Pesticide Action Network Updates Service (PANUPS)
Three U.S. states have applied for an emergency exemption to use the highly toxic pesticide carbofuran--an insecticide known to be extremely toxic to birds and other wildlife--on up to 2.4 million acres of cotton.
The U.S. Environmental Protection Agency (U.S. EPA) is considering granting a Section 18 emergency exemption in Louisiana, Texas and Oklahoma for use of a flowable form of carbofuran to treat cotton aphids. U.S. EPA is reviewing this request even though safer and equally effective alternatives are available, and will rule on the exemption without consulting federal and state wildlife agencies. Write EPA and tell them that alternatives exist and that the Agency should not permit use of this dangerous chemical.
In the early 1990's, during a U.S. EPA Special Review of the granular form of carbofuran, the Director of the U.S. Fish and Wildlife Service (U.S. FWS) wrote multiple letters urging cancellation of all formulations of carbofuran. At that time, U.S. FWS wrote, "Laboratory data verify that carbofuran is among the most highly toxic pesticides to birds... Birds can be lethally exposed to carbofuran even when it is applied with great care... Despite extensive study, it has not been demonstrated that there are any conditions under which carbofuran can be used without killing birds." Scientists from around the U.S. concurred with these viewpoints. Nothing has occurred in the past 10 years to reduce the risks associated with carbofuran or to change those opinions.
As a result of the Special Review, almost all uses of the granular formulation were withdrawn from the market because of its high toxicity to birds. Given the high level of toxicity of all formulations and the similarities in exposure routes, the American Bird Conservancy suggests that the risks posed by the flowable form are as great, if not greater than those posed by the granular formulation. Animals can be exposed via ingestion of contaminated insects, soil or vegetation; by swimming or bathing or ingesting contaminated water; through respiratory inhalation; through dermal absorption from direct spray or contact with exposed foliage or soil; and via secondary poisoning when a predator or scavenger ingests another animal that has been exposed.
Carbofuran is also one of the pesticides most frequently reported in farmworker poisonings, with cotton one of the top five crops associated with worker poisonings. Carborufan, a chemical in the carbamate class, (see the PAN Chemical Database http://www.pesticideinfo.org/PCW/Detail_Chemical.jsp?Rec_Id=PC35055) is considered highly acutely toxic because exposure to this nerve toxin can cause immediate severe poisoning symptoms, including headache, nausea, vomiting, blurred vision and, in severe cases, seizures, cardio respiratory depression, and coma. The American Bird Conservatory reports that chemical and non-chemical alternatives to carbofuran are available and are safer, more effective, and economically feasible.
Birds killed by carbofuran include a large number of species protected under the Endangered Species Act and the Migratory Bird Treaty Act. The act requires U.S. EPA to consult with the U.S. FWS to assess the impacts on threatened and endangered species. U.S. EPA has not requested the required consultation for the current exemption request, nor has it consulted with wildlife agencies in these states to determine what species will be at risk.
Over 180 species of birds have been known to visit cotton fields. If the emergency exemption is granted, the impact on wildlife could be devastating because of the vast amount of acreage (up to 2.4 million acres), the amount of pesticide applied (up to 1.2 million pounds), the numbers of federally and state listed species likely to be present, the persistence of carbofuran- it can remain in the environment for up to 120 days, and the timing and location of the applications. Millions of migratory birds will be moving south during late summer and early fall along the Central Flyway, traversing Louisiana, Texas and Oklahoma.
Last July, without consultation with U.S. FWS or other agencies, U.S. EPA granted a permit for use of carbofuran on 10,000 acres of rice in Louisiana. Conservation groups quickly mobilized (see PANUPS, Stop Carbofuran Use, July 3, 2002). U.S. EPA then reduced the permit to 2,500 acres, and promised to open a public comment period before any further use was considered.
The public comment period for the current emergency exemption officially closed on June 5, 2003; however, given the extreme toxicity of this pesticide and the public interest in this matter, U.S. EPA has agreed to keep the public docket open until Thursday June 12, 2003. It is especially important that U.S. EPA hear from the public because the agency will soon review all formulations of carbofuran for re-registration. Interested organizations can sign onto a group letter by contacting the American Bird Conservancy.
Please submit comments to email@example.com. The subject line must include the docket number OPP-2003-0167.
Sources: American Bird Conservancy, PANUPS, July 3, 2002.
Contact: American Bird Conservancy, P.O. Box 249, The Plains, VA 20198; phone (540) 253-5780; fax (540) 253-5782; email: firstname.lastname@example.org, web site: http://www.abcbirds.org.