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Poison Free Parks Info and Call to Action Copyright 2014 City of Dubuque Action Items # 4. ITEM TITLE: Poison Free Parks Info and Call to Action SUMMARY: City Manager recommending the formation of a City Work Group to draft an Integrated Pest Management Plan for the city to be presented to the City Council for approval by July 1, 2015. It is also recommended that the Park and Recreation Commission as well as the Environmental Stewardship Advisory Commission appoint one representative each to the work group. SUGGESTED DISPOSITION: Suggested Disposition: Receive and File; Approve ATTACHMENTS: Description Type DBQ Poison Free Park Information and Call to Action- City Manager Memo MVM Memo REVISED Poison Free Parks Info and Call to Action Staff Memo Staff Memo Call to Action Supporting Documentation Levee Onmer's Manual Supporting Documentation Guidelines for Landscape Planting &Vegetation Mgmt Supporting Documentation Corps of Engineers Letter Re Flood Wall Inspection Supporting Documentation THE CITY OF Dubuque UBE I erica .i Masterpiece on the Mississippi 2007-2012-2013 TO: The Honorable Mayor and City Council Members FROM: Michael C. Van Milligen, City Manager SUBJECT: AMENDED RECOMMENDATION - Transmittal of DBQ Poison Free Parks Information and Call to Action DATE: December 13, 2015 Leisure Services Manager Marie Ware is recommending formation of an Integrated Pest Management Control Work Group. A Facebook group was formed called DBQ Poison Free Parks. Parks and Recreation Commission members Jennifer Tigges and Kate Larson joined the Facebook group and met with some members of the Facebook group to better understand their concerns. In early December Leisure Services Manager Marie Ware met with nine members of the group plus Jennifer Tigges and Kate Larson. A Call to Action, individual statements and information sheets were given to her. As a city organization in various departments there is use of pesticides for a variety of control purposes. Each department either has personnel that are Certified Pesticide Applicators with Iowa licenses or contract with local firms for those services. There are a variety of state and federal regulations governing the use and application of chemicals. The method of formalizing policy related to pests is to develop and adopt an Integrated Pest Management plan as the group suggests. The adoption of an Integrated Pest Management plan affects not only Leisure Services but also many other city departments. Integrated Pest Management is an environmentally friendly, common sense approach to controlling pests according to the Environmental Protection Agency. Integrated Pest Management is not a single pest control method but rather involves integrating multiple control methods based on site information obtained through inspection, monitoring and reports. An Integrated Pest Management program is designed based on the pest prevention goals and eradication needs of the situation. Integrated Pest Management programs can combine management approaches for greater effectiveness. The Facebook group has requested an immediate ban on the use of Roundup (glyphosate) until an Integrated Pest Management is drafted. During the winter months this product is not used as it isn't needed and isn't effective in cold weather. The request for an immediate ban does not allow the many city departments an opportunity to be prepared for any consequences of this ban. This can have intended as well as unintended consequences. Additionally, this product has been used not only by the Leisure Services Department but also in control of vegetation for the floodwall by Public Works. The US Army Corps of Engineers has a Levee Owner's Manual for Non-Federal Flood Control Works that outlines the requirements for Control of Tree, Brush and Weeds and issued a technical letter on Guidelines for Landscape Planting and Vegetation Management. As you will see from the most recent inspection letter the requirements for vegetation control is noted and required to continue. The Facebook group requests a task force be formed and a policy approved by the Council. Instead of an immediate ban Marie Ware recommends the formation of a City Work Group to draft an Integrated Pest Management Plan for the city to be presented to the City Council for approval by July 1 , 2015. If the Work Group determines positive actions toward integrated pest management that can be implemented prior to Council presentation they would not have to wait until a policy is adopted. In addition to the city staff, Marie recommends the Park and Recreation Advisory Commission as well as the Environmental Stewardship Advisory Commission appoint one representative each to the work group. The policy developed by this work group would be reviewed by each of these commissions at a regular meeting prior to coming to the City Council for consideration. Subsequent to making this recommendation to City Council, the group Dubuque Poison Free Parks, asked for representation on this work group. I am amending my original recommendation to request that the work group also include one member as appointed by Dubuque Poison Free Parks. I concur with the recommendation and respectfully request Mayor and City Council approval. Mic ael C. Van Milligen MCVM:jh Attachment cc: Barry Lindahl, City Attorney Cindy Steinhauser, Assistant City Manager Teri Goodmann, Assistant City Manager Marie L. Ware, Leisure Services Manager Carolyn Pettit-Lange, Secretary, Dubuque Poison Free Parks 2 THE CITY OF Dubuque UBDgkE ;��-Americ111 aC i I. Masterpiece on the Mississippi 2007-2012-2013 TO: Michael C. Van Milligen, City Manager FROM: Marie L. Ware, Leisure Services Manager SUBJECT: Transmittal of DBQ Poison Free Parks Information and Call to Action DATE: December 11, 2015 INTRODUCTION The purpose of this memo is to transmit information and a call to action from DBQ Poison Free Parks. BACKGROUND A Facebook group was formed called DBQ Poison Free Parks. Parks and Recreation Commission members Jennifer Tigges and Kate Larson joined the Facebook group and met with some members of the Facebook group to better understand their concerns. Tigges and Larson kept me informed of their meetings. In early December I met with nine members of the group plus Tigges and Larson. The attached Call to Action, individual statements and information sheets were given to me. I listened to their concerns and asked questions to better understand the information they were providing. At that meeting I shared I would be having meetings with other city staff to share what they had provided as well as their questions and concerns. I also shared at that meeting I could not authorize the ban they were requesting. DISCUSSION As a city organization in various departments there is use of pesticides for a variety of control purposes. Each department either has personnel that are Certified Pesticide Applicators with Iowa licenses or contract with local firms for those services. There are a variety of state and federal regulations governing the use and application of chemicals. The method of formalizing policy related to pests is to develop and adopt an integrated pest management (IPM) plan as the group suggests. As a department the development of an IPM plan was on our agenda. Conversations had already taken place with Sustainability Coordinator Cori Burbach about IPM. Often people think of pests as just bugs. In an IPM plan pests include invertebrate (insect, tick, mites, snail), vertebrate (rodent, bird or other mammal), plant (weed) or other invasive species, nematode, pathogen (bacteria, virus, fungus) or other unwanted organisms that may harm water quality, animal life or other part of the ecosystem. This 1 means a plan relates to both buildings as well as grounds and parks. The adoption of an IPM plan thus affects not only Leisure Services but also many other city departments. Integrated Pest Management (IPM) is an environmentally friendly, common sense approach to controlling pests according to the Environmental Protection Agency. IPM is not a single pest control method but rather involves integrating multiple control methods based on site information obtained through inspection, monitoring and reports. An IPM program is designed based on the pest prevention goals and eradication needs of the situation. Successful IPM programs use this four-tiered implementation approach including identify pests and monitor progress, set action thresholds, prevent and control. An effective way to manage pests is by using a combination of methods that work better together than separately. Approach for managing pests is often grouped in the following categories: • Biological control. Biological control is the use of natural enemies — predators, parasites, pathogens, and competitors — to control pests and their damage. Invertebrates, plant pathogens, nematodes, weeds, and vertebrates have many natural enemies. • Cultural controls. Cultural controls are practices that reduce pest establishment, reproduction, dispersal, and survival. For example, cleaning practices can reduce pest problems. • Mechanical and physical controls. Mechanical and physical controls kill a pest directly or make the environment unsuitable for it. Traps for rodents are examples of mechanical control. Physical controls include mulches for weed management. • Chemical control. Chemical control is the use of pesticides. In IPM, pesticides are used only when needed and in combination with other approaches for more effective, long-term control and are selected and applied in a way that minimizes their possible harm to people and the environment. With IPM the most selective pesticide that will do the job and be the safest is used; use pesticides in bait stations rather than sprays; or spot-spray a few weeds instead of an entire area. IPM programs can combine management approaches for greater effectiveness. The group has requested an immediate ban on the use of Roundup (glyphosate) until an IPM is drafted. During the winter months this product is not used as it isn't needed and isn't effective in cold weather. The request for an immediate ban does not allow our department and the many city departments an opportunity to be prepared for any consequences of this ban. This can have intended as well as unintended consequences. Additionally, the use of this product has been used not only by the Leisure Services Department but also in control of vegetation for the floodwall by Public Works. The US Army Corps of Engineers has a Levee Owner's Manual for Non-Federal Flood Control Works that outlines the requirements for Control of Tree, Brush and Weeds and issued 2 a technical letter on Guidelines for Landscape Planting and Vegetation Management. As you will see from the most recent inspection letter the requirements for vegetation control is noted and required to continue. These documents are attached for your review. The group requests a task force be formed and a policy approved by the Council. Instead of an immediate ban I would like to suggest the formation of a City Work Group be established to draft an Integrated Pest Management Plan for the city to be presented to the City Council for approval by July 1 , 2015. If the Work Group determines positive actions toward integrated pest management that can be implemented prior to Council presentation they would not have to wait until a policy is adopted. I would recommend the following be part of the IPM Work Group: Marie Ware..................... Leisure Services Manager Jeff Ahlers ...................... Natural Resources & Sustainable Practices Specialist Crenna Brumwell............Assistant City Attorney Cori Burbach .................. Sustainable Community Coordinator Mary Rose Corrigan ....... Health Services Manager Steve Fehsal .................. Park Division Manager John Klostermann .......... Street Maintenance Supervisor Dan Kroger..................... Recreation Division Manager Gerry Lange ................... Golf Supervisor In addition to the above city staff I also recommend the Park and Recreation Commission as well as the Environmental Stewardship committee appoint one representative each to the work group. That would be done at their January meetings. This aids in citizen input as each of these commissions represent citizen input and advise the City Council on issues relative to parks and the environment. The policy developed by this work group would be reviewed by each of these commissions at a regular meeting prior to coming to the City Council for consideration. It is recommended that the Facebook group would be used as a resource for information related to Integrated Pest Management and other topics. The work group will review the Call to Action from the Facebook group and their handouts and resources during the development of the IPM. I will be meeting again with the group in early January as promised. The work group will also consult with the Building, Fire, Parking, Water, Water Resource and Recovery and other departments that may use pest control methods specific to their department that should be considered in the development of the IPM. RECOMMENDATION In summary, I transmit the Call to Action and recommend establishment of an Integrated Pest Management Work Group with responsibility to bring a policy through the Parks and Recreation and Environmental Stewardship commission to the City Council by July 1 , 2015. 3 ACTION REQUESTED This information is provided as requested for your consideration. MLW:et attachments Call to Action 3 Related Documents from Army Corps of Engineers copy Marie Ware, Leisure Services Manager Mary Rose Corrigan, Health Services Manager Crenna Brumwell, Assistant City Attorney John Klostermann, Street Maintenance Supervisor Cori Burbach, Sustainable Community Coordinator Dan Kroger, Recreation Division Manager Gerry Lange, Golf Supervisor Steve Fehsal, Park Division Manager Jeff Ahlers, Natural Resources & Sustainable Practices Specialist 4 DBQ Poison Free Parks A Call to Action to Implement Safer Poison Free Public Spaces in Dubuque county. Pesticide and other chemical lawn care chemical exposure is a growing concern to local citizens of the Dubuque area. Children,pregnant women,the elderly and sick, and those with certain genetic issues are particularly vulnerable to toxic chemicals. Concerns include chemical pesticides such as Round Up/glyphosate being scientifically linked to multiple health problems including: ADHD,Alzheimer's Disease, Anencephaly, Autism,Birth Defects,Brain Cancer,Breast Cancer, other Cancers, Celiac and gluten intolerance, Chronic Kidney Disease, Colitis,Depression,Diabetes, Heart Disease, Hypothyroidism, Inflammatory Bowel Disease,Liver Disease,Lou Gehrig's Disease (ALS),Multiple Sclerosis,Non-Hodgkin Lymphoma,Parkinson's Disease,Pregnancy Problems (infertility, miscarriages, stillbirths), obesity,reproductive problems, and respiratory illnesses. Scientists have been documenting the health consequences of Roundup and glyphosate and found that people who are sick were found to have higher levels of glyphosate in their bodies than healthy people. There are many studies and organizations that support our call to action. The World Health Organization published a full report earlier this year that announced glyphosate as a probable human carcinogen. The California EPA has become the fust state to label the active ingredient in Roundup (glyphosate) as being known to cause cancer or birth defects. In addition to the long-term health problems associated with these toxic chemicals,there are increasing numbers of people with MCS (Multiple Chemical Sensitivity) and Chemical Injury who experience immediate health issues when exposed to these toxic chemicals. These are ADA recognized disabilities and Dubuque public spaces should be ADA compliant. This vulnerable population needs proper advance notice when public spaces have been treated with toxic chemical pesticides,insecticides, fertilizers and other similar chemicals because even"small" short-term exposure can lead to severe and sometimes life threatening medical issues for this group of citizens. Round Up/Glyphosate is just one of many toxic pesticides which has a long list of health concerns linked with it. The accumulative effect of multiple poisons is of growing major concern to scientists and many of our local Dubuque families. In addition to better health for our local citizens and visitors, implementing a pesticide-free management policy will help make Dubuque more ecologically healthy including making it a pollinator friendly city Creating healthier chemical free public spaces would also expand on the"Sustainable Dubuque" principles. There is a growing list of countries that has banned Round Up and a growing list of cities and communities in the United States implementing similar policies for their parks and school grounds. We hope that Dubuque will join in this leading edge movement. We call upon the Dubuque Park& Recreation Board to implement a pesticide-free management policy/Integrated Pest Management(IPM) ProgrAm on all park-owned and park-leased properties to ensure that our public spaces are healthier and'more inclusive. We are asking the Council for an immediate ban on the use of Round-Up until an IPM policy is drafted (by a task force, The Environmental Stewardship Commission or other groups(s)) and approved by the Council. Our goal is to have this done by March 9th. As well as a ban, we call for increased communication,transparency and accountability of chemical usage with greater access to the public on information regarding spraying chemicals in the parks and public spaces (24 hour notification signs, an online record of chemical applications in public spaces, etc.) We are asking for increased awareness of and respect for chemically sensitive/injured individuals as part of a more inclusive,ADA compliant Dubuque. DBQ Poison Free Parks: Individual Statements: Pamela Engelken Please ban Glyphosate and other toxic chemicals used in city parks I have MCS,Multiple Chemical Sensitivity. Because it is so severe,this is one of the reasons I work from home (so that I can reduce my over all exposures. For example, avoidance of colognes,perfumes, lotions, cleaning products, and air fresheners in the workplace). Therefore,when I do get the chance to go to our parks, it would be most beneficial to not have to worry about chemicals having been used there. My three daughters are also negatively impacted by Glyphosate and other toxic chemicals. It would be great if we could go to our city's properties, especially our parks, and not have to worry that we are inhaling volatile chemicals, or absorbing them through our skin if we are wearing summer footwear or would like to sit on the ground. In addition,the health of everyone who uses our parks would benefit from the practice of not using toxic chemicals,not just those of us with MCS. Thank you in advance for considering the accessibility needs of all city residents, including those of us disabled by MCS, in the care of our cities'parks. Sincerely--- Pamela S. Engelken Carla Kaufman Carla Kaufinan(resident of Durango, Iowa) looks to Dubuque's parks and publicly managed spaces for refuge from all the pesticide spraying in the country. She visits Dubuque daily for errands and to visit family. Carla has chemical sensitivity due to her PCOS, an endocrine disease. Studies show Roundup is an endocrine disruptor. When the surrounding farm by her home sprays, she throws up every ten minutes for 18-36 hours, with sweats and tremors and has ended up in the emergency room several times. Carla miscarried after the farm sprayed twice during her pregnancy. To seek refuge from the spraying Carla stays at her mom's in Dubuque who lives near a park, or various Dubuque hotels. She would love to be able to visit Dubuque parks for activities and family functions,but feels Dubuque parks are non-inclusive to the chemically sensitive. Poison-free parks: Dubuque, IA Personal testimonial: Laura Elsinger Presented to Marie Ware, Dubuque Leisure Services Manager, 11/23/2015 1 have been regularly walking with my dog in Guttenberg, IA for 8 years. In my experience,there is NO SAFE way to use synthetic,toxic pesticides. This is the point I will address, and 1 will leave it to the other meeting attendants to provide the evidence that synthetic chemical pesticides are unhealthy to people and the planet. On several occasions of walking along the Mississippi river,we were inadvertently exposed to drifting spray. When walking up wind on a gently breezy day,at some point,we rounded a bend and could suddenly see that city workers were systematically blanketing the rock-covered face of the river bank with a spray of herbicide. We were walking right into the drifting aerosol. There was no way for us to avoid the exposure. The workers were abiding by the law in that the day was not excessively windy. The workers also installed warning flags in the ground to alert people to avoidance. And yet we were exposed. The city also regularly treats the grassy lawn of the park where people gather with family and pets throughout the summer. Furthermore,the effort that the city makes to be compliant with safety laws is entirely inadequate. The flags that are installed are small, do not stand out, and are spaced very far apart so that most people enjoying the walkway are unaware of the flags until long after exposure. And beyond this,the flags are left in place,forgotten about,for weeks and sometimes months; so long after application that people tend to ignore them. I would argue that choosing a park maintenance strategy that is chemical-free may serve Dubuque well. Advertise this attractive,forward-thinking feature, and rather than being burdensome, it becomes an investment in attracting intelligent,well educated,civic-minded people to make Dubuque their home. I will be looking to Dubuque and the progress that you make on this topic to serve as a model when I open the issue for consideration in my home town of Guttenberg. Thank you for your consideration. Laura Elsinger P.O. Box 726 Guttenberg, IA 52052 Dear Parks Commission: Thank you for addressing the concerns of citizens who are advocating for a healthy community to live in. As a community, we are enjoying greater options in the quality of the food we eat, more sustainably sourced goods, and recognized preservation efforts and attention to LEED certification in our buildings. As someone who enjoys the beautiful parks and public lands around Dubuque, I am writing to request greater transparency around chemicals_that are used in these spaces and also to request use of non-toxic alternatives where that is not already in place. One example that is most striking to me is the chemical spraying on the flood wall (behind Kerper Avenue). I frequently walk on that wall and am concerned about the chemicals used late each summer on the bank. Before the chemicals are sprayed the plants —and yes, weeds - provide a rich source of food and shelter for wild life. The beauty of the gold finches on the Canadian Thistle is incredible, as one_example, but the entire bank literally teams with birds and other wildlife. When the chemicals are sprayed —without signage or warning to the public when the spraying is occurring or after based on my experience of being caught during a spray—the entire bank goes sterile and the chemicals certainly run off directly into the river. This is extremely concerning and sad, and seems unnecessary due to the limited availability of the weeds to spread. The chemicals we use in our environment impact all of us, but our children may be impacted most. The Natural Resources Defense Council provides some excellent information on the impact of pesticides at this link, and an excerpt is below. http://www.nrdc.org/health/kids/ocar/chap5.asp SOURCES OF EXPOSURE Children encounter pesticides throughout their environment, including at home, at school, in playgrounds, in hospitals, and in many public buildings and parks. Children also consume water and foods that are often tainted with pesticide residues. When children come in contact with pesticides, the pesticides enter the body through four possible routes: the skin, lungs, mouth, and eyes. The skin is the largest organ in the body, and for its size a child's skin surface is twice that of an adult per unit of body weight.[72] When skin is wet, cut, or irritated, pesticides can penetrate even faster.[73]Pesticides applied as foggers, bombs, and aerosols generally have the smallest particle size and thus are the most readily inhaled.(74] Children ingest pesticide residues from contaminated food and drinking water and by accidentally ingesting dust. I urge the city to make choices that are healthy for all of us and for this beautiful, diverse landscape that we are so fortunate to enjoy and to keep us informed about those choices. Thank you for your consideration. Suzanne Guinn 563 West 11 t" Street Dubuque, Iowa 52001 DBQ Poison Free Parks- Glyphosate use in 2012 Estimated Agricultural Use for Glyphosate, 201 EPest-Love 2- 4;, r JL4 g„ Sdf Estimated use ot1 agricultural latidl,ire T pourids per square mile v <4.52 x]4.52-21.12 i- 21.13-88.08 >8&06 No estimated use Use by Year and Crop IM sM 200- 01ha Crops tt€e rOards and qWeS 100 ce 1=1 Wgetawes anafralt E Oftn cora iV 0 Nr In to fes.00,CA c*.r(v V)IT 47 to[+.,co a)c.—N MMM rn��,y,astise+ iac.oc�MUM 0)—4-"NNc�v-tVN(+d i1NtVN ikI.V _ : C emicalWatch Factsheet a Glyphosate Glyphosate (N-phosphono-methyl gly- hundreds of products currently registered National Agricultural Statistics Service cine) is a registered herbicide with with EPA under numerous formulationsz (NASS), use of glyphosate has dramatically the U.S. Environmental Protection Agency with active ingredient glyphosate (most increased over the last several years, con- (EPA)first registered in 1974.Since its reg- commonly used as its three salts—isopro- trary to common claims from industry that istration, its popularity has increased dra- plyamine, sodium and monoammonium GM crops would result in lower pesticide matically due to erroneous industry claims salts—as well as the technical acid,in regis- use rates. Data show that glyphosate use that it is of low toxicity, and the promotion tered pesticide products). has skyrocketed to more than double the of genetically modified (GM) crops engi- amount used five years ago,with 57 million neered to be tolerant to glyphosate. Stud- First registered for use in 1974,glyphosate pounds of glyphosate applied to corn fields ies have reported that glyphosate is associ- is used to kill a variety of broadleaf weeds in 2010 compared to 23 million pounds in ated with an increased risk 2005 and 4.4 million in 2000.5 of non-Hodgkin Lymphoma ChemicalWATCH Stats: (NHL), genetic damage, The most recent comprehen- and endocrine disruption, CAS Registry Number:1071-83-6 sive human health risk as- as well as environmental sessment for glyphosate was damage g a includin water Trade Name;Roundup contamination and harm Use:Non-selective herbicide for broadleaf we and grass control; conducted in 2006 entitled "Glyphosate Human Health to amphibians. Researchers on food and no fieldcrop sites. Risk Assessment for Proposed have also determined that Toxicity rating:Toxic. Use on Indian Mulberry and the "inert" ingredients in Signal Words:Caution Amended Use on Pea, Dry." glyphosate products, espe- Health Effects:Eye and skinirritation,associated with non-Hodg- The last registration review for cially polyethoxylated tal- kin Lymphoma,and spontaneous abortions:'Other ingredients in .glyphosate was published in lowamine or POEA- a sur- 1.993.are'linked to developmental abnormalities, 1993.That assessment did not factant commonly used in include an endangered species decreased sperm count,abnormal sperms and cell death of em. glyphosate and other her- determination for glyphosate.6 bicidalroducts- are even bryonic,placental and umbilical cord cells. p In 2009 EPA finalized the work more toxic than glyphosate Environmental Effects:Wd resistance due to use of GM fields, , g Yp ee ;,plan for the registration review itself. Monsanto, mak- water,contamination;soil quality degradation,toxic'to aquatic for glyphosate. It is estimat- ers of glyphosate, formu- organisms. ed to be completed in 2015. lates scores of products During the review period the such as RoundupT"^ and agency must collect up-to-date RodeoT""making glyphosate one of the most and grasses. Labeled uses of glyphosate in- data and conduct comprehensive risk as- widely used and well-known herbicides in clude over 100 terrestrial food crops as well sessments in keeping with the standard set the world. as other non-food sites including forestry, forth in the Federal Insecticide, Fungicide greenhouse, rights-of-way, and residen- and Rodenticide Act (FIFRA). A number of General Use and tial.3 The greatest glyphosate use, accord- ecological fate and effects studies, acute Registration Status ing to the U.S. Geological Survey(USGS), is and sub-chronic neurotoxicity studies, and Most commonly formulated as Monsan- in the Mississippi River basin where most an immunotoxicity study have been re- to's Roundup herbicide, glyphosate end- applications are for weed control on GM quested.As part of the registration review, use products account for approximately corn,soybeans,and cotton 4 EPA was urged to reinstate the 10X safety 180-185 million pounds applied per year,' factory for glyphosate to protect children making it the number one commonly GM or herbicide-tolerant crops (Roundup and vulnerable populations, expand risk used chemical in the U.S. Glyphosate use Ready crops) have dominated U.S. agricul- assessments to include effects to amphib- is currently growing due in large part to ture in recent years.According to the 2010 ians, aquatic plants, and soil biota, as well the increased cultivation of GM crops that Agricultural Chemical Use Report from the as the evaluation of POEA and non-POEA are tolerant to the herbicide. There are U.S. Department of Agriculture's (USDA) surfactants. NOW� , Mode of Herbicidal Action isms such as fairy shrimp15 and Daphnia velopment. Preconception exposures to Plants treated with glyphosate translocate magna,16 and accounts for more than 86% glyphosate were found to moderately in- the systemic herbicide to their roots,shoot of Roundup toxicity observed in microalgae crease the risk for spontaneous abortions regions and fruit, where it interferes with and crustaceans." It has been determined in mothers exposed to glyphosate prod- the plant's ability to form aromatic ami- that the order of toxicity is as follows;POEA ucts.25 In a Farm Family exposure study, all no acids necessary for protein synthesis. > Roundup > glyphosate acid > IPA salt of but one of the 79 children evaluated had Treated plants generally die in two to three glyphosate. detectable concentrations of glyphosate days. Because plants absorb glyphosate, it in their urine.21 While most of the active cannot be completely removed by washing Acute Tonicity ingredient glyphosate is excreted quickly or peeling produce or by milling, baking or EPA considers glyphosate to be "of rela- from the body, it was concluded, "a part brewing grains. It has been shown to per- lively low oral and dermal acute toxicity."18 may be retained or conjugated with other sist in food products for up to two years.7 Some glyphosate products are of higher compounds that can stimulate biochemical acute toxicity, primarily due to eye and/or and physiological responses."27 Glyphosate Formulated skin irritation. Symptoms following expo- Products and Other Ingredients sure to glyphosate formulations include: Environmental Fate An increasing number of studies have swollen eyes, face and joints; facial numb- EPA acknowledges that glyphosate has the found that formulated glyphosate products ness; burning and/or itching skin; blisters; potential to contaminate surface waters. (Roundup) are more toxic than the active rapid heart rate; elevated blood pressure; If glyphosate reaches surface water, it is ingredient, glyphosate, alone. Roundup chest pains, congestion; coughing; head- not broken down readily by water or sun- formulations can induce a dose-dependent ache; and nausea.19 In developmental tox- light 39 For instance, half-life of glyphosate formation of DNA adducts in the kidneys icity studies using pregnant rats and rab- in pond water ranges from 70 to 84 days.40 and liver of mice.' In Wister rats, formu- bits, glyphosate caused treatment-related A survey by the USGS of 154 water samples lated Roundup induced developmental re- effects in high dose groups, including diar- from 51 streams in nine Midwestern States tardation of the fetal skeleton, decreased rhea, decreased body weight gain, nasal reports glyphosate detected in 55 (36%)of sperm numbers, increased the percentage discharge and death.20 the samples, and aminomethylphosphonic of abnormal sperms and produced a dose- acid or AMPA (a degradation product of related decrease in the serum testosterone Chronic Toxicity glyphosate) detected in 107 (69%) of the level at puberty.9 A molecular link between EPA has classified glyphosate as a Group samples 41 APMA is typically detected glyphosate-based products and cell cycle E carcinogen—evidence of non-carcino- much more frequently, especially in urban deregulation—a hallmark of tumor cells genicity for humans—based on the lack environments 42 This survey found that and human cancers was observed,10 as of convincing evidence of carcinogenicity glyphosate contamination endured from well as exposure affects to human repro- in adequate studies. Since that decision, spring through to fall when many pre- duction and fetal development." Roundup studies have found that people exposed sumed it would have already degraded. reduces human placental JEG3 cell viability to glyphosate are 2.7 times more likely to at least two times more efficiently than contract non-Hodgkin Lymphoma (NHL).21 glyphosate, disrupts aromatase activity, In 2002, a study of Swedish men showed and mRNA levels.12 Human cell endocrine that glyphosate exposure was significantly e disruption on the androgen receptor, inhi- associated with an increased risk of NHL, , bition of transcriptional activities on estro- and hairy cell leukemia—a rare subtype gen receptors on HepG2,DNA damage and of NHL.22 Further, a review of studies con- cytotoxic effects occurring at concentra- ducted on farmers by researchers at the tions well below"acceptable" residues has National Cancer Institute showed that ex- also been observed.13 posure to glyphosate was associated with an increased incidence of NHL.23 Similarly, y A 2008 study confirmed that the adjuvants an Agricultural Health Study (AHS) found - in Roundup formulations kill human cells, that glyphosate had a suggested associa- r particularly embryonic, placental and um- tion with multiple myeloma.24 This associa- bilical cord cells, even at very low concen- tion with multiple myeloma was observed IUSIVEFORidlflA! trations, and causes total cell death within with use of glyphosate and cumulative ex- GP, e op sg- , 24 hrs.14 Polyethoxylated tallowamine or posure days of use(a combination of dura- POEA—a surfactant used in Roundup and tion and frequency). '' FREHFCNIlDA�'' other herbicidal products—was found to be the most potent "inert" and was re- Glyphosate and its formulated products 1 e : sponsible for the elevated toxic effects. adversely affect embryonic, placental and _ POEA is extremely toxic to aquatic organ- umbilical cord cells, and impacts fetal de- - 10 it Of all-torn planted rn a One which Utilized data r6m USDA;shows that GM crbp�-have bee�' s n j6le�l an Incr of 3-83 mi ion 0-com rnercial u_ ho- MW en- I— VIE ',.-AhlardrithUs-pa met ysju Ma now Glyphosate and AK4RAare more frequent- have observed that the heavy use of chemicals and its sudactants.' ly detected in surface water rather than Roundup onGK1crops appears tubecou* 8vuund waterm In addition to surface wm' in0harmful changes insoil and potentially A 2012 study found that Roundup, in sub- tem, glyphosate has also been detected in hindering yields ofcrops.^6 lethal and environmentally relevant con- significant levels in rain in agricultural areas on'ni8niMcant|eve}oinraininagrimu|tuo|oreas centrations,causes two species ufamphib' ac/ossthe Mississippi River watershed, au' Effects on Non-Target Animals iuna to change their shape by interfering cording to U3GS. Due to g|yphooate'u pu' Glyphosate use directly impacts avariety of with the hormones oftadpoles and poten' tentiu| for water contamination, EPA has nontargetanimals including insects, earth' tia||y many otheranima|o.sz A2005 study established umaximum contaminant level worms, and fish, and indirectly impacts found that Roundup alone is "extremely (MCL)for glyphosate (0.7ppm).44 EPA lists birds and small mammo|o.47 A study con- lethal" to amphibians in concentrations the short-and long-term health effects for ducted bythe International Organization found inthe envinnnment.aAnother study drinking water exposures: for relatively for Biological Control found that exposure found that Rana pip/ens tadpoles ohnoni' short periods of time, congestion of the to Roundup killed over G0percent nfthree ca|!y exposed to environmentally-relevant lungs and increased breathing rate;for life- species ofbeneficial insects—a parasitoid concentrations ofglyphosate formulations, time exposure atlevels above the MCL:kid- wasp, alacewing and a |adybu0.^^ Repeat- containing POEA" exhibited decreased neydamage and reproductive effects. edapplications ofglyphosate significantly snout-vent length atmetamorphosis, in- affected the growth and survival of earth- creased time to metamorphosis, tail dam- Glyphosate is moderately persistent in am'G|yphonateismodemte|ypenistentin vvorms.4' Environmental factors such as age, and gonadal abnormalities.m G|ypho' sni|,with onaverage half-life of47days, high sedimentation, increases in tempera- sate and its salts, as well as its metabolite although there are studies reporting field tuoeand pHlevels have been shown tnin- AK4PA, are also likely toadversely impact half-lives ofupto174dayo.45Residues nf crease the toxicity ofRoundup, especially the endangered California red-legged frog glyphosate have been known topersist to young fixh.'« Native freshwater mussels due toprey and habitat neducdon.n for months inanaerobic soils deficient in were found tobathe most sensitive oquat- microorganisms. Recent/y, USDA officials io organisms tested with glyphosate-based - � YaR 1�t '.:�� .. 1�'�J,s-:n5,a.rv�-s } {,:� �-.r z-� a ,,z^r .'�h'' `[•u,��'i�"'�-- �`*r:F�� "'.3. �:f��' 3.^-3 „��. -'�-�� - �j - ,_. - 1.USEPA.2006-2007 Pesticide Market Estimates:Usage.http://www.epa.gov/opp00001/pestsales/07pestsales/usage2007-2.htm#3_4 2.USEPA.2009.Glyphosate-Active Product Registrations.Office of Prevention,Pesticides and Toxic Substances.Washington DC 3.USEPA.2009.Glyphosate Final Work Plan.Registration Review Case No 0178.Office of Pesticide Programs.Washington DC 4.USGS.2011.Technical Announcement:Widely Used Herbicide Commonly Found in Rain and Streams in the Mississippi River Basin.USGS Newsroom.Available at http://www.usgs.gov/newsroom/article.asp?ID=29091t.T9o19VLQin4 5.USDA.2010.Agricultural Chemical Use Program.National Agricultural Statistics Service 6.USEPA.2009.Glyphosate Final Work Plan.Registration Review Case No 0178.Office of Pesticide Programs.Washington DC. 7.Pesticide Action Network,1997.Glyphosate fact sheet.For more information about glyphosate visit http://data.pesticideinfo.org/4DAction/GetRecord/PC33138 8. Marco,P.,Armelle,M.,Claudia,B.,&Silvio,P.1998.3213-postlabeling detection of DNA adducts in mice treated with the herbicide roundup.Environ Mol Mutagen 31(1),55-59. 9.Dallegrave,E.,et al.2003.The teratogenic potential of the herbicide glyphosate-Roundup"in Wistar rats.Toxicology Letters,142(1-2),45-52.;Dallegrave,E.,et al. 2007.Pre-and postnatal toxicity of the commercial glyphosate formulation in Wistar rats.Arch Toxicol,81(9),665-673. 10.Marc,J.,Mulner-Lorillon,O.,&Belle,R.2004.Glyphosate-based pesticides affect cell cycle regulation.Biology of the Cell(96),245-249. 11.Benachour N,Sipahutar H,Moslemi S,Gasnier C,Travert C,&Seralini GE.2007.Time-and dose-dependent effects of roundup on human embryonic and placental cells.Arch Environ Contam Toxicol.,53(1),126-133. 12.Richard S,Moslemi S,Sipahutar H,Benachour N,&Seralini GE.2005.Differential effects of glyphosate and roundup on human placental cells and aromatase.Environ Health Perspect,113(6),716-720. 13.Gasnier,C.,et al.2008.Glyphosate-based herbicides are toxic and endocrine disruptors in human cell lines.Toxicology,doi:10.1016/j.tox.2009.06.006. 14.Benachour,N.,&Seralini,G.-E.2008.Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic,and Placental Cells.Chemical Re- search in Toxicology,22(1),97-105. 15. Brausch,J.M.,&Smith,R N.2007.Toxicity of Three Polyethoxylated Tallowamine Surfactant Formulations to Laboratory and Field Collected Fairy Shrimp,Thamno- cephalus platyurus.Arch Environ Contain Toxicol 52(2),217-221. 16. Wang,N.,et al.2005.Influence of sediment on the fate and toxicity of a polyethoxylated tallowamine surfactant system(MON 0818)in aquatic microcosms.Che- mosphere.,59(4),545-551;Brausch,J.M.,Beall,B.,&Smith,R N.2007.Acute and Sub-Lethal Toxicity of Three POEA Surfactant Formulations to Daphnia magna.Bull Environ Contam Toxicol,78,510-514. 17. Tsui,M.,&Chu,L.2003.Aquatic toxicity of glyphosate-based formulations:comparison between different organisms and the effects of environmental factors. Chemosphere.,52(7),1189-1197. 18.USEPA.1993.Reregistration Eligibility Decision(RED)Document:Glyphosate.Office of Pesticide Programs 19.Northwest Coalition for Alternatives to Pesticides(NCAP).1998.Herbicide Factsheet:Glyphosate(Roundup).Journal of Pesticide Reform.18(3):4 20.EPA.1993.Reregistration Eligibility Decision(RED)Document:Glyphosate.Office of Pesticide Programs 21.Hardell,L.,&Eriksson,M.1999.A Case-Control Study of Non-Hodgkin Lymphoma and Exposure to Pesticides.Cancer,85(6),1353-1360. 22. Hardell L,Eriksson M,&Nordstrom M.2002.Exposure to pesticides as risk factor for non-Hodgkin's lymphoma and hairy cell leukemia:pooled analysis of two Swedish case-control studies.Leuk Lymphoma,43(5),1043-1049. 23. De Roos,et al.2003.Integrative assessment of multiple pesticides as risk factors for non-Hodgkin's lymphoma among men.Occup Environ Med,60(9). 24. De Roos,A.J.D., Blair,A.,et al.2005.Cancer Incidence among Glyphosate-Exposed Pesticide Applicators in the Agricultural Health Study. Environ Health Per- sp.113(1),49-54. 25.Arbuckle,T.E.,Lin,Z.,&Mery,L.S.(2001).An Exploratory Analysis of the Effect of Pesticide Exposure on the Risk of Spontaneous Abortion in an Ontario Farm Popu- lation.Environ Health Perspect,109,851-857. 26. Acquavella,J.F.,et al.(2004).Glyphosate Biomonitoring for Farmers and Their Families:Results from the Farm Family Exposure Study.Environ Health Perspect, 112(3),321-326 27. Acquavella,J.F.,et al.(2004).Glyphosate Biomonitoring for Farmers and Their Families:Results from the Farm Family Exposure Study.Environ Health Perspect, 112(3),321-326 28.Economic Research Service.2011.Adoption of Genetically Engineered Crops in the U.S.U.S.Department of Agriculture(USDA).Available at http://www.ers.usda. gov/data/biotechcrops/ 29.Economic Research Service.2011.National Statistics for Corn.U.S.Department of Agriculture(USDA).Available at http://www.ers.usda.gov/data/biotechcrops/ 30. Benbrook,C.2009.Impacts of Genetically Engineered Crops on Pesticide Use:The First Thirteen Years.The Organic Center. 31.Givens,W.A.,Shaw,D.R.,et al.2009.A Grower Survey of Herbicide Use Patterns in Glyphosate-Resistant Cropping Systems.Weed Technology,23(1),156-161. 32.APHIS.2011.Plant Pest Risk Assessment for DAS-40278-9 Corn.US Department of Agriculture. 33.VanGessel,M.J.2001.Glyphosate-resistant horseweed from Delaware.Weed Science,49(6),703-705. 34.Koger,C.H.,Poston,et al.2004.Glyphosate-Resistant Horseweed(Conyza canadensis)in Mississippil.Weed Technology,18(3),820-825;Koger,C.H.,&Reddy,K.N. 2005.Role of absorption and translocation in the mechanism of glyphosate resistance in horseweed(Conyza canadensis).Weed Science,53(1),84-89. 35. Hembree,K.,&Shrestha,A.2005.Glyphosate-Resistant Horseweed In California.University of California,Davis. 36. Shrestha,A.,Hembree,K.J.,&Va,N.2007.Growth stage influences level of resistance in glyphosate-resistant horseweed.California Agriculture,61(2),67. 37, Simarmata,M.,Bughrara,S.,&Penner,D.2005.Inheritance ofglyphosate resistance in rigid ryegrass(Lolium rigidum)from California.Weed Science,53(5),615-619; Simarmata,M.,Kaufmann,J.E.,&Penner,D.2003.Potential basis of glyphosate resistance in California rigid ryegrass(Lolium rigidum).Weed Science,51(5),678-682. 38. Powles,S.B.2008.Evolved glyphosate-resistant weeds around the world:lessons to be learnt.Pest Manag Sci,64(4),360-365. ry � - e 39. EPA.1993.Reregistration Eligibility Decision(RED)Document:Glyphosate.Office of Pesticide Programs 40. Extension Toxicology Network.1996.Pesticide Information Profiles:Glyphosate.httP:Hace.orst.edu/cgi-bin/mfs/01/pips/glyphosa.htm 41. Scribner,E.A.,Battaglin,W.A.,Dietze,J.E.,&Thurman,E.M.2003.Reconnaissance Data for Glyphosate,Other Selected Herbicides,Their Degradation Products, and Antibiotics in 51 Streams in Nine Midwestern States,2002 U.S.Geological Survey,Open-File Report 03-217(101 p). 42. Kolpin,D.W.,et al.2006.Urban contributions of glyphosate and its degradate AMPA to streams in the United States.Sci Total Environ,354(2-3),191-197 43. Scribner,E.A.,Battaglin,W.A.,Gilliom,R.J.,&Meyer,M.T.2007.Concentrations of Glyphosate,Its Degradation Product,Aminomethylphosphonic Acid,and Glufosinate in Ground-and Surface-Water,Rainfall,and Soil Samples Collected in the United States,2001-06.US Geological Survey,Scientific Investigations Report 2007-5122(111p). 44. U.S.EPA.2009.Glyphosate Summary Document Reregistration Review:Initial Docket(p10).Office of Prevention,Pesticides and Toxic Substances. 45.Extension Toxicology Network.1996.Pesticide Information Profiles:Glyphosate. 46. Beyond Pesticides Daily News Blog.August 22, 2011. Roundup May Be Damaging Soil and Reducing Yields, Says USDA http://www.beyondpesticides.org/ dai lynewsb log/?p=5817 47. Northwest Coalition for Alternatives to Pesticides(NCAP).1998.Herbicide Factsheet:Glyphosate(Roundup).J Pesticide Reform.18(3):4 48. Hassan,S.A.et al.1988.Results of the fourth joint pesticide testing programme carried out by the IOBC/WPRS-Working Group"Pesticides and Beneficial Organ- isms."J.Appl.Ent.105:321-329. 49.Springett,J.A.and R.A.J.Gray.1992.Effect of repeated low doses of biocides on the earthworm Aporrectodea caliginosa in laboratory culture.Soil Biol.Biochem. 24(12):1739-1744. 50.Folmar,L.C.,Sanders,H.0.,&Julin,A.M.1979.Toxicity of the herbicide glyphosate and several of its formulations to fish and aquatic invertebrates.Arch Environ Cant Tax,8(3),269-278. 51. Bringolf RB,Cope.WG.,Mosher S,Barnhart MC and Shea D.2007.Acute and chronic toxicity of glyphosate compounds to glochidia and juveniles of Lampsilis siliquoidea(Unionidae).Environ Toxicol Chem.,26(10),2094-2100. 52. Relyea,R.2012.New effects of Roundup on amphibians:Predators reduce herbicide mortality;herbicides induce antipredator morphology.Ecological Applications 22:634-647. 53. Relyea,R.2005."The lethal impact of Roundup on aquatic and terrestrial amphibians."Ecological Applications,15(4),1118-1124 54. Howe CM,B.M.,Pauli BD,Helbing CC,Werry K,and Veldhoen N.2004.Toxicity of glyphosate-based pesticides to four North American frog species.Environ Toxicol Chem,23(8),1928-1938. 55. U.S.EPA.2009.Glyphosate Summary Document Reregistration Review:Initial Docket(p10).Office of Prevention,Pesticides and Toxic Substances. BEYOND PESTICIDES 701 E Street,S.E.,Suite 200>Washington DC 20003 202-543-5450(v)•202-543-4791(f) info@beyondpesticides.org•wwiv.heyondpesticides.org h �gP t r<,FL �, a cr 30 Common ) Used Plestmiciden Endocrine Reproductive Kidney/Liver Sensitizer/ Cancer NeurotoxicityBirth Defects Disruption Effects Damage ` Irritant Benfluralin }z X1 Bens-ullde' � Clopyralid X7 X2 X7 Dicamba* z } 1 Dlquat Dibromide X1.2 X11 X1 -Dithiopyr. Fluazipop-p-butyl X1 X X1 Glyphosate* Xl?` X'` , 9 Imazapyr X7 X2 Isoxaben - X�f .77 MCPA X6 Xz Xz X11 X1 p. p ) 6_ Mecro or MEPP * „ Pelargonic Acid* Xl Pendimethalln*. Triclopyr X' X9 Xl X7 77ifluralin* Acephate __-Mf l ' X6 X11 X° X2 B�fenthrin*t4„€ aspectede l° Xu Description Most toxicity determinations based on interpretations and conclusions of studies by university,government,or organization databases.Empty cells may refer to either insufficient data or if the chemical is considered relatively non-toxic based on currently available data. The list of 30 commonly used lawn chemicals is based on information provided by the General Accounting Office 1990 Report, "Lawn Care Pesticides: Risks Remain Uncertain While Prohibited Safety Claims Continue,"U.S. Environmental Protection Agency(EPA)National Pesticide Survey(1990), Farm Chemicals Handbook(1989),The National Home and Garden Pesticide Use Survey by Research Triangle Institute, NC (1992),multiple state reports,current EPA Environmental Impact Statements,and Risk Assessments,EPA national sales and usage data,best- selling products at Lowe's and Home Depot,and Beyond Pesticides'information requests. For more information on hazards associated with pesticides,please see Beyond Pesticides'Gateway on Pesticide Hazards and Safe Pest Man- agement at www.beyondpesticides.org/gateway. For questions and other inquiries, please contact our office at 202-543-5450, email info@ beyond pesticides.org or visit us on the web at www.beyondpesticides.org. Citations 1. U.S. EPA. Office of Pesticide Program Reregistration Eligibility Decisions(REDs),Interim REDS(iREDs),and RED factsheets. http://www.epa.gov/pesticides/reregistration/. 2. National Library of Medicine,TOXNET,Hazardous Substances Database,http://toxnet.nlm.nih.gov/. 3. U.S. EPA. 2012.Office of Pesticide Programs, Chemicals Evaluated for Carcinogenic Potential. http://npic.orst.edu/chemicals_evaluated.pdf. 4. California Environmental Protection Agency.Proposition 65:Chemicals Known to the State to Cause Cancer or Reproductive Toxicity.Office of Environmental Health Hazard Assessment. http://www.oehha.org/prop65/prop65_list/files/P65singleO52413.pdf. 5. The Pesticide Management Education Program at Cornell University.Pesticide Active Ingredient Information. http://pmep.cce.cornell.edu/profiles/index.htmi. 6. The Endocrine Disruption Exchange.2011.List of Potential Endocrine Disruptors. http://www.endocrinedisru ption.com/endocri ne.TEDXL!st.overview.ph p. 7. Northwest Coalition for Alternatives to Pesticides(NCAP),Pesticide Factsheets. http://www.pesticide.org/get-the-facts/pesticide-factsheets. 8. Beyond Pesticides ChemWatch Factsheets, http://www.beyondpesticides.org/pesticides/factsheets/index.htm. 9. U.S. EPA. Chronic(Non-Cancer)Toxicity Data for Chemicals Listed Under EPCRA Section 313.Toxic Release Inventory Program.http://www.epa.gov/tri/trichemicals/hazardinfo/hazard_chronic_non-cancer95.pdf. 10. European Union Commission on the Environment.List of 146 substances with endocrine disruption classifications, Annex 13. http://ec.europa.eu/environment/endocrine/strategy/substances_en.htm#report2. 11. Extension Toxicology Network(EXTOXNET)Pesticide Information Profiles. http://extoxnet.orst.edu/ghindex.htmi. 12. International Agency for Research on Cancer,World Health Organization (IARC)category 2A,the agent(mixture)is probably carcinogenic to humans based on sufficient evidence of carcinogenicity in laboratory animal studies. http://monographs.iarc.fr/ENG/Classification/index.php. 4� Last Updated May 2015 chemicalWATCH Factsheet 294-D What is 2,4-D? Health effects of 2,4-D are of particular con- ity to walk, fatigue, stupor, coma, and 2,4-Dichlorophenoxyacetic acid, com- cern due to its widespread distribution.In a death."2,4-D is a serious skin and eye irri- monly known as 2,4-D, is a widely used 2003 study of indoor air toxins,2,4-D was tant.For the acid form,the LD 50 in rats is herbicide in the phenoxy class of chemi- found in the dust of 63%of sampled homes' 375-666 mg/kg orally and approximately cals. It is the most commonly used pesti- In a 2001 study,levels of 2,4-D in indoor air 1500 mg/kg dennally.12 cide in the non-agricultural sector and the and on surfaces(floors,tables,windowsills) sixth most common in the agricultural sec- increased following lawn application of the Chronic Toxicity tor,with over 40 million pounds being used herbicide. This resulted in exposure levels Although amounting body of evidence links in the U.S.annually.' 2,4-D production sup- for children that were ten times higher than 2,4-D to various cancers, particularly non- ports a world market of over$300 million. pre-application and shows that 2,4-D is eas- Hodgkin's lymphoma,EPA has been reluc- While the herbicide is manufactured and ily tracked into homes' tant to classify it as a carcinogen in the face marketed by many different compa- of industry pressure.EPA lists the her- nies,Dow AgroSciences is currently bicide in class D for carcinogenicity. the biggest producer. 2,4-D has been linked to Chemicals in this class are considered to have inadequate evidence for car- 2,4-D is a general use pesticide,and Cancer cinogenicity, or not enough data is does not require a license to use or Endocrine Disruption available." However,the link between purchase.It is used in a wide variety Reproductive Toxicity 2,4-D and non-Hodgkin's lymphoma of locations, including agricultural, has been demonstrated in the United residential, and public areas. 2,4-D Ne'urotoxieity States, Italy, Canada, Denmark, and can be found in many lawn care prod- Kidney/Liver Damage Sweden.14 A 1986 National Cancer In- ucts,it is used as a treatment for road- Toxicity to Dogs, Fish, stitute (NCI) study found that farm- sides and rights of way, and to con- ers in Kansas exposed to 2,4-D for 20 Birds,Earthworms,and trol aquatic weeds.In agriculture it is or more days per year had a six-fold used as a herbicide for grass-like Beneficial Insects higher risk of developing non- crops, including wheat and barley.' I Hodgkin's lymphoma than non-faim- Products containing 2,4-D are often ers.15 The risk of cancer was higher marketed as "weed and feed" and include Acute Toxicity for farmers who mixed or applied the pesti- Aqua-Kleen, Ortho Weed B Gon, Salvo, 2,4-D is produced in several forms,includ- tide themselves.Another study done in 1990 Spectracide, Scotts Green Sweep, ing acids, salts, amines and esters, and its found a 50%increase in non-Hodgkin'slym- U1traStop, and Weedone. toxicity varies between the different forms. phoma in farmers who handle 2,4-D.11 A The EPA toxicity class ranges fiom I-III(on manufacturer's study submitted to EPA in 2,4-D is a selective herbicide,used to kill a I-IV scale with I being the most toxic) 1986 indicated that the herbicide can cause broadleaf weeds with little harm to grass depending on the form and method of ex- rare brain tumors in rats.17 In 1991,an NCI crops.' It is a plant growth regulator, and posure. The diethylamine salt is the most study found that dogs were more likely to mimics the natural plant growth hormone, toxic (class I) by eye exposure. Inhalation contract canine malignant lymphoma if their auxin. Unlike auxins, 2,4-D stays at high generally leads to coughing,burning,dizzi- owners use 2,4-D on their lawns than if levels within plant tissues rather than flue- ness, and loss of muscle coordination.' owners did not use the herbicide.18 When tuating. As a result, it causes rapid cell Oral consumption irritates the digestive 2,4-D was applied four or more times per growth and plants die when their transport tract,results in nausea, diarrhea, vomiting, year, dogs were twice as likely to contract systems become blocked and destroyed by and can lead to kidney and liver damage.10 lymphoma. In addition to these epidemio- abnormally fast growth.' While 2,4-D is 2,4-D is one of few herbicides to cause logical studies,a laboratory study conducted normally applied to a plant's leaves,it can nervous system damage;both digestion and by the Food and Drug Administration(FDA) also be absorbed through the roots and inhalation affect the central nervous sys- found a 4%incidence of lymphoma in rats sterns.' The half-life of 2,4-D in soil is tem. Effects to the nervous system include exposed to 2,4-D and no lymphoma in un- about 1-2 weeks and 1-3 weeks in water.6 inflamed nerve endings, lack of coordina- exposed rats." Despite these studies, the tion, stiffness in the arms and legs, inabil- carcinogenic potential of 2,4-D remains BEYOND PESTICIDES 701 E Street,S.E.,Suite 200,Washington DC 20003 tf 202-543-5450 M • 202-543-4791 M i;F info@beyondpesticides.org • www.beyondpesticides.org controversial. The pesticide industry has age is treated with chlorophenoxy herbi- (about 50%)ofthe herbicide known as Agent criticized some of the studies mentioned cides,including 2,4-D. Children conceived Orange,which was used during the Vietnam here and cites other studies,which support during the time or herbicide production War.However,it is thought that most of the its claire that 2,4-D does not cancer.20 (April-June)were more likely to have birth health problems related to Agent Orange defects." were actually due to dioxin contamination of Long-term exposure to 2,4-D also results the other major component,2,4,5-T.41 While in a wide range of other health problems. Environmental Effects 2,4,5-T was the main culprit and has now Chronic (long-term) oral intake results in Due to its relatively short half-life, 2,4-D been banned, several forms of dioxin have lesions of the kidney and liver in both rats is said to have low persistence in both soil also been found in 2,4-D,including 2,4,7,8- and dogs.21 In humans,two studies showed and water. However, 2,4-D has a high po- TCDD 42 a connection between hepatitis cases and tential to leach from soils, and therefore a chronic oral consumption of 2,4-D, by potential for contaminating ground water. The history of dioxin contamination further golfers who habitually licked their golf The herbicide has been detected in ground increases the dangers related to 2,4-D,par- balls.12 water in at least five states and Canada.Low ticularly for the amine and ester forms." concentrations have also been detected in Dioxins are highly carcinogenic and can 2,4-D is also an endocrine disruptor, a surface water and drinking water in the cause health problems as severe as weak- chemical that can interfere with the body's US.32 ening of the immune system,decreased fer- hormone messaging system and can alter tility, altered sex hormones, miscarriage, many essential processes.2' The National 2,4-D has been shown to have negative im- birth defects, and cancer. EPA studies in Institute of Health Sciences lists 2,4-D as pacts on a number of animals.In birds,2,4- 1994 detected dioxins in a number of 2,4- a suspected endocrine disruptor.24 In stud- D exposure reduced hatching success and D products.43 The Washington Department ies with rats,2,4-D has been shown to alter caused birth defects." It also indirectly af- of Agriculture also detected dioxins in a levels of metabolism and sex hormones.25 fects buds by destroying their habitat and 2,4-D product in 1998 44 food source. The toxicity of 2,4-D to fish Several studies have demonstrated that 2,4- is variable.The butoxyethanol ester is very 2,4-D is currently undergoing EPA's D can be a mutagen,or a substance that in- toxic to fish, but other forms are less reregistration process. According to EPA duces genetic mutations. Workers who ap- toxic.34 2,4-D also bio-accumulates in fish, the Reregistration Eligibility Decision ply 2,4-D had a higher number of white meaning that fish tissues will contain a (RED) is scheduled for May 2005.A1 On blood cells with multiple nuclei than people higher concentration of 2,4-D than the wa- June 23,2004,the EPA released to the pub- who were not exposed 26 In rabbits,2,4-D ter surrounding them, which puts there at lic a series of risk assessment documents exposure resulted in unusual numbers of even greater risk.35 2,4-dichlorophenol, a summarizing current data on the human chromosomes in brain cells.27 Genetic breakdown product of 2,4-D, is extremely health and environmental effects of 2,4- problems like these can have further con- toxic to earthworms, 15 times more toxic D.46 This began a comment period during sequences in terms of cancer and reproduc- than 2,4-D itself.36 The herbicide also has which the EPA will accept statements from tive problems. negative effects on a range of beneficial any interested parties, which will then be insects. It reduces offspring numbers in considered in the final reregistration deci- Reproductive toxicity has also been ob- honeybees, kills predatory beetles and la- sion. As part of the reregistration process, served in relation to 2,4-D.Residues of 2,4- dybug larvae." This reduction in ladybug EPA also required over 200 new studies on D are detectable in urine and semen samples numbers caused an increase in aphids, a 2,4-D.47 A group of major manufacturers of men who apply the herbicide.21 In rats, major pest,in oat fields.38 Consumption of of 2,4-D set up the"Industry Task Force I1 exposure resulted in fetuses with abnormal plants treated with 2,4-D has killed cattle on 2,4-D Research Data" which has now cavity bleeding, increased mortality and and horses and 2,4-D can also indirectly fimded 270 of these studies.41 According genetic damage.29 A 1996 study of private affect many wild mammal species, includ- to EPA, there are still several data gaps in pesticide appliers in Minnesota found a ing moose, gophers, and voles, by damag- the current 2,4-D research.The risk assess- higher rate of birth defects among the chil- ing or killing plants they rely on for food.39 ment indicates that a 28-day inhalation study dren of appliers than the general public.30 is needed because there are no data avail- It also found the birth defect rate to be high- Regulatory Status and History able on the effects of repeated inhalation est in areas where 2,4-D use was the high- 2,4-D was one of the first herbicides to be of 2,4-D. A developmental neurotoxicity est. Another study conducted in 2003 ex- commercially marketed. It was first intro- study is also needed,as well as a 2-genera- amined the wheat producing states of Mon- duced in the United States in the late tion reproductive study that addresses en- tana, Minnesota, South Dakota and North 1940's.40 2,4-D made up a major portion docrine disruptor concerns.41 Dakota,where more than 85%of the acre- BEYOND PESTICIDES 701 E Street,S.E.,Suite 200,Washington DC 20003 202-543-5450(v) • 202-543-4791(f) = r3, info@beyondpesticides.org • www.beyondpesticides.org 2,4-D chemicalWATCHFactsheet Bibliography 1 US EPA.2003.Pesticide Industry Sales and Usage canine malignant lymphoma:positive association Duffard.1981.Embryotoxic and teratogenic effects of Report:1998-1999 Market Estimates.Office of with dog owner's use of 2,4-D herbicides.Journal of plienoxy herbicides.Acta Physiol.Latinoam.31:39- Pesticide Programs,Washington DC.<lritp:// the National Cancer Institute 83(17):1226-1231. 42;Lutz,H.and Y.Lutz-Ostertag.1972.The action of wxvNv.el)a.gov/ol2pbeadI/pestsales/99i)estsates 19 Hansen,W.H.et al.1971.Chronic toxicity of 2,4-D different pesticides on the development of bird table of contents 1999.html>(June 21,2004) in rats and dogs.Toxicology and Applied Pharma- embryos.Adv.Exp.Med.Biol.27:127-150. 'Pesticide Action Network UK.1997.2,4-DFactslieet. cology 20:122-129. 34 World Health Organization.1989.2,4-Dicliloroplte- <Irttp://vvwvv.pan-uk.orOpestnews/Actives/24d.htm> 20 Page,D.L.1996.2,4-D Passes EPA Re-registration noxyacetic acid(2,4-D)-Environmental aspects. (June 2l,2004) Muster.WheatLife 29(9). Geneva,Switzerland. 3 National Pesticide Information Center(NPIC).2004. "Cox,Caroline.1999.Herbicide Factsheet,2,4-D: 35 Wang,Y.,C.Jaw,and Y.Chen.1994.Accumulation Pesticide Fact Sheet for 2,4-D.<Iittp://iii2ic.orst.edu/ Toxicology Part 1.Journal of Pesticide Reform 19(1): of 2,4-D and glyphosate in fish and water.Water Air factsheets/2 4-D.pdf>(June 21,2004) 14-19. SoilPollut.74:397403. 4Hess,F.D.1993.Herbicide effects on plant structure, 22 Leonard,C.et al.1997."Golf Ball Liver":Agent 36 Roberts,B.L.and H.W.Dorough.1984.Relative physiology and biochemistry.In Pesticide interac- orange hepatitis.Cut 40:687-688;Johnston,J.,et al. toxicity of chemicals to the earthworm.Environmen- tions in crop production:Beneficial and deleterious 1998."Golf Ball Liver":A cause of chronic hepatitis? tal Toxicology and Chemistry 3:67-78. effects,ed.Allman,J.Boca Raton:CRC Press. Gnrt42:143-146. 37 Cox,Caroline.1999.Herbicide Factsheet 2,4-D: s See Ref 3 23 Colborn,T.,Saal,F.S.and Soto,A.M.1993. Ecological Effects.Journal of Pesticide Reform 19(3): 6Extension Toxicology Network(ETN).1996. Developmental Effects of Endocrine-Disrupting 14-19. Pesticide Information Profile for 2,4-D.<htttr://// Chemicals in Wildlife and Humans,Environmental 38 Adams,J.B.and M.E.Drew.1965.Grain aphids in extoxnetorstedtLlpips/24-D.htm>(June 21,2004) Health Perspectives 101(5):378-384. New Brunswick Ill,Aphid populations in herbicide 7 Rudel,Ruthann,et al."Phthalates,Alkylphenols, 24 National Institute of Health Sciences.1999.List of treated oat fields.Canadian Journal of Zoology 43: Pesticides,Polybrominated Diphenyl Ethers,and endocrine disrupting pesticides.<httGr//// 789-794. Other Endocrine-Disrupting Compounds in Indoor www.nihs.ao.jp/hse/endocrine-a/paradigm/pesticide/ 39 See Ref.37 Air and Dust."Environmental Science and pest-list-e.htrrnl>(June21,2004) 40 SeeRef.21 Technology 37(20):4543.4553. 25Florsheim,W.H.andS.M.Velcoff.1962.Some 4'See Ref.6 s Nishioka,M.,et al."Distribution of 2,4-D in Air and effects of 2,4-dichloropltenoxyacetic acid on thyroid 42 See Ref.6 and Ref.14 on Surfaces inside Residences after Lawn Applica- fi action in the rat:Effects on iodine accumulation. 43 US Dept of Health and Human Services.1998. tions:Comparing Exposure Estimates from Various Endocrinology 72:327-333;Liu,R.C.et al.1996,The Toxicological profile for chlorinated dibenzo-p- Media for Young Children."Environmental Health direct effect of hepatic peroxisome proliferators on rat dioxins.Public Health Service,Agency for Toxic Perspectives 109(11):1185-1191. Leydig cell function in vitro.Fundamental Applied Substances and Disease Registry;US EPA.1994, 9 See Ref 6 Toxicology 30:102-108. Estimating exposure to dioxin-like compounds,Vol.fl: 10 US EPA.2003.2,4-D(2,4-Dichlorophenoxyacetic 26 Figgs,L.et al.1998.Occupational exposure to the Properties,sources,occurrence and background Acid).Technology TransferNetwork-Air Toxics herbicide 2,4-diclilorophenoxyaceticacid is exposures.Office of Research and Development. Website. <http://w�vw.epa.gov/ttn/ahv/lilthef/di- associated with increased lymphocyte replicative Review draft.Washington DC,June. oxyac.htnti>(June 21,2004) index.Proceedings of the American Association for 44 Washington Depts.of Ecology,Agriculture,and 11 See Ref 6 and Ref 10 Cancer Research 39:337-338. Health.1998.Screening survey for metals and dioxins 11 See Ref 6 21Atanassov,K.1992.Effect of the herbicide in fertilizers,soil amendments,and soils in Washing- 13 US EPA.2000.List of chemicals evaluated for Sclipritshormit(Na salt of 2,4-D)on the karotype of ton state.Olympia WA. carcinogenic potential.Office of-Pesticide Programs. the domesticated rabbit.Animal science 29:54-61. 45 US EPA.2004.Pesticide Reregistration Status. Washington DC. 28 Health Canada.1999.Herbicide Residues Found in Office of Pesticide Programs.<http://cfpub.epa.eov/ 14Cox,Caroline.1999.Herbicide Factsheet:2 4-D: Semen.Farm Family Health Neivsletter.Population oppref/rereJstatus.cfm>(June 21,2004) , Toxicology,Part 2.Journal of Pesticide Reform 19(2): and Public Health Branch.Vol.7,No.2.<http:// 4G US EPA.2004.2,4-DichlorophenoxyaceticAcid, 14-19. ww-,iche-sage.ca/pphb-dgspt�/publicat/ffh-sfa/vol7- Availability of Risk Assessment.Federal Register. 15 S.K.Hoar,et al.1986.Agricultural Herbicide Use 2/ff7-2h e.hlttl>(June 21,2004) Wednesday,June 23,2004.69(120):35019-35021. and a Risk of Lymphoma and Soft-Tissue Sarcoma. "See Ref.6 47 Hammond,L.1996.New Perspectives on an Journal of the American Medical Association 256(9): 30 Garry,V.F.1996.Pesticide appliers,biocides,and Essential Product:2,4-D.Doivn to Earth 50(2). 1141-1147. birth defects in rural Minnesota.Environmental 41 See Ref.20 16 Zalum,S.H.1990.A case control study of non- Health Perspectives 104:394-399. 49 US EPA.Office of Pesticide Programs.Overview of Hodgkin's lymphoma and the herbicide 2,4-D in 31 Schreinemachers,D.M.2003.Birth malformations 2,4-D Risk Assessments.June 18,2004.EPADocket Eastern Nebraska.Epidemiology 1(5):349-356. and other adverse perinatal outcomes in four US Number:OPP-2004-0167-0002;Toxicology Chapterfor 17 Pesticide and Toxic Chemical News.1986.2,4-D wheat-producing states.Environmental Health the Reregistration Eligibility Decision Document. produces rare brain tumor in male rats,EPA officials Perspectives 111(9):1259-1264. Prepared by Linda L.Taylor.EPADocketNumber: note.June 25,1986. 32 See Ref.2 and Ref.6 OPP-0167-0019. IB Hayes,H.M.et al.1991.Case-control study of 33 Duffard,R.,L.Traini,and A.Evangelista de Updated July 2004 ;. BEYOND PESTICIDES 701 E Street,S.E.,Suite 200,Washington DC 20003 202-543-5450(v) • 202-543-4791(f) info@beyondpesticides.org • wwwbeyondpesticides.org chemical WATCH Factsheet AT INE Atrazine,a widely used herbicide on crops, trial weed control. It also restricts the sale several published scientific studies docu- golfcoursesand residential lawns,is linked and use to certified applicators or persons menting adverse effects on amphibians ►pith endocrine disruption,neuropathy and under their direct control.However,even as linked with atrazine exposure.In November cancer. This toxic chemical persists in the anRUP,atrazine contained in lawn care prod- 2003 Natural Resource Defense Council environmentfor long periods of time. ucts can still be purchased over the counter (NRDC)issued a lawsuit charging EPA,the for unsupervised residential use.Home use White House Office of Management and What is Atrazine? cannot be monitored for safe use or han- Budget(OMB),and the White House Co-Lm- The most widely used group of herbicides dling,and leaves open a dangerous route of cil on Environmental mental Quality with violating since their discovery in the 1950's,common exposure. Children are put at risk for post- the law by refusing to disclose documents triazines include atrazine, simazine, application dermal exposures with ordinary regarding the nature ofindustry involvement cyanazine,ametYyn,prometiyn,and zine are play on the lawn.Alarmingly,the common in EPA's assessment of atrazine's safety. used annually,malting it the number one pes- hand-to-mouth behavior of children puts ticide by volume in the U.S. Acute Toxici t3' Most triazines have moder- The Environmental Protec- Atrazine has been linked with ately low acute oral toxicity, tion Agency(EPA)classifies with ratLD50's ranging from atrazine in toxicity class III Cancer 1.4-5.0 grn/ltg.Atrazine falls (on a scale of I to IV,I being Birth Defects in the middle of this range, the highest toxicity class). with aratLD50=3.08gtn/kg. Absorbed by plants,the tri- Reproductive Effects However,fatigue,dizziness, azines act systemically to in- Neurotoxicity nausea, abdominal pain, di- hibit photosynthesis. Crop Kidney/Liver Damage arrhea, vomiting, and irrita- plants are able to partially Sensitizer/Irritant tion of the eye,skin and res- metabolize or otherwise Groundwater Contamination piratory tract,allergic eczema, detoxify the trazines,result- or asthma may follow expo- ing in the compounds'some- Toxic to Fish sure.' Rashes have also been what selective effect. Thus, reported with exposures Tri- the atrazine is used for broad- azines are known to be skin leaf and grassy weed control sensitizers and photosensi- in a variety of crops,includ- tizers for both humans and ing corn, sorghum, sugarcane, pineapple, them at risk for oral exposure as well.Adults other animals. Christmas trees,as well as in conifer resto- can also be exposed dermally, especially ration plantings!Annually,75%of all corn, when conducting higher contact activities In animals,triazines are not retained for ex- 58.5% of all sorghum, and 76% of sugar- such as heavy yard work. Inhalation, oral tended periods.Atrazine rat metabolism stud- cane grown are treated with atrazine,mostly and dermal exposures are also concerns for ies"found 65%was eliminated in the urine as a pre-emergent 2 It is also used as a non- adults during application.In January 2003, and 15%was retained in body tissues,mainly selective herbicide on turf, including golf the label for home application formulations in the liver,kidneys, and lungs.6 The most courses and residential lawns. Due to the was changed to somewhat limit,but not ban, common metabolic reactions are amine nature of atrazine, its use on lawns is usu- residential uses of atrazine,leaving the route dealkylation and side chain oxidation. ally limited to the SE,specifically Florida. of exposure open. There are no public health uses? Chronic Toxicity In October 2003,which was the settled dead- Animals given an oral dosage of atrazine for In 1990, EPA classified atrazine as a Re- line to incorporate threats to amphibians in 6 months showed respiratory distress, pa- stricted Use Pesticide(RUP),which included its atrazine risk assessment,EPA announced ralysis of the limbs,structural and chemical label amendments that reduced application that it had negotiated a deal with industry changes in the brain,heart,liver,lungs,kid- rates for agricultural uses and limited the that would not require any new restrictions ney, ovaries, and endocrine organs, as well maximum annual application rate for indus- on atrazine use. The decision carne despite as growth retardation.In a 2-year study with Aelond neat®41-48105 701 E Street, 5.E., Suite 200,Washington DC 20003 202-543-5450 (v) • 202-543-4791 (f) info@beyoiidpesticides.org beyondpesticides.org • www.beyondpesticides.org dogs,7.5 mg/kg/day caused decreased food tional Water Quality Assessment study Plants intake and increased heart and liver weights, found alterations in sex steroid hormones Plants can absorb atrazine through the roots increased adrenal weight,lowered blood cell (estrogen and testosterone)and vitellogenin and sometimes through the foliage.Once ab- counts, and occasional tremors or stiffness (egg protein produced by females)in blood sorbed, it accumulates in the growing tips in the rear limbs.' of wild carp that appear to be related to cer- and the new leaves of the plant, inhibiting tain chemical groups including atrazine dis- photosynthesis in susceptible plant species. Atrazine has also been implicated in the de- solved in water.15 Later research began de- In tolerant plants,it is metabolized.21 Atra- velopment of sensory motor polyneuropa- tecting effects in humans. A 2003 study zine increases the uptake of arsenic by thy in a farmer whole skin was exposed over found elevated levels of pesticide metabo- treated plants.22 several days.' lites, including atrazine, in men's urine Water Contamination samples, correlated with poor semen qual- As the second most common pesticidal wa- Carcinogenicity ity.16 ter contarninant23,atrazine shares character- EPA states atrazine is"not likely to be carci- istics with other tiazines which make them nogenic to hmnans"despite numerous stud- Frogs As Indicators of Toxicity serious threats to groundwater:high leach- ies that suggest otherwise.The chemical has A 2002 study found that male Leopard Frogs ing potential,persistence in soils, slow hy- been shown to cause cancer in the mammory dosed with>.1 part per billion(ppb)of atra- drolysis,low vapor pressure,moderate solu- glands of rats.9 One study showed women zine in water developed dramatic female bility in water, and moderate adsorption to workers exposed to atrazine were nearly three sexual characteristics, including retarded matter and clay. Hydrolysis of atrazine in tunes more likely to suffer ovarian cancer.10 gonadal development(gonadal dysgenesis) water,important for the disappearance ofthe A study conducted by Syngenta found a and testicular oogenesis (hermaphrodit- chemical if it is followed by biodegradation, statistically significant increase in prostate ism)."In addition,Joseph Kiesecker of Penn- is slowed in water of neutral pHs.24 Atrazine cancer among longtime workers at its St. sylvania State University tested the role that has been detected in each of 146 water Gabriel,LA atrazine production facility.Epi- pesticides, including atrazine, play in frog samples collected at 8 locations fromthe Mis- demiological studies have linked triazine ex- deformities.His findings suggest that pesti- sissippi,Ohio and Missouri Rivers and their posure to increased risk of non-Hodgkin's cides severely weaken the immune system, tributaries.27%of these samples contained lymphoma.11 In 2002,research by the Na- malting flogs much more susceptible to para- atrazine concentrations above the EPA's tional Lymphoma Foundation of America sitic infection and deformities.18 Scientists maximum contaminant level(MCL)25 showed an increase in lymphoma in popula- emphasize the importance of these findings Despite the problematic nature of atrazine tions with higher exposures to pesticides. when the threat is translated to human health. as a water contaminant, EPA announced a Atrazine was among the herbicides most fre- Environmentalists also hold concerns for deal in October 2003 to allow atrazine manu- quently associated with the increased inci- other wildlife facing risks from atrazine ex- facturer Syngenta to be responsible for test- dence and/or with mortality.12 posure such as sea turtles in the Chesapeake ing U.S.waterways for contamination of the Bay; salamanders in Austin, Texas; fresh- very chemical they produce. The program Endocrine Disruption water mussels in Alabama; and fish in the will begin in March 2004,and at its peak will Atrazine at low concentrations interferes with Midwest. only cover 3.4%of the 1172 highest-risk wa- the production and activity of sex hormones tersheds. The approach was developed by in salmon,causing decreases in the produc- Environmental Fate EPA,atrazine manufacturers,the US Depart- tion of sperm.13 Synergistic effects were de- Soil merit ofAgticulture and grower groups,bar- tected in mice exposed to aldicarb,atrazine Atrazine is highly persistent in soil,and can ring environmentalists frorn the negotia- and nitrate at levels of contamination within persist for longer than 1 year under dry or tion.26 the range often encountered in U.S. water cold conditions.19 Its half-life is between 60 supplies.14 A U.S. Geological Survey Na- and 100 days.20 Atrazine chemicalWATCH Factsheet Bibliography 1"Atrazine"Pesticide Information Profile, tion Agency Office of Prevention, January,2003. Extension Toxicology Network. Pesticides and Toxic Substances. 4 Ellenhorn,M.J.,S.Schonwald,G Ordog, Oregon State University. http:// January,2003. J.Wasserberger.Ellenhorn's ace.orst.edu/info/extoxnet/pips/ 3"Interim ReregistationEligibility Medical Toxicology:Diagnosis at•azine.htm,June 1996. Decision for Atrazine"Case No. and Treatment of Human Poison 2"Interim Reregistration Eligibility 0062.U.S.Environmental Protec ing.2nd ed.Baltimore,MD: Decision for Atrazine"Case No. tion Agency Office of Prevention, Williams and Wilkins,1997.1643 0062.U.S.Environmental Protec Pesticides and Toxic Substances. 5"Atrazine"Pesticide Information Profile, Aeyond Peetikides 701 E Street, S.E., Suite 200, Washington DC 20003 202-543-5450 (v) • 202-543-4791 (f) info@beyondpesticides.org • www.beyondpesticides.org Atrazine chemicalWAT'CH Factsheet Bibliography June 1996.Extension Toxicology Lymphoma Foundation of Volume 111,Number 12,Septem Network.Oregon State Univer America,Arlington VA.2001. ber 2003. sity. http://ace.orst.edu/info/ 13 Waring,C.P.&Moore,A.,"Environ "Hayes et al.,"Atrazine-Induced Her extoxnet/pips/atrazine.htm mental atrazine:Physiological maphroditism at 0.1 ppb in 'Stevens,J.T.and Sumner,D.D.Herbi effects on Atlantic Salmon(Sahno American Leopard Frogs(Rana cides.In Handbook of Pesticide salar)smolts in fresh water and pipiens):Laboratory and Field Toxicology.Hayes,W.J.,Jr.and after seawater exposure." Evidence,"Environmental Laws,E.R.,Jr.,Eds.Academic Presented at International Health Perspectives,Volume 111, Press,New York,NY,1991.8-4 Congress on the Biology of Number 4,April 2003. 'Stevens,J.T.and Sumner,D.D.Herbi Fishes,San Francisco,July 1996. 18 Kiesecker,Joseph.M.,"Synergism cides.In Handbook of Pesticide and Waring,C.P.&Moore,A., between trematode infection and Toxicology.Hayes,W J.,Jr.and "Mechanistic effects of a triazine pesticide exposure:A link to Laws,E.R.,Jr.,Eds.Academic pesticide on reproductive amphibian limb deformities in Press,NewYork,NY,1991.8-4 endocrine function in mature male nature?"Proceedings of the s Ellenhorn,M.J.,andBarceloux,D.G., Atlantic salmon(Sahno salar)," National Academy of Sciences, 1988.Medical Toxicology: PesticBiochem Physiol.62:41- vol.99,no.15,9900-9904.July 23, Diagnosis and Treatment of 50.1998. 2002 Human Poisoning.NewYork,NY. 14 Porter,WP,JW Jaeger and IH Carlson, "Howard,P.H.,Ed.Handbook of Environ Elsevier:1078-1080. `Endocrine,immune and behav mental Fate and Exposure Data 9 Stevens,J.T.and Sumner,D.D.Herbi ioral effects of aldicarb(carbain for Organic Chemicals.Pesticides. cides.In Handbook of Pesticide ate),atrazine(triazine)and nitrate Lewis Publishers,Chelsea,MI, Toxicology.Hayes,W.J.,Jr.and (fertilizer)mixtures at groundwater 1989.8-22. Laws,E.R.,Jr.,Eds.Academic concentrations" Toxicology and 20"Atrazine"Pesticide Information Profile, Press,NewYork,NY,1991.8-4 Industrial Health, 15:133-150. 10A.Donna,et al.,"Triazine Herbicides 1999. Extension Toxicology Network. 15« Oregon State University. hgp:// Epithelial Neo and Ovarian E Investigations of Endocrine Disiup P ace.orst.edu/info/extoxnetlpips/ plasms," Scandinavian Journal tion in Aquatic Systems Associ atrazine.htm,June 1996. of Work and Environmental ated with the National Water 21 Kidd,H.and James,D.R.,Eds.The Health,15:47-53,1989. Quality Assessment(NAWQA) 11 Hoar,S.K.et al."Agricultural herbicide Program,"USGS Fact Sheet FS- Agrochemicals Handbook,Third 081-98U.S.Department ofthe Edition.Royal Society of Chemis . . . use and risk of lymphoma and try Information Services,Cam soft-tissue sarcoma."Journal of Interior,USGS.October 1998. bridge,UK,1991(as updated).8-7. American Medical Association, 16 Swan,Sharma H.,et al,"Semen Quality 22 U.S.National Library of Medicine. 256(9);1141-1147,1986. in Relation to Biomarkers of Hazardous Substances Databank. 12 Osburn,Susan,M.T.(ASCP),M.A.,"Do Pesticide Exposure,"Environ Pesticides Cause Lymphoma?" mental Health Perspectives Updated December 2003 0ey®nd Peetieidee 701 E Street, S.E., Suite 200,Washington DC 20003 202-543-5450 (v) • 202-543-4791 (f) info@beyondpestieides.org • www.beyondpesticides.org � ��v � � � ld re P"ticlv,.de Children are especially vulnerable to IN A201Ometa-analysis of15 studies onresidential pesticide pesticides use and childhood leukemia finds anassociation with expo- sure duringpraQnancAaswe||ostoinsecbddosandherbi- • The National Academy ofSciences reports that children are ddes.Anassociation ioalso found for exposure toinserd- �z moresuscepdb|etoohemica|sthanadulisandesdmatesthat ddesduring childhood. 5O%oflifetime pesticide exposure occurs during the first five years of|ihe.' 0 AZO13study suggests that preconception pesticide expo' oure,andpuyoib|yexposunodurinOpro0noncy, isaosociated • EPA concurs that children take inmore pesticides relative to with anincreased risk ofchildhood brain tumors,zz body weight than adults and have developing organ systems that are more vulnerable and less able todetoxifytoxic M According toa2Ol5study,living inagricultural regions is chemicab.z linked tnincreased leukemia and central nervous system cancers in uhildren.13 • Infants crawling behavior and proximity tothe floor account for ogreater potential than adults for dermal and inhalation M Ameta-analysis study byscientists atthe Harvard University's exposure tocontaminants uncarpets,floors, lawns,and soil.a School ofPublic Health finds that children's exposure topes- ticides inandanoundthehomeeou|tsinonincreosedriokof • Children with developmental delays and those younger than developing certain childhood cancers.Authors found that can- six yeamareatincoeaoedriskofin0eotingpeudddenthrough cerrisks were connected most closely tothe type ofpesticide nonfood items,such uoSni|.4 used and the location where itwas app|ied.14 • Pre-natal exposure tothe herbicide atrazine are associated 0 The probability ofaneffect xuohuouunce�which requires fetal aperiod of�metodevelop a�e/exposure,isenhanced if s and fetal growth restriction. exposure occurs early in life. • A2U1Oanalysis observed that women who use pesticides M A study published inthe Journal oƒthe National Cancer intheir homes oryards were two times more likely tohave Institute finds that household and garden pesticide use can in- children withneumltubedefectoth»nvvomenvvithoutthese s reported exposures. Commonly.Used Chemicals. • Studies find that pesticides such asthe weedkiller Z,4-D pass from mother tochild through umbilical cord blood and breast milk.7 M Consistent observations have led investigators toconclude that chronic low-dose exposure tocertain pesticides might 8 pose ahazard tothe health and development ofchildren. N The World Health Organization(VVHO)cites that over 3U%ofhead Ii 6,gardL the global burden ofdisease inchildren can beattributed to n environmental factors,including pesticides. Key: Birth/developi�oental.defpcts=�d,Kidne /Ii Children, cancer and pesticides 0 |n201S,WHO found that there was sufficient evidence of Alternatives- carcinogenicity �Mduc'elbkjic�sur6 to toxic cheml sate,the active ingredient inthe most popular|awnoare -organic,orintegrate, (IP ei$d.pest:m-an, gement .. M)'practic that brand(Roundup)oo"probably carcinogenic tuhumans" (Group 2A).WHO also found that 2,4'D'found inmany .:and least7foxic chemicals only.as a1ast resort An-.or a I nitcliet 10 'weed and feed' pmm duot�'ispnss�b|ycaino0enio. .._�,�_..a. . _..e.®.e..... ...,e_�..__e — ._o.mym..—. . _.._...._._.. ....__a....._._ — .. _._'e..e. . .._e._....e.. ..,.....m..e�e �}I ' 5 _ Studies show children's develop ng organs create "early windows of 2 great vulnerability" during which " exposure to 'pesticides can cause great damage. � � F I. crease the risk of childhood leukemia as much as seven-fold.16 B One 2015 farmworker study found an association between early-life exposure to OPs and respiratory symptoms consis- 0 Studies show that children living in households where pesti- tent with possible asthma in childhood.zs tides are used suffer elevated rates of leukemia, brain cancer and soft tissue sarcoma.17 ■ A 2012 study concluded that prenatal PBO exposure was as- sociated with childhood cough in inner city children.26 ■ Pesticides can increase susceptibility to certain cancers by breaking down the immune system's surveillance against ® A 2004 study finds that young infants and toddlers exposed cancer cells. Infants and children,the aged and the chroni- to herbicides(weedkillers)within their first year of life are tally ill are at greatest risk from chemically-induced immune 4.5 times more likely to develop asthma by the age of five, suppression.18 and almost 2.5 times more likely when exposed to insecti- cides.27 ■ A study published by the American Cancer Society finds an increased risk for non-Hodgkin's lymphoma(NHL) in people 0 EPA material safety data sheets for the common herbicides exposed to common herbicides and fungicides,particularly 2,4-D, mecoprop,dicamba,(often combined as Trimec®)and the weedkiller mecoprop(MCPP). People exposed to glypho- glyphosate(Roundup®)list them as respiratory irritants that sate(Roundup®)are 2.7 times more likely to develop NHL.19 can cause irritation to skin and mucous membranes,chest burning,coughing, nausea and vomiting. ■ 75 out of all 99 human studies done on lymphoma and pesti- cides find a link between the two.20 Children, learning and developmental ® Four peer-reviewed studies demonstrate the ability of disorders and pesticides glyphosate-containing herbicides to cause genetic damage to DNA(mutagenicity),even at very low concentration levels.21 0 Roughly one in six children in the U.S. has one or more de- velopmental disability,ranging from a learning disability to a ■ A 2007 study published in Environmental Health Perspectives serious behavioral or emotional disorder.28 finds that children born to mothers living in households with pesticide use during pregnancy had over twice as much risk ® Scientists believe that the amount of toxic chemicals in the of getting cancer,specifically acute leukemia (AL)or non- environment that cause developmental and neurological Hodgkin lymphoma(NHL).22 damage are contributing to the rise of physical and mental effects being found in children.29 ■ A 2007 Canadian report shows that a greater environmen- tal risk exists for boys,specifically when it comes to cancer, ® According to researchers at the University of California- asthma, learning and behavioral disorders, birth defects and Berkeley School of Public Health,exposure to pesticides testicular dysgenesis syndrome.23 while in the womb may increase the odds that a child will have attention deficit hyperactivity disorder(ADHD).30 Children, asthma and pesticides ■ Studies show children's developing organs create"early ■ Researchers find that pesticides may increase the risk of windows of great vulnerability"during which exposure to developing asthma,exacerbate a previous asthmatic condi- pesticides can cause great damage.31 tion or even trigger asthma attacks by increasing bronchial hyper-responsiveness.24 0 Lawn pesticide products containing herbicides and fertilizers (such as"weed and feed"products)tested on mice show ■ Biomonitoring testing in Canada finds residues of lawn increased risk of infertility, miscarriage and birth defects at pesticides,such as 2,4-D and mecoprop,in 15 percent of very low dosages.32 children tested,ages three to seven,whose parents had recently applied the lawn chemicals. Breakdown products of ■ Results from a CHARGE study finds that agricultural expo- organophosphate insecticides are present in 98.7 percent of sures to organophosphates at some point during gestation children tested 40 was associated with a 60%increased risk for austism higher for third-trimester exposures,and second-trimester chlorpy- ■ Scientific studies show that 2,4-D applied to lawns drifts and rifos applications.Similarly,children of mothers residing near is tracked indoors where it settles in dust,air and surfaces pyrethroid insecticide applications just before conception or and may remain for up to a year in carpets.41 during third trimester were at greater risk for both autism and developmental delay.33 ■ One 2014 analysis of 129 preschool children,ages 20 to 66 months,found that children were exposed to indoor concen- ■ Researchers at the Cincinnati Children's Hospital Medical trations of pyrethroids,organophosphates and organochlo- Center found an association between increasing pyrethroid rines pesticides which were detected in soil,dust and indoor pesticide exposure and ADHD which they conclude may be air.42 stronger for symptoms seen in boys compared to girls.34 ■ Samples from 120 Cape Cod homes,where elevated inci- ■ Additional studies on lawn pesticide product formulations dente of breast,colorectal,lung,and prostate cancers are show effects on learning ability,aggressiveness,memory, reported,find high indoor air and dust concentrations of motor skills and immune system function.35 carbaryl,permethrin,and 2,4-D.43 ■ A 2002 study finds children born to parents exposed to ■ A study published in Environmental Health Perspetives glyphosate(Roundup®)show a higher incidence of attention found that children who eat a conventional diet of food deficit disorder and hyperactivity.36 produced with chemical-intensive practices carry residues of organophosate pesticides that are reduced or eliminat- ■ A study of 210,723 live births in Minnesota farming commu- ed when they switch to an organic diet.44 nities finds children of pesticide applicators have significantly higher rates of birth defects than the average population.37 ■ Scientists at the California Department of Public Health found that 28%of the mothers studied who lived near ■ In a 2004-2005 review of 2,4-D, EPA finds that,"there is a fields in the Central Valley,which were sprayed with organo- concern for endocrine disruption.i38 chlorines,such as endosulfan and dicofol,have children with autism.45 Pesticide accumulation and drift ■ A 2005 study published in the Journal of the American ■ Children ages 6-11 nationwide have significantly higher Medical Association found that students and school em- levels of pesticide residues in their bodies than all other age ployees are being poisoned by pesticide use at schools and categories.39 from drift off of neighboring farmlands.46 Endnotes 1. National Research Council,National Academy of Sciences.1993.Pesticides in the Diets of Infants and Children,National Academy Press,Washington,DC.184-185. 2. US EPA,Office of the Administrator,Environmental Health Threats to Children,EPA 175-F-96-001,September 1996.See also:http://www.epa.gov/pesticides/ food/pest.htm. 3. Bearer,CF.2000."The special and unique vulnerability of children to environmental hazards."Neurotoxicology 21:925-934,•Fenske,R.,et al.1990. 'Potential Exposure and Health Risks of Infants following Indoor Residential Pesticide Applications."Am J.Public Health.80.689-693. 4. Foustman EM,Silbernagel SM,Fenske RA,Burbacher TM,Ponce RA.2000. "Mechanisms underlying children's susceptibility to environmental toxicants."Envi- ronmental Health Perspectives.108(suppl1):13-21. 5. Chevrier C,Limon G,Monfort C,Rouget F,Garlantezec R,Petit C,et al.2011.Urinary Biomarkers of Prenatal Atrazine Exposure and Adverse Birth Outcomes in the PELAGIE Birth Cohort.Environ Health Perspect.119:1034-1041 6. Brender,JD.,et al.2010.Maternal Pesticide Exposure and Neural Tube Defects in Mexican Americans.Ann Epidemiol.20(1):16-22 7. Pohl,HR.,et al.2000. "Breast-feeding feeding exposure of infants to selected pesticides,"Toxicol Ind Health 16:55-77,•Sturtz,N.,et al.2000.'Detection of 2,4-dichlo- rophenoxyacetic acid(2,4-D)residues in neonates breast-fed by 2,4-D exposed dams."Neurotoxicology 21(1-2):147-54;Houlihan,J.,et al.2005.Body Burden, The Pollution in Newborns.Environmental Working Group,Washington,D.C.http://www.ewg.org/reportslbody_burden2/(accessed8/5/05). 8. Weiss,B.,et al.2004 April.'Pesticides,"Pediatrics 113(4):1030-1036. 9. World Heath Organization(WHO).2006.Principles for Evaluating Health Risks in Children Associated with Exposure to Chemicals.Geneva,Switzerland. 10. (IARC.IARC Monographs Volume 112:evaluation of five organophosphate insecticides and herbicides.20 march 2015.http://www.iorc fr/en/media-centre/iarc- news/pdf/MonographVolume112.pdf;and IARC.Carcinogenicity of lindane,DDT,and 2,4-dichlorophenoxyacetic acid.The Lancet Oncology,16(8).p891-892. 11. Turner,M.C.,et al.2010.Residential pesticides and childhood leukemia:a systematic review and meta-analysis.Environ Health Perspect 118(1):33-41 Endnotes continued 12. Green KR,Peters S,Bailey HD.2013)Exposure to pesticides and the risk of childhood brain tumors.Cancer Causes Control.DOI 10.10071s10552-013-0205-1 13, Booth BJ,Ward MH,Turyk ME,et al.2015.Agricultural crop density and risk of childhood cancer in the midwestern United States:an ecologic study.Environ- mental Hea)th:14(82) 14. Chen M,Chi-Hsuan C,Tao L,et al.2015.Residential Exposure to Pesticide During Childhood and Childhood Cancers:A Meta-Analysis.Pediatrics.DOI:10.1542/ peds.2015-0006 15. Vasselinovitch,S.,et al.1979.'Neoplastic Response of Mouse Tissues During Perinatal Age Periods and Its Significance in Chemical Carcinogensis,"Perinatal Carcinogenesis,National Cancer Institute Monograph 51. 16. Lowengart,R.,et al.1987."Childhood Leukemia and Parent's Occupational and Home Exposures,"Journal of the National Cancer Institute 79:39. 17. Leiss,J.,et al.1995. 'Home Pesticide Use and Childhood Cancer:A Case-Control Study,"American Journal of Public Health 85:249-252;Gold,E.et al.1979. 'Risk Factors for Brain Tumors in Children,"Am J of Epidemiology 109(3):309-319;Lowengart,P.,et al.1995."Childhood Leukemia and Parents'Occupational and Home Exposures,"J National Cancer Institute 79(1):39-45;Reeves,J.1982. 'Household Insecticide-Associated Blood Dyscrasias in Children,"(letter)Am J of Pediatric Hematology/Oncology 4:438-439;Davis,J.,et al.1993. 'Family Pesticide Use and Childhood Brain Cancer,"Archives of Environmental Contamina- tion and Toxicology 24:87-92;Buckley,J.,et al.1994. 'Epidemiological characteristics of Childhood Acute Lymphocytic Leukemia,"Leukemia 8(5):856-864. 18. Repetto,R.,et al.1996 March.Pesticides and immune System:The Public Health Risk,World Resources Institute,Washington,DC 19. Hardell,L.,et al.1999 Mar.'A Case-Control Study of Non-Hodgkins Lymphoma and Exposure to Pesticides,"J of the Am Cancer Soc,(85):6.p.1353. 20. Osburn,S.2001.Do Pesticides Cause Lymphoma?Lymphoma Foundation of America,Chevy Chase,MD. 21. Cox C.2004 Winter. 'Glyphosate."Journal Of Pesticide Reform Vol.24(4). 22. Rudant J.et al.2007 Household Exposure to Pesticides and Risk of Childhood Hematopo)etic Malignancies:The ESCALE Study(SFCE).Environ Health Perspect. 115:1787-1793. 23. Canadian Partnership For Children's Health and Environment 2007.A Father's Day Report-Men,Boys And Environmental Health Threats.www.healthyenvi- ronmentforkids.ca. 24. Hern6ndez,AF.,Parr6n,T.and Alarc6n,R.2011.Pesticides and asthma.Curr Opin Allergy Clin immuno).11(2):90-6 25. Raanan R,Harley KG,Balmes JR,et al.2015.Early-life exposure to organophosphate pesticides and pediatric respiratory symptoms in the CHAMACOS cohort. Environ Health Perspect.123(2):179-85. 26. Liu B,Jung KH,Horton MK,et al.2012.Prenatal exposure to pesticide ingredient piperonyi butoxide and childhood cough in an urban cohort Environ Int. 48:156-61. 27. Salam,MT,et al.2004.'Early Life Environmental Risk Factors forAsthma:Findings from the Children's Health Study."Environmental Health Perspectives 112(6):760. 28. Boyle,C.A.,et al.1994. 'Prevalence and health impact of developmental disabilities in US children."Pediatrics 93:399-403. 29. National Research Council.2000.Scientific frontiers in developmental toxicology and risk assessment.Washington,DC:National Academy Press;Physicians for Social Responsibility,The National Environmental Trust,and the Learning Disabilities Association ofAmerica.2000.Polluting ourfuture:Chemical pollution in the U.S,that affects child development and learning.http://www.neLorg/health/tri report.pdf(accessed 6/2/05). 30. Marks AR,Harley K,Bradman A,Kogut K,Barr DB,Johnson C,et al.2010.Organophosphate Pesticide Exposure and Attention in Young Mexican-American Children:The CHAMACOS Study.Environ Health Perspect 118:1768-1774. 31. Landrigan,P.J.,L Claudio,SB Markowitz,et al.1999.'Pesticides and in-ner--city children:exposures,risks,and prevention."Environmental Health Perspectives 107(Suppl 3):431-437. 32. Greenlee,A.et al.2004. "Low-Dose Agrochemicals and Lawn-Care Pesticides Induce Developmental Toxicity in Murine Preimplantation Embryos,"Environ- mental Health Perspectives 112(6):703-709;Cavieres,M.,et al.2002. 'Developmental toxicity of a commercial herbicide mixture in mice:Effects on embryo implantation and litter size."Environmental Health Perspectives 110:1081-1085. 33. Shelton,Geraghty,Tancredi.2014.Neurodevelopmental Disorders and Prenatal Residential Proximity to Agricultural Pesticides:The CHARGE Study.Environ- mental Health Perspectives:122(10). 34. Wagner-Schuman,M,Richardson,J,Auinger,P et al.2015.Association of pyrethroid pesticide exposure with attention-deficit/hyperactivity disorder in a nationally representative sample of U.S,children.Environmental Health.14:44 35. Porter,W.2004 Spring. 'Do Pesticides Affect Learning and Behavior?The neuro-endocrine-immune connection,"Pesticides and You,Beyond Pesticides 21(4):11- 15;Shettler,T.,et al.2000.'Known and suspected developmental neurotoxicants,"In Harms Way:Toxic Threats to Child Development,Greater Boston Physicians for Social Responsibility:Cambridge,MA;Mitchell,J.et al.1989."The Behavioral Effects of Pesticides in Male Mice,"Neurotoxicology and Teratology 11:45-50. 36. Cox C 2004.Journal Of Pesticide Reform Vol.24(4)citing:Garry,V.F.et al.2002."Birth defects,season of conception,and sex of children born to pesticide ap- plicators living in the Red River Valley of Minnesota."Environmental Health Perspectives 110(Suppl.3):441-449. 37. Garry,V.,et al.1996.'Pesticide appliers,biocides,and birth defects in rural Minnesota."Environmental Health Perspectives 104(4):394-399. 38. EPA.2004 June.2,4-D.HED's Human Health Risk Assessment for the Reregistration Eligibility Decision(RED).p7. 39. Centers for Disease Control and Prevention.2003 Jan.Second National Report on Human Exposure to Environmental Chemicals. 40. Valcke,Mathieu,et al.2004. "Characterization of exposure to pesticides used in average residential homes with children ages 3 to 7 in Quebec."Not Inst of Public Health,Quebec.www.inspq.gc.ca/pdf/publico-tions/319-CarocterisationPesticidesEnfants.pdf(accessed 6/2/05). 41. Nishioka,M.,et al.1996. "Measuring lawn transport of lawn-applied herbicide acids from turf..."Env Science Technology,30:3313-3320,•Nishioka,M.,et a). 2001. 'Distribution of 2,4-D in Air and on Surfaces Inside Residences..."Environmental Health Perspectives 109(11). 42. Morgan,M,Wilson,N,and Chuang C.2014.Exposures of 129 Preschool Children to Organochlorines,Organophosphates,Pyrethroids,and Acid Herbicides at Their Homes and Daycares in North Carolina.Int.J.Environ.Res.Public Health,11(4),3743-3764 43. Rude),Ruthann,et al.2003. 'Phthalates,Alkylphenols,Pesticides,Polybrominated Diphenyl Ethers,and Other Endocrine-Disrupting Compounds in Indoor Air and Dust."Environmental Science and Technology 37(20):4543-4553. 44. Lu,C.et al.2008.Dietary Intake and its Contribution to Longitudinal Organophosphorus Pesticide Exposure in Urban/Suburban Children.Environmental Health Perspectives doi:10.1289/ehp.10912 available via http://dx.doi.org/. 45. Roberts,C.et al.2007.Maternal Residence Near Agricultural Pesticide Applications and Autism Spectrum Disorders among Children in the California Central Valley. Environmental Health Perspectives 115(10) 46. Alarcon,WA.et al.2005.Acute illnesses associated with pesticide exposure at school.J Am Medical Association 294(4);455-465. BEYOND PESTICIDES 701 E Street, SE x Washington IAC 20005 202-543-5450 phone . 202-543--4791 'Fox t1 info@beyondpesticides.org x wwwbeyondposticides.org LAWN PESTICIDE FACTS AND FIGURES A Beyond Pesticides Factsheet PESTICIDE USAGE • 78 million households in the U.S. use home and garden pesticides. ' • Herbicides account for the highest usage of pesticides in the home and garden sector with over 90 million pounds applied on lawns and gardens per year." • Suburban lawns and gardens receive more pesticide applications per acre (3.2-9.8 lbs) than agriculture (2.7 lbs per acre on average)."' Pesticide sales by the chemical industry average $9.3 billion. Annual sales of the landscape industry are over$35 billion.' • Included in the most commonly used pesticides per pounds per year are: 2,4-D (8-11 million), Glyphosate (5-8 million), MCPP (Mecoprop) (4-6 million), Pendimethalin (3-6 million), Dicamba (2-4 million)." A 2004 national-survey reveals that 5 million homeowners use only organic lawn practices and products and 35 million people use both toxic and non-toxic materials."' HEALTH& EXPOSURE RISKS • Of 30 commonly used lawn pesticides 13 are probable or possible carcinogens, 13 are linked with birth defects, 21 with reproductive effects, 15 with neurotoxicity, 26 with liver or kidney damage, 27 are sensitizers and/or irritants, and 11 have the potential to disrupt the endocrine (hormonal) system." • Pregnant women, infants and children, the aged and the chronically ill are at greatest risk from pesticide exposure and chemically induced immune-suppression, which can increase susceptibility to cancer."' • Scientific studies find pesticide residues such as the weedkiller 2,4-D and the insecticide carbaryl inside homes, due to drift and track-in, where they contaminate air, dust, surfaces and carpets and expose children at levels ten times higher than preapplication levels.'" CHILDREN& PESTICIDES • Children take in more pesticides relative to body weight than adults and have developing organ systems that make them more vulnerable and less able to detoxify toxins." • The National Academy of Sciences estimates 50% of lifetime pesticide exposure occurs during the first 5 years of life."' • A study published in the Journal of the National Cancer Institute finds home and garden pesticide use can increase the risk of childhood leukemia by almost seven times."" • Studies show low levels of exposure to actual lawn pesticide products are linked to increased rates of miscarriage, and suppression of the nervous, endocrine, and immune systems." • Exposure to home and garden pesticides can increase a child's likelihood of developing asthma."'" • Studies link pesticides with hyperactivity, developmental delays, behavioral disorders, and motor dysfunction." • Children ages children ages 6-11 have higher levels of lawn chemicals in their blood than all other age categories. Biomonitoring studies find that pesticides pass from mother to child through umbilical cord blood and breast milk.'"' WILDLIFE, PETS& PESTICIDES • Studies find that dogs exposed to herbicide-treated lawns and gardens can double their chance of developing canine lymphoma and may increase the risk of bladder cancer in certain breeds by four to seven times.'"" • Of 30 commonly used lawn pesticides: 16 are toxic to birds, 24 are toxic to fish and aquatic organisms, and 11 are deadly to bees.'""' • Pesticides can be toxic to wildlife and cause food source contamination, behavioral abnormalities that interfere with survival, and death."'X • Lawn and garden pesticides are deadly to non-target species and can harm beneficial insects and soil microorganisms essential to a naturally healthy lawn.' PESTICIDES IN THE WATER • Of 30 commonly used lawn pesticides, 17 are detected in groundwater, and 23 have the potential to leach.`' • Runoff has resulted in a widespread presence of pesticides in streams and groundwater. 2,4-D, found in weed and feed and other lawn products, is the herbicide most frequently detected in streams and shallow ground water from urban lawns.`" • Of the 50 chemicals on EPA's list of unregulated drinking water contaminants, several are lawn chemicals including herbicides diazinon, diuron, naphthalene, and various triazines such as atrazine."` • Runoff from synthetic chemical fertilizers pollutes streams and lakes and causes algae blooms, depleted oxygen and damage to aquatic life. THE REGISTRATION SYSTEM& PESTICIDE REGULATION • The health data assessed by EPA for the registration of pesticides comes from the manufacturer of the pesticide. EPA is not obligated under the Federal Insecticide Fungicide and Rodenticide Act(FIFRA) to review peer-reviewed scientific literature. • The U.S. GAO has told Congress on several occasions that the public is misled on pesticide safety by statements characterizing pesticides as "safe" or"harmless." EPA states that no pesticide is 100 percent safe.`" • Pesticide testing protocol was developed before science fully understood the human immune and hormonal system. EPA still does not evaluate data for several neurological effects or disruption of the endocrine (hormonal) system. • EPA does not evaluate the health and environmental effects of actual pesticide formulations sold on the shelf. Data submitted to the EPA also does not account for low-dose effects, synergistic effects with inerts or combined exposure to more than one pesticide at a time. • Most states have preemption laws that prohibit localities from passing local pesticide-related ordinances that are stricter than the state policy.' 2 "INERT" INGREDIENTS • Pesticide products are made of an active ingredient and several inert, or other, ingredients. Inert ingredients are neither chemically, biologically nor toxicologically inert. Inerts are not disclosed to the public due to their status as "trade secrets". Active ingredients usually comprise only 5% of the actual product; the other ingredients make up the majority of a given pesticide product or form ulation."'i • Inert ingredients can be more toxic to humans than the active ingredient. Ethylene chloride, a nerve poison, is an example of an inert ingredient linked with damage to the heart, eyes, liver, and adrenal glands. • 800 out of 1200 inerts are classified as "of unknown toxicity," 57 as highly toxic due to known carcinogenicity, adverse reproductive effects, birth defects, neurotoxicity and/or other chronic effects, and 64 as potentially toxic."""" • 394 chemicals used as inert ingredients are listed as active ingredients in other pesticide products, and more than 200 inerts are considered hazardous pollutants and/or hazardous waste under federal environmental statutes.'iii REFERENCES 'U.S. Environmental Protection Agency(EPA). 2004. Pesticides Industry Sales and Usage: 2000 and 2001 Market Estimates. EPA-733-R-04-001. ibid. National Research Council. 1980. Urban Pest Management. National Academy of Sciences; Abrams, R., Attorney General of New York. 1991."Toxic Fairways: Risking Groundwater Contamination from Pesticides on Long Island Golf Courses," Environmental Protection Bureau; Pimentel, D, et al. 1991. "Environmental and Economic Impacts of Reducing U.S.Agricultural Pesticide Use," Handbook of Pest Management in Agriculture, 2nd ed. CRC Press, Florida, p.679. 1°EPA. 2004. Pesticides Industry Sales and Usage:2000 and 2001 Market Estimates; U.S. Census Bureau. 2004. Services to Buildings and Dwellings: 2002 Economic Census. ECO2-561-07. v EPA. 2004. Pesticides Industry Sales and Usage: 2000 and 2001 Market Estimates. "'The National Gardening Association and Organic Gardening Magazine. 2004 July. Environmental Lawn and Garden Survey. Beyond Pesticides Factsheet. 2005 April. Health Effects of 30 Commonly Used Lawn Pesticides. http://www.beyondpesticides.org/lawn/factsheets/30health.pdf v1" EPA. 2003. Tackling a Suspected Hazard of Aging. http://www.epa.qov/ord/archives/2003/ser)tember/htm/articlel.htm (accessed 3/4/05); U.S. EPA. 2002 Oct 31. "EPA Announces New Aging Initiative to Protect Older Persons From Environmental Health Threats." EPA Pesticide Program Update. Office of Pesticide Programs; National Research Council. 1993. "Pesticides in the Diets of Infants and Children," National Academy Press. Washington, DC.; Repetto, R., et al. 1996 March. Pesticides and Immune System: The Public Health Risk, World Resources Institute, Washington, DC. 'X Rudel, Ruthann, et al. 2003. "Phthalates, Alkylphenols, Pesticides, Polybrominated Diphenyl Ethers, and Other Endocrine-Disrupting Compounds in Indoor Air and Dust,"Environmental Science and Technology 37(20): 4543-4553; Nishioka, M., et al. 2001. "Distribution of 2,4-D in Air and on Surfaces Inside Residences After Lawn Applications: Comparing Exposure Estimates from Various Media for Young Children,"Environmental Health Perspectives 109(11); Lewis, R., et al. 1991. "Determination of Routes of Exposure of Infants and Toddlers to Household Pesticides: A Pilot Study," EPA, Methods Research Branch. X EPA. 1996. Environmental Health Threats to Children. Office of the Administrator. 175-F-96-001. 3 x' National Research Council, National Academy of Sciences. 1993. Pesticides in the Diets of Infants and Children. Washington, DC: National Academy Press. x" Lowengart, R. et al., 1987. "Childhood Leukemia and Parent's Occupational and Home Exposures, " Journal of the National Cancer Institute 79:39. x"`Greenlee, A. et al. 2004. "Low-Dose Agrochemicals and Lawn-Care Pesticides Induce Developmental Toxicity in Murine Preimplantation Embryos," Environ Health Perspect 112(6): 703-709; Cavieres, M., et al. 2002. "Developmental toxicity of a commercial herbicide mixture in mice: Effects on embryo implantation and litter size." Environ Health Perspect 110:1081-1085. x'"Salam, M.T., et al. 2004. "Early Life Environmental Risk Factors for Asthma: Findings from the Children's Health Study," Environ Health Perspectives 112(6): 760. xv Shettler, T., et al. 2000. "Known and Suspected Developmental Neurotoxicants," In Harms Way. Toxic Threats to Child Development Cambridge, MA: Greater Boston Physicians for Social Responsibility; Guillette, E.A., et al. 1998. "An Anthropological Approach to the Evaluation of Preschool Children Exposed to Pesticides in Mexico," Environ Health Perspectives 106(6); Porter, Warren. "Do Pesticides Affect Learning and Behavior?The neuro-endocrine-immune connection," Pesticides And You 21(4): 11- 15. Beyond Pesticides, Washington, D.C. www.beyond pesticides.ora/pesticidesandyou (Overview of Dr. Porter's findings published in Environ Health Perspectives and Toxicology and Industrial Health.) xvi Centers for Disease Control and Prevention. 2003 Jan. Second National Report on Human Exposure to Environmental Chemicals; Pohl, HR., et al. 2000. "Breast-feeding exposure of infants to selected pesticides," Toxicol Ind Health 16: 65-77; Sturtz, N., et al. 2000. "Detection of 2,4-Dichlorophenoxyacetic acid residues in neonates breast-fed by 2,4-D exposed dams," Neurotoxicology 21(1-2): 147-54; Houlihan, J., et al. 2005. Body Burden, The Pollution in Newborns. Environmental Working Group, Washington, D.C. x"Glickman, L., et al. 2004. "Herbicide exposure and the risk of transitional cell carcinoma of the urinary bladder in Scottish Terriers,"Journal of the American Veterinary Medical Association 224(8):1290-1297; Hayes, H. et al., 1991. "Case-control study of canine malignant lymphoma: positive association with dog owner's use of 2,4-D acid herbicides," Journal of the National Cancer Institute, 83(17):1226. x"ll`Beyond Pesticides Factsheet. 2005. Environmental Effects of 30 Commonly Used Lawn Pesticides. hftp://www.beyondpesticides.o[g/lawn/factsheets/30enviro.pdf "'x Defenders of Wildlife. The Dangers of Pesticides to Wildlife[white paper]. 2005 April www.pesticidefreelawns.org/resources. xx Restmeyer, S.J. 2003. Ecological Pest Management: Embracing the Organic Approach to Landscape Management. Pesticides and You 23(l): 11-12. Beyond Pesticides, Washington, D.C. xx' Beyond Pesticides Factsheet. 2005. Environmental Effects of 30 Commonly Used Lawn Pesticides. http://www.beyondpesticides.org/lawn/factsheets/30enviro.pdf xx" U.S. Geological Survey. 1998. Pesticides in Surface and Ground Water of the United States: Summary of Results of the National Water Quality Assessment Program; