United States Environmental Protection Agency
Office of Prevention, Pesticides and Toxic Substances
February 23, 2004
Mr. Thomas H. Martin, Director
INL Latin American Programs
Department of State
2201 C Street, NW
Washington, DC 20520
Dear Mr. Martin:
This is a response to the Department of State's (DoS) request that the Environmental Protection Agency (EPA) review the Environmental Management Plan for the Illicit Crop Eradication Program in Colombia (EMP). Specifically, DoS asked EPA to assess whether use of the herbicide mixture in Colombia is in accordance with the EMP, as included in the Foreign Operations, Export Financing, and Related Programs Appropriations Act, 2002, (P.L. 108-7). As you know, in 2002, EPA was asked to consult regarding potential health and environmental effects from use of the glyphosate pesticide spray mixture for coca eradication. In 2003, our consultation considered both coca and poppy eradication efforts.
The Agency reviewed the EMP for comparison with applicable U.S. requirements for pesticide use and we believe the Plan contains appropriate types of activities for a pesticide spray program. The information in the EMP is generally in agreement with information provided to EPA for the previous consultations and discussed in EPA's 2002 and 2003 written assessments. The EMP provides additional information regarding the spray program, such as requirements for environmental monitoring, waste management, and contingency plans.
The EMP gives general descriptions of many activities related to this spray program, including references to relevant Colombian laws, which are to be followed. These activities include spray application requirements and restrictions, training and safety precautions for personnel who handle and apply the pesticide, handling of waste resulting from program operations, training public health workers to recognize and treat pesticide poisoning, handling health and environmental complaints, environmental monitoring, and contingency plans for emergencies. EPA recognizes that these types of activities are appropriate for pesticide spray programs and in general reflect similar activities which can be included for pesticide spray programs in the U.S., depending on the specific pesticide, use conditions, known potential risks, and Federal, state, or local laws. In general Federal requirements and restrictions for handling and using pesticides in the U.S. are specific to individual licensed pesticides for their permitted uses; requirements are stipulated on the labels of individual products.
There were two specific sections of the EMP that EPA would like to offer comments. First, according to the Domestic Solid Waste Management Program, empty pesticide containers may be used for collection of garbage or for building barriers after containers are "completely washed and perforated." However, pesticide product requirements in the U.S. prohibits reuse of containers and suggests disposal by appropriate means, unless the containers are collected by the manufacturer for refilling. We would urge DoS to investigate with the manufacturer or the Government of Colombia methods for properly disposing of these containers rather than reusing them. The second specific comment relates to the Environmental Monitoring Program which states there is no significant impact on plants that surround the illicit crops being sprayed. As our consultation documents of the past two years have stated, glyphosate is highly toxic to many plants. Some levels of adverse effects are likely to occur to some non-target plants as a result of spray drift, as can be expected with herbicide applications. The Agency suggests an appropriate revision of this wording.
I hope this information is helpful. If you have additional questions, please let me know.
Jay S. Ellenberger
Field and External Affairs Division
Office of Pesticide Programs