Report of Greenbelt Advisory committee on environment on pesticide use in Greenbelt. Contains 12 recommendations adopted by City Council as guides for decision making and reduction of use. Recommends organic land care
Pesticide Report of Green Aces (Greenbelt Committee on Enviromental Sustainablity)
1. Report 2007-02
July 9, 2007
GREENBELT RECYCLING AND ENVIRONMENT ADVISORY
COMMITTEE (REAC) REPORT TO CITY COUNCIL
SUBJECT: PUBLIC AND ENVIRONMENTAL
HEALTH ISSUES REGARDING PESTICIDE USE
AND RECOMMENDATIONS FOR ADOPTION OF
ORGANIC LAND CARE AND ORGANIC PEST
MANAGEMENT (OPM) PRACTICES FOR
GREENBELT
2. Table of Contents Page
1. BACKGROUND 3
1.1 Use of the Precautionary Principle and Tools 3
1.2 Precautionary Principle Tools for Decision Making and Action 3
2. FINDINGS 4
2.1 Step One: Identify the Possible Threat and Characterize the Problem 4
2.2 Step Two: What is Known and Not Known About the Threat? 5
2.2.1 Pesticides and Health Generally 5
2.2.2 Pesticide Use By the City Staff 7
2.2.3 Pesticide Use by Residents and Businesses of Greenbelt 10
2.3 Step Three: Reframe the Problem to Help Decide What REAC Needs to Do 11
2.4 Step Four: Assess Alternatives---How Have Other Communities Addressed the 11
Issues? What Are the Possible Alternatives?
2.4.1 Examples from Canada: Bans, Phase Outs, and Public Education 12
2.4.2 Mandating and Defining Integrated Pest Management (IPM)--- 13
Maryland IPM In-Schools Legislation
2.4.3 Other Innovative US Ordinances 14
2.4.4 The Organic Pest Management and the Organic Land Care Movement 15
in Landscaping
3. RECOMMENDATIONS 17
3.1 Step Five: Determine the Course of Action and Recommendations 17
3.2 Specific Recommendations to Council 17
3.3 Step Six: Monitor and Follow Up 19
Appendices 20
Appendix A---SUMMARY REPORT BY CITY OF GREENBELT STAFF 20
Appendix B-- ONTARIO COLLEGE OF PHYSICIANS REPORT SUMMARY 27
Appendix C—SAMPLE PESTICIDE LABEL 30
Appendix D---EPA CRITERIA FOR EVALUATION OF CHEMICAL 31
CARCINOGENICITY
Appendix E---EXAMPLES OF CANCER RISK ASSESSMENT 35
Appendix F---PESTICIDE BY-LAW OF THE CITY OF TORONTO 36
Appendix G---BEST PRACTICE REVIEW REPORT SUMMARY 38
Appendix H--TOWN OF MARBLEHEAD BOARD OF HEALTH ORGANIC 41
PEST MANAGEMENT REGULATIONS
Appendix I---ANNOUNCEMENT OF ORGANIC LAND CARE BASIC 47
TRAINING FOR MUNICIPAL OFFICIALS OR TRANSITIONING
LANDSCAPERS
Appendix J---RESOURCES ON PESTICIDES AND ALTERNATIVES 48
8/14/2007 2
3. 1. BACKGROUND
In fall of 2004, REAC asked City Council to study the issue of pesticide use within Greenbelt. This
request was then sent to Greenbelt Staff for review. City staff recommended that REAC itself do
the study. In 2005 City Council requested REAC to: 1) review pesticide use by the City, 2) study
pesticide use in general, and 3) make recommendations to Council. Over the past 18 months,
REAC has invited experts on the topic to committee meetings and its members have studied the
issue working with City Staff.
Public Works Staff has worked very cooperatively with REAC and provided all information
requested. They have also shared their informed perspective on the topic of concern. REAC wishes
to express our thanks and acknowledgment to the Staff for the help provided.
Using a six-step process, based on the Precautionary Principle, this report presents a summary of
findings of the pesticide study and provides a set of recommendations for the Council to consider.
1.1 Use of the Precautionary Principle and Tools
Consistent with the United Nations (1992), and numerous international conventions and statements
and the President’s Council on Sustainable Development (1996), REAC endorses what has come to
be known as the Precautionary Principle (Tickner, Raffensperger, and Myers, 2001). The
precautionary principle broadly states: “When an activity raises threats of harm to human health or
the environment, precautionary measures should be taken even if some cause-and-effect
relationships are not fully established scientifically.” (taken from the January 1998 Wingspread Statement
on the Precautionary Principle). The Rio Declaration from the 1992 United Nations Conference on
Environment and Development, also known as Agenda 21 (which the United States signed and ratified)
similarly stated:
In order to protect the environment, the precautionary approach shall be widely applied by
States according to their capabilities. Where there are threats of serious or irreversible
damage, lack of full scientific certainty shall not be used as a reason for postponing cost-
effective measures to prevent environmental degradation (The Rio Declaration from the
1992 United Nations Conference on Environment and Development, also known as Agenda 21).
1.2 Precautionary Principle Tools for Decision Making and Action
In the publication (Tickner, Raffensperger, and Myers, The Precautionary Principle in Action: A
Handbook 2001) written for the Science and Environmental Health Network, the authors identify a
six step set of tools for arriving at policy decision making in an area when there is some uncertainty.
This report follows this process as a method of organizing the report--- starting with an
identification of the problem and moving to actionable recommendations. The six steps are:
Step One: Identify the possible threat and characterize the problem
Step Two: Identify what is known and what is not known about the threat.
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4. Step Three: Reframe the problem to describe what needs to be done
Step Four: Assess alternatives.
Step Five: Determine the course of action.
Step Six: Monitor and follow up
We move through each of the steps in this report to Council. Our findings are presented in steps
One to Four. Steps Five and Six contain the recommendations to Council. A number of
appendices are included. Appendix A prepared by Bill Phelan contains the report of City Staff on
Recent Pesticide Use and summarizes city staff views. Appendices B to J contain other relevant
information and are identified within the document in appropriate sections.
2. FINDINGS
2. 1 Step One: Identify the Possible Threat and Characterize the
Problem
The impetus to study the use of pesticides in Greenbelt, grew out of concerns for public and
environmental health (human, animal and plant) specific to Greenbelt, the wider Chesapeake Bay
Watershed, and the global community of which we are also a part. Concerns at these three
geographic levels can be summarized briefly as follows:
• The initial request to REAC for the study of pesticide use in Greenbelt grew out of two
specific incidents in 2004 ---a broad based spraying by GHI of an area around Hillside to
control invasive plants, and the observation by a member of REAC of evidence of a broad
based herbicide spraying by the City along the sidewalk on the route to the metro along
Cherrywood Lane and very close to Indian Creek. These citizens were concerned for their
own health, the ecology of their neighborhood, and the damage to wildlife, especially as
some of the spraying was on slopes that went directly into the local streams. In both cases
the expressed intent by GHI and the City was a positive goal. In one case the goal of the
spraying was to control invasive species, and in another case the goal was control plants that
were deemed too close to a public sidewalk where mowing with a large mower was not
possible. It should be noted that both GHI and the City have reduced the broad based
spraying that prompted the initial concern in 2004.
• The request for the study also grew out of wider general concerns for the Chesapeake Bay
Watershed. The Chesapeake Bay Foundation (CBF) has described the bay as “dangerously
out of balance,” and a “system in crisis.” Last year’s http://www.cbf.org “Annual State of the
Bay Report” summary states, “The Chesapeake and its rivers and streams are dying…” While
the sources of the problem are many, on a per acre basis urban run off is estimated to
contribute 7 times the pollution that farm areas contribute. The 2000 Chesapeake Bay
Agreement adopted a goal of a “Chesapeake Bay free of toxics by reducing or eliminating the input of
chemical contaminants from all controllable sources to levels that result in no toxic or bioaccumulative impacts
on the living resources that inhabit the Bay or on human health.” The Toxics 2000 Strategy
recommends the implementation of “Projects and programs that reduce the use of
pesticides, promote less toxic alternatives, or employ other voluntary efforts that ultimately
8/14/2007 4
5. reduce pesticide loads to the watershed.” The Chesapeake Bay Strategy recognizes that
“Nonpoint-sources, particularly urban stormwater runoff, represent a substantial source of
chemical contaminants to the Bay and its tidal rivers”. This fact, coupled with, “…increasing
population and expanded development within the watershed” suggest that efforts to reduce
the toxic contributions from individuals and homeowners should have a significant
cumulative benefit for the Bay and its rivers.
