2002–2003)
x American Association of Wildlife Veterinarians—AAWV
– President, 1991–1993

x Society of Environmental Toxicology and Chemistry—SETAC
– President SETAC North America, 2002–2003
x Society for Risk Analysis—SRA

x Wildlife Disease Association—WDA
– President, 1995–1997

Anne Fairbrother, DVM, Ph.D.
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04/09ANNEX 158

Marion Joseph Fedoruk, M.D., C.I.H., D.A.B.T., FACMT

Principal Scientist

Professional Profile

Dr. Marion Joseph Fedoruk is a Principal Scientist in Exponent’s Health Sciences and is an
advisor to all the Health Sciences Centers. Dr. Fedoruk holds subspecialty board certification in
Medical Toxicology and primary board certification in Occupational Medicine from the
American Board of Preventive Medicine. There are fewer than 40 physicians in the U.S. who

hold both these certifications. He is also a Diplomate of the American Board of Toxicology
(DABT) and is also certified by the American Board of Industrial Hygiene as a Certified
Industrial Hygienist (CIH).

Dr. Fedoruk maintains an active clinical practice and is engaged in teaching and research at the
University of California, Irvine, where he is Clinical Professor of Health Sciences, and Senior
Physician at the UCI Center for Occupational and Environmental Health Clinic.

Dr. Fedoruk has extensive experience in the assessment of exposure and related health effects
for a broad range of chemical and biological hazards. His 25-year experience involves
evaluating health significance from environmental, occupational, and product related exposures.
His assessments have involved mercury, lead, arsenic, cadmium, nickel, polychlorinated

biphenyl (PCBs), benzene, volatile organic hydrocarbons, isocyanates, pesticides, combustion
products, talc, silica, and other dusts. He has designed, developed, and implemented medical
monitoring programs for workers in several industries including hazardous waste, energy,

asbestos, and electronics, and directed a course on medical surveillance. He performed an
assessment of health needs for military and civilian personal involved in chemical weapons
destruction in Johnson Atoll, in Micronesia. His work has involved assessment of air quality
problems in homes, offices, schools, and work environments including assessments for

microbial hazards.

Dr. Fedoruk has served as advisor occupational and environmental health matters to both
government and industry. He served as a member of an expert panel convened by EPA and the

U.S. Department of Labor to develop national priorities for educating health care providers
about the adverse health effects of pesticides. Dr. Fedoruk has served as advisor to NFPA for
developing medical guidelines for the Nation’s firefighters. He has assisted health and fire
departments in evaluating public health impacts associated with accidental chemical releases.

He has also been involved in developing occupational medical programs and guidelines for
several jurisdictions, including the City of New York.

Dr. Fedoruk has conducted studies and published articles in the areas of occupational and

environmental medicine. He authored chapters in several books, including the World Health
Organization’s Encyclopedia of Occupational Safety and Health, the Encyclopedia of
Toxicology, and textbooks in occupational lung diseases and thoracic oncology. He most

04/08 ANNEX 158

recently designated as a Fellow of the American College of Medical Toxicology, the society for
board certified medical subspecialists.

Academic Credentials and Professional Honors

M.D., University of Alberta, Edmonton, Canada (with distinction), 1978
Biology Studies, University of Alberta, Edmonton, Canada, 1974
Premed, Selkirk College, British Columbia, Canada (honors standing), 1971

Medical Toxicology, Subspecialty, Certification in 1998 (certified by the American Board of
Preventive Medicine)
Occupational Medicine, Specialty, Certification in 1984 (certified by the American Board of

Preventive Medicine)
Certified Industrial Hygienist, Toxicology Aspects Certification December 1985 (certified by
the American Board of Industrial Hygiene
Diplomate, American Board of Toxicology (DABT), Certification in 1987

Residency: Occupational Medicine, Department of Community and Environmental Medicine,
University of California, Irvine, California, 1981–1983; Internship: Montreal General Hospital,

Montreal, Canada (McGill University), mixed internship, 1978–1979

1995 Recipient of Merit in Authorship Award from the American College of Occupational and
Environmental Medicine for publication, “Personal Risk Assessment Under the Americans with

Disability Act: A Decision Analysis Approach,” Journal of Occupational Medicine 1993,
35:1000–10

2001 Recipient of The Jean Spencer Felton Award for Excellence in Scientific Writing awarded
by The Western Occupational and Environmental Medical Association

Fellow American College of Medical Toxicology, 2007

Adolph G. Kammer Merit in Authorship Award, American College of Occupational and
Environmental Medicine, 1995

Publications/Abstracts

Richter RO, Kerger BD, Hoyt S, Fedoruk MJ. Influence of hydrocarbon composition on
benzene vapor emissions in mixed products. Abstract selected for platform presentation at 17th
International Society for Exposure Analysis Annual Meeting, Proceedings, Durham RTP, NC,
October 21, 2007.

Fedoruk MJ, Kerger BD, Bronstein R, Richter RO. Airborne dust exposure assessment for
automotive body shop work involving resin fillers and abrasives. Platform presentation at the

Annual Meeting of the Society of Toxicology, Charlotte, NC, 2007. Toxicological Sciences
96(1):147.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
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04/08ANNEX 158

Seltzer JM, Fedoruk MJ. Health effects of mold in children. Pediatr Clin North Am 2007;
54(2):309–333.

Fedoruk MJ, Smalstig T, Richter RO, Bronstein R, Kerger BD. Modeling residential exposure
to xylenes and ethylbenzene from window sealant application based on laboratory mass flux

measurements. Presented International Society of Exposure Analysis 15th Annual Meeting,
Tucson, AZ, November 2005. Proceedings Abstract Book, p. 173.

Fedoruk MJ, Smalstig T, Tran J, Shum M, Richter RO, Bronstein R, Kerger BD. Diesel-related

benzene exposures during refueling operations at two grocery distribution centers.
Toxicological Sciences 84(S-1):83, Abstract #412. Presented at Society of Toxicology (SOT)
44th Annual Meeting, New Orleans, LA, April 2005.

Fedoruk M, Bronstein R, Kerger D. Ammonia exposure and hazard assessment for selected
household cleaning product uses. Journal of Exposure Analysis and Environmental
Epidemiology 2005; 15:534–544.

Fedoruk MJ, Bronstein R, Kerger BD. Volatile organic compound exposure assessment for
government inspectors at gas stations. Toxicological Sciences 78(1-S):106(516). Presented at

43rd Society of Toxicology Annual Meeting, Baltimore, MD, March 2004.

Kerger BD, Bronstein R, Fedoruk MJ. Exposure assessment of volatile organic compounds and
metals for government inspectors at auto body Repair Facilities. Toxicological Sciences 78(1–

S):106-107(517). Presented at 43rd Society of Toxicology Annual Meeting, Baltimore, MD,
March 2004.

Fedoruk M, Kerger B. Pitfalls of broad-based chemical screening of fire responders in
California: A false alarm on cyanazine herbicide. Presented at 42nd Society of Toxicology
Annual Meeting, Baltimore, MD, March 2004. Toxicology Sciences 72(S-1):241, 2003.

Fedoruk M, Bronstein R, Kerger B. Benzene exposure assessment of use of Mineral spirits-
based degreaser. Applied Occupational and Environmental Hygiene 2003; 18:764–771.

Kerger B, Fedoruk M. Ammonia exposure and dose response assessment for household
cleaning uses. Abstract No. 1693, Society of Toxicology Annual Meeting, Nashville, TN,
March, 2002.

Fedoruk M, Kerger B. Assessment of toluene and ethyl acetate exposure from wearing a
costume mask bonded with contact cement. Abstract No. 1692, Society of Toxicology Annual
Meeting Nashville, TN, March 2002.

Jones P, Greaney P, Fedoruk M. A model medical surveillance program. Presented at National
Institute of Occupational Health and Safety (NIOSH) symposium Best Practices in Workplace

Surveillance: Identification and Tracking of Workplace Injury, Illness, Exposures, and Hazards,
Cincinnati, OH, November 7–9, 2001.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
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Fedoruk M, Kerger B. Measurement of volatile organic compounds in vehicles. Toxicologist

Suppl 2001; 1:97.

Kerger B, Fedoruk M. Benzene exposure assessment for the use of petroleum naphtha in a
metal parts cleaner. Toxicologist Suppl 2000; 54(1):21.

Carmean G, Chase W, Fedoruk M. Empirical validation of New York City police officer visual
acuity requirements. Abstract, 19th UOEH and 3rd IIES International Symposium, Kitakyushu,

Japan, October 1999.

Fedoruk M, Carmean G. Development of job-related medical screening criteria for New York

City police officers. Abstract, 19th UOEH and 3rd IIES International Symposium, Kitakyushu,
Japan, October 1999.

Fedoruk M, Kerger B D. Polychlorinated biphenyls (PCBs) measured in a grade school
following a fluorescent light ballast failure. Toxicologist Suppl 1999; 48(1–S):279.

Fedoruk M, Uhlman S, Baker D. Microbial contamination of a ventilation system detected by
rd
microbial volatile organic compound (MVOC) analysis. Abstract, presented at the 3
International Conference on Bioaerosols, Fungi and Mycotoxins, Sarasota Springs, NY,
September 1998.

Chester T, Fedoruk M, Langely R, Wilkinson C. The hazards of working in health care. Patient
Care 1996; February 15.

Chester T, Fedoruk M, Langely R, Wilkinson C. Caution: Work can be hazardous to your
health. Patient Care 1996; February 15.

Fedoruk M. ACOEM Reproductive and developmental hazard guidelines. J Occup Environ
Med 1996; 38:1.

Harber P, Fedoruk M. Work placement and work fitness: Implications of the Americans with
Disabilities Act for pulmonary medicine. Chest 1994; 105:15641571.

Harber P, Hsu P, Fedoruk M. Personal risk assessment under the Americans with Disability
Act: A decision analysis approach. J Occup Med 1993; 35:10001010.

Harber P, Fedoruk M, Goldberg R. Accommodation of respiratory handicaps. Seminars in
Respiratory Medicine 1993, 14:240–249.

Fedoruk M, Lee L. Positive pre-employment urine drug screen caused by foreign manufactured
vitamin formulation. West J Med 1991; 155:663.

Sargent E, Adolph J, Clemmons M, Kird G, Pena B, Fedoruk M. The evaluation of flu-like
symptoms in workers handling xanthan gum powder. J Occup Med 1990; 32:625–630.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
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Guidotti T, Alexander R, Fedoruk M. Epidemiologic features that may distinguish between

illness due to chemical exposure and of psychogenic origin in building-associated outbreaks.
J Occup Med 1987; 29:148–150.

Book Chapters

Fedoruk M, Hong S. Gastrointestinal toxicology. In: Information Resources in Toxicology, 4 th

Edition. Wexler P (ed), Elsevier, in press.

Fedoruk J, Miller JD. Health effects of bioaerosols. In: Field Guide for the Determination of
nd
Biological Contaminants in Environmental Samples, 2 edition. Hung LL, Miller JD, Dillon
HK (eds), American Industrial Hygiene Association, Fairfax, VA, 2005.

nd
Fedoruk M, Guidotti T. Gastrointestinal system. In: Encyclopedia of Toxicology 2 Edition.
Wexler P, Anderson B, de Peyster A, Gad S, Hakkinen PK, Kamrin M, Locey B, Mehendale H,
Pope C, Shugart L (eds), Elsevier Sciences, 2005.

nd
Fedoruk M, Guidotti T. Skeletal system. In: Encyclopedia of toxicology 2 Edition. Wexler P,
Anderson B, de Peyster A, Gad S, Hakkinen PK, Kamrin M, Locey B, Mehendale H, Pope C,

Shugart L (eds), Elsevier Sciences, 2005.

Fedoruk M, Uhlman S, Baker D, Yang H. Analysis of microbial contamination of a ventilation
system detected by measurement of microbial volatile organic compounds. pp. 386–395. In:

Bioaerosols, Fungi, and Mycotoxins: Health Effects, Assessment, Prevention and Control.
Johanning E (ed), Boyd Printing Company, Inc., New York, NY, 1999.

Fedoruk M. Gastrointestinal system. pp. 44–50. In: Encyclopedia of Toxicology, Volume 2.
Wexler P (ed), Academic Press, 1998.

Fedoruk M. Hazardous response personnel. In: Encyclopedia of Occupational Health and
Safety, 4th Edition, Vol. 3. International Labour Office, World Health Organization, Geneva
Switzerland, 95.19–95.21, 1997.

Hughson WG, Fedoruk MJ. Occupational and environmental causes of lung cancer and
esophageal cancer. pp. 66–89. In: Comprehensive Textbook of Thoracic Oncology. Green M,

Perry M, Martini N, Arriagada R (eds), Williams and Wilkins, New York, NY, 1996.

Harber P, Fedoruk M. Job demand, preplacement evaluation, and accommodation.

pp. 857867. In: Occupational and Environmental Respiratory Disease. Harber P, Schenker
M, Balmes J (eds), Mosby, 1996.

Guidotti, Fedoruk MJ. The private alternative in providing occupational health care: Options,
objectives, and object lessons. pp. 94–103. In: Occupational Health Services. In Canada
through the Year 2000 (Proc. Conference Organized by the Canadian Occupational Health

Association, Calgary, November 1986). Gibbs GW, Markham JW (eds), University Press of
Canada, North York, Ontario, 1988.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
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Medical and Scientific Presentations

Fedoruk M. The toxicology of mold—Review of the literature. Presented at UCLA/UCI
MOLD: State of the Medical and Environmental Science conference, February 27, 2008.

Fedoruk M. Health effects of bioaerosols. Presented at annual AIHce (American Industrial
Hygiene Association) Professional Development Conference, Philadelphia, PA, May 5, 2007.

Fedoruk M. Building associated health problems 2007: What are the issues? Presented at

Grand Rounds, Center for Occupational and Environmental Health, UCI, Irvine, CA, August 22,
2006.

Fedoruk M. Building-related health problems: The 2006 perspective. Presented at UCLA
Occupational-Environmental Preventive Medicine Conference Los Angeles, CA, May 30, 2006.

Fedoruk M. Exposure assessment. Presented at the California Industrial Hygiene Council, 14th

Annual Conference, Redondo Beach, CA, December 2, 2004.

Fedoruk M. Industrial toxicology. Presented at Internal Medicine Rounds, UCI Medical

Center, Orange, CA, December 2004 and Veterans Administration Hospital, Long Beach, CA,
December 2004.

Fedoruk M. National strategies for health care providers: Pesticide initiative. Presented at

American Occupational Health Conference, Kansas City, MO, May 4, 2004.

Fedoruk M. Fungal-related health issues for the integrated waste industry. Integrated Waste

Services Association (IWSA) Health and Safety Conference, Charleston, SC, April 20 2004.

Fedoruk M. Molds and mycotoxic effects. Presented at Pulmonary Medical Round, Newport

Beach CA, February 2004.

Fedoruk M. Industrial hygiene and exposure assessment issues. Presented at Internal Medicine
rounds, UCI Medical Center, Orange, CA, December 2003 and Veterans Administration

Hospital, Long Beach, CA, December 2003.

Fedoruk M. Mold remediation: medical toxicological considerations. Presented at the

American Conference of Industrial Hygienist (ACGIH) symposium entitled, “Mold
Remediation: The National Quest for Uniformity Symposium,” Orlando, FL, November, 2003.

Fedoruk M. Indoor health effects associated with residential mold exposure: Science versus

public perception. Presented at the UCI Medical Center, Department of Medicine Grand
Rounds, Orange, CA, October 29, 2002.

th
Fedoruk M. Home assessments: How are they done? Presented at the 60 Annual Meeting of
the American College of Allergy, Asthma and Immunology, San Antonio, TX, November 16,
2002.

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Fedoruk M. Fungi: Measurement and medicine. Presented at American Occupational Health
Conference, American College of Occupational and Environmental Medicine, April 2001.

Fedoruk M. Fungi and mycotoxic effects. Presented at Allergy Medical Round, UCI Medical
Center, Orange CA, March 2001.

Fedoruk M. Fungi: Exposure and health effects update. Presented at the 10th Annual
Conference of the California Industrial Hygiene Council, Redondo Beach, CA, December 4,
2000.

Fedoruk M. Industrial hygiene and exposure assessment issues for internal medicine residents.
Presented at UCI Medical Center, December 2000, and Veterans Administration Hospital, Long

Beach, CA, December 2000.

Fedoruk M. Acute exposure and health issues related to Hazmat incidents. Presented at the
ACOEM State of the Art Conference (SOTAC), Nashville, TN, October 28, 2000.

Fedoruk M. Industrial hygiene and environmental exposure assessment issues. Presented for
the ACOEM Basic Curriculum in Occupational Medicine, Segment 3 at the State of the Art

Conference (SOTAC), Nashville, TN, October 25–26, 2000.

Fedoruk M. Industrial hygiene and environmental exposure assessment issues. Presented for
the ACOEM Basic Curriculum in Occupational Medicine, Segment 3, San Diego, CA,

June 89, 2000.

Fedoruk M. Industrial toxicology. Presented to Residents in Internal Medicine at weekly

rounds at UC Irvine Medical Center and Long Beach Veterans Administration Hospital, CA,
January 1999.

