volume III | INTERNATIONAL COURT OF JUSTICE

Document Number

17558

Parent Document Number

17554

Document File

17558.pdf

INTERNATIONAL COURT OF JUSTICE

CASE CONCERNING
AERIAL HERBICIDE SPRAYING

ECUADOR
v.
COLOMBIA

REPLY OF ECUADOR

VOLUME III

ANNEXES

31 JANUARY 2011 VOLUME III

ANNEXES

TABLE OF CONTENTS

REGULATIONS & TECHNICALREPORTS

Annex 9. Italian Republic, Legislative Decree No. 194 (17 Mar. 1995)

Annex 10. Spray Drift Task Force, A Summary of Aerial Application Studies
(1997)

Annex 11. Sweden, Environmental Code 808 (last amended 2009) (1998)

Annex 12. A. J. Hewitt et al., Development of the Spray Drift Task Force
Database forAerialApplications, 21(3) ENVIRONMENTAL
TOXICOLOGYAND CHEMISTRY (2002)

Annex 13. C. N. Boutin, C. Elmegaard and C. Kjaer, “Toxicity Testing of
Fifteen Non-crop Plant Species with Six Herbicides in a Greenhouse
Experiment: Implications for RiskAssessment”, in Ecotoxicology.
13:349–369 (2004)

Annex 14. French Republic, Decree On the Use of Products Mentioned inArticle
L.253-1 of Rural Code (5 Mar. 2004)

Annex 15. Las Palmas Ltda., Technical Department, Glyphosate (10,4 l/ha) and

Three Different Adjuvants, For Illicit Coca Crop (Erythoxylum spp.)
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Crops: Final Report (July 2004)

Annex 16. Republic of Slovenia, Act on Plant Protection Products (9 Sept. 2004)

Annex 17. United Kingdom, Department for Environment, Food and Rural
Affairs, Code of Practice For Using Plant Protection Products (2006)

Annex 18. Costa Rica, Executive Decree No. 34202-MAG-S-MINAE-MOPT-G-
MSP (21 May 2007)

Annex 19. Nova Scotia Environment and Labour, Media Backgrounder:
Herbicide Management (July 2007)

Annex 20. Republic of Estonia, Plant Protection Products Act, entered into force
1 May 2004, amended 1 July 2008Annex 21. Austrian Federated State of Vorarlberg, Ordinance on Plant Protection
Products, LGB1.Nr. 18/2008 (2008)

Annex 22. Australian Pesticides and Veterinary MedicinesAuthority (APVMA),
AVPM Operating Principles in Relation to Spray Drift Risk (15 July
2008)

Annex 23. American Society ofAgricultural and Biological Engineers, Spray

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2009)

Annex 24. French Republic, Rural and Maritime Fishery Code,Art. L253-1(V)
(2010)

Annex 25. Government of Saskatchewan, Ministry ofAgriculture, 2010 Guide to
Crop Protection (2010)

Annex 26. Federal Republic of Germany, Federal Institute of RiskAssessment,

Health Assessment Report POE-tallowamines (6 Sep. 2010)

Annex 27. United States Roundup Ultra Label

Annex 28. Colombia GYL-41 SL Label and Safety Data Sheet

VERIFICATION & OBSERVATION REPORTS

Annex 29. Organization of Indigenous Nations of Colombia (ONIC), Evaluation
of the Fumigations in Colombia: Destruction of Rural Areas from

Plan Colombia (Aug. 2002)

Annex 30. Colombian Medical Inquests (Sept. 2002)

Annex 31. Ecuadorian Medical Inquests (Sept.- Nov. 2002)

Annex 32. Association ofAmerican Jurists, et al., ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
“Impacts in Ecuador of Fumigations in Putumayo Department under
Plan Colombia” (Oct. 2002)

Annex 33. Letter from Victor Velasco Tapia, Government of Sucumbios,

Republic of Ecuador, to Lourdes Luque, Minister of Health, Republic
of Ecuador (Oct. 2002) UNITED STATES GOVERNMENT DOCUMENTS

Annex 34. Memorandum from Peter P. Trent, INL/RM/ASD, PSC Bogota, to

Grant Harden,INL/RM/ASD, COR (4 July 1996)

Annex 35. Memorandum from David Johnson, INL/C/ASD, to Grant Harden,
INL/C/ASD (14 Nov. 1996)

Annex 36. Memorandum from David Johnson INL/C/ASD to Grant Harden,
INL/C/ASD (12 Dec. 1996)

Annex 37. Memorandum from Tim Doty, COR, INL/RM/AS to Dyncorp, PSD

Manager (28 May 1997)

Annex 38. Memorandum from Tim Doty, COR, INL/RM/AD, to Dyncorp, PSD
Manager (Aug. 1997)

Annex 39. Memorandum from Stephen H. Harris, INL/RM/AD, to Dyncorp (21
June 1999)

Annex 40. Aviation Resource Management Inspection ofAir Wing Colombia Site
(23 March 2000)

Annex 41. U.S. Department ofAgriculture,Agricultural Research Service,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯1 (7 July 2001)

Annex 42. Memorandum from Stephen H. Harris, COR, DoS/INL/A, to Dyncorp,
PSD Manager (Dec. 2001)

Annex 43. United States Congressional Research Service, Andean Regional
Initiative (ARI): FY2002 Assistance for Colombia and Neighbors (14
Dec. 2001)

Annex 44. Memorandum from Lowell E. Neese, SAA, DoS/INL/A(Bogota), to
Stephen H. Harris, COR, DoS/INL/A(13 Mar. 2002)

Annex 45. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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 (19Aug. 2002)

Annex 46. Memorandum from Lowell Neese, SeniorAviationAdvisor, DoS/

INL/A(Colombia), to Paul O’Sullivan, COR, DoS/INL/A(21Apr.
2003)Annex 47. Memorandum from Lowell Neese, SeniorAviationAdvisor, DoS/
INL/A(Colombia), to Paul O’Sullivan, COR, DoS/INL/A(9 May
2003)

Annex 48. Memorandum from DavidA. Campbell, COR, DoS/INL/A, to
Dyncorp, PSD Manager (Feb. 2004)

Annex 49. Memorandum from Stephen H. Harris, COR, DoS/INL/A, to Dyncorp,

L 55 (Undated)

Annex 50. United States Department of State, Evaluation Summary Technical
Operations, G 111 (Undated)

Annex 51. Memorandum from Michael J. Kenna, INL/RM/AD, SeniorAviation
Advisor, to Steve Harris (COR) and GeorgeArzente, INL/RM/AD/
COR, L 14 (Undated) Annex 9

Italian Republic, Legislative Decree No. 194 (17 Mar. 1995) Annex 9

LEGISLATIVE DECREE, MARCH 17, 1995, No. 194

IMPLEMENTATION OF THE DIRECTIVE 91/414/CEE IN MATTERS OF MARKET ENTRY OF
PHYTOSANITARY PRODUCTS

PRESIDENT OF THE REPUBLIC

Whereas articles 76 and 87 of the Constitution;

Whereas the law February 22, 1994, no. 146, and, specifically articles 1, 2 and 31;

Whereas the directive of the Council 91/414/CEE of July 15, 1991, related to the market entry of the
phytosanitary products;

Considering the directive 93/71/CEE of the Commission of July 27, 1993, modifying the directive

91/414/CEE;

Considering the directive 94/37/CE of the Commission of July 22 nd 1994, modifying the directive
91/414/CEE;

Considering the directive 94/43/CE of the Council of July 27 th 1994, that defines Annex VI of the
directive 91/414/CEE;

Whereas the decisions of the Cabinet of Ministers, adopted in the meeting of February 17, 1995;

After acquiring the opinions of the competent Commissions from the Chamber of Deputies and the Senate
of the Republic;

Whereas the decision of the Cabinet, adopted in the meeting of March 16, 1995;

On the Ministers' proposal for the co ordination of the European Union po licies and health, together with
the Ministers of foreign affairs, of leniency and justce, of the Treasury, of agriculture, food stuffs and forestry
resources, of industry, commerce and crafts, of labor and social welfare and the environment;

The following legislative decree
IS ENACTED:

Art. 1
(Field of application)

1. This decree governs:
a) The authorization, the market entry, the use and the contro l of the plant health pr oducts, introduced in

their commercial form;
b) The market entry and the control of the active ingredients intended for the uses defined in article 2,
paragraph 1, letter a);
c) The authorization to introduce into the market the plant health products c ontaining or constituted by
genetically modified organisms, for which the deliberate release into the environment has formed the

object of the formal provision of assent via legislative decree of March 3, 1993, no. 92.

2. Exceptions are made for the provisions of:
a) The decree of the President of the Republic, May 24, 198 8, no. 223, implementing "Realization of the

EEC directive numbers 78/631, 81/187 and 84/291, concerning th e reconciliation of the legislations ofAnnex 9

members States related to the classification, to the packaging and labeling of the hazardous preparations

(parasiticides), pursuant to article 15 of the law of April 16, 1987, no. 183";
b) The law May 29, 1974, no. 256, implementing "Cla ssification and regulation of the packaging and the
labeling of hazardous substances and preparations", and subsequent modifications and incorporations;
c) The regulation (EEC) of the Council no. 2455/92 of July 23, 1992, related to the exports and imports of

some hazardous chemical products.

Art. 5
(Authorizations of plant health products: release, renewal, modification, re-examination and withdrawal)

1. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

2. Repealed by art. 43, paragraph 1b) of the D.P.R April 23, 2001, no. 290

3. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

4. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

5. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

6. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

7. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

8. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

9. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

10. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

11. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

12. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

13. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

14. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

15. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

16. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

17. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

18. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

19. Repealed by art. 43, paragraph 1b) of the D.P.R. April 23, 2001, no. 290

20. For the purpose of protecting the vulnerable water resources or for other reasons of sanitary or environmental

preservation, including the preservation of the useful entomological fauna and the other useful organisms, the
Minister of Health, on documented request by the autonomous Regions or Provinces, after consulting with
the Commission referring to article 20; can set limita tions or exclusions of usage, also temporary, in specific
areas of the territory, for au thorized plant h ealth products; the autonomous Region or the Province can

request that the experts themselves are consulted by the Commission. Annex 9

21. Within one year from this decree’s date of entry into force, the Mini ster of the environment, after consulting
with the autonomous Regions and the Provinces, defines the criteria for the identification of the vulnerable

areas, in which the autonomous Regions and the Provinces can request the application of the limitations and
exclusions of usage referenced in paragraph 20.

22. The autonomous Regions and the Provinces, for the authorized plant health products pursuant to paragraph 1,
regulate:

a) the usage for non agricultural purposes such as those of herbicidal uses;
b) the treatment by aircraft in exceptional cases and cases of demonstrated necessity, by those authorized
for the specific purpose.Annex 9 Annex 9

DECRETO LEGISLATIVO 17 MARZO 1995, N. 194

ATTUAZIONE DELLA DIRETTIVA 91/414/CEE IN MATERIA DI IMMISSIONE IN COMMERCIO DEI
PRODOTTI FITOSANITARI

IL PRESIDENTE DELLA REPUBBLICA

VISTI gli articoli 76 e 87 della Costituzione;

VISTA la legge 22 febbraio 1994, n. 146, e, in particolare, gli articolo 1, 2 e 31;

VISTA la direttiva del Consiglio 91/41 4/CEE del 15 luglio 1991, relativa all'immissione in commercio dei

prodotti fitosanitari;

TENUTO CONTO della direttiva 93/71/CEE della Commissione del 27 luglio 1993, recante modifica alla
direttiva 91/414/CEE;

TENUTO CONTO della direttiva 94/37/CE della Commissione del 22 luglio 1994, recante modifica alla

direttiva 91/414/CEE;

TENUTO CONTO della direttiva 94/43/CE del Consiglio del 27 luglio 1994, che definisce l'Allegato VI della
direttiva 91/414/CEE;

VISTA la deliberazione del Consiglio dei Ministri, adottata nella riunione del 17 febbraio 1995;

ACQUISITI i pareri delle competenti Commissioni della Camera dei Deputati e del Senato della Repubblica;

VISTA la deliberazione del Consiglio dei Ministri, adottata nella riunione del 16 marzo 1995;

SULLA proposta dei Ministri per il coordinamento delle politiche dell'Union e europea e della sanità, di
concerto con i Ministri degli affari esteri, di grazia e giustizia, del tesoro, delle risorse agricole, alimentari e forestali,
dell'industria, del commercio e dell'artigianato, del lavoro e della previdenza sociale e dell'ambiente;

E M A N A

il seguente decreto legislativo:

Art. 1
(Campo di applicazione)

1. Il presente decreto disciplina:

a) l'autorizzazione, l'immissione in commercio, la utilizzazione ed il controllo dei prodotti fitosanitari,
presentati nella loro forma commerciale;
b) l'immissione in commercio ed il controllo delle sostanze attive destinate agli usi definiti nell'articolo 2,
comma 1, lettera a);
c) l'autorizzazione ad immettere in commercio i prodotti fitosanitari contenenti o costituiti da organismi

geneticamente modificati, per i quali l'emissione deliberata nell'ambiente abbia formato oggetto del
provvedimento formale di assenso di cui al decreto legislativo 3 marzo 1993, n. 92.

2. Sono fatte salve le disposizioni di cui:
a) al decreto del Presidente della Repubblica 24 maggio 1988, n. 223, recante "Attuazione delle direttive CEE
numeri 78/631, 81/187 e 84/291, concernenti il riavvicinamento delle legislazioni degli Stati membri

relative alla classificazione, all'imballaggio e all'etichettatura dei preparati pericolosi (antiparassitari), ai
sensi dell'articolo 15 della legge 16 aprile 1987, n. 183";
b) alla legge 29 maggio 1974, n. 256, recante "Classificazione e disciplina dell'imballaggio e dell'etichettatura
delle sostanze e dei preparati pericolosi", e successive modificazioni ed integrazioni;
c) al regolamento (CEE) del Consiglio n. 2455/92 del 23 luglio 1992, relativo alle espo rtazioni ed alle

importazioni di taluni prodotti chimici pericolosi.Annex 9

Art. 2
(Definizioni)

1. Ai fini del presente decreto si intende per:
a) prodotti fitosanitari: le sostanze attive ed i preparati c ontenenti una o più sostanze attive, presentati nella
forma in cui sono forniti all'utilizzatore e destinati a:
1) proteggere i vegetali o i prodotti vegetali da tutti gli organismi nocivi o a prevenirne gli effetti;

2) favorire o regolare i processi vitali dei vegetali, con esclusione dei fertilizzanti;
3) conservare i prodotti vegetali, con esclusione de i conservanti disciplin ati da particolari
disposizioni comunitarie;
4) eliminare le piante indesiderate;
5) eliminare parti di vegetali, frenare o evitare un loro indesiderato accrescimento;

b) residui di prodotto fitosanitario o sem plicemente residui: una o più sostanze, in clusi i loro metaboliti e
prodotti di degradazione o di reazione, presenti in o su vegetali o prodotti di origine vegetale o prodotti
animali destinati al consumo, o altrove nell'ambien te, e costituenti residui dell'i mpiego di un prodotto
fitosanitario;
c) sostanze: gli elementi chimici ed i loro compos ti, allo stato naturale o sotto forma di prodotti industriali,
inclusa qualsiasi impurezza derivante dal procedimento di fabbricazione;

d) sostanze attive: le sostanze o i microrganismi, compresi i virus, aventi un'azione generale o specifica sugli
organismi nocivi o su vegetali, su parti di vegetali o su prodotti vegetali;
e) preparati: le miscele o le soluzioni co mposte da due o più sostanze, delle quali almeno una sostanza
attiva, destinate ad essere utilizzate come prodotti fitosanitari;
f) vegetali: le piante vive o le parti vive di piante, compresi frutti freschi e sementi;

g) prodotti vegetali: i prodotti di origine vegetale non trasformati o sottoposti a trattamenti semplici quali la
macinazione, l'essiccazione o la compressione, esclusi i vegetali definiti alla lettera f);
h) organismi nocivi: i parassiti dei vegetali o dei prodo tti vegetali, appartenenti ai regni animale o vegetale,
nonché i virus, i batteri, i funghi o altri agenti patogeni;
i) animali: gli animali di specie normalmente alimentate e allevate o consumate dall'uomo;

l) immissione in commercio: l'importazi one di un prodotto fitosanitario no nché qualsiasi consegna a terzi,
sia a titolo oneroso che gratuito, esclusa la consegna per il magazzinaggio e la successiva spedizione fuori
del territorio comunitario;
m) autorizzazione di un prodotto fitosanitario: l'atto amministrativo mediante il quale il Ministero della
sanità, a seguito di una domanda inoltrata da un richiedente, autorizza l'immissione in commercio e

l'utilizzazione di un prodotto fitosanitario nel territorio italiano o in una parte di esso;
n) ambiente: l'acqua, l'aria, il suolo, le specie selvatiche della flora e d ella fauna e relative interrelazioni,
nonché le relazioni tra tali elementi e gli organismi viventi;
o) lotta integrata: l'applicazione razionale di un complesso di misure biologiche, biotecnologiche, chimiche,
colturali o di selezione vegetale, con le quali si limita al minimo indispensab ile l'impiego di prodotti

fitosanitari contenenti sostanze chimiche per mantenere i parassiti a livelli inferiori a quelli che provocano
danni o perdite economicamente inaccettabili.

Art. 3

(Disposizioni generali)

1. Fatto salvo quanto previsto dall'articolo 22, i prodotti fitosanitari po ssono essere immessi in commercio ed
utilizzati solo se sono stati autorizzati dal Ministero della sanità, conformemente alle disposizioni del presente
decreto.

2. Sono vietati la produzione, il magazzinaggio ed il trasporto di prodotti fitosanitari non autorizzati, salvo che i
prodotti stessi siano rispondenti a tutte le seguenti condizioni:
a) siano destinati ad essere utilizzati in un altro Stato membro, che ne abbia autorizzato l'impiego a scopo
fitosanitario in conformità alle norme comunita rie o siano destinati ad uno Stato non appartenente
all’Unione europea, che ne abbia autorizzato l’impiego a scopo fitosanitario, fatte salve le disposizioni di

cui al regolamento (CEE) n. 2455/92 del Consiglio, del 23 luglio 1992, e successive modificazioni;
b) siano prodotti in stabilimenti autorizzati, previa comunicazione al Ministero della sanità da parte del
direttore tecnico responsabile;
c) siano etichettati conformemente alla norm ativa vigente nello Stato di destinazione e racchiusi in apposito
imballaggio o muniti di etichettatura aggiuntiva da cui risulti la loro condizione;

d) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯c▯autele prescritte in relazione alla natura del prodotto, accompagnati dalla
documentazione prevista dalle norme vigenti e nel rispetto delle disposizioni vigenti in materia di sicurezza
e di controllo. Annex 9

5. Il riconoscimento degli enti e degli organismi di cui al punto 2.2 dell'introduzione all'allegato III è effettuato con
decreto del Ministro delle risorse agricole, alimentari e forestali, su richiesta documentata degli interessati

attestante il possesso dei requisiti prescritti.

6. Il Ministro delle risorse agricole, alimentari e forestali, con decreto da adotta rsi di concerto con i Ministri della
sanità e dell'ambiente, disciplina l'applicazione dei principi di buone pratiche per l'esecuzione di prove in campo
finalizzate alla determinazione dell'entità dei residui di prodotti fitosanitari, nonché i requisiti necessari per il

riconoscimento degli enti e degli organismi che possono eseguire tali prove.

7. Il riconoscimento degli enti e degli organismi che possono eseguire le prove di cui al comma 6 è effettuato su
richiesta documentata, con decreto del Ministro delle risorse agricole, alimentari e forestali.

8. Il mantenimento del riconoscimento di cui ai commi 5 e 7 è subordinato all'esito favo revole di ispezioni
periodiche e regolari, effettuate da ispettori iscritti in apposita lista nazionale, approvata con decreto del Ministro
delle risorse agricole, alimentari e forestali, di concerto con i Ministri della sanità e dell'ambiente, entro sei mesi
dalla data di entrata in vigore del presente decreto; gli oneri per l'espletamento delle attività ispettive sono posti a
carico dei richiedenti secondo modalità definite con decreto del Mini stro delle risorse agricole, alimentari e

forestali.

Art. 5
(Autorizzazione dei prodotti fitosanitari: rilascio, rinnovo, modifica, riesame e ritiro)

1. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

2. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

3. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

4. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

5. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

6. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

7. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

8. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

9. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

10. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

11. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

12. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

13 . Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

14. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

15. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

17. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

18. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290

19. Abrogato dall’art. 43, comma 1b) del D.P.R. 23 aprile 2001, n. 290Annex 9

20. Allo scopo di proteggere le risorse idriche vulnerabili o per altri motivi di tutela sanitaria o ambientale, inclusa la
tutela dell'entomofauna utile e degli altri organismi u tili, il Ministro della sanità, su documentata richiesta delle
Regioni o delle Province autonome, sentita la Commissione di cui all'articolo 20, può disporre limitazioni o

esclusioni di impiego, anche temporanee, in aree specifiche del territorio, per prodotti fitosanitari autorizzati; la
Regione o la Provincia autonoma possono richiedere che propri esperti siano sentiti dalla Commissione.

21. Entro un anno dalla data di entrata in vigore del presente decreto, il Min istro dell'ambiente, sentite le Regioni e
le Province autonome, definisce i criteri per l'individuazione delle aree vulnerabili, nelle quali le Regioni e le

Province autonome possono chiedere l'applicazione delle limitazioni e delle esclusioni di impiego di cui al
comma 20.

22. Le Regioni e le Province autonome regolamentano, per i prodotti fitosanitari autorizzati ai sensi del comma 1:
a) l'impiego per scopi non agricoli di quelli ad attività diserbante;

b) il trattamento con mezzi aerei in casi eccezionali e di dimostrata necessità, per quelli autorizzati per
lo scopo specifico.

Art. 6
(Iscrizione delle sostanze attive nell'allegato I)

1. L'iscrizione di una sostanza attiva nell'allegato I, pe r un periodo non superiore a dieci anni, le condizioni
eventualmente connesse a detta iscrizione, le modifiche e la cancellazione dell'iscrizione sono disposte con
decreto del Ministro della sanità, in conformità a disposizioni adottate in sede comunitaria.

2. L'iscrizione di una sostanza attiva nell'allegato I è effettu ata solo se si può ritenere che i prodotti fitosanitari che
la contengono soddisfino i seguenti requisiti:
a) assenza di effetti nocivi sulla salute dell'uomo e degli animali, nonché sulle acque sotterranee, e di effetti
inaccettabili sull'ambiente, correlati ai residui derivanti da un'applicazione del preparato in conformità alle
buone pratiche fitosanitarie, nonché la possibilità di determinare detti residui, se significativi dal punto di
vista tossicologico o ambientale, con metodi analitici di applicazione corrente;

b) assenza di effetti nocivi sulla salute dell'uomo e degli animali e di effetti inaccettabili sull'ambiente,
associati all'impiego dei preparati, secondo un'applicazione conforme ai principi delle buone pratiche
fitosanitarie, come stabilito dall'articolo 4, comma 1, lettera b), punti 4) e 5).

3. Per l'iscrizione di una sostanza attiva nell'allegato I si tiene conto, ove occorra, dei seguenti elementi:

a) dose giornaliera accettabile per l'uomo;
b) un livello ammissibile di esposizione dell'operatore;
c) stima del destino e della distribuzione nell'ambiente, nonché dell'impatto sulle specie non bersaglio.

4. L'iscrizione di una sostanza attiva nell'allegato I può essere assoggettata a condizioni concernenti:

a) il livello di purezza minima della sostanza attiva;
b) la natura ed il tenore massimo di talune impurezze;
c) le restrizioni che tengono conto delle condizioni agricole, fitosanitarie e am bientali, comprese quelle
climatiche;
d) il tipo di preparazione;

e)mledaldiàso.

5. I soggetti interessati all'iscrizione di una sostanza attiva nell'allegato I possono presentare domanda al Ministero
della sanità, il quale, dopo averne valu tata, senza ritardo ingiustificato, la conformità ai re quisiti previsti
dall'allegato II, invita il richiedente a trasmettere agli altri Stati membri ed alla Commissione europea la

domanda stessa unitamente ad un fascicolo conforme ai requisiti previsti da ll'allegato II e ad un fascicolo
conforme ai requisiti previsti dall'allegato III, concernente almeno un pr eparato contenente tale sostanza attiva;
le modalità di presentazione e di valutazione delle doma nde sono stabilite con d ecreto del Ministro della sanità
in conformità a disposizioni adottate in sede comunitaria.

6. I soggetti che hanno ch iesto l'iscrizione di una sostanza attiva nell'alleg ato I possono chiedere il rinnovo della
iscrizione stessa almeno due anni prima della scade nza del periodo di iscrizione.

7. Il Ministero della sanità, in attuazion e di disposizioni comunitarie relative ai programmi di riesame delle
sostanze attive già in commercio alla data del 26 luglio 1993, provvede a:

a) incaricare la Commissione di cui all'articolo 20, per la realizzazione dei programmi comunitari di
valutazione, ponendo i relativi oneri carico degli interessati, ai sensi dell'articolo 20, comma 5; Annex 10

Spray Drift Task Force, A Summary of Aerial Application Studies (1997) Annex 10

AS UMMARY OF
Aerial Applica tio
StudiesAnnex 10

The SDTF measured primary spray drift, the o-fsfite
Introduction movement of spray droplets before deposition. It did
not cover vapor drift, or any other form of secondary
The incidence and impact of spray drift can be drift (after deposition), because secondary drift is pre-
minimized by proper equipment selection and setup, and dominantly specific to the active ingredient.
good application technique. Although the Spray Drift
Task Force (SDTF) studies were conducted to support
product registration, they provide substantial information Prior to initiating the studies, the SDTF consulted with
technical experts from reearch institutions around the
that can be used to minimize the incidence and impact of world and compiled a list of 2,500 drift-related studies
spray drift. The purpose of this report is to describe the from the scientific literature. Because of diefrfing
SDTF aerial application studies and to raise the level of techniques, it was difficult to compare results across the
understanding about the factors that affect spray drift. studies. However, the information from these

The SDTF is a consortium of 38 agricultural chemical references was useful in developing test protocols that
were consistently followed throughout the field studies.
companies established in 1990 in response to
Environmental Protection Agency (EPA) spray drift data The objective of the aerial field studies was to quantify
requirements. Data were generated to support thererge- drift from the range of application practices common in
istration of approximately 2,000 existing products and the the early 1990s. Since some practices may have
registration of future products from SDTF member
companies. The studies were designed and conducted in changed since then, it is important to recognize that the
aerial model will use inputs based on current practices.
consultation with scientists at universitieserch insti-
tutions, and the EPA. The information being presented is not an in-edpth
presentation of all data generated by the SDTF. Use of
The purpose of the SDTF studies was to quantify
primary spray drift from aerial, ground hydraulic, air pesticide products is strictly governed by label inst-cu
tions. Always read and follow the label dircetions.
blast and chemigation applications. Using a common
experimental design, more than 300 applications were
made in 10 field studies covering a range of application
practices for each type of application. Procedures

The data generated in the field studies were used to
Test site location and layout
establish quantitative databases which, when accepted by Two sites were chosen in Texas because they pr voided
EPA, will be used to conduct environmental risk
assessments. These databases are also being used to open expanses, up to one-half mile downwind frm o
validate computer models that the EPAcan use in lieu of the application areas, and a wide range of weather
directly accessing the databases. The models will pioe conditions. Wind speeds varied from 2 mph to 17
a much faster way to estimate drift, and will cover a mph, with an average of 10 mph across all applica-
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
wider range of application scenarios than tested in the relative humidity varied from 7% to 94%.
field studies. The models are being jointly developed by
the EPA, SDTF and United States Department of
Agriculture (USDA).

Overall, the SDTF studies confirm conventional

knowledge on the relative role of the factors thatctff
spray drift. Droplet size was confirmed to be the most
important factor. The studies also confirmed that the
active ingredient does not significantly affect spray drift.
The physical properties of the spray mixture generally
have a small effect relative to the combined effects of

equipment parameters, application technique, and the
weather. This confirmed that spray drift is primarily a
generic phenomenon, and justified use of a common set
of databases and models for all products. The SDTF
developed an extensive database and model quantifying

how the liquid physical properties of the spray mixture
affect droplet size. figure 1
1 Annex 10

The test application area measured 2,000 feet in length Other factors affecting drift
and 180 feet in width (figure 1). Four, 45-foot wide
parallel swaths were sprayed going from left-to-right Other variables that were tested include: nozzle
and right-to-left. Three lines of horizontal alpha- heights from 6 feet to 31 feet above the ground; boom
cellulose cards (absorbent material similar to thick lengths of 69% and 84% of the wingspan; oil as a
carrier for the ultra low volume (ULV) applications; the
blotting paper) were placed on the ground at 12 effects of liquid physical properties of the pesticide
selected intervals from 25 feet to 2,600 feet downwind
from the edge of the application area. These collectors spray mixture; and the effects of crop canopy.
simulated the potential exposure of terrestrial and
aquatic habitats to drift. Acollector was also positioned Weather-related factors including wind speed and
direction, and air temperature were crorded during the
upwind from the application area to verify that drift field trials at four separate heights between 1 and 30 feet.
only occurs in a downwind dircetion.
Relative humidity, solar radiation, barometric pssere,
and atmospheric stability were alsoc rorded.
Relating droplet size spectra to drift
All agricultural nozzles produce a range of droplet sizes
Experimental design
known as the droplet size spectrum. In order to measure The varying weather conditions encountered during
the droplet size spectrum that was applied in each field multiple-application field studies presented a good
study treatment (and that rperesent those produced
from commercial applications), the critical application opportunity to evaluate their effects on drift. However,
parameters (nozzle type, orifice size, psrseure, angle, these variations complicated efforts to measure the
effects of equipment-related factors. For example, if a
and air speed) were duplicated in an extensive series of treatment using 8002 nozzles (producing a fine drp olet
atomization tests conducted in a wind tunnel. The spectrum) was run during low wind speeds, and then
controlled conditions of the wind tunnel allowed the
droplet size spectrum to be accurately measured using a a treatment using D8 nozzles (producing a coarse
laser particle measuring instruent. droplet spectrum) was run during high wind speeds,
the amount of drift would have been affected both by
the change in droplet size and the wind speed.
The volume median diameter (VMD) is commonly used
to characterize droplet size spectra. It is the droplet size
at which half the spray volume is composed of laerrg To factor out the meteorological effects, the SDTF used
droplets and half is composed of smaller dp rlets. a covariate experimental design, which is a commonly
accepted statistical technique for this type of study.
Although VMD is useful for characterizing the entire The design entailed a control treatment that was
droplet spectrum, it is not the best indicator of drift always applied immediately after an experimental
potential.
treatment. The control treatment was a medium
Amore useful measure for evaluating drift potential is droplet size spectrum produced with D6-46 nozzles at
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯1
the percentage of spray volume consisting of dp rlets mph. It was always applied in exactly the same
less than 141 microns in diameter. This value was manner. The experimental treatment difefred from
selected because of the characteristics of the particle-
measuring instrument, and because it is close to 150 application to application in nozzle type, nozzle orifice
microns, which is commonly considered a point below size, aircraft speed, etc.

which droplets are more prone to drift. The primary test airplane, a Cessna Ag Husky, was
equipped with a dual application system (tank, pump
The cut-off point of 141 microns or 150 microns has been
established as a guide to indicate which droplet sizes are and boom) that permitted successive applications of
most prone to drift. However, it is important to the control and experimental treatments without
landing. The two booms were never used simultane-
recognize that drift doesn’t start and stop at 141 minr.o ously in order to avoid any potential interferece
Drift potential continually increases as droplets get between the sprays.
smaller than 141 microns, and continually decreases as
droplets get bigger.
Four swaths of the experimental treatment were
applied first, beginning at the downwind side. The
The wind tunnel atomization tests verified that a baro control treatment was then immediately applied over
range of droplet size spectra was applied in the field the same area. The total elapsed time for both applica-
study treatments. These measurements were critical to
understanding the difefrences in spray drift that were tions was 12 minutes. Continuous weather monitoring
measured for each field study traetment. showed no appreciable changes in atmospheric

2Annex 10

conditions during the 12

minute periods. The
downwind collectors were
analyzed for both diazinon
(the tracer used with the
control treatment) and

malathion (the tracer used
with the experimental
treatment).
figure 2
Using this experimental
design, differences between
Findings
replications of the control treatments are due only to
atmospheric conditions, since the application
procedures were always the same. Dife frences between Typical drift levels from aerial application
experimental treatments are due to changes in the
atmospheric conditions and application prcoedures. The goal of aerial applicators is to protect ms fro
Consequently, differences between experimental and diseases, insects and weeds while keeping drift as close to
zero as possible. The SDTF studies show that drift can be
control treatments are due to application poedures. kept very low by using good applicationceprures.
This allowed direct comparisons to be made among all
the experimental treatments by factoring out the eeffcts
of weather (as measured by the control applications). Based on data generated by the SDTF, in a typical full field
aerial application, 98% of the total applied activegtre
stays on the field and only 2% drifts (figure .catl
Atotal of 90 experimental (45 treatments, 2 elicates application was defined as a 1200-foot wide, 20-swath field
each) and a corresponding 90 control applications were (suggested by EPA) using an Air Tractor 4set-up to
made. Besides providing a means of adjusting for produce a medium droplet spectrum, in a 10 mph
atmospheric conditions, the 90 applications of the
control treatment also provided an extensive database crosswind (typically the maximum allowable wind speed), a
60-foot swath adjustment, and 8-foot nozzle height
for evaluating the effects of meteorological parameters (application height).
on drift.

Aerial drift model

Due to the complexity of evaluating all possible inter-
actions of the numerous application variables, a
computer model is the most practical way to conduct

spray drift risk assessments. For aerial application, a
highly sophisticated simulation model had been
developed previously by the USDAF orest Service for
forestry applications. The SDTF, EPAand USDA figure 3
worked together to adapt and validate this model for
agricultural applications using the data generated in
Although aerial applications typically consist of twenty or
the SDTF field and atomization studies. After final
review and acceptance by the EPA, this model will more swaths, using fields of this size was not practical.
allow evaluation of a much wider range of applications Instead, a four-swath (180 feet wide) application area was
than those tested in the field studies. Its use will help used in the field studies. This design generated data that
ensure that SDTF assessments reflect curret represented drift from a
20-swath field since most drift originates from the farthest
application practices. downwind swaths.

Because so many interacting factors affect aerial spray
drift, this report only offers examples of how the major Because the application area was smaller than is typical
variables affect drift. for commercial applications, and because most drift
comes from the outer swaths of the field, the peenrtcage
of the active ingredient leaving the field in the SDTF

studies was 8% rather than 2% (figure 3). This peenrtcage
of drift is artificially high due to the relative size of the

3 Annex 10

application areas. The 8% drift is the average of the 90
applications of the control treatment. The SDTF con l tro
application difefred from the typical application only in
the aircraft used, swath width, and the size of the
application ara.

Figure 4 shows how the 8% of the control treatment that figure 5a
left the field deposited downwind. The amount of
material that deposits on the ground decreases rapidly

with distance and is already approaching zero at 250 feet
downwind. Ground deposition was measured out to one-
half mile downwind, but the amount of material was
normally too low beyond 250 feet to illustrate any
differences between tretments.
figure 5b

figure 5c

In order to maintain consistency across all applications in
figure 4 the SDTF field studies, the pilot made no swath
adjustment. However, in this report a swath adjustment
was applied by mathematically shifting the deposition
curve upwind by 50 feet. This would be a typical swath
Ground deposition measurements began 25 feet
downwind, which rp eresents a reasonable distance fro adjustment in a 10-mph crosswind, the average wind
the edge of a crop to the effective edge of a field where speed in the field studies.
drift would begin to be of concern.
The effects of swath adjustment are illustrated in figure
6 for no adjustment, a half swath adjustment, and a full
Ascale of Relative Drift is used in this and all subsequent
graphs to facilitate comparisons among treatments. Since the swath adjustment as applied for the control traetment.
control treatment will be used as a standard of comparison, With no swath adjustment, the amount of spray
it was set to 1.0 at 25 feet. For an application of one pound ofterial depositing at 25 feet downwind is apprx oi-
mately three and a half times that from a full swath
active ingredient per acre, thsrreesents 1.2 ounces per acre
deposited on the ground at 25 feet. ARelative Drift value of adjustment. Swath adjustment substantially rd euces
0.5 indicates that one-half as much was depositeda.luev drift, especially in the first 100 feet. These results are for
of 2 would indicate twice as much was deposited. In a medium droplet size spectra from the contrlo
subsequent graphs the deposition profile for the clontro

treatment is shown in red in order to facilitate comparisons.

How swath adjustment reduces drift

When the wind is low, virtually all of the spray is
deposited directly under the aircraft allowing the pilot

to fly close to the edge of the field (figure 5a). With a
crosswind, the spray swath is displaced downwind
(figure 5b). Pilots typically compensate for this swath
displacement by adjusting the position of the airrcft
upwind (figure 5c). The amount of swath adjustment

can vary from one half, to more than two swath widths,
depending upon wind speeds and proximity to figure 6
sensitive areas.

4Annex 10

treatment. The effects would be even more dramatic
with a finer droplet spectrum.

How nozzle and droplet size affect drift

The effect of droplet size on downwind gru ond
deposition is illustrated in figure 7. It shows that drift
decreases dramatically as the percent of volume in
droplets smaller than 141 microns decreases due to the
use of different nozzles, nozzle angles, and/or air

speeds.

The control treatment had 15% of the spray volume in
small droplets (less than 141 microns). The smaller D4-
45 nozzle at the same angle produced twice the volume

of small droplets and twice the amount of drift at 25 figure 8
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
produced a much lower volume of small droplets and setting up identical nozzles and nozzle angles on three
substantially less drift than the contrlo. aircraft: a helicopter, which flew at 64 mph; a piston-

powered, fixed-wing airplane at 107 mph; and a
turbine-powered, fixed-wing airplane at 156 mph. The
nozzle height was 8 feet.

When the same nozzles (D6-46) were positioned at a

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯fnces in
drift due to air shear (figure 9). At 156 mph, 39% of the
droplet volume was less than 141 microns. As speed
and subsequent air shear decreased, the volume

percent less than 141 microns decreased to 6% with a
corresponding decrease in drift.

It must be emphasized that figure 9 illustrates the eeffct
of air shear on droplet size and drift. It does not
figure 7
indicate that these are typical droplet spectra for each
aircraft. Normally the sizes and/or angles of the
nozzles are changed to compensate for the air shear at
Although droplet size was the primary factorec atfifng higher speeds.
drift, the data for the D6 at 64 mph are notctelry

comparable because they were obtained with a helicopter
instead of a fixed wing airplane. The helicopter data are
included to illustrate that it is possible to reduce the
percentage of small droplets to very low levels with a cor-
responding decrease in drift. The results show that pilots

can minimize drift by managing the factorsea ctffing
droplet size.

How air shear affects droplet size and drift
Air shear across the nozzle tip, which is a function of
both nozzle angle and aircraft speed, significantly

affects droplet size. When nozzles are pointed toward
the back of the plane, air shear is less than when the
nozzles are pointed downward (figure 8). Air shear
across the nozzle tip also increases with faster airrcaft
figure 9
speeds, resulting in smaller droplets. The effect of air
shear on droplet formation and drift was studied by

5 Annex 10

Although the SDTF did not extensively test the eeffcts
How nozzle height affects drift
In aerial applications over agricultural crop areas, spray of boom length on drift, the computer drift model
affirms that the common practice of maintaining boom
is typically released when the nozzles are about 8 feet length at 70% or less of the wingspan minimizes drift
above the ground or crop, compared with forestry and (figure 11). The effect of boom length is more
rangeland applications which are sometimes made at 20 important when spraying a fine versus coarse drp olet
feet or higher. Figure 10 compares drift from the conltro
treatment when the nozzle height is changed from 8 feet size spectrum.

to 22 feet. It shows that the higher nozzle heighelts How dynamic surface tension affects drift
in approximately 2.5 times more drift at 25 feet
downwind. Physical properties of the tank mixture can influence
the formation of droplets by agricultural nozzles,
although this effect is most important at higher levels

of air shear.

The SDTF examined dynamic surface tension, shear
viscosity, and extensional viscosity. Of these three
physical properties, dynamic surface tension usually

has the greatest influence on droplet size. Figure 12
represents the maximum range of drift attributable to
dynamic surface tension for the SDTF contrlo
treatment. The
72 dynes/cm represents water, 32 dynes/cm re presents
figure 10
the most extreme case, and 45 dynes/cm rp eresents a
large percentage of commercial pesticide tank
mixtures.
With a finer droplet spectrum, this difefrence would
have been greater; with a coarser droplet spectrum, the These curves were generated by the computer drift

differences would have been less. model. Field study data confirmed that for the conltro
treatment, physical properties had a very small effect on
How boom length affects drift drift compared to equipment and application pcreodures.

Turbulent air, ferred to as vortices, is created by the
wings. Wing or rotor tip vortices exist on all aft.c
When the length of the boom is too long, spray

droplets are caught in these vortices. The smaller
droplets follow the air movement up and over the
wing or rotor which effectively increases the
application height and increases the potential for drift.
When boom lengths are shortened, fewer drp olets

enter the vortices and drift iduced.

figure 12

How wind speed affects drift
The 90 replicates of the control applications clearly
established that wind speed was the most important

atmospheric factor affecting drift (figure 13). Although it
is commonly accepted that hot, dry conditions accelerate
figure 11 droplet evaporation, which results in smaller drlets,
this was not found to be as important as wind speed.

6Annex 10

Drift levels can be minimized by:

a. Applying the coarsest droplet size spectrum
that provides sufficient coverage and pest contl.ro

b. Continuing the standard practice of
swath adjustment.

c. Controlling the application height.

d. Using the shortest boom length that is practical.

figure 13 e. Applying pesticides when wind speeds are low.

Except at high levels of air shear, the physical
properties of the spray mixture have only a minimal
How crop canopy affects drift effect on drift. The SDTF studies show that the pattern
Ground cover in the application and drift collection
and magnitude of drift results from a complex
areas consisted of short grass. Alimited number of interaction of many factors. The drift model is an
treatments were conducted over cotton to determine if effective means of predicting aerial spray drift and
there was a significant effect due to the presence of a permits the evaluation of a much broader range of
more developed canopy. These treatments indicated a small
variables than those tested by the SDTF.
decrease in downwind ground deposition over cotton.
When accepted by the EPA, the SDTF model and
Because the effect of canopy was extremely small, and databases will be used by the agricultural chemical
because it was not practical to evaluate the infinite industry and the EPAfor environmental risk

number of canopy shapes, heights, and densities, assessments. Even though active ingredients do not
additional testing was not conducted. However, the differ in drift potential, they can differ in the potential
treatments on cotton suggest that the SDTF field to cause adverse environmental effects. Since drift
studies may slightly over-estimate drift for applica- cannot be completely eliminated with currn et

tions that are typically conducted over a well technology, the SDTF database and models will be
developed canopy. used to determine if the drift from each agricultural
product is low enough to avoid harmful envirn omental
effects. When drift cannot be reduced to low enough

levels through altering equipment set up and
Conclusions application techniques, buffer zones may be imposed
to protect sensitive areas downwind of applications.
The results from the SDTF studies confirm ps rent
knowledge concerning the role of factors that aefcft
spray drift. In many cases the studies quantified what Mention of a trademark, vendor, technique, orprietary
product does not constitute an endorsement, guarantee, or
was already known qualitatively. As expected, dp rlet warranty of the product by the authors, their companies, or the
size was shown to be the most important factor Spray Drift Task Force, and does not imply its approval to the
affecting drift from aerial applications. Logically, the exclusion of other products or techniques that may also be
results also confirm that drift only occurs downwind.
Waiting until the wind is blowing away from sensitive suitable.

areas is an effective application practice. Although drift Services, Inc., P.O. Box 509, Macon, Missouri 63552. (816) 762-4240 or▯ fax (816)
cannot be eliminated totally with current technology, 762-4295Area code changes to 660 after 11-97
there are many ways to minimize drift to levels
approaching zero. The SDTF studies confirm that when © 1997 by Spray Drift Task Force. All rights reserved.

good application practices are followed, all but a small
percentage of the spray is deposited on taregt.

7 Annex 11

Sweden, Environmental Code 808 (last amended 2009) (1998)Annex 11Annex 11Annex 11Annex 11 Annex 12

A. J. Hewitt et al., “Development of the Spray Drift Task Force Database forAerialApplications”,
(ENVIRONMENTAL TOXICOLOGY AND CHEMISTRY Vol.21 No.3 (2002)) Annex 12

Environmental Toxicology and Chemistry, Vol. 21, No. 3, pp. 648–658, 2002
䉷 2002 SETAC
Printed in the USA
0730-7268/02 $9.00.00

Hazard/Risk Assessment

DEVELOPMENT OF THE SPRAY DRIFT TASK FORCE DATABASE FOR

AERIAL APPLICATIONS

A NDREW J. H EWITT ,*† D AVID R. J OHNSON ,† JOHN D. F ISH ,‡ CLARENCE G. H ERMANSKY ,§ and

D AVID L. V ALCORE 㛳
†Stewart Agricultural Research Services, P.O. Box 509, Macon, Missouri 63552, USA
‡Aventis Crop Protection, 2 T. West Alexander Drive, Research Triangle P, North Carolina 27709, USA
§E.I. duPont de Nemours and Company, Wilmington, Delaware 19880, USA
㛳Dow AgroSciences, 9550 Zionsville Road, Indianapolis, Indiana 46268, USA

(Received 26 September 2000; Accepted 13 August 2001)

Abstract —This article is part of a series describing the development of the Spray Drift TForce (SDTF) database and its
application to agricultural chemical exposure rassessment modeling. The series describes the development of a large generic
database (assuming that active ingredient rate is not a factor affecting physical drift) and its use in estimating spray movement
immediately following application by aerial methods. The components of the database are described. In agreement with ﬁeld trials
in the open literature, the database shows that the major variables affecting off-target spray deposition are droplet size, spray release
position (boom height and length), and wind speed and direction. In addition, secondary parameters that can affect these variables
and drift are also discussed.

Keywords —Drift Aerial spraying Pesticide application Physical properties Droplet size

INTRODUCTION erties of a tank mix and that, after the formation of the spray
droplets, is independent of the speciﬁc active ingredient. As
The Spray Drift Task Force (SDTF) is a joint development such, spray drift for different tank mixes applied using the
project of 40 agricultural chemical companies that was formed
in 1990. The U.S. Environmental Protection Agency (U.S. same application equipment can be presumed to be generically
EPA) Ofﬁce of Pesticide Programs (OPP) required agricultural related to physical solution properties and not the chemistry
of the active ingredient. Therefore, a comprehensive database
chemical manufacturers to provide droplet-size spectrum mea- of off-site drift and deposition phenomena could be developed
surements and ﬁeld-drift evaluations when adverse effects to
nontarget organisms were possible (CFR 40.168.202.1 and independent of speciﬁc active ingredients. This generic ap-
proach rests on three general assumptions. The ﬁrst is that
202.2). Submission of spray drift data for individual product degradation and volatilization of the active ingredient analyte
registrations were, however, both expensive for the manufac-
turers and of limited value in evaluation of potential exposure during the spray and deposition timeframe is negligible. Near-
of organisms off-site over the wide range of application var- ﬁeld drift and deposition occur within a short time frame (30
min). Loss of the active ingredient either through degradation
iables. The primary goal of the SDTF studies was the provision or volatilization must be much slower than this to assure ef-
to OPP of a comprehensive database on the off-site drift of
crop protection chemicals during agricultural-spray applica- ﬁcacy of the compound within the ﬁeld. The second assump-
tion is that the physical properties should be measured in the
tions. This database was developed to improve the data for tank mix and tracer levels would correlate to full active-in-
regulatory decision-mak ing and provide a basis for the eval-
uation of risk mitigation strategies. Although over 40 separate gredient rates. It should also be noted that adjuvants were not
ﬁeld-trial studies of crop-protection chemical drift were iden- tested completely in the SDTF studies but rather only a subset
of tank mixes. The third assumption (U.S. EPA policy/science)
tiﬁed in the open literature [1], these studies do not form a is that the risk to nontarget organisms can be evaluated as a
systematic dataset for analysis of off-site drift. In addition,
these open-literature studies were not collected using Good two-stage process where environmental concentrations are
used to estimate exposure to the contaminant and then com-
Laboratory Practice Standards, 40 CFR Part 160 in the Federal bined with measurements of biological activity to determine
Register, as required for regulatory data submissions. A few
registrant companies had run very limited range aerial drift risk [2].
and atomization studies. In the development of the database, spray drift was viewed
as a series of physical processes, i.e., atomization, movement,
The fundamental premise of the cooperative SDTF effort evaporation, and, ﬁnally, deposition of droplets. Laboratory
was that off-site drift is primarily a function of application
techniques, environmental conditions, and the physical prop- and ﬁeld experiments were performed to analyze and quantify
each of these physical components important in the spray drift
process. The SDTF reviewed over 800 published and internal
* To whom correspondence may be addressed
(ahewitt@mark twain.net). company reports on spray drift. Several prior studies had iden-
Mention of trade names or commercial productsdoesnotconstitute tiﬁed droplet size as the primary application variable control-
endorsement or recommendation for use by the authors of this article,ling drift from low-ﬂight agricultural spraying [3–6]. Droplet
their companies, or the Spray Drift TaForce. size is also one of the most important variables affecting spray

648Annex 12

Spray Drift Task Force database for aerial applications Environ. Toxicol. Chem. 21, 2002 649

efﬁcacy, along with placement, timing, coverage, and chemical the SDTF studies. The aerial survey showed that nozzles were
toxicity [7,8]. Many application parameters including nozzle usually oriented 45 ⬚ backward on booms positioned belowand/

type, nozzle orientation, pressure, aircraft speed, and tank mix or behind the trailing edge. Surfactants and/or drift control
formulation affect droplet size. Development of a database to adjuvants are often used for tank mixing. Swath displacement,
quantify atomization as a function of these application vari- offset, or adjustment is nearly always used by aerialapplicators
ables and the physical properties of the tank mix was a central to compensate for using ﬁner sprays or spraying under con-
effort in the SDTF studies. Additional laboratory studies were ditions of higher wind speeds. This practice involves offsetting

performed to quantify the physical properties of tank mixes the application by different swath proportions to allow for the
used in both atomization and ﬁeld studies as well as the evap- wind carrying the droplets downwind. Applications typically
oration rate of droplets. cease when conditions favor high drift levels (exact conditions
The overall objective of the SDTF studies as required by will vary depending on proximity to sensitive areas and other

the U.S. EPA was quantiﬁcation of downwind sedimentation drift mitigation practices, but often 10 mph represents an upper
deposition for a wide range of label conditions and atomization wind speed), especially when close to sensitive or occupied
characteristics. Meteorological variables such as wind speed areas. Although the SDTF aerial application studies were de-
and direction, atmospheric stability, and relative humidityhave veloped based on typical application practices for the early

a signiﬁcant impact on off-target movement and deposition 1990s and reasonable worst case meteorological conditions, it
[3–5,9,10]. The ﬁeld studies were designed to quantify the should be noted that aerial application is a dynamic industry
response of drift to meteorological variables, resolve discrep- and application practices change based on available technol-
ancies in the historical studies on the relative importance of ogy, information, and regulations. In particular, new nozzles

application parameters, and account for the confounding ef- and global positioning satellite systems are becoming more
fects of the meteorology on these application variables. common place. However, the SDTF database covered a wide
This article summarizes the development of the SDTF da- range of conditions providing resources for the development
tabase in the areas of aerial ﬁeld, atomization, and physical of the AgDRIFT 威 model (Spray Drift Task Force, Stewart
property studies, summarizes the major results of the aerial Agricultural Research Services, Macon, MO, USA), whichcan

ﬁeld studies, and presents results on off-target deposition. predict drift for a wider range of conditions than actually test-
These studies were used to verify and modify existing drift ed.
models, thus providing a tool to evaluate a wider range of
application and meteorological scenarios than could be tested. Test site locations

Accompanying articles describe the model development and Test sites were selected in the high plains of Texas, near
evaluation [11,12]. While the present article focuses on the Plainview, and in the Rio Grande Valley of south Texas, near
SDTF aerial database, information on the SDTF ground rig Raymondville, USA. These two sites provided a wide range
studies can be found elsewhere [13]. of temperature, relative humidity, and wind speeds. Each test

The SDTF ﬁeld, atomization, and physical property studies site comprised an area large enough to allow several test areas
involved hundreds of treatments. It is beyond the scope of the usable regardless of wind direction. At the Plainview site,
present article to present all of the data and ﬁndings from those applications were made to a level ﬁeld of mowed grass (height
studies; however, additional information is availableattheU.S. ⫽ 10–15 cm). The absence of a crop provided a reasonable

EPA web site for scientiﬁc advisory panel reviews at worst case scenario for drift (because there was no vegetation
www.epa.gov/scipoly/sap or from the U.S. EPA Ofﬁce of Pes- to intercept droplets) and also allowed a comparison among
ticide Programs dock et. all treatments without the confounding effects of a crop can-
opy. At Raymondville, the applications were made over rough,
MATERIALS AND METHODS
disked, bare ground or grain sorghum stubble mowed to a
Aerial ﬁeld studies height of 25 cm. Two of the variable treatments at Raymond-
An application practices matrix was developed based on a ville were applied to a cotton canopy in the green boll stage
survey of registered labels and knowledge of use patterns in (height ⫽ 104 cm).

the United States to encompass the range of signiﬁcant ap- Covariate approach
plication practices. To determine typical application practices,
a survey of about 20% of aerial applicators was conducted by Off-target deposition is a function of application scenario
the SDTF and summarized by the National Agricultural Avi- (treatment) and meteorological effects. Since meteorological

ation Association [14]. Survey results showed that aerial spray variables continually change, the ideal experimental design is
application volume rates range from ultralow volume ( ⱕ0.8 to apply all treatments simultaneously. However, this is not
L/ha) through low ( ⬎0.8–3.0 L/ha) and medium ( ⬎3.0–7.7 L/ practical. The SDTF used a covariate approach that provided
ha) to high volume ( ⬎7.7–38.0 L/ha) and are made using ﬁxed- a reasonable solution to this by always applying twotreatments

and rotary-wing aircraft. Flight speeds range from low-speed almost simultaneously. One treatment, referred to as the stan-
helicopters (11–33 m/s) through medium-speedﬁxed-wingpis- dard treatment, always involved the same application scenario
ton aircraft (33–50 m/s) to high-speed turbine engine ﬁxed- (i.e., the test substance and application parameters remained
wing aircraft (⬎50 m/s). Typical applications are made using constant), while the second treatment, referred to as the var-

water as a carrier, with an application volume rate in the me- iable treatment, included a change of those variables being
dium-volume range. Spray pressures are typically around 2 studied. Diazinon (Aventis Crop Protection, Raleigh, NC,
bar. Most aerial applications are made at a height of 1.5 to 3 USA) was used for all the standard treatments, and malathion
m above the canopy, with a swath width of 15 to 18 m. Dif- (Platte Chemical Company, Greeley, CO, USA) was used for
ferent nozzle types and operational parameters may be used all the variable treatments. A covariate analysis was performed

within each combination of application volume rate and ﬂight using the standard treatment as the covariate for facilitating
speed. Appropriate combinations for testing were selected for comparisons among treatments without the confounding ef- Annex 12

650 Environ. Toxicol. Chem. 21, 2002 A.J. Hewitt et al.

Table 1. Summary statistics of spray period wind speeds during Spray at a height of 1.8 m above the ground. The upwind fetch was
Drift Task Force ﬁeld trials
unobstructed and properly represented the area of the drift and
Mini- Maxi- deposition. Tables 1 and 2 show summary statistics for wind
No. of Mean Median mum mum speed, temperature, and relative humidity for each set of stud-
Study trials (m/s) (m/s) (m/s) (m/s)
ies.

Plainview 1992 74 3.70 3.62 1.57 6.92 Sprayer setup and use
Plainview 1993 48 4.76 4.85 2.27 7.72
Raymondville 1993 60 4.86 5.05 1.34 6.56 A Cessna Ag Husk y威 (Cessna Aircraft Company, Wichita,
Overall 182 4.36 4.54 1.34 7.72
KS, USA) piston engine-powered aircraft ﬂying at 47 to 52
m/s was used for all applications of the standard treatment and
most of the variable treatments. This aircraft hadbeenmodiﬁed
fects of meteorology. The covariate analysis approach is de-
to allow application of two tank mixes through separate sets
tailed in many statistical texts [15,16]. Data from the standard of spray tank s, pumps, booms, and nozzles. The two booms
treatments provided a means for quantifying the effects of were never used simultaneously in order to avoid any potential
meteorological variables on drift through a multiple regression
interference between the sprays. Applications were also made
analysis of all meteorological variables (temperature, relative using an Air Tractor 502 (Air Tractor Corporation, Olney, TX,
humidity, wind, etc.) and off-target deposition. USA) turbine engine-powered ﬁxed-wing aircraft and a Wasp

Meteorological monitoring (Bell Textron, Houston, TX, USA) rotary-wing aircraft (he-
licopter). These two aircraft represented typical relatively high
Meteorological data were collected at four heights on a (66–71 m/s) ﬁxed-wing and low-speed (22–29 m/s) rotary ap-
tower near the spray area and were used to extract the mean
plications, respectively.
wind speed and aerodynamic roughness length by ﬁtting the Setting the width of the application area required careful
wind speed measurements to a logarithmic proﬁle as consideration of the carrying capacity of the spray equipment

ln(z/z0) relative to the size and time required to spray the area. A
U ⫽ U r relatively large application area was needed to accurately sim-
ln(zr/z0) ulate a full ﬁeld application. However, it tak es longer to spray

where the reference height, z ,ris assumed to be 2 m (its value larger areas, increasing the potential variability in meteoro-
is arbitrarily chosen and does not affect the vertical depen- logical conditions between the variable and standard appli-
dence) and the reference wind speed at that height, U r and cations.
aerodynamic roughness length, z , were recovered from a least
o Four parallel swaths (ﬂight-line passes), the maximum
squares analysis of the wind speed recorded during the run. number that could be applied by the modiﬁed Cessna Ag Hus-
Meteorological variables affect spray drift, mainly through ky 威 aircraft without reloading, were used in the aerial studies,
the evaporation and transport of droplets following emission for an overall spray block width of 50 m. The on-target ap-
2
from a sprayer. The wind speed, wind direction, and air tem- plication rates were veriﬁed using 1,000 cm horizontal alpha-
perature were measured at heights of 0.3, 1.8, 3.05, and 9.1 cellulose strips on the ground perpendicular to the lineofﬂight.
m above the ground throughout the study. Richardson number, The alpha-cellulose strips spanned 20% of the total swath

a dimensionless measure of atmospheric stability, was calcu- width (where swath width is the width of the spray deposition
lated using from ﬂight passes), producing samples that covered in-swath
variation.
gT
冢冣 The application scenarios (treatments) are summarized in
Tdz Table 3. The treatments included different sprayer setups (noz-
Ri ⫽ 2 zle types, nozzle angles, spray pressures, and tank mixes) for
dU
冢dz investigating effects on off-target spray movements. The noz-
zle types (supplied by Spraying Systems, Wheaton, IL, USA)
where Ri ⫽ Richardson number, g ⫽ acceleration due to grav- and mean D and %vol ⬍ 141 ␮m values included ﬂat fan
2 v0.5
ity in m/s , T ⫽ mean temperature in layer dz in ⬚C, dT/dz ⫽ nozzles 8002 (with D v0.5⫽ 160; %vol ⬍ 141 ␮m ⫽ 45.1%)
temperature gradient in layer dz in ⬚C/m, and dU/dz ⫽ hori- and 8003 ( D v0.5 178–332 ␮m; %vol ⬍ 141 ␮m ⫽ 6.4–
zontal wind velocity gradient in layer dz in s .1 40.4%); disc-core (swirl) nozzles D4-45 ( D ⫽ 107–173 ␮m;
v0.5
Richardson numbers were calculated for the layer between %vol ⬍ 141 ␮m ⫽ 33.8–69.9%), D6-46 ( D v0.5 178–359 ␮m;
0.3 and 9 m (layer dz). The values showed that the atmospheric %vol ⬍ 141␮m ⫽ 15.0–33.8%), and D8-46 ( D v0.5 340 ␮m;
conditions were neutral or unstable for nearly all of the trials %vol ⬍ 141␮m ⫽ 6.0%); solid stream (jet) nozzles D6 ( D
v0.5
(Richardson number near or ⬍0). ⬎ 811 ␮m; %vol ⬍ 141 ␮m ⬍ 0.2%) and D8 ( D v0.5⫽ 413–
Relative humidity and barometric pressure were recorded 546 ␮m; %vol ⬍ 141 ␮m ⫽ 2.1–6.5%), where D v0.5is the

Table 2. Summary statistics for temperature and relative humidity during ﬁeld trials

No. of Mean Median Minimum Maximum
Study trials (⬚C/%) (⬚C/%) (⬚C/%) (⬚C/%)

Plainview 1992 74 27.0/63.2 26.4/62.2 21.1/35.6 32.8/92.6
Plainview 1993 48 13.4/39.9 12.7/35.5 0.2/7.1 29.0/91.4
Raymondville 1993 60 30.7/63.9 31.5/58.6 24.2/43.1 35.1/93.8
Overall 182 24.7/57.3 27.1/57.3 0.2/7.1 35.1/93.8Annex 12

Spray Drift Task Force database for aerial applications Environ. Toxicol. Chem. 21, 2002 651

Table 3. Summary of spray parameters for Spray Drift TaskForce aerial ﬁeld studies

Nozzle type/ Spray pressure Application Boom Boom Carrier (water/ D v0.5 Spray volume Spray volume
angle down (⬚) (kPa) volume (L/ha) heighta lengthb soybean oil) (␮m) ⬍ 105 ␮m (%) ⬍ 141 ␮m (%)

Rotary-wing aircraft (21–25 m/s)

8003 (45) 200 12 VL 73 Water 332 2.0 6.4
D4-46 (45) 200 25 VL 73 Water 339 2.1 6.2
D4-46 (45) 200 26 MH 73 Water 339 2.1 6.2
D6 (0 back ) 200 57 VL 73 Water 811 0.1 0.2
D6 (0 back ) 200 56 MH 73 Water 811 0.1 0.2

Piston engine-powered ﬁxed-wing aircraft (47–52 m/s)
8002 (90) 214 2.8 L 68 Oil 160 35.3 45.1

8002 (90) 214 2.8 H 68 Oil 160 35.3 45.1
D4-45 (45) 214 15 L 68 W ater 173 17.6 33.8
D4-45 (45) 214 13 H 68 Water 173 17.6 33.8
D6-46 (45) 214 28 H 68 Water 263 7.8 15.0
D8-46 (0 back ) 214 63 L 68 Water 340 2.0 6.0
D8-46 (0 back ) 214 65 H 68 Water 340 2.0 6.0
D8 (0 back ) 214 70 L 68 Water 546 0.7 2.1

D8 (0 back ) 214 67 H 68 Water 546 0.7 2.1
D6-46 (45) 214 30 L 82 Water 263 7.8 15.0
D6-46 (45) 214 29 L 68 Water 263 7.8 15.0
D6-46 (45) 214 30 L 68 Water 178 18.9 33.8
D6-46 (45) 214 30 L 68 Water 318 13.8 20.3
D6-46 (45) 214 33 L 68 Water 256 8.5 15.3
D6-46 (45) 214 35 L 68 Water 325 12.8 19.1

D6-46 (45) 214 30 L 68 Water 235 12.4 20.6
D4-45 (45) 214 16 L 68 Water 173 17.6 33.8
D4-45 (45) 214 16 L 68 Water 173 17.6 33.8
D4-45 (45) 214 14 L 68 Water 173 17.6 33.8
D8 (0 back ) 214 74 L 68 Water 546 0.7 2.1
D8 (0 back ) 214 69 H 68 Water 546 0.7 2.1
D8 (0 back ) 214 73 L 68 W ater 546 0.7 2.1

D6-46 (45) 214 30 L 68 Water 263 7.8 15.0
D6-46 (45) 179 32 L 68 Water 359 17.8 31.2
D8 (0 back ) 214 74 L 68 Water 546 0.7 2.1
D4-46 (45) 214 14 L 68 Water 173 17.6 33.8
D6-46 (45) 214 30 L 68 Water 263 7.8 15.0
D6-46 (45) 193 30 L 68 Water 200 16.3 26.6
D6-46 (45) 200 30 L 68 Water 241 10.8 18.8

8002 (90) 214 3.2 L 68 Oil 160 35.3 45.1
8003 (30) 200 5.1 L 68 Oil 178 28.6 40.4
Turbine engine-powered ﬁxed-wing aircraft

D6-46 (45) 214 36 L 68 Water 163 22.6 38.8
D8 (0 back ) 214 68 L 68 Water 413 3.2 6.5
D4-45 (45) 214 12 L 68 Water 107 49.2 69.9
D6-46 (45) 214 35 L 68 Water 163 22.6 38.8
D8 (0 back ) 214 72 L 68 Water 413 3.2 6.5

a
bVL ⫽ very low (1.6–1.8 m); L ⫽ low (2.2–2.9 m); MH ⫽ medium high (4.0–5.4 m); H ⫽ high (6.9–9.3 m).
Percent of wing semispan.

volume median droplet diameter, i.e., the diameter within the Veriﬁcation of application rates
droplet size spectrum at which half of the droplets by volume
are contained in larger droplets, and %vol ⬍ 141 ␮m is the The on-target application rates were established by careful
mixing of the required volumes (see Table 3) of the active
percentage of the spray volume contained in droplets with
diameter below 141 ␮m (considered by many to be close to ingredient tracers (diazinon,malathion—at10%ofcommercial
rates), carrier liquid (water or oil), and any adjuvants (surfac-
the droplet sizes more lik ely to drift under unfavorable con- tants/polymers). The application rate was established through
ditions [7]).
The treatments also included boom lengths of 69 and 82% calibration of the spraying system (number of nozzles, ﬂow
rate through nozzles, ﬂight speed) and effective swath width.
of the wing span since the spray release position relative to
the wing-tip vortices affects droplet movements. Boom length As a check in the ﬁeld, tank samples were tak en prior to and
following the application for analysis for tracer concentrations
expresses the percentage extent of nozzle positions across the and were frozen until analysis.
spray boom relative to the length of the aircraft wingspan or
helicopter rotor diameter. Spray release height treatments var-
Collectors
ied from 1.8 to 9.4 m above the ground. The use of oil as a
carrier for the ultralow volume applications, the effects of tank The selection of collectors for ﬁeld studies depends on

mix physical properties, and crop canopy effects on spray many issues such as suitability for collecting and extracting
movements were also studied. the tracers, ease of use, and representativeness for the sur- Annex 12

652 Environ. Toxicol. Chem. 21, 2002 A.J. Hewitt et al.

Distances were close together immediately downwind from
the application area because this area is where most of the

differences among treatments would occur and where most of
the driftable material would fall and are important in consid-
ering buffer zones, a potential regulatory use of the SDTF
data. Three collector stations were established 15.2 m apart,

at each distance perpendicular to the application area. A single
sampling station was also located at a distance of 30 m upwind
of the spray block to conﬁrm that drift does not occur in the
upwind direction and to check for any back ground contami-

nation. Since the closest collector to the edge of the ﬁeld was
7.6 m, meaningful data on deposition closer to the ﬁeld than
this cannot be inferred. The drift sampling lines were set up
to be perpendicular to the ﬂight line. Adjustments for devia-

tions from this direction during actual applications, including
considerations of effects on the most distant sampling stations,
are discussed in the model evaluation article in this series [12].
No account was tak en of possible contamination of the sam-
Fig. 1. Layout of test site for aerial ﬁeld studies showing ﬂight and
sampling lines and sample station locations from 8 to 792 m down- plers by tracer-loaded soil particles that might be blown by
wind. Although not shown here, a sample station was also located at the wind, which means that the deposition data might be slight-
a distance of 10 m upwind of the spray bloc. Four swaths were ﬂown ly higher than expected if this did occur for any of the appli-
on ﬁeld for each application. cations under higher wind speed conditions.

face(s) that are being simulated. Collection efﬁciency isrelated Sample handling
to the shape and dimensions of the collector with respect to Following the application of the standard and variable treat-
ments, the drift cloud was allowed to completely pass the
the drift particle ﬂow ﬁeld, the local wind speed, and the size
and velocity of the droplets in the spray cloud [17,18]. Com- furthest sampling stations prior to sample collection (calcu-
puter modeling indicates that turbulence intensity may also be lated based on droplet release height and wind speed and then
important for some conditions [19]. Droplet collection occurs doubled to give a maximum of 25 min after application). The
samples were then collected, sealed in clear plastic bags,
by impaction and sedimentation. Impaction predominates on
vertical surfaces, while sedimentation is the main mechanism placed on dry ice, and tak en to a freezer for storage and ship-
of collection by fallout onto horizontal surfaces. ment. At the analytical laboratory, malathion and diazinon
The SDTF reviewed the available techniques and selected tracer analytes were extracted from the alpha-cellulose col-
lectors and simultaneously analyzed by gas chromatography.
four types of collectors. Other reviews of ﬁeld drift sampling
techniques exist elsewhere (e.g., [20]). The primary collector
used in the development of the database and subsequent mod- Canopies
els was alpha cellulose (type GR512, Procter & Gamble, Cin- The SDTF ﬁeld studies involved applications over bare

cinnati, OH, USA), a cotton pulp product thick andstiffenough ground, representing worst case conditions for spray drift. The
to facilitate handling under ﬁeld conditions. The absorbent presence of a canopy would be expected to reduce drift as the
texture of the alpha-cellulose samplers enabled droplets to be droplets are intercepted by vegetation. Studying the effects of
captured while maintaining tracer stability and allowing efﬁ- crop canopy on drift can be difﬁcult due to the large variety

cient analytical extraction. Alpha cellulosesamplerswereﬁxed of vegetation types and structures (height, density, orientation,
horizontally on the ground at all collection sites. Each sampler etc). Two treatments involving a cotton canopy were included
consisted of a 1,000 cm 2 surface area. There were three of in the SDTF database only as a means of demonstrating that
these samplers at each downwind distance, separated by ap- canopy is a signiﬁcant factor in drift. The cotton canopy com-

proximately 15 m. The data from these collectors were a mea- prised 104-cm-tall plants in 76-cm rows. The plants were at
sure of deposition primarily by sedimentation, representative the green boll stage of development and provided afullcanopy.
of spray collection on ground and aquatic surfaces. Being ﬁ- Two cotton canopy treatment comparisons were included in
brous in nature, the alpha-cellulose samplers collect some ma- the study. One treatment involved a four-swath application

terial by impaction, though the primary collection is sedi- starting at the edge of the cotton ﬁeld (outside treatment). The
mentation deposition. second treatment involved a four-swath application beginning
59 m (four swaths) in from the edge of the ﬁeld (inside treat-
Sampling layout ment).

All studies were set up with distinct application and off- Atomization studies
target drift areas. The American Society of Agricultural En-
gineers standard procedure for drift studiesS-561[21]suggests The measurement of droplet size spectra under ﬁeld con-
that the application length should be at least 0.6 times the ditions introduces many sources of variability and uncertainty

length of the collection area. The ratio in the SDTF aerial ﬁeld compared with the controllable and easily monitored environ-
studies was 0.8 (application length ⫽ 650 m; drift sampling ment of a wind tunnel. Field assessments of droplet size typ-
area ⫽ 850 m length). ically involve collection of a sample of the spray cloud and
The layout of the ﬁeld sites is shown in Figure 1. Sampling subsequent measurement of the droplet sizes [22,23]. Such

stations were located at 7.6, 15.2, 23, 31, 45, 61, 91, 137, 183, techniques are intrusive and may not sample the smallest drop-
305, 549, and 792 m downwind of the edge of the spray block . lets efﬁciently. Furthermore, the droplets are measured afterAnnex 12

Spray Drift Task Force database for aerial applications Environ. Toxicol. Chem. 21, 2002 653

evaporative and other effects may have caused them to change Physical property studies
in size following emission through the nozzle. Some success
For database and modeling developments, the SDTF also
has been found measuring droplet size on aircraft sprayers measured droplet size spectra for combinations of application
using optical array probes [24]. However, such measurements variables and liquid physical properties encompassing a wide
are relatively difﬁcult, expensive, and time consuming com-
pared with using a wind tunnel to simulate the sprayer. Highly range of possible aerial spray applications. These data, in con-
junction with the model, yield drift data for a much wider
accurate laser-based instruments are used to measure droplet range than those of typical or normal agricultural tank mixes.
size in wind tunnels. Wind tunnels have been successfullyused The physical properties of agricultural tank mixes canaffect
for several decades at research facilities around the world to
make such measurements. Previous studies have shown good drift mainly through their effect on the initial droplet size
spectra emitted from the sprayer and through subsequent de-
agreement between droplet size spectra data measured in wind creases in droplet size from evaporation. The SDTF developed
tunnels and on ﬁxed-wing aircraft (e.g., [24]). a database on physical properties for the tank mixes that were
It was assumed that generic phenomena such as droplet size sprayed in the ﬁeld and atomization studies. Atomization was
effects on drift from aerial applications can be covered for a
shown to be related to several physical property parameters
wider range of nozzles than were tested in the ﬁeld. At the that can be measured using various techniques. These included
initiation of the SDTF studies, disc-core nozzles were most the dynamic surface tension at surface lifetime ages represen-
common. However, during the course of the SDTF studies, a tative of the atomization process for typical hydraulic agri-
deﬂector nozzle (CP nozzle, CP Products, Mesa, AZ, USA)
cultural nozzles (e.g., 20 ms) and shear and extensional vis-
was introduced to the mark et and quick ly became widely used. cosity. Dynamic surface tension was measured using a max-
Therefore, the SDTF conducted droplet size measurements for imum bubble pressure technique [27]; shear and extensional
this nozzle type to provide a more complete database. By viscosity were measured using a Rheometrics RFX instrument
knowing the droplet size spectrum for any aerial nozzle, drift
[28] (this instrument is no longer being manufactured). Shear
potential can be predicted from the existing database and mod- viscosity was assessed at shear rates up to 10,000/s, with low
els. In cases where other factors inﬂuence drift, e.g., with and high shear viscosity being represented by shear rates of
applications using electrostatic or wing-tip modiﬁcation sys- 1 and 8,000/s, respectively. Extensional viscosity was repre-
sented by the maximum inertia-corrected value measured at
tems, additional tests may be needed to demonstrate drift po-
tential. strain rates up to 20,000/s. The ratio of extensional to shear
An underlying objective of the SDTF atomization studies viscosity, referred to as effective Trouton ratio, was an appro-
was to evaluate a wide range of droplet size spectra through priate way to represent viscous forces for modeling atomiza-
tion/physical property relationships [29].
the use of a range of typical commercial practices. Within each
aircraft speed, the different spray volumes and droplet size spec- Evaporation rates were measured using a video-imaging
tra were achieved by changing nozzle type, oriﬁce size, and/or technique that assessed the rate of change of droplet mass over
orientation. The nozzle types, application volume rates, and time for different conditions (e.g., temperature and relative
humidity, formulations, and droplet diameters [30,31]).
summary droplet size spectra statistics are shown in Table 3.

Equipment SUMMARY OF RESULTS

Aerial ﬁeld studies
The SDTF atomization studies were conducted using wind Calculation of application rate. Ideally, the tank mix sam-
tunnels at New Mexico State University (Las Cruces, NM,
USA) and at SpraySearch, Werribee, Australia. The SDTF at- ples would agree with the application volume rate established
omization studies measured droplet size spectra of simulated from the tank mix preparation. However, there was a discrep-
ancy between these two values. For malathion, the mean pre-
aerial sprays using Malvern (Malvern Instruments, Malvern, and postapplication tank mix samples were 85 to 106% of the
Worcestershire, UK) and Sympatec (Princeton, NJ, USA) laser target concentrations from the mixing recipes. For diazinon,
diffraction particle size analyzers in wind tunnels. Details of
the measurement procedures are described elsewhere [25]. the mean was 91 to 108%. Although there were differences
in tank sample concentrations between studies and treatments,
Representative sampling for the nonuniform sprays was there was no signiﬁcant difference between tracer concentra-
achieved using a continuous scan technique or multiple mea- tion rates for the pre- and postapplication samples within a
surements at different heights within the spray plume [26].
The wind tunnel studies included airstream velocities rep- given treatment. This supports the concept that there was no
degradation of the tracers during application. The difference
resenting those encountered in applications with helicopters between the target recipe and tank sample tracer application
(18–36 m/s) and ﬁxed-wing piston engine- (36–54 m/s), and rates could be due to several factors.
turbine engine- (54–72 m/s) powered aircraft. The major noz-
Since the tank mixes included emulsiﬁable concentrate for-
zle types used for commercial applications and tested in the mulations, the active ingredient was held in suspension and
wind tunnel studies include simplex swirl (disc-core), jet(solid subject to a somewhat heterogeneous mixture. Study protocols
stream), hollow and full cone, ﬂat fan, deﬂector, rotary cage, speciﬁed that the tank mixture must be continually agitated.
rotary drum, spinning disc, air shear, and preoriﬁce twin ﬂuid
However, it is possible that the small sample volumes (10 ml)
(including air inclusion and air induction). Several different relative to the total tank mix (110 L) may not have been totally
designs and sizes were tested for many of these nozzle types. representative of the entire tank mix. Prior to analysis, the
The measured droplet size spectra wereused to developmodels samples were serially diluted, which can magnify (or com-
for predicting droplet size and drift for aerial spray applica- pound) small deviations. Finally, the exact amount of active

tions. The study ﬁndings were too numerous to be compre- ingredient withdrawn is subject to variation from the type of
hensively reported here, so only major ﬁndings are discussed. pipette used. During the initial phases of testing, the SDTF Annex 12

654 Environ. Toxicol. Chem. 21, 2002 A.J. Hewitt et al.

Fig. 2. Deposition with distance from edge of spray blo. Example
for standard applications with wind speeds of 9 to 11 m/s. Fig. 3. Spray deposition against downwind distance from edge of
spray block for different tracers.

determined that pipettes or syringes with small inlet oriﬁce
diameters could produce a bias toward the withdrawal (sam- cluded rotary-wing aircraft and piston and turbineengine-pow-
pling) of aqueous solution. ered ﬁxed-wing aircraft. These were operated at increasingly
The actual application rates were based on the measured high speeds for the SDTF studies, in the respective order 28,
48, and 68 m/s mean ﬂight speed. The increasing air shear
average ﬂight speed and ﬂow rate, lane separation of 13.7 m
as the swath width, and a tank mix concentration based on the associated with these higher speeds results in ﬁner sprays. This
ﬁeld mixing recipe. A data logger was installed on the aircraft can be partly offset through the selection of different nozzle
to monitor these parameters. Aircraft ﬂight speed was mea- types and uses such as lower operational pressure that can

sured using a radar gun. increase droplet size. Figure 4 shows the off-target deposition
Deposition. This section describes deposition data on hor- that was measured in the ﬁeld for these three aircraft types.
izontal alpha-cellulose collectors. It should be noted that the All of these applications were made using D6-46 or D4-46
deposition rates measured for applications with sprays ﬁner disc-core nozzles with spray pressure around 200 kPa and a

than coarse and applications at relatively high wind speeds medium-volume application rate. As explained above, the
were higher in the SDTF studies than would be expected in higher speed applications produced higher downwind depo-
real-world situations because the SDTF data were not adjusted sition rates primarily because they produced ﬁner sprays. The
sprays showed droplet size spectra using D6-46 nozzles of,
for swath adjustment, which is a common practice in most
aerial applications [14]. Swath adjustment can, however, be for high-speed application, D v0.5 163 ␮m and %vol ⬍ 141␮m
applied with drift assessments using the AgDRIFT 威 model. ⫽ 38.8%; for medium-speed application, D v0.5 263 ␮m and
Overall, the SDTF results were consistentwithobservations %vol ⬍ 141␮m ⫽ 15.0%; and for low-speed application,

in previous drift studies [1]. Off-target deposition rates were
always highest within a relatively short distance of the edge
of the application area and decreased rapidly with distance
(Fig. 2). This ﬁgure is a set of standard case applications in

a narrow range of wind speeds (9–11 m/s) and illustrates the
declining deposition with distance from the edge of the ﬁeld
(distance ⫽ 0 m) as droplets deposit by sedimentation (and,

to a much lesser degree for horizontal collectors, impaction)
on surfaces. The wide range of deposition values at each mea-
surement distance shown in Figure 2 cannot be directly ex-
plained by any of the variables observed during the trials. This

level of variability is consistent with variability observed in
other ﬁeld trials.
The selection of tracer, diazinon or malathion, did not have
a large effect on deposition rate measurements and so was not

a major source of variability, as shown on Figure 3. However,
diazinon did generally show lower deposition rates beyond
300 m from the edge of the ﬁeld. This is probably due to
volatile losses of diazinon at far-ﬁeld distances due to its great- Fig. 4. Mean deposition rates for applications with different aircraft
(high-speed ﬁxed-wing producing ﬁne spray, medium-speed ﬁxed-
er volatility than malathion. wing producing medium spray, and low-speed rotary-wing producing
Flight speed. Aircraft ﬂight speed is one of the most im- coarse spray) with medium volume rate. Rotary-wing aircraft data
portant variables affecting droplet size. Different aircraft types
only plotted to 200 m because deposition beyond 200 m was less than
can operate at different speeds. The SDTF ﬁeld studies in- the level of quantiﬁcation.Annex 12

Spray Drift Task Force database for aerial applications Environ. Toxicol. Chem. 21, 2002 655

Fig. 5. Deposition rates for different spray release heights (2.4, 5.2,
and 9.4 m above ground) with low volume rate, ﬁxed-wing aircraft Fig. 6. Deposition rates for different boom length (84 and 69% of
application. wing semispan) with medium volume rate, ﬁxed-wing aircraft appli-
cation.

D ⫽ 339 ␮m and %vol ⬍ 141␮m ⫽ 6.2%. Using the British position for different wind speeds for the standard application.
v0.5 Off-target deposition increased with higher wind speeds due
Crop Protection Council (BCPC) [32] and American Society
of Agricultural Engineers S-572 [33] spray classiﬁcation to droplet transport to greater lateral distances prior to sedi-
schemes, these were ﬁne, medium, and coarse sprays, respec- mentation deposition. The wind speeds were measured at a
tively. Data for deposition with the rotary-wing aircraft ap- height of 3 m above the ground.
Canopy. Two cotton canopy treatment comparisons had
plication at distances beyond 200 m were not plotted because
recovery rates were lower than the level of quantiﬁcation, been included in the drift studies. One treatment involved a
indicating extremely low deposition rates at these far-ﬁeld dis- four-swath application starting at the edge of the cotton ﬁeld
tances. (outside treatment). The second treatment involved a four-
swath application beginning 59 m (four swaths) in from the
Spray release height. Sprays are applied in the ﬁeld at re-
lease heights that are appropriate for obtaining effective spray edge of the ﬁeld (inside treatment). There was no signiﬁcant
coverage in ﬂight swaths while maintaining a safe distance difference in downwind deposition between the no-canopy
from the ground. For a low application volume rate with the (bare ground) standard treatment and the outside treatment(see
above). However, downwind deposition appeared to be re-
ﬁxed-wing piston engine aircraft, drift potential at distances
up to 200 m from the edge of the sprayed ﬁeld increased with duced by a canopy when the tracer was applied in the inside
greater spray release height (Fig. 5) due to the greater fall treatment scenario in which drift moved across and through
four swaths of cotton canopy (Fig. 8). It should be noted that
distance and opportunity for wind displacement prior to sed- these results do not reﬂect downwind deposition with swath
imentation deposition. At distances beyond 200 m, the greatest
release height always produced the highest off-target deposi- adjustment (offsetting the aircraft position to compensate for
tion rates. Beyond 200 m, the lowest release height deposition cross wind). If appropriate swath adjustment had been applied,
then the canopy may have intercepted a relatively greater
rate was not signiﬁcantly different from the medium release
height.
Boom length. The movement of aircraft tends to cause a
roll-up of air into trailing vortices from each wing or rotor tip.

If droplets become entrained in the vortices, they may be dis-
placed vertically and laterally, often increasing the potential
for drift. Boom length can be adjusted relative to the wing
semispan to offset this effect. Figure 6 shows the slight de-

crease in off-target deposition when the boom length was de-
creased from 84 to 69%. The missing data point for the 84%
boom length at a distance close to 600 m reﬂects the fact that
the deposition rate for this location was lower than the level

of quantiﬁcation. The data shown on Figure 6 are for an ap-
plication of a medium spray at a medium ﬂight speed (piston
engine ﬁxed-wing aircraft). Further decreases might be ex-
pected for ﬁner sprays and shorter boom lengths than 69%,

based on model predictions using AgDRIFT 威 [34,35], which
supports the suggestion that shorter boom length is important
in practical drift management with aerial spray applications.
Wind speed. Wind speed is an important meteorological
Fig. 7. Deposition rates for different wind speed ranges (wind speed
variable affecting spray drift potential. Figure 7 shows de- measured at 10 ft. above ground) with standard treatment conditions. Annex 12

656 Environ. Toxicol. Chem. 21, 2002 A.J. Hewitt et al.

Fig. 9. Examples of cumulative volumetric droplet size spectra with
same D v0.5volume median diameter) values but differentdistributions
Fig. 8. Deposition rates for application with and without cotton can- for different nozzle types spraying water.
opy. Same equipment setup with and without canopy—piston engine
ﬁxed-wing aircraft, Dv0.5 263 ␮m and %vol ⬍ 141 ␮m ⫽ 15%.
rate, and higher liquid ﬂow rate. A spinning disc atomizer

produced very narrow droplet size spectra (relative span ⫽
0.42–0.48) compared with hydraulic nozzles, which generally
produced relative span values ⬎1. Relative span is a useful
amount than the no-canopy treatment. These results also prob-
ably do not represent all canopy types. Different trends might parameter for describing the width of a droplet size spectrum
be expected with different canopy types and locations. by volume, with a smaller value indicating that the droplets
With no swath adjustment, the cotton canopy only slightly are contained in fewer size classes. It is calculated by ( D v0.9
⫺ D )/D , where D , D , and D are the respective
decreased downwind ground deposition when applied near the v0.1 v0.5 v0.9 v0.5 v0.1
downwind edge of the canopy. However, it reduced downwind droplet diameters at which 90, 50, and10%ofthesprayvolume
exposure from airborne droplets. There was a substantial de- is contained in droplets with smaller diameter. Most of the
trends observed in SDTF studies agreed with those reported
crease in ground deposition for treatments applied further in-
side the cotton canopy. The results also indicate that the worst in the literature (e.g., rotary atomizer tests [36] and hydraulic
case drift scenario is associated with low-growing vegetation nozzle tests [37]).

or no vegetation, the standard condition for most of the SDTF Physical properties studies
applications. It should be noted that these canopy effect treat-
ments were very limited in replication and scope and so only Liquid physical properties were not as important as appli-
illustrate general trends. cation variables for determining droplet size. The SDTF stud-

Atomization. With a few noted exceptions, the droplet size ies had investigated dynamic surface tension (at very short
spectra produced by the hydraulic nozzles generally became surface ages) and shear and maximum extensional viscosity.
coarser with lower airstream velocity, larger oriﬁce diameter With a few exceptions, sprays tended to become coarser with
higher dynamic surface tension, extensional viscosity, and
(within a nozzle type), lower liquid pressure(exceptwithsolid-
stream jet nozzles at small angles to airstream), and lower shear viscosity. Droplet size produced by many non-Newto-
nozzle angle relative to the airstream. Solid-stream nozzles nian test substances containing a polymer was sensitive to
and some nozzles described by the manufacturers as being low agitation rates. The type and rate of agitation can be important

drift produced relatively coarse sprays. Examplesofthedroplet for such substances [38]. Droplet size trends for the SDTF
size spectra with the same D v0.5or different nozzle types with- sprays have been summarized and conﬁrmed elsewhere [39].
in the thousands of atomization data sets are shown on Figure Evaporation was found to occur at a constant rate within a
given temperature/relative humidity regime. The only effect
9. These were data sets that could be closely matched for liquid
ﬂow rate. The data show that substantial differences in droplet of physical properties on droplet evaporation was the ﬁnal
size spectra occurred with different nozzle types. Solid-stream droplet size achieved (i.e., the nonvolatile fraction). More dis-
cussion of evaporation effects from the SDTF database is pro-
nozzles generally produced the coarsest sprays (largest drop-
lets), and the full cone nozzles produced relatively ﬁne sprays vided elsewhere [30,31,40].
(small droplets). Further information on the SDTF atomization and physical
The sprays produced by ﬂat fan nozzles became coarser property studies is provided in the following publications. The

(general increase in droplet size) with narrower spray angle. SDTF atomization study designs and measurement techniques
Spray angle is the angle formed by the spray plume as it leaves were described earlier [25,39,41]. The results are summarized
the nozzle. Going from 110 to 80, 65, and 40 ⬚ spray angles, in several articles [39,42]. The analysis of the data to develop
atomization models is explained [29,43,44], and the inclusion
the ﬂat fan nozzles produced coarser sprays. A comparison of
ﬂat fan and deﬂector nozzle tips produced by different man- of the atomization data and models within the AgDRIFTmodel
ufacturers for similarﬂowand sprayplumeanglespeciﬁcations is discussed [45].
showed that some sprays were similar while others differed.
DISCUSSION AND CONCLUSIONS
Differences, where observed, were due to differences in the
nozzle designs. The sprays produced by the rotary atomizers The SDTF ﬁeld drift studies and associated atomization
became coarser with lower airstream velocity, lower rotation and physical property studies showed that spray drift is af-Annex 12

Spray Drift Task Force database for aerial applications Environ. Toxicol. Chem. 21, 2002 657

fected by many variables associated with the application, drop- ﬁciency of spray droplets in turbulent air. ASAE Paper 941503.
let size spectrum, meteorological conditions, and spray release Proceedings, American Society of Agricultural Engineers Sym-
posium, Atlanta, GA, pp 1–8.
position. Drift tended to be greater with the application of 20. Miller PCH, Walk late PJ, Mawer CJ. 1990. A comparison ofspray
smaller droplets, greater release heights, greater wind speeds, drift collection techniques.Proceedings, British Crop Protection
and greater boom lengths. The ﬁndings of the SDTF studies Council Brighton Conference, Weeds, Brighton, UK, pp 669–
676.
were very extensive. More information on the studies and
detailed description of the protocols and techniques are in- 21. American Society of Agricultural Engineers. 1998. Procedure for
measuring drift deposits from ground, orchard, and aerial spray-
cluded in other reports [46,47]. The results have been used to ers. Standard S561. St. Joseph, MI.
develop and validate modeling tools that are described in the 22. Hewitt AJ, Megenasa T. 1993. Distribution of a pyrethroid in-
two other articles in this series [11,12]. secticide within grass and maize canopies for the control of Spo-
doptera exempta larvae. Crop Protec 12:59–62.
23. Mount GA, Pierce NW. 1972. Droplet size of ultra low volume

Acknowledgement —The authors wish to ack nowledge the contribu- ground aerosols as determined by three collection methods. Mosq
tions made by professional aerial applicators and the SDTF, U.S. EPA, News 32:568–569.
California Department of Pesticide Regulation, and other reviewers 24. Yates WE, Cowden RE, Ak esson NB. 1983. Nozzle design in-
of the manuscript. The SDTF is grateful to the numerous scientists ﬂuence on uniformity of droplet size spectrums from agricultural
who provided advice on the design and conduct of the drift studies. aircraft. Trans ASAE 26:1633–1637.
These include, but are not limited to, the following experts: W.E. 25. Hewitt AJ, Sanderson R, Huddleston EW, Ross JB. 1994. Ap-
Yates, L.F. Bouse, E.W. Huddleston, D.E. Kuhlman, F. Hall, and D. proaches to measuring atomization droplet size spectra usinglaser

Reichard. diffraction particle size analyzers in wind tunnels.Proceedings,
ILASS 94, May 31–June 3, Seattle, WA, USA, pp 109–110.
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namic surface tension by the maximum bubble pressure method.
Qual 25:1095. Colloid Polym Sci 272:731.
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3. Yates WE, Ak esson NB, Coutts HH. 1966. Evaluation of drift breakup. Proceedings, ILASS Americas 94, May 31–June 3,
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4. Yates WE, Ak esson NB, Coutts HH. 1967. Drift hazards related 29. Hermansk y CG. 1998. A regression model for estimating spray
quality from nozzle, application and physical property data. Pro-
to ultra-low-volume and diluted sprays applied by agricultural ceedings, ILASS Americas 98, May 17–21, Sacramento, CA,
aircraft. Trans ASAE 10:628–638. USA, pp 60–64.
5. Yates WE, Ak esson NB, Cowden RE. 1974. Criteria for mini-
mizing drift residues on crops downwind from aerialapplications. 30. Tesk e ME, Hermansk y CG, Riley CM. 1997. Evaporation rates
Trans ASAE 17:627–632. of agricultural spray material at low relative wind speeds. At-
6. Ware GW, Cahill WP, Estesen BJ. 1974. Pesticide drift: Aerial omization and Sprays 8:471–478.
applications comparing conventional ﬂooding vs. raindrop noz- 31. Riley CM, Sears II, Picot JJC, Chapman TJ. 1995. Spray Drift
zles. Econ Entomol 68:329–330. Task Force droplet evaporation studies. In Hall FR, Berger PD,
Collins HM, eds, Pesticide Formulations and Application Sys-
7. Hewitt AJ. 1997. The importance of droplet size in agricultural tems, Vol 14. STP 1234. American Society for Testing and Ma-
spraying. Atomization & Sprays 7:235–244. terials, Philadelphia, PA, pp 225–236.
8. Matthews GA. 1992. Pesticide Application Methods. Longman
Scientiﬁc and Technical, New York , NY, USA. 32. Southcombe ESP, Miller PCH, Ganzelmeier H, Van de Zande JC,
9. Crabbe RS, McCooeye M, Mick le RE. 1994. The inﬂuence of Miralles A, Hewitt AJ. 1997. The International British Crop Pro-
atmospheric stability on wind drift from ultra-low-volume aerial tection Council (BCPC) spray classiﬁcation system including a
forest spray applications. J Appl Meteorol 33:500–507. drift potential factor. Proceedings, British Crop Protection Con-
ference, Brighton, UK, pp 371–380.
10. Maybank J, Yoshida K, Grover R. 1978. Spray drift from agri- 33. American Society of Agricultural Engineers. 1999. Spray nozzle
cultural pesticide applications. J Air Pollut Control Assoc 28: classiﬁcation by droplet spectra. ASAE S-572. St. Joseph, MI.
1009–1014.
11. Tesk e ME, Bird SL, Esterly DM, Curbishley TB, Ray SL, Perry 34. Hewitt AJ, Valcore DL, Esterly D, Tesk e ME. 1997. What If drift
SG. 2002. AgDRIFT 威: A model for estimating near-ﬁeld spray mitigation scenarios with the AgDRIFT Model. ASAE Paper
drift from aerial applications. Environ Toxicol Chem 21:659–671. 971073. American Society of Agricultural Engineers, St. Joseph,
12. Bird SL, Perry SG, Ray S, Tesk e ME. 2001. Evaluation of MI.
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boom length effects for drift minimization. Trans ASAE 41:545–
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13. Hewitt AJ, Valcore DL, Barry T. 2001. Analyses of equipment, 551.
meteorology and other factors affecting drift from applications 36. Hewitt AJ. 1993. Droplet size spectra produced by air-assisted
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system and recirculation on the atomization ofsprayformulations.
14. Kidd FA. 1994. Spray Drift Task Force survey of aerial appli-
cators. SDTF Report L92-001. MRID 43485601. U.S. Environ- In Bode LE, Chasin DJ, eds, Pesticide Formulations and Appli-
mental Protection Agency, Ofﬁce of Pesticide Programs, Wash- cation Systems, Vol 11. STP 1112. American Standards for Test-
ington, DC. ing and Materials, Philadelphia, PA, pp 193–205.
15. Snedecor GW, Cochran WG. 1989. Statistical Methods. Iowa 39. Hewitt AJ, Valcore DL, Bryant JE. 1996. Spray Drift Task Force
State University Press, Ames, IA, USA. atomization droplet size spectra measurements. Proceedings, IL-
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17. May KR, Clifford R. 1967. The impaction of aerosol particles on 2001. Droplet evaporation corrections for aerial spray drift mod-
cylinders, spheres, ribbons and discs. Annal Occup Hyg 10:83– eling. Proceedings, ILASS Americas 2001, Dearborn, MI, USA,
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18. Spillman JJ. 1984. Spray impactions, retention and adhesions: An 41. Hewitt AJ, Valcore DL. 1998. The measurement, prediction and
introduction to basic characteristics.Pestic Sci 15:97–106. classiﬁcation of agricultural sprays. ASAE Paper 981003. Amer-
19. Zhu H, Reichard DL, Fox RX, Brazee RD. 1994. Collection ef- ican Society of Agricultural Engineers, St. Joseph, MI. Annex 12

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42. Hewitt AJ, Hermansky C. 1997. Effect of liquid properties on AgDRIFT 威 model for aerial application from helicopters and

spray performance. Proceedings, Chem Show, New York, NY, ﬁxed-wing aircraft. Proceedings, Envirotox, Environment Aus-
USA, pp 362–364. tralia, Canberra, pp. 121–129.
43. Hewitt AJ, Hermansky C, Valcore DL, BryantJE. 1997.Modeling 46. Johnson DR. 1995. Drift from applications with aerial sprayers:
atomization and deposition of agricultural sprays. Proceedings, Integration and summary of 1992 and 1993 ﬁeld studies. Study
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44. Esterly DM. 1998. Neural network analysis of Spray Drift Task 47. Johnson DR. 1996. Spray Drift Task Force ﬁeld testing protocol
Force DROPKICK II TM. ASAE Paper 981014. American Society and techniques. Report T95-004. MRID 44708171. U.S. Envi-
of Agricultural Engineers, St. Joseph, MI. ronmental Protection Agency, Ofﬁce of Pesticide Programs,
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C. N. Boutin, C. Elmegaard and C. Kjaer, “Toxicity Testing of Fifteen Non-crop Plant Species
with Six Herbicides in a Greenhouse Experiment: Implications for RiskAssessment”, in
Ecotoxicology. 13:349–369 (2004) Annex 13

Ecotoxicology, 13, 349–369, 2004
Ó 2004 Kluwer Academic Publishers. Manufactured in The Netherlands.

Toxicity Testing of Fifteen Non-crop Plant Species with Six Herbicides

in a Greenhouse Experiment: Implications for Risk Assessment

C. BOUTIN, * N. ELMEGAARD AND C. KJÆR 2
1National Wildlife Research Centre, Canadian Wildlife Service, Environment Canada, 1125 Colonel

By Drive (Raven road), Carleton University, Ottawa, Canada K1A 0H3
2National Environmental Research Institute, P.O. Box 314, Vejlsovej 25, DK-8600 Silkeborg,

Denmark

Accepted 21 May 2003

Abstract. Estimation of risk to plants not targeted by herbicides when used in agricultural or forestry
situations requires appropriate data on multiple species. Currently, many questions remain unresolved as to
the adequate type and number of species to be tested. This paper presents the result of a unique greenhouse

experiment where testing was performed with 15 non-crop plant species sprayed with 6 herbicides. The
herbicides were chosen because of their diﬀerent modes of action and because they are widely used in
several countries. The plants favoured were species commonly found in ﬁeld margins of Europe and/or

North America. This dataset (called thereafter Danish/Canadian) was compared to the crop species that
had been submitted to the US EPA for the same herbicides. In general, the selected plant species in the
Danish/Canadian database were easy to grow and maintain in the greenhouse. The Danish/Canadian

plants were overall more sensitive than the species tested in the US EPA data, yielding to a 5% protection
threshold (HC5 (50) that was always more conservative. There was a large variability in plant responses
among herbicides. Recommendations are provided on species that should and should not be used for risk

assessment of non-target plants.

Keywords: terrestrial plants; herbicide toxicity; risk assessment; pesticide regulation; guidelines

Introduction (Schwinn, 1988). In Canada and Denmark, 70–
80% (volume) of all pesticides used are herbicides.

Pesticides are increasingly used in developed (Statistics Canada, 1992; Miljøstyrelsen 2002). In
countries where modern intensive agriculture Canada a threefold increase in herbicide use has
requires that productivity is optimised; in general, been observed since the mid-seventies (Statistics

pesticide sales have continued to rise worldwide Canada, 1992).
(Pesticide company proﬁts – 1998, panup- Habitats adjacent to cultivated ﬁelds, although
[email protected]). North America and Europe not targeted during application, may be aﬀected by

are the predominant market for herbicides pesticides. This exposure is likely to occur through
*To whom correspondence should be addressed: direct overspray (mainly when applied by aircraft),
through spray drift from application on target
Tel.: 613-998-0493; Fax: 613-998-0458;
E-mail: [email protected] crops to adjacent wildlife habitats, and throughAnnex 13

350 Boutin et al.

runoﬀ or washoﬀ. Pesticides can travel consider- son, 1990; Dennis and Fry, 1992; Rodenhouse and
able distances with aerial equipment, e.g. 500 m Best, 1994; Elmegaard, et al., 1999). In countries

downwind (Conacher and Conacher, 1986; Davis and areas where most of the land is devoted to
and Williams, 1990). With ground equipment, it farming, e.g., Denmark, south-eastern Canada
has been estimated that under certain conditions, and the Canadian prairies, recurrent adverse her-
more than 10% of herbicide application rates can bicide eﬀects on habitats associated with agricul-

drift from a single swath, from the point of appli- ture become signiﬁcant.
cation to adjacent non-target habitats (Nordby and Risk assessment of herbicide phytotoxicity,
Skuterud, 1975; Maybank et al., 1978). Low doses apart from exposure evaluation, requires appro-

of herbicides aﬀecting plants have been docu- priate data on the toxicity of herbicides to a num-
mented from nonpoint sources (Felsot et al., 1996) ber of plant species. In Denmark, risk assessment
or from vapour drift (Poster, 1986). Some studies for terrestrial plants is not a part of the current
suggested that many agricultural pesticides are legislation. In Canada and the USA, data on 6 to

rapidly lost from ﬁelds by processes such as vola- 10 crop species are submitted to regulators for risk
tilisation and plant evapo-transpiration. Herbi- assessment of non-target crops or other non-target
cides used throughout an area may then become plants that ought to be protected within agroeco-

entrained in local convective clouds, and are re- systems. In some countries, eﬃcacy data for weed
distributed by rainfall over the agricultural land- and crop species are provided to pesticide regula-
scape (Al-Khatib et al., 1992). tors as part of a readily available package, but
Many insecticides, and to a lesser extent fungi- largely only qualitative endpoints have been mea-

cides, are acutely toxic to animals (Thomson, sured (Boutin and Rogers, 2000; Fletcher, et al.,
2000, 2001). In contrast, the most prominent 1985). The question as to whether or not the rec-
impact of herbicides is undoubtedly through ad- ommended surrogate species in current guidelines

verse lethal eﬀects on plants, by changing plant (Holst and Ellwanger, 1982; Organisation for
species composition and diversity, or sublethal Economic Co-operation and Development, 1984)
impact by modifying plant development, growth represent an adequate safeguard for environmental

and morphology. (Boutin, 1999). Most herbicides protection against herbicide impact is debatable. If
may adversely impact wildlife through reduction conservation of native species (and other plants
of food sources and diversity and by modifying important for wildlife) is the goal, then ecologically
cover needed to survive and reproduce (Freemark relevant test species/groups should be favoured,

and Boutin, 1995). Low doses of herbicides may unless it can be demonstrated (and this has not
aﬀect host plant quality to herbivores (Kjær and been established so far) that crop species are rep-
Elmegaard, 1996). A community of plants com- resentative of noncrop species found in nature.

posed largely of grass crops (maize, wheat, barley, The objectives of this study were (1) to investi-
oats) and grass weeds (Bromus, Elytrigia, Setaria, gate the pattern of sensitivity of several types of
Echinochloa, Poa, Panicum, etc.) has become the plant species to six herbicides with diﬀerent modes
norm with modernisation of agriculture where of action, and (2) to explore the feasibility of using

herbicides primarily eliminate broad-leaved species non-crop plants commonly found in ﬁeld bound-
in already impoverished monotypic cultures of aries as test species for herbicide risk assessment.
intensive farming areas. Modiﬁcations in plant Data were gathered on 15 non-crop plant species

species composition of noncrop ﬁeld edges sprayed tested with six herbicides, and results were com-
with herbicides has been documented in Europe pared to data required by the US EPA regulatory
(Marrs et al., 1989) and more recently in Canada agency and the Pest Management Regulatory

(Jobin et al., 1997; Boutin and Jobin, 1998). In the Agency in Canada.
latter studies more annual grass species of weedy
propensity were inventoried in habitats adjacent to
herbicide treated ﬁelds. These may have a marked Material and methods

eﬀects on invertebrate populations (Lagerlo¨ et al.,
1992) with consequences for vertebrate wildlife The experimental part was performed in the green-
(Potts, 1970; Potts, 1985; Sotherton and Robert- house at the National Environmental Research Annex 13

Terrestrial Plant Sensitivities to Six Herbicides 351

Institute at Silkeborg, Denmark, between August open regularly disturbed habitats. Two species

and December 1998. grow in wet areas, Inula helenium and Mentha
spicata. The overall morphology of the diﬀerent

Plants selected species varies considerably. Seed size was signiﬁ-
cantly related to growth rate (r ¼ )0.578,

Fifteen plant species were selected for the experi- p ¼ 0.024) with a few notable exceptions (Table 1).

ment (Table 1), ﬁve species from the Asteraceae Seed size and early growth rate may be criteria to
family (daisy family), four from the Lamiaceae take into account for selecting non-crop species to

family (mint family), two from the Polygonaceae be tested. One species, Polygonum convolvulus,
family (buckwheat family) and the rest from four needed vernalisation to germinate. Because they

other families. Except for Polygonum convolvulus also needed light to germinate, all species were

and Sinapis arvensis, which were collected in sown at the soil surface in large trays and later
Denmark, all species were ordered from seed were transplanted into individual 11 cm pots at

suppliers in Canada or the US. Among the 15 early seedling stage. Mortality rate was very low at

species tested, seven were short-lived species and transplanting. The soil used during the experiment
eight were perennial species (Table 1). Most spe- was a commercial potting soil with high peat

cies are native from Europe, commonly found in content.

Table 1. Characteristics of the plant species selected for the experiment (P = perennial, A = annual, B = biannual, WA = winter
annual)

Days

English Average between
Common seed size sowing to
Species names Family Life cycle Origin Habitat (mg/seed) 2 leaf-stage

Bellis perennis L. English daisy Asteraceae P North Europe Lawn, open 0.17 23
habitats

Centaurea cyanus L. Cornﬂower Asteraceae A or WA Mediterranean Fields, roadsides 4.93 11
Inula helenium L. Elecampane Asteraceae P Europe Moist, disturbed 1.29 18
sites

Rudbeckia hirta L. Black-eyed Asteraceae B or P North Disturbed habitats 0.29 23
Susan short- America
lived (Prairies)

Solidago Canada Asteraceae P North America Pasture, secondary 0.08 22
canadensis L. goldenrod succession
Leonorus cardiaca L. Motherwort Lamiaceae P Asia Open habitats 0.75 19

Mentha spicata L. Spearmint Lamiaceae P Europe Moist habitats 2.21 25
Nepeta cataria L. Catnip Lamiaceae P Eurasia Disturbed habitats 0.54 17.5
Prunella vulgaris LSelf-heal Lamiaceae P Europe & Disturbed habitats 0.58 20

North America
Polygonum Wild Polygonaceae A Europe Roadsides, open 7.68 15
convolvulus L. buckwheat habitats

Rumex crispus L. Curled dock Polygonaceae P Europe Roadsides, open 1.38 21
habitats
Anagallis arvensis L. Scarlet Primulaceae A Eurasia Disturbed open 0.45 20

pimpernel habitats, roadsides
Digitalis purpurea L. Foxglove Scrophulariaceae B or P Europe Open habitats 0.59 25
Sinapis arvensis L.Wild Brassicaceae A Europe Fields, open 2.49* 15

mustard habitats
Papaver rhoeas L. Poppy Papaveraceae A Eurasia Fields, open 0.16 16
habitats

*From seeds collected in Canada.Annex 13

352 Boutin et al.

Herbicides solved. Bromoxynil degrades rapidly in most soil

types, with a half-life in the order of two weeks
Six herbicides with contrasted modes of action were that can be considerably enhanced at low tem-

tested (Table 2), and all are currently applied on peratures. It is moderately water soluble (130 mg/
major crops, e.g. maize, wheat, barley, soybeans, l) thereby potentially harmful to ﬁsh and aquatic
oats, peas, potatoes and tomatoes. They were se- invertebrates for which it is toxic if it reaches

lected because they are widely used in post-emer- waterbodies (Muir et al., 1991). A few crops have
gence applications in Canada and/or Denmark been made resistant to this herbicide through

(except for metolachlor which is not on the Danish genetic modiﬁcation (Stephenson et al., 1995;
marked), and generally in North America and Freyssinet et al., 1996). Bromoxynil is used on

Western Europe, for the control of broad-leaved monocot crops such as maize, cereals, onions,
plants and grasses. Herbicides were obtained di- garlic, and on some dicot crops (alfalfa and mint)

rectly from the diﬀerent companies originally for the control of several broad-leaved species.
making the herbicides: Saxo (20% octanoate- There are two forms of bromoxynil, the hept-
bromoxynil), Rhone Poulenc (now BASF); Banvel anoate and the octanoate esters. They are consid-

4S (480 g/l dimethylamine salts of dicamba), ered to be toxicologically similar to the pure
Novartis (now Syngenta); Roundup Bio (360 g/l bromoxynil phenol (US EPA fact sheet, www.

glyphosate with 480 g glyphosate-isopropylamin- epa.gov/pesticides/factsheets). Bromoxynil esters
salt), Monsanto; Dual Gold (87.3% S-metolachlor are absorbed by sprayed foliage and hydrolysed to

– 960 g/l), Novartis (now Syngenta); Ally (20% the active herbicide bromoxynil by esterases in
metsulfuron methyl), Dupont, sprayed with the leaves (Eberlein et al., 1998).
0.05% surfactant Citowett (100% alkylarylpoly-
Dicamba (3,6-dichloro-o-anisic acid) is a sys-
glykolether); Stomp SC (36% pendimethalin – temic selective herbicide absorbed by the leaves
400 g/l), Cyanamid (now BASF). All herbicides and roots of young plants, with ready translo-

were used as formulated products thereby con- cation throughout the plant via both the sym-
taining a number of surfactant compounds. plastic and apoplastic system as well as through

Bromoxynil (2,6-dibromo-4-cyanophenyl octa- xylem and phloem (Frear, 1976; Worthing and
noate) is a selective herbicide with limited systemic Hance, 1991). Two forms of dicamba are com-

activity (Thomson, 1989; Tomlin, 1997) formu- monly used as the active ingredient, the dim-
lated as an emulsiﬁable concentrate. It is absorbed ethylamine salt and the sodium salt (Pesticide
by the foliage through cuticular penetration rather Fact Sheet, US Department of Agriculture,

than stomatal or by the root system, both ways Forest Service). Dicamba resembles the naturally
with poor translocation. Bromoxynil is a benzo- occurring plant growth hormone auxin and thus

nitrile herbicide that kills by inhibition of photo- causes similar but uncontrolled growth reactions
synthesis in annual broad-leaved plants but the that disrupt normal functions and death soon

precise mode of action appears to remain unre- follows. Although auxinic herbicides have been

Table 2. Characteristics of herbicides used, label rates used in the range-ﬁnding experiment, and leaf stage at which plants were tested

Herbicide common Commercial name and content Label rate Leaf stage
name Chemical family in active ingredient (a.i.) g-ai/ha tested Mode of action

Bromoxynil Benzonitrile Saxo (20% octanoate bromoxynil) 400 4 Photosynthetic inhibitor

Dicamba Benzoic acid (auxin)Banvel 4S (480 g/l dimethylamin4440 2-3 Hormone auxine-like
salt of dicamba) herbicide
Glyphosate Organophosphate Roundup Bio (360 g/l glyphosate1440 4-8 Biosynthesis inhibitor
of aromatic amino acids
Metolachlor Chloroacetamide Dual Gold (87.3% S-metolachlor)2500 2 Lipid biosynthesis

inhibitor
Metsulfuron Sulfonylurea Ally (20% metsulfuron methyl) 4 4 Biosynthesis inhibitor of
chained amino acids
Pendimethalin Nitroaniline Stomp SC (36% pendimethalin) 2000 2 Cell division inhibitor Annex 13

Terrestrial Plant Sensitivities to Six Herbicide353

in use for over 50 years (e.g., chlorophenoxy 2,4- inhibitor that impairs seedling growth of grasses
D, 2,4-DB and MCPA), their precise mode of (Gronwald, 1991). It is formulated as an emul-

action remains unclear. Dicamba is widely used siﬁable concentrate. Even though in use for over
on grass crops (maize and cereals) for the con- 40 years, the primary mode of action of chloro-
trol of broad-leaved weeds. Persistence is high acetamide herbicides has not been identiﬁed al-
(half-life 5–6 months) and is enhanced in cases of though recent ﬁndings indicate that the inhibition

drought and cold temperature. It is highly mo- of lipid synthesis accompanied by the disruption
bile in most soil with a water solubility of 6.5 g/l of the integrity of cell membranes may likely be
at 25 °C. Volatilisation occurs at high soil tem- implicated (Gronwald, 1991; Matthes et al.,

perature and slow air movement. It is generally 1998). Two isomers occur, the inactive R-enan-
nontoxic to animals but adverse eﬀects on tiomer and the active S-enantiomer of metola-
aquatic algae have been documented (Caux chlor, which was the dominant form in the
et al., 1993). formulation used in the current Danish/canadian

Glyphosate [N-(phosphonomethyl)glycine] is a experiment. Metolachlor selectively controls
systemic non-selective soluble concentrate herbi- numerous grasses and some broad-leaved species in
cide that will aﬀect most plants. It is taken up by several important crops such as maize, soybeans,

the leaves and then translocated through the plant cotton, sugar beets, potatoes, tomatoes, several
from the point of contact towards the root system types of beans, etc. (Thomson, 1989; Tomlin,
(Monsanto Canada, 1991). If properly applied, it 1997). Metolachlor is water soluble (488 mg/l at
will kill the entire plant including the roots and 25 °C) and exhibits residual phytotoxicity (half-

therefore prevent later root sprouts (Kennedy and life > 200 days), thus will conceivably move to
Jordan, 1985). Absorption takes place through the waterbodies where it is toxic to ﬁsh and some
waxy cuticle on leaves where it is then translocated aquatic plants (Peterson et al., 1994). It is volatile

through the plant by cell to cell diﬀusion and under certain conditions.
vascular transport primarily through the phloem Metsulfuron methyl [2-(4-methoxy-6-methyl-
(Ribo, 1985 1986; Carlisle and Trevors, 1988) 1,3,5-triazin-2-ylcarbamoylsulfamoyl)benzoic acid]

where it is then transported to the main bio- is a potent inhibitor of plant growth and is used
chemical target: location of the enzyme 5-eno- on wheat and barley crops for the control of
lpyruvylshikimate-3-phosphate (EPSP) synthase, broad-leaf species and suppression of a few
situated largely within chloroplasts. The main grasses. It is formulated as dry ﬂowable. The

mechanism of action of glyphosate is inhibition of herbicide is taken up by the foliage or the roots
the shikimic acid pathway (Liu et al., 1997), which and translocated via xylem and phloem. Metsul-
is responsible for the production of the aromatic furon methyl is a selective herbicide that acts by

amino acids phenylalanine, tyrosine, and trypto- inhibiting the enzyme acetolactate synthase (ALS
phan. inhibitor) which catalyses the synthesis of the three
Glyphosate is degraded by rapid microbial branched-chain amino acids valine, leucine and
action, with a DT50 of three to ﬁve weeks. isoleucine (Moberg and Cross, 1990). The precise

Otherwise it is non-volatile and does not degrade mechanism of action is unknown but soon after
photochemically. The water solubility is high herbicide application, plant cell division stops, and
(11.6 g/l at 25 °C) but because it strongly binds death occurs within one to three weeks. Metsul-

to soil particles it becomes immobile unless furon methyl is considered mobile in most soils
transported with the soil. This herbicide, already and mobility is enhanced as pH increases (Beyer
widely applied worldwide, will see its use et al., 1988; Blair and Martin, 1988). It is degraded

expanding with the emergence of genetically by two processes: chemical hydrolysis and micro-
modiﬁed crops (maize, soybean, oilseed rape, bial action and may be very persistent in alkaline
cotton among others) that are made resistant to soils. Photolysis and volatilisation are negligible at
glyphosate. all pH levels. Sulfonylureas are increasingly known

Metolachlor [2-chloro-6’ethyl--(2-methoxy-1-me to inhibit the reproduction of several terrestrial
thylethyl)aceto-o-toluidide] is a chloroacetamide and wetland plant species (Kjær, 1994; Fletcher
herbicide considered to be a general growth et al., 1996; Boutin et al., 2000).Annex 13

354 Boutin et al.

Pendimethalin [N-(1-ethylpropyl)-2,6-dinitro- were sprayed at various sizes that were determined
3,4,-xylidine] is a selective dinitroanaline herbicide by the herbicides most susceptible leaf stage as

that inhibits growth of the entire plant by altering indicated on labels. An automatic sprayer (desig-
the process of mitosis. It is an antimitotic sub- ned in Denmark by Jens Kristensen, 1994) was
stance but the exact mechanism of action is un- used whereby the herbicide application is achieved
known (Tarkowska et al., 1994). Pendimethalin by a moving boom equipped with two ordinary

aﬀects microtubule formation during cell division hydraulic ﬂat fan nozzles (Hardi 4110–16 nozzle).
by binding to its main proteinic component, Two pots per spray event were placed in the
tubulin, eventually causing a complete loss of middle of the spray chamber at 50 cm distance

microtubules (Vaughn and Lehnen, 1991). Micro- from the nozzle, delivering 200 l of water per
tubules are required for cell division and cell wall hectare with the desired herbicide concentra-
formation. Pendimethalin is absorbed by roots tions (working pressure ¼ 2 bars, speed of spray
and leaves and it initially limits root growth, boom ¼ 4.7 km/h). The spraying was performed

especially the development of lateral or secondary starting with the lowest concentration ﬁrst, pro-
roots (Tomlin, 1997). The formulated product is gressing towards the highest concentration. Be-
an emulsiﬁable concentrate made of the active tween each herbicide, the sprayer was thoroughly

ingredients and several adjuvants. The nitro group rinsed several times with water. Two weeks after
on the phenyl ring imparts the pronounced yellow spraying, visual eﬀects on plants were noted, using
orange colour of pendimethalin (Anderson, 1997). the rating chart described in Hamill et al. (1977)
Pendimethalin was developed for use as a pre- and Boutin et al. (1993); a rating of zero indicates

emergence or early post-emergence product, mostly full growth and vigour, nine, no growth/mortality.
for the control of grasses and several broad-leaved The deﬁnitive test, aimed at obtaining dosage–
plants on numerous important crops, e.g., maize, response curves, was performed using four dosages

wheat, soybeans, rice, cotton, potatoes, several as determined by the range-ﬁnding test, plus con-
beans and peas, etc. It will not control established trol. Immediately before spraying, a stock solution
plants. Pendimethalin is moderately persistent in was prepared which consisted in the highest dos-

moist sandy loam (half-life for dissipation time of age tested and then dilutions were made to obtain
50 days) to highly persistent in moist silt soil (half- the other lower dosages. A sample (60 ml) of the
life 140 days) and in dry silty clay loam (250 days). stock solution was kept for chemical analysis ver-
Consequently it is a very stable herbicide except iﬁcation. Samples were analysed by the Labora-

when it volatilises from moist soil surfaces (Barrett tory Division of the Pest Management Regulatory
and Lavy, 1983). The water solubility being mini- Agency, Ottawa, Canada. High performance
mal (0.3 mg/l at 20 °C) it is unlikely to be trans- liquid chromatograhy was used for bromoxynil,

ferred to other environmental compartments dicamba, glyphosate, metsulfuron methyl while
although it may move with soil particles to water- metolachlor and pendimethalin were analysed
bodies where it is toxic to ﬁsh (Thomson, 1989; using a gas chromatograph.
Tomlin, 1997). In most cases, a geometric progression of 1.8 or

2 was used in the determination of dosages. For
each spray event, six replicates were used with a
Methods – Danish/Canadian database single plant per pot (two pots per spray, times

three independently prepared replicates). Three
First, in order to determine dosages at which weeks after spray, the aboveground parts of plants
plants were susceptible (post-emergence applica- was harvested, placed in a forced air dryer at

tion only), a range-ﬁnding test was performed 70 °C for 24–48 h until thoroughly dry, and
using between three to ﬁve plants per pot and two total dry weight was recorded separately for each
replicates per dosage. Four dosages plus control plant.
were sprayed, 0.01, 0.1, 1 and 5 or 10 times rec- During both experiments, plants were watered

ommended label rates for agricultural use in from the bottom, the temperature in the green-
Canada and Denmark. Label rates used for the house was maintained between 15 and 25 °C with
range-ﬁnding test are indicated in Table 2. Plants variations due to external weather, and the pho- Annex 13

Terrestrial Plant Sensitivities to Six Herbicide355

toperiod was 16 h daylight. Some problems arose hazardous dosage (HD) was done using the

with the greenhouse thus for a short period plants ET X program developed by Aldenberg and Slob
underwent longer daylight exposure. This, how- (1993). All the analyses were performed using the
ever, should not aﬀect the outcome of the experi- Danish/Canadian and the US EPA databases

ment. The greenhouse was divided in diﬀerent separately.
units, which allowed the maintenance of the con-
trol plants separate from the sprayed plants to

avoid undesirable eﬀects due to vapour drift. Results
The database created comprising the deﬁnitive
results of eﬀects of the six herbicides tested with Chemical analysis
the 15 plant species became the Danish/Canadian

dataset. Tests done directly with the products provided by
companies showed good accuracy, ranging from
95% to 107% of expected concentrations of active

The US EPA database ingredients. In dilutions performed prior to
spraying of the diﬀerent herbicides, the amount of
The US EPA database, which includes data sub- active ingredient was 102% and 120% for brom-

mitted up to 1999, was kindly provided to us by oxynil (n ¼ 2), 95% to 96% for dicamba (n ¼ 3),
the US EPA Oﬃce of Pesticide Programs, to carry between 91% and 107% for glyphosate (n ¼ 5),
out further analyses. Between three and 11 species between 95% and 115% for metolachlor (n ¼ 5)

have been tested and only crop plants are repre- and between 95% and 107% for pendimethalin
sented, except with metsulfuron methyl where (n ¼ 3). No result could be obtained for metsul-
several non-crop plants were included in the furon methyl because of damaged samples.

database. Testing was performed in the green-
house, following the US EPA guidelines (Holst
and Ellwanger, 1982) for vegetative vigour (spray Phytotoxicity
post-germination). Quantitative endpoints were

reported, e.g. dry weight, fresh weight, height, etc. Rank of species sensitivity was plotted separately
Only the most sensitive endpoint was recorded in for the six herbicides tested, using the EC 50for
the database and thus used in these analyses. each of the 15 plant species examined (Fig. 1).

Testing was carried out with the active ingredient Detailed results of both the range-ﬁnding and
of each herbicide. deﬁnitive tests are presented in Appendix 1. In
many cases the EC calculated was situated
50
slightly lower or in the low end of the dosages
Statistical analyses selected for the deﬁnitive test. This is due to the
fact that, because of time constraint, eﬀects were

The EC 50is the eﬀective dosage that results in 50% recorded after two weeks into the range-ﬁnding
reduction in the test endpoint (in this case growth) test where it appears that most herbicides were still
being measured relative to control. For the calcu- actively impacting plants, whereas the deﬁnitive

lation of the EC50the linear interpolation method test was concluded after three weeks. This ﬁnding
for sublethal toxicity, also called the inhibition may be of prime importance for designing phyto-
concentration approach (ICp) was used (as toxicity test for regulatory purposes. Except for

described in US EPA report EPA/600/4/-89-001 metolachlor and metsulfuron methyl, the four
and 001A). This method works by smoothing data other herbicides followed a normal distribution
that are not following a normal reduction with (Shapiro–Wilk test for normality, p > 0.05). The

increased dosages in the selected endpoint – they bimodal distribution of metolachlor is due to
are adjusted by averaging or pooling. It is assumed the marked diﬀerence in sensitivity amongst the
that any unexpected increases in the mean weight Asteraceae (ﬁve species) and the Lamiaceae (four
species). In the case of metsulfuron methyl,
or other endpoints, at higher concentrations, are
due to random variations. The calculation of the Polygonum convolvulus, Digitalis purpurea, andAnnex 13

356 Boutin et al.

Figure 1. Rank of species sensitivities plotted for the 15 species tested with the six herbicides used in the Danish/Canadian database.
Species names are provided in Table 1 and Appendix 1.

especially Centaurea cyanus exhibited little sensi-
bicides. Yet three patterns seem to emerge. (1)
tivity as compared to other plant species. Bromoxynil, dicamba and glyphosate induced
The Danish/Canadian database is unique similar toxicity to most species. No one family
because it includes the same plant species tested emerged as more or less sensitive. Consequently,

with six herbicides. Results clearly indicate that when extrapolating from one genus to another
species sensitivity varies considerably among her- within the two families, Asteraceae and Lamia- Annex 13

Terrestrial Plant Sensitivities to Six Herbicides357

ceae, in which more that two species were tested, Ten species were tested with dicamba acid in the
an uncertainty factor of ten would capture all the US EPA database (as opposed to dicamba dim-

variability. Likewise, when extrapolating from one ethylamine salt in the Danish/Canadian database)
family to another, a factor of 10 would suﬃce. (2) including four monocots (three grasses) and six

A second pattern was exhibited by metolachlor dicots (Fi)1 2). The toxicity ranged fro)1
and pendimethalin, i.e., low sensitivity by plant 7.28 g ai ha for Glycine max to 4368.0 g ai ha
species of the Asteraceae family, accrued sensitiv- for Zea mays. The three grasses tested in the US

ity by species of the Lamiaceae family and large EPA database, Zea mays, Lolium perenne and
variability among species in general. (3) The third Avena sativa were very insensitive, predictably
trend is manifested by metsulfuron methyl which since they are crops on which the herbicide can be

stands alone whereby no consistency could be applied for the control of weeds. The other
distinguished among the diﬀerent species. For the monocot tested, Allium cepa, also exhibited a
latter three herbicides, a much larger uncertainty higher EC than most dicots except for Brassica
25
factor would be needed as will be seen below. oleracea.
A few herbicides induced extreme results to In the US EPA database, plant species were

one or a few sp)1ies. Solidago canadensis tested with glyphosate containing 48.3%, 75.0% or
(EC 50¼ 30.76 g ai ha ) was much less sensitive 96.6% active ingredient. This is in contrast with the
than any other species tested with dicamba, one test performed in the Danish/Canadian database

order of magnitude diﬀerence from the most sensi- where plants were tested with the formulated
tive species Inula helenium (E50 ¼ 3.32 g ai ha ), product containing 41% active ingredient and
two species from the Asteraceae family. Centaurea 59% of other unspeciﬁed ingredients. A total of
)1
cyanus (EC 50 ¼ 1.63 g ai ha ) was remarkably 19 species were tested with one, two or three con-
insensitive to metsulfuron methyl, approaching centrations of the herbicide. Some variations exist

two orders of magnitude diﬀerence with most among species tested with the diﬀerent concentra-
other species. Likewise, Centaurea cyanus tions. In the 48.8% presented in Fig. 2, the toxicity
(EC 50¼ 8280.72 g ai ha ) and especially Rudbec- ranged from 82.88 g ai ha )1 for Brassica campes-
)1 )1
kia hirta (EC 50¼ 8966.44 g ai ha ) displayed tris to 851.20 g ai ha for Cyperus rotundus.
much lower toxicity then most other plant species Ten species were tested with metolachlor
tested with pendimethalin. Mentha spicata (no speciﬁcation as to which isomers were pres-
)1
(77.84 g ai ha ) was the least sensitive species to ent), including four monocots (three grasses)
bromoxynil, a close relative to the crop species and six dicots (Fig. 2). The toxicity ranges
(Mentha spp.) on which bromoxynil can be applied from 22.40 g ai ha )1 for Lolium perenne to
)1
for the control of weeds. 4480.0 g ai ha for Glycine max. Many insensitive
In contrast to the Danish/Canadian database, species were tested in the US EPA database,

the six herbicides examined in the US EPA data- including crops such as soybean (Glycine max),
base were tested with three to eleven diﬀerent corn (Zea mays) and tomatoes (Lycopersicon es-
species for a total of 22 plant species. Ranks of culentum). Species of the Brassicaceae family also

species sensitivity are shown in Fig. 2. Ten species seem rather insensitive, e.g., Brassica oleracea and
were tested with bromoxynil heptanoate, including Raphanus sativus tested in the US EPA database.
ﬁve monocots (four grasses) and ﬁve dicots. The Sinapis arvensis in the Danish/Canadian database
)1
toxicity ranges from 12.32 g ai ha for Brassica also exhibited an elevated EC 25value. Six species
oleracea and 414.40 g ai ha )1 for Avena sativa. were tested with metolachlor-S-isomer in the US
Crops on which bromoxynil has been registered EPA database (not shown), including four mono-

for use (Zea mays, Avena sativa, Allium cepa), all cots (three grasses) and only two dicotyledonous
monocots, were selected as test species for plant species. Lolium perenne (23.52 g ai ha )1) was the

risk assessment. In another testing set (not shown), most sensitive and another monocot, A)1ium cepa
six plant species were tested with bromoxynil oct- was the least sensitive (571.0 g ai ha ).
anoate, including ﬁve broad-leaved species and Nine species were tested with metsulfuron

one monocot from the Liliaceae family (Allium methyl in the US EPA database, including four
cepa). monocots (three grasses) and ﬁve dicots (Fig. 2).Annex 13

358 Boutin et al.

Figure 2. Rank of species sensitivities of the species tested in the US EPA database. Allium cepa, onion; Avena sativa, oats; Beta

vulgaris, sugar beet; Brassica campestris, rape; B. rapa, turnip; B. oleracea, cabbage; Cyperus rotundus, nutsedge; Cucumis sativa,
cucumber; Echinochloa crusgalli, barnyard grass; Glycine max, soybean; Gossypium sp., cotton; Hibiscus esculentum (Abelmoschus
esculentus), okra; Ipomea sp., morning glory; Lactuca sativa, lettuce; Lolium perenne, ryegrass; Lycopersicon esculentum, tomato; Oryza
sativa, rice; Polygonum convolvulus, black bindweed; Raphanus sativus, radish; Triticum aestivum, wheat; Zea mays, maize; Xanthium
pensylvanicum, cocklebur.

)1
The toxicity ranges from 0.134 g ai ha for a crop, Oryza sativa, on which the herbicide can
Xanthium pensylvanicum and 16.80 g ai ha )1 for be used for the control of weeds.

Oryza sativa, over two orders of magnitude. The Only three species were tested with pendimeth-
least sensitive species in the US EPA database is alin in the US EPA database. Toxicity levels Annex 13

Terrestrial Plant Sensitivities to Six Herbicides 359

were always higher with species of the Danish/ Species sensitivity distribution

Canadian database, except for pendimethalin and
metolachlor-S where only three and six species Table 3 presents the calculation of the hazard
respectively were available in the US EPA data- concentration that will protect 95% of the species

base. with 50% (median HC5 or HC5 (50) and 95%
The range of species sensitivity was plotted for (HC5 (95) conﬁdence levels, according to the

both the Danish/Canadian data and the US EPA method of Aldenberg and Slob (1993). The median
data for ease of comparison between the two conﬁdence level should be favoured because it is
datasets (Fig. 3). The EC 25 was used because this considered the best estimate of the hazardous

was the only toxicity measurement provided in the concentration (Aldenberg and Slob, 1993).
US EPA database. In the Danish/Canadian data- Furthermore, the endpoint measured in both
set, the range of species sensitivity was narrow for datasets were not mortality but sublethal eﬀects.

bromoxynil, dicamba and glyphosate, the ratio of The more conservative 95% conﬁdence level is,
the least to most sensitive species barely reaching however, a safer value. With the Danish/Canadian

one order of magnitude (<10). In the case of the database, calculations were performed with both
three other herbicides tested, the ratio of the least the EC 50and the EC ,25he latter to allow a com-
to most sensitive species was much broader, parison with the US EPA data. In a few cases the

spanning from 73 for metsulfuron methyl, to 1651 data did not ﬁt the log-logistic distribution, which
for metolachlor, and 2668 for pendimethalin. The implies that the calculations should not have been
range of species sensitivity was higher in the US performed for metsulfuron methyl in the Danish/

EPA database for bromoxynil, dicamba and met- Canadian database (EC 25) and for bromoxynil
sulfuron methyl. heptanoate in the US EPA database.

Figure 3. Range of plant species sensitivity for the six herbicides tested in the Danish/Canadian (left side for each herbicide) and US

EPA databases. Each square represents t25 EC individual plant species for any given herbicide. Bars denote squares grouped
together. Bry ¼ bromoxynil, dic ¼ dicamba, gly ¼ glyphosate, meto ¼ metolachlor, mets ¼ metsulfuron methyl, pen ¼ pendimetha-
dimethalin.Annex 13

360 Boutin et al.

Table 3. HC5s (Hazard Concentrations protecting 95% of species) calculated separately with the Danish/Canadian and the U.S. EPA
databases. HC5s were calculated with 50% (HC5(50) and 95% (HC5(95) conﬁdence levels.

)1 )1
With EC 25(g-ai ha ) W ith EC50(g-ai ha )

Logistic Ratio Logistic Ratio

n distribution HC5(50) HC5(95) HC5(50/95) distribution HC5(50) HC5(95) HC5(50/95)

a) Danish/Canadian database
Bromoxynil 15 Accepted 3.720 1.9056 1.95 Accepted 7.967 4.1354 1.93

Dicamba amine 15 Accepted 1.300 0.7630 1.70 Accepted 2.781 1.6038 1.73
Glyphosate 41% 15 Accepted 5.449 3.3248 1.64 Accepted 12.468 8.2314 1.51
Metolachlor (87.3% 15 Accepted 0.459 0.0285 16.11 Rejected 1.383 0.0992 13.94

S-isomer)
Metsulfuron methyl 15 Rejected 0.005 0.0014 3.23 Rejected 0.010 0.0028 3.37

Pendimethalin 15 Accepted 0.626 0.0500 12.52 Accepted 1.228 0.0939 13.08
)1
With EC 25(g-ai ha )

Logistic Ratio

n distribution HC5(50) HC5(95) HC5(50/95)

b) U.S. EPA database

Bromoxynil heptanoate 10 Rejected 5.443 0.6696 8.13
Bromoxynil octanoate 6 Accepted 6.591 0.3823 17.24
Dicamba acid 10 Accepted 1.765 0.0830 21.27

Glyphosate 48.3% 11 Accepted 82.069 40.6030 2.02
Glyphosate 75% 10 Accepted 119.240 47.5740 2.51
Glyphosate 96.6% 10 Accepted 96.636 41.5670 2.32

Metolachlor (unspeciﬁed) 10 Accepted 25.350 2.4989 10.14
Metolachlor (S-isomer) 6 Accepted 29.786 2.4567 12.12
Metsulfuron methyl 9 Accepted 0.058 0.0071 8.16

Pendimethalin 3 Accepted 24.990 0.2943 84.91

The HC5 (50)was always higher when calculated calculated using the US EPA database, except for

using the EC 25 of US EPA database than when metolachlor.
using the Danish/Canadian database (Table 3). Figure 4 shows that the HC5 calculated with
(50)
This was expected because species tested in the the US EPA data would have underestimated the

Danish/Canadian database were generally more risk of adverse eﬀects for several species of
sensitive than those tested in the US EPA data- the Danish/Canadian database: all 15 species for

base. When considering the HC5 (95) the Danish/ glyphosate, 12 species metsulfuron methyl, eight

Canadian data elicited a more conservative value for pendimethalin, six for metolachlor, three for
in the case of bromoxynil and dicamba, while it bromoxynil and one for dicamba. When using the

was the opposite for glyphosate and metolachlor. more conservative HC5 (95) the risk would have
The comparison was not possible with metsulfu- been grossly underestimated for glyphosate with

ron methyl in the Danish/Canadian data because 14 species below the threshold, and to a lesser

the data did not follow a log-logistic distribution, extent for metolachlor (three species) and metsul-
nor with pendimethalin in the US EPA dataset due furon methyl (one species).

to the very low sample size.

An indication of the margin of error was esti- Discussion
mated using the ratio between HC5 (50)and HC5 (95)

Large diﬀerences between both values indicate Limitations of the study

considerable uncertainty and may be an indication
that more species should be tested (Aldenberg and The current study was not designed to investigate

Slob, 1993). The ratio was always greater when a worst-case scenario. Herbicide applications were Annex 13

Terrestrial Plant Sensitivities to Six Herbicides 361

Figure 4. Risk assessment performed using the plant species tested in the Danish/Canadian database and the HC5 (Hazard Con-
centration protecting 95% of species) calculated with the crop species of the US EPA database. Histograms represent the log10 values
of the E25for each of the 15 species tested with the six herbicides in the Danish/Canadian experiment. The two lines across for each
herbicides represent the (50)full lines, 50% conﬁdence level) an(95)dotted lines, conﬁdence level) calculated using the US
EPA data. Plant species of the Danish/Canadian database that would not be protected are situated below the lines. Bry ¼ bromoxynil,
dic ¼ dicamba, gly ¼ glyphosate, meto ¼ metolachlor, mets ¼ metsulfuron methyl, pen ¼ pendimethalin.

only performed at the seedling stage, presumably and Boutin, 2003). Pendimethalin may be more
the most sensitive one for each study herbicide, toxic to germinating seeds when applied preemer-

according to labels provided by registrants and gence or pre-planted incorporated. For most her-
documented in some studies (Marrs et al., 1991). bicides, eﬀects at the vegetative and reproductive
Where eﬀects on other growing stages have been stages are largely unknown.

documented, it appears that some herbicides may Another limitation inherent to our study rests in
be equally or even more harmful, e.g., reproductive the fact that species were selected for availability

stages for plants sprayed with minute amounts of from seed suppliers, and because documentation
metsulfuron methyl (Boutin et al., 2000) and sul- on germination and facility to grow under experi-
fonylureas in general (Fletcher et al., 1993; Felsot mental conditions existed. Selected species were

et al., 1996). Glyphosate is also more toxic to hard- not representative of a particular ecosystem except
to-kill perennial species in the fall than in the spring that several plants were characteristics of open

when plants are fully grown thus have a large disturbed habitat. Ideally, the tested species should
contact surface for penetration of the herbicide that be chosen at random among all species of the tar-
can be translocated into the storage organs (Dekker get ecosystem they are assumed to represent, a

and Chandler, 1985). Glyphosate has been shown prerequisite that can hardly be met in risk assess-
to aﬀect seed germination when parent plants were ment. Testing was performed in the greenhouse

sprayed during the seed development (Blackburn with single species grown per pot. Whether resultsAnnex 13

362 Boutin et al.

from these tests are representative of ﬁeld situa- Choice of species and formulation
tions where plants undergo more adverse condi-

tions (wind, occasional drought, insect damage, Species sensitivity varies greatly with the herbicide
competition) is debatable and is beyond the scope tested. As found in other studies (Marrs et al.,
of this work but poses question on the legitimacy 1989; Fletcher et al., 1990; Pestemer and Zwerger,

of extrapolating from greenhouse tests to natural 1999), no one species was the most or the least
ecosystems. Kjær et al. (1998) found that the sensitive plant. In the Danish/Canadian database
combined eﬀect of several stressors in the ﬁeld in- in the case of metolachlor, pendimethalin and to a

creased the sensitivity of P. convolvulus to copper lesser extent metsulfuron methyl, the Asteraceae
compared to laboratory tests. Further research family clearly exhibited less sensitivity and the
is needed to tackle this question. It is likely that Lamiaceae generally showed more sensitivity. In
very conservative estimates of the potential phy- the US EPA database, monocotyledons (Poaceae

totoxicity were generated in the Danish/Canadian and Liliaceae) were frequently less sensitive than
database in relation to what could be observed in dicotyledons. There was no overlap between the
nature (Forbes and Forbes, 1993). two datasets except for Polygonum convolvulus

tested with metsulfuron methyl. Regardless, the
Phytotoxicity versus mode of action overall toxicity of each herbicide was always
higher in the Danish/Canadian database. Two

The mode of action of the six herbicides tested factors may explain the diﬀerence in the magni-
includes general eﬀects that are common to all tude of toxicity between the two datasets. First, in
plant systems, e.g., inhibition of photosynthesis, the US EPA database, species were tested with the

disruption of various amino acid synthesis, mitotic active ingredients alone while in the Danish/
poison, suppression of lipid synthesis or auxin Canadian database, all species were tested with the
mimic. Consequently, it appears that plant selec- formulated product. The ingredients entering in
tivity is obtained by the timing and method of the formulation of each herbicide is trade secret

application or by the diﬀerential morphology, and is therefore largely unknown. What is known
anatomy or physiology of the plants that are thus is that surfactants or additives form a signiﬁcant
protected or aﬀected by a given herbicide. Prior to amount of herbicidal compounds usually applied,

the herbicidal active ingredient reaching the bio- and that they serve numerous functions, among
chemical site of action within the plants, the her- them emulsifying, dispersing and wetting, or
bicide must reach the surface of the plants, must solubilisating (Deming and Magin, 1987; Knowles,

penetrate the leaves or roots, must be translocated 1995). These functions result in bioenhancement of
within the plants without killing plant parts at herbicidal activity by improving spreading and
once, must remain toxic avoiding detoxiﬁcation, retention on leaf surface, thereby increasing
and must remain active for a suﬃcient period of uptake or translocation within plants. For instance,

time to achieve eﬀectiveness (Hess, 1987). this may be the primary reason why the formula-
Eﬀects obtained on terrestrial plants using the tion with glyphosate, a non-selective herbicide,
test methodology followed in the present study, yielded more toxicity with plants tested with the

deviates from eﬀects found for other organisms Danish/Canadian database than to those of the US
such as birds and aquatic organisms, in that the EPA database. The active ingredient of Roundup R
dosage does not indicate the concentration in the is formed by 41% by volume of the monoisopro-

organism, but merely how much of the chemical pylamine salt of glyphosate, N-(phosphonomethyl)
was applied per unit ground area. The actual glycine (Ghassemi et al., 1982; Payne et al., 1987;
herbicide uptake in an individual plant depends on Carlisle and Trevors, 1988). It also includes 59% by

species speciﬁc traits, individual conditions, timing volume of inert (non-herbicidal) ingredients,
and environmental factors. The ingredients that including about 41% water and 15% of a polyeth-
compose the formulation of a herbicide are crucial oxylated tallow amine surfactant that enhances the
in the selectivity process as will be further con- spreading of spray droplets when they contact fo-

sidered below. liage (Freedman, 1991). Annex 13

Terrestrial Plant Sensitivities to Six Herbicid363

Secondly, as mentioned earlier, species selected known to be more potent on grass species, as
in the US EPA database were frequently insen- shown in the US EPA results. Finally, only

sitive, i.e. crop species on which the herbicide is minute amount of metsulfuron methyl is neces-
to be used for the control of weeds. For example, sary to cause toxicity on plants hence the need of
bromoxynil selectivity between gramineous and a surfactant to be added for good spreading and
broad-leaved plants is based mainly on diﬀeren- penetration into leaves and to assist the trans-

tial retention by morphologically contrasting location into the whole plants (Beyer et al.,
species due to diﬀerence in uptake (e.g. hairs, 1988).
nature of waxy cuticle), movement within plants It is quite clear that much uncertainty can be

and also metabolism – monocots naturally pos- reduced by testing diﬀerent species than those
sess a nitrilase gene capable of metabolising currently submitted at present to the US EPA and
bromoxynil herbicides into non-phototoxic ben- to many other countries. It seems almost unfea-
zoic forms (Sanders and Pallett, 1987; Cuthbert sible to select representative plants considering

et al., 2001). Likewise, Banvel is the formulated the massive variability in response and the large
product containing dicamba and was used in the number of plant species in existence. Neverthe-
Danish/Canadian experiment – it likely contains less, if what is intended is protection of both

both the dimethylaminesalt and related acids as adjacent crop plants but also species in ﬁeld
well as a number of surfactants. This is in con- margins and habitats interspersed within the
trast with the US EPA test which was done with agricultural landscapes, the selection of species
the active ingredient of dicamba acid only. Ban- should be done diﬀerently than what currently

vel is more toxic to dicots than to monocots. The prevails.
anatomy of monocots and dicots is diﬀerent with By and large, all species used in the Danish/
respect to the phloem arrangement; In monocots Canadian experiment were uncomplicated to

it is scattered in bundles surrounded by protec- grow, transplant and maintain in the greenhouse.
tive sclerenchyma tissue (Sterling and Hall, 1997). Even the requirement for vernalisation necessary
Other characteristics in the anatomy of monocots for Polygonum convolvulus did not constitute a

may explain the diﬀerential sensitivity, such as major impediment as it merely consisted of plac-
the absence of cambium and pericycle from the ing in cold temperature for 8 weeks, seeds already
vascular bundle which is herbicide sensitive, and sown in trays. Alternatively, more seeds could be
the presence of intercaly meristem in the stems sown as germination is not entirely prevented by

and young leaves that may act as a barrier for a lack of cold treatment. Hitherto, it was found
the translocation of the herbicide dicamba that Centaurea cyanus, Nepeta cataria, Sinapis
(Sterling and Hall, 1997). Clearly, both brom- arvensis, and Papaver rhoeas were the easiest to

oxynil and dicamba exhibit little toxicity to germinate and were fast growing, therefore
grasses and the monocot Allium as shown in the should be considered preferred candidates for
US EPA database and are exceedingly toxic to further experiments. Polygonum convolvulus has
broad-leaved plants as demonstrated in both the disadvantage of being a climbing species

databases. which makes it more cumbersome to use. Other
Dual, the formulated product containing smaller species, e.g. Bellis perennis, Mentha spi-
metolachlor, is likely to contain both S-enantio- cata, Prunella vulgaris and Anagallis arvensis were

mer (87.3% in Dual Gold) of metolachlor and its slower to reach the required growth stage. Sur-
R-enantiomer. In the US EPA database, tests prisingly, Solidago canadensis, a large species
were performed with the S-isomer form of met- common in ﬁeld margins and pastoral habitats,

olachlor as well as another form of metolachlor and Rucbeckia hirta, a common species in old
probably containing both isomers (but unspeci- ﬁelds, were rather slow growing species at ﬁrst.
ﬁed). The S-enantiomer is the herbicidal com- Many other non-crop species have been used by
ponent, being very potent while the researchers all over the world that could be good

R-enantiomer is inactive (Matthes et al., 1998). candidate test species in risk assessment testing
In contrast to bromoxynil and dicamba it is for herbicide.Annex 13

364 Boutin et al.

Species sensitivity distribution favoured in the US EPA and other countries
(Holst and Ellwanger, 1982; Organisation for

The HC5 (50)is a conservative estimate of the Economic Co-operation and Development, 1984)

threshold of toxicity (Okkerman et al., 1991; causes an unacceptable bias with consequences
Aldenberg and Slob, 1993; Baril et al., 1994). In that risk is underestimated. Some basic rules

the Danish/Canadian study the HC5 (50)for a given should be followed in the selection of plants: (1)
compound was always lower than the minimum No crop species on which products will be applied,

EC 50 or EC 25 calculated for any species. In the US (2) No known species for which the product is
EPA database, only in two cases was the EC presumably not toxic, often revealed by eﬃcacy
25
lower than the threshold HC5 (50)calculated with data (see Boutin and Rogers, 2000; Boutin et al.,
the US EPA database. In marked contrast, using 1995), (3) Mostly non-crop species and preferably

the threshold HC5 (50)calculated with the US EPA species of ﬁeld margins. Many non-crop species

database to estimate the risk to the Danish/ are easy to grow in greenhouses. Factors that
Canadian species tested (assuming these represent could be considered in the selection of non-crop

native/wild plants to be protected within agricul- species to be tested are seed size, growth rate and
tural areas), showed that many species would be requirements for germination. In this comparative

left unprotected, the extreme being glyphosate analysis, however, it was not possible to distin-
with 100% of species. This value, the HC5 is guish between eﬀects caused by the plant species
(50)
what is recommended for use in risk assessment in selected and eﬀects induced by the formulation of
some countries (Van Straalen and Van Leeuwen, the herbicides tested, and this alone commands

2002). The HC5(95%) value calculated with the further research.

US EPA data would have protected 95% of the
Danish/Canadian non-crop species for only three Acknowledgements

herbicides (Fig. 4).
This work was performed in National Environ-

mental Research Institute of Silkeborg, Denmark,
Conclusion and was made possible with a grant provided by

the Danish Environmental Protection Agency to
It is very likely that the current suite of species NE and CK and by the Canadian Wildlife Service

prescribed in current guidelines will not be ade- of Environment Canada to CB. A very special

quate for the protection of habitats, e.g., ﬁeld thank to Ingelise Lauridsen and Inge Møller for
margin species, in agricultural areas. The non- the logistics and technical assistance in the green-

randomness in the current selection of species house.

Appendix 1. Result of range ﬁnding test, doses used for testing in the deﬁnitive 50st and EC s calculated with conﬁdence intervals,
using the dry weight of aerial parts as endpoint. Eﬀects in the range ﬁnding test were recorded by visual assessment (see text)

Range ﬁnding test
)1
(g ai ha) Deﬁnitive test 50 Conﬁdence intervals
a a )1 EC )1
Plant species LOEL HOEL Concentrations tested (g ai ha ) ( g ai ha ) Lower Higher

(a) Bromoxynil
Bellis perennis 40 400 40 72 130 240 33.28 27.84 44.68

Centaurea cyanus 4 40 4 8 16 32 17.22 13.98 21.54
Inula helenium 4 400 14 24 44 80 8.76 8.14 9.82
Rudbeckia hirta 4 40 6.8 12 22 40 9.26 6.00 12.88

Solidago canadensis 40 40 20 40 80 160 19.84 15.46 47.40
Leonorus cardiaca 4 2000 20 40 80 160 29.30 20.54 35.86
Mentha spicata 40 400 40 80 160 320 77.84 59.42 113.68 Annex 13

Terrestrial Plant Sensitivities to Six Herbicides 365

Appendix 1. Continued

Range ﬁnding test
)1
(g ai ha ) Deﬁnitive test Conﬁdence intervals
EC 50
Plant species LOEL a HOEL a Concentrations tested (g ai ha ) (g ai ha ) Lower Higher

Nepeta cataria 4 400 20 40 80 160 50.46 39.64 60.28
Prunella vulgaris 4 400 4 8 16 32 14.54 11.74 18.38

Polygonum convolvulus 40 400 40 72 130 234 21.00 20.68 21.32
Rumex crispus 4 2000 10 20 40 80 18.20 13.50 23.70

Anagallis arvensis 4 400 10 20 40 80 14.48 9.74 18.96
Digitalis purpurea 40 400 40 80 160 320 56.02 46.50 61.50

Sinapis arvensis 4 40 25 50 100 200 31.24 23.94 39.16
Papaver rhoeas 40 400 40 80 160 320 56.88 39.22 78.00

(b) Dicamba

Bellis perennis 44 4440 10 20 40 80 11.50 7.82 17.20
Centaurea cyanus 44 4440 5.5 11 22 44 3.90 3.60 4.74

Inula helenium 44 444 5 10 20 40 3.32 3.08 3.56
Rudbeckia hirta 44 44 5 10 20 40 6.52 4.32 8.20
Solidago canadensis 44 4440 44 88 176 352 30.76 27.76 38.26

Leonorus cardiaca 44 444 5 10 20 40 8.20 5.30 11.88
Mentha spicata 44 444 5 10 20 40 5.46 4.26 7.50

Nepeta cataria 44 444 10 20 40 80 9.96 8.08 25.02
Prunella vulgaris 44 444 7.5 15 30 60 7.68 6.58 11.26

Polygonum convolvulus 44 44 5.5 11 22 44 8.30 5.06 16.18
Rumex crispus 44 44 5 10 20 40 10.72 8.34 13.18

Anagallis arvensis 44 444 5 10 20 40 8.32 5.80 11.04
Digitalis purpurea 44 444 5 10 20 40 4.92 4.44 7.30

Sinapis arvensis 44 444 5 10 20 40 3.54 3.24 3.96
Papaver rhoeas 44 4440 5 10 20 40 5.76 4.04 11.72

Bellis perennis 14.4 1440 20 36 64 116 14.26 13.22 16.02
Centaurea cyanus 144 144 18 36 72 144 29.18 23.32 37.34
Inula helenium 144 7200 70 140 280 560 43.46 38.42 51.36

Rudbeckia hirta 14.4 1440 20 36 64 116 24.70 15.86 29.98
Solidago canadensis 14.4 144 10 20 40 80 24.06 17.44 31.38

Leonorus cardiaca 14.4 7200 18 36 72 144 35.82 27.84 48.34
Mentha spicata 144 144 20 38 66 120 17.94 15.64 21.12

Nepeta cataria 14.4 1440 20 36 64 116 39.74 32.28 48.46
Prunella vulgaris 14.4 7200 9 18 36 72 28.00 22.10 33.34

Polygonum convolvulus 14.4 144 20 100 180 260 15.76 14.34 17.30
Rumex crispus 144 7200 40 80 160 320 27.50 24.92 29.92

Anagallis arvensis 14.4 144 9 18 36 72 17.52 15.06 26.40
Digitalis purpurea 144 7200 40 80 160 320 64.66 61.04 69.22
Sinapis arvensis 144 144 20 36 64 116 19.28 16.28 26.04

Papaver rhoeas 14.4 144 8 16 32 64 18.52 13.12 25.12

(d) Metolachlor
Bellis perennis 2500 12500 1000 2000 4000 8000 1534.76 899.12 2419.14

Centaurea cyanus 2500 12500 4000 8000 12000 16000 4068.60 3326.12 6170.28
Inula helenium 2500 12500 1000 2000 4000 8000 1105.32 847.02 1660.24

Rudbeckia hirta 250 12500 1000 2000 4000 8000 1580.58 946.44 1773.76
Solidago canadensis 25 12500 400 800 1600 3200 2000.78 Not possible

Leonorus cardiaca 25 2500 10 20 40 80 9.50 Not possible
Mentha spicata 25 2500 4 8 14 25 3.76 3.18 5.58

Nepeta cataria 25 2500 7.6 13.8 25 45 9.62 6.84 14.20
Prunella vulgaris 25 2500 3.2 6.4 12.6 25 9.20 5.88 11.88

Polygonum convolvulus 250 2500 420 780 1380 2500 258.68 250.28 265.64
Rumex crispus 25 2500 40 80 160 320 205.84 143.12 262.20Annex 13

366 Boutin et al.

Appendix 1. Continued

Range ﬁnding test
)1
(g ai ha ) Deﬁnitive test Conﬁdence intervals
EC 50
Plant species LOEL a HOEL a Concentrations tested (g ai ha ) (g ai ha ) Lower Higher

Anagallis arvensis 25 2500 3.4 6 12 20 11.64 4.80 15.54
Digitalis purpurea 25 12500 2.5 5 10 20 2.46 Not possible

Sinapis arvensis 25 2500 1000 1800 3240 5840 2568.54 1879.02 3037.96
Papaver rhoeas 250 2500 300 600 1200 2400 285.68 230.36 425.06

(e) Metsulfuron methyl

Bellis perennis 0.04 40 0.08 0.12 0.18 0.28 0.0550 0.0500 0.0638
Centaurea cyanus 0.04 40 0.6 1.2 2.2 4 1.6250 0.6796 2.8316

Inula helenium 0.04 40 0.04 0.08 0.16 0.32 0.0236 0.0228 0.0242
Rudbeckia hirta 0.04 40 0.04 0.08 0.16 0.32 0.0678 0.0430 0.0816

Solidago canadensis 0.04 0.4 0.06 0.09 0.136 0.2 0.0692 0.0536 0.0830
Leonorus cardiaca 0.04 20 0.04 0.08 0.16 0.32 0.1406 0.1112 0.1728

Mentha spicata 0.04 20 0.04 0.08 0.16 0.32 0.0392 0.0338 0.0614
Nepeta cataria 0.04 40 0.04 0.08 0.16 0.32 0.0392 0.0338 0.0614
Prunella vulgaris 0.04 20 0.02 0.04 0.08 0.16 0.0246 0.0164 0.0312

Polygonum convolvulus 0.4 40 0.5 1 2 4 0.2888 0.2794 0.3036
Rumex crispus 0.04 20 0.068 0.122 0.22 0.4 0.0604 0.0540 0.0706

Anagallis arvensis 0.04 20 0.01 0.02 0.04 0.08 0.0238 0.0120 0.0370
Digitalis purpurea 0.04 20 0.4 0.8 1.6 3.2 0.6252 0.5074 0.7532

Sinapis arvensis 0.04 400 0.04 0.08 0.16 0.32 0.0496 0.0374 0.0614
Papaver rhoeas 0.04 20 0.04 0.08 0.16 0.32 0.0424 0.0348 0.0584

(f) Pendimethalin

Bellis perennis 2000 10000 2000 3600 6480 11664 1200.34 1122.00 1372.00
Centaurea cyanus 2000 10000 10000 15000 20000 25000 8280.72 7524.00 17254.00

Inula helenium 200 10000 400 800 1600 3200 304.34 274.00 342.00
Rudbeckia hirta No result 15000 22500 33700 50500 8966.44 8362.00 10158.00

Solidago canadensis 200 10000 300 600 1200 2400 1068.56 Not possible
Leonorus cardiaca 20 20000 25 50 100 200 44.24 24.88 65.80
Mentha spicata 20 20000 3 6 12 24 4.24 2.60 8.10

Nepeta cataria 200 10000 25 50 100 200 16.34 15.06 18.32
Prunella vulgaris 20 20000 10 30 90 270 8.46 7.48 11.48

Polygonum convolvulus 200 20000 500 1000 2000 4000 343.72 324.60 364.74
Rumex crispus 20 20000 40 80 160 320 53.54 39.90 65.78

Anagallis arvensis 20 20000 5 10 20 40 4.38 3.60 7.02
Digitalis purpurea 20 20000 10 20 40 80 16.06 10.96 19.44

Sinapis arvensis 200 20000 250 500 1000 2000 300.56 206.02 445.40
Papaver rhoeas 20 20000 20 40 80 160 14.32 12.60 16.24

a
LOEL – low observed eﬀect level = lowest dose where an eﬀect occurred; HOEL – high observed eﬀect level = highest dose where an
eﬀect occured before mortality.

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ticides. Fresno, CA: Thomson Publications. British Crop Protection Council. Annex 14

French Republic, Decree On the Use of Products Mentioned inArticle L.253-1 of
Rural Code (5 Mar. 2004) Annex 14

▯▯▯▯▯▯▯▯▯▯▯▯▯▯ OFFICIAL GAZETTE OF THE FRENCH REPUBLIC▯▯ ▯▯▯▯

▯ ▯ ▯ ▯ ▯ ▯
Decree of 5 March 2004 regarding the aerial use of products mentioned in article L 253-1
of the Rural Code▯

NOR: AGRG0400670A

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▯ Annex 14

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ARRETE

Arrêté du 5 mars 2004 relatif à l'utilisation par voie aérien ▯ ne de produits mentionnés
à l'article L. 253-1 du code rural

NOR: AGRG0400670A

Version consolidée au 01 mai 2010

La ministre de l'écologie et du développement durable, le ministre de la santé, de la famille et des personnes
handicapées et le ministre de l'agriculture, de l'alimentation, de la▯ pêche et des affaires rurales,

Vu le code rural, et notamment ses articles L. 253-1 à L. 254-2 ;

Vu le code de la santé publique, et notamment ses articles L. 1321-2, L ▯ . 5132-2 et R. 5167 ;

Vu le code de l'aviation civile ;

Vu le code de l'environnement, et notamment ses articles L. 331-1 à L. 331-25 et L. 332- ▯ 1 à L. 332-27 ;

Vu l'arrêté du 25 février 1975 modifié fixant les dispositions▯ relatives à l'application des produits antiparasitaires à

usage agricole ;

Vu l'avis de la commission des produits antiparasitaires à usage agricole en date du 28 mars 2003,

Article 1 En savoir plus sur cet article...

Au sens du présent arrêté, on entend par traitement aérien toute utilisation au moyen d'aéronefs, tels que définis
à l'article L. 110-1 du code de l'aviation civile, de produits mentionnés à l'article L. 253-1 du code▯ rural à des fins
de protection des végétaux.

Le donneur d'ordre est celui pour le compte duquel est effectué le tra ▯ itement aérien, l'opérateur celui qui en

assure la réalisation.

Article 2 En savoir plus sur cet article...

Tout traitement aérien est soumis à une déclaration préalable comportant les éléments suivants :

- le formulaire prévu à cet effet, dûment rempli ;

- à défaut d'avoir indiqué sur ce formulaire la localisation précise des points de▯ ravitaillement de l'aéronef, un plan
au 25000 précisant la localisation de ces points ;

- toute autre information jugée utile par le donneur d'ordre ou l'opér▯ ateur.

Article 3 En savoir plus sur cet article...
Modifié par Décret n°2010-429 du 29 avril 2010 - art. 6 (V)

Le donneur d'ordre et l'opérateur du traitement aérien adressent la déclaration visée à l'article 2 à la direction
régionale de l'alimentation, de l'agriculture et de la forêt, servi▯ ce régional de la protection des végétaux, ou à la

direction de l'agriculture et de la forêt, service de la protection ▯ s végétaux, pour les départements d'outre-mer.

Il tient également à la disposition des agents de ces services la l▯ iste des personnes concernées par chaque
chantier de traitement aérien ainsi que les coordonnées cadastrales des parcelles faisant l'objet d'une déclaration

1 of 3 1/26/11 4:38 AMAnnex 14

Détail d'un texte ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

de traitement aérien.

Cette déclaration doit parvenir au service concerné au plus tard le jour ouvré précédant▯ la date prévue du
traitement aérien et 24 heures au moins avant le début de la réalisation du traitement déclaré.

Article 4 En savoir plus sur cet article...
Modifié par Décret n°2010-429 du 29 avril 2010 - art. 6 (V)

Dans les cinq jours qui suivent le traitement aérien, l'opérateur du traitement doit faire parvenir à la direction
régionale de l'alimentation, de l'agriculture et de la forêt, servi▯ ce régional de la protection des végétaux, ou à la

direction de l'agriculture et de la forêt, service de la protectio▯ s végétaux, le formulaire prévu à l'article 2 du
présent arrêté, dûment rempli, ainsi que toutes informations▯ jugées utiles par la direction régionale de
l'alimentation, de l'agriculture et de la forêt, service régio▯ e la protection des végétaux, ou à la direction de
l'agriculture et de la forêt, service de la protection des végét▯ aux, pour les départements d'outre-mer.

Article 5 En savoir plus sur cet article...

L'utilisation pour les traitements aériens de produits antiparasitaires classés "toxique" et "très toxique" au sens de
l'article L. 5132-2 du code de la santé publique est interdite.

Article 6 En savoir plus sur cet article...

Lors des traitements aériens, l'opérateur doit respecter une distance minimale de sécurité de 50 mèt▯ res vis-à-vis
des lieux suivants :

- habitations et jardins ;

- bâtiments et parcs où des animaux sont présents ;

- points d'eau consommable par l'homme et les animaux, périmètres d ▯ e protection immédiate des captages pris

en application de l'article L. 1321-2 du code de la santé publique ;

- bassins de pisciculture, conchyliculture, aquaculture et marais salants ;

- littoral maritime, cours d'eau, canaux de navigation, d'irrigation et de drainage, lacs et étangs d'eau douce ou

saumâtre ;

- ruches et ruchers déclarés ;

- parcs d'élevage de gibier, parcs nationaux, ainsi que les réserves naturelles au titre respectivement des articles

L. 331-1 à L. 331-25 et L. 332-1 à L. 332-27 du code de l'environnement.

Article 7 En savoir plus sur cet article...

Lorsqu'un traitement aérien a lieu sur un couvert végétal ne permettant pas au pilote de l'aéronef de s'assurer de
l'absence de personnes dans la zone à traiter ou sur un espace fréquenté par le public, le donneur d'ordre doit

porter au préalable à la connaissance du public, notamment par voie d'affichage, la réalisation de ces traitements.

Article 8 En savoir plus sur cet article...

Les articles 5, 6 et 7 de l'arrêté du 25 février 1975 susvisé▯ sont abrogés.

Article 9 En savoir plus sur cet article...

Les agents mentionnés au I de l'article L. 251-18 du code rural sont habilités à rechercher et constater les
infractions aux dispositions du présent arrêté.

Le fait de ne pas respecter les dispositions du présent arrêté,▯ en particulier le défaut de déclaration ou la
présentation de déclaration fausse ou incomplète, est puni des peines prévues au II de l'▯ article L. 253-17 du code

2 of 3 1/26/11 4:38 AM Annex 14

Détail d'un texte ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

rural.

Article 10 En savoir plus sur cet article...

Le directeur général de l'alimentation, le directeur de la prévention des pollutions et des risques et le directeur
général de la santé sont chargés, chacun en ce qui le concerne, de l'exé ▯ cution du présent arrêté, qui sera publié

au Journal officiel de la République française.

Le ministre de l'agriculture, de l'alimentation, de la pêche et des af▯ faires rurales,

Pour le ministre et par délégation :

Le directeur général de l'alimentation,

T. Klinger.

La ministre de l'écologie et du développement durable,

Pour la ministre et par délégation :

Le directeur de la prévention des pollutions et des risques,

T. Trouvé.

Le ministre de la santé, de la famille et des personnes handicapées ▯ ,

Pour le ministre et par délégation :

Le directeur général de la santé,

W. Dab.

3 of 3 1/26/11 4:38 AMAnnex 14 Annex 15

Las Palmas Ltda., Technical Department, Glyphosate (10,4 l/ha) and Three Different Adjuvants,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Glyphosate in Illicit Crops: Final Report (July 2004) Annex 15

GLYPHOSATE (10.4 L/HA) AND THREE ADJUVANTS,

FOR THE CONTROL OF ILLICIT COCA CROPS, Erythoxilum spp.

AGRONOMIC EFFICACY TESTING OF DOSES OF
GLYPHOSATE IN ILLICIT CROPS

FINAL REPORT

(Seal) Las Palmas

TECHNICAL DEPARTMENT

Bogota, July 2004

1Annex 15

GLYPHOSATE (10,4 L/HA) AND THREE DIFFERENT ADJUVANTS, FOR ILLICIT COCA
CROP (Erythoxylum spp.) CONTROL

(AGRONOMY EFFICACY TESTING OF
DOSES OF GLYPHOSATE IN ILLICIT CROPS)

1. INTRODUCTION

The United States Embassy Narcotics Affairs Section (NAS) supports the Colombian State’s efforts in

its strategic goal of reducing the drug supply by fighting drug production, trafficking, and distribution,

including the destruction of existing illicit crops either manually or through aerial spraying with

herbicides, as well as the illicit drug business support infrastructure.▯

Recently, the Government of the Republic of Colombia decided to reinitiate the eradication of illicit

crops, using a dose of 10.4 liters of a commercial formula (CF) of the herbicide glyphosate, along with
an adequate adjuvant. That is why the need to forward agronomic efficacy testing became evident, in

order to meet the standard requirements set by the Colombian Farming and Livestock Institute (ICA)

and by the environmental authorities, as set forth in 1995 Ministry of Agriculture and Rura▯l

Development Resolution 3079.

The Colombian Government, along with the United States Government through its Narcotics Affairs

Section (NAS), contracted Sociedad las Palmas Limitada’s Technical Department to conduct and track

the agronomic efficacy testing, using a dose of 10.4 L/ha. of a commercial formula of glyphosate and

three different types of adjuvants in the provincial department of Guaviare, following the terms set
forth in a Technical Protocol approved by ICA experts. The first phase of applying these treatments

started on February 10, using the Colombia National Police (PNC) Anti-Narcotics Division Base

located on the premises of the local airport, to spray commercial coca plots (Erythroxylum spp.).

Through the above-mentioned Protocol Efficacy Testing, we intended to evaluate the effectiveness of

the different treatments with the three different adjuvants, test their effect on the environment, identify

the main conditions that could improve the effect of the spraying and, thus, the efficacy of the Illicit

Crop Eradication Program.

4 Annex 15

2. BACKGROUND AND JUSTIFICATION

The eradication of coca and other illicit crops is of major concern in all producing countries, and the

fastest, safest alternative to controlling the harm caused by drugs, including deforestation and planting

of new crops, is the eradication of the existing illicit crops.

The information obtained throughout the years while control has been enforced on i▯llicit crops in

Colombia using aerial spraying of glyphosate (30, 31) has demonstrated that the commercial formula of

the herbicide glyphosate has been adequate, although it has raised some controversies. Sociedad Las
Palmas Ltda.’s Technical Department was selected among the institutions invited to bid on doing the

agronomic efficacy testing, and it was previously established that those tasks ▯were to be carried out and

performed following the parameters contained in a special Protocol to be approved and supported by

ICA. All field testing was to be witnessed and supervised by ICA, National Directorate for Dangerous
Drugs (DNE), and Ministry of the Environment, Housing and Territorial Development representatives,

in addition to technical supervision by the United States Embassy NAS Office.

5Annex 15

5.0 LITERATURE REVIEWED

There is no information or experience regarding illicit crop eradication using aerial spra▯ying of

herbicides from altitudes greater than 10 meters in international technical literature. As a matter of fact,

the most updated information may well be the Colombian experience related to the treatments and
aircrafts used by the Illicit Crop Eradication Program (Briñez, 5), (Helling, 13), (Revelo, 30, 31, 32),

for spraying from altitudes greater than those traditionally used in phytosanitary agronomic programs.

We found no experiences other than the above-mentioned ones and those indirectly related to the topic

found in different unpublished isolated reports or whose distribution is restricted. In some cases, they
are specialized articles and in many cases, they are not reliable signed sources.

There is a report of interest prepared by Sociedad Las Palmas Ltda.’s Technical Department, in charge

of Gemsi Ltda. (Revelo, 31), which documents discharge and drift testing experiences in T-65 aircraft
from maximum altitudes of 20 meters. Through the search engines available on Internet, there is no

information regarding aerial spraying of illicit crops from more than 20 meters of altitude.

Notwithstanding the above, it is worth mentioning that there are some good contributions made by Eng.
Orlando Briñez (5), experts L. E. Parra, Lake Ellis and M. Revelo P., Eng. Jairo Pérez, from Consulting

Firm EPAM and several bulletins prepared by the Tennessee University Engineering Department (46),

USA, WRK from Manhattan, and by Bishop Equipment MFG., INC, Steward Agricultural Research
Services Inc. (Missouri) USA, Spray Drift Task Force ( 33a) (Missouri), in addition to other sources of

reference. In the specific case of Colombia, there are some publications that are also useful, written a

few years ago by Ciba Geigy (8, 9) as part of phytosanitary technical advice to be used in food and

industrial crops), Hernández (14), Calderón (6) and Angel (2▯), to name a few.

In addition to the above, in all experiences similar to those of Colombia which have taken place in

Peru, Bolivia, and Panama (Helling, 13), the spraying was done from very low altitudes and, therefore,

the corresponding technical parameters cannot be used as applicable references for the spraying done in
Colombia.

12 Annex 15

The Project Technical Director was concerned that the labor did not include studies related to the effect
of certain properties of each adjuvant concerned, but, taking into account that the terms in the

Technical Protocol could not be modified after approval, the discharge testing had to be done leaving

various technical aspects out and without including any comparison spraying for data of a discharge

using a formula with a 10.4-liter glyphosate mix without adjuvants.

Reviewing the data in the Charts and Graphs in Section 7.1.1 herein enabled us to identify various

results of great importance for any spraying program. Among them, we highlight the following:

a) Although the environmental conditions under which the discharge, evaporation, and drift

testing was done were not ideal, they were not outside the acceptable margins adopted in

the Colombian National Police Anti-Narcotics Division Illicit Crop Eradication Pr▯ogram.

b) There was much variation in the “losses” of the product due to evaporation, drift or other

causes, in the mixes being tested, but we have no adequate evidence to identify the

magnitude and individual causes of such variation and, with no no facts to the contrary, we

could think that some portion of the variations may be due to some of the
physical-chemical characteristics of the adjuvants used, including the effect of diff▯erences

in the quantities of the active ingredient applied in the tested mixes. Also, the lack of results

of comparison to a glyphosate-based treatment without adjuvants does not enable us to
know to what point the reducing effect of the surface tension of some or all of the adjuvants

tested could have acted.

c) The greatest losses occurred in the glyphosate mix using the adjuvant Cosmoflux 411 F (the
Commercial Control Treatment), representing losses of 72.67% and the least losses, based

on the data available, was 32.69% using the glyphosate mix with the adjuvant Agrotin,

according to the numerical data obtained. The mixes using the adjuvants Potenzol and

Inex-A gave intermediate values, as may be appreciated by reviewing the average data on
the actual discharges, which appears in the charts and graphs included i▯n this section of the

report.

d) The results of the testing enabled us to calculate that the theoretical spray discharge should be
0.250 mg/cm of mix, in which 16% would correspond to the equivalent acid of glyphosate▯,

that is to say, 0.0374 mg/cm 2, or 21.33 % of isopropylamine salt, that is to say, 0.04992

40Annex 15

2
mg/cm . Reviewing the records of the original readings and analyzing the water-sensitive

paper cards enabled us to calculate that this value was not reached in any of the spraying
operations, as may be seen below.

CHART 7.1.1. d 1

DISCHARGE CALCULATED BY PROCESSING

THE DATA FROM THE CARDS

mg. of Recovery % of Recovery

2
Glyphosate with Cosmoflux 411 F 0.06397 mg/cm 27.33% recovery
2
Glyphosate with Agrotin 0.15747 mg/ cm 67.31% recovery
Glyphosate with Potensol0.11837 mg/cm 2 50.58% recovery

Glyphosate with Inex-A 0.07034 mg/cm2 30.05% recovery

e) Based on the experiences of aerial spraying using pesticides in phytosan▯itary programs

(Aerial Application of Agrochemicals, 1979), we already expected the spray particles with
less than 200-micron average diameters to be very susceptible to the effect of evaporation,

if the discharge from the spraying equipment is done from more than 5 meters of altitude,

and especially if conditions of temperature, relative humidity, and rising or transversal air
currents facilitate evaporation. This phenomenon appears to have occurred in some of the

test spraying done at the beginning of the San José del Guaviare Airport runway, if we keep

in mind that no stains less than 250 microns in diameter were identified on the water-
sensitive paper cards. The experiences in phytosanitary handling also indicated to us that

even in the most refined spraying equipment calibration processes (8, 8a. – Ciba-Geigy), a

good portion of the particles of the sprayed material breaks down into particles smaller than

200 microns in diameter, which can evaporate in a few seconds while falling to the ground. ▯
Due to the above, it was not too adventurous for us to estimate that most of the particles

smaller than 300 microns in diameter would not reach the surface of the water-sensitive

paper cards and that they were lost due to evaporation or transversal drift during their fall,
before reaching the ground.

f) In one part of the testing (Cosmoflux and Inex-A), without a doubt, we▯ saw the

phenomenon of drift evidenced by a lateral shift of some stains on the paper of up to 10

meters of distance, from the central axis of the spray swath, due to a transversal wind

41 Annex 15

8.0 CONCLUSIONS AND RECOMMENDATIONS

After concluding the field testing and laboratory tests stipulated in the Experimental Protocol designed
to measure the efficiency of the spraying using 10.4 L/ha commercial formula of glyphosate with one

of four adjuvants selected to be part of the 23.4 L/ha formula used, we drew the conclusions that we
summarize below.

8.0.1 Calculation of Spray Deposit and Drift, Using 10.4 L./ha Commercia▯l Formula of Glyphosate

a) We would like to say that the results foreseen in this objective could ha▯ve been better if we

had not had the limitations of resources, materials, and time stipulated in the Official
Protocol. Despite the above, the results achieved were very satisfactory▯.

b) The glyphosate mix with Agrotín had least losses in the 30-meter fall from the spraying

equipment nozzle to the coca plant leaves, followed by the glyphosate mix with▯ Potenzol.
However, with the results of the discharge, evaporation, and drift testing, we still cannot

explain for certain why these two mixes were superior to the glyphosate mix with Inex-A

and the glyphosate mix with Cosmoflux 411 F (27). Not having included a glyphosate mix

without any adjuvant in the testing impeded us from being able to evaluate the effect of
glyphosate without those adjuvants, because, even the commercial formula already comes

with a special adjuvant.

8.0.2 Aerial Spraying of the Coca Crop Plots

a) Although all of the mixes used provided a degree of coca crop control superior to 85%,

with the data available, we could not identify for certain which was the most or least

effective. Nonetheless, we can affirm that the 10.4 L/ha dose of glyphosate was efficient
and effective from an agronomic point of view.

b) Although we do not know the causes due to which the glyphosate mix with ▯Agrotín so

notoriously reduced losses from evaporation and drift and we still do not know the
economic surfactance threshhold of that adjuvant, we could recommend adopting the

glyphosate mix with Agrotín, as an alternative to the glyphosate mix with Cosmoflux, in

spite of the fact that the treatment using the glyphosate mix with Cosmoflux provided

degrees of mortality of the sprayed coca plants at percentages equal or superior to the
glyphosate mix with Agrotín or the glyphosate mix with Potenzol.

104Annex 15

8.0.3 Sampling and Evaluation of Bodies of Water and Soils Likely Contaminated▯ with Glyphosate

We met this specific objective completely. In addition, we would like to mention that no harmful

effects on the plants that could have absorbed water with glyphosate res▯idues were identified.

8.0.4 Evaluation of the Effect of Glyphosate on Native Vegetation in Spr▯ayed Plots

We met this specific objective satisfactorily and we can affirm that no degrading impacts on the soil or

the flora in the coca plots treated with the glyphosate mixes were identified.

8.1 CONCLUSIONS AND SUGGESTIONS

The following comments may summarize the overall evaluation of the results of the research process

called “Protocol for Agronomic Efficacy Testing of a Dose of Glyphosate with Three Different
Adjuvants, for the Control of Illicit Crops”.

ONE
The results of the CONTROL of the sprayed coca crops using the diferent glyphosate mixes are very

good and overwhelmingly exceed 85% mortality of the sprayed crops, as may be appreciated by

reviewing the summary of the Statistical Analyses. The AGRONOMIC EFFICIENCY (coca plant▯
control) of the Illicit Crop Eradication Program is very good, although it could be better from another

perspective.

TWO

Based on the results of the discharge, evaporation, and drift testing, the quantity of glyphosate that is

deposited on the coca plant leaves, in some cases, is barely near one third part of the quantity
discharged from 30 meters of altitude. In spite of the above, the quantity that is deposited on the plant

leaves is sufficient to cause the mortality of the coca plants.

THREE

With the data from spraying the commercial coca crops, we believe that all of the mixes tested were
very effective, including the glyphosate mix with Cosmoflux 411 F, corresponding to the Commercial

Control Treatment, despite the fact that it is the mix using with losses of more than 70% of the quantity

discharged from 30 meters of altitude.

105 Annex 15

FOUR

The results of the discharge, evaporation, and drift testing, do not enable us to recommend for certain

the adjuvant that most contributes to coca crop control and, although there are several tech▯nical reasons
that suggest that AGROTIN is the best, followed by POTENZOL, we cannot yet recommend them

without any reservation, in spite of them being the most opted adjuvants to incorporate into the
eradication program.

The technical data from the testing done as part of the Experimental Protocol indicates that, in addition
to using the appropriate calibration for the spraying equipment, the adjuvants can also contribute to

reducing losses from evaporation, drift, and other causes, to the benefit of the agronomic efficiency of

the dose of glyphosate.

FIVE

If we take into account the NOEL or NOEC (Non Observable Effect Concentrations) values of 158 mg.
of technical-grade glyphosate per kg. of soil and of 3.74 mg. per liter of water, the Eradication Program

spraying using 10.4 L/ha of commercial-grade glyphosate does not cause soil contamination in the coca
crop plots or in the water bodies in or near the coca crop plots and any▯ residue that may possibly

contaminate a lentic body is of a non-significant value and of no toxicological or environmental

importance (29).

106Annex 15

9.0 SUMMARY

We designed a Technical Protocol that was reviewed and appraised by ICA and NAS to individually

measure the Agronomic Efficacy of aerial spraying from 30 meters of altitude using Cosmoflux under
the Illicit Crop Eradication Program. The testing was done on the illicit coca crops located in the

Provincial Department of Guaviare.

To have some reference estimates on the coca plants to be eliminated, we designed a test to measure
the values of the discharge and losses from evaporation and drift in the operation base failities. This

testing was done at the airport, not on the coca crops when they were sp▯rayed for control purposes

(which would have been the most desireable and appropriate thing to do), for security reasons and for

not being in a position to do the testing on the commercial coca crop plots themselves.

As part of the objectives stipulated in the Experimental Protocol, we also evaluated the effect of

possible glyphosate contamination of the soil and bosies of water, in addition to the vegetation covering
in the sprayed illicit crops.

Another part of the Experimental Protocol was the task of measuring the losses of the mix sprayed

from 30 meters of altitude due to evaporation, drift, and other causes. The results that we came up with
were: using the glyphosate mix with the adjuvant Agrotín, the losses were 36.69%; using the

glyphosate mix with Potensol they were 49.32%; using the glyphosate mix with Inex they were 69.95%

and using the glyphosate mix with Cosmoflux (the treatment that we used as the Commercial Control

Treatment) they were 72.67%. Using the glyphosate mix with Agrotín there were least losses, but we
must clarify that, the particle recovery cards did not identify particles ▯less than 300 microns in diameter

using any of the mixes.

The cover of all of the plant species native to the ecological area wher▯e the illicit crops grow was not
significantly affected and two to three months later the cover looked the same as it had before the

spraying.

We saw the effect of drift using one of the mixes when the wind velocity exceeded tolerable limits. The
spray particles traveled up to 10 meters away from the foreseen discharge point.(See datas and

diagrams corresponding to Inex-A).

107 Annex 16

Republic of Slovenia, Act on Plant Protection Products (9 Sept. 2004) Annex 16

Official Consoliated version of Act on plant protection product; OJ No. 11/01 and 37/04

ACT ON PLANT PROTECTION PRODUCTS

Official consolidated version

Official Gazette of the Republic of Slovenia, No. 98/2004
9. September 2004

I. GENERAL PROVISIONS

Article 1

(content)

This Act regulates the placing on the market and the control of active substances which are plant
protection products (hereinafter: »PPP«), the authorisation of PPP, the issue of authorisations on the

basis of this Act, the placing on the market, use and control of PPP, residues of PPP, the register of
PPP and the register of legal and natural entities involved in the placing on the market of PPP, the
delivery of data and the keeping the records associated with PPP, technical requirements for

equipment for the application of PPP (hereinafter: »equipment«) and its elements, authorizations of
bodies responsible for the implementation of this Act and for the monitoring thereof and for of the
implementation of rules issued on the basis thereof.

This Act also regulates the authorization of PPP, cont aining or composed of genetically modified
organisms, provided that the authorization for the release into the environment of genetically
modified organisms has been granted after the ri sk to the environment ha s been assessed in
accordance with provisions of the regulation on genetically modified organisms.

The import into and the export from the territory of the European Union (hereinafter: »EU«) is
provided for with this Act and regulations, governing the import into and the export from the

territory of the EU of certain dangerous chemicals.

PPP shall be classified, packed and labelled in accordance with this Act and with the regulations on
chemicals.

Production of PPP, the related placing on the market, notification in relation to the content of safety
data sheets and good laboratory practice, and th eir control are governed by the regulations on

chemicals.

Wastes of PPP, their waste packaging and the state of immissions of PPP in the environment are
governed by the regulations on environmental protection.

Article 2
(meaning of terms)

The terms used in this Act shall have the following meaning:

1. PPP shall be in final form active substances and preparations, which are intended to:

- protect plants or plant products against harmful organisms or prevent the action of such
organisms;
- influence the life processes of plants, other than as a nutrient;

1/35Annex 16

Official Consoliated version of Act on plant protection product; OJ No. 11/01 and 37/04

More detailed content and manner of keeping re cords and data communication shall be laid down
by the minister in agreement with the minister of health.

Article 7

(sale of PPP)

PPP shall be placed on the market with regards to the classification, packaging and intended use:
- only in sales outlets specialised in PPP or;

- also in flower-shops and sales outlets with non-food goods or;
- also in a special section of sales outlets with foodstuffs.

A point of sale shall be specified by the competent authority by means of an authorisation upon the
proposal of the commission for PPP (further on as the »Commission«).

PPP for which it is provided for with the authorisation to may be sold in specialised sales outlets

only, shall be sold only to a user, who presents a valid certificate to meet the conditions as regards
education or professional competence as provided for in the regulation laid down in Article 9 of this
Act.

Article 8
(proper use of PPP)

PPP must be used properly.

Proper use of PPP shall mean compliance with the instructions for use and quotation on label,
including preparation of PPP in the prescribed concentration, respecting the principles of good

agricultural practice, of integrated plant protection, if possible, and ▯the protection of environment
and of non-target organisms.

Aerial application of PPP shall not be permitted.

The use of PPP in a manner so as to cause pollution of residential, business and similar premises,
used by people or animals, and the neighbouring land and waters, shall not be permitted.

Users of PPP, who are performers of plant health pursuant to Article 9 of this Act, shall keep
records on the use of PPP in the pres cribed manner, provide for the proper storage of PPP and

management of PPP waste, pursuant to regulations governing the waste management.

Only the use of authorised PPP may be advised, advertised or recommended, and only for the
purposes as specified in the authorisation and in instructions for use, and in accordance with the

wording stated on the label.

Obligations of users as regards the use of PPP and the more detailed content and the manner of
keeping the record shall be prescribed by the minister.

Article 9
(operators of plant protection)

A legal or natural entity involved in agricultural activity and being a market producer may use PPP
only if meeting the prescribed conditions as regards education or professional competence and if
being equipped with corresponding equipment for the application of PPP.

5/35 Annex 17

United Kingdom, Department for Environment, Food and RuralAffairs, Code of Practice For
Using Plant Protection Products (2006) Annex 17

Pesticides

Code of practice for using plant

protection products
This code of practice has been prepared jointly by the Department for Environment,
Food and Rural Affairs (Defra), the Health and Safety Commission (HSC) and the
National Assembly for Wales Environment, Planning and Countryside Department.

Agriculture

Amenity

Horticulture

ForestryAnnex 17

This code is also available on the PSD website
(www.pesticides.gov.uk/farmers_growers_home.asp#Codes_of_Practice)
and on the Defra website (www.defra.gov.uk///)

A Welsh language version of this code is available on the NAW website (//www.wales.gov.uk///).
Printed copies of the Welsh language version are available from:

Plant Health and Biotechnology Branch Biotechnoleg a Iechyd Phlanhigion
Animal and Plant Health Division Is-Adran Polisi Iechyd Anifeiliaid a Phlanhigion
Welsh Assembly Government Llywodraeth Cynulliad Cymru
Department for Environment, Planning and Adran yr Amgylchedd, Cynllunio a

Countryside Chefn Gwlad
Cathays Park Parc Cathays
Cardiff CF10 3NQ Caerdydd CF10 3NQ

As a Scottish version of this code (approved by the Scottish Parliament) is being produced, this code is for
England and Wales only. The Scottish version of the code will be available on the Scottish Exe▯cutive website.
Printed copies of the Scottish version will be available from:

APPP
Scottish Executive Environment and Rural Affairs Department
Pentland House, 47 Robb’s Loan
Edinburgh EH14 1TY.
Phone: 0131 244 6356

E-mail: [email protected]
Northern Ireland will produce their own updated version of this code in due course.

Department for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London SW1P 3JR

Telephone 020 7238 6000
Website: www.defra.gov.uk

The text in this document (excluding the Royal Arms and departmental lo▯gos) may be reproduced free of
charge in any format or medium provided that it is reproduced accurately and not used in a misleading
context. The material must be acknowledged as Crown copyright and the title of the document specified.

Any enquiries relating to the copyright in this document should be addressed to

The Information Policy Team, Office of Public Sector Information,
St Clements House, 2-16 Colegate, Norwich, NR3 1BQ.
Fax: 01603 723000 or e-mail: [email protected]

Further copies of this publication are available from:

Defra Publications
Admail 6000

London
SW1A 2XX
Tel: 08459 556000

This document is also available on the Defra website

Published by the Department for Environment, Food and Rural Affairs. Printed in the UK, January 2006, on
material that contains 100% recycled fibre for uncoated paper and a minimum of 75% recycled fibre for
coated paper.

Product code PB 11090 Annex 17

Pesticides

Code of practice for using plant
protection products

January 2006Annex 17

Working with pesticides

4.7.2 What causes spray drift?

A combination of factors may contribute to spray drift, including:

• the speed of the wind;

• the height of the spray nozzles, the design of the equipment and ground conditions;

• the spray quality (which will depend on the choice of nozzles and the s▯pray pressure);
• the type of crop or other vegetation, if any;

• the speed of the vehicle the spray is being applied from;

• local atmospheric conditions;
• the condition of the equipment used to apply the pesticide; and

• the equipment settings.

4.7.3 Weather conditions
Do not apply pesticides in a way which may lead to drift. You should think about:

• if the wind direction and speed would cause the pesticide to drift away from the target; or
• there is a chance that air movement will carry spray droplets or vapour away from the
target area.

This is especially important when spraying near sensitive areas.

Check the weather forecast before starting work. The Meteorological Office gives information on
wind speed measured at 10 metres above the ground. When spraying a typical field crop or
grassland, the wind speed at the correct height of the nozzle (an important factor affecting drift)
will be roughly half the value measured at 10 metres. If there is no crop (for example, when
spraying hard surfaces in amenity areas) the wind speed at the height of the nozzle may be more
than half of the value at 10 metres above the ground. As wind speed and direction will be
influenced by a variety of local factors (such as the presence of trees and buildings), it is

important to assess the suitability of the conditions at the area you intend to treat.

When you arrive at the area you intend to treat, look for signs to show you the wind speed and
direction. If you have a suitable wind-speed meter (anemometer), use this▯. However, you should
take care to make sure that individual meter readings reflect the general situation as you see it.

Remember that hot, dry weather will reduce the size of spray droplets because of evaporation

and increase the risk of spray drift.

The safest conditions in which to spray are when it is cool and humid with a steady wind of 2 to
4 miles an hour or 3.2 to 6.5 kilometres an hour (light breeze) blowing away from any sensitive
areas or neighbours’ land. Avoid spraying in the following weather conditions:

• when there is little or no wind under a clear sky in the morning or evening, when air
layers do not mix, as any drift may hang over the treated area and unexpected air

movements may move it to other places;
• when there are low winds on warm sunny afternoons when humidity is low;

89 Annex 17

Section 4

• when temperatures are above 30˚C, as rising air currents may carry spray droplets and
vapour in an unexpected way.

Whatever equipment you use, make sure that you do not use it when the wind will cause the
pesticide to drift off target. In general, if you have low-drift spraying equipment, use this▯ to

improve the targeting of your pesticide and reduce (to the lowest possible level) the
environmental effect.

The table below is a guide to assessing wind speed and recommendations for standard field crop
sprayers. The relationship between the wind speed at the height of the spray nozzles an▯d the

wind speed (according to the Beaufort scale, measured at a height of 10 metres above the
ground) assumes that there is a crop covering the ground. If there is no crop or grass cover, the

wind speed at the height of the spray nozzle will be higher.

Table 6: A guide to wind speed and using field-crop sprayers with conventional nozzl▯ es

Beaufort scale Description Visible signs Guide for using a Approximate
(measured 10 standard crop wind speed at the
metres above the sprayer height of the
ground) spray nozzle

Force 0 Calm Smoke rises Use only ‘medium’ Less than 2
vertically or ‘coarse’ spray kilometres an hour

quality (less than 1.2 miles
an hour)

Force 1 Light air Smoke drifts, Acceptable spraying 2 to 3.2 kilometres
showing the wind conditions an hour
direction
(1.2 to 2 miles an
hour)

Force 2 Light breeze Leaves rustle and Ideal spraying 3.2 to 6.5
you can feel the conditions kilometres an hour

wind on your face (2 to 4 miles an
hour)

Force 3 Gentle breeze Leaves and twigs Increased risk of 6.5 to 9.6
are constantly spray drift. Avoid kilometres an hour
moving spraying herbicides (4 to 6 miles an
and take special
care with other hour)
pesticides

Force 4 Moderate breeze Small branches are Do not spray 9.6 to 14.5

moved and dust kilometres an hour
and loose paper are (6 to 9 miles an
raised
hour)

90Annex 17

Working with pesticides

4.7.4 How can off-target drift be prevented or controlled?

When using pesticides, take all reasonable precautions to prevent drifting off target. Reasonable
precautions include using appropriate methods and equipment to apply the product, taking
account of the weather conditions, taking account of neighbours’ inte▯rests and protecting

members of the public, wildlife and the environment. Consider the following points:

• Check the weather forecast and the conditions at the site you are treating before you start
to apply a pesticide. Do not apply a pesticide if it is likely to drift ▯off target or if there is a
chance that wind will carry spray droplets or vapour away from the target area;

• Reducing the dose of the product you apply will reduce the amount of product which will
drift off target;

• Use the coarsest appropriate spray quality at all times;
• When using a sprayer,

keep the boom as low as
possible, providing an even
spray pattern at the correct
target height. The correct
boom height will depend
on the spray pattern and
the angle of the individual

nozzles, the space between
nozzles, the flatness of the
area being treated and the
design of the boom;

• When using a sprayer with
hydraulic nozzles, reduce
the spray pressure and
speed of the vehicle (but
make sure you maintain
the intended dose, water

volume and spray quality);
• Consider not treating an area closest to the downwind border of the area you are treating.
For field crops, an untreated buffer zone will be most effective if the crop (or plants of at

least the same height as the crop) continues into the buffer zone;
• In orchards, consider having appropriate natural windbreaks, such as other trees, around
the treated area;

• Use one of the various spraying systems which are available to help reduce spray drift.
Suitable drift-reducing systems may include twin-fluid nozzles, air-induction nozzles, rotary
atomisers, pre-orifice nozzles, air-assistance for field crop sprayers, shrouded-boom

sprayers for sports turf and other amenity areas, and re-circulating tunnel sprayers for
spraying fruit bushes and trees. Sprayers and nozzles meeting the needs for low-drift
equipment under the LERAP schemes will give lower levels of drift than c▯onventional
systems when used correctly;

• Use an authorised drift-reducing additive to pesticides in appropriate situations (depending
on the type of equipment being used and the nature of the spray solution).

91 Annex 17

Section 4

Pesticide manufacturers and suppliers will be able to give you information on their nozzles

and spraying systems.

You can get general advice on how to choose nozzles which will apply the ▯pesticide

effectively while reducing drift in the Voluntary Initiative stewardship leaflet ‘Nozzle selection
and maintenance’, which includes the Home Grown Cereals Authority (HGCA) nozzle
selection chart (see www.voluntaryinitiative.org.uk).

4.8 After working with pesticides

4.8.1 What you need to do after you have applied a pesticide

The following is a brief checklist of what you need to do when you have ▯finished applying
a pesticide.

✓ Clean the equipment you have used, inside and out, preferably before leaving the treatment area.
Dispose of unused spray solution and sprayer washings safely and legally.▯

✓ After cleaning, store the sprayer (or other equipment) under cover.

✓
Return any unused pesticide concentrate to your pesticide store.

✓ Keep the appropriate records.

✓ Remove warning notices when they are no longer needed.

✓ If you have given warnings to beekeepers, tell them that you have finished applying the pesti▯cide.

✓ Make sure that you:

• dispose of used PPE safely and legally (if it is not designed to be use▯d again or is unfit for further
use); or

• where appropriate, clean re-usable PPE before you store it and dispose of washings safely and
legally; and

• report any faults with engineering controls or PPE.

✓ Let the appropriate manufacturers know (either directly or through the supplier) if you have found
any product-related, packaging-related or equipment-related problems when mixing, loading or
applying the product.

92Annex 17

Annex G

Applying pesticides from an aircraft

52 You must meet specific legal obligations before, during and after applying pesticide from the
air. You can only use products which are specifically approved for this purpose, and you must
regularly send details of all pesticides applied from aircraft to:

Pesticides Usage Survey Group (PUSG)

Defra
Central Science Laboratory
Sand Hutton Lane
Sand Hutton
York.

You must follow the conditions of use shown on the product label when applying pesticides from
the air.

Everyone applying pesticides from an aircraft must hold a Civil Aviation Authority qualification
(the aerial application certificate) and, in the case of contractors o▯r people born after

31 December 1964, the appropriate certificate of competence in applying pesticides.

Under the Control of Pesticides Regulations 1986 (as amended) you must give notice to▯ specific
organisations before applying a pesticide from the air. You will also need to consult the following
organisations (see below and table 6) and get their agreement before carrying out the treatment.

53 Consultation
Consultation means more than just giving notice to the relevant authorities. It should take place

well before you intend to apply pesticide and certainly not after the minimum cons▯ultation period
set by law. The person applying the pesticide will need to provide the information so the
organisations consulted can comment in full. You will need to take account of the organisations’
views when deciding how to apply the pesticide (or whether to apply it ▯at all). If you are not sure
what to do, talk to the organisations concerned for more advice.

Ideally, you will consult the relevant authorities when deciding to use a contractor to apply
pesticides from the air. This will give the organisations consulted as much time as possible to▯
consider the matter. They will then have reached a decision by the time you carry out the
consultation you need to do by law.

When you give notice that you intend to apply a pesticide from the air, you must include the
following information:

• The name, address and, where possible, phone number of the person applying the
pesticide;

• The name of the pesticides you will use and their active ingredients;

• The date and time you intend to apply the pesticide;

• Confirmation that you have given the same details to the Chief Environmental Health
Officer for the district.

144 Annex 17

Applying pesticides from an aircraft

54 Consultation and conditions for giving notice before applying

a pesticide from the air
Under the Control of Pesticides Regulations 1986 (as amended) any person applying a p▯esticide

from the air must do the following:

55 At least 72 hours before starting the treatment you must do the following:

• Consult the relevant conservation agency (English Nature or the Countryside Council for
Wales) if any part of a local nature reserve, marine nature reserve, a national nature
reserve or a site of special scientific interest lies within 1500 metres of any part of the land

to be treated;
• Consult the appropriate area office of the Environment Agency if the land to be treated is
next to, or within 250 metres of, water;

• Get permission from the Environment Agency if the pesticide will be applied to control
weeds in water or on the banks of watercourses or lakes.

56 At least 48 hours before starting the treatment you must do the following:

• Give notice to the appropriate reporting point of the local beekeepers’ spray-warning
scheme running in the district.

57 At least 24 hours and (as far as reasonably possible) no more than 48 hours before starting
the treatment, give notice to:

the Chief Environmental Health Office for the district;
•
• the people occupying any property within 25 metres of the boundary of the land to be
treated (or those people’s agents); and

• the person in charge of any hospital, school or other institution with b▯oundaries lying
within 150 metres of the flight path intended to be used for the treatment.

58 At least 24 hours before starting the treatment you must do the following:

• Put sturdy and clear signs within 60 metres of the land to be treated to tell people about
the place, date and time of the treatment.

You can find information on these and other legal conditions in the Civil▯ Aviation Authority

(CAA) booklet ‘Information on requirements to be met by applicants and holders of the aerial
application certificate’ (CAP 414).

145Annex 17 Annex 18

Costa Rica, Executive Decree No. 34202-MAG-S-MINAE-MOPT-G-MSP (21 May 2007) Annex 18

No. 34202-MAG-S-MINAE-MOPT-G-MSP

THE PRESIDENT OF THE REPUBLIC

THE MINISTER OF AGRICULTURE AND LIVESTOCK

THE MINISTER OF HEALTH

THE MINISTER OF ENVIRONMENT AND ENERGY

THE MINISTER OF PUBLIC WORKS AND TRANSPORT

AND THE MINISTER OF THE INTERIOR AND POLICE
AND PUBLIC SAFETY

In exercise of the powers conferred by Article 140, paragraphs 3) and 1▯8), and Article 146 of the
Political Constitution and based on the provisions of paragraph 50 of the Political Constitution,
as well as Articles 2, 4, 239, 240, 244, 278, 298 and 299 of the General▯ Law of Health, No. 5395

of 30 October 1973 and its amendments, Articles 2 and 6 of the Organic Law of the Ministry of
Health, No. 5412 of 8 November 1973 and its amendments, Articles 1, 2, 3, 4 and 5 of the
Organic Law of the Environment No. 7554 of 4 October 1995, Article 5, paragraph o), 8
paragraphs b), e) and j), 23, 25, 30, 32, 35, 39 and 72 of the Law of Plant Protection No. 7664 of
8 April 1997, the Law for Establishment of the Ministry of Public Wor ks and Transport, No.

4786 of 5 July 1971 and its amendments, the Law of Civil Aviation No. 5150 of 14 May 1973
and its amendments and the General Law of Public Administration, No. 6227 of 2 May 1978 and
its amendments.

WHEREAS:

1º-All agricultural aviation activities as well as fumigation activities must be conducted in
conformity with Article 50 of the Political Constitution, in order to guarantee the citizens’ right
to a healthy and ecologically balanced environment without affecting the quality of life of
agricultural workers and their families, with respect to their health, life, the right to work, and the

environmental quality of their surroundings.

2 º -That at promulgation of Executive Decree No. 15846-MAG-MOPT dated 6 November 1984,
its Article 75 took into account the empirical aviation technology of the post-war itself because

the applications were being conducted via the “flagging” ( “banderilleo”) method, so named
because a wor ker would hold a flag as a visual guide for pilots who were fumigating, thereby
generating great criticism for affecting the health of workers, causing material to be wasted,
being imprecise, as well as increased production costs.

3 º-Subsequently, using a more humane approach to agricultural activity, the development of
information technology and satellites used by the agricultural sector throughout much of the
country, the use of information systems which would sensibly reduce drift in aerial fumigation

Annex 18

was possible. Such systems avoid negatively affecting wor kers’ health, as well as the health of
the area’s inhabitants, and allow for a more economical use of the activity. At this time, the
paper entitled Aerial Applications and Drift in Banana Cultivation in Costa Rica ,” written
by J.R. Washington, F. Gauhl, R. Valenciano, and A. Fournier was used as a basis to▯ determine
that aerial fumigations could be conducted using new techniques and scientific developments

without affecting the health or lives of people as long as buffer zones of between 20 and 30
meters were observed. The authors provided the following conclusion in said paper:

[…]
[PAGE 4]

HEREBY DECREE
Amend Article 70 of Executive Decree
No. 31520-MS-MAG-MOPT-MGSP,
Regulations for the Agricultural Aviation activities,

of 16 October 2003

Article 1º--Article 70 of Executive Decree No. 31520-MS-MAG-MOPT-MGPSP, “Regulations
for Agricultural Aviation activities,” of 16 October 2003 is amended, adding the following to the

first paragraph:

[PAGE 5]

b) Height of flight: Must be equal to or less than 5 meters above the crop’s canopy, in order to

reduce the concentration of particles that may be dragged by the wind, so as to minimize drift
and evaporation of the sprayed product.

c) Drop size of the mixture: An average droplet size between 200 and 300 microns (▯m) must
be used in order to minimize drift due to drops with a slower terminal velocity and greater

potential for evaporation.

[…[

g) Meteorological conditions for application: 1) Speed and direction of wind: the wind speed

must not exceed 15 k ilometers per hour when village crop areas are fumigated up to the buffer
zones and wind direction must be against the buffer zones or sensitive zones, 2) Temperature:
applications in village areas up to buffer zones cannot be conducted if ▯temperature exceeds 29
ºC, and, 3) Relative humidity: must exceed 70%.

Annex 18

Nº 34202-MAG-S-MINAE- MOPT-G- MSP

EL PRESIDENTE DE LA REPÚBLICA

EL MINISTRO DE AGRICULTURA Y GANADERÍA

LA MINISTRA DE SALUD

EL MINISTRO DEL AMBIENTE Y ENERGÍA

LA MINISTRA DE OBRAS PÚBLICAS Y TRANSPORTES

Y EL MINISTRO DE GOBERNACIÓN Y POLICÍA

Y SEGURIDAD PÚBLICA

En ejercicio de las facultades conferidas por los artículos 140, incisos 3) y 18); y 146 de la
Constitución Política y con fundamento en lo establecido en el numeral 50 de la Constitución
Política, así como en los artículos 2, 4, 239, 240, 244, 278, 298 y 299 de la Ley Gene▯ral de
Salud, Nº 5395 del 30 de octubre de 1973 y sus reformas; los artículos 2 y 6 de la Ley Orgánica

del Ministerio de Salud, Nº 5412 del 8 de noviembre de 1973 y sus reformas; artículos 1, 2, 3, 4
5 de la Ley Orgánica del Ambiente Nº 7554 del 4 de octubre de 1995, los artículos 5 inciso o)▯, 8
incisos b), e) y j), 23, 25, 30, 32, 35, 39 y 72 de la Ley de Protecc▯ión Fitosanitaria Nº 7664 del 8
de abril de 1997; la Ley de Creación del Ministerio de Obras Públicas y Transportes, Nº 4786 del
5 de julio de 1971 y sus reformas; la Ley General de Aviación Civil, Nº 5150 del 14 de mayo de
1973 y sus reformas y la Ley General de la Administración Pública, Nº 6227 del 2 de mayo de

1978 y sus reformas.

Considerando:

1º—Que todas las actividades de aviación agrícola, y las act▯ividades de aspersión, deben

ejercerse en armonía con el artículo 50 de la Constitución Política, para garantizarle a los
ciudadanos el derecho a un ambiente sano y ecológicamente equilibrado, sin afectar la calidad de
vida de los trabajadores agropecuarios y sus familias, en cuanto a su salud, su vida, el derecho al
trabajo, y la calidad ambiental de su entorno.

2º—Que al promulgarse el Decreto Ejecutivo Nº 15846-MOPT-MAG del 6 de noviembre de
1984, su artículo 75 tomó en cuenta la tecnología aérea empírica propia de la posguerra porque
las aplicaciones se llevaban a cabo mediante el método de “banderilleo”, llamado así porque un
trabajador sostenía una bandera como guía óptica a los pilotos que asperjaban, generando
grandes criticas por afectar la salud de los trabajadores, desperdicio de material, por ser
imprecisa, e incrementaba los costos de producción.

3º—Que posteriormente con un sentido más humano de la actividad agraria, el desarrollo de las
tecnologías y satélites de la información, en uso del sector agrícola de buena parte del país, fue
posible utilizar sistemas informáticos que reducen sensiblemente la deriva en la aspersión aérea,Annex 18

necesidad de actualizar la legislación acorde con los avances tecnológicos, los cuales han venido
a proporcionar un sistema de guía de precisión y un mejor manejo de la deriva, en donde
interactúan varios factores como las técnicas adecuadas de aplicación, uso adecuado del equipo,
condiciones meteorológicas idóneas durante la aplicación, tipo de formulación de producto y el
establecimiento de zonas de amortiguamiento. Por lo anterior, prácticamente se garantizan las

medidas necesarias para minimizar el riesgo por error humano.

10.—Que el Poder Ejecutivo, con fundamento en los avances de la ciencia y de la técnica,
debidamente acreditados en estudios e investigaciones, ha decidido reglamentar la actividad de
aspersión aérea, adicionando el artículo 70 del Decreto Ejecuti▯vo Nº 31520-MS-MAG-MOPT-

MGPSP, “Reglamento para las actividades de Aviación Agrícola”, del 16 de octubre del 2003,
en los términos señalados por la Sala Constitucional para cumplir con el principio del derecho al
ambiente sano y ecológicamente equilibrado, por medio de la exigencia del uso de técnicas
adecuadas de aplicación, de manera que se evite la caída de partículas fuera del perímetro de la

plantación, para reducir el peligro potencial de la deriva se encuentran: altura de vuelo, velocidad
del vuelo, tamaño de gotas, tipo de boquillas, calibración del equipo, equipos de señalamiento
satelital, longitud de barra de aspersión, manejo de condiciones meteorológicas, tipo de
productos y zonas de amortiguamiento, para garantizar la actividad productiva agraria en
armonía con el medio ambiente y los derechos constitucionales de las personas, para

garantizarles su salud, su vida, y su entorno. Por tanto,

DECRETAN:

Reforma al artículo 70 del Decreto Ejecutivo Nº 31520-

MS-MAG-MOPT-MGSP, Reglamento para las

actividades de Aviación Agrícola, del 16 de

octubre del 2003

Artículo 1º—Se reforma el artículo 70 del Decreto Ejecutivo Nº 31520-MS-MAG-MOPT-
MGPSP, “Reglamento para las actividades de Aviación Agrícola”, del 16 de octubre del 2003,
para adicionar al primer párrafo el siguiente:

“La distancia podrá reducirse de 100 hasta 30 metros si se dispone de una zona de
amortiguamiento y se cumplen las siguientes condiciones:
a) Zonas de amortiguamiento. Estas zonas deberán ser áreas reforestadas con árboles de

especies preferiblemente nativas con una altura mayor al cultivo y un ancho mínimo de 30
metros, para servir como barreras para reducir la deriva de las aplicacion▯es aéreas, si la
aplicación se lleva a cabo en dirección paralela a la zona de amortiguamiento. Si la aplicación se
realizara con avión y en forma perpendicular a la línea de cultivo, adicionalmente se deberá dejar
una franja de 40 metros dentro del cultivo, en la que no se deberá asperjar para reducir el efecto

del arrastre. La autoridad administrativa competente podrá aumentar esta distancia mediante
resolución razonada cuando en el área por asperjar existan situaciones particulares y objetivas
que requieran una mayor distancia a pesar de la existencia de la zona de amortiguamiento. La

- 4 - Annex 18

franja de no aplicación de productos podrá omitirse en caso de vías o caminos internos de uso

exclusivo para el cultivo y mientras no existan viviendas.

b) Altura de vuelo. Debe ser igual o inferior a 5 metros sobre dosel de la plantación, para
que la concentración de partículas que pueden ser arrastradas por la influencia del viento, se
reduzcan para minimizar la deriva y evaporación del producto asperjado.

c) Tamaño de las gotas de la mezcla. Se debe trabajar con un tamaño de gota promedio
entre 200 y 300 micras (μm) para minimizar la deriva con una aplicación más lenta en su
velocidad de caída libre y de más fácil evaporación.

d) Calibración sistemática de equipo de aplicación. Para garantizar una aplicación
efectiva y la dosis adecuada de los productos, un técnico capacitado en la materia deberá
verificar el tamaño de las gotas y el flujo de los aspersores con la siguiente frecuencia: 1) Flujo
boquillas: semestral, 2) Número de gotas: semestral, 3) Dosificación: diaria. Antes y después de
las aplicaciones aéreas un técnico deberá realizar una revisión que asegure el buen estado del

sistema de mangueras, aspersores, válvulas, el sistema de señalamiento satelital y del Medidor
Automático de Flujo.

e) Sistemas de señalamiento satelital. Todas las aeronaves deben contar con un sistema de
señalamiento satelital para ofrecer la posibilidad de asegurar una adecuada aplicación de los

productos en las áreas de cultivo, así como de disponer de una evidencia gráfica de esta. Los
gráficos generados por el sistema de señalamiento satelital deben ser mantenidos por la empresa
aspersora, por un mínimo de dos años. En todas las aeronaves que asperjen en fincas que poseen
zonas de amortiguamiento deben instalar en el plazo de un año, un sistema automático de cierre
de aspersores.

f) Longitud de la barra de aspersión (boom). La longitud efectiva de la barra no debe
exceder el 80% de la longitud de cada ala del avión.

g) Condiciones meteorológicas de aplicación: 1) Velocidad y dirección del viento: la

velocidad del viento no puede ser mayor a 15 kilómetros por hora cuando se asperjen las zonas
de cultivo aledañas a las áreas de amortiguamiento y la dirección del viento debe ser contraria a
la zona de amortiguamiento o zonas sensibles, 2) Temperatura: las aplicaciones en zonas
aledañas a las áreas de amortiguamiento no podrán realizarse si la temperatura es superior a los
29 ºC, y, 3) Humedad relativa: debe ser superior al 70%.

h) Tipos de productos. En las fincas que poseen zonas de amortiguamiento sólo se podrán
aplicar vía aérea los productos inscritos y autorizados de conformidad con el artículo 69 de este
reglamento. Dichos productos deben ser de moderada toxicidad.”

Artículo 2.—Rige a partir de su publicación.

Dado en la Presidencia de la República.—San José, a los veintiún días del mes de mayo del dos
mil siete.

- 5 -Annex 18

ÓSCAR ARIAS SÁNCHEZ.—El Ministro de Agricultura y Ganadería, Marco Vargas Díaz; la
Ministra de Salud, María Luisa Ávila Agüero; el Ministro del Ambiente y Energía, Roberto
Dobles Mora; la Ministra de Obras Públicas y Transportes, Karla Gonzá▯lez Carvajal; y el

Ministro de Gobernación, Policía y Seguridad Pública, Fernando Berrocal Soto.—1 vez.—
(D34202-34).

- 6 - Annex 19

Nova Scotia Environment and Labour,
Media Backgrounder: Herbicide Management (July 2007) Annex 19

Media Backgrounder

Herbicide Management

July 2007

Health Canada's Pest Management Regulatory Agency (PMRA), is the federal agency
responsible for the regulation of pest control products in Canada. As the federal authority

under the Pest Control Products Act (PCPA), the PMRA also:

• Develops pest management policies and guidelines;
• Promotes sustainable pest management;

• Looks to improve the regulatory process to increase efficiency;
• Enforces compliance with the PCPA; and,
• Distributes pest management information to the general public and key stakeholders.

Glyphosate is registered with the PMRA for use as a forestry herbicide and other purposes,
such as in the production of food crops and residential home and garden use. The agency
regularly reviews scientific literature on registered pesticides. The PMRA can be reached
at 613-736-3500 if you have questions about glyphosate or their role.

Provincial and territorial agencies, such as Nova Scotia Environment and Labour, are
responsible for ensuring that registered products are used as specified by the PMRA, with

proper care for human health and the environment. Municipalities may also assume some
responsibility.

In Nova Scotia, the forestry application of herbicide s falls under the jurisdiction of Nova

Scotia Environment and Labour. The department requires compliance with the
PMRA-registered label and also imposes conditions of its own. The department's
requirements for the forestry use of glyphosate include:

• Formal application for permission

• Application of the herbicide to a specified spray zone
• Buffer zones around watercourses and wells
• Proper weather conditions for drift control
• In recognition of the right to know, there must be notification of residents and

businesses within 500 metres of the spray area at least 30 days before spraying.
This is a notification zone only – not a danger zone.
• Signs advising of the spraying must be posted on access roads to the area 30 days
in advance

• The company applying the product must be certified by NSELAnnex 19

• The person applying the product must pass an examination and be certified by NSEL
• NSEL must be notified when spraying is about to take place

In addition, NSEL can require special conditions where circumstances warrant.

Glyphosate has been determined by the PMRA to be safe when used as directed on the

product label and presents a low risk. These conditions imposed on its use are effective
management of that risk.

Spraying
The application of glyphosate for forestry, whether from the air or ground, is tightly
controlled.

Aerial spray applicators use low-flying helicopters equipped with Global Positioning Systems
(GPS) and Geographical Information Systems to ensure the spray lands within the
boundaries specified on their permit. The process generates a computer record of where
the spray is applied.

Ground-spray applicators are required to flag the spray boundaries and ensure t he spray
lands within them.

Applicators must meet the same kinds of requirements whether spraying by ground or air,
although aerial buffer zones may be larger.

Compliance
Both ground and aerial applicators are required to notify NSEL before they start work on an
approved area.

NSEL inspectors can and do arrive at approved sites at any time to monitor the spraying
and applicators are aware of that.

NSEL can request the computer records from aerial applications.

Misapplication is obvious from the effect on vegetation.

Citizens are quick to file complaints with NSEL when they believe there is a problem.

Penalties can include loss of certification and fines of up to $1 million.

Contact:

Bill Turpin

Communications Director
902-424-2575
Cell: 902-478-0542 Annex 20

Republic of Estonia, Plant Protection Products Act, entered into force 1 May 2004,
amended 1 July 2008 Annex 20

1
Plant Protection Act
Passed 21 April 2004
2
(RT I 2004, 32, 226),
entered into force 1 May 2004,

amended by the following Act:
21.05.2008 entered into force 01.07.2008 - RT I 2008, 23, 150

01.06.2006 entered into force 01.07.2006 - RT I 2006, 28, 211

08.12.2005 entered into force 01.01.2006 - RT I 2005, 68, 530.

Chapter 1

General Provisions

§ 1. Scope of application of Act

(1) This Act prescribes the requirements for plant health and pl▯ant protection products to guarantee the
safety of plant protection products to the health of human beings and animals and to the environment, as well as

the requirements for plant protection equipment, and the bases and extent of state supervision.
(2) The provisions of the Administrative Procedure Act (RT I 20▯01, 58, 354; 2002, 53, 336; 61, 375; 2003,

20, 117; 78, 527) apply to administrative proceedings prescribed in thi▯s Act, taking into account the

specifications provided for in this Act.
(3) The provisions of this Act apply to plant protection product▯s containing genetically modified organisms,

taking into account the specifications provided for in the Deliberate Release of Genetically Modified Organisms
into the Environment Act (RT I 2004, 30, 209).

§ 2. Notification

The Plant Production Inspectorate shall notify in writing the European Commission and the competent

authorities of other states of the harmful organisms and plant protectio▯n products admitted to the market, as well
as decisions and supervision operations on which notice must be given pursuant to legislation of the European

Union.
(08.12.2005 entered into force 01.01.2006 - RT I 2005, 68, 530)

Chapter 2
Plant Health

Division 1

Plant, Plant Product and Harmful Organism

§ 3. Plant and plant product

(1) For the purposes of this Chapter, ‘plants’ are living plants and living parts thereof, including seeds.
(2) For the purposes of this Act, ‘seeds’ are seeds in the▯ botanical sense which are intended for sowing.Annex 20

3) to minors.

(2) Plant protection products which have not been marketed befor▯e the expiry of the term provided in the

authorisation may be marketed until stocks run out but not beyond one year from the expiry of such term.
(3) The marketing of plant protection products which conform to the requirements and whose durability

period has expired may be continued for up to one year from the expiry of▯ the durability period. A
corresponding comment shall be made on the packaging of plant protection▯ products.

(4) Highly toxic plant protection products must not be marketed by retail sale.

(21.05.2008 entered into force 01.07.2008 - RT I 2008, 23, 150)

(5) Information concerning persons who wish to engage in the mar▯keting of plant protection products and
the conveyance of highly toxic plant protection products to Estonia shal▯l be entered in the register of plant

protection products.
(6) (Repealed - 21.05.2008 entered into force 01.07.2008 - RT I▯ 2008, 23, 150)

§ 77. Storage and marketing facilities for plant protection products ▯

(1) Premises where plant protection products are stored and marketed shall conform to the requirements
provided for in the Chemicals Act and this Act. The plant protection prod▯ucts to be marketed shall be stored and

marketed separately from foodstuffs, medicinal products and animal feed ▯in order to avoid the contamination of

the substances listed above with plant protection products.
(08.12.2005 entered into force 01.01.2006 - RT I 2005, 68, 530)

(01.06.2006 entered into force 01.07.2006 - RT I 2006, 28, 211)
(2) There shall not be any open packages of plant protection pro▯ducts in the storage and marketing facilities

of plant protection products. It is prohibited to re-package plant prote▯ction products at the facilities where the
products are stored or marketed. Plant protection products with broken pa▯ckaging shall be promptly removed

from distribution and rendered harmless pursuant to the procedure provided in the Chemicals Act.

(3) Before the marketing of plant protection products is commenc▯ed, the distributor of the plant protection
products shall apply to the Plant Production Inspectorate for entry of th▯e marketing premises in the register of

plant protection products.
(4) Records shall be kept at the marketing premises concerning p▯lant protection products marketed on the

basis of plant protection certificates. The procedure for keeping records concerning plant protectio▯n products
marketed on the basis of plant protection certificates shall be established by the Minister of Agriculture.

§ 78. Use of plant protection products

(1) Plant protection products may be used only under the conditi▯ons, for the purposes, in the manner and at

the application rate specified on the labelling, and observing the number of applications and waiting periods
before and after using the products. It is recommended that the principles of good plant protection practice and

integrated pest control be observed in the use of plant protection produ▯cts.
(2) Integrated control is the rational application of a combination of biological, biotechnological, chemical, Annex 20

cultural or plant-breeding measures whereby the use of chemical plant protection products is limited to the strict
minimum necessary to maintain the pest population at levels below those causing economically unacceptable

damage or loss.
(3) Users of plant protection products shall maintain records of the used plant protection products in field

records.
(4) Pest control from aircraft is prohibited.

(5) The requirements for the use of plant protection products sh▯all be established by the Minister of

Agriculture.
(6) (Repealed - 21.05.2008 entered into force 01.07.2008 - RT I▯ 2008, 23, 150)

(7) (Repealed - 21.05.2008 entered into force 01.07.2008 - RT I▯ 2008, 23, 150)

§ 79. Training in plant protection; plant protection certificates

(1) Distributors of plant protection products and in the cases p▯rescribed by a decision on authorisation of a
plant protection product, the persons who purchase or use the plant prote▯ction product shall undergo training in

plant protection and hold a plant protection certificate.
(2) A plant protection certificate is a document which certifies that a person may market, buy and use all

plant protection products except those classified as highly toxic.
(3) The training programmes of plant protection, the requirement▯s for obtaining plant protection certificates

and the procedure for the issuing of certificates shall be established by the Government of the Republic.

1
§ 79 . Requirements for persons using highly toxic plant protection products

(1) Data concerning a person who wishes to use highly toxic plan▯t protection products shall be entered in the

(2) The person specified in subsection (1) of this section or ▯an employee thereof may use only such highly
toxic plant protection products for the safe and proper use of which the person has adequate qualification withi▯n

the meaning of the Chemicals Act.

(3) A person using a highly toxic plant protection product shall observe the requirements provided in the
user manual of the plant protection product and ensure the safety thereof to the neighbouring populations an▯d

the environment.

(4) A person using a highly toxic plant protection product shall prepare a plan for the use of the plant
protection product compliance with which is mandatory. The plan shall be ▯prepared by taking into account the

special characteristics and temperature of the treated object and be approved by the possessor of the site bef▯ore
the use of the highly toxic plant protection product.

(5) A person using a highly toxic plant protection product shall▯ keep record of the use. For that purpose, theAnnex 20 Annex 21

Austrian Federated State of Vorarlberg, Ordinance on Plant Protection Products,
LGB1.Nr. 18/2008 (2008) Annex 21

State Government Regulation
on the Use of Plant Protection Agents
(Plant Protection Regulation)
State Law Gazette No. 18/2008 1)

On the basis of section 10 subsection 5, and section 11 subsections 6 an▯d 8 of the
Austrian Plant Protection Act, State Law Gazette No. 58/2007, the follow▯ing is enacted:

Section 1
Prohibitions

(1) It shall be prohibited
a) to disperse plant protection agents from aerial vehicles,
b) to use plant protection agents
1. in wetlands, straw meadows and rough pastures or dry grasslands as well as in

adjoining three meter wide strips of land
2. in three meter wide strips of land bordering forests or the shore edge of surface
waters,
3. in other areas, especially in residential or agricultural areas, if an impact on the
neighbor’s health, the health of other persons staying there, or on the plants or

plant products growing on adjacent properties can be expected.
(2) The use of plant protection agents showing no hazardous properties withi▯n the
meaning of section 3 subsection 1 of the Chemicals Act of 1996 shall be exempted from
the prohibition of subsection 1 letter b numbers 1 and 2.

(3) Subsection 1 shall not affect other provisions on the impermissibility of the use of
plant protection agents.

1)The purpose of this Regulation is to implement Directive 2005/36/EC.Annex 21 Annex 21
7004/9

Verordnung
der Landesregierung über das Verwenden von Pflanzenschutzmitteln
(Pflanzenschutzmittelverordnung)
LGBl.Nr. 18/2008 1)

Auf Grund der §§10 Abs.5 und11 Abs.6 und8 des Pflanzenschutzgesetzes,
LGBl.Nr. 58/2007, wird verordnet:

§ 1
Verbote

(1) Verboten ist
a) das Ausbringen von Pflanzenschutzmitteln aus Luftfahrzeugen,
b) die Verwendung von Pflanzenschutzmitteln
1. in Feuchtgebieten, Streue- und Magerwiesen oder Trok censtandorten sowie in

daran angrenzenden drei Meter breiten Geländestreifen,
2. in an Wald oder die Uferober kante von Oberflächengewässern angrenzenden
drei Meter breiten Geländestreifen,
3. in sonstigen Gebieten, insbesondere in Wohn- oder Landwirtschaftsgebieten,

wenn eine Beeinträchtigung der Gesundheit des Nachbarn, der sonstigen
sich dort aufhaltenden Personen oder der auf benachbarten Grundstück en
wachsenden Pflanzen oder Pflanzenerzeugnisse zu erwarten ist.
(2) Vom Verbot des Abs. 1 lit. b Z. 1 und 2 ausgenommen ist die Verwendung
von Pflanzenschutzmitteln, welche keine gefährlichen Eigenschaften im Sinne des

§ 3 Abs. 1 des Chemikaliengesetzes 1996 aufweisen.
(3) Abs. 1 lässt andere Vorschriften über die Unzulässkeit der Verwendung von
Pflanzenschutzmitteln unberührt.

§ 2
Bewilligungspflicht

(1)Pflanzenschutzmittel, die den Wir kstoff Streptomycin enthalten und deren
Inverkehrbringen nach dem Pflanzenschutzm ittelgesetz 1997 aufgrund von Gefahr
im Verzug zulässig ist, dürfen nur mit Bewilligung der Bezir kshauptmannschaft
verwendet werden.

1)
Diese Verordnung dient der Umsetzung der Richtlinie 2005/36/EG.

8.04.2008 1Annex 21 Annex 22

Australian Pesticides and Veterinary MedicinesAuthority (APVMA),AVPM Operating Principles
in Relation to Spray Drift Risk (15 July 2008) Annex 22

APVMA OPERATING PRINCIPLES
IN RELATION TO SPRAY DRIFT RISK

15 JULY 2008Annex 22

This work is copyright. Apart from use permitted under the Copyright Act 1968, no part may be

reproduced by any process without prior written permission from the Australian Pesticides and
Veterinary Medicines Authority (APVMA). Requests and enquiries regarding reproduction and

rights should be addressed to: APVMA Spray Drift Comments, Regulatory Strategy and
Compliance Program, PO Box 6182, Kingston ACT 2604, Australia or by emai▯l to
[email protected]

APVMA operating principles in relation to spray drift risk

First Published 15 July 2008

This document is published by the APVMA. In referencing this document, the APVMA should be

cited as both author and publisher.

For more information on the APVMA go to <http://www.apvma.gov.au> Annex 22

Important information

The Australian Pesticides and Veterinary Medicines Authority (APVMA) has prepared this
document to describe its approach to spray drift risk assessment and risk management.

This document has been published previously in four earlier draft versions (1 July 2003,
5 August 2005, 24 July 2006 and 20 February 2008) each of which was fol▯lowed by a period of

public consultation. All comments from previous submissions to the APVMA have been
considered in the preparation of this document.

This document is now in final form as an overview of APVMA spray drift risk regulation. The
methods and principles described herein will apply uniformly to both new applications and

reconsiderations.

The APVMA will continue to improve its risk assessment methods to strengthen their reliability.
The APVMA will publish minor changes on its website as they occur and will announce a
consultation period for stakeholders to comment on any major changes that may be

contemplated.Annex 22

2 APVMA r’ssponsibilii ty

relation to spray drift

The legislation under which the APVMA derives its powers (Agricultural and Veterinary
Chemicals Code Act 1994) sets out the factors that the APVMA must consider in registering an
agricultural or veterinary chemical product for use. When the APVMA considers registering an
agricultural chemical product, it must satisfy itself, according to scientific principles, that the
product can be used to achieve its intended purpose and at the same time not be likely to harm
human health, the environment or Australia’s international trade. To achieve this end, the
APVMA determines instructions for use and limitations on use for each product and places them
on the product’s label. User compliance with these instructions and limitations falls under the
enforcement powers of the states and territories.

Ideally, a product would only be applied to the intended target. However, the APVMA
recognises that measurable off-target spray drift can occur at times even when the product is
applied with care. The APVMA therefore has an obligation to consider the potentially harmful
consequences of that associated spray drift and determine whether it would be likely to harm
human health, the environment or unduly prejudice Australia’s international trade.

cause harm, the APVMA cannot allow that product to be used unless a way can be fou▯nd toly to
prevent that harm from occurring.

2 APVMA operating principles in relation to spray drift risk Annex 22

6 Genera ap l plicatio cnoncerns

6.1 Groun adpplication

In relation to spray drift risk, ground application has some distinct advantages such as being able
to keep spray release height low, operating at slower speeds that do not▯ shatter droplets and
being able to use wind-shielding hoods or shrouds around nozzles in some circumstances.

However, ground applications, both broadacre and orchard, can also result in unacceptable
amounts of spray drift in some circumstances. For example, the slower speed of ground
machines (compared to aerial application) can lead to spraying through changing wind
conditions and to all night spraying during surface temperature inversion conditions that can
result in significant spray drift. The temptation to increase machine ground speed to finish the
job more quickly can also lead to greater bouncing of the spray boom over rough ground that
also increases spray drift.

Orchard applications with radial airblast machines can cause significant spray drift when the
machine is not properly set up to avoid driving spray above tree tops or when outer nozzles are
not shut down on row turns or outside rows. Modern tower and tunnel airb▯last machine designs
perform better but are not yet the most common types in use.

6.2 Aera iaplplication

Aerial application has great advantages in speed of coverage, in being able to access crops when
fields are too wet for ground machines and in avoiding soil compaction and crop damage from
ground machinery. However, aircraft have some inherent properties that can add to spray drift
risk. One of the most significant is that aircraft need to release spray droplets high enough for
safe operation, and higher release heights add to spray drift risk. Moreover, the high speed air
moving past aircraft-mounted nozzles can shatter droplets delivered by the nozzles into smaller
droplets that are more drift prone. Wake disturbances to the air from large and necessarily fast
moving aircraft also contribute to spray drift by lofting droplets highe▯r.

Some of these inherent features of aircraft can be compensated for by proper set up of accessory
equipment such as ensuring that a nozzle design is chosen that will deliver a ▯coarse enough spray
to compensate for droplet shatter. Booms can also be positioned optimally and shortened in
relation to wingspan to avoid much of the droplet lofting effect from wingtip vortices. However,
the higher release height remains a disadvantage in comparison to ground application that has
not been overcome.

APVMA operating principles in relation to sp9ay drift riskAnnex 22

8 Operational risk factors and

mitigation measures that the

APVMA considers

As stated earlier, the APVMA must link its consideration of chemical risk to the need to protect
human health, the environment and Australia’s international trade. The specific issues discussed

in the following paragraphs should be viewed from that perspective.

Many factors affect how much off-target spray drift might occur. Among them are droplet size,
weather conditions, the type of equipment and methods used, local landforms where the
application is made and the expertise of the applicator. In reducing risk, the APVMA uses a
range of integrated strategies to mitigate the potentially harmful effects of spray drift and at
times may need to impose restrictions or qualifications on one or more of the risk factors.
Normally the APVMA would prefer to rely on industry best practices and the c▯ompetence of
applicators whenever it can be satisfied that such would be adequate.

Some examples of how instructions relating to these factors are incorporated into label
statements are presented at the end of this document in Section 10. More information on these
risk factors can be found in a publication sponsored by the Primary Industries Standing
Committee and titled, Spray Drift Management—Principles, Strategies and Supporting
Information, published by CSIRO Publishing, 2002, ISBN 0 643 06835 X. (This book is also
available for download from the internet at <http://www.publish.csiro.au/pid/3452.htm>)

8.1 Factors affecting spray drift that are not related to
the specific chemical

Droplet size

Spray droplet size (which is directly proportional to droplet mass) is the most important single
factor in spray drift risk. Smaller, lower mass droplets have greater potential for drifting off
target. In most circumstances, the APVMA imposes a limitation on the range of droplet sizes that
can be used for applications. An acceptable droplet size range is influenced by the need for
adequate coverage to achieve efficacy of the chemical product. As long as risk standards are not
exceeded, the APVMA balances the need for efficacy with the need to limit spray drift. For dust

formulations, the dust particle size is fixed during manufacture, and except where information
shows dust particles are further fragmented by handling, the APVMA uses the nominal particle
size range (backed by measurement data) in assessing risk.

18 APVMA operating principles in relation to spray drift risk Annex 22

Medium and Course ranges for the bulk of the downwind distance only dropping to the vicinity

of the Medium profiles beyond 600 metres.

A droplet size range can be set by using specific types of nozzles, nozzle angles, rotary atomizer

speeds and system pressures. In the case of aerial application, high airspeeds can cause excessive
fragmentation of droplets delivered by the nozzle system when the droplets are impacted by fast
moving air flowing relative to the wing boom. Aerial operators must choose a nozzle that will

provide a sufficiently coarse droplet spectrum to partially compensate for droplet shatter. With
the highest speed aircraft, that can be difficult and the number of suitable nozzles is limited. The
aerial agriculture industry in Australia with chemical company support has sponsored wind

tunnel tests to determine which nozzles can be relied upon for situations requiring the ASAE
Coarse spray category (see below) such as is required for all 2,4-D products.

Many industry organisations support the use of the droplet size standard, ASAE S572, adopted
by the American Society of Agricultural Engineers. This standard defines a set of droplet spectra
that can be used to describe the output of specific nozzle types under defined conditions.

Manufacturers categorise most commonly available nozzles in terms of this standard. The
APVMA has adopted ASAE S572 as a uniform way of describing droplet spectra on its labels
for both aerial and ground application. (See Section 8.3 for discussion▯ of the new ISO droplet

spectrum standard currently under development.)

When specifying a droplet size range on a product label, the APVMA prescribes a particular

droplet size classification as defined in the ASAE standard. That prescribed size classification
along with the needed application rate then specifies the nozzle options▯ that can be selected by
the user.

It is important to emphasise that a chemical user must not rely on tank mix products advertised
as ‘drift retardants’ to achieve the correct droplet spectrum. The APVMA has no consistent data
supporting the efficacy of these products. For the present, chemical users should always rely on

proper nozzle choice and system pressures to achieve optimal droplet size rather than using
unproven tank-mix additives.

Although correct nozzle choice is always critical, there is a different kind of tank-mix strategy
that does have merit and can further improve the benefits of correct nozzle choice. It is the use of
non-volatile tank-mix additives that have the effect of reducing drift deposits from fine droplets

at the greater downwind distances by imposing a minimum mass limit on each evaporating
droplet. This strategy is discussed in greater detail in the next section under ‘Humidity and
temperature’.

Droplet size classification categories for nozzles in manufacturers’ catalogues are largely based
on tests done with water. The APVMA recognises that product formulations and final tank mix

ratios can have a significant influence on the droplet spectra actually ▯delivered by nozzles. By
specifying a standard droplet size classification on labels, the APVMA provides a standard that
must be met, and chemical users will need to use the best available information in meeting that

standard. At the present time, that would be catalogue specifications in most cases. In the future,
further work by scientific testing laboratories and wind tunnel facilities will provide updated and

20 APVMA operating principles in relation to spray drift riskAnnex 22

reliable information for product formulations and tank mixes relative to nozzle choice. As new

information becomes widely available, chemical users can more accurately achieve the label
standard. In the meantime, choosing appropriate nozzles based on current best information will
be a great improvement on choices often made in the past.

Weather conditions

Wind speed and direction

Weather conditions are critical factors influencing spray drift risk. Wind speed and wind
direction must be taken into account. In an important sense, wind direction is the most critical
factor of all because spray droplets move only downwind. As was pointed out in Figure 2, the
droplet size range is the single most important factor affecting spray drift in the downwind

direction, but wind speed is perhaps the second most important factor that must be considered.

The APVMA may require that the label provide advisory information or mandatory limitations
in relation to wind direction and speed. For example, the label may specify a maximum and
minimum wind speed during spray operations and may state where the wind speed must be
measured as, for example, outside an orchard at a specified distance upwind from the trees (or if

not possible, 2 metres above the tree tops). Wind direction will always be taken into account in
the description of any mandatory no-spray zone or declared spray drift r▯isk area (see Section 8.2
for more detail). Both restricted areas will only exist in the downwind direction from the

application site at the time of application.

The APVMA does not specifically require use of an anemometer to make accurate wind speed

measurements. However, state and territory laws and the courts require a demonstration of duty
of care so that an applicator should be capable of proving, if necessary in court, that a reliable
method was used to measure wind speed and direction on site at the time of application. When

other factors are favourable, applications can be made safely at wind speeds of between 3 and
20 km/hr, but in higher risk situations, the maximum speed allowable may be reduced. In
assessing risk, the APVMA first uses 20 km/hr as the wind speed in modelling and then assesses

at reduced wind speeds if the higher figure points to unacceptable risk.

A minimum speed of 3 km/hr is required because times of no wind (essentially below 3 km/hr)

often precede or accompany periods of highly stable air and surface temperature inversion
conditions both of which can greatly increase spray drift risk. Moreover, when wind resumes
after periods of calm, its direction is not predictable. Spraying only when there is at least some

wind ensures that wind direction is known (so that drift onto sensitive areas can be avoided) and
greatly reduces the likelihood of surface temperature inversions forming during or shortly after
application.

When the APVMA sets a declared spray drift risk area or a mandatory no-spray zone on a label
(see Section 8.2), it will specify three wind speed ranges for aerial applications, usually 3–8,
9–14 and 15–20 km/hr. Each wind speed range will be associated with either a mandatory no-

spray zone or a declared spray drift risk area specifically calculated for that wind speed and the

APVMA operating principles in relation to spray drift ris21 Annex 22

appropriate risk conditions for that product. Providing three wind speed options will allow

chemical users greater flexibility in matching label requirements to actual wind conditions at the
time of application. The distances associated with each wind speed will also give chemical users
a better appreciation of how to manage risk.

At this time, the APVMA cannot model different wind speeds for ground applications ▯because
validated and flexible modelling programs for ground applications have not yet been developed.

Since ground application no-spray zones and risk areas are substantially smaller than those for
aerial application, the differences obtained for different wind speeds would be less significant.
The APVMA expects to have access to modelling capability for ground applications in the future

(see Section 8.3). When such modelling is available, the APVMA can introduce this option for
ground applications in situations where it is needed.

Humidity and temperature

For water based tank mixes, humidity and temperature affect droplet evaporation rates and can

make a surprisingly large difference in drift deposits at longer downwind distances due to
shrinkage in droplet size (and therefore mass). Spray operations cannot be suspended during
summer months when temperatures are high and humidity is low, and one way of compensating

is to increase both the droplet size spectrum (so that larger droplets on average leave the nozzle)
and the carrier water volume applied per hectare to provide adequate droplet numbers for
coverage. In cases where the APVMA specifies a minimum carrier volume on the label, it is

expressly stated as a ‘minimum’ volume to allow the user to increase the volume if desired.

Increasing the carrier water volume is sometimes not practicable, particularly for aerial

operators. A different management approach is to make the spray droplets less vulnerable to the
effects of evaporation. A simple method is to add dispersible non-volatile material to the tank
mix. The added non-volatile material in each droplet imposes a minimum mass value on the

droplet, and as the droplet shrinks due to evaporation, acts as a humectant (depending on the
properties of the added material) further slowing evaporation. The added material might be a
non-volatile crop oil adjuvant, ammonium sulphate, urea, molasses or other substances that have

been found to be safe to apply and compatible with the particular tank mix and application
equipment.

Figure 3 illustrates how significant a difference can be achieved using ▯this approach [modelled
with AgDRIFT version 2.0.07, Tier III Aerial (Agricultural)].

22 APVMA operating principles in relation to spray drift riskAnnex 22

Figure 3 Effect of adding non-volatile material to the tank mix

Effect of Non-Volatile Additives

2.0%

No Additive
1.8% 2 kg/ha Added
4 kg/ha Added
1.6%
No Evaporation
1.4%

1.2%

1.0%

0.8%

0.6%
Percentage of Field Rate
0.4%

0.2%

0.0%
0 200 400 600 800 1000 1200

Metres Downwind

In the graph above, the deposit profiles are modelled for an aerial application all using a Medium droplet spectrum and a wind
speed of 20 km/hr. Ambient conditions were set at 30º Centigrade and 50% relative humidity for the three upper curves. The top
red curve is the profile where only the product formulation and carrier water are in the tank. The pink curve is a case where an
additional 2 kg/ha of non-volatile material has been added to the tank mix, and the green curve is where an extra 4 kg/ha has been
added. The lowest curve (blue) is an example where evaporation has been suppressed by setting the model conditions to 1º C and
99% relative humidity. (Note that the curve for ‘no additive’ does not look the same as the comparable curve in Figure 1 because
the scale is different, a different aircraft was used and different model input parameters were used.)

In Figure 3, comparison of the blue curve (negligible evaporation) and the red curve (significant
evaporation), both with no added non-volatile material, shows how significant the effect of

evaporation on the drift profile can be. In this example, adding 2 or 4 kg/ha of non-volatile
material to the tank mix has a surprisingly large beneficial effect in reducing off-target drift

deposits. The effect does not become important until the deposits have dropped below about 1%
of the field rate, but the differences are very significant at greater downwind ranges for
chemicals that have a very sensitive impact threshold such as 2,4-D or typical trade risk

scenarios. For example in Figure 3, if the acceptable deposition threshold was 0.2% of field rate,
the unaltered tank mix would fail by a large margin even at 1200 metres downwind and the

unacceptable risk distances for the 2 and 4 kg/ha additions would extend to 830 and 602 metres
respectively, a substantially lesser distance.

The APVMA will assist registrants and the application industry in implementing this approach
through permits, where necessary, when scientific data or acceptable argument has been

provided to show that a proposed non-volatile tank supplement meets all safety and
efficacy criteria.

APVMA operating principles in relation to spray drift23isk Annex 22

Surface temperature inversion conditions

The potential for or presence of a surface temperature inversion condition is a very important

factor in spray drift risk management. The ability to recognise a surface inversion condition or
the atmospheric conditions likely to lead to one requires training beyond what can be included in
label instructions.

Pilots are well trained in weather related issues and an aircraft’s speed of coverage can be a great
advantage in fitting applications between adverse weather conditions such as surface inversions.

The slower rate of coverage of ground application makes it important that ground applicators
should also be well-trained in recognising weather conditions signalling an impending surface
inversion. Where the properties of the product and use situation present▯ an exceptional risk from

surface inversion conditions, the APVMA may find it necessary to invoke a Restricted Chemical
Product status for the product to limit chemical access to those who are properly trained.

Height of spray release

Spray release height is another of the major factors affecting spray drift risk: the higher the

release height, the greater the potential for off-target drift. In practice, release height is usually
controlled within relatively narrow limits (see below). Because the release height will be
accounted for in APVMA risk assessments and because operators have little motivation to depart
from good practice norms, the APVMA will not specify release heights on labels in most cases.

In unusual cases where it might be desirable to limit release heights on labels, the APVMA will
be able to consult with its Application Technical Reference Group which ▯includes people with
expertise in application technology from both industry and academia.

Aerial applicators in broadacre situations seek a compromise between optimal spray placement
and safety and generally maintain a release height of approximately 3 metres. In its risk

assessments using computer modelling, the APVMA uses an aerial release height of 3 metres as
a standard.

Aerial applications to forests have different requirements due to the fact that tree tops are uneven
and forests are often located in hilly areas. For pilot safety, a release height of 15 metres above
the general forest canopy is typical, and the APVMA uses this value in its risk asses▯sments. In

relation to risk, the higher release height in forestry applications is largely compensated for by
the efficient droplet trapping properties of forest canopies. Localised turbulence eddies caused by
wind interacting with uneven tree tops help move droplets down into the canopy volume more

quickly for capture.

Exceptional aerial application situations and methods such as those relating to plague locust

control authorities and regional mosquito control programs will be assessed on their own merits
and appropriate instructions placed on labels when needed. Representatives from the authority in

24 APVMA operating principles in relation to spray drift riskAnnex 22

question and the APVMA Application Technical Reference Group may be consulted in such
circumstances.

Applicators using ground boom equipment are constrained in most cases by nozzle design and
placement that fix release height to a narrow range in order to achieve uniform spray deposition.
The most common release height is 50 cm for 110º nozzles with 50 cm spacing on the boom.

Different boom heights apply to setups with different nozzle spray angles (such as 80º) and
different nozzle spacing. The release height is not always set from ground level (as for bare
ground applications) but often from the general surface of a maturing crop canopy or over high

weed infestations. In addition, rough ground and higher machine ground speeds can cause boom
bounce that disturbs a uniform release height.

The overseas data sets that the APVMA uses for ground application assessment used typical
application heights for the various studies undertaken. In using these data sets, the APVMA
applies a conservative safety factor by using the 90 percentile of the data.

Release height is not easily related to orchard applications because spraying usually takes place
under the trees and is directed sideways and upward into the tree canopy rather than being

applied from above the canopy. Radial airblast machines that are improperly set up and that
drive droplets above the tree canopy or do not turn off outside nozzles at turns or outer rows
present a significant added risk. For orchard ground applications, the APVMA may impose

limitations on how airblast and other spray applications are done.

With vineyards, the spray needs to be directed sideways into the vines or with tunnel-type

equipment, sideways and down into the vines. The key feature for applications ▯in orchards and
vineyards is that spray must be directed into the foliage and not above it or below it (i.e. to the
trunk area) where there is no foliage to intercept the spray.

Time of application

The time of day of application is important only in the way it relates to atmospheric conditions.
Evening hours are frequently associated with stable air conditions. Nigh▯t-time hours are often

associated with surface temperature inversion conditions. Both are conditions of high spray drift
risk. In particular, spray operations should not be conducted during inv▯ersion conditions. The
APVMA encourages better training for all applicators to recognise and avoid spraying in these

conditions and may at times require such training (see Section 8.2).

In rare circumstances, the APVMA may also find it necessary to limit application of a product to

a particular period of the year in order to control spray drift risk. This type of restriction is
sometimes needed because of a crop’s stage of development or to constrain the risk period to a
defined calendar interval so that an industry under risk can limit the time during which

commodities must be monitored for that chemical. The current calendar restrictions on
endosulfan applications to cotton are an example of such a limitation.

APVMA operating principles in relation to spray drift risk 25 Annex 23

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Droplet Spectra,ANSI/ASAE S572.1 (Mar. 2009) Annex 23

ASAES-572SprayTipClassificationbyDropletSize

Developed by the Pest Control and Fertilizer Application Committee; approved by the Power and Machinery
Division Standards Committee; adopted by ASAE PM41.

This standard defines droplet spectrum categories for the classification of spray tips, relative to specified

reference fan tips discharging spray into static air or so that no stream of air enhances atomization.
The purpose of classification is to provide the tip user with droplet size information, primarily to
indicate off-site spray drift potential, and secondarily, for application efficiency.

This standard defines a means for relative tip comparisons only based on droplet size. Other spray drift and
application efficiency factors, such as droplet discharge trajectory, height and velocity, air bubble inclusion,

droplet evaporation and impaction on target are examples of factors not addressed by the current standard.

Classification categories, symbols and corresponding color codes are as follows:

Classification
Category Symbol Color Code ApproximateVMD

Very Fine . . . . . . . . . . . . . . VF Red <100

Fine . . . . . . . . . . . . . . . . . . . F Orange 100-175
Medium . . . . . . . . . . . . . . . . M Yellow 175-250
Coarse . . . . . . . . . . . . . . . . C Blue 250-375

Very Coarse . . . . . . . . . . . . VC Green 375-450
Extremely Coarse . . . . . . . XC White >450

Degree of Droplet Size Relative Size
Atomization (Microns) Relative Size Related to
Common Objects Droplet sizes are usually expressed in
microns (micrometers). One micron equals

Fog Up to 20 Point of Needle one thousandth of a millimeter. Other than
(25 Microns) the effects of the specific material being

sprayed, the four major factors effecting
Fine Mist 20-100 Human Hair droplet size are: tip style, capacity, spraying
(100 Microns)
pressure and spray pattern type. Lower

spraying pressures provide larger droplet
Fine Drizzle 100-250 Sewing Thread sizes, while higher spraying pressures yield
(150 Microns)
smaller droplet sizes.The smallest droplet
sizes are achieved by air atomizing tips.
Light Rain 250-1000 Staple
(420 Microns) Generally speaking, the largest spray
droplets are produced by wide-angle, flat

hydraulic spray tips. In the hydraulic spray tip
Thunderstorm 1000-4000 #2 Pencil Lead series, the smallest droplet sizes are
Rain (2000 Microns)
produced by hollow-cone spray tips.

64Annex 23

Pressure Conversions
Color Code Classifications Thresholds
Dv0.1 Dv0.5 Dv0.9

VF Very Fine 41.5 99.9 170.8 1 Bar. . . . . . 15 psi 6 Bar . . . . . . 87 psi

F Fine 65.7 163.6 350.1 1.5 Bar . . . . 22 psi 7 Bar . . . . . . 102 psi

M Medium 88 249.4 495.2 2 Bar. . . . . . 29 psi 8 Bar . . . . . . 116 psi

C Coarse 95.6 365.1 683.5 2.76 Bar . . . 40 psi 10 Bar . . . . . 145 psi

VC Very Coarse 109.2 408.3 842.6 3 Bar. . . . . . 44 psi 11 Bar . . . . . 160 psi

XC Extremely Coarse >109.2 >408.3 >842.6 3.5 Bar . . . . 51 psi 12 Bar . . . . . 174 psi
4 Bar. . . . . . 58 psi 20 Bar . . . . . 290 psi

4.5 Bar . . . . 65 psi 30 Bar . . . . . 435 psi
Droplet size classification are based on BCPC specification and in accordance
with ASAE S-572 as of 5/01. Classifications are subject to change. Measures5 Bar. . . . . . 73 psi
made by MALVERN particle sizer 2600 and Oxford Visizer.

ULD 120° - Ultra Lo-Drift - Dual Air Eduction

15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI 80 PSI 90 PSI 100 PSI115 PSI
ULD120-015 C VC C C C M M M M F F

ULD120-02 CVC C C C M M M M F
ULD120-025 CVC C C C M M M M M
ULD120-03 CVC C C C M M M M
ULD120-04 CVC C C C M M M M
ULD120-05 XC XC C VC C C C M M
ULD120-06 XC XC XC CCVC C C C M

ULD120-08 XC XC XC CCVC C C C M

AVI 110° - Air-Inducing Venturi Flat Fan CeramicTip

30 PSI 40 PSI 50 PSI 60 PSI 70 PSI 80 PSI 90 PSI 100 PSI
AVI-11001 CVC C C C
AVI-110015 VC VC VC VC VC VC C C

AVI-11002 VC VC VC VC VC VC VC C
AVI-110025 XC VC VC VC VC VC VC VC
AVI-11003 XC XC XC VC VC VC VC VC
AVI-11004 XC XC XC VC VC VC VC VC
AVI-11005 XC XC XC XC VC VC VC VC
AVI-11006 XC XC XC XC VC VC VC VC

AVI-11008 XC XC XC XC XC XC XC XC
AVI-11010 XC XC XC XC XC XC XC XC

LD 80° - Lo-Drift Flat FanTip LD 110° - Lo-Drift Flat FanTip

15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI 15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI
LD015F80 C C M M M M M LD015F110 M M M M M M F
LD02F80 C C C M M M M LD02F110 C C M M M M M
LD03F80 C C C C M M M LD025F110 C C M M M M M
LD04F80 C C C C M M M LD03F110 C C C M M M M
LD05F80 C VC C C C M M LD04F110 C C C M M M M
LD06F80 VC VC VC C C C C
LD05F110 C VC C C C M M
LD08F80 XC VC VC VC C C C LD06F110 C VC C C C C C
LD08F110 C VC C C C C

65 Annex 23

ASAES-572Chart

Continued

ADI 110° - Anti-Drift Flat Fan CeramicTip

30 PSI 40 PSI 50 PSI 60 PSI 70 PSI
ADI-11001 M M F F F
ADI-110015 M M M M M
ADI-11002 M M M M M

ADI-11003 C M M M M
ADI-11004 VC C C C M

VP 80° - Variable Pressure Range Flat FanTip VP 110° - Variable Pressure Range Flat FanTip

15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI 15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI
VP80-015 M M F F F F F VP110-015 M F F F F F F
VP80-02 M M F F F F F VP110-02 M M F F F F F
VP110-025
VP80-03 M M M F F F F M M F F F F F
VP80-04 C M M M M F F VP110-03 M M M F F F F
VP80-05 C C M M M M F VP110-04 C M M M M F F
VP80-06 C C C C M M M VP110-05 C C M M M M F
VP110-06
C C C M M M M
VP110-08 VC C C M M M M
VP110-10 VC C C M M M M
VP110-15 VC VC VC C C M M

AXI 110° - Wide Pressure Range Flat Fan Ceramic
AXI 80° - Wide Pressure Range Flat Fan Ceramic

20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI
AXI-80015 F F F F F VF AXI-110015 F F F F F VF
AXI-8002
M F F F F F AXI-11002 F F F F F F
AXI-8003 M M M F F F AXI-11003 M M M F F F
AXI-8004 M M M M M F AXI-11004 M M M M F F
AXI-8005 M M M M M M AXI-11005 M M M M M M
AXI-8006 AXI-11006
M M M M M M M M M M M M

TR 80° -Total Range - Stainless Steel Insert TR 110° -Total Range - Stainless Steel Insert

15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI 15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI 70 PSI

TR80-01 M F F VF VF VF VF TR110-01 F F F VF VF VF VF
TR80-015 M F F F FF V VF TR110-015 M F F F F F VF
TR80-02 M M F F F F VF TR110-02 M M F F F F F
TR110-03
TR80-03 C M M F F F F M M M F F F F
TR80-04 C C M M M F F TR110-04 C M M F F F F
TR80-05 C C C M M M F TR110-05 C C M F F F F
TR80-06 C C C M M M M TR110-06 C C C M M M F
TR110-08 C C C M M M M
TR80-08 C VC C C C M M
TR80-10 VC VC VC C C C M TR110-10 VC VC C M M M M
TR80-15 XC VC VC C C C C TR110-15 VC VC VC C C M M

FanTip 80° - Standard Flat Fan SprayTip FanTip 110° - Standard Flat Fan SprayTip

30 PSI 40 PSI 50 PSI 60 PSI 30 PSI 40 PSI 50 PSI 60 PSI
30-02F110YE
30-0067F80 VF VF VF VF F F F F
30-01F80OR F F F F 30-03F110UB M F F F
30-015F80RG M F F F 30-04F110RE M M M F
30-02F80YE M F F F 30-05F110LB M M M M
30-06F110GY
30-03F80UB C M M F M M M M
30-04F80RE C M M M 30-08F110WH C C C C
30-05F80LB C M M M 30-10F110CB C C C C
30-06F80GY C C M M 30-15F110LG C C C C

30-08F80WH C C C C
30-10F80CB C VC C C
30-15F80LG VC VC C C
30-20F80BL VC VC VC VC

66Annex 23

DT - DeflecTip Wide-Angle Flat FloodTip OCI 80° - Ceramic Off-Center

30 PSI 40 PSI 50 PSI 60 PSI
10 PSI 15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI
30DT0.5 C M M F F F F OCI-8002 M M M F
30DT0.75 C C M M F F F OCI-8003 M M M M
30DT1.0 C C M M M M F OCI-8004 M M M M

30DT1.5 C M M M M M M
30DT2.0 C C C M M M M
30DT2.5 C C C M M M M
30DT3.0 C C C M M M M

30DT4.0 C C C M M M M
30DT5.0 C C C C M M M E - Even Flat Fan
30DT7.5 C C C C C C C
30 PSI 40 PSI 50 PSI 60 PSI
30DT10 C VC C C C
30DT15 XC VC VC VC C C C 30-01E80OR F F F F
30DT20 XC XC 30-015E80RG M F F F
VC VC VC C C 30-02E80YE M M M F
30-03E80UB C M M M

30-04E80RE C C M M
30-05E80LB C C C C
30-06E80GY C C C C
30-08E80WH C VC C C
DTC - Cam Couple DeflecTip Wide-Angle Flat FloodTip

10 PSI 15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI
30DT10C C VC C C C

30DT15C XC VC VC VC C C C
30DT20C XC XC VC VC C C C
30DT30C XC XC XC VC VC VC C
30DT40C XC XC XC XC VC VC VC

30DT50C XC XC XC XC XC XC VC
30DT60C XC XC XC XC XC XC XC
30DT80C XC XC XC XC XC XC XC
30DT100C XC XC XC XC XC XC XC

30DT120C XC XC XC XC XC XC XC
30DT150C XC XC XC XC XC XC XC
30DT180C XC XC XC XC XC XC XC

APM - Wide-Angle Flat FloodTip

10 PSI 15 PSI 20 PSI 30 PSI 40 PSI 50 PSI 60 PSI
APM-Yellow M M M M M M M
APM-Orange
M M M M M M M
APM-Red C C C M M M M
APM-Green C C C M M M M
APM-Blue C C C C M M M
APM-Gray
C VC C C C C C
APM-Black C VC C C C C

AVI-OC 80° - Air-Inducing Venturi Ceramic Off-Center

40 PSI 50 PSI 60 PSI 70 PSI 80 PSI 90 PSI 100 PSI

AVI-OC-8002 XC VC VC VC VC VC VC
AVI-OC-80025XC XC VC VC VC VC VC
AVI-OC-8003 XC XC XC VC VC VC VC
AVI-OC-8004 XC XC XC XC VC VC VC

%▯▯▯▯K▯ ▯▯@0AA▯%55 ▯4<B4@

30 PSI 40 PSI 50 PSI 60 PSI
28OC2 M M M F
28OC3 M M M F

28OC4 C M M M
28OC6 C C M M
28OC8 C C C M
28OC12 C C C C

28OC16 C VC C C

67 Annex 23

ASAES-572Chart

Continued

TVI 80° - Hollow Cone

70 PSI 150 PSI 200 PSI
TVI-80015 XC C C
TVI-8002 XC XC C
TVI-80025 XC XC C

HCX 80° - Hollow Cone

40 PSI 50 PSI 60 PSI 70 PSI 80 PSI 90 PSI 100 PSI125 PSI150 PSI
30HCX2 VF VF VF VF VF VF VF VF VF

30HCX3 VF VF VF VF VF VF VF VF VF
30HCX4 F F VF VF VF VF VF VF VF
30HCX6 F F VF VF VF VF VF VF VF
30HCX8 F F F VF VF VF VF VF VF

30HCX9 F F F F FFVVVV
30HCX10 F F F F F FFVVV
30HCX12 F F F F F F FF VV
30HCX18 F F F F F F F FF V

HCA / ATR 80° - Hollow Cone

40 PSI 50 PSI 60 PSI 70 PSI 80 PSI 90 PSI 100 PSI 125 PSI 150 PSI 350 PSI
ATR-White
VF VF VF VF VF VF VF VF VF VF
HCA-01 VF VF VF VF VF VF VF VF VF VF
ATR-Lilac VF VF VF VF VF VF VF VF VF VF
HCA-015 VF VF VF VF VF VF VF VF VF VF
ATR-Brown VF VF VF VF VF VF VF VF VF VF

HCA-02 F F VF VF VF VF VF VF VF VF
ATR-Yellow F F VF VF VF VF VF VF VF VF
HCA-025 F F F VF VF VF VF VF VF VF
ATR-Orange F F FFFFVVVVVV

HCA-03 F F F FFFFVVVVV
ATR-Red F F F F F FFVVVV
HCA-045 M F F F F F FFVVV
ATR-Green M M F F F F F FF VV

ATR-Blue M M M M F F F F F F

DC-CR Disc/Core

40 PSI 50 PSI 60 PSI 70 PSI 80 PSI 90 PSI 100 PSI125 PSI150 PSI
30-DC-01/30-CR-23 F F VF VF VF VF VF VF VF

30-DC-015/30-CR-23 F F VF VF VF VF VF VF VF
30-DC-02/30-CR-23 F F F VF VF VF VF VF VF
30-DC-03/30-CR-23 F F FFFFVVVVV
30-DC-04/30-CR-23 F F F F F FFVVV

30-DC-05/30-CR-23 F F F F F F FF VV
30-DC-06/30-CR-23 M F F F F F F FF V
30-DC-01/30-CR-25 F F F VF VF VF VF VF VF
30-DC-1.5/30-CR-25 F F FFFFVVVVV

30-DC-02/30-CR-25 F F FFFFVVVVV
30-DC-03/30-CR-25 F F F F FFVVVV
30-DC-04/30-CR-25 M F F F F FFVVV
30-DC-05/30-CR-25 M M M F F FFF VV
30-DC-06/30-CR-25
M M M M M M F F F
30-DC-07/30-CR-25 M M M M M M M F F
30-DC-08/30-CR-25 C C C C M M M M M
30-DC-10/30-CR-25 C C C C C M M M M
30-DC-01/30-CR-45 F F F VF VF VF VF VF VF

30-DC-1.5/30-CR-45 M F F F VF VF VF VF VF
30-DC-02/30-CR-45 M M F F F VF VF VF VF
30-DC-03/30-CR-45 M M M F F F VF VF VF
30-DC-04/30-CR-45 M M M M F F F VF VF

30-DC-05/30-CR-45 M M M M M F F FF V
30-DC-06/30-CR-45 C M M M M M M F F
30-DC-07/30-CR-45 C C M M M M M M F
30-DC-08/30-CR-45 C C C M M M M M M

68Annex 23 Annex 24

French Republic, Rural and Maritime Fishery Code,Art. L253-1(V) (2010) Annex 24

Detail of a code article http://www.legifrance.gouv.fr/affichCodeArticle.do;jsessionid=

Rural and marine fisheries code

▯ Legislative part

▯ Book II: Food, veterinary public health and protection of plant life

▯ Title V: The protection of plant life
▯ Chapter III: Marketing of plant health products

▯ Section 1: General provisions.

Article L253-3

Modified by LAW n° 2010-788 of July 12, 2010 - art. 102
Modified by LAW n° 2010-788 of July 12, 2010 - art. 103

Modified by LAW n° 2010-788 of July 12, 2010 - art. 95

In the interest of public health or the environment, the administrative authority may take any

particular measure of prohibition, restriction or prescription concerning the placement on the
market, delivery, use and holding of the products mentioned in article L. 253-1, after notice by
the national agency responsible for health, food safety, the environment and labor, and
assessment of the socioeconomic and environmental effects of such a measure, except when the
measure is taken in application of a decision of the European Union. In particular, it can prohibit

or restrict the use of these products in particular zones frequented by the general public or groups
of vulnerable people, notably in park s, public gardens, sports grounds, school grounds and
playgrounds, as well as in proximity to public health institutions.

Aerial distribution of the products mentioned in article L. 253-1 is forbidden, except under
conditions strictly defined by the administrative authority for a limited duration when a danger
threatening plants, animals or public health cannot be controlled by any other means or if this
type of spreading present s manifest advantages for h ealth and the environment in relation to a
terrestrial application, in conformity with national provisions established following the opinion

of the consultative committee for the protection of plant life, and following information from the
competent departmental commission in matters of environment, health and technological risks.

Citation:

Rural code - art. L253-1 (V)

Cited by:
Rural and marine fisheries code - art. R253-1 (V)Annex 24 Annex 24

Détail d'un article de code !!▯▯▯$$$▯▯▯"#▯▯▯'▯
!▯ ▯▯▯▯

Code rural et de la pêche maritime

Partie législative
Livre II : Alimentation, santé publique vétérinaire et protecti▯ n des végétaux

Titre V : La protection des végétaux
Chapitre III : Mise sur le marché des produits phytosanitaires

Section 1 : Dispositions générales.

Article L253-3
Modifié par LOI n° 2010-788 du 12 juillet 2010 - art. 102
Modifié par LOI n° 2010-788 du 12 juillet 2010 - art. 103
Modifié par LOI n° 2010-788 du 12 juillet 2010 - art. 95

Dans l'intérêt de la santé publique ou de l'environnement, l'autorité administrative peut prendre toute mesure
d'interdiction, de restriction ou de prescription particulière concer▯ ant la mise sur le marché, la délivrance,

l'utilisation et la détention des produits mentionnés à l'article L. 253-1, après avis de l'Agence nationale chargée
de la sécurité sanitaire de l'alimentation, de l'environnement et du travail, et évaluation des effets socio-
économiques et environnementaux d'une telle mesure, sauf lorsque celle-ci est prise en app ▯ lication d'une décision
de l'Union européenne. En particulier, elle peut interdire ou encadrer l'utilisation de ces produits dans des▯ zones
particulières fréquentées par le grand public ou des groupes de personnes vulnérables, notamment les parcs, les

jardins publics, les terrains de sport, les enceintes scolaires et les terrains de jeux, ainsi qu'à proximité
d'infrastructures de santé publique.

L'épandage aérien des produits mentionnés à l'article L. 253-1 ▯ est interdit, sauf dans des conditions strictement
définies par l'autorité administrative pour une durée limitée lorsqu'un danger menaçant les végét▯ aux, les animaux
ou la santé publique ne peut être maîtrisé par d'autres moyens ou si ce type d'épandage présente des avantages

manifestes pour la santé et l'environnement par rapport à une application terrestre, conformément aux
dispositions nationales fixées après avis du comité consultatif de la protection des végétaux, et aprè ▯ s information
de la commission départementale compétente en matière d'environnement, de risques sanitaires et
technologiques.

Cite:

Code rural - art. L253-1 (V)

Cité par:
Code rural et de la pêche maritime - art. R253-1 (V)

1 of 1 12/27/10 12:37 PMAnnex 24 Annex 25

Government of Saskatchewan, Ministry ofAgriculture, 2010 Guide to Crop Protection (2010) Annex 25

2010 GUIDE TO
weeds,plantdiseases,insects

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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯ )URPOHIW&OHDYHUVVHWHGOLQJ6FOHURWLQLDWERGLHVVFOHURWLDIRWUPLQJLQVLGHFDQRODWVWHPV$SKLGVRQ¿HOGSHDSWRGV Annex 25

Protecting Your Eyes, Face and Lungs

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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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Avoiding Spray Drift ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Annex 25 Annex 26

Federal Republic of Germany, Federal Institute of RiskAssessment, Health Assessment
Report POE-tallowamines (6 Sep. 2010)Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26Annex 26 Annex 27

United States Roundup Ultra LabelAnnex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27Annex 27 Annex 28

Colombia GYL-41 SL Label and Safety Data Sheet Annex 28

SECTION 1
READ THE LABEL BEFORE USING THIS PRODUCT
KEEP OUT OF CHILDRENS REACH

CAUTION AND USE WARNINGS

Spray solutions of this product should be mixed, stored, and applied using only stainless steel,
alumina, fiberglass or plastic-lined steel containers.

DO NOT MIX, STORE OR APPLY THIS PRODUCT OR SPRAY SOLUTIONS IN
GALVANIZED STEEL OR UNLINED (EXCEPT STAINLESS STEEL) STEEL

CONTAINERS OR SPRAY TANKS. This products or spray solutions of this product react with
such containers and tanks to produce hydrogen gas which may form a highly combustible gas
mixture. This gas mixture could flash or explode causing serious personal, if ignited by ope▯n
flame, spark or a welder’s torch, a lighted cigarette or other ignition source.

AVOID CONTACT OF HERBICIDE WITH FO LIAGE, GREEN STEMS, EXPOSED ROOTS
OR FRUIT OF CROPS, DESIRABLE PLANTS AND TREES, BECAUSE SEVERE INJURY
OR DESTRUCTION MAY RESULT

CAUTION: THIS PRODUCT CAUSES EYE IRRITATION. Avoid contact with eyes and
clothes.

FIRST AID

Call a medical center or doctor for treatment advice

IF IN EYES: - Hold eye open and rinse slowly and gently with water for 15 - 20 minutes. -
Remove contact lenses if present after the first 5 minutes then continue rinsing eye.

TOXICOLOGICAL EMERGENCIES PHONE NUMBER

Have the product container or label with you when calling a poison control center or

DOMESTIC ANIMALS: This product is considered to be relatively nontoxic to dogs and other
domestic animals; however, ingestion of this product or large amounts of freshly sprayed

vegetation may result in temporary gastrointestinal irritation (vomiting, diarrhea, colic, etc.). If
such symptoms are observed, provide the animal with plenty of fluids to prevent dehydration.
Call a veterinarian if symptoms persist for more than 24 hours

STORAGE AND DISPOSALWASTE

When storing or disposing the product, do not contaminate water, foodstuffs, animal foodstuff or
seeds. Do not store at home. DO not transport or store in vehicles or places where seeds or
foodstuffs for human consumption are transported or stored. Keep container closed to prevent
spills and contamination. DESTROY THIS CONTAINER AFTER USING THISAnnex 28

PRODUCT. No container that has contained herbicides should be used to store water or food for

human or animal consumption.

Approval date by ICA: 25/11/2008 SECTION 2 GLY-41 SL

GLY-41 SL

Herbicide for land and aerial applications to remove unwanted vegetation in nonagricultural sites

ICA SALES REGISTERED No. 4294

GUARANTEED COMPOSITION

ACTIVE INGREDIENT:

*Glyphosate, N-(phosphonomethyl) glycine, in the form of its
isopropylamine salt ……………………….…………▯…...…………………..41.0%

INERT INGREDIENTES……………………………………▯……………..... 59.0%
__________

100.0%

*Contains 480 grams per litre of active ingredient glyphosate, in the form of
isopropylamine salt. Equivalent to 356 grams per litre of the acid, Glyphosate.

DISTRIBCNTE:TENT:
CAC. Ltda, y Cía. S.C.A. Formulation date:
50.1., pirdo:ntie
Tel:(57-1) 288-6012 -- 01 8000916012 Lot number:
Bogota, Colombia

TOXICOLOGICAL CATEGORY IV
SLIGHTLY TOXIC
CAUTION

SECTION 3

GENERAL INFORMATION

Product description: This product is a post-emergence, systemic herbicide with no soil Annex 28

residual activity. It gives broad-spectrum control of many annual weeds, perennial weeds, woody

bush and trees. It may be applied using most equipments commonly used on farms, after diluting
and mixing it well in water or other solvents, according to the label recommendations.

MIXTURE:

Clean thoroughly all parts of application equipment after using this pro▯duct, rinsing
with abundant water.

NOTICE: RESULTS WILL NOT BE OPTIMAL IF DIRTY WATER, OR WATER
FROM PONDS AND DRAINS THAT IS NOT CLEAR IS USED.

Mixing with water: This product mixes readily with water. Mix spray solutions of this product as
follows: Begin filling the mixing tank or spray tank with the required amount of clean water.
Add the recommended amount of this product near the end of the filling process and mix well.
Use caution to avoid siphoning back into the carrier source. Use approve▯d anti-back siphoning

devices. During mixing and application, foaming of the spray solution may occur. To prevent or
minimize foam, avoid the use of mechanical agitators, terminate by-pass and return lines at the
bottom of the tank and, if needed, use an approved anti-foaming agent.

Surfactants.

Non-ionic surfactants may be used to improve wetting on foliage. Do not reduce rates
of this product when adding surfactant. Read and carefully observe all c▯aution
statements and other information on the surfactant label.

WEED CONTROL

Annual weeds

Apply from 2 to 3 litres of GL Y-41 SL per hectare to control the following species: Amaranthus
spp (pigweed), Bidens pilosa (Spanish needle), Boerhaavia erecta (erect spiderling), Borreris

laevis (purple-leaved button weed) , Cenchrus brownii (Brown’s burgrass), Commoiina diffusa
(climbing dayflower), Cyperus diffuses ( Dwarf Umbrella Grass ), Digitaria sanguinalis (hairy
crabgrass), Echinochloa coIonum (Jungle rice), Eleusine indica (wire grass), Euphorbia hirta
(asthma weed), Fimbrisilys annua (annual fimbry), Galinsoga ciliata (hairy galingosa), Ipomoea
spp ( morning glory), Ischaemum rugosum (ribbed muriana grass ), Jussiaea linifolia,

Kallstroemia maxima ( big caltrop), Oryza sativa* ( Asian rice), Portulaca oleracea ( common
purslane), Physalis angulata ( cutleaf groundcherry ), Rottboellia exaltata ( itch grass ),
Tradescantia cumanensis* (spiderwort).

Perennial weeds: Apply from 4 to 6 litres of GL Y-41 SL per hectare to control the following

species:
Andropogon bicomis (West Indian foxtail) , Axonopus micay (pasto micael), Brachiaria mutica
(para grass), Cynodon dactylon ( bermudagrass), Cyperus spp ( papyrus), Cyperus rotundus
(nutgrass), Imperata cilindrica (cogongrass), Panicum maximum (Embu guinea grass), PaspalumAnnex 28

conjugatum ( hilograss), Paspalum fasciculatum (Mexican crown grass), Paspalum virgatum

(talquezal), Paspalum paniculatum (arrocillo) Pennisetum purpureum (elephant grass),
Pennisetum clandestinum, (Kikuyograss), Sorghumhalepense (Johnsongrass),

Herbaceous semi-woody weeds such as Croton leptostachyus (empidonax), globules of Croton
(myrtle), edible Randia (cruceto), Myrcia acuminata (smooth myrtle), canescent Cordia

(sharpened foliage), Acacia farnesiana (pela, corona de Cristo, aromo), among other difficult to
control. Knowing that the ligneous brushes and trees do not grow in the form of ordered plants
occupying constant areas, we recommend a solution of 6 % (12 liters of GLY-41 SL per hectare,
applying 27 cc of herbicide solution per plant for the control of plants woody shrubs and trees of
waxy cuticle. For shrubby weeds plants with leaf area less waxed, the re▯commendation is a

solution of the herbicide from 4% to 5% (8-10 litres of GLY-41 SL) per hectare, applying 22.5
cc per plant.

TECHNIQUES AND EQUIPMENT FOR IMPLEMENTATION:

Sites for implementation: You can use this product, as recommended for:
x Control of annual herbaceous weeds and undesirable perennial and perennial weeds
in non cultivated lands,
x Control of semi-ligneous shrubs and small trees

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯burning limit, fire perimeters and "black"
lines,
x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯lots, buildings, fences, etc

Implementation techniques: Always use this product to the higher dose per hectare, within the
range recommended, when the growth of weeds is large or dense, or if the weeds are g▯rowing up
in an area without disturbing

The control can be reduced when addressing the weeds in terms of stress and little growth as in

drought, damage caused by disease or insects. They can also detract the results of control when
treated weeds are covered by a layer of dust. When they have been lopped or cut, the weeds must
be expected to grow back prior to treat them. For best results, the implementation should be
uniform and complete. It is not necessary to sp ray the foliage of weeds until the solution drains.
It may be necessary to repeat the treatments to control weed that regrow from the roots or

runners or when new weeds germinate by seed below the surface of the soil. You can repeat the
treatments up to an annual maximum download of 27.7 litres of this product per hectare. You can
use the product of 10 to 12 L/has for best results t control perennial w▯eeds, semiligneous shrubs
and trees of difficult control, when the plants grow in poor conditions,▯ or when the infestation is
dense. Do not apply this product through an irrigation system. THE HERBICIDE SOLUTION

WITH WELL MAINTAINED AND CALIBRATED EQUIPMENTS, CAPABLE OF
SPRAYING THE DOSES IN DESIRED VOLUMES

This product can be applied using the following equipments:

Implementation with land equipments: Systems with or without boom and other Annex 28

equipment for the implementation on the ground.

To control annual weeds or perennial with equipment for the implementation on the ground, use
the recommended doses per hectare for this product in volumes of 30 to 350 litres of solution. As
it increases the population density of the weeds, the volume of implementation must be increased
within the range recommended to obtain full coverage with the recommended dose per hectare.

Select carefully the nozzle to prevent that the application is too thin and causes drift. For better
results in terrestrial application use flat spray nozzle.

Hand-held or high-volume spray equipment. Knapsack and backpack sprayers, pump –up
pressure sprayers, handguns, handwands, mistblowers, lances or other hand-held or motorized

spray equipment used to direct the spray onto weed foliage.

Apply the spray solution onto vegetation foliage to be controlled. For a▯pplications made on a
spray-to-wet basis, spray coverage should be uniform and complete. Do not spray to the point of
runoff. Use coarse sprays only. Prepare the desired volume of the spray solution by mixing the

amount of this product with the volume water, as shown in the following table:

Quantity of GLY-41 herbicide
Desired
volume ½ % 1% 1½ % 2% 5% 10%
4 L 20 cc 40 cc 60 cc 80 cc 200 cc 400 cc
20 L 100 cc 200 cc 300 cc 400 cc 1 L 2 L

200 L 1 L 2 L 3 L 4 L 10 L 20 L

When using backpack sprayers, it is suggested to mix the recommended quantity of this product
with the water volume in a big container separately. Then pour the spray solution into the tank of
the spray pump

Equipment for aerial – fixed wing and helicopter

Use the recommended dose of herbicide in 20 to 140 litres of water volume per hectare, unless
otherwise specified on the label. Refer to the recommended volumes, application dose, and

additional instructions in the individual sections of use area in the label according to the type of
mixture.

Avoid direct application to any body of water. AVOID DRIFT – DO NOT APPLY DURING
INVERSION CONDITIONS, WHEN WINDS ARE GUSTY, OR UNDER ANY OTHER

CONDITION WHICH FAVORS DRIFT. DRIFT MAY CAUSE DAMAGE TO ANY
VEGETATION CONTACTED TO WHICH TREATMENT IS NOT INTENDED. TO
PREVENT INJURY TO ADJACENT DESIRABLE VEGETATION, APPROPRIATE BUFFER
ZONES SHOULD BE MAINTAINED.Annex 28

Coarse sprays are less likely to dritherefore, do not use nozzles or nozzles configurations

which dispense spray as fine spray droplets. Do not angle nozzles forward into the airstream and
do not increase spray volume by increasing nozzle pressure. Drift control additives may be used.
When a drift control additive is used, read and carefully observe the cautionary statements and
all other information appearing on the additive label. Ensure uniform application. To avoid
streaked, uneven or overlapped application use appropriate marking devices. Thoroughly wash

aircraft, especially landing gear, after each day of spraying to remove residues of this product
accumulated during spraying or flap spills. PROLONGED EXPOSURE OF THIS PRODUCT
TO UNCOATED STEEL SURFACES MAY RESULT IN CORROSION AND POSSIBLE
FAILURE OF THE PART. LANDING GEAR ARE MOST SUSCEPTIBLE. The maintenance
of an organic coating (paint) which meets aerospace specifications ML-C- 38413 may prevent

corrosion.

LIMITED WARRANTY AND LIABILITY:

The owner of the Registration ensures that this product meets the label chemical description and

that is reasonably designed for specific purposes, when used according to these instructions and
under the conditions described for implementing. DO NOT OFFER ANY OTHER EXPRESS
OR IMPLIED GUARANTEE AS TO THE SUITABILITY FOR A PARTICULAR PURPOSE
OR ITS MERCHANDISING. This warranty is also subject to the conditions and restrictions here
stipulated. The buyer and users must notify opportunely this Company any complaint, either
based on contract, negligence, strict obligation, injury or otherwise. T▯he buyer and all users are

responsible for the loss or damage by use or handling, resulting from conditions outside the
control of the Company, including but not limited and incompatibility with products other than
the indicated on the label, implementation or contact with desirable vegetation, unusual climate
conditions, other than the conditions that are considered normal for the site and during the period
of the application, as well as weather conditions other than those specified in the label and other

implementation than the explicitly specified in the label. This company does not guarantee any
product reformulated or re-packaged from this product, except in accordance with the
requirements of this Company and express permission in writing, granted by this Company.

THE WAY OF COMPENSATE THE USER OR THE BUYER DAMAGE AND THE

LIABILITY LIMIT OF THIS COMPANY OR ANY OTHER SELLER IN REGARD TO ANY
AND ALL THE LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR
HANDLING OF THIS PRODUCT (INCLUDING CLAIMS BASED ON CONTRACT,
NEGLIGENCE, STRICT OBLIGATION, OTHER DAMAGE, OR OTHERWISE), WILL BE
THE PURCHASE PRICE PAID BY THE USER OR THE BUYER FOR THE RESPECTIVE

QUANTITY OF THIS PRODUCT OR AS THIS COMPANY OPTION OR ANY OTHER
SELLER, THE REPLACEMENT OF THE QUANTITY, IF NOT BOUGHT, THE
REPLACEMENT OF THE QUANTITY IN ANY CASE SHALL THIS COMPANY WILL BE
RESPONSIBLE OR ANY OTHER SELLER FOR ANY INCIDENTAL, CONSEQUENTIAL
OR SPECIAL PREJUDICE Once the product IS open and used, it is understood that the buyer

and users have accepted the terms of this limited warranty and liability, which may not be altered
by any verbal or written agreement. If these terms are unacceptable, immediately return the
product without opening it. Annex 28

SALES REGISTRATION 4294

SAFETY DATA SHEET Glyphosate Herbicide

Section 2: IDENTIFICATION OF CHEMICAL PRODUCT:

Commercial name: Glyphosate Herbicide

Use: Agricultural herbicide, Soluble Liquid
Glyphosate N-(phosphonomethyl) glycine, Isopropylamine salt ……480.0 g/l
Formulation agents ………………………………………▯…………. C.s.p. 1 L C.A.S No. 38-
642-94-0
Section 3: RISKS IDENTIFICATION: Glyphosate herbicide is neither flammable nor

explosive. It is irritating when in contact with eyes. Keep in a locked place and keep out of
children’s reach
Section 4: FIRST AID MEAURES: The person must be taken away from the con▯tamination
source and check that he/she is breathing. Artificial breathing must be ▯provided if necessary to
ensure that this vital function continues. People in charge of providing first aid must avoid

direct contact with the very contaminated clothes or vomit of the victim. Impermeable gloves
must be used to decontaminate the hair and skin of the victim. LOOK FOR MEDICAL
ASSISTANCE AS SOON AS POSSIBLE If ingested If the person is conscious an▯d aware,
give her two glasses of milk or water. An unconscious person or with unusual movements
must never be fed or induced to vomit. LOOK FOR MEDICAL ASSITANCE In cas▯e of skin

contact: Wash the skin immediately with water and soap. If possible, remove the shoes and
shoes of the patient. Contaminated clothes must be washed separately before wearing it again.
In case of inhaling: Take the person to a fresh air area; if he/she is not breathing, provide
artificial breathing and oxygen if necessary. LOOK FOR MEDICAL ASSITANCE▯ In case of
contact with the eyes: Keep eyelids open and wash with running water for at least 15 minutes.

LOOK FOR MEDICAL ASSITANCE NOTE FOR THE PHYSICIAN Treatment must be
based on symptoms. This product does not inhibit

cholinesterase. Atropine and oximes must not be used as an antidote. s open given
Section 5: MEASURES TO EXTINGUISH FIRES Glyphosate herbicide is neither ▯flammable
nor explosive. In case of fire, combustion of the product may produce toxic vapors such as
carbon oxides and nitrogen. Extinguishing: Containers exposed to heat mu▯st be kept cool. It is
extinguished with carbon dioxide, foam, dry chemical powder or water spr▯ay in limited

quantities. Water used to extinguish it must not be allow to flow to superficial water nor must
it be allowed to flow to sewage systems. Water must be collected and kept as special residues.
Autonomous breathing protection equipment must be used.
Section 6: MEASURES IN CASE OF ACCIDENTAL SPILL Spills are contained wit▯h sand
or earth dikes. It is pick up by suction or vacuuming or by absorption using dry sand or earth

and the material collected is packed in a sealed container duly labeled. The contaminated sites
must be decontaminated by washing it with industrial detergent and it is handled as special
residues in burning devices or approved safety landfills. Recommended personal protection:
See section 8Annex 28

Section 7: HANDLING AND STORAGE: Handling: Eating, drinking
or smoking not allowed during handling or application of this product.
Was hands after being in contact with this product. Storage: Keep the
product in original packaging and containers. No smoking in the place.
Keep out of children and animals’ reach. Stored in a ventilated place,

away from food, drink, hay, or concentrated food for animals.
Compatible materials for storage: Stainless steel, aluminum, fiber glass
or plastic.
Section 8: EXPANSION CONTROLS AND PERSONAL
PROTECTION: Chemical safety gloves and eye protection must be

worn while handling. Occupational health and safety general rules must
be observed.
Section 9 PHYSICAL-CHEMICAL PROPERTIES: State: Liquid
Appearance and color: Amber viscous liquid, practically odorless
Density: 1,17 g/mL pH: 4.99 (Solution at 1%)

Section 10: STABILITY AND REACTIVITY: Glyphosate herbicide is
stable under normal storage and manipulation conditions. There is no
probability of dangerous reaction in the original containers. It reacts
with galvanized steel or soft steel without covering layer, producing
hydrogen, a very flammable gas that may cause explosion.

Section 11: TOXICOLOGICAL INFORMATION: ACUTE
TOXICITY: It is very unlikely that exposure to glyphosate herbicide
poses risk of acute toxicity (LD50 Oral (rats): > 5.000 mg/Kg; LD50
Dermal (rats): > 5.000 mg/Kg. It may cause slight irritation on skin and

from moderate to severe in the eyes. CHRONICLE TOXICITY: No
chronicle effects on humans have been documented, attributable to
chronicle exposure. Mutagenicity and carcinogenicity studies have
resulted negative.
Section 12: ECOTOXICOLOGICAL INFORMATION:

ECOTOXICITY:

It is not dangerous for aquatic organisms, nor is it toxic to birds. It must
not be poured into or near channels, drains, nor water courses or
reservoirs.

Section 13: CONSIDERATIONS ON PRODUCT DISPOSAL:
Residues resulting from the use of this product cannot be chemically re-
used and must be disposed of as special residues in adequate burning
devices or approved safety landfills. Annex 28

Section 14: INFORMATION ON TRANSPORT: It cannot be
transported nor stored with food for people or concentrated food for

animals, beverages, medicine, nor items for human use such as clothes,
blankets or mattresses. Glyphosate herbicide is not classified as
dangerous.
ISSUING DATE: August 2005

This information is applicable only to the purposes stated for the product. It complements the
technical information on the label but does not substitute it in any matter. It is based on the best
information available at the time of issuing; it does not imply insurance or warranty and it is
provided on good faith basis.Annex 28Annex 28Annex 28Annex 28Annex 28Annex 28Annex 28Annex 28Annex 28 Annex 29

Organization of Indigenous Nations of Colombia (ONIC), Evaluation of the Fumigations in Co-
lombia: Destruction of Rural Areas from Plan Colombia (Aug. 2002) Annex 29

ORGANIZATION OF INDIGENOUS NATIONS OF COLOMBIA- ONIC

PROCESS OF AFRO-COLOMBIAN COMMUNITIES - CN

NATIONAL UNION FEDERATION OF AGRICULTURE- FENSUAGO – CUT

EVALUATION OF THE FUMIGATIONS IN COLOMBIA

DESTRUCTION OF RURAL AREAS AS A RESULT OF PLAN COLOMBIA

AUGUST 2002

Annex 29

[PAGE 3-25]

who do not plant illicit crops, whose crime is being located next to others who do plant them.

This situation is described in numerous complaints reviewed.

x Many farmers can abstain from filing a complaint because they believe that it is a waste
of time if no one believes them. In fact, both the state and the antinarcotics police have
considered complaints for abuses and destruction caused by aerial fumigation to be false

or rigged.

x The groups who have resorted to armed confrontation can cause displacement of people
or failure to submit their complaints.

x The antinarcotics police’s offensive attitude with the Ombudsmen, in asserting their
unreliability, because they are relatives of those who plant coca, can induce ombudsmen

to refuse to receive complaints.

x Many farmers may abstain from filing complaints due to the inoperability of the system,
given that no compensation has been awarded.

The volume of parties harmed could be 100 times greater or more than what is detected in the
analyzed sample of complaints, since only a fraction of all complaints located at the
Ombudsmen’s Office were analyzed, and it was calculated that not more than 10% of the

complaints filed with various institutions in the whole country reach this particular office. As
has been noted above, many of those affected do not file complaints.

3.3 RESULTS FROM THE REVIEW OF COMPLAINTS

3.3.2 Types of complaints, their origin and destination

A sample of 1,852 complaints was reviewed, presented in the departments of Bo▯yacá,
Meta, Guaviare, Caquetá and Putumayo, between 1997 and January 2002, ▯through the regional
ombudsmen, police inspectors and Municipal Ombudsmen. We found only one complaint

presented at the antinarcotics police, because this institution manages its files independently
from the Ombudsman, but it is known that many complaints lie there, which, according to police

investigations, are almost never well-founded.

Ninety-five percent of the complaints reviewed correspond to 10 municipalities. These

statistics are presented in the following tables, subject to the clarification that only a fraction of
the Ombudsman’s files were reviewed, which can represent a small percentage of the actual files

Annex 29

on a national level. Some ombudsmen calculate that the complaints that reach the Ombudsman’s

office represent only 10% of all complaints filed

[PAGE 3-26]

on a national level. And the total complaints presented only cover an estimated 10% of the cases
that actually occur.

Quantity of complaints in the sample reviewed, per year
Year Number of complaints reviewed

1997 64
1998 69
1999 153

2000 238
2001 1,154
2002 174

Total complaints reviewed 1,852

Institutions in which complaints were filed
1
Institution Number of complaints filed
Municipal Ombudsmen 944
Municipal police inspectors 904

Regional Ombudsmen 3
Antinarcotics police 1
Total complaints reviewed 1,852

Departments in which these complaints were filed
2
Department Number of complaints filed
Putumayo 1,254
Caquetá 503

Guaviare 90
Meta 4
Boyacá 1 3

Total complaints reviewed 1,852

1The Antinarcotics police must be crammed by complaints. Complaints are also filed with the townships, offices of
Umata, Ministries of Health, Agriculture and Environment, Colombian Agricultural Institute – ICA, General
Comptroller of the Republic and District Attorney, but there is no state office that currently exists that collects or
systematizes them.
2The Departments of Cauca, Vichada, Norte de Santander, Tolima and others do not appear, because not all the
Ombudsman’s files were reviewed, but it was confirmed that they exist at this entity.
3Collective, filed in 1997 by 111 signatories.

Annex 29

We can see that the greatest portion of complaints come from only 3 departments,
therefore demonstrating that the damages are undervalued, since fumigations are being
conducted in at least 12 departments and there is no reason to presume that

[PAGE 3-27]

the police acts in a different manner in certain departments as opposed to others. Additionally,
the complaints are concentrated in only 10 out of the 260 municipalities with illicit crop

presence.

Municipalities with the largest number of complaints

Municipality Department Complaints Percentage
presented
Valle del Guamuez Putumayo 909 49

Curillo Caquetá 358 19
Puerto Asís Putumayo 149 8
San Miguel Putumayo 100 5
Albania Caquetá 75 4

Puerto Guzmán Putumayo 54 3
Calamar Guaviare 51 3
El retorno Guaviare 36 2
Solano Caquetá 26 1

La Hormiga Putumayo 20 1
10 Municipalities 3 Departments 1,778 95%

3.3.3 Collective complaint proceedings

Fifteen collective complaints were detected in the analyzed sampling of complaints. Close to half

of them corresponded to 1997 and 1999 in the departments of Caquetá and Guaviare, and the
other half between 2000 and January 2001 in the department of Putumayo. 36% of these

complaints arise from Indigenous Reservations, in which aggressions against people’s projects
such as Coreguaje, Cofanes and Ingas were recorded.

Some of these collective complaints were supported by hundreds of signatures; one of them was
filed by 8 physicians who confirmed the serious impacts and projects affected in the reservation
Cofán de Santa Rosa in Putumayo. In addition to the damages to thousands of hectares among

food crops, pastures, weeds and virgin forest areas, intoxication symptoms were reported such as
diarrhea, vomiting, fever, headache and coughing. In Cumaribo, Vichada, 942 peasants

complained and reported the deaths of two drowned persons who were trying to ford the river,
because 130 houses, in addition to being fumigated, were gunned down.

Annex 29

The collective complaints are a diffuse technique, but an important one to understanding

the magnitude of the damages caused by the fumigations. The fumigation that covers ancestral
territories is, by definition, a process close to genocide, given that certain communities have such

a limited population that their dispersion is the probable cause of their disappearance as an ethnic
group.

[PAGE 3-28]

“At the end of the month of July and the start of the month of August of the present year, the

Indigenous Reservation Inga de Aponte was the scene of the most intense indiscriminate
fumigations, there was no mercy for the sources of water, flora, fauna, food crops, including the

fields financed by the Alternative Development Plan PLANTE such as: potato, coffee, among
others; additionally, pastures were fumigated as well as other crops that had been planted by

natives with their very efforts, where they had invested the entirety of their few possessions in
the hopes of obtaining their harvests and acquiring the necessities for subsistence once their

products had been sold. All their efforts have become illusory because they have not been able
to obtain anything, on the contrary, more hunger and misery is being encouraged, leading to the

imminent extinction of the Ingas de Aponte as an ethnic group. Our rights to life, tranquility, and
health, are being abruptly attacked by the fumigations, each time that human beings, such as

children, who have been most affected, show skin rashes, subsequent fever as a result of said
fumigations. And this occurs now that it is the beginning; we do not know whether more cases

of disease will surface as a result of the spreading of chemicals.”
Libardo Chaso Jansasoy, indigenous governor. 4

Approximately eight days ago, the corn crops on my farm as well as the grass in general started

to yellow without knowing the reasons for it doing so. ASKED: Do you kn▯ow or have you heard
who has caused or who are responsible for what you say? ANSWER: Nothing is known about

this, we only hear rumors from villagers about an aircraft that passes at night, but no one knows
who it belongs to. I ask that you find out who is causing these damages, so that it does not affect

my neighbors, so that the soil is not sterilized and the waters are not polluted, because they are
used by everyone.

Guillermo Gines Ilvira 5

[PAGE 3-29]

4Letter signed by Libardo Chassoy Jansasoy, indigenous governor and a series of authorities from the Indigenous
reservation Inga de Aponte, Nariño, 14 August 2001.
5Complaint ·111, 9 November 1999, Municipal Ombudsman of Puerto Caicedo, Putumayo.

Annex 29

We have been subject to a series of fumigations in the middle of January 1998 and I was

fumigated on 7 January 1999. On 11 and 12 March they also passed by and fumigated us, they
fumigated two hectares of our plantain and three hectares of our yucca, they fumigated our pipes,

from which we collect water for our food, they fumigated our house, and our chickens. These
chickens died as a result of the fumigation, some pregnant rabbits also died and we were also

affected by the fumigation. The birds fell from the trees; they also sprayed the entire jungle, who
allowed the jungle, with its myriad of animals, to be fumigated? ASKED: Do you have
anything more to add or amend in the present proceeding? ANSWERED. I ask the government

to take a look at what they can do, we are poor, and we started to work on the field so that we
need not harm anyone, and they come and take us away from the field by fumigating our food,

our grass and even our animals. Or does the government want us to be just another criminal in
the city? Because what are we to do with 4 children? We have no education, no money and, to

sum up, they fumigate the little that we have. We also have rights, even as poor people, they
need to respect us. The government has everything and does not know what it means to be
hungry.

Magda Liliana Cruz Sarmiento 6

3.4 IMPACT ON HEALTH AND ENVIRONMENT

In the complaints reviewed, the damage to food crops such as fruit orchards and others is

denounced, the destruction of pastures and natural grasslands, illness and death of both
domesticated and wild animals, intoxication in human beings, mainly in children and other
contamination problems. Calculating how many thousands of hectares will be affected is not

easy, because there are collective complaints and others in which, in addition to food crop areas
and pastures, damages to wild areas are reported such as jungles and weed areas. The losses for

farmers and for biodiversity caused by the fumigations directly or indirectly can be incalculable.

Symptoms such as fever, vomiting, diarrhea, headaches, skin affectations, dizziness,
ocular irritation and others are among the health problems that have been reported, The
epidemiological nurse, Diva Ravelo, from the Administrative Health Department of the

Putumayo, Dasalud, has monitored and systematized hundreds of complaints and medical
consultations and her report, included below, clearly reflects

[…]
[Page 3-42]

6Complaint ·8, at the Office of the Ombudsman, Municipality of Calamar, 16 March 1999.

Annex 29

3.4.7 Posture held by the Ministry of Environment

It is interesting to consider the Ministry of Environment’s contradictory stance, which has
publicly defended the fumigations as safe for the environment, including Senate debates, at the

same time that it rejected the Plan for Environmental Management proposed by the National
Narcotics Directorate, for not responding to the “scope and objectives defined in the terms
referenced or to the requirements for information that this Ministry has requested in repeated

opportunities” (Resolution 0341 dated May 2001). Finally, the Ministry, after a six-year
process, imposed the Plan of Environmental Management on the National Narcotics Directorate,

pursuant to Resolution 1065 dated 26 November 2001 (where little relevance has been given to
the health component), and the same day it issued Resolution 1066, “Through which an
investigation is opened, a statement of objections is elevated to a higher authority and other

findings are made,” as a result of violations of certain provisions requiring immediate actions
ordered in Resolution 0341 dated May 2001.

The Comptroller General of the Republic had already registered several of these

violations, such as the lack of geo-referentiation in adequate degrees in the fumigated zones; and
the non-compliance in performing evaluations of the environmental impact in order to establish

the nature and characteristics of the possible environmental impact caused, and having failed to
measure the residues of glyphosate in soil and its effects on physical, chemical and biological
properties of the soils, using sample parcels.

As a response, the National Narcotics Directorate filed, the following month, in
December of 2001, an appeal against Resolution 1065 setting forth a series of arguments, among
them the lack of jurisdiction to assume the responsibility of the entirety of the execution of the

Plan of Environmental Management. Although a series of other considerations of normative
type will be made, what is clear is that the government has made irresponsible declarations

regarding the harmlessness of these fumigations, despite the lack of studies regarding the impacts
on the environment or the fact that an epidemiological monitoring has not been carried out by the
health authorities.

3.4.8 Position held by the Ministry of Health

The response that the Health Ministry sent to the National Organization of Indigenous
People in Colombia (ONIC) on August 22, 2001, in response to three interrogatories th▯at were

formulated to it as part of a right to petition, is proof that said Ministry▯ has not concerned itself in
years over what can occur to the communities as a result of these fumigations. When concretely

asked about the preventative measures in public health that had been decided on for the
provinces of Cauca, Nariño, and Putumayo, in light of the use of glyphosate or other

[PAGE 3-43]

Annex 29

chemicals used by eradication. The Ministry, in two extensive paragraphs, referred itself to
Decree 1843 of 1991 regarding pesticide use and management with respect to buffer zones and
toxicological classification: but the true and relevant response occupie▯d less than two lines and

consisted of the following: “there are no experimental studies in the country that deal with the
impact of aerial spraying of Glyphosate on human health.”

Regarding the second question, about the number of those intoxicated, ill, or affected by
the use of chemicals used by eradication, the answer was that the Direcciones Departamentales

de Salud de Putumayo (“Departmental Health Directorates of Putumayo”) have been asked to
carry out the appropriate investigation, and they highlight that the Dep▯artmental Health
Directorate of Putumayo has not reported any cases of intoxication as a result of glyphosate.

With respect to this, the complaints reviewed at the Ombudsman’s office and the February 2001
report issued by epidemiologist Diva Revelo, official from the Department of Health of

Putumayo (Dasalud), to which we refer to below, show the Ministry of Health’s lack of interest
for the problem.

“Around 8:00 a.m. on 17 January of the present year, they fumigated the whole village and my
farm, in particular. They fumigated around 50 hectares of pasture, two hectares of rubber crops,

and two hectares of plantain and yucca. That poison also drenched 80 cows and it is not the first
time that this has occurred with respect to cattle and because of that I assume that this poison has

caused me a high mortality of born cattle as well as cattle miscarriages. On another note, I sent
my child to collect guavas on the pasture and when she was collecting the guavas, the aircraft
passed over and fumigated her as well. She immediately started to experience dizziness, and I

was forced to leave the farm which is approximately two hours away by canoe, by river
transportation. The physician found that she was affected by the beginnings of intoxication, this
is confirmed by a written medical diagnosis and is the reason that I come to file a complaint so

that this does not continue to happen to the majority of us who inhabit the field, as well as
animals, food crops and other species. ASKED: MIREYA TORRES, please tell us about the

fumigation of which you were a victim. ANSWERED: My dad sent me to the pasture to collect
guavas and bring them home. At that moment, aircraft passed over and fumigated the pasture
and fumigated me as well. I immediately felt dizzy, felt a headache and at that moment, I went

to pee and my lungs hurt. I started to itch and feel a burning sensation in my bladder. My dad
immediately took me to the village, to the health center, and I was examined there. The doctor

told me that I showed symptoms of intoxication. ASKED: Did the physician prescribe any
medication when he diagnosed you with symptoms of intoxication?”

Annex 29Annex 29Annex 29Annex 29Annex 29Annex 29Annex 29Annex 29 Annex 30

Colombian Medical Inquests (Sept. 2002) Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________
C.I.: ___________________________

Signature: ________SIGNED________
CLINICAL TOXICOLOGICAL SHEET

First names: ____Soledad_____________ Last Names: ______________________

Age: __32_____ Nationality: _Colombian_ Parish/Village: __Nueva Granada_____
County/Municipality: ___Puerto Asis_____ Province/Department: ___Putumayo___

Occupation: ___Farmer_______________ Place of work: _______Farm_________

Signs and symptoms

GaAstrointestinal X dominal Pain X Diarrhea X Nausea
X Vomiting Intestinal Spasms Hyperperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor

Cyanosis Hypotension
Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion

Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/ dizziness Sweatiness Arreflexia
Disorientation
Paresthesia Shock
temp/esp Unconsciousness
X Other: Bodily pain
Neuro-muscular Paralysis X Loss of strength Speech disorder

Others:
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory Cough: dry / Dysnea Wheeze
productive Other:

Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with
X Other:Itchiness, blood

Pruritus on all the body
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and Fatigue, depression
Observations:
What activity do you perform in your farm:

X Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)Annex 30

Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer

(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gayep)rsgteen

Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)

Glyfoagri (Disagri) Tunda (coffee
fertilizers)
Socar (Agrevo)
ç
Crossout (Agroser)
Candela (Agroser)
Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________

When did you start noticing them? __________________________________________
What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance

No
When did the events occur? __I was the subject of fumigations on many occasions ___
How many times a day did the aircraft pass over? __________________________▯____

How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________
X Sources of water X Crops
X People X Houses

Others: (please specify) ___________________________________________________
Other affected parties
Other family members affected:
Name Age Effects

J 22 Exactly the same as him
M 19 Exactly the same as him
M 16 Exactly the same as him

V 42 Exactly the same as him
Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS:Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002____________
Organization: _________________________
C.I.: ________________________________

Signature:___________SIGNED__________
CLINICAL TOXICOLOGICAL SHEET
First names: ___Jose_________________ Last Names: ______________________
Age: __48______ Nationality: __________ Parish/Village: Nueva Granada_______

County/Municipality: Puerto Asis Province/Department: __Putumayo____
Occupation: ____Farmer___________ Place of work: Nueva Granada_______

Signs and symptoms

GaAstrointestinal X dominal Pain Diarrhea X Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor

Cyanosis Hypotension
Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion

Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia

Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:
Neuro-muscular X Loss of strength
Paralysis Speech disorder
Others:
Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis
Ocular pain
Other:
Respiratory Cough: dry / Dysnea Wheeze
productive
Other:
Pulmonary edema
Skin X Dermatitis Like a Ulcers Sweatiness with
Rash blood

X Other: Itchiness
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and Tiredness. Fatigue. Depression
Observations:
What activity do you perform in your farm:

X Agricultural What type of crops? See annex Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)Annex 30

Pillaround Caldeon Faena Panzer
(Invechemical)

Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)

Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)

Candela (Agroser)

Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________

No
When did the events occur? _______30 August and 3 September________________
How many times a day did the aircraft pass over? ________5 aircraft, 2 overpasses
How many days were the fumigations conducted? _________2 days ______________

What could you see was affected by the fumigations? _____________________________
Sources of water Crops
People Houses

Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:

NAME AGE EFFECTS
M 40 All felt the same
M 23 All felt the same

V 12 All felt the same

Any pregnant women?

Name Age Effects

Other effects

Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: They visited and the discomfort remainsAnnex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature: _________SIGNED_______

CLINICAL TOXICOLOGICAL SHEET
First names: ____DAVID_____________ Last Names: ___VILLAMARQUES_____
Age: ___72____ Nationality: Colombian__ Parish/Village: Nueva Granada____
County/Municipality: __Pro Asis________ Province/Department: Nueva Granada

Occupation: ____Farmer______________ Place of work: Nueva Granada

Signs and symptoms
GaAstrointestinal X dominal Pain X Diarrhea X Nausea

X Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
X Other: Sore throat

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor
Cyanosis Hypotension

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
X Insomnia Drowsiness X Anxiety
X Depression
Euphoria / Salivation
Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp
Unconsciousness
Other:
Neuro-muscular Paralysis X Loss of strength Speech disorder
Others:

Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory Cough: dry / Dysnea Wheeze
productive Other:
Pulmonary edema

Skin Dermatitis Ulcers Sweatiness with
X Other: Great blood
Itchiness

Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and I am out of breath; I am fatigued

Observations:
What activity do you perform in your farm:
X Agricultural What type of crops? Plantain, pastures, fruit trees, avocado, cane, orange, pineapple

Livestock What type of cattle? Aviculture What type of birds?
Aquaculture What type of fish? Other Please specify:Annex 30

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gaypgrsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)

Glyfoagri (Disagri) Tunda (coffee
fertilizers)
Socar (Agrevo)

ç Crossout (Agroser)
Candela (Agroser)

Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________
When did you start noticing them? __________________________________________
What do you think the cause is? ____________________________________________

Have fumigations been conducted in your area?
X Yes Please specify at what distance
No
When did the events occur? ________________________________________________

How many times a day did the aircraft pass over? _4 aircraft and 5 helicopters________
How many days were the fumigations conducted? __They have been fumigating for one month every day
What could you see was affected by the fumigations? _____________________________
Sources of water X Crops

People Houses
Others: (please specify) ___________________________________________________
Other affected parties

Other family members affected: I live alone
Name Age Effects

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects

Quantity Quantity

OBSERVATIONS: The two cows from the government are about to die.Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature :________SIGNED_______
CLINICAL TOXICOLOGICAL SHEET
First names: Pedro__________________ Last Names: ______________________

Age: 45_______ Nationality: Colombian_ Parish/Villgez:ul ___________________
County/Municipality: Puerto Asis_______ Province/Dep artment: Putumayo_________
Occupation: Farmer __________________▯_ Place of work: ______________________

Signs and symptoms
GaAstrointestinal X dominal Pain Diarrhea X Nausea
Vomiting Intestinal Spasms Hyperistalsis

Burning Rectal incontinence
Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias

Hypertension ppm Pallor
Cyanosis Hypotension
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
X Insomnia (Stress) Drowsiness X Anxiety
X Depression Euphoria / Salivation
Vertigo/dizziness
Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis X Loss of strength Speech disorder
X Others: Bone ache
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory Cough: dry / Dysnea Wheeze

productive Other:
Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with

X Other: Generalized blood
pruritus, mainly on arms
and face
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and Fever, General discomfort
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA Annex 30

Roundup Clyphosate Roundup
Glyphosate Mon 0139 Rocket

Glyphonox Candela Super Rocky
Pillaround Caldeon Faena

Glyphosate 480 g/l Glyalca Patrol
Glyphogan Glyphosan Squadron
Ranger Banox Ranger

Rodeo Super Source
Atila Rondo Batalla Gaypg)rgteen

Arbex Rocket Glifonox (Crystal)

Glyfoagri (Disagri)

Socar (Agrevo)
ç Crossout (Agroser)

Candela (Agroser)

Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________

When did you start noticing them? __________________________________________
What do you think the cause is?__________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance

No
When did the events occur? 5 and 6 September______________________________
How many times a day did the aircraft pass over? 4 planes went over twice___

Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:

Name Age Effects
H 14 All the same
M 23 All the same

M 4 All the same, very frightened
H 24 All the same
Any pregnant women?

Name Age Effects

Other effects

Animal Type Effects Plant
Quantity Quantity

OBSERVATIONS: Things have gotten a little better but they are going to Ecuador as we can no longer stay here.Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________
C.I.: ___________________________

Signature: _________SIGNED_______

CLINICAL TOXICOLOGICAL SHEET
First names: Manuel_______________ Last Names: ______________________

Age:31 _______ Nationality: Colombian _ Parish/Village: Nueva Granada__________
County/Municipality: Puerto Asis_______ Province/Department: _______________
Occupation: Farmer __________________▯_Place of work: ______________________

Signs and symptoms
Gastrointestinal Abdominal Pain Diarrhea X Nausea
X Vomiting Intestinal Spasms Hyperistalsis

Burning Rectal incontinence
Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias

Hypertension ppm Pallor
Cyanosis Hypotension
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/dizziness
Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis Loss of strength Speech disorder
X Others: Body ache
Ocular X Ocular irritation Visual Alteration Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory Cough: dry / Dysnea Wheeze

productive Other:
Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with

Other: blood
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic
Other:
Other and Fever, Bone ache, Fatigue, Tiredness
Observations:
What activity do you perform in your farm:

X Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser) Annex 30

Glyphosate Mon 0139 Rocket
Glyphonox Candela Super Rocky

Pillaround Caldeon Faena

Glyphosate 480 g/l Glyalca Patrol

Glyphogan Glyphosan Squadron
Ranger Banox Ranger
Rodeo Super Source

Atila Rondo Batalla Gaypr)rgteen
Arbex Rocket Glifonox (Crystal)

Glyfoagri (Disagri)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance Above
No
When did the events occur? Tuesday 3rd and Friday 6th of September_________

How many times a day did the aircraft pass over? 6 planes, twice each_____
How many days were the fumigations conducted? 2 times_____________________
What could you see was affected by the fumigations? _____________________________
Crops X waterofurcesX

s e s u o H X e l p o e P X
Others: (please specify) ___________________________________________________

Other affected parties

Other family members affected:
Name Age Effects
M 33 The

V 22 The
V 17 The
M 20 The

V 5 The
M 3 The
M 1 The

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant
Quantity Quantity

OBSERVATIONS: They still have the symptoms. They even double over with the affectation,Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______

Organization: ____________________
C.I.: ___________________________
Signature: _________SIGNED_______

CLINICAL TOXICOLOGICAL SHEET
First names: Jon___________________ Last Names: ______________________
Age: 22_______ Nationality: Colombian_ Parish/Village: Nueva Granada__________

County/Municipality: Puerto Asis________ Provin ce/Department: Putumayo ________
Occupation: Farmer __________________▯_ Place of work: Putumayo_______________

Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor

Cyanosis Hypotension
Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion

Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
Vertigo/dizziness Sweatiness Arreflexia

Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis Loss of strength Speech disorder
Others:
Ocular Ocular irritation Visual Alteration Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory Cough: dry / Dysnea Wheeze

productive Other:
Pulmonary edema
Skin X Dermatitis Ulcers Sweatiness with

X Other: Skin rashes in blood
the face
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and Face lesions that are still present. The lesions are look like a pimple. Before,
Observations: he had nothing.

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which oneAnnex 30

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer

(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)

Glyfoagri (Disagri) Tunda (coffee
fertilizers)
Socar (Agrevo)

ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
Yes Please specify at what distance
No
When did the events occur? On 2 days. 6 planes, flew twice over______________

How many times a day did the aircraft pass over?____________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected: He lives alone.
Name Age Effects

Any pregnant women?

Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: The lesions remain to date.Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______

Organization: ____________________
C.I.: ___________________________
Signature: ___________SIGNED____
CLINICAL TOXICOLOGICAL SHEET

First names: Francisca_______________ Last Names: ______________________
Age: 30 _______ Nationality: Colombian_ Parish/Village: Nueva Granada__________
County/Municipality: Puerto Asis_______ Province/Dep artment: Putumayo_________
Occupation: Farmer __________________▯_ Place of work: ______________________

Signs and symptoms
Gastrointestinal Abdominal Pain Diarrhea X Nausea
Vomiting Intestinal Spasms Hyperistalsis

Burning Rectal incontinence
Other:
Cardio-circulatory Bradycardia X Tachycardia: …….. Arrhythmias

X Hypertension ppm Pallor
Cyanosis Hypotension
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
X Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/dizziness
Sweatiness Arreflexia
X Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis X Loss of strength Speech disorder
Others:
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory Cough: dry / Dysnea Wheeze

productive Other:
Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with blood

Other:
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and Fever, lack of appetite, bone ache
Observations:
What activity do you perform in your farm:

Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)Annex 30

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)

Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance Above the houses
No
When did the events occur? It was a Saturday she remembers___________________

How many times a day did the aircraft pass over? 5 planes, only 1 time_______
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________
Sources of water Crops

People Houses
Others: (please specify) ___________________________________________________
Other affected parties

Other family members affected: There were 5 other people in the house
but they were not affected.
Name Age Effects

5 Bloody nose and cough
M 20 5 persons in the house but they were
not affected
V 15 5 persons in the house but they were

not affected
M 38 5 persons in the house but they were
not affected

M 8 5 persons in the house but they were
not affected
M 4 5 persons in the house but they were
not affected

Any pregnant women?
Name Age Effects

Other effects
Animal Type EfQ fuatpteEtffects
Quantity

OBSERVATIONS: She has no more discomfortAnnex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature _________SIGNED_______
CLINICAL TOXICOLOGICAL SHEET
First names: Luz María______________ Last Names: ______________________

Age: 37_______ Nationality: Colombian_ Parish/Village: Los Cristales (33 families)_
County/Municipality: _________________ Provin ce/Department: _______________
Occupation: _________________________ Place of work: ______________________
Signs and symptoms

Gastrointestinal X dominal Pain X Diarrhea X Nausea
X Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
X Other: Agony

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor

Cyanosis Hypotension
Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion

Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation
Paresthesia Shock
temp/esp Unconsciousness
Other:
Neuro-muscular Paralysis Loss of strength Speech disorder

Others:
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory X Cough: dry / Dysnea Wheeze
productive Other:

Pulmonary edema
Skin X Dermatitis Ulcers Sweatiness with blood
X Other: Hives
Renal / Urinary
Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and Fever, fatigue, lack of appetite, It smells like weeds are being killed;

Observations:
What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)

Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer (Invechemical)Annex 30

Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gaypr)rsgteen

Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance Above the houses
No

When did the events occur? 17 August_____________________________________
How many times a day did the aircraft pass over?__________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects
V 10 they all have the same as her: Diarrhea,

Cough: dry , Hoarseness, Fever
M 8 they all have the same as her: Diarrhea,
Cough: dry , Hoarseness, Fever

M 6 they all have the same as her: Diarrhea,
Cough: dry , Hoarseness, Fever
V 4 they all have the same as her: Diarrhea,
Cough: dry , Hoarseness, Fever

V 15 they all have the same as her: Diarrhea,
Cough: dry , Hoarseness, Fever
M 25 they all have the same as her: Diarrhea,
Cough: dry , Hoarseness, Fever

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: They are still ill after a month.Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature: _______SIGNED________

CLINICAL TOXICOLOGICAL SHEET
First names: Janet__________________ Last Names: ______________________
Age: 28 _______ Nationality: Colombian_ Parish/Village: Los Cristales____________
County/Municipality: _________________ Provin ce/Department: _______________

Occupation: _________________________ Place of work: ______________________

Signs and symptoms
GaAstrointestinal X dominal Pain X Diarrhea Nausea

X Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
Other:

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor
Cyanosis Hypotension

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety

Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp
Unconsciousness
Other:
Neuro-muscular Paralysis X Loss of strength Speech disorder
X Others: Bone ache

Ocular X Ocular irritation X Visual Alteration Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory Cough: dry / Dysnea Wheeze
productive Other:
Pulmonary edema

Skin Dermatitis Ulcers Sweatiness with
X Other: Boils all over blood
her body

Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and

Observations:
What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIAAnnex 30

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)

Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer
(Invechemical)

Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)

Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gaypgrsgteen

Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)
Glyfoagri (Disagri) Tunda (coffee

fertilizers)
Socar (Agrevo)
ç Crossout (Agroser)

Candela (Agroser)
Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________
When did you start noticing them? __________________________________________

What do you think the cause is?__________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distanceAbove

No
When did the events occur? 17 / 18 August ________________________________
How many times a day did the aircraft pass over?__________________________
How many days were the fumigations conducted? ______________________________

What could you see was affected by the fumigations? _____________________________
Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected: They all have the same effects as
her.

Name Age Effects
M 20
V 13

V 9
V 7
M 1
Any pregnant women?

Name Age Effects

Other effects

Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: (Illegible)Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature: _________SIGNED_______

CLINICAL TOXICOLOGICAL SHEET
First names: Manuel_________________ Last Names: ______________________
Age: 19 ______ Nationality: Colombian_ Parish/Village: Los Cristales __________
County/Municipality: _________________ Provin ce/Department: _______________

Occupation: _________________________ Place of work: ______________________

Signs and symptoms
GaAstrointestinal X dominal Pain X Diarrhea X Nausea

X Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
X Other: Throat ache

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor
Cyanosis Hypotension

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety

Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp
Unconsciousness
Other:
Neuro-muscular Paralysis Loss of strength Speech disorder
X Others: Bone ache,

Depression
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory X Cough: dry / X Dysnea Wheeze
productive Other:

Pulmonary edema
Skin X Dermatitis Ulcers Sweatiness with
X Other: Boils blood
Renal / Urinary
Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and The chemical landed on him and he has started to lose his hair. It happened to

Observations: a neighbor too.

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which oneAnnex 30

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)

Glyfoagri (Disagri) Tunda (coffee
fertilizers)
Socar (Agrevo)

ç Crossout (Agroser)
Candela (Agroser)

What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance Above
No

When did the events occur? ________________________________________________
How many times a day did the aircraft pass over?____________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected: He lives alone.
Name Age Effects

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS:Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______

Organization: ____________________
C.I.: ___________________________
Signature: ________SIGNED_______
CLINICAL TOXICOLOGICAL SHEET

First names: Julio_________________ Last Names: ______________________
Age:60 _______ Nationality: __________ Parish/Village: Aguas B. Los Cristales ___
County/Municipality: _________________ Provin ce/Department: _______________
Occupation: _________________________ Place of work: ______________________

Signs and symptoms
GaAstrointestinal X dominal Pain X Diarrhea Nausea
X Vomiting Intestinal Spasms Hyperistalsis
X Burning
Rectal incontinence
Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
ppm
Hypertension Pallor
Cyanosis Hypotension
Other:
Neurological- mental X Chronic Headache
Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness
Arreflexia
Disorientation X Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis Loss of strength Speech disorder
X Others: Bone ache
Ocular X Ocular irritation Visual Alteration X Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory Cough: dry / Dysnea Wheeze

productive Other:
Pulmonary edema
Skin X Dermatitis Ulcers Sweatiness with
X Other: Rashes,
blood
pruritus
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic
Other:
Other and Shortness of breath, fatigue, depressed, fever.
Observations:
What activity do you perform in your farm:

Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap) Annex 30

Glyphonox Candela Super Rocky
Pillaround Caldeon Faena

(Invechemical)
Glyphosate 480 g/l Glyalca Patrol
Glyphogan Glyphosan Squadron

Ranger Banox Ranger
Rodeo Super Source
Atila Rondo Batalla Gayp)rsgteen

Arbex Rocket Glifonox (Crystal)
Cauca)

No
When did the events occur? 1 month ago___________________________________
How many times a day did the aircraft pass over?__________________________

How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________
Crops wateXfurces X
s e s u o H Xe l p o e P X

Other affected parties

skin Other family mmaie,rs affected: Throat
Name Age Effects
Man 8 The

Woman 4 The
Woman 2 The
Man 9 The
Woman 7 The

Woman 54 The
Man 18 The
Man 28 The

Man 30 The
Woman 22 The
Man 12 The

Any pregnant women?
Name Age Effects
Others: (please specify) ___________________________________________________

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS:Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature:_________SIGNED________

CLINICAL TOXICOLOGICAL SHEET
First names: Carla__________________ Last Names: ______________________
Age: 29 _______ Nationality: Colombian _ Parish/Village: Los Cristales____________
County/Municipality: _________________ Provin ce/Department: _______________

Occupation: _________________________ Place of work: ______________________
Signs and symptoms
Gastrointestinal Abdominal Pain Diarrhea Nausea

Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
Other:

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias

Hypertension ppm Pallor
Cyanosis Hypotension
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / X Salivation

X Vertigo/dizziness Sweatiness Arreflexia
Disorientation X Paresthesia Shock
temp/esp Unconsciousness

Other:
Neuro-muscular Paralysis Loss of strength Speech disorder
X Others: Body aches
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory X Cough: dry /
Dysnea Wheeze
productive Other:
Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with

X Other: Pruritus blood
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and Rhinorrhea, high fever, fatigue
Observations:
What activity do you perform in your farm:

Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)Annex 30

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance
No
When did the events occur? 17 / 18 August_________________________________

How many times a day did the aircraft pass over? 6 planes, many flights (5). On Sunday there were more than 5
flights ______________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects

H 32 Same as him. Rhinorrhea
H 5 Colds and fever, Chronic
Headache
H 4 Colds and fever, Chronic

Headache
M 2 discomfort, fever, rhinorrhea
H 4 Same

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: They all still ill.Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature _________SIGNED_______

CLINICAL TOXICOLOGICAL SHEET
First names: _________________ Last Names: ______________________
Age: 38 _______ Nationality: Colombian _ Parish/Village: Nueva Floresta _____
County/Municipality: Puerto Asis_______ Province/Dep artment: Putumayo____

Occupation: Farmer ___________________ Place of work: Farm owner ________

Signs and symptoms
GaAstrointestinal X dominal Pain Diarrhea X Nausea

Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
Other:

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor
Cyanosis Hypotension

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety

Depression Euphoria / X Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation X Paresthesia (feet Shock

temp/esp and hands)
Other: Unconsciousness
Neuro-muscular Paralysis Loss of strength Speech disorder

X Others: Bone ache
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory Cough: dry / Dysnea Wheeze
productive Other:
Pulmonary edema

Skin Dermatitis Ulcers Sweatiness with
X Other: boils on the blood
skin and all over the

body, where the rain fell.
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and She still gets dizzy and has paresthesia. She feels burning in her nasal passage
Observations: as if blood were going to come out.

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:Annex 30

Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)

Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)

Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance Above the house
No

When did the events occur? 16 / 17 August__________________________________
How many times a day did the aircraft pass over? 6 planes, twice, then they went and came back the following day
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

X Sources of water - tap water couldn´t be drunk on those days.
Crops People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects
Man 45 Mouth and skin were also burnt.

Not her.
V 7 All the same
H 26 All the same

M 17 All the same
Any pregnant women?
Name Age Effects

Other effects
Animal Type EfQ fuatpteEtffects
Quantity

OBSERVATIONS: The 45 year old has tremendously burnt skin.Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________
C.I.: ___________________________

Signature:________SIGNED________

CLINICAL TOXICOLOGICAL SHEET
First names: Pedro__________________ Last Names: ______________________

Age: 40_______ Nationality: Colombian_ Parish/Village: Agua Blanca. Los Cristales_
County/Municipality: Puerto Asis________ Province/Dep artment: Putumayo_________
Occupation: _________________________ Place of work: ______________________

Signs and symptoms
Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis

Burning Rectal incontinence
X Other: Throat pain
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias

Hypertension ppm Pallor
Cyanosis Hypotension
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation

Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis Loss of strength Speech disorder
Others:
Ocular X Ocular irritation X Teariness / Myosis
Visual Alteration
Mydriasis Ocular pain
Other:
Respiratory X Cough: dry /
Dysnea Wheeze
productive Other:
Pulmonary edema
Skin X Dermatitis Ulcers Sweatiness with

X Other: Pruritus all blood
over the body
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and Rhinorrhea, Fever, Bone ache, Loss of strength
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)Annex 30

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gaypgrsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance 500 meters
No
When did the events occur? 3 weeks ago_____________________________________

How many times a day did the aircraft pass over? 6 planes flew over twice_____
How many days were the fumigations conducted? 3 weeks in different areas______
What could you see was affected by the fumigations? _____________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________
Other affected parties

Other family members affected: They all got sick just as he did
and had boils on their skin.
Name Age Effects

M 25
H 5
H 3
Any pregnant women?

Name Age Effects

Other effects

Animal Type Effects Plant Type Effects
Quantity Quantity
1 CatGtets skinny 1/2 Hectare Banana It yellows
and dies

1/2 Hectare Cassava The root rots
OBSERVATIONS: The wife is still sick.Annex 30Annex 30 Annex 30

Date of report: __11 Sept 2002_______
Organization: ____________________

C.I.: ___________________________
Signature:_________SIGNED_______
CLINICAL TOXICOLOGICAL SHEET
First names: Elisenda________________ Last Names: ______________________

Age: 26 _______ Nationality: Colombian_ Parish/Villgee:teye _________________
County/Municipality: Puerto Asis_______ Province/Dep artment: Putumayo ________
Occupation: Farmer ___________________ Place of work: Owned farm ____________
Signs and symptoms

Gastrointestinal Abdominal Pain X Diarrhea X Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
Hypertension ppm Pallor

Cyanosis Hypotension
Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion

Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
Vertigo/dizziness Sweatiness Arreflexia

Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis X Loss of strength Speech disorder
X Others: Bone ache
Ocular Ocular irritation Visual Alteration Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory Cough: dry / Dysnea Wheeze

productive Other:
Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with

Other: blood
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic
Other:
Other and Bitter water, shivers, fever
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)Annex 30

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gaypgrsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance500 meters
No

When did the events occur? Thursday 6 September_____________________________
How many times a day did the aircraft pass over? 6 planes, 3-4 times_________
How many days were the fumigations conducted? Every day they fumigated and advanced
What could you see was affected by the fumigations? _____________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:

Name Age Effects
M 2 Vomiting, diarrhea, fever, loss of
appetite

V 33 Nothing
M 46 Rashes,itching, red eyes, tearful

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: The doctors told her to boil the water.Annex 30Annex 30 Annex 31

Ecuadorian Medical Inquests (Sept.- Nov. 2002) Annex 31

Date of report: __12 Sept 2002___________________
Organization: ________________________________
C.I.: _______________________________________
Signature: ___________SIGNED________________

CLINICAL TOXICOLOGICAL SHEET

First names: __Ma. Isabel______________ Last Names: __Campoverde ______

Age: ___34____ Nationality: _Ecuadorian Parish/Village: ____Chone 2 ________

County/Municipality: _________________Province/Department: __________ _____
Occupation: ___Farmer________________Place of work: Owned Farm_____ _

Signs and symptoms
Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis

Burning Rectal incontinence
X Other: Sore Throat
Cardio-circulatory Bradycardia Tachycardia: Arrhythmias

Hypertension Hypotension Pallor
Cyanosis
Other:

Neurological- mental X Chronic Headaches Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety

Depression Euphoria / Salivation
Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
Other: Unconsciousness

Neuro-muscular Paralysis Loss of strength Speech disorder
Others:

Ocular X Ocular irritation Visual Alteration Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory Couth: dry/ Dysnea Wheeze
productive Other:
Pulmonary edema

Skin X Dermatitis Ulcers Sweatiness with blood
X Other: generalized
itchiness

Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Annex 31

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer

Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gayep)rsgteen

Arbex Rocket Glifonox (Crystal) Agrochem. of Cauca
Glyfoagri (Disagri) Tunda
Socar (Agrevo) Candela (Agroser)

ç Crossout (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance : 1,000 meters
No

When did the events occur? __6 September___________________________________
How many times a day did the aircraft pass over? ______________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

Sources of water X Crops
X People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects

Juan Camilo 34 Same
José (18) Luz (13) None became ill
Jimmi (5) Tania (25) None became ill

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS:

Annex 31Annex 31 Annex 31

Date of report: __12 Sept 2002_____
Organization: ___________________
C.I.: __________________________

Signature:______SIGNED_________
CLINICAL TOXICOLOGICAL SHEET

First names: __Alicia _______________ Last Names: __Calero _______________

Age: ___16____ Nationality: Ecuadorian Parish/Village: ___ _Chone 2 ________
County/Municipality: _________________ Province/Department: __________ _

Occupation: ___Farmer_______________ Place of work: Owned Farm_ __ ___

Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation

Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness

Other:
Neuro-muscular Paralysis Loss of strength Speech disorder
X Others: Bone pain

Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other: Bone Pain
Respiratory
Cough: dry / Dysnea Wheeze
productive Other:
Pulmonary edema
Skin
Dermatitis Ulcers Sweatiness with
Other: blood
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)Annex 31

Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer

(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gaypgrsgteen

Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)

Glyfoagri (Disagri) Tunda (coffee
fertilizers)
Socar (Agrevo)

Crossout (Agroser)
Candela (Agroser)

Please specify other pesticides that you use _________________________________

Have you noticed any changes, disorders or effects on your health? ________________
When did you start noticing them? __________________________________________
What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?

X Yes Please specify at what distance 3,000 meters
No
When did the events occur? __6 September____________________________________

How many times a day did the aircraft pass over? __________________________▯____
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________
X Sources of water X Crops

X People Houses
Others: (please specify) ___________________________________________________

Other affected parties

Other family members affected:
Name Age Effects
Martin 18 All became ill, + leg pain.

Manuel 19
Edgar 28
Simon 50

Margarita 50
Libio 25

Any pregnant women?

Name Age Effects

Other effects

Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: Edgar continues to have headaches and pain in his bonesAnnex 31Annex 31 Annex 31

Date of report: __12 Sept 2002______
Organization: ____________________
C.I.: ___________________________

Signature:___________SIGNED______

CLINICAL TOXICOLOGICAL SHEET

First names: __María _______________ Last Names: __ILBAY _____________

Age: ___34 ____ Nationality: __Ecuadorian___ Parish/Village: ____Chone 2________

County/Municipality: _________________Province/Department: ______________ _

Occupation: ___Farmer___________________ Place of work: _Rented Farm______

Signs and symptoms
GaAstrointestinal X dominal Pain Diarrhea Nausea
Vomiting
Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
X Other: Sore Throat
Cardio-circulatory
Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic Headaches Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety

Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock

temp/esp Unconsciousness
Other:
Neuro-muscular Paralysis Loss of strength Speech disorder

Others: Bone pain
Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

X Other: Bone Pain
Respiratory Dry cough/ Dysnea Wheeze
productive Other:
Pulmonary edema

Skin X Dermatitis Ulcers Sweatiness with
Other: generalized blood
itchiness

Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and

Observations:
What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which oneAnnex 31

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gaypgrsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance 1,000 meters
No

When did the events occur? __6 September___________________________________
How many times a day did the aircraft pass over? _11___________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

Sources of water X Crops
X People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects

Jenny Sanchez 8 The same + irritation of eyes
Lorenzo Sanchez 35 The same + irritation of eyes
Junior Sanchez 18 The same + irritation of eyes

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: They are still affected.Annex 31Annex 31 Annex 31

Date of report: __12 Sept 2002_______
Organization: ____________________
C.I.: ___________________________

Signature: ___________SIGNED_____
CLINICAL TOXICOLOGICAL SHEET

First names: __Obdulia _______________ Last Names: __PINEDA _____________

Age: ___57 ____ Nationality: Ecuadorian Parish/Village: _____ _Chone 2________
County/Municipality: _________________ Province/Depar tment: ____ ___________

Occupation: ___Farmer_______________ Place of work: _______________________

Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other: Sore Throat
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
X Insomnia Drowsiness Anxiety
X Stress Euphoria / Salivation
Depression
Sweatiness Arreflexia
Vertigo/dizziness X Paresthesia Shock
Disorientation Unconsciousness
temp/esp

Other:
Neuro-muscular Paralysis Loss of strength Speech disorder
Others:

Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
X Other: Bone Pain

Respiratory Cough: dry / Dysnea Wheeze
productive Other:
Pulmonary edema

Skin Dermatitis Ulcers Sweatiness with blood
Other:
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)

Annex 31

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla (Gaypgrsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)

What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance 1,000 meters
No

When did the events occur? __6 September___________________________________
How many times a day did the aircraft pass over? _ ____________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:

Name Age Effects
Arturo Calevo 57 Pain in the lungs, irritation of eyes,
numbness of the arms
Julio Calevo 3 Stomach ache, and appetite

Lorena Calevo 13 Skin rash
Eduardo Calevo 4
Diana Calevo 11

Hernan Calevo 23
Francisco Calevo 22

Any pregnant women?

Name Age Effects

Other effects

Animal Type Effects Plant Type Effects
Quantity Quantity
#

OBSERVATIONS:

Annex 31Annex 31 Annex 31

Date of report: __12 Sept 2002_______
Organization: ____________________
C.I.: ___________________________

Signature:___________SIGNED_________
CLINICAL TOXICOLOGICAL SHEET

First names: __Rosa Margarita________ Last Names: Jimenez__________________

Age: ___51 _ Nationality: Ecuadorian___ Parish/Village:Chone 2- 30 Families______
County/Municipality: _________________ Province/Departm ent: _______________

Occupation: ___Farmer________________ Place of work: _Owned Farm___________

Signs and symptoms

Gastrointestinal X Abdominal Pain X Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

X Other: Sore Throat
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:
Neurological- mental X Chronic Headache
Behav. Alteration Epileptic Convulsion
X Insomnia Drowsiness Anxiety
X Stress Euphoria / Salivation
Depression Sweatiness
Arreflexia
Vertigo/dizziness Paresthesia Shock
Disorientation Unconsciousness
temp/esp

Other:
Neuro-muscular Paralysis X Loss of strength Speech disorder
Others:

Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory Cough: dry / X Dysnea Wheeze
productive X Other: Out of breath
Pulmonary edema

Skin Dermatitis Ulcers Sweatiness with blood
Other:
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and Fatigue, Chills and “it seems like there is a gas in the air”
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIAAnnex 31

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)

Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)

Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance 500 to 1,000 meters
No

When did the events occur? __6 September____________________________________
How many times a day did the aircraft pass over? _ 6 aircraft fumigated over 4 hours _
How many days were the fumigations conducted? We heard them all week_____ ___
What could you see was affected by the fumigations? _____________________________

X Sources of water X Crops
X People X Houses
Others: (please specify) ___________________________________________________
Other affected parties

Other family members affected:
Name Age Effects
Simon Merino 56 All feel the same in the house

Manuel Merino 20 All feel the same in the house
Martin Merino 18 All feel the same in the house s
Libio Merino 23 All feel the same in the house
Edgar Merino 26 All feel the same in the house +

bone pain and chills

Any pregnant women?

Name Age Effects
Verónica Calero (6 months 16
pregnant)

Other effects
Animal Type Effects Plants Type Effects
Quantity Quantity

OBSERVATIONS:Annex 31Annex 31 Annex 31

Date of report: __12 Sept 2002_______________
Organization: _____________________________
C.I.: ____________________________________

Signature:___________SIGNED______________

CLINICAL TOXICOLOGICAL SHEET

First names: __Ma ____________ Last Names: Encarnación_____

Age: ___53 Nationality: Ecuadorian Parish/Village: Chone 2 _______

County/Municipality: _________________ Province/Depar tment: ________ _______

Occupation: ___Farmer________________ Place of work: ____Owned Farm________

Signs and symptoms
Gastrointestinal X Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis

Burning Rectal incontinence
Other: Sore Throat
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias

…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression
Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation X Paresthesia Shock
temp/esp Unconsciousness

X Other: Loss of
appetite
Neuro-muscular Paralysis X Loss of strength Speech disorder
X Others: Bodily pain

Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory X Cough: dry / Dysnea Wheeze
productive Other: Out of breath
Pulmonary edema

Skin X Dermatitis Ulcers Sweatiness with blood
X Other: generalized
itchiness
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:Annex 31

Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gaypgrsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)

Glyfoagri (Disagri) Tunda (coffee fertilizers)
Socar (Agrevo)
ç Crossout (Agroser)

Candela (Agroser)
Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________

No
When did the events occur? __ ___________________________________
How many times a day did the aircraft pass over? ______________________________
How many days were the fumigations conducted? ______________

What could you see was affected by the fumigations? _____________________________
Sources of water Crops
People Houses

Others: (please specify) ___________________________________________________
Other affected parties
Other family members affected:
Name Age Effects

Hortensio Calero 63 Same
Rosa Calero 15 Generalized Itchiness
Juan Calero 13 COUGH. RINORREA, HEADACHES.

Leonidas Calero 15 Same as above
Hugo Calero 16 Same as above
Jacinto Calero 19 Cough

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS:Annex 31Annex 31 Annex 31

*Blood Sample
Date of report: ____13 November 2002_______________
Organization: _____A.E.___________________________

C.I.: ___________________________________________
Signature: __[SIGNED]____________________________

CLINICAL TOXICOLOGICAL SHEET

First names: _BEATRIZ ESPERANZA___ Last Names: _URBINA _____________
Age: __71_____ Nationality: _Ecuadorian Parish/Village: GENERAL FARFÁN__ _
County/Municipality: LAGO AGRIO____ Province/Department:_SUCUMBIOS___

Occupation: _FARMER_______________ Place of work: _STA MARIANITA_____

Signs and symptoms
Gastrointestinal Abdominal Pain X Diarrhea X Nausea

X Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
Other:

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor
Hypertension Hypotension

Cyanosis
Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion

X Insomnia X Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation X Paresthesia
Shock
temp/esp Unconsciousness
Other:
Neuro-muscular Paralysis X Loss of strength Speech disorder

X Others: Swelling of
Legs up until Knees
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory X Cough: dry / Dysnea Wheeze
productive
Other:
Pulmonary edema
Skin X Dermatitis X Ulcers Sweatiness with
Other: blood

Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological
Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and She is diabetic, controlled by diet. The fumigations caused her to suffer an
Observations: ulcer that does not cease and that she has just recently been able to control.

What activity do you perform in your farm:

X Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one: NO Annex 31

ECUADOR COLOMBIA
Roundup Clyphosate Roundup

Glyphosate Mon 0139 Rocket
Glyphonox Candela Super Rocky

Pillaround Caldeon Faena

Glyphosate 480 g/l Glyalca Patrol

Glyphogan Glyphosan Squadron
Ranger Banox Ranger
Rodeo Super Source

Atila Rondo Batalla Galep)rsgteen
Arbex Rocket Glifonox (Crystal)

Glyfoagri (Disagri)

Socar (Agrevo)

Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance 1 KM
No
When did the events occur? ___September ___________________________________

How many times a day did the aircraft pass over? _3 times, 3 aircraft_______________
How many days were the fumigations conducted? ___8 days _____________________
What could you see was affected by the fumigations? _____________________________
Crops XwatSerofurces X

s e s u o H X e l p o e P X
Others: (please specify) ___________________________________________________
Other affected parties
Other family members Age Effects

affected:
Cintia Rivera 7 Skin rash and stye

Any pregnant women?

Name Age Effects

Other effects
Animal Type EffectsPlant Type Effects

Quantity Quantity
50 ChickDeenasd#
5 CatsDed#

2 PigsDed#
2 Dogsead

OBSERVATIONS:Annex 31Annex 31 Annex 31

* Blood sample
Date of report: 13 November 2002_ ______________________

Organization: ________________________________________
C.I.: _______________________________________________

Signature:_________________[Signed]___________________
CLINICAL TOXICOLOGICAL SHEET
First names: Italo Ramón_______________Last Names: Bene Cosa________________

Age: 24_______ Nationality: Ecuadorian _ Parish/Village: __General Farfán _______
County/Municipality: Lago Agrio_______ Provin ce/Department: Sucumbios________

Occupation: Farmer__________________▯_Place of work: Santa Marianita __________
Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:

Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation

Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
X Other: Fever

Neuro-muscular Paralysis X Loss of strength Speech disorder
Others:
Ocular X Ocular irritation Visual Alteration X Teariness / Myosis

Mydriasis X Ocular pain
Other:
Respiratory X Cough: dry / Dysnea Wheeze

productive Other:
Pulmonary edema
Skin X Dermatitis Ulcers Sweatiness with blood
X Other: Intense Pain

Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological
Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and Working on the farm, his face started itching and he had a headache. He then
Observations: began to have rashes in his face and body. His face became flushed, hot and
swollen. That day they were spraying and he was 600 meters this side of the
border. He reports that he had washed his face due to the heat, with water from

the river Charapa. He was treated at the Red Cross, where he was injected which
calmed the symptoms, but then ...
What activity do you perform in your farm:

X Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Annex 31

Do you use any of the following pesticides on your lands? Please indicate which one
They do not use any chemicals
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Galyp)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)

Glyfoagri (Disagri) Tunda (coffee fertilizers)
Socar (Agrevo)
ç Crossout (Agroser)

Candela (Agroser)
Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________

When did you start noticing them? __________________________________________
What do you think the cause is? ____________________________________________

Have fumigations been conducted in your area?
X Yes Please specify at what distance 600 meters

No
When did the events occur? Towards the end of September______________________ _

How many times a day did the aircraft pass over? 6 airplanes and 4 helicopt_____
How many days were the fumigations conducted? 1 day _________________________

What could you see was affected by the fumigations? ___________________________
X Sources of water X Crops
X People Houses

Others: (please specify) ___________________________________________________
Other affected parties

Other family members affected:
Name Age Effects
José Alfonso Bone 53 Skin lesions: Vitoligo that started

after the Colombian fumigations

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

# 2 Calves Dead In the folder
# PiDseIand the folder
# 8 Chickens Dead In the folder

# 1 Rooster Dead In the folder

OBSERVATIONS:

Annex 31Annex 31 Annex 31

Date of report: 12 September 2002 ______________
Organization: _______________________________
C.I.: ______________________________________

Signature:_____________[Signed] _____________
CLINICAL TOXICOLOGICAL SHEET

First names: Zacarías ________________ Last Names: García Chavez_____ _______

Age:70_______ Nationality: Colombian__ Parish/Village: Puerto Nuevo ___________
County/Municipality: Sucumbios ________ Province/Department: Putumayo_________

Occupation: Farmer ___________________ Place of work: temporary worker _______

Signs and symptoms

GaAstrointestinal X dominal Pain X Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:

Neurological- mental X Chronic headaches Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation

Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
X Other: General

discomfort
Neuro-muscular Paralysis X Loss of strength Speech disorder
Others:

Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory Cough: dry/ Dysnea Wheeze
productive Other:
Pulmonary edema

Skin X Dermatitis Ulcers Sweatiness with blood
X Other: General
Pruritus
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and Itchiness, Fever
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:Annex 31

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Galyp)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Please specify other plaguicides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________
When did you start noticing them? __________________________________________

What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance 700 meters
No

When did the events occur? 17 August______________________________________
How many times a day did the aircraft pass over? 5 days (4-5 planes) _________
How many days were the fumigations conducted? 3-4 times ____________________
What could you see was affected by the fumigations? ___________________________

X Sources of water Crops
X People X Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects
Elizabeth Andrade 64 All exactly the same

Elizabeth Garcia 17 All exactly the same
Elisa Garcia 24 All exactly the same
Norberto Garcia 42 All exactly the same

Daniel Garcia 7 All exactly the same
Jairo Garcia 6 All exactly the same
Ever Garcia 2 1/2 All exactly the same

Any pregnant women?
Name Age Effects

Other effects

Animal Type EffectsPlant Type Effects
Quantity Quantity

OBSERVATIONS: Itchiness persistsAnnex 31Annex 31 Annex 31

Date of report: 12 September 2002 ____________
Organization: _____________________________

C.I.: ____________________________________
Signature:_______________[Signed] __________
CLINICAL TOXICOLOGICAL SHEET

First names: Edith ____________ Last Names: Garcia ______________________

Age: 22_______ Nationality: Colombian_ Parish/Village: Puerto Nuevo ___________

County/Municipality: Pacayacu _________ Province/Department: Sucumbios _______

Occupation: Farmer___________________Place of work: Day laborer _____________

Signs and symptoms
Gastrointestinal Abdominal Pain X Diarrhea X Nausea
X Vomiting Intestinal Spasms Hyperistalsis

Burning Rectal incontinence
Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias

…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic headaches Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression
Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness

X Other: Bone pain
Neuro-muscular Paralysis Loss of strength Speech disorder
Others:

Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory X Cough: dry / Dysnea Wheeze
productive Other:
Pulmonary edema
Skin X Dermatitis
Ulcers Sweatiness with blood
X Other: General
Pruritus
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and Fatigue and despair, as intoxicated
Observations: Diarrhea having drunk the fumigated water

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:Annex 31

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gaypr)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance: Directly above and at 700 meters.
No

X Sources of water Crops
X People X Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects
Salomon Ruiz 82 The same

Mario 47
R N 4 months General boils all over the skin. Skin
infection. Impetigo on legs, feet and

left shoulder

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects

Quantity Quantity

OBSERVATIONS: They were at home when the spraying occurred and the child began having skin problems.

Before the spraying occurred, the boy was chubby and had no skin problems.Annex 31Annex 31 Annex 31

* Blood sample
Date of report: 12 September 2002 _______________

Organization: ________________________________
C.I.: _______________________________________
Signature: [Signed]___________________________

CLINICAL TOXICOLOGICAL SHEET
First names: Jose Felix_______________ Last Names: Guerga Rodriguez _________

Age: 27_______ Nationality: __________ Parish/Village: _____________________
County/Municipality: Puerto Nuevo______ Province/Department: _______________
Occupation: Farmer___________________Place of work: Puerto Nuevo____________

Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
Other:

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression
Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis Loss of strength Speech disorder
Others:
Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory Cough dry / Dysnea Wheeze
productive Other:
Pulmonary edema

Skin X Dermatitis Ulcers Sweatiness with
X Other: Intense skin blood
boils
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and He was sprayed directly while he was in the crops. * A blood sample was
Observations: taken.

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)Annex 31

Pillaround Caldeon Faena Panzer

(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)

Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla (Bayer) Glyphosate Agrogen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)
Socar (Agrevo)

ç Crossout (Agroser)
Candela (Agroser)

Please specify other pesticides that you use __________________________________

Have you noticed any changes, disorders oreffects on your health? ________________
When did you start noticing them? __________________________________________
What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance Directly above
No

When did the events occur? 7 September______________________________________
How many times a day did the aircraft pass over? ______________________________
How many days were the fumigations conducted? ______________________________
What could have been affected by the fumigations? _____________________________
Sources of water Crops

People Houses
Others: (please specify) _______________________________________________▯____

Other affected parties

Other family members affected:
Alone
Name Age Effects
Alone

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS:Annex 31Annex 31 Annex 31

Date of report: 12 September 2002 _______________________
Organization: ________________________________________

C.I.: _______________________________________________
Signature:________________[Signed] ____________________

CLINICAL TOXICOLOGICAL SHEET

First names: José Hilberto______________ Last Names: Reyes Ramirez ____________

Age: 38_______ Nationality: Ecuadorian__Parish/Village: Puerto Nuevo___ ________

County/Municipality: Pacayacu_________ Provin ce/Department: Sucumbios________

Occupation: _________________________Place of work: __________ ____________

Signs and symptoms
Gastrointestinal Abdominal Pain X Diarrhea Nausea
X Vomiting Intestinal Spasms
Hyperistalsis
Burning Rectal incontinence
Other:
Cardio-circulatory
Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety

Depression Euphoria / Salivation
Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock

temp/esp Unconsciousness
Other:
Neuro-muscular Paralysis Loss of strength Speech disorder

Others:
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory X Cough: dry / Dysnea Wheeze
productive Other:

Pulmonary edema
Skin X Dermatitis Ulcers Sweatiness with blood
X Other: General
Pruritus

Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and Fever, Chills

Observations:

What activity do you perform in your farm:

X Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Annex 31

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Galyp)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance 400 meters
No

When did the events occur? 17 August_______________________________________
How many times a day did the aircraft pass over? A lot (3-4) 5 planes__________
How many days were the fumigations conducted? 5 days_________________________
What could you see was affected by the fumigations? ___________________________

Sources of water Crops
People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects

Caroliall 11 the same
Luz Dori 6 All the same
Nidia Cristina 33 All the same

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: The itching is still present. A coffee-like powder was poured on everything at a distance of 1500
meters. It's not the chemical, it is something else. The last day they poured the "gocterra" and then went away. (It
was around the 21st). After 5 days, the rain began.

Annex 31Annex 31 Annex 31

P* Blood sample
Date of report: 12 September 2002 _______________________

Organization: ________________________________________
C.I.: _______________________________________________
Signature:_________________[Signed]___________________

CLINICAL TOXICOLOGICAL SHEET
First names: Lucelia__________________ LastNa mes: Torres García _____________

Age: 53_______ Nationality: Colombian__ Parish/Village: Puerto Nuevo ___________
County/Municipality: _________________ Province/Department: _____ __________
Occupation: Farmer__________________▯_Place of work: ______________________

Signs and symptoms

Gastrointestinal X Abdominal Pain Diarrhea X Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
Other:

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation

X Vertigo/dizziness Sweatiness Arreflexia
Disorientation X Paresthesia Shock
temp/esp Unconsciousness
Other:
Neuro-muscular
Paralysis Loss of strength Speech disorder
Others:
Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory X Cough: dry / X Dysnea Wheeze
productive Other:
Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with

X Other: General blood
Pruritus
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:
Other and

Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)

Annex 31

Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla (Bayer) Glyphosate Agrogen

Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Please specify other pesticides that you use __________________________________
Have you noticed any changes, disorders oreffects on your health? ________________
When did you start noticing them? __________________________________________
What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?

X Yes Please specify at what distance 200 meters
No
When did the events occur? 1 month _____________________________________
How many times a day did the aircraft pass over? __________________▯___________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? ___________________________

Sources of water X Crops
X People Houses
Others: (please specify) ____________________________________________▯_______

Other affected parties
Other family members affected: They all suffered the same
effects
Name Age Effects
Alberto 52 Fever, Strong Dysnea

Jovana 7 Fever, Strong Dysnea
Soraida 32 Fever, Strong Dysnea
Marcelo 22 Fever, Strong Dysnea
R N Andrea 10 Fever, Strong Dysnea

Any pregnant women?
Name Age Effects

Other effects

Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: Received “rain water” from the planes.

Annex 31Annex 31 Annex 31

* Blood sample
Date of report: 12 September 2002 __________________

Organization: ___________________________________
C.I.: ___________________________________________

Signature :___________[Signed]____________________
CLINICAL TOXICOLOGICAL SHEET

First names: Sabina__________________ Last Names: Encarnación ______________

Age: 37_______ Nationality: Ecuadorian_ Parish/Village:Playera Oriental(18 families)

County/Municipality: Cayasu ___________ Province/Department: Sucumbios _______

Occupation: Farmer___________________Place of work: Owned farm_____________

Signs and symptoms

GaAstrointestinal X dominal Pain X Diarrhea Nausea
X Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:

Neurological- mental X Chronic Headaches Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation

Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness

Other:
Neuro-muscular Paralysis X Loss of strength Speech disorder
X Others: Bone ache
Ocular X Ocular irritation X Teariness / Myosis
Visual Alteration
Mydriasis Ocular pain
Other:
Respiratory X Dry cough/
Dysnea Wheeze
productive X Other: Burning
Pulmonary edema throat
Skin X Dermatitis Ulcers Sweatiness with

X Other: Rashes all blood
over the body
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and She only has the headaches remaining, and a lack of appetite
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which oneAnnex 31

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer

(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Galyp)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)

Glyfoagri (Disagri) Tunda (coffee
fertilizers)
Socar (Agrevo)

ç Crossout (Agroser)
Candela (Agroser)
Please specify other pesticides that you use __________________________________▯

Have you noticed any changes, disorders or effects on your health? ________________
When did you start noticing them? __________________________________________

What do you think the cause is? ____________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance 200 meters

No
When did the events occur? 2-7 September and Friday 6September ________

How many times a day did the aircraft pass over? 3 hours of fumigating (5-6 planes)___
How many days were the fumigations conducted? 2-7 September and Friday 6September

What could you see was affected by the fumigations? ___________________________
Sources of water Crops

People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects

Marcelino Riveda 38 All the same, no variation.
Nelson Riveda 15 All the same, no variation.
Mauricio Riveda 13 All the same, no variation.

Nelly Riveda 9 All the same, no variation.
Glenda Riveda 8 All the same, no variation.
Any pregnant women?
Name Age Effects

Other effects

Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: They do not use chemicals.Annex 31Annex 31 Annex 31

Date of report: __12 Sept 2002_______
Organization: ____________________
C.I.: ___________________________

Signature:___________SIGNED_____
CLINICAL TOXICOLOGICAL SHEET
First names: Santa Angelina__________ Last Names: Calero ___________________
Age: 40 _______ Nationality: Ecuadorian_ Parish/Village: La Playera Orienta_____

County/Municipality: _________________ Provin ce/Department: _______________
Occupation: Farmer ___________________ Place of work: Owned farm_____________

Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:

Neurological- mental X Chronic headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation

X Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:

Neuro-muscular Paralysis X Loss of strength Speech disorder
X Others: Bone pain
Ocular X Ocular irritation X Visual Alteration X Teariness / Myosis

Mydriasis Ocular pain
Other:
Respiratory Dry cough/ productive Dysnea Wheeze

Pulmonary edema Other:
Skin Dermatitis Ulcers Sweatiness with blood
X Other: General

Pruritus
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic
Other:
Other and Fatigue
Observations:
What activity do you perform in your farm:

Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)Annex 31

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gayep)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)

Glyfoagri (Disagri) Tunda (coffee fertilizers)
Socar (Agrevo)
ç Crossout (Agroser)

Candela (Agroser)
Please specify other pesticides that you use __________________________________▯
Have you noticed any changes, disorders or effects on your health? ________________

When did you start noticing them? __________________________________________
What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance 200 meters

No
When did the events occur? 6 September_____________________________________
How many times a day did the aircraft pass over? 10 to 2 in the afternoon_/ 6 planes, 5 helicopters
______________________________

How many days were the fumigations conducted? 2 days_________________________
What could you see was affected by the fumigations? _____________________________
X Sources of water X Crops
X People Houses

Others: (please specify) ___________________________________________________
Other affected parties
Other family members affected:

Name Age Effects
Hernan Calero 22 All had the same symptoms
Maria Calero 17 All had the same symptoms

Vicente Encarnación 15 All had the same symptoms
Pedro 10 All had the same symptoms
Juan 5 All had the same symptoms
Rosa Encarnación 21 All had the same symptoms

Roberto Encarnación 6 months All had the same symptoms. Plus
Vomiting.
Jacinto Encarnación 5 All had the same symptoms. Vomiting;

rashes, Boils; and later
Segundo Encarnación 27 All had the same symptoms
Any pregnant women?

Name Age Effects

Other effects
Animal Type Effects Plant Type Effect

Quantity Quantity

OBSERVATIONS:Annex 31Annex 31 Annex 31

Date of report: __12 Sept 2002_______
Organization: ____________________
C.I.: ___________________________

Signature:_______SIGNED_________
CLINICAL TOXICOLOGICAL SHEET

First names: Lucía _____________ Last Names: Calero ______________________

Age: 40_______ Nationality: Ecuadorian_ Parish/Villgla:erraiental _________
County/Municipality: _________________ Provin ce/Department: _______________

Occupation: Farmer __________________▯_ Place of work: ______________________

Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
X Burning Rectal incontinence

Other:
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor

Hypertension Hypotension
Cyanosis
Other:

Neurological- mental X Chronic headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety
Depression Euphoria / Salivation
X Vertigo/dizziness
Sweatiness Arreflexia
Disorientation X Paresthesia Shock
temp/esp (Hands)
Other: Unconsciousness

Neuro-muscular Paralysis Loss of strength Speech disorder
Others:
Ocular
Ocular irritation Visual Alteration Teariness / Myosis
Mydriasis Ocular pain
Other:
Respiratory X Cough: dry /
Dysnea Wheeze
productive Other:
Pulmonary edema
Skin Dermatitis Ulcers Sweatiness with blood

Other:
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and Observations: Fatigue, Burning throat
What activity do you perform in your farm:

Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one

ECUADOR COLOMBIA
Roundup Clyphosate Roundup Glyphosan (Agroser)

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)Annex 31

Glyphonox Candela Super Rocky Stelar (Dow)
Pillaround Caldeon Faena Panzer (Invechemical)

Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)

Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla Gayep)rsgteen

Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)
Socar (Agrevo)

ç Crossout (Agroser)
Candela (Agroser)
Please specify other pesticides that you use __________________________________▯

Have you noticed any changes, disorders or effects on your health? ________________
When did you start noticing them? __________________________________________
What do you think the cause is?____________________________________________
Have fumigations been conducted in your area?

X Yes Please specify at what distance 2000 m – 3000 m
No
When did the events occur? 6 September______________________________________

How many times a day did the aircraft pass over?_____________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? _____________________________
X Sources of water X Crops

X People Houses
Others: (please specify) ___________________________________________________
Other affected parties
Other family members affected:

Name Age Effects
María Encarnación 15 Fungus
Angel 50 Healthy, they don't have anything.

Francisco 20 Healthy, they don't have anything.
Victor Antonio 14 Healthy, they don't have anything.
Maria 15 Healthy, they don't have anything.

Silvio 10 Healthy, they don't have anything.
Olger 7 weeks Healthy, they don't have anything.
Elsa 1 Healthy, they don't have anything.

Any pregnant women?
Name Age Effects

Other effects

Animal Quantity Type Effects Plant Type Effects
Quantity

OBSERVATIONS: “We are poor people working and we don't feel anything”Annex 31Annex 31 Annex 31

Date of report: 12 September 2002_______________________
Organization: _______________________________________

C.I.: ______________________________________________
Signature:____________[Signed] _______________________

CLINICAL TOXICOLOGICAL SHEET

First names: Rosa Elvira _____________ Last Names: Mañay___________________
Age: 26_______ Nationality: Ecuadorian_ Parish/Village: Playera Oriental_________
County/Municipality: _________________ Province/Department: _______________
Occupation: Farmer___________________Place of work: Owned farm_____________

Signs and symptoms
Gastrointestinal Abdominal Pain Diarrhea Nausea
X Vomiting
Intestinal Spasms Hyperistalisis
Burning Rectal incontinence
Other:
Cardio-circulatory
Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
Insomnia Drowsiness Anxiety

Depression Euphoria / Salivation
X Vertigo/dizziness Sweatiness Arreflexia
Disorientation X Paresthesia Shock

temp/esp Unconsciousness
Other:
Neuro-muscular Paralysis X Loss of strength Speech disorder

Others:
Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory X Cough: dry / X Dysnea Wheeze
productive Other:
Pulmonary edema

Skin X Dermatitis Ulcers Sweatiness with
X Other: Pruritus blood
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia

Hyperglycemia Other:
Hepatic Other:
Other and
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:
Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)Annex 31

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)

Glyphogan Glyphosan Squadron Faena (Proficol)
Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Galyp)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of

Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Have fumigations been conducted in your area?
X Yes Please specify at what distance 400 meters
No
When did the events occur? 6 September_____________________________________

X People Houses
Others: (please specify) ___________________________________________________
Other affected parties

Other family members affected:
Name Age Effects
Angel Naigua 37 Chronic Headaches, Dizziness

Micay Edison 3 Fever
Miriam 7 Healthy
Wilmer 5 Healthy
Juan Pasa 6 Healthy

Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects

Quantity Quantity

OBSERVATIONS:Annex 31Annex 31 Annex 31

Date of report: 12 September 2002_______________________
Organization: ________________________________________

C.I.: _______________________________________________
Signature: _______________[Signed]_____________________

CLINICAL TOXICOLOGICAL SHEET

First names: Carmen _________________ Last Names: Pineda___________________

Age: 33_______ Nationality: Ecuadorian_ Parish/Village: Playera Oriental_________

County/Municipality: _________________ Province/Department: _______________
Occupation:Farmer ___________________ Place of work: ______________________

Signs and symptoms

Gastrointestinal Abdominal Pain Diarrhea Nausea
Vomiting Intestinal Spasms Hyperistalsis
Burning Rectal incontinence
Other:

Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias
…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic Headache Behav. Alteration Epileptic Convulsion
X Insomnia (stress) Drowsiness X Anxiety
Depression Euphoria / Salivation

Vertigo/dizziness Sweatiness Arreflexia
Disorientation Paresthesia Shock
temp/esp Unconsciousness
Other:
Neuro-muscular
Paralysis Loss of strength Speech disorder
Others:
Ocular Ocular irritation Visual Alteration Teariness / Myosis
Mydriasis Ocular pain

Other:
Respiratory Dry cough/ Dysnea Wheeze
productive Other:
Pulmonary edema

Skin Dermatitis Ulcers Sweatiness with
Other: blood
Renal / Urinary Albuminuria Anury Hematuria
Urinary incontinence Other:

Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:
Hepatic Other:

Other and
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?

Aviculture What type of birds? Aquaculture What type of fish?
Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)
Glyphosate Mon 0139 Rocket Glyphosol (Coljap)

Annex 31

Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer
(Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)
Atila Rondo Batalla (Bayer) Glyphosate Agrogen

Arbex Rocket Glifonox (Crystal) Agrochemicals of
Cauca)
Glyfoagri (Disagri) Tunda (coffee
fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)
Candela (Agroser)

Please specify other pesticides that you use __________________________________
Have you noticed any changes, disorders oreffects on your health? ________________
When did you start noticing them? __________________________________________
What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?

X Yes Please specify at what distance 1000m to 2000m
No
When did the events occur? 6 September_____________________________________
How many times a day did the aircraft pass over?____________________________
How many days were the fumigations conducted? ______________________________
What could you see was affected by the fumigations? ___________________________

X Sources of water X Crops
X People Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects
Sergio 16 Healthy
Patricio 14 Dizziness

Angelitaealt12
JaqueliHealthy
Diana 7 Healthy
Freddy 4 Healthy

RobinsoSnkin 2 boils
Any pregnant women?
Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS:

Annex 31Annex 31 Annex 31

* Blood sample
Date of report: 12 September 2002______________________
Organization: _______________________________________

C.I.: ______________________________________________
Signature:________[Signed] ___________________________

CLINICAL TOXICOLOGICAL SHEET

First names: Benilde_________________ Last Names: Pineda___________________
Age: 40_______ Nationality: __________ Parish/Village: Palma Seca (18 Families) _
County/Municipality: _________________ Province/Department: _______________
Occupation: Farmer___________________Place of work: Owned farm_____________

Signs and symptoms
Gastrointestinal Abdominal Pain X Diarrhea Nausea
X Vomiting Intestinal Spasms
Hyperistalsis
X Burning Rectal incontinence
X Other: Sore throat
Cardio-circulatory Bradycardia Tachycardia: …….. Arrhythmias

…….. ppm ppm Pallor
Hypertension Hypotension
Cyanosis

Other:
Neurological- mental X Chronic headache Behav. Alteration Epileptic Convulsion
X Insomnia (Stress) Drowsiness Anxiety

Ocular X Ocular irritation Visual Alteration X Teariness / Myosis
Mydriasis Ocular pain
Other:

Respiratory Dry cough/ productive Dysnea Wheeze
Pulmonary edema Other:
Skin X Dermatitis Ulcers Sweatiness with blood

X Other: Boils with
general pruritus
Renal / Urinary Albuminuria Anury Hematuria

Urinary incontinence Other:
Hematological Leukocytosis Thrombocytopenia Anemia
Hyperglycemia Other:

Hepatic Other:
Other and Discomfort when urinating
Observations:

What activity do you perform in your farm:
Agricultural What type of crops? Livestock What type of cattle?
Aviculture What type of birds? Aquaculture What type of fish?

Other Please specify:

Do you use any of the following pesticides on your lands? Please indicate which one
ECUADOR COLOMBIA

Roundup Clyphosate Roundup Glyphosan (Agroser)Annex 31

Glyphosate Mon 0139 Rocket Glyphosol (Coljap)
Glyphonox Candela Super Rocky Stelar (Dow)

Pillaround Caldeon Faena Panzer (Invechemical)
Glyphosate 480 g/l Glyalca Patrol Glyphogan (Magan)
Glyphogan Glyphosan Squadron Faena (Proficol)

Ranger Banox Ranger Regio (Quimor)
Rodeo Super Source Sunup (Sundat)

Atila Rondo Batalla Gaypr)rsgteen
Arbex Rocket Glifonox (Crystal) Agrochemicals of Cauca)
Glyfoagri (Disagri) Tunda (coffee fertilizers)

Socar (Agrevo)
ç Crossout (Agroser)

What do you think the cause is?___________________________________________
Have fumigations been conducted in your area?
X Yes Please specify at what distance 200 meters
No

When did the events occur? 6 September and all of the prior week______________
How many times a day did the aircraft pass over? 10 in one afternoon.
6 planes and 5 helicopters. ___________________________
How many days were the fumigations conducted? ______________________________

What could you see was affected by the fumigations? ___________________________
X Sources of water X Crops
X People X Houses
Others: (please specify) ___________________________________________________

Other affected parties
Other family members affected:
Name Age Effects

Angel Salazar 50 They all have the same symptoms
Victor Salazar 24 They all have the same symptoms
Olger Salazar 18 They all have the same symptoms

Angel Salazar 15 They all have the same symptoms
Susana Salazar 12 They all have the same symptoms
Veronica 10 They all have the same symptoms
Carlos 8 They all have the same symptoms

Marcelino 5 They all have the same symptoms
Marco 3 They all have the same symptoms
Any pregnant women?

Name Age Effects

Other effects
Animal Type Effects Plant Type Effects
Quantity Quantity

OBSERVATIONS: Treatment is only water based. There is no money.Annex 31Annex 31 Annex 32

Association ofAmerican Jurists, et al., ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Fumigations in Putumayo Department under Plan Colombia” (Oct. 2002) Annex 32

Report on Verification Mission,

"Impacts in Ecuador of fumigations in Putumayo as part of Plan Colombia,▯"

October 2002

We thank the Joint Armed Forces Command of Ecuador for enabling us to move about Ecuador's
border territory, as well as local authorities of the communities we visited in Colombia for

facilitating our access to the places we examined.

Prepared by:

Acción Ecológica Adolfo Maldonado
Lucía Gallardo
ALDHU Talía Alvarez

Asociación Americana de Juristas (AAJ) Galo Chiriboga
Raúl Moscoso
CEDHU Elsy Monge
Ecociencia Fernando Rodríguez

INREDH Patricio Benalcázar
Laboratorio de Suelos (LABSU) José Luis Pazmiño
RAPAL Ecuador David Reyes
SERPAJ Jhonny Jiménez
Acción Creativa Juan Pablo Barragán

With support from:

American Friends Services Committee Lina CahuasquíAnnex 32

0. EXECUTIVE SUMMARY

The constant concern about the hazards of spraying the herbicide glyphosate and its effects
on Ecuador's border territory has brought together various organizations to conduct a
verification mission aimed at determining how it has affect ed the population in Colombia

and Ecuador living alongside the San Miguel River, in the sectors of Aguas Blancas, La
Pedregosa, Nueva Granada, and Los Cristales, in Colombia, and Chone 2 and Puerto Nuevo,
in Ecuador (see map). The results of this verification are as follows:

x The new fumigation period to elimi nate illicit crops that started on July 28 in the
Department of Putumayo, in Colombia, and on the border zone, in Ecuador, has

triggered severe impacts on the population's health and on crops, animals, and ways
of living.
x The work done by the mult idisciplinary and in ter-institutional team in the border

zone and the calculation of distances with GPS from the points where there were
fumigations up to the San Miguel Ri ver have made it possible to corroborate that no
attention has been paid to the requests made by Ecuador's Ministry of Foreign Affairs

or by the Ecuadorian Ambassador to Colombia, regarding the establishment of a
buffer zone for the fumigations, preventing fumigati on within a perimeter of 8 to 10
km from the San Miguel River (binational limit) inside Colombian territory.

x Regarding this, it was confirmed that fumigations are affecting Ecuadorian territory.
In some cases, spraying extends up to the bank of the San Miguel River, and planes
are infringing upon Ecuador's air space. In addition, because of the air currents

chemicals drift into Ecuador and severely damage the way of life of Ecuador's border
population.
x Medical tests have established a relationship between the symptomatology described

by the population and that stemming from the inactivation of cholinesterase, which is
the effect coming from organophosphates. The central nervous system is
overstimulated, which causes the following: headache, dizziness, nausea, vomiting,

stomachache, and weakness. To these symptoms must be added others that are
specific to Roundup Ultra, characterized by intense eye and skin irritation.
x Blood samples drawn from inhabitants of the border zone call attention to the risk

involved in fumigating a popu lation that has chromosome fr agility levels that are 17
times higher than normal. Thi s situation poses questions about the incidence of
recent fumigation in increasing chromosome aberrations that have been detected or,

if they are due to other factors that have not as yet been determined, about the
negative influence on a population that is already at risk. This situation is extremely
sensitive, because chromosome vulnerability implies that cancer, mutations,
malformations, and abortions may appear more easily.

x Inhabitants of the area reported having seen two different types of fumigations (one
involving a whitish liquid and the other brown dust), and this has led us to analyze
plant samples to discount the possibility that the biological agent Fusarium

oxysporum is being used despite prohibitions curre ntly in force. Should this be the
case, it would mean that biological agents identified as biological weapons were
being used, which would eviden tly have severe internatio nal implications. Although

constraints for the technical analysis for detection prevented us from determining the
species, the genus Fusarium was found in all of the samples that were taken,
whether roots, leaves, or soil.

x The damage to both subsistence and cash crops, whether entire crops or a very large
share of them, has affected this region's population, bringing it to the brink of a food
crisis and forced displacement. These peoples are not receiving any health support

or compensations to offset their losses.

- 1 - Annex 32

1. BACKGROUND

Aerial fumigations, as part of the Plan Colombia, officially started in the Department of
Putumayo on December 22, 2000. By January 28, 2001, about 29,000 hectares had been

fumigation; during 2001, according to the U.S. Embassy in Colombia, 94,000 hectares were
fumigated. The U.S. Administration is planning to expand the fumigation area to 150,000
hectares during 2002 and to 200,000 hectares during 2003, which will heighten socio-

environmental and health impacts on the people in the border area.

1.a The chemical formula used

Although it has been impossible to confirm the chemical mix that is being sprayed,

according to the technical parameters of the National Narcotic Drugs Council for the aerial
fumigation of illicit crops, [1] following amounts are being applied in the mix:

Plan load 300 – 450 gallons 1137 – 1705 liters

Effective unloading (of Roundup Ultra, with 43.9% 23.4 liters/hectare 10.3 L/ha of
of glyphosate) glyphosate
(30 tp 50
2)
drops/cm
Deposit of mix 0.4 – 0.740 – 70 liters/ha
3 2
mm /cm

The mix used contains: 44% of Roundup Ultra, whereas the label for use in the United
States for Roundup Ultra permits concentrations of between 1.6% and 7.7% for the
majority of uses and a maximum concentration of 29%. The U.S. label indicates that, under

most conditions, the aerial application should not be over 1 liter (quart) per acre of the
formulated product. In Colombi a, the rate is equivale nt to almost 4.5 times this amount.
[2]

If it is estimated that a 300-gallon plane (1,137 liters) drops 40 L/ha of mix, with an
effective drop of 23.4 L/ha of Roundup Ultra; thi s drop is equivalent to 10.3 L/ha of

glyphosate in the form of IPA salts. This means that the glyphosate is applied in
concentrations of 26%, not at the 1% rate recommended in the United States for land
applications, with protection gear and aimed at farm weeds. To this situation must be

added the fact that Cosmo Flux 411F multiplies the biological action of glyphosate fourfold.

1.b Impacts of fumigations in Colombia in 2001

The fumigations in Colombia have spark ed a major debate, in view of the many reports of
damage to licit crops and especially to the health of the population living in the areas
adjacent to the areas of fumigation.

In the Municipality of Valle del Guamuez, which lies on the Ecuadorian border, a
consolidated report on the impacts stemming from fumigations was issued: 1,551 persons

had their health affected, 3,174 hectares of licit crops were destroyed, and 55,045 animals
were affected or died, distributed across 44 precincts.

This report, prepared by th e Police Station, [3]focuses on damage to crops and animals,
broken down as follows:

- 2 -Annex 32

Damage to crops and animals in the Valle del Guamuez (Colombia)- 2001

Crops Has % Animals N° %
Grasses 1,308 41.0% Fish 34,150 62.0%
Banana 229 7.2% Hens 8,632 15.7%

Corn 188 5.9% Cows 1,038 1.9%
Yucca 163 5.1% Guinea pigs 980 1.8%

Fruits 138 4.3% Ducks 365 0.6%
Others 1,148 36.0% Horses 155 0.3%

Others 9,725 17.7%

Total 3,174 100% 55,045

1.c Impacts on Ecuador of the fumigations in Colombia in 2001

In October 2000, the press reported the first impacts on health in Mataje (Esmeraldas)
associated to the fumigations in the Department of Nariño, with 44 persons falling sick after
the first fumigation (El Comercio, Quito, October 22, 2000).

In January, El Comercio reported on the impacts in the province of Sucumbíos stemming
from fumigations in December (El Comercio, Quito, January 12, 2001).

Months later, 188 campesinos from different communities filed a report with the Office of

the Human Rights Ombudsman in Lago Agrio, which was transferred to the Ombudsman in
Quito, where its processing came to a standstill. The report set forth the claims of the
campesinos of the parishes of General Farfán, Nueva Loja, Pacayacu, Dureno, and Tarapoa.

The claim noted the following losses:

Damage to crops and animals in Sucumbíos (Ecuador)– 2001
Crops No. of hectares PercentageAnimals No. of dead Percentage
damaged animals

Coffee 1,215 47.4% Fish 6,355 53.7%
Grasses 785 30.6% Hens 4,681 39.6%

Bananas182 7.1% Pigs 315 2.7%
Rice 103 4.0% Cows 188 1.6%

Corn 87 3.4% Guinea 117 1.0%
pigs

Cacao 79 3.1% Ducks 73 0.6%
Fruit 53 2.0% Dogs 49 0.4%

Yucca 51 2.0% Horses 43 0.4%
Total 2,560 Total 11,828

Despite huge loses for subsistence and household ming, no government official has

traveled to the areas to check, in the field, the damage reported in this claim.

1.d Impacts of fumigations in Colombia in 2002

The second phase of fumigations started on July 28, 2002. Despite the short time that has

elapsed, reports are piling up in the following institutions:

- 3 - Annex 32

- The Municipality of Puerto Asís [4] reported that, since August 11, 2002, it has been
fumigated, and this has “affected more than 2,254 families (from 58 precincts), some of
whom are beneficiaries of the Manual Eradication Program."

- A report from Agroamazonía [5] dated September 23, 2002 describes how palm
heart plantations have been affected in the Valle del Guamuez, Puerto Asís, and Orito. Out

of 32 palm heart growers covering 54.8 hectares of sown crops, damage has been reported
in 43.8 hectares, which accounts for 80% of farmed area.

- The Office of the Human Rights Ombudsman for the Colombian People [6] asserted
the following on October 9: “3.9.5 In addition to the previous reports, in the department
there have been complaints about harm to the health of the inhabitants, presumably caused

by fumigations. The report of the Deputy Department of Public Health of the Department of
Putumayo on the impacts of fumigations in various municipalities of this territorial institution
informed that “(…) 4,883 (85%) of the 5,929 persons referred to in the complaint forms and

interrogated by the officials of the Technical Assistance Unit of Orito and coming from
46.4% of the 282 precincts comprising the three municipalities, spoke about symptoms that
can be attributed to the fumigation. The symptoms were associated to respiratory problems

29% (964), gastrointestinal problems 26.4% (876), skin problems 15.8% (524),
psychological problems 1.9% (64), fever 15.5% (516), general indisposition 5.4% (179),
dizziness 4.1% (32) and others 0.9% (29)”. This report adds that, in the Hospital de la

Hormiga, there was “a statistically significant rise in episod es of fever, diarrhea, abdominal
pain, acute respiratory infections, and skin infections.” The report concludes: “An
epidemiological surveillance system for acute intoxication caused by pesticides and a

nutritional surveillance system are required.” [7]

1.e Impacts on Ecuador of fumigations in Colombia 2002

The “Santa Marianita” Association of Campesinos [8] of the Parish of General Farfán,
comprised of 27 members, reported that after the recent fumigations in Colombia they have

suffered from “skin and eye diseases, respiratory infections, fevers like those resulting from
malaria, but tests turn out to be negative. Females animals have problems when giving
birth and we have noted a fall in the production of corn, cacao, rice, bananas, to such an

extent that we cannot get our investment back.”

The Chone 2, Puerto Nuevo and La Playera communities on the Tetetes road, in the parishes

of Pacayacu, reported damage to their crops and animals. Likewise, they spoke of severe
damage and health problems in the border community of Cohembí.

1.f Government actions

On July 2, 2001, the Ecuadorian Government requested the Colombian Government:

- “that the applications of chemical formulas used on its territory take place at least
10 kilometers away from the Ecuadorian border, so as to prevent the dispersion
caused by winds from reaching Ecuadorian territory and producing toxic effects on persons
and plant life.” [9]

The Ministry of Foreign Affairs of Colombia replied to this request [10] on July 14, 2001 and

stated:

- 4 -Annex 32

To check the distance of the fumigations made on the border, the verification mission
entered Colombian territory and, with GPS equipment, proceeded to identify the zones

fumigated in Colombia and their distance from the San Miguel River. It obtained the
following results:

GPS points and distance to the border from Colombia
Place PointElevation18° NorthUTM Distance to Ecuador

La Pedregosa (Col)7 248 m 0317989 00296016 m
Nueva Granada (Col)8 266 m 0318341 00310951,412 m

Nueva Granada (Col)9 275 m 0318295 00313181,635 m
La Pedregosa (Col)10 270 m 0318088 0030359706 m

Los Cristales (Col)14 270 m 0333976 00375158,285 m
Aguas Blancas (Col) 15 276 m 0332612 00354596,981 m

Aguas Blancas (Col) 16 292 m 0332616 00354636,986 m

- In Pedrera (point 7), six meters from the San Miguel River, signs of crops destroyed
by fumigation, possibly from wind drifts, were found.

- At point 10, severe impacts were observed, since the area was sprayed directly at
706 meters away from the border.

- In the precinct of Nueva Granada (points 8 and 9), at 1,600 meters from the border,
eye-witness accounts by the population reported that, between August 30 and September

6, planes fumigated directly onto their houses. As proof of this, on the football field, located
in the middle of the town, there were large rings of chlorosis. The schoolteacher stated that
her 35 students fell ill with headaches, sore and runny eyes, and fever.

- In Aguas Blancas (points 15 and 16), at a distance of 7 to 8 km from the border,
there were clear signs that all kinds of crops had been destroyed.

- In Los Cristales (point 14), there were eye-witness accounts of airplanes flying over

the houses and spraying them on August 1 and 18, 2002, without any considerat▯ howor
it would be affecting homes, food crops, and water sources.

GPS points and distance to border from Ecuador
Place PointElevation18° NorthUTM Distance to Colombia

Frente La Pedregosa12 257 m 0318397 0028996186 m
Puerto Nuevo 17 276 m 0327151 002783813 m

Chone – 2 18 260 m 0331636 00256461,236 m
Chone – 2 19 255 m 0331462 0026463584 m

Playera Oriental 20 263 m 0330474 0027463526 m
Playera Oriental 21 257 m 0329942 0027781743 m

Playera Oriental 22 253 m 0330071 0027817622 m
Playera Oriental 23 277 m 0330098 0027662702 m

Playera Oriental 24 256 m 0331031 0027533Reference river 0 m
Chone - 2 26 261 m 0331624 00256281,257 m

- In La Playera Oriental and Chone 2 (between 1 and 1,257 m from the bank of the San

Miguel River, evident damage from the fumigation of September 6, 2002 on the Colombian

- 7 - Annex 32

side of the banks of the San Miguel River was observed. At all points, soil and plant
samples were taken, health data on the population were gathered, and eye-witness
accounts on social impacts were recorded.

- In front of La Pedregosa (point 12, at 186 m inside Ecuadorian territory) damage was
found in the banana plantations and other crops, which showed signs of chlorosis

(yellowing), as a result of th e proximity of fumigations in Colombia. The accounts pointed
out that these impacts stemmed from the fumigations done on the Colombian side between
August 30 and September 6, 2002.

What was observed by the verification mission, the results from the samples that were
taken, the eye-witness accounts that were recorded, and the interviews that were

conducted enable us to assert that the fumigations in Colombia are taking place less than
10 kilometers away from the Ecuadorian border. On the basis of the above, it can be
concluded that, at the time of the mission, the request made by the Ministry of Foreign

Affairs and the Ecuadorian Ambassador to Colombia had not been met.

In some cases, there were fumigations as close as the banks of the San Miguel River. The
drifting of sprayed products has caused severe harm to the Ecuadorian border population.

3.b Objective 2: Check the reports of impacts of fumigations on the health of the
inhabitants of the zone and corroborate a report on the death of five persons in
Cohembí (Ecuador).

In June 2001, Ecological Action published a Research Report [16] on the impacts of
fumigations of January 2001 on the border of Sucumbíos. The report showed that:

- 100% of the population living in the border zone had been intoxicated by the

Roundup Ultra fumigations over a 5 km strip, and 89% of the population, if the strip is
extended to 10 km.

- Three months after the fumigations, the population up to 5 km kept showing
symptoms of chronic intoxication with signs of neurological impairment, skin problems and
conjunctivitis.

- There is a direct linkage, in terms of time, between fumigations and the appearance
of disease.

- There is a direct linkage between the distance of site that was fumigated and

symptomatology. The symptomatology in the population declines in proportion to the
distance of the fumigated site.

- The possibility of new fumigations on the population that is already suffering from
symptoms of chronic intoxication may cause an impact of incalculable consequences for
their lives.

- The population, which has suffered from the impacts of the fumigation, has become
frantic. They do not benefit from any economic support, compensation, or suitable care for

their health, which has been undermined by a fumigation program that renders them
invisible.

- 8 -Annex 32

can be appreciated in the chart on the “Imp acts of fumigations on health in Ecuador and
Colombia”.

From the clinical histories that were examined, we can infer the following:

- A large majority of the population after the fumigati ons has felt adverse impacts
such as headaches and eye irritation and tearfulness. In the Colombian communities that
were more intensely fumigated, it was common to find digestive problems, with dizziness,

abdominal pains, vomiting and nausea, diarrhea, fatigue and loss of energy. This
symptomatology is typical of organophosphates, which is the group that Roundup Ultra
belongs to. The presence of fever in Colombi a is also significantly more widespread than in
Ecuador.

- Another group of symptoms appears because of skin diseases. A great deal of

pruritus (itchiness) is associated to different diseases, ranging from dermatitis
(inflammation) to the appearance of pimples for different reasons. The irritation caused by
the chemical is evident in this symptomatology, which also occurs in the eyes, which has a

higher incidence on the Ecuadorian side than the digestive symptoms.

- Some campesinos indicated that there are two types of fumigations: one involving

a whitish or transparent fluid and the other a dark color, after which there is a powerful
"itch."

- The psychological impact that the fumigations exert on the campesinos of Ecuador is
different from that on Colombia. Whereas the former display stress which leads to
insomnia, the Colombians are depressive as a result of the complex reality that the

inhabitants of this zone have to live through, heightened by the impacts of fumigations.

The symptomatology described by the population is consistent with what is produced as a
result of the inactivation of cholinesterase, which is the impact of the organ ophosphates.
The central nervous system is overstimulated, whi ch in turn causes: headaches, dizziness,
nausea, vomiting, stomachaches, and fatigue. This symptomatology is accompanied by the

specific components of this product, which produces acute eye and skin irritation.

- 10 - Annex 33

Letter from Victor Velasco Tapia, Government of Sucumbios, Republic of Ecuador, to Lourdes
Luque, Minister of Health, Republic of Ecuador (Oct. 2002) Annex 33

Republic of Ecuador
Governorship of Sucumbíos

Proceeding No. 511-GS-2002
Nueva Loja, 16 October 2002

Eng. Lourdes Luque

MINISTER OF ENVIRONMENT
In your Offices

Dear Madam:

With the present letter, I allow myself to express my cordial greetings to you and to wish you

much success in your job functions. At the same time, I would like to take advantage of this
opportunity to notify you of the following:

In light of the various complaints, in writing as well as through various means of
communication, with respect to damages caused to peasants in the bordering area with

Colombia, especially from peasants who are located on the riverbanks of Río San Miguel, in the
province of Sucumbíos, due to anti-narcotic fumigations conducted in neighboring Colombia as

part of Plan Colombia, for this reason I personally visited the area on 15 October of this year at
these locations and was able to confirm that as a result of the fumigations the orito, plantain,
banana, corn, and yucca crops, and, in general, all the different agricultural crops that are basis of

sustenance for peasants in the area were burnt. Similarly, the fish in pools, which comprise part
of the sector’s industry, have died. Barnyard fowl has also been affected. As a result, negative

effects exist which harm the inhabitants of the Border with Colombia. I was also able to confirm
the effects caused to individuals’ health, such as itchiness, boils o▯n their bodies, skin affectations
and respiratory problems.

For your heightened awareness, I hereby enclose copies of the complaint filed by Mr. Víctor

Mestanza with the Ombudsman of the Village of Sucumbíos.

Annex 33

I allow myself to inform you of this situation, awaiting your instructions, which will be fulfilled
by this Governorship.

Sincerely,
GOD, COUNTRY AND FREEDOM

Signed

Mr. Víctor Velasco Tapia
Governorship of Sucumbíos

Annex 33Annex 33 Annex 34

Memorandum from Peter P. Trent, INL/RM/ASD, PSC Bogota, to Grant Harden,
INL/RM/ASD, COR (4 July 1996)Annex 34Annex 34 Annex 35

Memorandum from David Johnson, INL/C/ASD, to Grant Harden, INL/C/ASD (1▯4 Nov. 1996)Annex 35Annex 35 Annex 36

Memorandum from David Johnson INL/C/ASD to Grant Harden, INL/C/ASD (12 ▯Dec. 1996)Annex 36Annex 36 Annex 37

Memorandum from Tim Doty, COR, INL/RM/AS to Dyncorp, PSD Manager (28 May 1997)Annex 37Annex 37Annex 37Annex 37 Annex 38

Memorandum from Tim Doty, COR, INL/RM/AD, to Dyncorp, PSD Manager (Aug. 1997)Annex 38Annex 38 Annex 39

Memorandum from Stephen H. Harris, INL/RM/AD, to Dyncorp (21 June 1999)▯Annex 39Annex 39 Annex 40

Aviation Resource Management Inspection ofAir Wing Colombia Site (23 March 2000)Annex 40Annex 40Annex 40Annex 40Annex 40Annex 40Annex 40Annex 40 Annex 41

U.S. Department ofAgriculture,Agricultural Research Service, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-
sion April-May 2001 (7 July 2001)Annex 41Annex 41Annex 41Annex 41Annex 41Annex 41 Annex 42

United States Congressional Research Service, Andean Regional Initiative (ARI): FY2002 Assis-
tance for Colombia and Neighbors (14 Dec. 2001) Annex 42
Order Code RL31016

CRS Report for Congress

Received through the CRS Web

Andean Regional Initiative (ARI):

FY2002 Assistance for Colombia and Neighbors

Updated December 14, 2001

K. Larry Storrs

Specialist in Latin American Affairs
Foreign Affairs, Defense, and Trade Division

Nina M. Serafino
Specialist in International Security Affairs
Foreign Affairs, Defense, and Trade Division

Congressional Research Servi•eThe Library of CongressAnnex 42

CRS-25

Appendix D. Controversy over Spray Eradication

Efforts in Southern Colombia

The following discussion of the controversy over spray eradication (i.e., fumigation)

of illegal coca crops in southern Colombia was prepared in response to the controversy
over this effort in southern Colombia. This short synopsis of available information on the
effects of fumigation of coca crops in Colombia is only meant to provide a summary of
various claims; it is not a judgment on their validity.

In its U.S.-supported coca eradication program, the government of Colombia
sprays coca crops from aircraft with a mixture of the herbicide glyphosate,
manufactured bytheU.S. companyMonsanto and marketed as “Roundup,” and two
additives or “adjuvants.” 15 According to the State Department (in its report of

January 23, 2001, submitted to Congress consistent with the provisions of the
Statement of Managers accompanying Title III, Chapter 2 of the Emergency
Supplemental Appropriations Act. P.L. 106-246, which provided funding for Plan
Colombia), the Environmental Protection Agency (EPA) has foundthat “the use of

glyphosate, as labeled for use in theU.S., is acceptable provided that the regulatory
controls required by the EPA – the labeled instructions – arefollowed.” The State
Department also claims that the ingredients in the two additives (COSMO▯ FLUX-
16
411F, a surfactant, andCOSMO-iN-D, ananti-foaming additive ), both produced in
Colombia, are on anEPA listof acceptable chemicals“for use on food crops when
the labelinstructions are followed.” Thisreport states an EPA review of “adequate
scientificstudies” showsthat when properlyused glyphosate“will notcause adverse

effects in humans,” and“does not causerisks of concernfor birthdefects, mutagenic
effects,neurotoxiceffects,reproductiveproblems,orcancer.”Itdoes,however,state
that“splashes”ofglyphosate“cancausetransientirritationtoskinandeyes,”although
at the same level of irritation as baby shampoo according to one cited study. F▯or its

conclusionthat there are “no grounds to suggest concern forhuman health” from the
spray mixture usedin Colombia, theState Department cited a recent studypublished
inRegulatory Toxicology and Pharmacology. 17

15The activeingredient inRoundup isisopropylamine saltof N-(phosphonomethyl) glycine,
commonly known asglyphosate, Chemical Abstract Registration Number38641-94-0, EPA
Registration Number000524-004445. “Adjuvant” is a term for an ingredient that facilitates

or modifies the action of the principal ingredient.
16COSMO FLUX-411F, according to theState Departmentreport, “increases theherbicide

penetration through the waxy layer of the coca leaf byallowing ore of the spray to stick to the
plant. When more of the spray solution sticks to the plant, the herbicide becom▯es more
effective which means it can be applied in smaller doses.” COSMO-IN-▯D “is used to
minimize thefoamcreated by themixture-circulating pumpinside theaircraft spray hopper”
in order to avoid the creation ofa vacuum within the spray pressure pumpwhich couldshut

off the spray system during flight.
17Gary M. Williams, Robert Kroes, and Ian C. Munro. Safety Evaluation and Risk
Assessment of the HerbicideRoundup and its Active Ingredient, Glyphosate, for Humans.

Regulatory Toxicology and Pharmacology. Vol. 31, No. 2, April 2000. Available through
[http://www.ciponline.org/colombia/12301.htm]from a hyperlink at the bottom of the text of
theState Department’sJanuary 23, 2001 report. This publication isthe official journal of the
(continued...) Annex 42

CRS-26

Since spraying began in December 2000 in Colombia’s Putumayo province▯
(where it is now indefinitelysuspended), however, there have beenmanyallegations

that the spray mixture has caused extensive harm to humans, other crops, and
livestock. The illhealth effects onthousands of children andadults most commonly
reported in the areas of Putumayo fumigation includefever, eye and gastrointestinal
irritation, and skin and bronchial irritation and infections. There have also been

allegations of increased incidence of brain damage in children in these areas since
fumigation was started. In addition, criticsclaim,many crops other than coca have
been sprayed, depriving peasants of food crops and other sources of income, and
livestock reportedly have suffered ill effects, including hair loss in cattle from
moderate exposure, abortion among pregnantcows (possiblydue, one source notes,

from stampedes caused by the noise of overhead helicopters) and the death offowl
from sprayingordrinkingcontaminatedwater. (The effects on livestock and fowl are
taken from the “Counter-Fact Sheet” of February 9, 2001, prepared by Acción
Andina, a non-governmental organization, and posted at

[http://usfumigation.org/Literature/FactSheets/ContraDoS/AA-IPS-RAPAL%2▯0F
act%20Sheet%20-English.htm].) Supporters of aerial fumigation, howev▯er, state
that negative health andenvironmental effects can beattributed to drug producers
themselves, whom, theyclaim, also use Roundup to suppress weeds around coca
bushes, and who pollute Colombian rivers with chemicals used in processing and

refining coca into cocaine in their drug labs.

Some U.S. officialsassert that many of thecomplaints come fromthose with an
interest incontinuingcoca production, especially as aerialspraying ofcoca crops has

taken place for many years in other areas of Colombia without the outcry▯ that the
spraying in Putumayo has produced. However, according to a Washington Post
article of January 7, 2001, about the spraying in Putumayo: “Until recently,▯ spraying
focusedalmostentirelyonremoteindustrial-sizedcocaandpoppyplantations....Now

the planes are targeting more populous farmingareas...where coca...is often grown
side by side withcorn, yucca, pineapple and livestock. Often it shares a plot next to
the farmer’s tin-roofed shack.” (“Aerial Attack Killing More than Coca,” by▯ Scott
Wilson.) Regarding crop damage, the Post reporter stated that his “inspection of
fields in the area suggested that food crops have been hit at least as hard as coc▯a.”

Critics haveattributed food crop damage to the side-by-side plantings of legal and
illegalcropsinPutumayo,butalsochargethat sprayplanesflyhigher than normal for
crop dusting operations elsewhere in order to avoid ground fire, and under
unacceptablewindconditions,thusleadingto thedispersionofspraybeyondintended
18
targets.

17
(...continued)
International Society of Regulatory Toxicology and Pharmacology.
18
One website’s ([http://www.farmsource.com]) discussion of the use▯ of Roundup (accessed
throughtheMonsantowebsite,[http://www.monsanto.com]) notes that Roundup should “only
be applied fromaircraft whenthepotentialfordrifttoadjacentsensitiveareas (e.g.residential
areas, bodies of water, knownhabitat forthreatened or endangered species,non-target crops)
is minimal (e.g. when the wind is blowing away from sensitive areas).” It gives detailed
instructions for aerial applications,including the maintenanceof an appropriate buffer zone
from “any desirablevegetationorcrops,”i.e.,normallysome100feet,but 500feetifthewind

(continued...)Annex 42

CRS-27

Some analysts,however,havenoted that complaints of illeffectsto humans and
animals may not be entirely inconsistent with StateDepartment assertionsof safety

under controlled circumstances as thehealth and environmental effects could vary
depending on the exact formulation ofthe spray mix, themanner of itsapplication,
and the conditions underwhich it wasused. Some critics have argued that Roundup
is not being applied in a manner consistent with U.S. usages and with the

manufacturer’s recommendations, and that not all issues related to ingredients used
in the mixture applied in Colombia have been explored.

• The World Wildlife Fund, in an October 30, 2000 statement,
“Comments onGlyphosate,”states that existing studies“may not be

adequateto assesstheimpactsresultingfromPlanColombia’sactual
useofglyphosate(aerialapplications,productformulation, frequency
and rate of application,etc.), especially giventhe soils,topography,
climatic conditions (temperature, rainfall, etc.) plant and animal

species found in Colombia.” (Online at:
[http://www.ciponline.org/colombia/103001.htm]).

• In a February 9, 2001 statement calling for the end of aerial
eradication, representatives of three non-governmental organizations

claimedthat “there is evidence that herbicide concentrations much
higher than ones recommended are being applied in Colombia” and
that “there are no toxicological studies...regarding the effects of
mixing the Cosmoflux-4111F surfactant with pesticides.” 19 The

statementalsonotedthatRoundupUltra (whichopponentssayisthe
actual variety of Roundup being used in Colombia, although the
State Department report cited above does not refer to either trade
name) “contains other ingredients besides glyphosate and the two

adjuvants.” The World Wildlife Fund, in the October 2000 statement
cited above, foundthat studies on the effects ofRoundup “focus on
the pesticide active ingredient alone, not the combination ofinert
ingredientsactuallyapplied,therebygivinganincompleteassessment
of the toxic threat,” and asserted that “the inert ingredients mixed

with the Roundup to increase its effectiveness can be as, or more,
toxictohumans,wildlifeandfoodwebsthanthepesticideitself.”The
Monsantowebsitestatesthatthe“newingredients”inRoundupUltra
are on an EPA approved list (#4B), but the specific “new”

ingredients are not named.

• An analysis by agronomist Elsa Nivia, identified as associated with
thenon-governmentalReddeAcciónenPlaguicidasyAlternativas-
América Latina, RAP-AL. PAN-Colombia (Pesticide Action

Network), claims that the aerial fumigation of illegal crops in

18(...continued)

is blowing up to five miles an hour, and more at greater windspeeds.
19Forced Aerial Eradication of Illicit Crops: A Reply to the State Department , signed by

Ricardo Vargas M. of Acción AndinaColombia, Martin Jelsma of Transnational Institute,
TNI, and Elsa Nivia of RAPALMIRA. Posted at [http://www.usfumigation.org▯]. Annex 42

CRS-28

Colombia with Roundup is “very different from the recommended
agricultural use in the UnitedStates,” citing theconcentration as 26
times greater than that recommended, with negative effects
intensified bythe use of Cosmoflux 411F. Even though the authors
ofthereport citedbytheState Departmenthadfoundglyphosateand
Roundup to be at most mildly toxic, Ms. Nivia’s conclusion from

their discussion of the effects of accidental and occupational
exposures to higher concentrations, and of the doses that proved
lethal inpeople attemptingsuicide, isthat higher thanrecommended
concentrations or applications could help to explain thesevere ill
effects reported in the fumigated areas. (See Las fumigaciones
aéreas sobre cultivos ilícitos si son peligrosas - Algunas

aproximaciones, by Elsa Nivia. Paper given at a conference on The
Wars in Colombia: Drugs, Guns and Oil, held atthe University of
California at Davis, May 17-19, 2001, accessible through
[http://www.usfumigation.org].)

The State Department isfunding astudy, withdesign assistance supplied by the

Center for Disease Control (CDC) and the EPA, of the health effects of▯ aerial
eradication in Putumayo Department. Results are anticipated by late 200▯1.Annex 42 Annex 43

Memorandum from Stephen H. Harris, COR, DoS/INL/A, to
Dyncorp, PSD Manager (Dec. 2001)Annex 43Annex 43 Annex 44

Memorandum from Lowell E. Neese, SAA, DoS/INL/A(Bogota), to Stephen H. Harris,
COR, DoS/INL/A(13 Mar. 2002)Annex 44Annex 44 Annex 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Substances, Report on Issues Related to the Aerial Eradication of Illicit Coca in Colombia,
Response from EPA Assistant Administrator Johnson to Secretary of State (19Aug. 2002) Annex 45

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

BUREAU FOR INTERNATIONAL NARCOTICS AND LAW ENFORCEMENT AFFAIRS
September 2002

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

OFFICE OF

PREVENTION, PESTICIDES AND
TOXIC SUBSTANCES

The Honorable Colin L. Powell, Secretary
U.S. Department of State

Washington, D.C. 20520

Dear Secretary Powell:

We are enclosing our consultation review as per your request to Environmental Protection Agency (EPA) Administrator Christine Todd
Whitman, for consultation on the potential human health and environmental effects of the aerial coca eradication program in Colombia,

pursuant to the Foreign Operations, Export Financing, and Related Programs Appropriation Act (P.L 107-115). Administrator Whitman has
asked me to respond on her behalf because my office has primary oversight responsibility for pesticides, and the nature of this

consultation centers around the technical aspects of chemicals used in the aerial fumigation of coca.

The Foreign Operations, Export Financing, and Related Programs Appropriation Act specifically requires the Department of State to
consult with EPA on whether (1) "aerial coca fumigation is being carried out in accordance with regulatory controls required by the EPA as
labeled for use in the United States .... ; and (2) whether the chemicals used in the aerial fumigation of coca, in the manner in which

they are being applied, do not pose unreasonable risks or adverse effects to humans or the environment..."

As part of our consultation review, we considered the full range of available scientific information from laboratory and field testing and
incident reports. Our consultation review evaluates the potential impact to human health and the environment from the eradication

program, based on information provided by Department of State, on the pesticide used (glyphosate), inert ingredients, and the
application rates and methods, In addition, Agency scientists reviewed scientific studies on glyphosate, conducted a limited literature

search for human health incidents related to glyphosate use, and examined information on glyphosate use conditions in the United
States. We also considered information provided by non-governmental organizations, concerning effects reportedly connected to coca

eradication in Colombia.

Glyphosate is widely used in the United States. Based upon EPA reviews of domestic use conditions, glyphosate appears to be one of the
most safely-used pesticides in the U.S. EPA's regulatory authority for domestic pesticide use allows significant controls through pesticide
labeling and compliance and enforcement infrastructure implemented with the states and other federal agencies. Recognizing that these

mechanisms are not available to EPA in Colombia, the Agency has evaluated potential risks associated with the coca eradication program
and identified areas where Department of State should pay particular attention to minimize the potential for adverse effects.

I trust that the attached document will assist you in preparing your response to Congress. Please let me know if you have additional

questions concerning this consultation review.

Sincerely,

Stephen L. Johnson
Assistant Administrator

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 Contents

Executive Summary

1. Section 1. Description of Glyphosate Use in the U.S. For Comparison To Use in Colombia For Coca EradicationAnnex 45

1. Use of Glyphosate in the United States Agricultural Use Sites
2. Non-Agricultural Uses Including Forestry

3. Properties of Glyphosate
4. Formulation of Glyphosate

5. Glyphosate Used With Surfactant For Foliar Absorption

2. 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.

1. Hazard Identification
2. Dose Response Assessment

3. Exposure Assessment

3. Section 3. Review of Glyphosate Incident Reports With Special Reference To the Aerial Spraying Program in Colombia

1. California Data-1982 Through 2000

2. Literature Review
3. A Study of Health Complaints Related To Aerial Eradication in Colombia

4. Conclusions

4. Section 4. Ecological Risk Assessment For the Use of Glyphosate Herbicide As Part of the U.S. Supported Aerial Eradication Program
of Coca in Colombia

1. Background

2. Ecological Risk Assessment
3. Potential Spray Drift of Glyphosate

4. Environmental Fate And Transport Assessment of Glyphosate

5. Risk Characterization

EXECUTIVE SUMMARY

CONSULTATION REVIEW OF THE USE OF PESTICIDE FOR COCA ERADICATION IN COLOMBIA

BACKGROUND

The Department of State currently 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 illicit crops (coca and poppy). In accordance
with a provision in its 2002 Appropriations Bill, Department of State has consulted with the U.S. Environmental Protection Agency (EPA)

on two specific questions: that fumigation is "...being carried out in accordance with regulatory controls required by the Environmental
Protection Agency as labeled for use in the United States" and, that the chemicals being used "...in the manner they are being applied, do

not pose unreasonable risks or adverse effects to humans or the environment."

FINDINGS

EPA has reviewed information provided by Department of State concerning the pesticide formulation applied (combination of the pesticide
active ingredient, glyphosate, and inert ingredients), and application rates and methods. According to the most recent figures (1999 sales

and usage) glyphosate is the most widely used conventional pesticide in the United States. The Agency evaluates all pesticides used in
the U.S. to determine whether they meet the U.S. safety standard of no unreasonable adverse effects. Consequently, EPA has a

significant amount of information about glyphosate from a health and environmental standpoint because of our reviews of use conditions

in the U.S. In the U.S., the Agency can assure significant controls on use and potential health and environmental impacts through the
pesticide label, and through a state infrastructure which governs label compliance to address issues such as drift and worker and

bystander exposure.

Based on a comparison of the glyphosate use pattern in Colombia, as described by the Department of State, and use in the U.S., EPA
determined that the most equivalent U.S. uses of glyphosate would be forestry or rights-of-way. The glyphosate product which has been

identified to us as used in Colombia is registered in both the U.S. and Colombia, although it has never been marketed in the U.S. The
Agency found application rates described as used in Colombia to be within the parameters listed on U.S. labels. The addition of a spray

adjuvant (to facilitate the formulation adhering to and penetrating the coca plant) is also in keeping with U.S. practice. While the specific
spray adjuvant product identified as that used in Colombia is not sold in the U.S., similar substances and products are commonly used.

Most U.S. labels for forestry and right-of-way use of glyphosate suggest application by helicopter. Since application in Colombia is done
by fixed-wing aircraft, it is likely conducted at a higher speed and from a greater altitude, than would be typical in the U.S. Department

of State has assured the Agency that mixers/loaders and applicators of the glyphosate formulation receive training comparable to U.S.
label requirements for glyphosate products including the use of personal protective equipment such as gloves and goggles.

As for potential human health effects of the coca eradication program, there are no risks of concern for glyphosate, per se, from dermal
or inhalation routes of exposure, since toxicity is very low. There is concern for acute eye toxicity due to an inert ingredient in the

glyphosate formulated product used to treat coca. The potential eye effects are related to an inert ingredient, not the glyphosate itself, Annex 45

and greatest potential for exposure is expected for workers mixing and loading the concentrated glyphosate product. The components of
the spray adjuvant, Cosmoflux 411F, are substances with low oral and dermal toxicity that have been approved for use in/on food by EPA

and the Food and Drug Administration. There are no expected toxicological effects of concern for acute (short-term) or chronic (long-
term) dietary exposure through food and water from the coca eradication program. Incident data from Colombia involving humans,

livestock, mammals and birds, are based on potential exposure to glyphosate from fumigation of poppy fields, which may differ from use
of and exposure to glyphosate from coca eradication, so conclusions should be made cautiously.

Relative to the potential environmental effects of the spraying program based on U.S. data, phytotoxicity to non-target plants outside of

the application zone would be expected, since glyphosate is a broad spectrum herbicide. Given the application method described by
Department of State, offsite exposure from spray drift is probable, as it would be under similar uses in the U.S. This proposed use of

glyphosate itself does not appear to pose a significant direct risk to terrestrial or aquatic animals, although secondary adverse effects
from the temporary loss of habitat in the spray area could occur. EPA would not expect any risk to birds and mammals, including

livestock, based on dietary exposure to the active ingredient glyphosate. Anticipated effects to animals are based on an extrapolation of
data related to North American species. Glyphosate does not have a high potential to leach to ground water or reach surface water as

dissolved runoff but does have potential to contaminate surface water as a result of residues suspended in runoff water. A more refined
assessment is difficult due to uncertainty regarding the exact formulation of the spray solution.

As part of its consultation, EPA reviewed available scientific studies and information on the human health and environmental effects of

glyphosate and the inert ingredients and on exposure pathways; conducted a literature search for human health incidents related to
glyphosate use in the U.S.; and summarized use patterns for glyphosate in the U.S., including use sites, methods and rates of

application, and differing formulations. In addition, the Agency considered information, provided by non-governmental sources,
concerning adverse effects reportedly connected to the eradication program.

Details of the Agency's findings are provided in the attached document.

SECTION 1. Description of Glyphosate Use in the U.S. for Comparison to Use in Colombia for Coca Eradication

INTRODUCTION: The Biological and Economic Analysis Division (BEAD) within the Office of Pesticide Programs, Environmental
Protection Agency, has been asked to describe the use of glyphosate within the United States with a more detailed description of its use

in forestry sites so that methods of use in the United States may be used as a basis for comparison for coca eradication in Colombia (1).

1
SUMMARY: Glyphosate is the herbicide most widely used in the United States (2). In agriculture this popularity is due, in large part, to
the development of crops that are highly tolerant to broadcast applications of glyphosate which allows growers to use this non-selective

herbicide as their principal method of weed control in certain crops. Growers have rapidly adopted glyphosate-based weed control
programs with glyphosate tolerant crops because they are simple and economical (3). In addition, due to it's unique properties,

glyphosate is also widely used for non-agricultural weed control situations including home lawns and gardens, forestry and other non-
crop sites where total vegetation control is desired.

1EPA's (BEAD's) biannual pesticide sales and usage report estimates that in 1999, glyphosate was the most used conventional pesticide in the U.S. (83 to 95 million pounds of

glyphosate applied) in all markets. It was second behind atrazine in the agricultural market (67 to 73 million pounds of glyphosate applied); and second behind 2,4-D in the non-
agricultural market (16-22 million pounds of glyphosate applied). In the agricultural market, data for 2000 and 2001 suggest that the usage of glyphosate has increased to as much

as 100 million pounds. Data is not yet available for 2000 and 2001 for the non-agricultural market.

Glyphosate must be applied to the target plant's foliage to be effective. Glyphosate is non-selective in action, controlling a wide variety of
plants. Once absorbed, it circulates to untreated portions of the plant; and it has no residual activity after contact with soil. Glyphosate

may be applied using hand-held, ground-driven or aerial equipment; the choice of equipment is determined by the site to be treated.
Although higher rates of application are allowed, actual rates per application in agricultural sites average less than 0.75 pounds of the

active ingredient glyphosate per acre (Table One). For the non-agricultural site, forestry, use is allowed at rates per application ranging
from 2 to 10 pounds per acre (2.2 to 11.2 kilograms of active ingredient/ hectare) of glyphosate in the form of the isopropylamine salt

(6). This rate of use may also be expressed as 1.5 to 7.5 pounds per acre of acid equivalent (pure glyphosate; not a salt). A more
detailed discussion of the use of glyphosate in the U.S. follows.

USE OF GLYPHOSATE IN THE UNITED STATES: Products containing glyphosate are registered with the U.S. Environmental Protection

Agency, which means they may legally be used within the United States if used in accordance with label instructions.

Glyphosate may be used on over 400 crop and non-crop sites. The largest agricultural use sites include soybeans, cotton and field corn.

The following table summarizes estimates the use of glyphosate in three primary agricultural use sites.

Table One. 2000 Glyphosate Use in U.S. Agriculture: In Total and for the Three Major Use Sites

Site Acres Base Percent Total Pounds Avg. Avg.

Grown Acres of Crop Acres Applied Number Application
(million Treated Treated 2 Treated (million of Apps Rate (lbs

acres) (million (million lbs ai) ai/acre/app)
acres) 1 acres) 3

All Ag. - - - 102.7 73.5 - -

Sites

Corn 73.8 6.6 9% 7.3 4.4 1.1 0.59Annex 45

Cotton 14.4 8.1 56% 13.8 9.5 1.7 0.67

Soybeans 71.0 44.0 62% 57.2 41.8 1.3 0.68

Source: USDA, National Agricultural Statistics Service (NASS) 2000 field crop chemical use (May, 2001), and EPA proprietary data.

1Base acres treated = acres treated 1 or more times with glyphosate.
2Percent of crop treated = base acres treated with glyphosate divided by acres grown.

3Total acres treated = based acres treated with glyphosate multiplied by the average number of applications of glyphosate.

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). The estimate includes both home owner

and professional applications as well as use on forested lands (11). 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.

AGRICULTURAL SITES: In certain annual crops, glyphosate may be applied before planting (preplant) to control existing weeds; often
replacing tillage as a weed control measure in "no-till" crop culture systems designed for reducing soil erosion. However, most of the

glyphosate currently used in agricultural sites is used in a cropping system employing crop varieties that have been developed to be
resistant to glyphosate so that glyphosate may be applied "over-the-top" of the resistant crop to kill susceptible weeds. The most

prevalent of these systems is the Round-up Ready Soybean® system. These soybeans, which are highly tolerant to glyphosate, were
marketed starting in 1996. Since then this system has been widely and rapidly adopted; in 1990-1991, glyphosate ranked 11 thamong

conventional pesticides used in the U.S. with annual use estimated to be 18.7 million pounds (4). In 2000, glyphosate was the most
widely used herbicide in soybeans; nearly 42 million pounds of glyphosate were applied to soybeans alone (2) with over 60 percent of

soybeans surveyed by USDA's National Agricultural Statistical Service treated with glyphosate (5). Round-up®, a glyphosate product
marketed for agricultural use is formulated with a surfactant during manufacture to facilitate foliar absorption. The following table (Table
TM
Two) summarizes the use rates specified in label instructions for Roundup Original product herbicide concentrate (12) which contains
the isopropylamine salt of glyphosate for use in glyphosate-tolerant soybeans.

Table Two. Allowed Rate of the Isopropylamine Salt of Glyphosate Per Application in Tolerant Soybeans

Maximum for Quarts of Pounds of Active Kilograms of Active
Application Timing Product/Acre Ingredient/Acre Ingredient/Hectare

For Entire Season 8 8 9

Before Crop Emergence 5 5 5.6

In Crop 3 3 3.4

Up to Two Weeks Prior 1 1 1.1

to Harvest

NON-AGRICULTURAL USES INCLUDING FORESTRY: BEAD has been asked to describe the use of glyphosate in U.S. forestry sites

since that use most closely corresponds to the use of glyphosate in Colombia for coca control. For simplicity this document only refers to
Accord® which is intended specifically for forestry use (6). This product contains the isopropylamine salt of glyphosate (41.5%), and is

labeled for non-agricultural uses including Forestry Site Preparation and Utility Rights-of Way, Forestry Site Conifer and Hardwood
Release, and Wetland Sites in the U.S. Table Three describes the rates at which it may be used. It is recommended for use in site

preparation prior to planting any tree species, including Christmas tree and silvicultural nursery sites (7). Specific methods of application
for forestry uses include: aerial spraying; spraying from a truck, backpack or hand-held sprayer; wipe application; frill treatment; cut

stump treatment (7).

For forestry site preparation it may be applied using either ground or aerial equipment at rates from 2 to10 pounds glyphosate active
ingredient per acre which is equivalent to 2.2-11.2 kilograms of active ingredient per hectare (Table Three). It may also be applied using

hand-held equipment. Product instructions specify that a non-ionic surfactant be added to the spray mixture for all forestry uses at a rate
of 0.5 to 1.5 percent by spray volume (2 to 6 quarts of surfactant per 100 gallons of spray solution). It may also be combined with

certain residual herbicides to extend the period of weed control beyond that obtained with glyphosate alone.

The isopropylamine salt of glyphosate may also be used in forestry conifer and hardwood release as a directed spray or by using selective
equipment. This product may also be used in or around wetland sites generally at no more than 5 quarts of product per acre (5 lbs

isopropylamine salt of glyphosate per acre which is equal to 5.6 kg/ha) using over-water broadcast application (5).

Table Three. Rate of Isopropylamine Salt of Glyphosate Per Application For Certain Use Sites

Quarts of Pounds of Active Kilograms of Active

Use Site Product/Acre Ingredient/Acre Ingredient/Hectare

Forestry Site Preparation 2-10 2-10 2.2-11.2
and Utility Rights-of Way

Forestry Site Conifer and 2-10 2-10 2.2-11.2

Hardwood Release

Wetland Sites 2-5 2-5 2.2-5.6 Annex 45

PROPERTIES OF GLYPHOSATE: Glyphosate is a foliar-active herbicide; to exert herbicidal properties it must enter the plant through
foliage (or in some cases, the stem). Glyphosate applied to foliage is absorbed by leaves and rapidly moves through the plant. It acts by

preventing the plant from producing an essential amino acid. This reduces the production of protein in the plant, and inhibits plant
growth.

Glyphosate has systemic activity, meaning that it circulates through the plant's vascular system; affecting the entire plant, not just the

treated foliage. Other foliar-active herbicides, like paraquat for example, are contact herbicides; affecting only the portion of the plant
onto which they are applied. After treatment with a contact herbicide, a plant may then regrow from untreated portions, often

necessitating re-treatment for complete control. The advantage to a systemic herbicide is that if applied at an appropriate dose, it can kill
an entire plant, thus preventing regrowth from an untreated plant part such as a root.

Glyphosate has no residual activity, once adsorbed to soil it quickly becomes unavailable to plants and no longer has herbicidal activity.
This means that a plant that would ordinarily be susceptible to glyphosate can be planted shortly after an application of glyphosate; this

is common practice in U.S. agriculture. In contrast, some herbicides have month-long or even year-long residual activity which limits the
plants that may be grown following their use.

Glyphosate is non-selective. Some herbicides are selective in their action, controlling only grassy weeds in a broadleaf crop like soybeans,

for example. However, glyphosate exerts herbicidal action on a variety of plants; it is active on grasses, herbaceous plants including deep
rooted perennial weeds, brush, some broadleaf trees and shrubs, and some conifers. However, glyphosate does not control all broadleaf

woody plants. Plants vary in their susceptibility to glyphosate, so the treatment of dose in important. Plants of certain species and older
plants are less susceptible to glyphosate Timing is critical for effectiveness on some broadleaf woody plants and conifers.

FORMULATIONS OF GLYPHOSATE: Glyphosate and four salts of the parent glyphosate molecule are currently used as active

ingredients in registered pesticide products in the U.S.(9). These products are registered with the U.S. EPA for use in the U.S. in many
different crop, non-crop, industrial and residential sites.

Table Four. Number of Products and Sites for Different Formulations of Glyphosate

Active Ingredient Number of Products Number of Sites

Glyphosate acid 28 more than 250

Ethanolamine salt 2 more than 200

Ammonium salt 16 more than 300

Isopropylamine salt 237 more than 400

Trimesium salt 6 more than 100

Sesquisodium salt no currently active products no active sites

GLYPHOSATE USED WITH SURFACTANT FOR FOLIAR ABSORPTION: Since glyphosate is only effective if absorbed by plant foliage,

glyphosate is combined with a surfactant to facilitate its absorption. Many herbicide concentrates, including glyphosate, are mixed with
water before application. Without a surfactant, the aqueous spray mixture is repelled by the plant's waxy cuticle layer ("beads up"), and

quickly runs off the plant's surface, preventing absorption.

Surfactants are commonly used as wetting agents with herbicides and in other products such as laundry and dishwashing detergent. Non-
ionic surfactants, which are comprised of alcohols or fatty acids and considered an all-purpose surfactant are commonly used with
glyphosate-containing products. Surfactants are frequently added during manufacture of the herbicide concentrate. If not, a non-ionic

surfactant is generally mixed with the herbicide and water before spraying to enable the liquid to make better contact with the waxy
cuticle of the plant. These glyphosate products, which are formulated without a surfactant, are considered "non-loaded" (10).

A short description of international usage of glyphosate, including Colombia, appears after the following references to the above

discussion.

REFERENCES:

(1) Description of Use of Glyphosate in Coca Eradication in Colombia in attachment to a letter from Secretary of State Colin Powell
to Environmental Protection Agency Administrator Governor Christine Whitman.

(2) Donaldson, D., T. Kiely, and A. Grube. Pesticide Industry Sales and Usage, 1998 and 1999 Market Estimates. June 2002.

Biological and Economic Analysis Division, Office of Pesticide Programs, U.S. Environmental Protection Agency.

(3) Gianessi, L.P., Silvers, C., Sankula, S., and Carpenter, J. Plant Biotechnology: Current and Potential Impact for Improving Pest
Management in U.S. Agriculture - An Analysis of 40 Case Studies. June 2002. National Center for Food and Agricultural Policy.

(4) Glyphosate - Reregistration Eligibility Decision. United States Environmental Protection Agency. September 1993.

(5) Agricultural Chemical Usage - 2000 Field Crops Summary. May 2001. United States Department of Agriculture. National
Agricultural Statistics Service.

(6) Accord® Herbicide Specimen Label. Available on-line from CDMS.Annex 45

(7) Pesticide Fact Sheet. Prepared for the U.S. Department of Agriculture, Forest Service.

(8) D. Lantagne., M. Koelling, and D. Dickman. Effective Herbicide Use in Christmas Tree Plantations. Michigan State University

Extension.

(9) U.S. Environmental Protection Agency, Office of Pesticide Programs. Search of the Reference Files System dated June 11, 2002.

(10)Miller, P., and P. Westra. Crop Series: Production. Colorado State University.

(11) EPA Proprietary Information

TM
(12) Roundup Original Herbicide Supplemental Labeling for Postemergence Applications to Soybeans with Roundup Ready®
Gene. Available online from CDMS.

BEAD was asked to report on the use of glyphosate in forestry sites since it seemed similar to the use pattern for coca eradication.
However, it is not clear how closely this use approximates that for coca eradication. Glyphosate is typically applied to forestry sites using

helicopters at air speeds of 50-70 knots (about 60-80 miles per hour). Application to forestry sites by fixed wing aircraft, if practiced at
all, is extremely rare (1). The recommended rate of application for pine release (conifer release) is 1.5 to 2 pounds active ingredient per

acre.

Aerial application to other sites comprises less than one percent of the total amount of glyphosate applied in the United States (3).

In addition to surfactants, drift control agents may be added to the spray mixture for forestry uses in an effort to prevent drift to off
target sites. BEAD has not investigated the prevalence of use or the effectiveness of these products.

BEAD estimates total global use of glyphosate to be between 350 and 360 million pounds of glyphosate per year. Annual use in the

United States is approaches 100 million pounds of active ingredient and an estimated 250 to 260 million pounds of glyphosate is used
outside of the United States. Use of glyphosate in Colombia accounts for between four and five million pounds of this use. Primary sites in

Colombia include coffee, bananas, pasture-land and rice (3).

REFERENCES:

(1) Personal communication between Virginia Werling, United States Environmental Protection Agency and John Taylor, United
States Forest Service on August 9, 2002.

(2) Hamilton, R.A. "2002 North Carolina Agricultural Chemicals Manual - Chemical Weed Control In Forest Stands" Extension Forest

Resources Department, North Carolina State University. Available on-line at http://ipm.ncsu.edu/agchem/chptr8/821.pdf

(3) United States Environmental Protection Agency Proprietary Data.

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

The Department of State has requested that the US Environmental Protection Agency (EPA), Office of Pesticide Programs (OPP) provide a

human health risk assessment for the aerial coca eradication in Colombia. The Department of State (DoS) has requested that the risk
assessment address whether or not the aerial eradication program in Colombia is being carried out in accordance with regulatory controls
required by the EPA as labeled for use in the United States, and the chemicals used, in the manner in which they are being applied, do

not pose unreasonable risks or adverse effects to humans and or the environment. According to information provided by DoS, the
eradication program, includes the use of a spray mixture of a glyphosate containing pesticide product, an adjuvant (Cosmo-Flux 411F)

and water. The glyphosate tank mixture is applied in an over the top aerial foliar application in certain provinces within Colombia. To
facilitate the request, the DoS met with members of OPP on April 18 and sent a written request, dated May 8, 2002, with documentation

on the coca eradication program, including a description of the pesticide spray mixture components, application methods, target site
identification, and potential exposures. DoS also supplied EPA with incident reports for aerial eradication of illicit poppy in Colombia.

The Field and External Affairs Division (FEAD) of OPP, which has the responsibility of managing the EPA's role of providing technical

information and assistance to DoS for this program, forwarded the DoS request to Health Effects Division (HED), the Environmental Fate
and Effects Division (EFED), and the Biological and Economics Assessment Division (BEAD) for scientific assessments. The HED of OPP is

charged with estimating the risk to human health from exposure to pesticides. Registration Action Branch 1 (RAB1), Reregistration
Branch 1 (RRB1) and the Chemistry and Exposure Branch (CEB) of HED as a team have performed the assessment requested by the

Department of State and have evaluated the potential hazard, exposure, and risk to human health from the U.S. supported coca
eradication program Colombia.

A summary of the findings and an assessment of human risk resulting from the use of glyphosate in Colombia to eradicate coca is
provided in this document.

Unless otherwise specified, all information pertaining to the U.S. supported coca eradication program in Colombia was provided to the

Agency from two sources: (1) Department of State (DoS) Presentation, DoS Coca Eradication Program, 4/18/02, (2) DoS document Annex 45

entitled Chemicals Used for the Aerial Eradication of Illicit Coca in Colombia and Conditions of Application.

II EXECUTIVE SUMMARY

USE PATTERN

According to the State Department, the glyphosate tank mixture is applied as an over the top aerial foliar application to coca in certain
provinces within Colombia. The tank mixture sprayed for eradication of coca in Colombia contains 55% water, 44% of glyphosate

herbicide product, and 1% adjuvant (Cosmo-Flux 411F). Up to two applications of the glyphosate tank mixture are sprayed over coca
crops at a maximum of 1.25 gallons of product/Acre. In order to assess the hazard of what was sprayed in Colombia, components of the

mixture were evaluated separately.

HAZARD ASSESSMENT

The Cosmo-Flux 411F adjuvant used in the glyphosate tank mix is produced by a Colombian company and is not sold in the U.S. All
ingredients identified as contained in this product are substances that are not highly toxic by oral or dermal routes. They may cause mild

eye and skin irritation. 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).

The available hazard data base on experimental animals indicates that the Glyphosate technical grade active ingredient (TGAI) has low
acute toxicity via the oral and dermal routes. It is a mild eye irritant and a slight dermal irritant. It is not a dermal sensitizer. The

requirement for an acute inhalation study was waived since no respiratory or systemic toxicity was seen following subchronic inhalation
exposure in rats. In the subchronic and chronic oral toxicity studies (1-year dog, 24-month mouse, 2-year chronic/carcinogenicity rat,

and 2-generation rat reproduction), systemic toxicity manifested most commonly as clinical signs, decreases in body weight and/or body
weight gain, decreased food consumption, and/or liver and kidney toxicity at doses equal to or above the limit dose (1000 mg/kg/day).

No dermal or systemic toxicity was seen following repeated dermal exposures. There was no quantitative or qualitative evidence for
increased susceptibility in fetuses following in utero exposure to rats and rabbits in developmental toxicity studies or following pre/post-

natal exposure to rats in the 2 generation reproductive toxicity study in rats. Effects in the offspring were observed only at or above
treatment levels which resulted in evidence of appreciable parental toxicity.

The Food Quality Protection Act (FQPA) Safety Factor Committee (SFC) concluded that the safety factor, to protect infants and children,
of 10x be removed (reduced to 1x). The Hazard Identification Assessment Review Committee (HIARC) met on March 26, 1998 and,

again, on November 20, 2001. The most recent report of the HIARC for glyphosate has the complete assessment of the endpoints
selected for dietary exposure and residential/occupational exposure. No endpoints were selected for the acute Reference Dose (RfD) since

no hazard attributed to a single dose was identified from the oral toxicity studies, and there are no concerns for developmental or
reproductive toxicity. In addition, the HIARC did not identify endpoints of concern for dermal and inhalation exposures for any exposure

period (short term 1-30 days, intermediate term- 1 to 6 months, or long term- 6 months to lifetime) since no hazard was identified due
to the low toxicity of glyphosate. HIARC did identify an incidental oral endpoint for short- and intermediate-term exposure. The chronic

dietary RfD of 1.75 mg/kg/day was based on diarrhea, nasal discharge, and mortality in a rabbit developmental toxicity study.
Glyphosate was not mutagenic in a full 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).

EXPOSURE

An exposure and risk assessment is required for an active ingredient if: (1) certain toxicological criteria are triggered and (2) there is

potential for exposure. Upon review and analysis of the hazard database in total, the Agency's HIARC did not identify a hazard of concern
for acute dietary, dermal, or inhalation exposures. Therefore, quantitative estimates of risk for these exposure durations have not been

conducted (TXR No. 0050428, W. Dykstra, 22-JAN-2002).

Acute dietary exposure is possible for persons consuming livestock or food crops which have been inadvertently sprayed as a result of
the aerial eradication program in Colombia. However, since glyphosate is a contact herbicide that systemically kills plants after absorption

through leaves, dietary exposure due to consumption of treated crops is expected to be limited. In addition, since an acute dietary
endpoint was not identified in the hazard database, no significant risk due to acute dietary food exposure to glyphosate residues is

expected. Based on the fact that a coca field is sprayed no more than twice to eradicate the crop, no chronic food exposure is expected.

Handler (e.g., individuals mixing the concentrated formulated product to prepare the tank mix and loading the tank mix in
the aircraft) exposure is anticipated for short-term (1-30 days) and, possibly intermediate-term (1-6 months) durations based on the
frequency of application and duration of the spray program.

Based on the use pattern described by the DoS, short-term dermal post-application exposures are expected for persons pruning, or

leaf pulling treated coca plants immediately after spray events. In cases such as glyphosate, where the vapor pressure is negligible, OPP
experience with post-application data suggests that inhalation exposure is minimal and OPP does not quantitatively assess post-

application inhalation exposure. Intermediate- and long-term post-application exposures are not expected due in part to the fact that a
coca field is sprayed twice to eradicate the crop. Additionally, glyphosate is a translocated herbicide which is rainfast within 48 hours after

spraying. Therefore, potential exposure to dislodgeable residues of glyphosate after 48 hours is expected to be minimal.

DoS states that pilots are instructed not to spray fields where people are present. Therefore, incidental oral exposure (hand-to-mouth)
resulting from individuals being directly sprayed by glyphosate was not assessed. Non-dietary incidental oral exposure was not

quantitatively assessed for the use of glyphosate in Colombia.Annex 45

There is potential for exposure to bystanders in areas near those targeted for spraying. However, the technology and other safeguards
described by DoS as being used in this program are consistent with common approaches in the United States for reducing spray drift.

Therefore, it is likely that drift is minimized in this program if all procedures are adhered to and operational equipment is in working
order.

From the review of Colombian glyphosate product human incident reports for poppy eradication, it should be emphasized that the

overwhelming majority (95%) of the illnesses reported are likely background incidents unrelated to the spraying of herbicide to poppy.
The remaining 5% increase could be due to a variety of causes and do not support a conclusion that the spraying of the glyphosate tank

mixture was responsible for these complaints. Furthermore, the individual with the highest potential for exposure would be the mixer
loader. They are handling the concentrated glyphosate product and the tank mix. The incidence data that has been submitted to the
Agency by DoS, does not include any incident reports for those individuals. There are data to suggest that the poppy spray eradication

program could have resulted in minor skin, eye, or respiratory irritation, and perhaps headache or other minor symptoms. However, the
detailed information on timing of application, history of exposure, and medical documentation of symptoms related to exposure to

glyphosate tank mix were not available. Given the limited amount of documentation, none of the data in the report from Colombia
provide a compelling case that the spraying of the glyphosate mixture has been a significant cause of illness in the region studied.

Prospective 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.

A direct comparison of the epidemiological data in Colombia (which is from aerial application to poppy) to the conditions of use, (as

presented at the April 18, 2002 briefing for aerial application to coca by DoS to OPP risk assessors), would be limited. The briefing and
the materials provided did not address the conditions of use for poppy. Nor was the Agency provided any human incident data for the

coca eradication program. Subsequent to the April 18 briefing HED received an e-mail communication from OPP/Field and External Affairs
Division, stating that DoS informed EPA that the application rate for poppy was lower than that for coca. According to the DoS, the use
pattern of the glyphosate mixture on poppy differs from the use on coca. Other details of the differences between the two spray

programs have not been supplied to the Agency. Specifically, the Agency has no information as to the exact makeup of the tank mixture
sprayed on poppy, or whether the same glyphosate product and adjuvants used in the coca eradication program were used in the poppy

eradication program. The Agency also has questions as to the geographical area differences, the frequency of repeated applications, and
the size of the area treated on each spray mission. Therefore, generalized conclusions drawn from human incident data as a result of

application to opium poppy, in comparison to conditions of use for the coca eradication program should be made with caution.

The glyphosate formulated product used in the coca eradication program in Colombia contains the active ingredient glyphosate, a
surfactant blend, and water. The acute toxicity test of the glyphosate technical is classified as toxicity category III for primary eye

irritation and toxicity category IV for acute dermal and oral toxicity, and skin irritation. It is not a dermal sensitizer. However, the
surfactant used in the formulated product reportedly can cause severe skin irritation and be corrosive to the eyes, as would be expected
for many surfactants. The label for the formulated product used in the coca eradication program in Colombia includes the "Danger" signal

word. These findings suggest that any of the reports of toxicity to the eye may be due to the surfactant, not glyphosate per se. The
product has been determined to be toxicity category I for eye irritation, causing irreversible eye damage.

There may be a correlation between the ocular toxicity caused by the surfactant and reported incidents of ocular effects. This is

supported by data obtained from the California Pesticide Illness Surveillance Program (1982-2000). In 1992 the glyphosate product was
reformulated in the US to reduce the amount of surfactant which posed a hazard to the eye. From 1982 through 1991, there were 221

illnesses involving the eye or 22.1 cases per year. From 1994 (allowing 2 years for the product to be introduced into trade and
widespread use) through 2000, there were 65 illnesses involving the eye or 9.3 cases per year, a decline of 58%. Therefore, these data

support the finding that use of the reformulated glyphosate product since 1992, has resulted in a significant drop in illnesses. Overall, the
total illnesses due to glyphosate declined by 39% from the 1982-1991 time period to the 1994-2000 time period, largely due to reduction
in eye injuries.

The greatest potential for eye exposure is expected for workers mixing and loading the concentrated glyphosate product. There is also

the potential for eye exposure as a result of entering treated fields after treatment to perform pruning or harvesting activities.

During an April 18 briefing, the Department of State agreed to supply the Agency with a full battery of the six acute toxicity tests on the
tank mix. To date this information has not been received. Until such information is supplied to the Agency, EPA cannot evaluate the

potential ocular or dermal toxicity resulting from direct contact with the tank mixture. Therefore, 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 and/or poppy aerial
eradication programs.

III BACKGROUND

EPA regulates pesticides under two statutes, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug,

and Cosmetic Act (FFDCA). FIFRA provides the authority to register and review pesticides as well as the authority to suspend and cancel
if use poses unreasonable risks. FFDCA provides authority to set maximum residue levels (tolerances) for pesticides used in or on foods
or animal feeds.

Section 3 of FIFRA provides authority to register (license for sale and distribution) pesticide products. The label of the pesticide product

specifies the use (pest and crop/site), amount of product to be applied, frequency, timing of use, restrictions, storage and disposal
practices and precautionary statements. The active ingredient in a pesticide product is the "ingredient which will prevent, destroy, repel,

or mitigate any pest." The inert or other ingredient(s) in a pesticide product is "an ingredient which is not active." The registrant must
provide data for the Agency to assess potential environmental and human health risks. The data required to make a safety finding are

dependent on the intended use, e.g., food use vs non-food use. The data requirements for pesticides may be found in 40 CFR Part 158. Annex 45

For human health risk assessment, data is required to permit characterization of hazard and exposure.

Data requirements on the chemical identity and composition of the formulated pesticide product, may be found in 40 CFR 158.150. The
list of ingredients for a pesticide product and the percent of each ingredient in the formulation are contained in the confidential statement

of formula (CSF). The CSF is FIFRA confidential business information (CBI) and is entitled to treatment as trade secret or proprietary
information. Agency risk assessments do not typically contain this information. 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.

Residue chemistry data required as per 40 CFR 158.240 support the ability of the Agency to estimate the amount of pesticide that will
result in food as a result of application of the pesticide according to the product labels directions for use. The magnitude of the residue
studies for crop field trials use the typical end use product as the test material. The livestock feeding studies are required whenever a

pesticide residue will be present in livestock feed. The livestock feeding studies evaluate the magnitude of the resulting pesticide residue
in meat, milk, poultry, and eggs. The studies are conducted with the technical grade of the active ingredient or the plant metabolites

Residue chemistry data are also required to identify any potential metabolites of concern. These data are used to determine the
tolerances for the parent and or metabolites. Additional data is required on environmental fate, degradation, metabolism, and dissipation.

Hazard data required for human health risk assessment are provided in 40 CFR 158.340. The use of the active ingredient (i.e., food use

or non-food use) will determine what studies are required. The acute toxicity data on the technical grade of the active ingredient are used
for classification and precautionary labeling for protective clothing requirements, and worker reentry intervals. The only studies that are

required to be conducted on the manufacturing use product or end use product are the acute toxicity studies. The remaining toxicology
studies (e.g., developmental toxicity, reproduction, subchronic, chronic feeding, or carcinogenicity studies) require that the test
substance is the technical grade of the active ingredient. Subchronic toxicity studies provide data on potential target organ toxicity and

are also used to select dose levels for long term or chronic toxicity studies. Chronic toxicity or carcinogenicity studies are conducted for
food use chemicals to determine potential effects following prolonged or repeated exposure that may have a latency period for

expression. The test animals are exposed orally for a significant portion of their life span. Developmental toxicity studies are required in
two species (usually the rat and rabbit) for food use chemicals. They are conducted to detect alterations in the normal development of

fetuses following in utero exposure. The 2-generation rat reproductive toxicity study is required to assess potential alterations in gonadal
function, estrus cycles, mating, conception, birth, lactation, weaning, as well as growth and development of offspring. The Agency also

requires a battery of mutagenicity studies to assess the potential induction of changes in the genetic material of cells. The above studies
are required for food use active ingredients. In general, less data is required for non-food use active ingredients and inerts unless a

concern has triggered additional testing.

The Agency conducts separate risk assessments for all pesticide active ingredients and has conducted risk assessments for some inerts.
The remaining inerts are cleared by the Agency. It should be understood that whenever the inert ingredient was cleared, whenever the
tolerance exemption was established, the inert met the standards of the time. Inert ingredients, also known as "other ingredients," are

the carrier for the active ingredients which allow the product to deliver the active ingredient at a specific rate and ensure proper
distribution during application. Currently there are over 3200 inert ingredients cleared by EPA for use in various domestic pesticides

products. There are two major classifications: non-food use (such as lawn care products and bathroom cleaners), and food-use, which
require an exemption from the requirement of a tolerance and can also be used in non-food products.

The Agency has a newly developed methodology for evaluating low or low/moderate toxicity chemical substances by way of a screening

process that incorporates elements of a tiered approach (US EPA, May 2002). Use of this process will permit the Agency to clear more
chemicals of low to moderate toxicity for use in pesticide products. The Agency is aware that some chemicals may be used as inert

ingredients in some formulations and as active ingredients in other formulations. EPA believes this methodology is appropriate for
evaluating some low toxicity chemicals regardless of whether they are categorized as active or inert ingredients. The new process will
permit the Agency to be able to conduct more in-depth evaluations of other ingredients that are of potentially higher toxicity. Chemicals

of higher toxicity that can not be appropriately addressed in the lower tiers would be evaluated in a manner substantially similar to that
of an active ingredient. Later as the Agency begins to review chemical-specific or surrogate information in the open literature, the

preliminary tier determination may be revised (US EPA, May 2002).

Inert ingredients that are exempt from tolerance are listed in 40 CFR 180.1001 (c). The inert ingredients in the glyphosate formulation
have been approved by the Agency. The components of the adjuvant (Cosmo-Flux 411F), that DoS indicates have been sprayed on coca

plants in Colombia have also been determined to be approved for use on food by the Agency.

The two federal statutes for regulating pesticides in the US give EPA limited authority to regulate the sale, or use of adjuvants in the US.
EPA only has authority to regulate the pesticide product itself. For example, if a chemical in an adjuvant was intentionally included in the

formulation of a pesticide product, the chemical would be regarded as an inert ingredient. In the US as with all countries, adjuvants are
commonly used and added to pesticides as wetting agents, spreaders. emulsifiers, antifoamers, penetrants, or for other purposes. These
may contain surfactants, solvents, or other types of chemicals to achieve the desired purpose.

An adjuvant is a subsidiary ingredient or additive product added to a pesticide in a mixture that aids the effectiveness of the primary or

active ingredient. Adjuvants are most commonly added to tank mixes of pesticide products prior to application to the site to be treated.
Adjuvants are not directly subject to FIFRA registration if no pesticidal claims are made. Pesticide manufacturers choose whether or not

to address on their product labels the use of adjuvants with their product(s). However, when added to a tank mix for application to a food
or feed crop/site, the individual components must be cleared under FFDCA. While adjuvant products are not registered on the federal

level, they are subject to registration under some state laws. The states of Washington and California are two states that register
adjuvants. The adjuvant (Cosmo-Flux 411F) used in the glyphosate tank mix is produced by a Colombian company and is not sold in the

U.S. The Department of State has agreed to provide the Agency with acute toxicity data performed on the actual tank mix that has beenAnnex 45

sprayed in Colombia.

IV HISTORICAL REGULATORY INFORMATION

The glyphosate product used in Colombia according to the Department of State was registered in the US in April 1974. From 1974-1992

the product was registered for use on a number of agricultural and nonagricultural sites. The product had a "Warning" signal word for eye
irritation. In 1992, the registrant submitted an eye irritation study that was categorized as Toxicity Category I and required a "Danger"
signal word. The registrant decided that they did not want to market a glyphosate product with a "Danger" signal word. Around July

1992, the registrant registered a reformulated glyphosate product for use in the United States that had the percentage of surfactant
reduced to a level that produced Toxicity Category II eye irritation. The original product was re-labeled - "Not for use in the United

States". Because the Agency never rescinded the registrations for the use sites that were on the initial label before it was changed, the
product technically remains registered for use on numerous agricultural and nonagricultural sites although it is not currently labeled for

these uses. In November 2001, the Company submitted a label for the original product for ground and aerial application to control
undesirable vegetation in nonagricultural sites. This registration was intended to register a glyphosate product that corresponds to the

product being used in Colombia. In February 2002 the product name was changed and the maximum application rate was reduced as per
the request of the registrant.

V HAZARD IDENTIFICATION

Hazard identification is the first step in the risk assessment process. The objective is to qualitatively characterize the inherent toxicity of a

chemical. Scientific data are evaluated to establish a causal relationship between the occurrence of adverse health effects and exposure
to a chemical. Because high quality controlled toxicology studies on humans are frequently unavailable, regulatory scientists rely on
animal data to estimate hazard to support regulatory decision making. Prior to and subsequent to initial registration, the Agency has

required the registrants of glyphosate products to submit appropriate studies according to contemporary study requirements and testing
protocol requirements.

Glyphosate

The available hazard data base on experimental animals indicates that glyphosate has low acute toxicity via the oral and dermal routes

with LD 50s > 5000 mg/kg. It is a mild eye irritant and a slight dermal irritant. It is not a dermal sensitizer. The requirement for an acute
inhalation study was waived since no respiratory or systemic toxicity was seen following subchronic inhalation exposure in rats. In the

subchronic and chronic oral toxicity studies (1-year dog, 24-month mouse, 2-year chronic/carcinogenicity rat, and 2-generation rat
reproduction), systemic toxicity manifested most commonly as clinical signs, decreases in body weight and/or body weight gain,

decreased food consumption, and/or liver and kidney toxicity at doses equal to or above the limit dose (1000 mg/kg/day). No dermal or
systemic toxicity was seen following repeated dermal exposures. There was no quantitative or qualitative evidence for increased

susceptibility in fetuses following in utero exposure to rats and rabbits in developmental toxicity studies or following pre/post-natal
exposure to rats in the 2-generation reproductive toxicity study in rats. Effects in the offspring were observed only at or above treatment

levels which resulted in evidence of appreciable parental toxicity. Glyphosate was not mutagenic in a full 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) 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 (study citation 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 (study citation 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 (study citation 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 (study citation 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 Annex 45

a hazard assessment 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 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 Cosmo-flux 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, Letter from
R.Forrest/EPA, to R.Woolfolk/DoS, 7/30/2001).

Components of Cosmflux

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 (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 (information not
included as it may be entitled to confidential treatment) 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.

VI 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 biologically 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. Glyphosate

On March 26, 1998 and, again, on November 20, 2001 the HED HIARC met to examine the hazard data base and identify dietary

endpoints for Females 13-50 years old, as well as the General Population, the chronic reference dose. The HIARC also considered
toxicological endpoints for incidental oral exposure (on 20-NOV-01) appropriate in residential exposure risk assessments.

The most recent report of the HIARC for glyphosate has the complete assessment of the endpoints selected for dietary and

residential/occupational exposures (W. Dykstra, 01/22/02; TXR# 0050428). OPP calculates acute (24 hour or single day) and chronic
(continuous lifetime exposure) RfDs for the purposes of calculating dietary risk for food and drinking water. The RfD is calculated by
dividing the appropriate no observed adverse effect level by a ten fold factor for interspecies variability ("average" human sensitivities

might be up to 10 times that of lab animals) and a ten fold factor for intraspecies variability (i.e., some individuals within a population
might be 10 times more sensitive than the "average" person).

For glyphosate, no endpoints were selected for the acute RfD since no hazard attributed to a single dose was identified from the oral

toxicity studies, and there are no specific concerns for toxic effects on the developing fetus or infants and children. In addition, the HIARC
did not identify endpoints of concern for dermal and inhalation exposures for any exposure period (short term- 1 to30 days, intermediate

term- 1 to 6 months, or long term- 6 months to lifetime) since no hazard was identified due to the low toxicity of glyphosate (TXR No.
0050428, W. Dykstra, 22-JAN-2002). The chronic dietary RfD of 1.75 mg/kg/day was based on diarrhea, nasal discharge, and mortality

in a rabbit developmental toxicity study. A summary of doses and toxicological endpoints selected for various relevant exposure scenarios
are summarized in Table 1.

Table 1. Glyphosate Endpoint Selection Table

EXPOSURE DOSE ENDPOINT STUDY
SCENARIO (mg/kg/day)

Acute Dietary An effect of concern attributable to a single dose was not identified
(24 hour or single from the oral toxicity studies; there are no concerns for

exposure) developmental or reproductive toxicity.

Chronic Dietary NOAEL = Maternal toxicity based on clinical Developmental
175 signs (diarrhea and nasal discharge) toxicity -Rabbit

(continuous resulting in mortality of some dams
lifetime exposure) uncertainty at 350 mg/kg/dayAnnex 45

Occupational Handler and Post-application Exposure

Use Pattern Information

The tank mixture sprayed for eradication of coca in Colombia contains 55% water, 44% of glyphosate herbicide product, and 1%

adjuvant (Cosmo-Flux 411F). No more than two applications of the glyphosate tank mixture are sprayed over coca crops at a maximum
of 1.25 gallons/Acre (equivalent to 1.1 gallons/Acre of glyphosate product, 0.03 gal/Acre of Cosmo-Flux 411F, and 0.12 gal/Acre of
water). DoS also stated that the average field size for coca in Colombia is 3-5 hectares (approximately 7-12 acres). The program for

aerial eradication of coca treats a maximum of 1000 Acres/day, during 3-5 missions/day.

Handler Exposure

Exposure is expected for workers mixing and loading the glyphosate formulated product and tank mix, and applicators applying the
pesticidal mixture via fixed-wing aircraft. Mixers, loaders, and applicators (handlers) have the potential for dermal exposure to the

concentrate glyphosate formulated product or tank mix from droplets contacting the skin. There is also the potential for inhalation
exposure to the concentrated glyphosate formulated product or mixed formulation from breathing in aerosolized spray droplets.

According to the DoS, the mixer/loaders are trained on the label requirements for handling the chemicals in the spray mixture, first aid,

and use of personal protective equipment (PPE). The required PPE according to the label includes long-sleeved shirts and long pants,
waterproof gloves, shoes and socks, and protective eyewear. PPE is expected to mitigate potential exposure to handlers. Exposure to

handlers is anticipated for short-term (1-30 days) durations. There also may be the possibility for intermediate-term(1-6 months)
handler exposure for individuals mixing, loading, and applying the glyphosate mixture to multiple fields for more than 30 days. However,

the Agency does not have information pertaining to the duration of coca spray programs or number of days spent mixing, loading, and
applying the glyphosate mixture.

An occupational handler exposure and risk assessment is required for an active ingredient if: (1) certain toxicological criteria are

triggered and (2) there is potential exposure to handlers (i.e., mixers, loaders, applicators, etc.) during use. Upon review and analysis of
the hazard database in total, the Agency's HIARC did not identify a hazard of concern for dermal or inhalation short- and intermediate-
term exposures. Therefore, quantitative estimates of risk for short-term dermal and inhalation have not been conducted (TXR No.

0050428, W. Dykstra, 22-JAN-2002). No significant handler risk is expected.

Post-application Exposure

According to the DoS, Colombian coca plants (Erythroxylum species) are woody perennial shrubs native to the Andean region. Coca
plants have leaves with waxy cuticles which retard herbicide uptake in the plant. The coca bushes grow to approximately chest level and

are harvested mainly by leaf pulling, 4 to 5 times per year. Coca plants grow from seedlings to a harvestable plant in 12 to 18 months.
Representatives from DoS indicated that, growers will prune the coca plants, immediately after spraying, in order to salvage the coca

crop. Specifically, since glyphosate is a contact herbicide that works systemically to kill the plant after absorption through the leaves,
workers may enter fields immediately after spraying in order to prune or pull off the coca leaves in order to prevent the coca plant from

dying. In the US, most uses of glyphosate are applied to kill weeds - which are the target. In general, glyphosate is not applied in the US
to destroy or kill the raw agricultural commodity. The intended US uses are for undesired vegetation in and around crop fields, forests,

industrial areas and residential areas (for more detailed information, please refer to the June 28, 2002 memorandum entitled Description
of Glyphosate Use in the U.S. for Comparison to Use in Colombia for Coca Eradication from Virginia Werling and Timothy Kiely to Jay
Ellenberger).

DoS states that pilots are instructed not to spray fields where people are present. Therefore, based on the use pattern described by the

DoS, potential short-term dermal exposures are expected for persons pruning, or leaf pulling treated coca plants immediately after spray
events. These activities are expected to result in dermal exposure from treated foliage contacting the skin. In cases such as glyphosate,

where the vapor pressure is negligible, HED experience with post-application data suggests that inhalation exposure is minimal and
therefore, HED does not quantitatively assess post-application inhalation exposure. Intermediate- and long-term post-application

exposures are not expected due in part to the fact that a coca field is sprayed no more than twice.

Additionally, glyphosate is a translocated herbicide which is rainfast (unable to be rinsed off by water) within 48 hours after spraying.
Therefore, potential exposure to dislodgeable residues of glyphosate after 48 hours is expected to be minimal. Glyphosate has no residual

soil activity. Results from the first 12 months of bareground field dissipation trials from eight sites show that the median half-life (DT50)
for glyphosate (Roundup) applied at maximum annual use rates (7.95 lb a.i./acre, 10.7 lb a.i./acre) was 13.9 days with a range of 2.6

(Texas) to 140.6 (Iowa) days. Acceptable aerobic soil, aerobic aquatic and anaerobic aquatic metabolism studies demonstrate that under
those conditions at 25 oC in the laboratory glyphosate degrades rapidly with half-lives of approximately 2, 7 and 8 days respectively. The

reported half-lives (DT50) from the field studies conducted in the coldest climates, i.e. Minnesota, New York. and Iowa, were the longest
at 28.7, 127.8, and 140.6 days respectively indicating that glyphosate residues in the field are somewhat more persistent in cooler
climates as opposed to milder ones (Georgia, California, Arizona, Ohio, and Texas) (Memo, J.Carleton, 10/26/98, D238931). The climate

in Colombia would favor a shorter half life than the colder regions of the US. Thereby, HED believes glyphosate would not be persistent or
be available for intermediate-term or long-term post-application exposures in the Colombian climate.

A post-application exposure and risk assessment is required for an active ingredient if: (1) certain toxicological criteria are triggered and

(2) there is potential exposure. Upon review and analysis of the hazard database in total, the Agency's HIARC did not identify a hazard of
concern for these durations or routes of exposure. Therefore, quantitative estimates of risk for short-term dermal and inhalation have not

been conducted (TXR No. 0050428, W. Dykstra, 22-JAN-2002). No significant post-application risk due to glyphosate exposure is
expected as a result of this use. Annex 45

X RISK CHARACTERIZATION

Risk characterization combines the assessments of the first three steps to develop a qualitative or quantitative estimate of the

probability, that under the assumed conditions or variables of the exposure scenario, that harm will result to an exposed individual. Risk
is equal to hazard multiplied by exposure. For the scenarios that are relevant to the subject use, the Agency has not identified toxic

effects attributable to a single oral exposure, short- or intermediate-term dermal, or short- or intermediate-term inhalation exposures
(TXR No. 0050428, W. Dykstra, 22-JAN-2002). Therefore, no quantification of exposure or risk was performed. Nonetheless, it is

appropriate to qualitatively characterize the potential for risk concerns for this use.

From the review of glyphosate product incident reports for the use on poppy, it should be emphasized that the spraying reported to have
occurred in 2000 and not in 1999 suggests, that the overwhelming majority (95%) of the illnesses reported would be background

incidents unrelated to the spraying of herbicide. The remaining 5% increase could be due to a variety of causes and do not support a
conclusion that the spraying of the glyphosate tank mixture was responsible for these complaints. Furthermore, the individual with the
highest potential for exposure would be the mixer loader. They are handling the concentrated glyphosate product and the tank mix. The

incident data that has been submitted to the Agency by DoS, does not include any incident reports for those individuals. There is some
data to suggest that the poppy eradication program could have resulted in minor skin, eye, or respiratory irritation, and perhaps

headache or other minor symptoms. However, the detailed information on the use, timing of application, history of exposure, and
medical documentation of symptoms related to exposure to glyphosate tank mix were not available. The evidence collected and

presented in the epidemiology report cannot confirm that the glyphosate tank mixture used in Colombia as the likely cause of a single
illness. There is suggestive evidence in the form of reported increases of morbidity and reports from municipalities that some cases of

relatively mild complaints could have occurred in relation to the spraying eradication program. Some of the reports appear to be similar
to those reported in the literature and by California. These cases report irritation to skin, eyes, and respiratory passages and suggest that

the Cosmo-Flux 411F added to the glyphosate product in Colombia has little or no effect on the overall toxicity of the formulated product.
The information so far collected indicates that any increase in health problems is likely to be relatively small at most and the severity of

those symptoms is likely to be minor to moderate at most. The Amazon Alliance and Earth Justice submission provided little, if any,
information on the number of persons affected, age and sex, symptoms of illness, or diagnosis or treatment received. Without such

information EPA cannot even begin to characterize the extent and pattern of the health effects claimed to result from glyphosate
application. Given the limited amount of documentation, none of the data in the report from Colombia provide a compelling case that the

spraying of the glyphosate mixture has been a significant cause of illness in the region studied. Prospective 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.

The glyphosate formulated product used in the coca eradication program in Colombia contains the active ingredient glyphosate, a

surfactant blend, and water. The acute toxicity test of the glyphosate technical is classified as category III for primary eye irritation and
category IV for acute dermal and oral toxicity, and skin irritation. It not a dermal sensitizer. However, the surfactant used in the

formulated product reportedly can cause severe skin irritation and be corrosive to the eyes, as would be expected for many surfactants.
The label for the formulated product used in the coca eradication program in Colombia includes the "Danger" signal word. The product

has been determined to be toxicity category I for eye irritation, causing irreversible eye damage. Some of the findings reported in the
incident data are in alignment with that, reports of toxicity to the eye due to the surfactant, not glyphosate per se. This is supported by

data obtained from the California Pesticide Illness Surveillance Program (1982-2000). As stated previously, in 1992 the glyphosate
product was reformulated in the US to reduce the amount of surfactant which posed a hazard to the eye. From 1982 through 1991, there

were 221 illnesses involving the eye or 22.1 cases per year. From 1994 (allowing 2 years for the product to be introduced into trade and
widespread use) through 2000, there were 65 illnesses involving the eye or 9.3 cases per year, a decline of 58%. Therefore, these data

support the finding that the use of the reformulated glyphosate product since 1992, has resulted in a significant drop in illnesses. Overall,
the total illnesses due to glyphosate declined by 39% from the 1982-1991 time period to the 1994-2000 time period, largely due to the

reduction in eye injuries.

The acute toxicity of the undiluted glyphosate product is most pertinent to mixers and loaders, who are potentially exposed to that form
of the glyphosate product. On April 18, 2002, during a consultation with the DoS, in preparation for the current risk assessment, the DoS

agreed to supply the Agency with a full battery of the six acute toxicity tests on the tank mix. To date, the Pesticide Program has not
received this data. Until such information is supplied to the Agency, EPA cannot evaluate any potential acute toxicity effects resulting

from direct contact with the tank mixture. Therefore, 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 an alternative glyphosate product (with
lower potential for acute toxicity) be used in future coca and/or poppy aerial eradication programs.

A direct comparison of the epidemiological data in Colombia (which is from aerial application to poppy) to the conditions of use, (as

presented at the April 18, 2002 briefing for aerial application to coca by DoS to OPP risk assessors), would be limited. The briefing did not
address the conditions of use for poppy. Subsequent to the April 18 briefing HED received an e-mail communication from OPP/ Field and

External Affairs Division, stating that the application rate for poppy was lower than that for coca. According to the DoS, the use pattern of
the glyphosate mixture on poppy differs from the use on coca. Other details of the differences between the two spray programs have not

been supplied to the Agency. Specifically, the Agency has no information as to the exact makeup of the tank mixture sprayed on poppy,
or whether the same glyphosate product and adjuvants used in the coca eradication program were used in the poppy eradication

program. The Agency also has questions as to the geographical area differences, the frequency of repeated applications, and the size of
the area treated on each spray mission. Therefore, generalized conclusions drawn from human incident data as a result of application to

opium poppy, in comparison to conditions of use for the coca eradication program should be made with caution.

In summary, HED concludes that:

z There are no risks of concern for glyphosate, per se, from the dermal or inhalation routes of exposure, since toxicity is very low.
z The identified components of the adjuvant Cosmoflux 411F are not highly toxic by the oral and dermal routes; they have beenAnnex 45

approved for use in/on food by the Agency.

z Glyphosate is not highly toxic. Based on the conditions of glyphosate use described by DoS, there is likely minimal exposure or
concern for acute and chronic dietary or incidental oral risks.

z The incident data from Colombia based on the poppy use may differ from use of glyphosate as part of the coca eradication
program, so conclusions should be made with caution.

z There is concern for acute eye toxicity because of an inert ingredient present in the glyphosate formulated product used to treat
coca. The potential for eye effects is primarily for mixers/loaders of the concentrated glyphosate product, which should be mitigated

by protective eye wear which DoS states is being used.
z Due to the acute eye irritation caused by the concentrated glyphosate product and the lack of acute toxicity data on the tank

mixture, the Agency recommends that DoS consider using an alternate glyphosate product in future coca and/or poppy aerial
eradication efforts.

REFERENCES

HIARC Report for Glyphosate (TXR No. 0050428, W. Dykstra, 22-JAN-2002)

Glyphosate in/on Pasture and Rangeland Grasses, Roundup Ready® Wheat, and Nongrass Animal Feeds. (DP Barcode: D280831, 20-

FEB-2002)

Farmer, D.R., T.A. Kaempfe, W.F. Heydens and W.R. Kelce. 2000. Developmental toxicity studies with glyphosate and selected
surfactants in rats. Teratology 61(6): 446.

US Environmental Protection Agency, Office of Pesticide Programs May 9, 2002: Guidance Document on Methodology for Determining the

Data Needed and the Types of Assessments Necessary to Make FFDCA Section 408 Safety Determinations for Lower Toxicity Pesticide
Chemicals.

Williams, G.M., R. Kroes and I.C. Munro. 2000. Safety evaluation and risk assessment of the herbicide Roundup and its active ingredient,

glyphosate, for humans. Reg. Toxic. Pharm. 31: 117-165.

Certain references deleted for protection of CBI.

SECTION 3. Review of Glyphosate Incident Reports with special reference to aerial spraying in Colombia

BACKGROUND

On May 8, 2002 the U. S. Department of State requested that the U.S. Environmental Protection Agency provide consultation on the
U.S.-supported aerial coca eradication program in Colombia. Specifically, the Department of State requests advice on whether the aerial

application program may pose unreasonable risks or adverse effects to humans or the environment. This review is part of a health risk
assessment performed by the Health Effects Division of the glyphosate product used in Colombia. This review will focus on reports of

human health effects reported from the leading pesticide poisoning surveillance data sources in the United States, which include Poison
Control Centers and the California Pesticide Illness Surveillance Program. The California data source is especially useful for this review

because of it's high quality, documentation going back to 1982, and because glyphosate is the second most widely used pesticide in
California affording ample opportunity for unintentional exposures. The world scientific literature on glyphosate and a report from

Colombia examining reports of the adverse health effects are also reviewed.

The aerial spray mixture used in Colombia consists of water, glyphosate formulation, and 1 percent Cosmo-Flux 411F. According to
documentation supplied by the Department of State, this diluted mixture is applied to coca at the rate of 2.53 gallons per acre (U. S.

Department of State 2002). "The commercial glyphosate formulation used in the spray mixture is registered with U. S. Environmental
Protection Agency (EPA) for sale in the United States for non-agricultural use and contains 41 percent glyphosate salt and 59 percent

inert ingredients. Approximately three fourths of the inert ingredient content are water and the remainder is a surfactant blend. A
surfactant is essentially a soap that enhances the ability of the herbicide to penetrate the waxy cuticle of the leaf surface."(U. S.

Department of State 2002).

This review will not be able to fully assess the formulation containing 1 percent Cosmo-Flux 411F because that particular surfactant has
not been used in the United States. Nevertheless, it will consider the summary of the investigation in Colombia of the formulation which

does contain this additional surfactant. Though all aspects of glyphosate human poisoning data will be considered, this review will focus
on one particular scenario, namely the effects of dermal and inhalation exposure from spray drift or residues, that result from aerial

application.

The following data bases have been consulted for the poisoning incident data on the active ingredient glyphosate (PC Code: 103601):

1) Poison Control Centers - as the result of a data purchase by EPA, the Office of Pesticide Programs (OPP) received Poison Control
Center data covering the years 1993 through 1998 for all pesticides. Most of the national Poison Control Centers (PCCs) participate in a

national data collection system, the Toxic Exposure Surveillance System which obtains data from about 65-70 centers at hospitals and
universities. PCCs provide telephone consultation for individuals and health care providers on suspected poisonings, involving drugs,

household products, pesticides, etc. Note that Poison Control Center data does not have information on the type of application. So it is
not possible to limit the review to the aerial application scenario or to limit it to only those persons secondarily exposed to drift or

residue. However, it will be possible to exclude oral exposures which are inconsistent with the focus of the present review. Annex 45

and §158.590 (Nontarget insect data requirements).

All non-target terrestrial and aquatic animal toxicity studies, and aquatic plant studies, are performed using the technical grade active
ingredient (TGAI). Non-target terrestrial plant toxicity tests are performed with pesticide in a formulated product (as sold to users).

Aquatic fish and invertebrate toxicity studies using formulated product are also required if the use of the formulation is expected to lead
to transport to water bodies, either directly or through runoff. The potential exposure and toxicity of each pesticide are considered to

characterize the potential of ecological risk.

The present environmental fate assessment is based on regulatory environmental fate studies submitted to the Agency to support the
registration of glyphosate salts and their formulated pesticide products. These studies were conducted under Good Laboratory Practices

(GLP), as required under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The studies used in the assessment have been
deemed acceptable and have served to generate previous environmental and ecological risk assessments for glyphosate.

The number and types of environmental fate studies required for each pesticide depends on its proposed use pattern (terrestrial, aquatic,

forestry, indoors, greenhouse). The required studies consist of a series of core laboratory studies for all pesticides and field dissipation
studies for pesticides used on outdoor crops (terrestrial/aquatic), non-crops (terrestrial/aquatic), and forestry. Each study provides

specific data that, together with the physical and chemical properties of the pesticide, are then combined to produce an integrated
environmental fate assessment and to identify the potential of the pesticide to leach to groundwater, and/or reach surface water, and/or

bioaccumulate in aquatic organisms. The data are also used as input parameters in models to estimate exposure concentrations in the
environment. Monitoring data, if available, are also incorporated into the assessment.

The limited number of species and environmental systems tested can introduce a degree of uncertainty when attempting to extrapolate

the data outside the experimental conditions of the studies, such as different soils, geographical regions, and ecosystems. As part of the
overall risk characterization of a pesticide, the Agency also identifies uncertainties associated with the available data and those

introduced by the assumptions needed to estimate concentrations using models.

III Ecological Risk Assessment

Glyphosate

Terrestrial

The Agency does not expect any risk to birds and mammals based on dietary exposure to active ingredient glyphosate. Acute avian

dietary studies using bobwhite quail and mallard ducks resulted in no mortality at concentrations up to 5200 ppm, and no reproductive
effects were seen up to 1000 ppm, the highest levels tested. Toxicity tests involving feeding or direct contact of honey bees to glyphosate

also resulted in no mortality at the highest rate tested (100 micrograms/bee). Acute L50 values could not be established in oral and
dermal mammalian studies at concentrations up to and including 5000 mg/kg, and chronic mammalian effects were only seen in a series

of studies at 1000 mg/kg/day or higher. The Agency waived the requirement for an acute inhalation study for mammals with active
ingredient glyphosate since no respiratory or systemic toxicity was seen following subchronic inhalation exposure in rats.

Risk to non-target terrestrial plants is likely from exposure to glyphosate as a result of its use in the coca eradication program.

Glyphosate is a foliarly applied, broad spectrum herbicide effective at very low exposure rates. Vegetative vigor studies for North
American crops reviewed by the Agency in 1999 indicate that 25% of exposed plants can be damaged by exposure to glyphosate applied

at rates as low as 0.07 lb ai/A.

Table 1. Vegetable Vigor Toxicity of Glyphosate Wettable Powder to US Crops

EC NOEL
25
Species Parameter (lbs ai/A) (lbs ai/A)

Cucumber phytotoxicity 0.074 0.049

Lettuce dry weight 0.217 0.148

Oilseed rape phytotoxicity 0.098 0.049

Okra dry weight 0.172 0.049

Radish phytotoxicity 0.235 0.148

Soybean dry weight 0.126 0.049

Sugarbeet " 0.277 0.148

Corn phytotoxicity 0.227 * 0.148

Oat dry weight 0.201 0.148

Purple nutsedge " 0.805 * 0.445

Winter wheat " 0.176 * 0.049

*
Determined by linear interpolation.

The application rate of glyphosate recommended by the State Department for the coca eradication program is 3.34 lb ai/A in acid
equivalents. This is well above the rates listed in the table above. AgDrift modeling of potential spray drift from the use in ColombiaAnnex 45

(detailed below) simulates that non-target plants hundreds of feet away may be exposed to a fraction of this glyphosate application.
Based on the toxicity data for North American crops, AgDrift indicates the possibility that 50% of young crop plants would be expected to

show measurable reductions in dry weight from150 to nearly 600 feet downwind (depending on spray and wind conditions). Some
affected plants would likely recover while more sensitive plants may die, have reduced reproductive success, or reduced yields (crop

plants).

Aquatic

Laboratory studies indicate glyphosate is slightly toxic to fish, invertebrates and aquatic plants. The lowest resulting acute LC values
50
(concentrations at which half the test animals died) were in parts-per-million (ppm) for active ingredient glyphosate. For instance, the

most sensitive freshwater fish (fathead minnow) had an LC 50of 85 ppm, while chronic effects were not seen in another study at the
highest test concentration of 26 ppm. The EC (level at which adverse effects are seen in half the test animals) for the freshwater
50
invertebrate Daphnia magna was 134 ppm, and the chronic NOEL 50 ppm.

OPP exposure models indicate that surface-water exposure in the parts-per-billion could be expected from the use on coca. OPP also

considered a more conservative exposure scenario of 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 glyphosate toxicity values measured for aquatic organisms in

the laboratory. Therefore, aquatic organisms should not be at risk from exposure to glyphosate. The environmental fate assessment

which is the basis of this exposure calculation is described in the following section.

Salts of glyphosate (isopropylamine, diamine, and trimesium) are registered in the United States for a wide variety of agricultural and non-agricultural uses. All of the salts of
glyphosate generate the "free acid of glyphosate" (glyphosate acid), the actual herbicide-active chemical. The glyphosate acid equivalents vary from salt to salt to salt, as it depends

on the ratio of the molecular weight of the glyphosate free acid to that of the salt. For this reason, application rates are generally expressed in terms of "glyphosate acid equivalents"
when estimating exposure concentrations of glyphosate in water and soil. The ratio of glyphosate acid to the glyphosate isopropylamine salt is 0.75. Thus, each pound of this salt is

equivalent to 0.75 pounds of glyphosate acid (or 1 g of the salt is equivalent to 0.75 g of the acid)

It is possible that much greater exposure could occur from direct overspray of water bodies much smaller than a 1-hectare, 6-foot deep

pond, but such simulation is not a standard component of Agency risk assessments. The product label of the specific glyphosate product

DoS indicates is being used against coca, and the DoS application guidelines, prohibit direct overspray of water bodies. It is possible that
some ecologically important water bodies too small to appear on maps could be sprayed directly in a project as large as the coca

eradication program. EPA has registered other glyphosate products for direct application to aquatic sites to kill undesirable vegetation.

Freshwater aquatic plants also seem unlikely to be at risk from exposure to active ingredient glyphosate. Submitted studies resulted in

EC50 values of 12.5 ppm for green algae (Selenastrum capricornatum), 21.5 ppm for duckweed (Lemna gibba) and 38.6 ppm for the
freshwater diatom Navicula pelliculosa. These values are well beyond the 230 ppb exposure calculated for direct overspray in the pond

simulation described above.

Risk Specific to Formulations of Glyphosate

Ecological toxicity studies submitted to EPA for some of the formulations of glyphosate products that EPA has registered have shown

them to be more toxic than glyphosate alone. The results of these studies indicate that the formulations will pose a risk primarily to non-
target plants, as described above. For instance, the minimum bluegill sunfish LC of 5.8 ppm reported for a 41.8% glyphosate
50
formulation in EPA's glyphosate reregistration eligibility document (RED, 1993) is 20 times more toxic than the bluegill sunfish LC 50

observed for technical glyphosate, but is still much higher than exposure levels expected in the environment. The bluegill sunfish LC 50 for
a test with surfactant MONO818 by itself was 1.0 ppm.

The risk to non-target terrestrial and aquatic animals from formulated glyphosate used for coca eradication is uncertain because the
Agency does not have relevant toxicity data for the Colombian formulation, nor for the adjuvant Cosmo-Flux 411F. An adjuvant is a

subsidiary ingredient or additive in a mixture that adds to the effectiveness of the primary or active ingredient. Adjuvants are most
commonly added to tank mixes of pesticide products before they are applied. Further discussion is provided in the Health Effects

Division's assessment of the coca eradication program.

Potential Spray Drift of Glyphosate

The AgDrift model (version 2.01) was used to estimate downwind deposition of aerial applications of herbicide sprays during coca

eradication efforts. The aerial part of the AgDrift model, which was used in this assessment, was developed from USDA Forest Service

models designed to estimate deposition of forestry applications. The model has been the subject of a Scientific Advisory Panel (SAP)
meeting and showed a good correlation with field trial data of downwind deposition. Reviews and descriptions of AgDrift have been

published.4

AgDrift uses a number of input parameters associated with the application equipment and the meteorology during application in

calculating deposition levels. An attempt was made to enter important input parameters appropriate for coca eradication applications in
5
Colombia as described by the Department of State (DoS) in their presentation to the Office of Pesticide Programs (OPP) or in documents
provided by DoS to OPP. Many input parameters in AgDrift do not greatly affect deposition levels and a number of default inputs were
used for these parameters. The inputs considered to be more important in determining drift levels that were used to model coca

eradication spraying are listed in Table 1 below.

http://www.epa.gov/scipoly/sap/1997/december/spraydrift.htm
4
Hewitt AJ, DR Johnson, JD Fish, CG Hermansky, and DL Valcore. 2002. Development of the Spray Drift Task Force database for aerial applications. Environmental Toxicology and Annex 45

range. In the DoS presentation the VMD was stated to be 200 to 300 microns during application conditions. In addition to the wide range

of VMD values presented, VMD is not a good descriptor of droplet size spectra for estimating spray drift. Spray drift is predominately
associated with finer sprays and VMD does not define the amount of small droplets contained in spray. Although specific data on droplet

size under application conditions was not provided, it is unlikely that very coarse sprays would be achievable due to shearing effects of
releasing droplets at high airspeeds. Large droplets released into the turbulence created by an aircraft traveling in excess of 120 mph

tend to break into smaller more driftable droplets.

6
Chemicals Used for the Aerial Eradication of Illicit Coca in Colombia and Conditions of Application. An undated, unsigned, 9-page document provided to OPP by the State
Department.

Other uncertainties associated with inputs include inputs for meteorology and release height. AgDrift modeling requires site-specific

inputs for meteorology. In coca eradication efforts (as well as agricultural applications in the US) wind speed, temperature and humidity
are measured at the airport which may not be representative of these parameters at the application site. The applicator is ultimately
given the responsibility of determining if conditions at the target site are acceptable. DoS reports that the coca eradication program

selects experienced applicators for spray missions with the expectation they will better be able to identify unacceptable conditions and
make applications within specified parameters.

In order to capture the range of deposition values expected during coca eradication applications, AgDrift was run with two droplet size

spectra and at two wind speeds. The droplet size spectra were extremely coarse to very coarse and medium. The definitions refer to the
American Society of Agricultural Engineering (ASAE) Standard 572 definition of droplet size spectra. The wind speeds used were 3 mph

and 10 mph. AgDrift was run in tier 3 to estimate downwind depositions shown in Figure 1 below.

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
eradication spraying is likely to be bounded by these estimates. The effect level for 50% of young plants@ is based on glyphosate toxicity

studies on ten crop plants. At the level corresponding to approximately 11% of the application rate, 50% of plants species would be
expected to show measurable reductions in dry weight. Of the affected plants some would likely recover while more sensitive plants may

die, have reduced reproductive success, or reduced yields (crop plants).

V. Environmental Fate and Transport Assessment of Glyphosate

Integrated Environmental Fate Assessment- Summary

The major route of transformation of glyphosate identified in laboratory studies is microbial degradation. In the field, glyphosate
dissipation appears to correlate with climate, being more persistent in cold than in warm climates. Dissipation of glyphosate in Colombia

may therefore be more rapid than in the U.S. Glyphosate was not observed in laboratory studies to break down by abiotic processes such
as hydrolysis and direct photolysis.

Glyphosate is very soluble, and has a low potential to volatilize, but adsorbs strongly to soils and sediments. Therefore, glyphosate does

not have a high potential to leach to ground water or reach surface water as dissolved runoff. However, glyphosate has the potential to
contaminate surface water as a result of residues adsorbed to soil particulates suspended in runoff water. Offsite exposure is also
possible due to spray drift or inadvertent direct overspray.

Physical and chemical properties of glyphosate acid

Glyphosate belongs to the glycine family of herbicides. Glyphosate is a phosphono derivative of glycine, the simplest of all of the amino
acids. It works as an herbicide by inhibiting the enzyme A5- enolpyryl-shikimate-3-phosphate@ synthase (i.e., it is an ESPS inhibitor).Annex 45 Annex 46

Memorandum from Lowell Neese, SeniorAviationAdvisor, DoS/INL/A(Colombia),
to Paul O’Sullivan, COR, DoS/INL/A(21Apr. 2003)Annex 46Annex 46 Annex 47

Memorandum from Lowell Neese, SeniorAviationAdvisor, DoS/INL/A(Colombia),
to Paul O’Sullivan, COR, DoS/INL/A(9 May 2003)Annex 47Annex 47 Annex 48

Memorandum from DavidA. Campbell, COR, DoS/INL/A,
to Dyncorp, PSD Manager (Feb. 2004)Annex 48Annex 48 Annex 49

Memorandum from Stephen H. Harris, COR, DoS/INL/A, to Dyncorp, L 55 (Undated)Annex 49Annex 49 Annex 50

United States Department of State, Evaluation Summary Technical Operations, G 111 (Undated)Annex 50Annex 50 Annex 51

Memorandum from Michael J. Kenna, INL/RM/AD, SeniorAviationAdvisor, to Steve Harris
(COR) and GeorgeArzente, INL/RM/AD/COR, L 14 (Undated)Annex 51Annex 51

Document Long Title

volume III