• Finally, Greenbelt is part of the global community. There is a general recognition that the
global environment is under grave stress from numerous sources related to burning of fossil
fuels, and extensive use of chemical fertilizers and pesticides, most of which have unknown
long term effects. Worldwide use of pesticides increases yearly and estimates are that 3
billion kilograms of pesticides are spread annually. According to the USDA over 100 million
pounds of pesticides were applied to ornamental landscapes alone in the year 2002 (in the
USA).
2.2 Step Two: What is Known and Not Known About the Threat?
The following is a summary of our findings presented under the following topics:
1. Pesticides and Health Generally
2. Pesticide Use by the City of Greenbelt
3. Pesticide Use by Residents and Businesses in Greenbelt (on this topic little is
known currently, however we include it because one of the things REAC
increasingly came to realize was of importance of this issue to the problem)
2.2.1 Pesticides and Health Generally
• Definititon of Pesticides as Used in this Document: Pesticides are “substances or
mixtures of substances that prevent, destroy, repel, or mitigate pests, or defoliate, desiccate,
or regulate plants” (Massachusetts Department of Food and Agriculture Pesticide Bureau).
Herbicides, fungicides, insecticides, miticides, avicides and rodenticides are all considered
pesticides.
• Pests are and may be known as undesirable plants, insects, fungi, bacteria, and rodents, birds
and other animals. Common examples in turf grass and the landscape can be, but are not
limited to, crabgrass, knotweed, poison ivy, chinch bugs, grubs, and a variety of plant
pathogens.
• While the REAC working group looked at pesticides generally, most of our work has
been with regard pesticides as applicable to landscape care. We consider only in a
limited manner issues related to pesticides designed for in-door use, or insect control.
• According to the United States Environmental Protection Agency (EPA) “By their
very nature, most pesticides create some risk of harm. [They] can cause harm to
humans, animals, or the environment because they are designed to kill or [harm]… living
organisms.” US court cases have ruled that: it is not legal for companies that make pesticides
and pest control companies to say that a pesticide is “safe.” They cannot claim it is “safe”
even if it is registered for public use and even if it is used as directed.
8/14/2007 5
6. • According to Center for Disease Control studies (2005 Third National Report on Human
Exposure to Chemicals, as reviewed by the Pesticide Action Network of North America
(PANNA)), most people in the U.S. have pesticides in their bodies, and 6-11 year olds
have levels four times and 12-19 year olds three times what EPA considers safe.
• Pesticides may kill or harm desirable organisms in addition to those they target.
There is growing evidence of the hazards associated with long-term use of pesticides.
Pesticide exposure in humans has been associated with birth defects; numerous cancers,
including non-Hodgkin’s lymphoma, (the second fastest growing cancer in the U.S.);
Parkinson’s disease and other neurological disorders; immune systems problems; and male
infertility. The web site for Beyond Pesticides gives summary information on the effects of the
most commonly used pesticides, as well as providing information on organic lawn care.
http://www.beyondpesticides.org/lawn/index.
• After a comprehensive systemic review of the literature, the Ontario College of
Family Physicians (OCFP) in April of 2004 strongly recommended that people
reduce their exposure to pesticides wherever possible. The review shows consistent
links to serious illnesses such as cancer, reproductive problems and neurological diseases,
among others. The study also shows that children are particularly vulnerable to pesticides.
“Many of the health problems linked with pesticide use are serious and difficult to treat – so
we are advocating reducing exposure to pesticides and prevention of harm as the best
approach”, said Dr. Margaret Sanborn of McMaster University, one of the review’s authors.
Appendix B is a copy of the executive summary of this report. The full text of the report is
available at:
http://www.ocfp.on.ca/local/files/Communications/Current%20Issues/Pesticides/Final%
20Paper%2023APR2004.pdf
• The full range of harm from pesticides is not known. This is because few studies have
looked at: how pesticides affect children; what happens when people are exposed to them
long-term; what happens when people are exposed to a few different pesticides at the same
time; what happens when they combine with other chemicals or medicines in our bodies;
what happens if a person is exposed to a pesticide over and over again (Maryland Pesticide
Network in Pesticides: The Risks, Prevention and Healthier Choices, 2006).
• EPA does not currently evaluate or consider the endocrine disrupting properties of
pesticides during registration or re-registration. Recent press reports have highlighted
(Science News September 2006; Beyond Pesticides September 6 2006) that some species of male
fish are acquiring female sexual characteristics at unusually high frequencies in the Potomac
River and its tributaries, prompting concerns about pollutants that might be causing the
problem. Environmentalists have long pointed to pesticides and other endocrine disrupting
chemicals as having the potential for wreaking such hormonal chaos. Many scientists believe
that wildlife provides early warnings of effects produced by endocrine disruptors, which may
as yet be unobserved in humans. A recent study found that the commonly used lawn
pesticide formulation Round-Up, with the active ingredient glyphosate, causes damaging
endocrine effects in fetuses.
(http://ehp.niehs.nih.gov/docs/2005/7728/abstract.html)
(http://www.beyondpesticides.org/pesticides/factsheets/Glyphosate.pdf).
8/14/2007 6
8. • As part of the study REAC asked for and received City records of pesticide use for land
care, and also staff perspective on the pesticide issue. A summary of recent use is included
in Appendix A.
• It is important to note that the EPA toxicity categorization presented in Appendix A is for
“acute exposure” and is not an evaluation of the long-term or cumulative effects of exposure
to humans, animals, or plants. Current federal pesticide labeling laws require pesticide
manufacturers to include acute (short-term), and not chronic (long-term) health risk
information on pesticide labels. Therefore, product-specific cancer risk information is not
readily available. An example of a pesticide label is provided in Appendix D. An
explanation of the 4 acute toxicity categories as provided by EPA is given below.
Toxicity Categories and Pesticide Label Statements
EPA uses the following criteria to determine the toxicity category of pesticides. These criteria are based on
the results of animal tests done in support of registration of the pesticide. Category I is the most toxic.
I II III IV
Up to and including From 500 thru Greater than 5000
Oral LD50 From 50 thru 500 mg/kg
50 mg/kg 5000 mg/kg mg/kg
Inhalation LC Up to and including From 2.0 thru 20 Greater than 20
From 0.2 thru 2 mg/liter
50 0.2 mg/liter mg/liter mg/liter
Dermal LD Up to and including From 200 thru 2000 From 2,000 thru Greater than 20,000
50 200 mg/kg. mg/kg 20,000 mg/kg mg/kg
No corneal
Corrosive; corneal Corneal opacity reversible
opacity; irritation
Eye effects opacity not reversible within 7 days; irritation No irritation
reversible within 7
within 7 days persisting for 7 days.
days
Moderate
Severe irritation at 72 Mild or slight
Skin effects Corrosive irritation at 72
hours irritation at 72 hours.
hours
Human hazard signal word
Toxicity Category I - All pesticide products meeting the criteria of Toxicity Category I shall bear
on the front panel the signal word "Danger.'' In addition if the product was assigned to Toxicity
Category I on the basis of its oral, inhalation or dermal toxicity (as distinct from skin and eye local
effects) the word "Poison'' shall appear in red on a background of distinctly contrasting color and
the skull and crossbones shall appear in immediate proximity to the word "poison.''
Toxicity Category II - All pesticide products meeting the criteria of Toxicity Category II shall bear
on the front panel the signal word "Warning.''
Toxicity Category III - All pesticide products meeting the criteria of Toxicity Category III shall
bear on the front panel the signal word "Caution.''
8/14/2007 8
9. Toxicity Category IV - All pesticide products meeting the criteria of Toxicity Category IV shall
bear on the front panel the signal word "Caution.''
Child hazard warning - Every pesticide product label shall bear on the front panel the statement "keep out
of reach of children.'' Only in cases where the likelihood of contact with children during distribution,
marketing, storage, or use is demonstrated by the applicant to be extremely remote, or if the nature of the
pesticide is such that it is approved for use on infants or small children, may the Administrator waive this
requirement.
Further information on these criteria and labeling requirements is published in the Code of Federal
Regulations (40 CFR 156.10).
Source: http://www.epa.gov/agriculture/tpes.html
Interpreting signal words on pesticide labels (refers only to acute toxicity not long term
effects)
Signal Word Toxicity Approximate amount needed
to kill the average person
Danger (Category 1) Highly toxic A taste to teaspoon
Warning (Category II) Moderately toxic A teaspoon to a tablespoon
Caution (Category III and IV) Slightly toxic An ounce to more than a pint
• To obtain information on such things as evaluation of cancer risk, one must determine the
ingredients in the product and look up information under the chemical name. Appendix D
gives an explanation of the EPA cancer risk ratings and Appendix E gives examples of an
evaluation of the cancer risk classification given by the Program on Breast Cancer and
Environmental Risk Factors (BCERF) database on Turf Pesticides and Cancer Risk Data
Base for some of the chemicals contained in two of the products listed on the City Listing;
Manage and Kleen-up. For more information, see
http://envirocancer.cornell.edu/turf/searchProdMore.cfm?key=27295
• Public Works Staff has indicated that they have significantly reduced the use of chemical
pesticides since the REAC review started and they report that attempts are being made to
use the least toxic chemicals. However, while limiting their use, the city continues to use
some chemicals that have been classified as Category I and II, and a few others that are in
the Category III and IV as to acute toxicity, but have been classified as “likely carcinogens”
or for which sufficient information is not available on long term effects.
• Public Works Staff indicates that they have fully adopted Integrated Pest Management
(IPM).
• Integrated Pest Management (IPM) definition. As defined in a report on school
compliance with the Maryland IPM-In School legislation Integrated Pest Management
8/14/2007 9
10. (IPM) is a pest management system of prevention, monitoring and control that eliminates or
mitigates economic and health damage caused by pests while minimizing the use of
pesticides and their associated health risks. IPM does this through a combination of practices
such as site or pest inspections, pest population monitoring, and evaluating the need for pest
control. Pest control methods include sanitation, structural repairs, mechanical and living
biological controls, other non-chemical methods. As defined in the “Maryland IPM in
Schools Legislation”, only when nontoxic options are exhausted or shown to be
unreasonable, may the use of the use of the least toxic chemical pesticides be
considered.
• While the Public Works Staff are following Best Practice guidelines for application and use
of pesticides as required by law and directed in industry manuals, REAC was not made aware
that Greenbelt has a written statement concerning adoption of and definition of IPM
implementation in Greenbelt.
• Integrated Pest Management suffers from not being specifically defined and
implementation can range from infrequent use of chemical pesticides as a last resort
to more frequent pesticide use with much less caution. This issue was recently noted
with reference to the study of compliance with Maryland In-School Pesticide law that directs
schools to use IPM. As defined in that legislation, pesticides should only be after all other
alternatives had been tried.
• It is not clear that the understanding of IPM adopted by the City of Greenbelt is that
indicated in the Maryland School law that requires that pesticides be used only when other
alternatives have been tried and found not to be effective.
• The city contracts for a substantial portion of lawn care. The city currently has two
contracts with TruGreen (formerly known as ChemLawn). According to Public Works
Staff, the city does not have pesticide use in the lawn care contract. When pesticides are
needed in turf areas, the City does the application. However, Trugreen is allowed to use a
glyphosate product (like Roundup) to spot spray weeds in the landscape contract (median
landscaping on Mandan, Hanover, Cherrywood and Breezewood). Trugreen uses Manage for
control of nutsedge- as Public Works Staff note that it cannot be controlled by other means
such as hand weeding. It should be noted that Manage contains Oryzalin (EPA number
72167-15-74477) as an active ingredient and that this product has been deemed by
EPA as likely to be a carcinogenic to humans in the 1999 USEPA Cancer Risk
Category.
• Greenbelt is a recognized leader in city beautification, promotion of native plants and other
positive landscaping practices. Largely due to resource restraints and perceived levels of
citizen expectations for aesthetics of land care, the Public Works Staff has indicated that the
elimination of chemical pesticides use would create problems for the city as described in
their “Pesticide Summary.”
8/14/2007 10
11. 2.2.3 Pesticide Use by Residents and Businesses of Greenbelt
As the City Summary Report prepared by Public Works Staff demonstrates, City use of pesticides is
limited, and is being reduced. However, use by citizens and businesses for lawn control in all
probability is a greater problem in terms of health risks and environmental degradation. At this
time, REAC has limited information on pesticide use by private citizens, GHI, condominiums and
apartments, businesses and other governmental entities in and around Greenbelt.
We note, however, that over the past year, GHI has made notable efforts in environmental
stewardship through hiring an environmental land care manager, through efforts of the Woodlands
Committee, and the newly formed Sustainability Committee in fostering planting of Native Plants
and moving toward more sustainable practices of land care. GHI has recently sponsored purchase
and installing of rain barrels and has prepared a brochure on rain gardens sent to cooperative
members.
2.3 Step Three: Reframe the Problem to Help Decide What REAC
Needs to Do
• The material above documents the recognized health hazards to humans and wildlife of pesticide
use. It also documents the Cities’ expressed adherence to IPM, and also their perceived need to
continue limited use of certain chemical pesticides for aesthetic, plant health, safety and resource
reasons. Given this knowledge, what is the best recommendation for REAC to make
with regard to the City use of pesticides?
• The prevalence of pesticide use by private residents and businesses is unknown to
REAC. Given that residents and businesses cover a larger area than that covered by the City
Staff, and pesticide use may well be more prevalent and uninformed among residents than by the
City, it is clear that resident and business pesticide usage could well be a large threat to
health and environment. The question is what needs to be done in this regard?
• Can a third way be found that will address the aesthetic, health, safety and resource concerns
of the City as well as the health and safety concerns raised by citizens and environmental
groups?
2.4 Step Four: Assess Alternatives---How Have Other Communities
Addressed the Issues? What Are the Possible Alternatives?
Greenbelt is not unique in struggling with this issue. In this section, we include information on 4
topics that discuss alternative ways of approaching the issues.
• Examples of what has been done in Canada on the pesticide issue
• Examples from two US municipalities (Marin County CA; and Marblehead MA)
• The Maryland IPM In School Legislation
8/14/2007 11
12. • Organic Pest Management (OPM) and the Organic Land Care movement
2.4.1 Examples from Canada: Bans, Phase Outs, and Public
Education
• Bans and Phase Outs. Within Canada, as of 2006, about 70 municipalities, covering about
two-thirds of the population, have passed by-laws prohibiting the use of pesticides for
cosmetic reasons within their communities. These include major cities such as Toronto,
London and Montreal, as well as smaller jurisdictions such Hudson and, Port Mooney. An
example of such a by-law (Toronto) is presented in Appendix F. These by-laws have been
challenged in the courts in Canada by the pesticide industry. TruGreen-Chemlawn was a
major sponsor of these challenges. Recently Canada's top court upheld Toronto's pesticide
ban by refusing to hear an appeal brought by pesticide industry. Toronto's City Council
passed a by-law in 2003 outlawing cosmetic pesticide use on lawns and gardens. Much earlier
the Canadian courts in a case involving the town of Hudson ruled: “it is not necessary for
municipalities to prove or decide that it has proven the exact health effects of pesticides.
That there is cause for concern and that it is considered prudent to reduce pesticide
exposure is sufficient to pass a by-law controlling pesticides in the community.”
• These by-laws do not outlaw all pesticide use, but have clearly defined exceptions to the ban.
• Toronto and other municipalities have usually taken an approach of phasing in the
prohibitions over time and combined the ordinance with educational work. In the case of
Toronto, polling of residents found that most residents did not use pesticides, however
enough used lawn and garden pesticides that the effects were measurable in the urban
streams in the spring and summer. Toronto found that a large majority of even those
residents currently using pesticides were in favor of the ban. The by-laws provided the
impetus to actually change the behavioral norms for accepted and desirable
landscaping behavior.
• In 2004, a best practice review was done to assess the effectiveness of the by-laws and
educational campaigns in pesticide reduction as measured by surveys and sales of pesticides.
The study included 62 communities, and an in-depth study of results in 9 communities,
including 3 in the United States and 2 in Europe. The remainder was in Canada. The study
concluded that:
Only those communities that passed a by- law and supported it with
education or made a community agreement were successful in reducing the
use of pesticides by a high degree (51-90%) (see summary table below).
Education and outreach programs alone, while more popular than by-laws, are far
less effective. We could find none that have achieved more than a low reduction (10-
24%) in pesticide use to date. (The Impact of By-Laws and Public Education Programs on
Reducing the Cosmetic/Non-Essential, Residential Use of Pesticides: A Best Practice Review.
Kassirer Jay, Koswan, and Wolnick Chris. Jointly prepared by the Canadian Centre
for Pollution Prevention and Cullbridge Marketing and Communications, March
2004).
8/14/2007 12
13. They also found that controversy itself resulted in reduced use. For example, the publicity
around the Hudson legal challenge led to large reductions in pesticide use, prior to the
favorable court decision. The Executive summary is included in appendix G. The complete
report can be found at:
http://www.c2p2online.com/documents/Jay_Kassirer.pdf
2.4.2 Mandating and Defining Integrated Pest Management (IPM)-
--Maryland IPM In-Schools Legislation
In 1998 and 1999, the Maryland State Legislature passed legislation that mandated that schools in
Maryland follow and an IPM program and that “pesticides are only to be considered as an option
when non-toxic options are unreasonable or have been exhausted, in order to a) minimize the use of
pesticides and b) minimize the risk to human health and the environment associated with pesticide
applications.” The law also mandates including potential adverse health effects from exposure to the
pesticides in the notices provided to parents/guardians and employees prior to applications and after
emergency applications of pesticides.
According to the Maryland Pesticide Network report, Are We Passing the Grade? Assessing MD Schools’
Compliance with IPM-In-Schools Law, published in 2004) implementation has been mixed and confused
by a manual that did not track well to the legislation especially the definition of IPM in the
8/14/2007 13
14. legislation. Specifically they noted that schools were not properly instructed to exhaust all other
alternatives before using pesticides and to enact the strict notification provisions. However, they
note that some school systems such as Ann Arundal and Montgomery are examples of successful
implementation. As described in Safer Schools, a National Report, published in April 2003:
Richard Stack, IPM supervisor for Montgomery County schools, coordinates one of the
nation’s longest running school IPM programs...He believes that “pesticides are 99%
unnecessary.” The IPM crew for these schools removes hornet nests manually, catches rodents
in traps instead of relying on pesticides, and uses vacuum cleaners to eliminate small insect
pests. School building and cafeteria staff receive annual training regarding the IPM-in-
Schools program, and each school is monitored at least twice monthly for pest issues and
IPM compliance, a process involving intensive inspection of food service areas, trash rooms,
loading docks, and interviews with building services managers. The Montgomery schools
program has succeeded largely because of preventive measures taken by the schools,
including sanitation, heat treatment, sand blasting, biological management, and pest
exclusion. The schools have altered storage practices, storage shelving designs, and food
inspection practices in order to prevent pests on school grounds and in school buildings.(As
presented in: Are We Passing the Grade? Assessing MD Schools’ Compliance with IPM-In-Schools Law,
September 2004)
The report notes that in addition to adherence to the legal instructions with regard to IPM
“Education in the form of workshops, training sessions, and written materials is an essential
component of an IPM program for everyone from administrators, teachers, maintenance, personnel,
cafeteria staff and nurses to parents and students. Regular monitoring, record keeping, and
evaluation are also necessary to guarantee a successful IPM.”
2.4.3 Other Innovative US Ordinances
Within the United States, there are fewer communities that have adopted laws such as Canada;
however there are a number of jurisdictions that have passed pesticide legislation. We note two
below.
• Marin County California, Integrated Pest Management (IPM) legislation passed in 1998
includes specific goals for reduction in pesticide use from 1997 (by 75 percent by the year
2004) and also not using pesticides unless other alternatives are tried.
• A more recent example (2005), is that of a small town in Massachusetts-- Marblehead–a
town in which the Department of Health has mandated Organic Pest Management
(OPM) for city property. A copy of their ordinance is included in Appendix H. This
legislation is notable in that it embraces a positive alternative, rather than simply a ban as
most of the Canadian legislation does.
8/14/2007 14
15. 2.4.4 The Organic Pest Management and the Organic Land Care
Movement in Landscaping
As defined in the Marblehead legislation:
Organic Pest Management is a problem-solving strategy that prioritizes a natural, organic
approach to turf grass and landscape management without the use of toxic pesticides. It mandates
the use of natural, organic cultural practices that promote healthy soil and plant life as a preventative
measure against the onset of turf and landscape pest problems.
Essential OPM practices include, but are not limited to:
• regular soil testing;
• addition of approved soil amendments as necessitated by soil test results, following, but
not limited to, the recommendations of NOFA/Mass (Northeast Organic Farmers’
Association/Mass) and/or the Organic Material Review Institute of Eugene, OR;
• selection of plantings using criteria of hardiness; suitability to native conditions; drought,
disease and pest-resistance; and ease of maintenance;
• modification of outdoor management practices to comply with organic horticultural
science, including scouting, monitoring, watering, mowing, pruning, proper spacing, and
mulching;
• the use of physical controls, including hand-weeding and over-seeding;
• the use of biological controls, including the introduction of natural predators,
and enhancement of the environment of a pest’s natural enemies;
• through observation, determining the most effective treatment time, based on pest
biology and other variables, such as weather and local conditions; and eliminating pest
habitats and conditions supportive of pest population increases.
Organic Land Care. Recently in the United States and Canada, there have been efforts to apply
organic farming principles and standards to urban and suburban land care and management. The
Northeast Organic Farming Association (NOFA) and SOUL (Society of Organic Urban Land Care)
have developed organic land care standards and also have developed educational and certification
programs for land care professionals. They noted that the landscape industry is undergoing rapid
change as it responds to a growing demand for organic practices.
• The Northeast Organic Farming Association Organic Land Care Committee for
Connecticut and Massachusetts has prepared a set of standards for organic land care.
REAC has a copy of these standards. They have also prepared a Citizens Guide that can be
downloaded and they offer periodic courses that can result in certification for landscape
professionals. They also maintain a listing of certified land care professionals on their web site
and there are two listings from Maryland on the site http://www.organiclandcare.net/about.php
8/14/2007 15
16. • Within their Citizens Guide they note: “The guiding principle of organic land care is
ecological stewardship.’ They note:
The watchword, as in the ancient medical tradition, is “First, do no harm.”
This applies to many aspects of the health of the land and the people living on it.
One of the most harmful practices to be avoided is the use of synthetic chemicals
like pesticides and fertilizers. Important objectives of organic land care include:
Working with natural systems to enhance biological cycles rather than seeking to
dominate them; Maintaining and improving the long-term health of soils; Avoiding
pollution when creating or caring for landscapes (NOFA, Citizens Guide to Organic
Land Care 2004).
• The CT-Mass NOFA Standards for Organic Land Care cover all aspects of land care,
including: site analysis, soil health, fertilizers and soil amendments, planting and plant care, lawn
and lawn alternatives, invasive plants, weeds, mulches, pest management, wildlife management,
and disease control.
• For each of these areas, the standards include an overview and management practices
that are designated as preferred, allowed, or prohibited. Preferred practices and materials
are those considered to be ecologically appropriate and in accordance with the goals of organic
land care. Allowed practices and materials are acceptable when needed but should be reduced in
favor of the preferred alternatives. Prohibited practices and materials are not acceptable in
organic land care.
• According to the SOUL website: “Organic land care practices go beyond Integrated
Pest Management (IPM), beyond the use of so-called organic fertilizers and pesticides. They
acknowledge the concept of intrinsic health, and seek to create environments that cater to the
well-being of all their inhabitants. Organic land care professionals know that they are but
stewards of the land, and can at best hope to work WITH nature, never to dominate it.”
• SOUL Certified Organic Land Care Professionals are certified to have the knowledge
and experience to provide Organic Land Care according to the SOUL Organic Land
Care Standard. The SOUL Organic Land Care Standard was developed to define the practice
of Organic Land Care for the public and for professionals in the industry. This standard clarifies
the term "organic", and is intended to protect the public from misleading claims and practices.
http://www.organiclandcare.org/certification/index.php
• In addition to the NOFA courses, Gaia College offers on-line programs in organic land
management. More information can be obtained at the site below.
http://www.organic-land-care.com/Gaia_College/programs/land_care/index.php
• In addition, The National Coalition for Pesticide-Free Lawns periodically offers an on-
line/telephone lunch time course entitled-- Organic Land Care Basic Training for
Municipal Officials and Transitioning Landscapers. This three-part teleconference explains
the Simple Steps to beginning an organic turf program and will cover the basic concepts,
methods, and materials needed to get started. The training is geared toward school or park and
recreation officials, however landscapers interested in transitioning are encouraged to attend (see
appendix I) for more information.
8/14/2007 16
17. 3. RECOMMENDATIONS
3.1 Step Five: Determine the Course of Action and
Recommendations
Step five involves taking all the information collected thus far to determine what needs to be done in
the specific issues before the working group? Is there a need to change or modify the behaviors that
were the cause of the initial concern? What is the best way to do this? What does the weight of
evidence lead to in terms of a course of action?
Thanks to the dedication of City Staff and high levels of citizen interest, REAC has concluded that
Greenbelt is in a position to be an innovative leader in Maryland in the efforts to promote the health
of its citizens and the Chesapeake Bay Watershed by endorsing and promoting best practice land
care stewardship throughout Greenbelt. We urge the City Council to do so in as many ways as
possible.
3.2 Specific Recommendations to Council
The following are 12 concrete steps, some with performance goals, which REAC urges the City of
Greenbelt to act upon in a timely manner. These recommendations have grown out of our two-year
review of pesticide use and its alternatives. REAC recommends that:
Adoption of Organic Land Care Standards and Organic Pest Management (OPM) for
Care of Public Lands and Phasing out of chemical pesticides by 2010
1. City Council set a goal for Greenbelt of meeting the Northeast Organic Farming
Association Standards for Organic Land Care and adopting a program of Organic Pest
Management (OPM) for all public lands of Greenbelt by January 2010. A copy of these
standards has been provided to city staff.
2. City Council set a goal of phasing out the cosmetic use of chemical pesticides on public
lands by 2010 and providing City staff with adequate resources to do so. By cosmetic use is
meant any use other than the direct protection of the public and environmental health.
Organic Land Care and Pesticide Use Monitoring Group
3. City Council instruct REAC to establish a citizen Organic Land Care and Pesticide Use Working
and Monitoring Group that will be tasked with supporting and monitoring the implementation
of Organic Land Care practices within the city. Every two years this group would review
the City’s progress in phasing out the cosmetic use of pesticides by the City and substitution
of Organic Pest Management and Organic Land Care.
8/14/2007 17
18. Formal Written Policies and Procedures for Organic Land Care for City Staff and
Contractors
4. City staff develop formal written policy and procedures with regard to pesticide use by
Public Works staff that is consistent with goals noted above of meeting Organic Land Care
and Organic Pest Management standards and the “pesticide as the last resort” guideline as
defined in the Maryland Integrated Pest Management in Schools legislation in its’
implementation of IPM.
5. The City require best Organic Pest Management and Organic Land Care practices among its
contractors, and should include clauses in contracts requiring use of Organic Pest
Management and Organic Land Care. The City should favor local businesses whenever
possible.
Citizen Right to Know
6. City staff be required to report to the public on a yearly basis the brand names, listed
ingredients, EPA ratings, planned locations, and amount and frequency of use of any
pesticides applied to public lands within Greenbelt by the city staff or city contractors, and
that this be publicized in a widely read publication, such as the News Review, well ahead of
dates of application.
City Staff Training and Professional Development
7. Council provide funding for adequate training and professional development in Organic
Land Care methods for city staff such as the organic land care certification programs now
offered by the Northeast Organic Farming Association (NPFA), Society for Organic Urban
Land Care (SOUL), and other groups.
Partnerships with Other Government Entities, Local Businesses, and Citizen Groups
8. The city of Greenbelt partner wherever possible with: federal, state, other local government
entities, national and local environmental and watershed groups; and other interested civic
groups in obtaining funding, technical support, and volunteers to help achieve the goal of
Organic Land Care for Greenbelt by 2010.
A Comprehensive Study of All of Greenbelt’s Impact--with Metrics and assessment of what
Must be Done to Reduce Pollution and Restore Health of the Chesapeake Bay.
9. REAC recommends that the City seek funding and/or volunteers to conduct
comprehensive study designed to assess impact from Greenbelt upon the Chesapeake Bay
Watershed, and develop specific goals, metrics, and practices that will be necessary to
reduce the on-going environmental degradation. As noted in the body of this report, The
Chesapeake Bay has been described as a “system in crisis,” and on a per acre basis the urban
areas have been estimated to contribute 7 times the pollution into the Bay as rural areas.
10. The study should also address the impact of land care practices and pesticide use by private
citizens and businesses within Greenbelt. REAC was able to find little information about
the extent of pesticide and chemical fertilizer use by residents and businesses. As we
proceeded, we became convinced that addressing citizen use on private property must be a
significant part of any effort to reduce usage. The study might also access public support for
8/14/2007 18
19. policies or legislation that would prohibit pesticide use for cosmetic purposes. The city
should also seek counsel concerning the legality of legislation such as the Canadian By-laws
against cosmetic use of pesticides within Maryland.
Public Outreach and Education Campaign
11. The City and partners engage in a strong public education campaign designed to inform
residents of Bay friendly and Organic Land Care, and to provide interested citizens with
knowledge of alternatives to pesticide use. Outreach and education tools include:
household brochures, workshops, Greenbelt Recreation Department courses, and
experimental community demonstration gardens.
Appreciation, Encouragement, and Rewards for City Staff
12. City staff be given appreciation, encouragement, and rewards for their efforts to transition
the city to Organic land Care and help to restore the Chesapeake Bay Watershed. Thanks to
the efforts of dedicated city staff, Greenbelt is known for its beautiful gardens, and
hopefully will soon be known as a leader and innovator in the area of Organic Land Care.
3.3 Step Six: Monitor and Follow Up
No matter what action is taken, it is critical to monitor that activity over time to identify expected
and unexpected results. All of the recommendations noted above should be monitored and
follow-up should be incorporated into the actions.
8/14/2007 19
20. Appendix A---Summary Report by Greenbelt Public Works
Staff
PESTICIDE SUMMARY
Pesticides are not used routinely on the majority of City-managed property and there has
been a significant reduction in the variety, toxicity, and amount of pesticides used by City crews
over the last 10 years. For example:
• Less than 10% (estimate) of the 450 acres of developed parkland and landscape areas
are treated with pesticides annually.
• Less than 1% (estimate) of the 7,300 street trees maintained by city crews are treated
with pesticides annually.
• Less than 5% (estimate) of the 27 miles of rights of way are treated with pesticides
annually.
• Less than 25% (estimate) of the 70 acres of turf/ballfields are treated with pesticides
annually. This year because of a severe grub infestation 75% of fields were treated. At
Schrom Hills Park alone, we estimate over 50% of the turf was killed.
When pesticides are used, they are part of an integrated program of controls, known as
“Integrated Pest Management,” which encourages use of non-chemical approaches - such as
physical, mechanical, and biological – over chemical. The City horticulture staff is very
familiar with the theories, practices and processes of IPM which have been used by the City of
Greenbelt for many years. Management strategies of IPM will vary from one situation to
another, location to location, and year to year, based on changes in pest populations. IPM
focuses on developing an understanding of and an ability to monitor the grounds ecosystem, and
addresses topics such as weed and insect identification, pest monitoring, and how to protect
pests’ natural enemies. The following details provide an overview of general pesticide
application practices (following IPM) for those sites where pesticides are used:
• Pesticides are applied by or under close supervision of a certified pesticide applicator.
(The City currently has four Certified Pesticide Applicators and an additional four
Registered Pesticide Applicators. The State of MD trains, tests and registers Certified
Pesticide Applicators. Registered Pesticide Applicators are trained and tested in-house
by Certified Pesticide Applicators and are registered with the State. The Registered
Pesticide Applicators are supervised by Certified Pesticide Applicators.)
• Pesticides are only applied when weather conditions permit.
• Low-toxicity pesticides are used.
• Pesticide applicators receive annual re-certification training and additional integrated pest
management training.
• Pesticide applications are accompanied by public notification (signs).
• Pesticide inventories and pesticide application records are kept.
The City primarily purchases Category III pesticides in an effort to use the least toxic option
for each control issue. To further reduce pesticide use, the horticultural staff now uses a large
volume of organic controls (nematodes, beneficial fungal and bacterial products, mulching in
8/14/2007 20
21. lieu of pre-emergent herbicides) and is evaluating ways to expand uses of these controls.
(Pesticides have not been used in City playgrounds since Spring 2005. Weeds have been
controlled through heavy mulching – and changing of mulch when weeds do appear.)
Bill Phelan, Assistant Director of Public Works, authorizes both the purchasing of all
pesticides and the application of all pesticides by the horticultural staff. A chart is attached
detailing all pesticides used by the City.
Pesticide Free Cities
There are a number of cities in Europe and Canada and a few cities in the United States
(primarily in the northwest) that are “pesticide free”. However, after researching the cities in the
US, they have not totally eliminated the use of pesticide but have only designated certain parks
and playgrounds as “pesticide free.” There are a number of things that are still treated in the
pesticide free parks when needed:
• Infestation of noxious weeds that cannot be mowed or controlled by other means.
• Sprays to control wasp and hornet nests around restrooms and shelters.
• Treatment of stagnant water to control mosquito larva.
• Treatment of over population of pests such as grubs, cutworms, ticks and bagworms
when alternate means have not controlled the problem and further infestation will
cause significant damage.
If pesticide use was eliminated in city-maintained parks, playgrounds, ballfields, landscape
beds, it would be a major challenge for us to keep the same level of citizen satisfaction in the
appearance of the parks with these new policies. Even with using best practices and alternative
means of control, we feel labor cost would need to increase significantly to keep up with
weeding landscape beds and replacement of diseased plant materials, additional equipment will
need to be purchased, and some landscape areas will need to be redesigned. It would also
require additional dollars to be spent on alternative product purchases. As an example, treating
grubs in turf with nematodes is several times more expensive than treatment with the products
currently being used and has a much greater chance of failing to control the grubs. There are
significant concerns that our inability to use pesticides may reduce the quality of our parks and
could threaten the long-term health of the City’s parks, trees, shrubs and flowers.
8/14/2007 21
22. PLAYGROUNDS
Playgrounds Equip. Maint. Landscaping Mowing
1 court Crescent City City Contract
2 court Northway City City Contract
3 court Gardenway City City Contract
14 court Laurel Hill City City Contract
54 court Crescent City City Contract
Community Center City City Contract
Greenbriar Park City City Contract
Ivy & Lastner City City Contract
SHL Comm. Ctr. City Contract Contract
St. Hugh’s City City Contract
1 court Southway City City Contract
2 court Southway City City Contract
5 court Gardenway City City Contract
39 court Ridge City City Contract
73 court Ridge City City Contract
Buddy Attick Park City City City
Fayette Place City City Contract
GreenSpring Park City Contract Contract
Plateau & Ridge City City Contract
Schrom Hills Park City City City
Westway City City Contract
2 court Laurel Hill City GHI GHI
4 court Plateau City GHI GHI
8 court Southway City GHI GHI
38 court Ridge City GHI GHI
2 court Research City GHI GHI
7 court Southway City GHI GHI
12 court Hillside City GHI GHI
44 court Ridge City GHI GHI
Greenwood Village City Greenwood Greenwood
7128 Ora Glen Court City Windsor Green Windsor Green
7251 South Ora Ct. City Windsor Green Windsor Green
7854 Jacobs Drive City Windsor Green Windsor Green
7230 Mandan Road City Windsor Green Windsor Green
7356 Frankfort Dr. City Windsor Green Windsor Green
8301 Canning Terr. City Windsor Green Windsor Green
The City has not used chemicals on playgrounds since Spring of 2005. Weeds have been
controlled by heavy application of engineered wood fibers – or removal of old surfacing and
weeds and replacement with new surfacing when weeds are too numerous to hand pull.
However, specific problems could develop in the future and it may be necessary to treat
playgrounds with chemicals; i.e. insect infestation of trees.
8/14/2007 22
23. BALLFIELDS & LANDSCAPE AREAS
Landscaping/
Maintenance Mowing
Ballfields
Braden Field City City
Northway Field City City
Schrom Hills City City
Mandan Road City City
McDonald Field City City
Landscape Beds
Windsor Green City & Contract Contract
Springhill Lake City & Contract Contract
Greenbriar City & Contract Contract
Greenbrook Estates City & Contract Contract
Schrom Hills City City
Buddy Attick Park City City
Glen Oaks City & Contract Contract
Hanover – Bus. Side City & Contract Contract Includes 2 circles
Southway City Contract Includes 193@Sway beds
Underpasses
Hillside Underpass City Contract
Gardenway City Contract
Underpass
Library Underpass City Contract
Roosevelt Center City Contract
Underpass
Facilities
Community Center City Contract
Youth Center City Contract
Police Facility City Contract
Public Works City Contract
City Office Bldg. City Contract
Museum City Contract
Springhill Lake Rec City & Contract Contract
Buddy Attick Park City City
Schrom Hills City City
8/14/2007 23
24. PESTICIDES USED BY THE CITY
All pesticides are grouped by the EPA into one of four categories based on acute toxicity. Category I
is the most toxic and category IV the least toxic.
Category III and IV- Slightly Toxic to Relatively Non-Toxic
Chemical Current Use Option to Chemical *Frequency Size of Type of Area
and of Use Treatment Area Treated
Signal
Word
Manage Selective control No effective treatment Limited Less than 1,000 Landscape beds
Caution of nutsedge available sf.
Dipel Pro Pest control on Insecticidal soaps – 50% Rare 10,000 sf. – Street Trees
(Organic) ornamentals efficiency 25,000 sf.
Caution Beneficial insects/
remove & replace plants
Merit Pest control in Beneficial nematodes in Turf- rare >100,000 sq ft of Ballfields,
Caution turf and turf- not always Ornamentals- turf treated this Azaleas, German
ornamentals effective. Limited year due to heavy Irises, some
Replace ornamentals infestations in daylilies
with resistant varieties ballfield turf
Mach2 Pest control in Beneficial nematodes in One time >100,000 sq ft Ballfields
Caution turf turf- not always treated this year
effective. due to heavy
infestations in
ballfield turf
Bayleton Fungal control Remove and replace One Time 1,000 sf. – 9,999 Hawthorne trees
Caution on ornamentals trees, shrubs & flowers sf. for severe
Quince rust
Princep Pre-emergent Hand weeding Rare Less than 1,000 Tree & shrub
Caution vegetation Corn gluten- sf. beds where
control tried/ineffective weeds are out of
control
Acclaim Post emergent Hand remove (Used for One Time 1,000 sf. – 9,999 Ballfields
Caution grass control crabgrass and sf.
goosegrass)
Snapshot Pre-emergent Hand weeding Rare 1,000 sf. – 9,999 Landscape beds
Caution vegetation Corn gluten- sf. where weeds are
control tried/ineffective out of control
Roundup Non-selective Torch type machine n/a Not currently used Landscape beds,
Pro vegetation (Propane Burner), because Kleenup Sidewalk crack
control horticultural vinegar- Pro is same weeds,
Post Emergent neither kills the root product at ½ the Infields of
cost ballfields
* Frequency of Use:
Limited - Specific areas treated as needed approximately 1-2 times annually.
Rare – Specific areas treated as needed less than one time per year.
One Time – Specific weed problems treated one time within past 20 years. At some point specific problem may reappear and another treatment may be
required.
8/14/2007 24
25. Category II- Moderately Toxic
(The three products used in this category have oral and dermal toxicities in the category III &IV range,
but eye contact with the straight chemical will cause substantial damage)
Chemical Current Use Option to Chemical *Frequency Size of Type of Area
and of Use Treatment Area Treated
Signal
Word
Finale Post emergent None (Only used for Rare Less than 1,000 Landscape beds
Warning- vegetation horsetails) This weed sf.
eye control has a severe root system
contact and cannot be hand
causes pulled.)
substantial
damage
Dimension Pre-emergent Hand remove One Time 50,000 sf. Used once at
Warning - turf control Mandan Field
eye
contact
causes
substantial
damage
**Kleen- Non-selective Torch type machine Limited > 100,000 sf. Landscape beds,
up Pro vegetation (Propane Burner), Sidewalk crack
Warning control horticultural vinegar- weeds,
Post Emergent neither kill the root Infields of
ballfields
** Kleen-up is a product with the same chemical composition as Round-Up Pro, but it contains a
different surfactant. Our best guess is that the surfactant in Kleenup is different and causes eye irritation,
which would create a need for a Warning label.
8/14/2007 25
26. Category I- Highly Toxic
(The two products used in this category have oral and dermal toxicities in the category III &IV
range,
but eye contact with the straight chemical will cause irreversible damage.)
Chemical Current Use Option to Chemical *Frequency Size of Type of Area
and Signal of Use Treatment Treated
Word Area
Confront Selective Hand pull them- Limited 50,000 sf. – Turf and
Danger- control of Corn Gluten- 100,000 sf. Ballfields
eye contact broadleaf expensive and not
can cause weeds in turf reliably effective
irreversible
damage.
Garlon 3a Used to treat Hand pull/backhoe- limited Less than 1000 Landscape
Danger- cut stumps of difficult and time sf Beds to kill
eye contact weed trees or consuming large weed
can cause shrubs trees primarily
irreversible by painting cut
damage. stumps
*Frequency of Use:
Limited - Specific areas treated as needed approximately 1-2 times annually.
Rare – Specific areas treated as needed less than one time per year.
One Time – Specific weed problems treated one time within past 20 years. At some point specific problem may
reappear and another treatment may be required.
8/14/2007 26
31. Appendix D---EPA CRITERIA FOR EVALUATION
OF CHEMICAL CARCINOGENICITY
Source: http://envirocancer.cornell.edu/turf/cancerRiskCat.cfm
The EPA evaluates chemical carcinogenicity using data from many types of studies.
• Most of the cancer risk information currently available is in the form of scientific results
from studies of laboratory animals, such as rats or mice.
• Other types of laboratory studies done at a smaller scale, such as individual cells, provide
information about a chemical's ability to damage DNA or promote tumor growth.
• Results from studies of groups of people exposed to certain chemicals, such as in the
workplace or a community, may provide additional valuable information about a chemical's
potential to cause cancer.
For many chemicals, however, no human data are available, so we must rely on data from laboratory
and animal studies. Information on the species of laboratory animal tested, and the tumor types
observed, provides some information about the extent to which the chemical may be carcinogenic.
This information is just part of the total information EPA uses to estimate cancer risk. Other
information from human studies and laboratory analyses is not currently available from EPA for use
in the Turf Pesticides and Cancer Risk database.
EPA's cancer risk classification systems and categories
In classifying the cancer risk of a particular chemical, EPA uses a combination of all of these types
of evidence to arrive at a cancer risk category. EPA's cancer risk assessment methods have changed
over the years to accommodate new scientific understanding. As a result, the four EPA cancer risk
classification systems cannot be combined or used interchangeably due to the different methods
used.
Pesticide products
Cancer risk categories do not apply directly to pesticide products. Rather, cancer risk information
pertaining to the product's active ingredient(s) can be used in combination with other information to
estimate potential risk.
• Estimating the cancer-causing potential of a specific pesticide product involves many factors,
such as the amount of active ingredient contained in the product, the application methods
and rates used, proper use of personal protective equipment, and frequency and degree of
exposure to the pesticide over time.
• Current federal pesticide labeling laws require pesticide manufacturers to include only acute
(short-term), and not chronic (long-term) health risk information on pesticide labels.
Therefore, product-specific cancer risk information is not available.
• Some states, such as California and Massachusetts, require that pesticides sold in those states
carry labels specifying whether or not the product's active ingredients have been identified as
health hazards, such as carcinogens, reproductive toxins, etc. Other states may include this
information on their labels as well.
8/14/2007 31
32. Using RED documents and other pesticide review information
Re-registration Eligibility Decision, or 'RED', documents are risk assessment reports done by EPA
to determine whether or not to continue the registration of older pesticide products. Older
pesticides (those first registered before 1984) must be re-evaluated by EPA to ensure that they meet
current health and safety standards. RED documents are publicly available and are included process.
This process, which will take effect October 10, 2006, was established to ensure that all pesticides
distributed and sold in the U.S. (not just older pesticides or those used on food crops) will be re-
evaluated on a periodic basis to ensure they meet current health and safety standards. For more
information, see Pesticide Registration. As pesticides are reviewed as part of this process, risk
information will be added to the Turf Pesticides and Cancer Risk Database as it becomes available.
2005 USEPA Cancer Risk Classification
The following descriptors from the 2005 Guidelines for Carcinogen Risk Assessment can be used as an
introduction to the weight of evidence narrative in the cancer risk assessment. The examples presented in the
discussion of the descriptors are illustrative. The examples are neither a checklist nor a limitation for the
descriptor. The complete weight of evidence narrative, rather than the descriptor alone, provides the
conclusions and the basis for them.
Carcinogenic to Humans
This descriptor indicates strong evidence of human carcinogenicity. It covers different combinations of
evidence.
• This descriptor is appropriate when there is convincing epidemiologic evidence of a causal
association between human exposure and cancer.
• Exceptionally, this descriptor may be equally appropriate with a lesser weight of epidemiologic
evidence that is strengthened by other lines of evidence. It can be used when all of the following
conditions are met:
a. there is strong evidence of an association between human exposure and either cancer or the
key precursor events of the agent's mode of action but not enough for a causal association,
and
b. there is extensive evidence of carcinogenicity in animals, and
c. the mode(s) of carcinogenic action and associated key precursor events have been identified
in animals, and
d. there is strong evidence that the key precursor events that precede the cancer response in
animals are anticipated to occur in humans and progress to tumors, based on available
biological information. In this case, the narrative includes a summary of both the
experimental and epidemiologic information on mode of action and also an indication of the
relative weight that each source of information carries, e.g., based on human information,
based on limited human and extensive animal experiments.
Likely to be Carcinogenic to Humans
This descriptor is appropriate when the weight of the evidence is adequate to demonstrate carcinogenic
potential to humans but does not reach the weight of evidence for the descriptor "Carcinogenic to Humans."
Adequate evidence consistent with this descriptor covers a broad spectrum. As stated previously, the use of
the term "likely" as a weight of evidence descriptor does not correspond to a quantifiable probability. The
examples below are meant to represent the broad range of data combinations that are covered by this
descriptor; they are illustrative and provide neither a checklist nor a limitation for the data that might support
8/14/2007 32
33. use of this descriptor. Moreover, additional information, e.g., on mode of action, might change the choice of
descriptor for the illustrated examples. Supporting data for this descriptor may include:
• an agent demonstrating a plausible (but not definitively causal) association between human
exposure and cancer, in most cases with some supporting biological, experimental evidence,
though not necessarily carcinogenicity data from animal experiments;
• an agent that has tested positive in animal experiments in more than one species, sex, strain,
site, or exposure route, with or without evidence of carcinogenicity in humans;
• a positive tumor study that raises additional biological concerns beyond that of a statistically
significant result, for example, a high degree of malignancy, or an early age at onset;
• a rare animal tumor response in a single experiment that is assumed to be relevant to
humans; or
• a positive tumor study that is strengthened by other lines of evidence, for example, either
plausible (but not definitively causal) association between human exposure and cancer or
evidence that the agent or an important metabolite causes events generally known to be
associated with tumor formation (such as DNA reactivity or effects on cell growth control)
likely to be related to the tumor response in this case.
Suggestive Evidence of Carcinogenic Potential
This descriptor is appropriate when the weight of evidence is suggestive of carcinogenicity; a
concern for potential carcinogenic effects in humans is raised, but the data are judged not sufficient
for a stronger conclusion. This descriptor covers a spectrum of evidence associated with varying
levels of concern for carcinogenicity, ranging from a positive cancer result in the only study on an
agent to a single positive cancer result in an extensive database that includes negative studies in other
species. Depending on the extent of the database, additional studies may or may not provide further
insights. Some examples include:
• a small, and possibly not statistically significant, increase in tumor incidence observed in a
single animal or human study that does not reach the weight of evidence for the descriptor
"Likely to Be Carcinogenic to Humans." The study generally would not be contradicted by
other studies of equal quality in the same population group or experimental system (see
discussions of conflicting evidence and differing results, below);
• a small increase in a tumor with a high background rate in that sex and strain, when there is
some but insufficient evidence that the observed tumors may be due to intrinsic factors that
cause background tumors and not due to the agent being assessed. (When there is a high
background rate of a specific tumor in animals of a particular sex and strain, then there may
be biological factors operating independently of the agent being assessed that could be
responsible for the development of the observed tumors.) In this case, the reasons for
determining that the tumors are not due to the agent are explained;
• evidence of a positive response in a study whose power, design, or conduct limits the ability
to draw a confident conclusion (but does not make the study fatally flawed), but where the
carcinogenic potential is strengthened by other lines of evidence (such as structure-activity
relationships); or
• a statistically significant increase at one dose only, but no significant response at the other
doses and no overall trend.
8/14/2007 33
34. Inadequate Information to Assess Carcinogenic Potential
This descriptor is appropriate when available data are judged inadequate for applying one of the
other descriptors. Additional studies generally would be expected to provide further insights. Some
examples include:
• little or no pertinent information;
• conflicting evidence, that is, some studies provide evidence of carcinogenicity but other
studies of equal quality in the same sex and strain are negative. Differing results, that is,
positive results in some studies and negative results in one or more different experimental
systems, do not constitute conflicting evidence, as the term is used here. Depending on the
overall weight of evidence, differing results can be considered either suggestive evidence or
likely evidence; or
• negative results that are not sufficiently robust for the descriptor, "Not Likely to Be
Carcinogenic to Humans."
Not Likely to be Carcinogenic to Humans
This descriptor is appropriate when the available data are considered robust for deciding that there is
no basis for human hazard concern. In some instances, there can be positive results in experimental
animals when there is strong, consistent evidence that each mode of action in experimental animals
does not operate in humans. In other cases, there can be convincing evidence in both humans and
animals that the agent is not carcinogenic. The judgment may be based on data such as:
• animal evidence that demonstrates lack of carcinogenic effect in both sexes in well-designed
and well-conducted studies in at least two appropriate animal species (in the absence of
other animal or human data suggesting a potential for cancer effects),
• convincing and extensive experimental evidence showing that the only carcinogenic effects
observed in animals are not relevant to humans,
• convincing evidence that carcinogenic effects are not likely by a particular exposure route, or
• convincing evidence that carcinogenic effects are not likely below a defined dose range.
A descriptor of "not likely" applies only to the circumstances supported by the data. For example, an
agent may be "Not Likely to Be Carcinogenic" by one route but not necessarily by another. In those
cases that have positive animal experiment(s) but the results are judged to be not relevant to
humans, the narrative discusses why the results are not relevant.
Multiple Descriptors
More than one descriptor can be used when an agent's effects differ by dose or exposure route. For
example, an agent may be "Carcinogenic to Humans" by one exposure route but "Not Likely to Be
Carcinogenic" by a route by which it is not absorbed. Also, an agent could be "Likely to Be
Carcinogenic" above a specified dose but "Not Likely to Be Carcinogenic" below that dose because
a key event in tumor formation does not occur below that dose.
8/14/2007 34
35. Appendix E---EXAMPLES OF CANCER RISK
ASSESSMENT
Summary report on Oryzalin (EPA number 72167-15-74477) an active
ingredient in the MANAGE product (first product on the city list)
Cancer Risk Information
1999
USEPA Cancer Risk Category: Likely to be Carcinogenic to Humans
Species and Tumor Types: Multiple sites (thyroid, mammary); F344 rats (M & F).
NOTE: Cancer risk classifications are specific to active ingredients, not products. To arrive at an
overall health or cancer risk evaluation for a pesticide product, active ingredient cancer risk
information should be used together with other risk and exposure information, such as USEPA Risk
Management Decision Documents (REDs, IREDs, TREDs, and others).
Summary report on ingredient Sodium Acifluorfen listed under
KleenUP in the
http://envirocancer.cornell.edu/turf/searchProdMore.cfm?key=272
95 data base
Cancer Risk Information
Other
USEPA Cancer Risk Category: Likely to be Carcinogenic to Humans (High Doses); Not
Likely to be Carcinogenic to Humans (Low Doses)
Species and Tumor Types: Liver; B6C3F1 & CD-1 mice (M& F).
NOTE: Cancer risk classifications are specific to active ingredients, not products. To arrive at an
overall health or cancer risk evaluation for a pesticide product, active ingredient cancer risk
information should be used together with other risk and exposure information, such as USEPA Risk
Management Decision Documents (REDs, IREDs, TREDs, and others).
8/14/2007 35
36. Appendix F---PESTICIDE BY-LAW OF THE CITY
OF TORONTO
PESTICIDES, USE OF
§ 612-1. Definitions.
§ 612-2. Restrictions.
§ 612-3. Offences.
[HISTORY: Adopted by the Council of the City of Toronto 2003-05-23 by By-law
No. 456-2003.1 Amendments noted where applicable.]
GENERAL REFERENCES
1
Editor’s Note: This by-law was passed under the authority of section 130 of the Municipal Act, 2001, S.O. 2001, ch. 25.
Section 2 of this by-law states that it comes into force 2004-04-01.
Property standards — See Ch. 629.
§ 612-1. Definitions.
As used in this chapter, the following terms shall have the meanings indicated:
ENCLOSED — Closed in by a roof or ceiling and walls with an appropriate opening or openings
for ingress or egress, which openings are equipped with doors which are kept closed except when
actually in use for egress or ingress.
HEALTH HAZARD — A pest which has or is likely to have an adverse effect on
the health of any person.
INFESTATION — The presence of pests in numbers or under conditions which involve an
immediate or potential risk of substantial loss or damage.
PEST — An animal, a plant or other organism that is injurious, noxious or troublesome, whether
directly or indirectly, and an injurious, noxious or troublesome condition or organic function of
an animal, a plant or other organism.
PESTICIDE — Includes: A. A product, an organism or a substance that is a registered control
product under the federal Pest Control Products Act which is used as a means for directly or
indirectly controlling, destroying, attracting or repelling a pest or for mitigating or preventing its
injurious, noxious or troublesome effects.
B. Despite Subsection A, a pesticide does not include:
TORONTO MUNICIPAL CODE
§ 612-2 PESTICIDES, USE OF
612-2 2005 - 02 - 16
(1) A product that uses pheromones to lure pests, sticky media to trap pests or “quick-kill” traps
for vertebrate species considered pests, such as mice and rats.(2) A product that is or contains
only the following active ingredients:
[Amended 2004-05-20 by By-law No. 385-2004]
(a) A soap;
(b) A mineral oil, also called “dormant or horticultural oil”;
(c) Silicon dioxide, also called “diatomaceous earth”;
(d) Biological pesticides, including Bt (bacillus thuringiensis) and
nematodes; [Amended 2005-02-16 by By-law No. 121-2005]
(e) Borax, also called “boric acid” or “boracic acid”;
(f) Ferric phosphate;
8/14/2007 36
37. (g) Acetic acid;
(h) Pyrethrum or pyrethrins;
(i) Fatty acids;
(j) Sulphur; or
(k) Corn gluten meal.
§ 612-2. Restrictions.
A. No person shall apply or cause or permit the application of pesticides within the
boundaries of the City.
B. The provision set out in Subsection A does not apply when pesticides are used:
(1) To disinfect swimming pools, whirlpools, spas or wading pools;
(2) To purify water intended for the use of humans or animals;
(3) Within an enclosed building;
(4) To control termites;
(5) To control or destroy a health hazard;
(6) To control or destroy pests which have caused infestation to property;
(7) To exterminate or repel rodents;
(8) As a wood preservative;
TORONTO MUNICIPAL CODE
PESTICIDES, USE OF § 612-3
612-3 2005 - 02 - 16
(9) As an insecticide bait which is enclosed by the manufacturer in a plastic or
metal container that has been made in a way that prevents or minimizes access
to the bait by humans and pets;
(10) For injection into trees, stumps or wooden poles;
(11) To comply with the Weed Control Act2 and the regulations made there under; or
(12) As an insect repellent for personal use.
§ 612-3. Offences.
Any person who contravenes any provision of this chapter is guilty of an offence and,
upon conviction, is liable to a fine or penalty provided for in the Provincial Offences Act.3
2
Editor’s Note: See R.S.O. 1990, c. W.5.
3
Editor’s Note: This section was passed under the authority of section 425 of the Municipal Act, 2001, S.O. 2001, ch. 25, and,
under section 61 of the Provincial Offences Act, R.S.O. 1990, c. P.33, a person convicted of an offence under this section is
liable to a fine of not more than $5,000.
8/14/2007 37
41. Appendix H--
TOWN OF MARBLEHEAD
BOARD OF HEALTH
ORGANIC PEST MANAGEMENT
REGULATIONS
Adopted: December 7, 2005
Effective: December 22, 2005
Carl D. Goodman, Esq., Chairman
David B. Becker, D.M.D., M.P.H.
Helaine R. Hazlett
Wayne O. Attridge, Director of Public Health
TOWN OF MARBLEHEAD
BOARD OF HEALTH
ORGANIC PEST MANAGEMENT REGULATIONS
SECTION I – FINDINGS & PURPOSE
The Board of Health does hereby find that:
All pesticides are toxic to some degree and the commonplace, widespread use of pesticides is
both a major environmental problem and a public health issue; and
All citizens, and in particular children, as well as other inhabitants of our natural environment,
have a right to protection from exposure to hazardous chemicals and pesticides in particular; and
A balanced and healthy ecosystem is vital to the health of the town and its citizens; and as such
is also in need of protection from exposure to hazardous chemicals and pesticides; and
8/14/2007 41