Fedoruk M. Tuberculosis in workplace. Presented at UMA Pacific Section, American
Industrial Hygiene Association, San Diego, CA, January 27, 1997.

Fedoruk M. Bioaerosol update. Presented at the University of California, Irvine, Center for

Occupational and Environmental Health, January 1997.

Fedoruk M. Occupational lead toxicity: ethical aspects. Presented at the 39th Western

Occupational Health Conference, Monterey CA, April 15, 1995.

Fedoruk M. Medical surveillance for reproductive hazards. Presented at American

Occupational Health Conference, American College of Occupational and Environmental
Medicine, Chicago, IL, May 7, 1994.

Fedoruk M. Biological monitoring methods for industrial chemical exposure. Presented at

Orange County Section of the Industrial Hygiene Association Annual Conference, Norwalk CA,
October 12, 1993.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
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Fedoruk M. Sick building syndrome: An update. 36th Annual Western Occupational Health
Conference, San Diego, IL, October 25, 1992.

Fedoruk M. Environmental assessment. 58th Annual Scientific Assembly, American College
of Chest Physicians, Chicago, IL, October 25, 1992.

Fedoruk M. Hazardous waste workers. American Occupational Health Conference, American
College of Occupational and Environmental Medicine, Washington, DC, May 7, 1992.

Fedoruk M. Building-related illnesses. Presented at Occupational Medicine Rounds, University
of California, Irvine, November, 1991.

Fedoruk M. The fire department medical program. Presented at the Symposium on the
Occupational Health and Hazards of the Fire Service, International Association of Firefighters,
20th John P. Redmond Foundation Conference, Las Vegas, NV, September 20, 1991.

Fedoruk M. Environmental medicine: Consulting. Presented at the American Occupational
Health Conference at the American College of Occupational Medicine, San Francisco, CA, May
3, 1991.

Fedoruk M. Sick building syndrome: Health effects. Presented at University of California, San
Diego, California, School of Medicine, Pulmonary Rounds, California, March 17, 1991.

Fedoruk M. Sick building syndrome perceived risks and case studies. Presented at UCLA
Occupational Medicine Rounds, Los Angeles, CA, February 27, 1991.

Fedoruk M, Levine S. Hazardous waste workers. Presented at the American College of
Occupational Medicine Annual State of the Art Conference on Fitness for Work, Pittsburgh,
PA, October 8, 1990.

Fedoruk M. Occupational/environmental concerns associated with use of Ribaviron and
Pentamidine. Presented at the American Lung Association of Orange County meeting entitled
Issues In Neonatal And Pediatric Pulmonary Care, Orange, CA, May 5, 1990.

st
Fedoruk M. Man-made mineral fibers. Presented at the 21 Annual Technical Symposium,
American Industrial Hygiene Association-Southern California Section, Long Beach, CA,

November 16, 1989.

Fedoruk M. Indoor air pollution. Presented at Occupational Medicine Symposium, AMI
Tarzana Regional Medical Center, Tarzana, CA, June 6, 1989.

Fedoruk M. Occupational medicine in the hazardous waste industry: Regulatory aspects.
Presented at American Occupational Health Conference, Boston, MA, May 1989.

Fedoruk M. Toxicologic risk assessment, a mechanism for establishing environmental
standards. Presented at 32nd Annual Western Occupational Health Conference, Irvine, CA,
October 1988.
Marion Joseph Fedoruk, M.D., C.I.H., DABT
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Fedoruk M, Thorne D, and Yang M. Toxicology and health effects of asbestos fibre exposure.
Proc. Third Annual Hazardous Material Management Conference—West, Long Beach, CA,
December 1987.

Yang M, Thorne D, Fedoruk M, and Turl E. Assessment of exposure and public health risks
during the excavation of a refinery waste contaminated site. Presented at the Air Pollution
Control Association meeting, New York, NY, June 1987.

th
Fedoruk M. Asbestos—Perceived risks and interactive effects. Presented at the 6 University of
California, Irvine, Symposium on Environmental Psychology, May 14–15, 1987.

Fedoruk M. Walk-through assessment. Rohm and Haas, Corporate Occupational Health
Conference, Philadelphia, PA, April, 1987.

Fedoruk M. Medical surveillance for hazardous waste workers. Presented at Occupational
Medicine, Grand Rounds, School of Medicine, University of California, Irvine, March, 1987.

Fedoruk M. Lead and mercury—hazardous exposures. Occupational Health and Preventive
Medicine Seminar, Naval Medical Clinic, San Diego, CA, April 6, 1986.

Fedoruk M. Health hazards and toxicology. Presented at 9th Annual Pacific Southwest Safety
and Health Workshop/Seminar, San Diego, CA, April 16, 1986.

Fedoruk M. Worker “Right to Know Laws” health hazard training and industrial hygiene
practice. Presented at the Occupational Medicine and Health Symposium, American Lung
Association, San Diego, CA, March, 1986.

Fedoruk M. Heavy metal toxicology. Presented at the course: Industrial Toxicology Workers
Right to Know, University of California, Irvine, CA, August 15, 1985.

Fedoruk M. Chemical exposures in the work place. Presented at St. Joseph’s Medical Center,
Burbank, CA, August 6, 1985.

Fedoruk M. Reproductive issues in the hospital setting. Presented at the Annual Conference
Meeting of the Association of Hospital Employee Health Professional, San Diego, CA, October
17, 1984.

Fedoruk M. Asbestos diseases: An epidemic? Mercy Hospital and Medical Center, Medical
Grand Rounds, San Diego, CA, August 9, 1983.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
Page 9
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Academic Appointments

x Clinical Professor of Medicine, Department of Medicine, University of California,

Irvine, School of Medicine, 2002–current
x Associate Clinical Professor of Medicine, Department of Medicine, University of
California, Irvine, School of Medicine, 1998–2002

x Assistant Clinical Professor of Medicine, Department of Community and Environmental
Medicine, University of California, Irvine, School of Medicine, 1985–1991; Department
of Medicine 1991–1997

x Assistant Clinical Professor of Medicine, Pulmonary Division, Department of Medicine,
University of California, San Diego, School of Medicine, July 1991January 2000
x Lecturer, Graduate School of Public Health, Division of Public Health, Division of

Occupational and Environmental Health, San Diego State University, 1983–1988
x Clinical Instructor of Medicine, Department of Medicine, University of California, San
Diego, School of Medicine, 1985–1986

Teaching Experience

Graduate of Public Health, Division of Occupational and Environmental Health, San Diego

State University. Primary instructor for two courses:

x “Occupational Medicine”—Core 3-unit course for MPH students specializing in

occupational health, 1984–1987
x “Occupational Health Management”—3-unit course for MPH students specializing in
occupational health, 1985

University of Southern California, Institute of Safety Systems and Management, Los Angeles,
California:

x Instructor for several USC-sponsored extension programs and lecturer on several
subjects including industrial hygiene, toxicology, occupational disease and carcinogens.
x Developed and presented a one and one half day course regarding the development and

management of medical surveillance programs. This course was given in September
1985, and has been presented biannually through 1990.

Department of Health Services Division of Toxics, State of California, 1987–1988:

x Instructed portions of a course entitled “Introduction to Toxicology” for State of
California, D.H.S. employees engaged in Hazardous Waste Operations. (Los Angeles,

Berkeley) Sacramento.

University of California, Irvine. Instructor for courses entitled:

x “Air Pollutants and Toxic Chemicals,” Social Ecology; 498.3; 1988–1991
x “Managing Indoor Air Quality Episodes,” Social Ecology; February 12, 1991

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University of California, Berkeley/Northern Occupational Health Center:

x Instructor for a course entitled “Pesticide Contaminated Hazardous Waste Sites” and
taught section on pesticide toxicology and medical surveillance, 1989

Committees

American Lung Association, Committee on Environmental and Occupational Health, San
Diego, California, 1983–1987.

County of San Diego, Subcommittee Advisory Panel, Hazardous Materials Management Team.
Designated representative of County of San Diego Medical Society. The subcommittee advises

County Government about the applicability, enforcement, and technical aspects of County
Ordinances dealing with hazardous materials management, 1984–1987.

Agricultural/Urban Pesticide Issues Task Force. Task force member of a committee appointed
by the County Board of Supervisors to review pesticide usage and determine how it impacts on
both urban and agricultural concerns, January 1986–November 1986.

NIOSH/Northern and Southern California Educational Resource Centers. Served on the
Advisory Committee on pesticide related hazardous waste training for health and safety
professionals, 1989–1990.

National Fire Protection Association. Subcommittee member on the 1001 and 1500 committees
concerning medical and physical fitness criteria for structural firefighters, 1989–present.

American College of Occupational and Environmental Medicine. Planning committee member
for 1990 State of the Art Conference on Fitness for Work. Pittsburgh, Pennsylvania,
October 812, 1990.

American College of Occupational and Environmental Medicine. Member of Occupational and
Clinical Toxicology committee, 1991–2000, appointed chairman, May 1992.

American College of Occupational and Environmental Medicine. Member of Committee on
Scientific Affairs, May, 1992–2000.

American College of Occupational and Environmental Medicine. Member of Committee on
Medical Surveillance May, 1993–2000.

Toxicology Excellence for Risk Assessments, Cincinnati, Ohio. Member of Peer Review
Committee sponsored by EPA, Health Canada and Metal Finishing Association of Southern
California, concerning a risk assessment on the carcinogenicity and toxicity of soluble nickel
salts.

U.S. Environmental Protection Agency. Member of expert panel concerning the development
of a strategy for educating the nation’s health care providers on pesticide-related health matters.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
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Proceedings published in Pesticides and National Strategy for Health Care Providers, July 1998
(EPA 735-R-98-001).

Special Projects

American College of Occupational Medicine, Chicago, IL. Developed questions for the

national Medical Self-Assessment Program 2 for physicians to test their knowledge base in
occupational medicine.

American Lung Association. Prepared “Solvents in the Workplace” fact sheet for ALA
publication Lung Hazards at Work, a program developed to inform employers and employees
on the control of harmful occupational exposures that can lead to lung disease.

City of San Diego Fire Department. Developed and presented a risk communication program
concerning the fetal health risks from physical and chemical exposures to female firefighters.

The program covered the areas of health effects of heat stress, carbon monoxide and other
agents on the fetus. The program was presented to all female firefighters with the City of San
Diego in 1988 and 1990.

Marion Joseph Fedoruk, M.D., C.I.H., DABT
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Charles A. Menzie, Ph.D.

Principal Scientist and Practice Director

Professional Profile

Dr. Charles A. Menzie is a Principal Scientist and Director of Exponent’s EcoSciences practice.
His primary area of expertise is the environmental fate and effects of physical, biological, and
chemical stressors on terrestrial and aquatic systems. Over the past two decades most of this
work has been focused on chemicals. Dr. Menzie has worked at more than 100 sites and has

been involved in approximately a dozen NRDA-related cases. He is recognized as one of the
leaders in the field of risk assessment and was awarded the Risk Practitioner Award by the
Society for Risk Analysis. He has served on the Council of SRA and the Board of SETAC, the
two major professional organizations in this field. Dr. Menzie has led numerous peer reviews

for industry and for government. He has taken the lead in developing guidance documents for
industry and government and has focused on methods that are workable and acceptable to a
broad range of parties. He was one of the committee members to draft the ASTM Standard for
risk-based corrective action (RBCA) for chemical release sites and extended that standard to

ecological considerations. In addition to his work on chemical risk-related matters, Dr. Menzie
has developed and applied methods for identifying third parties who have contributed to
contamination in aquatic and terrestrial environments. These projects have involved meshing
historical information with transport and fate analyses, risk considerations (remediation drivers),

and forensic analysis. Most of this work has been carried out for a select group of industrial
clients. Dr. Menzie’s expertise in chemical transport and fate includes organochlorine
compounds (e.g., PCBs, dioxins, many pesticides), PAHs, benzene and other light aromatic

hydrocarbons, chlorinated volatile compounds (e.g., TCE and PCE), phthalate esters, petroleum
hydrocarbons, metals (e.g., arsenic, cadmium, lead, vanadium, nickel, and zinc), and cyanide
compounds.

In addition to Dr. Menzie’s work on chemical-related matters, he has been involved in
evaluating the risks associated with habitat modifications and the introduction of species.
Prominent among these efforts was work related to the introduction of shrimp viruses to U.S.
coastal systems. Dr. Menzie has developed a number of software tools to analyze the effects of

chemical and other stressors at the level of landscapes. Much of this work is being used to
predict future effects and to sort among alternatives.

Academic Credentials and Professional Honors

Ph.D., Biology, City University of New York, 1978
M.A., Biology, City College of New York, 1974
B.S., Biology, Manhattan College, 1971

01/09 ANNEX 158

Licenses and Certifications

OSHA Certified Eight-Hour HAZWOPER Annual Refresher Training in Hazardous Waste
Operations and Emergency Response, updated annually; OSHA Certified 40-Hours of Training
in Hazardous Waste Operations and Emergency Response

Patents

Patent Application: SediMite: A Low-Impact Technology for Remediating Contaminated

Sediments, patent pending.

Publications

Menzie CA, Booth P, Law SA, von Stackelberg K. Use of decision support systems to address
contaminated coastal sediments: Experience in the United States. In: Decision Support
Systems for Risk-Based Management of Contaminated Sites. Marcomini A, Suter II GW, Critto

A (eds), Springer Verlag, 439 p, 2009.

Menzie CA, Southworth B, Stephenson G, Feisthauer N. The importance of understanding the

chemical form of a metal in the environment: The case of barium sulfate (barite). Hum Ecol
Risk Asses 2008; 14:5:974–991.

Menzie CA, Coleman AJ. Debate & commentary. Polycyclic aromatic hydrocarbons in

sediments: An overview of risk-related issues. Hum Ecol Risk Assess 2007; 13(2):269–275.

Menzie CA, MacDonell MM, Mumtaz M. A phased approach for assessing combined effects

from multiple stressors. Environ Health Perspect 2007; 115(5) 807–816.

Johnson, MS, Wickwire WT, Quinn MJ, Ziolkowski DJ, Burmistrov D, Menzie CA, Geraghty

C, Minnich M, Parsons PJ. Are songbirds at risk from lead at small arms ranges? An
application of the Spatially Explicit Exposure Model (SEEM). Environ Toxicol Chem 2007;
26(10):22152225.

Magar VS, Wenning RJ, Menzie C, Apitz SE. Parsing ecological impacts in watersheds. J
Environ Eng 2006; 132(1):1–3.

Wickwire WT, Menzie CA, Burmistrov D, Hope BK. Incorporating spatial data into ecological
risk assessments: The Spatially Explicit Exposure Module (SEEM) for ARAMS. In:
Landscape Ecology and Wildlife Habitat Evaluation: Critical Information for Ecological Risk

Assessment, Land-Use Management Activities, and Biodiversity Enhancement Practices.
ASTM STP 1458. Kapustka LA, Galbraith H, Luxon M, Biddinger GR (eds). ASTM
International, West Conshohocken, PA, 2004.

Menzie CA, Lacey R. Ecological risk assessment in a new millennium: Where are we going?
Risk Policy Report 2002; 9(3):36–38.

Charles A. Menzie, Ph.D.
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von Stackelberg K, Menzie C. A cautionary note on the use of species presence and absence
data in deriving sediment quality criteria. Environ Toxicol Chem 2002; 21(2):466–472.

Menzie CA, Hoeppner SS, Cura JJ, Freshman JS, LaFrey EN. Urban and suburban storm water
runoff as a source of polycyclic aromatic hydrocarbons (PAHs) to Massachusetts estuarine and

coastal environments. Estuaries 2002; 25(2):165–176.

Shatkin JA, Wagle M, Kent S, Menzie CA. Development of a biokinetic model to evaluate
dermal absorption of polycyclic aromatic hydrocarbons from soil. Hum Ecol Risk Asses 2002;

8(4):713–734.

Menzie CA. Hormesis in ecological risk assessment: A useful concept, a confusing term,

and/or a distraction? Belle Newsletter 2001; 10(1):17–20.

Menzie CA, Wickwire WT. Defining populations: A key step in identifying spatial and
temporal scales. Toxicol Indust Health 2001; 17:223–229.

Menzie CA, Burke AM, Grasso D, Harnois M, Magee B, McDonald D, Montgomery C, Nichols
A, Pignatello J, Price B, Price R, Rose J, Shatkin J, Smets B, Smith J, and Svirsky S. An

approach for incorporating information on chemical availability in soils into risk assessment and
risk-based decision making. Hum Ecol Risk Assess 2000; 6(3):479–510.

Menzie CA. Applying risk-based solutions—the importance of communication. Environ Eng

1999; 35(4):20–22.

Menzie CA. Risk communication and careful listening—resolving alternative world views.

Hum Ecol Risk Assess 1998; 4(3):619–622.

Charles JC, Menzie CA. Identifying Southeast Asian immigrant populations in Massachusetts

at risk from eating contaminated shellfish. J Environ Manage 1998; 52:161–171.

Menzie CA. Implementing risk management at manufactured gas plant sites. Soil Groundwat
Cleanup 1997; August/September: 12–18.

Menzie CA, Freshman JS. An assessment of the risk assessment paradigm for ecological risk
assessment. Hum Ecol Risk Assess 1997; 3(5):853–892.

Freshman JS, Menzie CA. Two wildlife exposure models to assess impacts at the individual
and population levels and the efficacy of remedial actions. Hum Ecol Risk Assess 1996;

2(3):481496.

Menzie CA, Henning MH, Cura J, Finkelstein K, Gentile J, Maughan J, Mitchell D, Petron S,
Potocki B, Svirsky S, Tyler P. Special report of the Massachusetts weight-of-evidence

workgroup: A weight-of-evidence approach for evaluating ecological risks. Hum Ecol Risk
Assess 1996; 2(2):277–304.

Charles A. Menzie, Ph.D.
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Menzie CA. The question is essential for ecological risk assessment. Hum Ecol Risk Assess
1995; 1(3):159162.

Menzie CA, Potocki B, Santodonato J. Exposure to carcinogenic PAHs in the environment.
Environ Sci Technol 1992; 26(7):1278–1284.

Menzie CA, Burmaster DE, Freshman JS, Callahan CA. Assessment of methods for estimating
ecological risk in the terrestrial component: A case study at the Baird & McGuire Superfund
Site in Holbrook, Massachusetts. Environ Toxicol Chem 1992; 11:245–260.

Callahan CA, Menzie CA, Burmaster DE, Wilborn DC, Ernst T. On-site methods for assessing
chemical impact on the soil environment using earthworms: A case study at the Baird &

McGuire Superfund Site, Holbrook, MA. Environ Toxicol Chem 1991; 10(6)817–826.

Burmaster DE, Menzie CA, Freshman JS, Burris JA, Maxwell NI, Drew SR. Assessment of

methods for estimating aquatic hazards at Superfund-type sites: A cautionary tale. Environ
Toxicol Chem 1991; 10(6)827–842.

Menzie CA. Diminishment of recruitment: A hypothesis concerning impacts on marine benthic

communities. Mar Pollut Bull 1984.15:127-129.

Menzie CA. Environmental concerns related to offshore oil and gas activities: Muddy issues.

Oceanus 1983; 26:32–38.

Menzie CA. Contamination control can be cost effective. Industry Magazine 1982; August:

1922.

Menzie CA. The environmental implications of offshore oil and gas activities: An overview of
the effects of routine discharges based on the American experience. Environ Sci Technol 1982;

16(8):454A472A.

Maurer D, Leathem W, Menzie CA. Macrobenthic invertebrates from the Mid-Atlantic

continental shelf. Int Rev der Ges Hydrobiol 1982; 67(4):491-515.

Menzie CA, Cura JJ, Skinner WF. Thermal impact evaluation for Brunner Island Steam

Electric Station: Toward a more realistic assessment. Environ Monit Assess 1982; 2:301-308.

Menzie CA. Production ecology of Cricotopus sylvestris Fabricius (Diptera: Chironomidae) in
a shallow estuarine area. Limnol Oceanog 1981; 26(3):467-481.

Mauer D, Leathem W, Menzie CA. The impact of drilling fluids and well cuttings on
polychaete feeding guilds from the U.S. northeastern continental shelf. Mar Pollut Bull 1981;

12(10):234-347.

Menzie C, Mariani G, Ryther, Jr. J. Seafloor mapping system applied to biological,
environmental surveys. Sea Technol 1981; 22(2):15-16.

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Menzie CA. The potential significance of insects in the removal of contaminants from aquatic

systems. Water Air Soil Pollut 1980; 13:473-479.

Menzie CA. A note on the Hynes method of estimating secondary production. Limnol

Oceanogr 1980; 25(4):770–773.

Menzie CA. The chironomid (Insecta: Diptera) and other fauna of a Myriophyllum spicatum L.
plant bed in the lower Hudson River. Estuaries 1980; 3(1):38-54.

Menzie CA. An approach to estimating probabilities of transportation related spills of
hazardous materials. Environ Sci Technol 1979; 13(2):224-228.

Menzie CA. Growth of the aquatic plant Myriophyllum spicatum in a littoral area of the Hudson
River Estuary. Aquat Bot 1979; 6:365-375.

Mulligan HF, Menzie CA. How to prepare environmental reports for drilling on the OCS (outer
continental shelf). Oil Gas J 1978; 8687.

Books and Book Chapters

Lanno R, Menzie CA. Risk assessment of cyanide in water and soil. Chapter 17. In: Cyanide

in Water and Soil: Chemistry, Risk, and Management. Dzombak DA, Ghosh RS, Wong-Chong
GM (eds), CRC Press/Lewis Publishers, Boca Raton, FL, 2005.

Menzie CA, Efroymson RA, Ells SJ, Henningsen GM, Hope BK. Risk assessment and risk

management. Chapter 2. In: Pellston Workshop on Contaminated Soils: From Soil-Chemical
Interactions to Ecosystems Management. Lanno RP (ed), SETAC Publications. Pensacola, FL,
2003.

Menzie CA. The evolution of ecological risk assessment during the 1990s: Challenges and
opportunities. Chapter 16. pp. 281–299. In: Environmental Analysis of Contaminated Sites.
Sunahara GI, Renoux AY, Thellen C, Gaudet C, Pilon A (eds), John Wiley & Sons, Ltd., 2002.

Gaudet CL, Menzie CA, Ouellet S. Risk-based assessment of soil contamination: Generic
versus site-specific approaches. Chapter 12. pp. 203–219. In: Environmental Analysis of

Contaminated Sites. Sunahara GI, Renoux AY, Thellen C, Gaudet C, Pilon A (eds), John Wiley
& Sons Ltd., 2002.

Cura, JJ, Kane Driscoll SB, Lacey R, McArdle M, Menzie CA. Assessing ecological risks of
PAH-contaminated sediments. In: Sediments Guidance Compendium. Electric Power
Research Institute (EPRI), Palo Alto, CA, 2001.

Menzie CA, Heiger-Bernays WJ, Montgomery CR, Linz DG, Nakles DV. Development of an
ecological risk assessment framework based on contaminant availability. In: Ecotox—

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Environmental Contaminants through the Macroscope. Wuerz Publishing Ltd., Winnipeg, MB,
Canada, 1996.

Menzie CA. Perspectives on sediment risk analysis for hazardous waste sites. Proceedings,
22nd Pellston Conference Workshop, Sediment Risk Assessment. SETAC Special Publication,
Pacific Grove, 1996, April 23–28, 1995.

Menzie CA. Work group summary report for site clean-up decisions. Chapter 6. Proceedings,
22nd Pellston Conference Workshop, Sediment Risk Assessment, SETAC Special Publication,
Pacific Grove, 1995, April 23–28, 1995.

Cura JJ, Mariani G, Ketchum C, Gillmor R, Menzie C, Curtis W, Tuholke B. Site-selection
criteria for deep ocean disposal of low-level radioactive wastes. Volume 3, Marine Waste

Management: Science and Policy. pp. 177185. In: Oceanic Processes in Marine Pollution.
Champ M, Park K (eds), Kreiger Publishing Co., Melbourne, FL, 1989.

Menzie CA, Cura J, Gillmor R, Magnell B, Mariani G, Bartholomew T, Gardner W, Smith W.

The optimum mix of pollution-monitoring platforms: Deepwater Dumpsite-106 Case Study.
Volume 3 - Marine Waste Management: Science and Policy. pp. 260–276. In: Oceanic
Processes in Marine Pollution. Champ M, Park K (eds), Kreiger Publishing Co., Melbourne,
FL, 1989.

Nocito JA, Walker HA, Paul JF, Menzie CA. Application of a risk assessment framework for
marine disposal of sewage sludge at mid-shelf and off-shelf sites. Proceedings, 11th ASTM

Symposium by American Society for Testing and Materials, Philadelphia, PA, 1986

Gillmor RB, Menzie CA, Mariani GM, Levin D, Ayers RC, Sauer TC. . Effects of exploratory
drilling discharges on the benthos. Volume 4, Energy Wastes in the Ocean. pp. 244–257. In:

Wastes in the Ocean. Duedall IW, Kester DR, Park PK (eds), Wiley Interscience Publications,
John Wiley & Sons, New York, NY, 1985.

Robson DS, Menzie CA, Mulligan HF. An environmental monitoring study to assess the impact
of drilling discharges in the Mid-Atlantic. II. An experimental design and statistical methods to
evaluate impacts on the benthic environment. In: Research of Environmental Fate and Effects
of Drilling Fluids and Cuttings, 1980.

Menzie CA, Maurer D, Leathem W. An environmental monitoring study to assess the impact of
drilling discharges in the Mid-Atlantic. IV. The effects of drilling discharges on the benthic
community. In: Research of Environmental Fate and Effects of Drilling Fluids and Cuttings,

1980.

Proceedings, Conferences, and Symposia

Wickwire WT, Menzie CA, Burmistrov D. Enhancing the realism of wildlife exposure
modeling: An introduction and demonstration of the Spatially Explicit Exposure Model
(SEEM). In: An Introduction to the Terrestrial Wildlife Exposure Model (TWEM) and the

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Spatially Explicit Exposure Model (SEEM). Johnson MJ, Sample BE, Wickwire WT, and
Kapustka LA (eds.). SETAC 2004 Short Course Instructor. Society of Environmental
Toxicology and Chemistry (SETAC) 4th World Congress and 25th Annual Meeting, Portland,

OR, November 14–18, 2004.

Wickwire WT, Menzie CA, Burmistrov D, Johnson MS. Applying a spatially explicit wildlife

exposure model to improve remedial efficiency: The SEEM case study (Abstract/Poster
Presentation). Annual International Conference on Soils, Sediments and Water, University of
Massachusetts, Amherst, MA, October 18–21, 2004.

Kane Driscoll SB, McArdle ME, Menzie CA, Coleman A. Application of sediment quality
guidelines of PAHs to manufactured gas plant sites. Presented at the 23rd Annual Meeting of
SETAC North America, Salt Lake City, UT, November 16–20, 2002.

Menzie CA, Cura JJ, Kane-Driscoll S, Lacey R, McArdle M. Assessing ecological risks of
PAH-contaminated sediments. Proceedings, International Conference on Remediation of
Contaminated Sediments, Venice, Italy, October 10–12, 2001. Battelle Press, Columbus, OH.

Cura JJ, Menzie C. Methodologies for ecological risk assessment: the overall process and
recent advances. Conference Workshop #12 - Ecological Risk Assessment: Why and How—
An Important Tool in Environmental Decision Making. Presented at the Water Environment

Federation 69th Annual Conference & Exposition, Dallas, TX, October 5–9, 1996.

Menzie CA. Problems in ecological assessment related to contaminated site management.

pp. 26–27. Proceedings, NRC-CNRC Workshop, Toxicity Testing Applied to Soil
Ecotoxicology. NRC’s Biotechnology Research Institute in collaboration with Environment
Canada and the Quebec Ministry of Environment and Wildlife, Montreal, Quebec, November
28–29, 1995.

von Stackelberg K, Menzie CA, Cura JJ. Risk assessment: Helping to focus risk management
objectives for MGP sites. Land Contam Reclam (Special issue) 3(4):24-29. Presented at the
International Symposium and Trade Fair on the Clean-up of Manufactured Gas Plants, Prague,

Czech Republic, September 19-21, 1995.

Menzie CA, Cura JJ. Environmental evaluations at hazardous waste sites. pp. 77–84.

Proceedings, HMC-Northeast ‘91 Conference, Hazardous Materials Control Research Institute,
Boston, MA, July 10–12, 1991.

Menzie CA, Cura J. Loadings of pollutants in Massachusetts Bay. Presented at U.S.

Environmental Protection Agency Conference on Estuaries, Sarasota, FL, February 24–26,
1991.

Burmaster DE, Thompson KM, Menzie CA, Crouch E, McKone T. Monte Carlo techniques for
quantitative uncertainty analysis in public health risk assessment. pp. 21521. Proceedings,
1990 Hazardous Materials Control Research Institute Conference, New Orleans, LA, 1990.

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Menzie CA. Application of Connecticut’s aquatic toxicity program. Panel discussion and
presentation to the 2nd Annual Workshop of the Connecticut Forum of Regulated

Environmental Professionals, New Haven, CT, June 2, 1988.

Menzie CA. The use—and possible misuse—of risk assessment as part of overall site

management. Presented at the 2nd Hazardous Waste Superfund Conference in San Francisco
and Washington, DC, 1988.

Menzie CA, Burmaster DE. Overview of soil clean-up levels and risk based decision making.

Presented at the HazMat ‘88 Conference, Atlantic City, NJ, June 14–16, 1988.

Menzie CA, Burmaster DE. Evaluation of environmental risk assessment methods. Presented

at the 9th Annual Meeting of the Society of Environmental Toxicology and Chemistry,
Arlington, VA, November 13–17, 1988.

Burmaster DE, Murphy B, Gushue J, Menzie CA. A risk assessment for the Baird & McGuire

Superfund Site. Presented at the Hazardous Materials International Conference, Washington,
DC, 1987.

Menzie CA, Cura JJ, Gillmor R, Mariani G, Wilson S. Research needs related to ocean
disposal. Presented at the Ocean Waste Management Conference at the University of Rhode
Island, Kingston, RI, May 1983.

Menzie CA, Ryther, Jr. J, Boyer LF, Germano JD, Rhoads DC. Remote methods of mapping
seafloor topography, sediment type, bedforms, and benthic biology. pp. 1046-1051. In:
Oceans ‘82 Conference Record, IEEE Publication Number 82CH1827-5, Piscataway, NJ, IEEE

Service Center, 1982.

Gillmor, RB, Menzie CA, Ryther, Jr. J. Side-scan sonar and T.V. observations of the benthic

environment and megabenthos in the vicinity of an OCS exploratory well in the Middle Atlantic
Bight. In: Oceans ‘81 Conference Record. IEEE Publication No. 81CH1685-7, Piscataway,
NJ, IEEE Service Center, 1981.

Menzie CA, Ryther, Jr. J. Diego Garcia (Indian Ocean): An Atoll estuary. Presented at the
New England Estuarine Research Society at the University of Rhode Island, Spring Session,
Kingston, RI, 1980.

Menzie CA, Frye D, Hazelwood RN. OTEC-1 environmental monitoring program. In: Proc.
7th Ocean Energy Conference, Washington, DC, June 1980.

Mulligan HF, Menzie CA. Phytoplankton as tracers of water masses on and around Georges
Bank. Presented at the Second Informal Workshop on the Gulf of Maine and Scotian Shelf,
May, Dalhousie, Nova Scotia, 1979.

Menzie CA, et al. The environmental impact of the Clean Water Act on the Hudson River
Estuary. Presented at the 4th Hudson River Environmental Symposium, 1976.

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Menzie CA, Hyman R, Woodward B. Investigations of the chironomid fauna of Haverstraw

Bay. Presented at the 4th Hudson River Environmental Symposium, 1976.

Menzie CA, Logan D, Matousek J. 1976. Benthic investigations in the Hudson River Estuary.

1972-1974. Presented at the 24th Annual Meeting of the North American Benthological
Society, Madison, WI, 1976.
Prior Experience

Principal and President, Menzie-Cura & Associates, Inc., 1983–2006
Manager of Environmental Services Department, EG&G Environmental Consultants, 1976-1983
Lecturer, Boston University and University of Lowell, Developed and presented graduate-level

courses on Risk Assessment, Marine Pollution, and Environmental Science, 1978-1993

Project Experience

Manufacturing Industry (Metals and Organic Chemicals) with an Emphasis on Sediments

Worked on ecological and human health issues associated with contaminated sediments since

the mid 1970s. Worked on projects involving the following classes of chemicals:
organometallic compounds (e.g., methylmercury), inorganic metals such as chromium, lead,
copper, cadmium, nickel, vanadium, and barium, chlorinated compounds such as PCBs, dioxins,
and pesticides, petroleum related hydrocarbons, and chemicals arising from combustion

(e.g., PAHs). This work has involved assessing transport and fate of these chemicals, evaluating
risks, and providing guidance for remediation. Developed a low-impact remedial technology
referred to as SediMiteTM .

Contribution Cases

Participated in several large contribution cases involving regional contamination from multiple
sources. Most of this work has focused on PCBs, pesticides, and metals. Developed a line-of-
evidence methodology that has been successfully applied to these cases. Risk assessment
expertise has been an important element of establishing the connections between sources and

environmental conditions. This framework also makes it possible to establish the implications
and degree of risk associated with the particular sources.

Manufactured Gas Plants (MGP) and Other Utility Work

Twenty years of experience evaluating the human health and ecological risks associated with
MGP sites. Primary author of the Gas Research Institute (GRI) guidance on risk assessment for

MGP sites and has conducted assessments at more than forty sites. Currently a principal
investigator for Electric Power Research Institute (EPRI)-funded research on the toxicity of
soils and sediments at MGP sites. Principal investigator for the environmentally acceptable

endpoints (EAE) program, which focused on the bioavailability of PAHs in surface soils. This
program was subsequently extended to evaluations of PAHs in sediments. Co-author of the

Charles A. Menzie, Ph.D.
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industry white paper on naphthalene toxicity and implications for risk assessment and risk
management.

Principal investigator for the Gas Research Institute, Gas Technology Institute, and currently
serves as principal investigator for EPRI on effects of hydrocarbons associated with MGP

operations. Authored human health and ecological risk assessment guidance developed for
MGP sites.

Published several papers related to the assessment of risks at MGP sites; author of the critical

review on sources of exposure to carcinogenic PAHs. This paper was prepared to help provide
a perspective on PAHs in soils at MGP and other sites. Published work on exposures to
cyanides, including the complex cyanides that can be present at some MGP sites.

Guided evaluations of background in a wide variety of cases. These evaluations have involved
surface soils in urban and rural environments, and sediments in various water bodies.

Currently involved in permitting for coal-fired and nuclear power plants. For the latter, serves
as an expert on chemical releases from such facilities. Also worked on approximately twenty
projects involving entrainment/impingement and thermal discharges.

Led human health and ecological assessments related to the disposal of coal and oil ash at
facilities.

Oil and Gas Industry

Has worked on upstream and downstream components of the oil and gas industry since the

1970s. Author of a key review paper in Environmental Science and Technology on the
environmental implications of oil and gas exploration, development, and production. This paper
addressed produced waters, drilling fluids, and other releases. Served as Principal Investigator

for multi-industry study of the environmental risks associated with oil and gas exploration.
Author of numerous reports related to potential environmental risks associated with onshore,
coastal, and offshore oil and gas exploration and development. This includes an API report and
associated peer-reviewed paper on the potential risks associated with barite.

Wrote the ecological risk assessment guidance related to petroleum releases for the American
Petroleum Institute. Member of the ASTM RBCA work group. Served as the principal risk

assessor for assessments at refinery sites: Bayway, New Jersey, Destrehan, Louisiana, Wood
River, Illinois, Texas City, Texas, and Sugar Creek, Missouri.

Principal investigator for the Petroleum Environmental Research Form program related to the

evaluation of ecological and human health risks associated with petroleum-contaminated soils.
He has served as a participant within the Total Petroleum Hydrocarbon Criteria Workgroup, an
industry- and government-sponsored effort to develop a methodology for evaluating complex

mixtures of hydrocarbons.

Charles A. Menzie, Ph.D.
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Impacts and Natural Resource Damages to Aquatic Ecological Resources

More than thirty years of experience working on aquatic and marine environments. Natural
resource work began in New York; documented the distribution of habitats in the lower Hudson
River. Worked extensively on lakes in the northeast United States including the Finger Lakes,

Lake Ontario, and Lake Erie. Published on the biological communities inhabiting submerged
aquatic vegetation and benthic environments. Also involved in more than 100 reports that deal
with various fish populations and their response to chemical stressors and habitat modification.
These projects have included the development of multi-pathway food webs and models.

Developed the conceptual approach for the Spatially-Explicit Exposure Model, a system that
uses information on the spatial distribution of habitats to evaluate the distribution of species and

to account for exposures that occur at the population level. Served as topic chair for the SETAC
Pellston Workshop on assessing risks to populations.

Invited to prepare an issue paper associated with evaluating the combined effects of multiple

stressors. The approach includes a habitat-specific methodology that can be employed in either
aquatic or terrestrial environments.

Impacts and Risk Evaluations for Desert and Tropical Environments

Principal investigator evaluating impacts of development on Diego Garcia (Indian Ocean). This
is a desert island on which the U.S. Navy established a base to support military operations at

countries bordering the Indian Ocean. The work involved an extended stay on the island with
investigations of physical and chemical impacts on upland and coastal environments.

Evaluated the potential effects of aerial spraying of herbicides on environmental conditions in
South America.

Evaluated the environmental impacts of pulp mill discharges on ecological conditions in a South
American River.

Chaired the external peer review of radionuclide impacts associated with the Nevada Test Site,

where nuclear weapons had been tested. Associated with this testing were a range of potential
human health and ecological risks for this desert environment. Led a group of scientists who
evaluated the studies performed by the Department of Energy.

Field operations manager and principal investigator for the Hawaiian Ocean Thermal Energy
Conversion (OTEC) Program. Responsible for overseeing studies to evaluate the impacts of
OTEC on Hawaiian coastal environments. The work involved an extended field program in

coastal Hawaii. Also served as field operations manager and principal investigator for the
evaluating of dredging and dredge material disposal for the Naval Roads Navy base in Puerto
Rico.

Charles A. Menzie, Ph.D.
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Current Academic Appointments

x Adjunct Professor, University of Maryland at Baltimore County

Editorships and Editorial Review Boards

x Associate Editor, Human and Ecological Risk Assessment, 2003–present

x Editorial Board, Human and Ecological Risk Assessment, 1995–2002

Professional Affiliations

x Water Environment Federation
x Society for Risk Analysis, (Past President of New England Chapter)

x Society of Exposure Analysis
x Society of Environmental Toxicology and Chemistry, (Board Member)
x New England Estuarine Research Society

x Estuarine Research Federation
x Boston Bar Association, (Environmental)
x Association for the Environmental Health of Soils

x ASTM

Charles A. Menzie, Ph.D.
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Katherine Palmquist, Ph.D.
Senior Scientist

Professional Profile

Dr. Katherine Palmquist is a Senior Scientist in Exponent’s EcoSciences practice. She has a

strong interdisciplinary background in insect biology/physiology, toxicology, Integrated Pest
Management, and communications. Dr. Palmquist has experience in aquatic entomology and
aquatic toxicology concerning the sublethal effects of insecticide exposure to aquatic
invertebrates, specifically aquatic insect life history variables in relation to insects’ sensitivity to

synthetic pyrethroid insecticides. Additionally, she has experience with terrestrial and
agroecosystem insect ecology and has been involved with the Integrated Pest Management
programs in both Oregon and Washington states.

Dr. Palmquist has four years experience in designing and implementing novel laboratory studies
utilizing field-collected stream invertebrates. She has developed and published methodology
concerning the laboratory maintenance and rearing of several stream insect species.
Additionally, she has experience in performing lotic and lentic benthic surveys, as well as

terrestrial insect field sampling.

Academic Credentials and Professional Honors

Ph.D., Toxicology, Oregon State University, 2007
B.S., Entomology, Washington State University, 2003
B.A., Communications (print journalism), Washington State University, 2003

Recipient of the Best Doctoral Student Presentation—Pacific Northwest Branch Society of
Environmental and Molecular Toxicology, Port Townsend, WA, 2007

National Institute of Environmental Health Sciences Training Grant Recipient— Oregon State

University, 2003–2007

Outstanding Senior—Washington State University, Department of Entomology, 2003

04/08 ANNEX 158

Publications

Palmquist KR, Jenkins JJ, Jepson PC. Effects of dietary esfenvalerate exposure on three aquatic
insects species representing different functional feeding groups. Environ Toxicol Chem 2008;

27(8): 8–14.

Palmquist KR, Jenkins JJ, Jepson PC. Impact of aquatic insects life stage and emergence

strategy on sensitivity to esfenvalerate exposure. Environ Toxicol Chem 2008; 27(8):1–7.

Palmquist KR, Jenkins JJ, Jepson PC. Clutch morphology and timing of exposure impact the

susceptibility of aquatic insects eggs to esfenvalerate. Environ Toxicol Chem 2008; 27(8):52–
59.

Johnson KR, Jepson PC, and Jenkins JJ. Esfenvalerate-induced case-abandonment adversely
impacts Brachycentrus americanus behavior and survival. Environ Toxicol Chem 2008; 27
(2):397–403.

Johnson JD, Johnson KR. Hybrid poplar genotype affects attack incidence by the Poplar-and-
Willow Borer (Cyptorhynchus lapathi). West J Appl For 2003; 18: 276–280.

Presentations

Palmquist KR, Jenkins JJ, Jepson PC. Impact of aquatic insects life stage and emergence

strategy on sensitivity to esfenvalerate exposure. Presented at the Pacific Branch Society of
Environmental Chemistry and Toxicology Meeting and at the North American Benthological
Society Meeting, 2008.

Johnson KR, Jenkins JJ, Jepson PC. Clutch morphology and the timing of exposure impact the
susceptibility of aquatic insect eggs to esfenvalerate. Presented at the Society of Environmental
th
Chemistry and Toxicology 28 Annual Meeting, 2007.

Johnson KR, Jenkins JJ, Jepson PC. Use of multiple life stages in assessing Cinygmula sp.

mayfly nymph sensitivity to esfenvalerate. Presented at the Pacific Northwest Branch Society
of Environmental Chemistry and Toxicology Meeting, Port Townsend, WA and presented at the
Pacific Branch Entomological Society of America 91 Annual Meeting, Portland, OR, 2007.

Johnson KR. Pesticide sub-lethal effects in non-target aquatic organisms. Presented at
Washington State University Pesticide Re-certification short courses, Lacey & Vancouver, WA,

2007.

Johnson KR, Jenkins JJ, P.C. Jepson. Esfenvalerate and chlorpyrifos differentially affect native
nd
Pacific Northwest aquatic insects. Presented at the American Chemical Society 232 Annual
Meeting, San Francisco, CA, 2006.

Katherine Palmquist, Ph.D.
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04/08ANNEX 158

Johnson KR, Jenkins JJ, Jepson PC. Life stage influences Pacific Northwest aquatic insect
th
susceptibility to esfenvalerate. Presented at the North American Benthological Society 54
Annual Meeting, Anchorage, AK, 2006.

Johnson KR, Jenkins JJ, Jepson PC. Esfenvalerate induces case-leaving in the Pacific

Northwest caddisfly Brachycentrus americanus. Presented at the Society of Environmental
Toxicology and Chemistry 26 thAnnual Meeting, Baltimore, MD, 2005.

Project Experience

Designed and coordinated laboratory experiments at Oregon State University to determine the

impact of aquatic insect life history strategies and exposed life stage on pyrethroid insecticide
sensitivity. Potentially sensitive life stages, morphologies and behaviors were explored during
the course of these studies:

Examined the influence of egg clutch morphology on esfenvalerate susceptibility in
terms of hatchability, post-hatch neonate survivorship, and growth for three species of
aquatic insect (Baetis sp mayfly, Brachycentrus americanus caddisfly, Hesperoperla

pacifica stonefly)

Defined Brachycentrus americanus caddisfly larval case-abandonment as a sub-lethal

effect of esfenvalerate exposure, and determined impact on survivorship

Determined toxic availability of particulate-bound esfenvalerate for trophic uptake and

the affect of functional feeding strategy on consumption rates of three aquatic insect
species

Established the susceptibility of late-stage aquatic insects to esfenvalerate, and

quantifying the effect on fecundity.

Performed lotic and lentic aquatic invertebrate samplings in Oregon and Washington states to

obtain insect specimens for use in laboratory experiments and university collections, with
proficiency in field and laboratory identifications of several aquatic insect taxa.

Assisted in agroecosystem insect sampling, species identification, and data collection for WSU
research on the impacts of chemical and biological control methods on insect generalist predator
populations in Washington State potato fields. Sampled surface- and canopy- active insects in

both Oregon and Washington states.

Professional Affiliations

x Society of Environmental and Molecular Toxicology (current member)
x North American Benthological Society (current member)

x Entomological Society of America (former member)
x American Chemical Society (former member)

Page 3ine Palmquist, Ph.D.
04/08 ANNEX 158

Brian J. Prince, MRQA

Regulatory Efficacy Advisor

Professional Profile

Mr. Brian J. Prince is a Regulatory Efficacy Advisor in Exponent’s Health Sciences Center for
Chemical Regulation and Food Safety. Mr. Prince has extensive regulatory experience with
plant protection products working for the UK regulatory authority for pesticides, and practical
experience of efficacy and residues field testing of pesticides, working for several different

Agrochemical companies. He has a comprehensive working knowledge of EU regulatory
evaluation procedures and assessment methods, including relevant guidelines and EC Directives
for the efficacy aspects of both existing and new active substances. He has written Biological
Assessment Dossiers for clients, which have been exceptionally well received by EU regulatory

authorities.

Mr. Prince’s role in Exponent is to provide the lead within the area of efficacy under Directive
91/414/EEC (for plant protection products) and Directive 98/8/EC (for biocides), including the

commissioning and co-ordination of efficacy studies and the writing of Biological Assessment
Dossiers to support new and existing product registrations within the EU. In addition,
Mr. Prince provides a service to clients wishing to gain certification for efficacy testing within
the EU. The service includes the provision of detailed guidance and auditing of client facilities

prior to application for certification under the ‘Official Recognition of Efficacy Testing
Facilities or Organisations’ (‘Official Recognition’) also known as Good Experimental Practice
(GEP).

Academic Credentials and Professional Honors

B.Sc., Hons (2.I) Agricultural Science (Crops), University of Leeds, 1984

MRQA (Member of Research Quality Assurance)

07/08ANNEX 158

Publications and Presentations

Prince BJ. GLP for Efficacy Studies—Pesticide efficacy studies intended for submission to US
EPA/GEP inspections update. BARQA GLP Field Studies Discussion Day, November 2007.

Prince BJ. Official Recognition/GEP Efficacy Inspections Update. BARQA Field Studies
Discussion Day, November 2006.

Prince BJ. GEP/Official Recognition—One road to compliance, two routes to quality.
Compliance & Quality, 2004 BARQA Annual Conference, November 2004.

Prince BJ. Regulatory requirements for the weed control claims that appear on product labels.
AAB Meeting: Control of Weeds Not on the Product Label, February 2003.

Prince BJ. Sulfonyl-urea hethicides—rotational loading and management restrictions: A
regulators view. BCPC 39 Annual Review of Weed Control, November 2002.

Prince BJ. Official Recognition of Efficacy Testing Facilities. BARQA 22 ndAnnual Meeting,

November 1999.

Prior Experience

Higher Scientific Officer—Efficacy Section, Pesticides Safety Directorate, 1992–1997
Field Trials Officer, Dow AgroSciences Ltd., 1987–1992

Field Trials Officer, Cyanamid UK Ltd., 1985–1987
Field Trials Officer, A.H. Marks and Co Ltd., 1984–1985
Research Technician, University of Surrey (UK), 1980–1981
Research Technician, Camborne College/Rosewarne Research Centre, 1978–1980

Research Technician—ICI Plant Protection Division, 1975–1978

Project Experience

Written Biological Assessment Dossiers for clients in support of product authorisations under
the Plant Protection Products Directive (91/414/EEC).

Written Efficacy Summary Dossiers for clients in support of active substance submissions and
product authorisations under the Biocides Directive (98/8/EC).

Developed a Biocide Product Efficacy Template, specifically for the summary of product
related efficacy data under the Biocides Directive (98/8/EC).

Involved in the development, implementation, and management of the UK scheme for ‘Official
Recognition of Efficacy Testing Facilities or Organizations’ (required under Directive
91/414/EEC), also known as Good Experimental Practice (GEP).

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07/08 ANNEX 158

Extensive experienced in evaluation of efficacy data in support of product authorizations under

UK national legislation (Control of Pesticides Regulations) and European Union legislation
(Plant Protection Products Directive 91/414/EEC), writing relevant sections of regulatory
documents for consideration by expert committees. Involved in the production of efficacy
guidance to applicants in the areas of herbicides, fungicides, plant growth regulators, and GEP.

Involved in training regulatory staff in candidate/newly acceded EU Member States and
COLEACP countries in GEP inspections or efficacy evaluation to EU, FAO or OECD data
requirements.

Involved in the EU GEP Managers Group and the EU Herbicide Evaluators Group (forwarding
the harmonization of requirements between EU Member States for GEP and efficacy data—

particularly herbicides). Provided expert comments on OECD and EPPO guidance documents
relating to non-target plant testing and efficacy testing, respectively.

Undertaken efficacy and residues field testing, across a broad range of plant protection products,
for several national and multi-national agrochemical companies.

As a member of the Field Studies Group of the British Association of Research Quality

Assurance (BARQA), provided guidance on quality systems relating to efficacy testing of plant
protection products.

Professional Affiliations

x Member of British Research Quality Assurance (BARQA)

– GEP/GLP Field Studies Liaison

Page 3J. Prince
07/08 ANNEX 159

Inter-American Drug Abuse Control Commission (CICAD),

Second Phase Environmental and Human Health Assessment of the Aerial Spray
Program for Coca and Poppy Control in Colombia (date unknown)ANNEX 159ANNEX 159ANNEX 159ANNEX 159ANNEX 159ANNEX 159ANNEX 159ANNEX 159ANNEX 159ANNEX 159 ANNEX 160

Charles S. Helling & Mary J. Camp, United States Department of Agriculture,
Verifying Coca Eradication Effectiveness in Colombia (date unknown)

Redactions by the Government of the United States of America.
Document obtained by Ecuador through the U.S. Freedom of Information Act. ANNEX 160

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act.ANNEX 160

Redactions by the Government of the United States of America.

Document obtained by Ecuador through the U.S. Freedom of Information Act. ANNEX 160

Redactions by the Government of the United States of America.
Document obtained bEcuador through the U.S. Freedom of Information Act.

Document Long Title

volume III

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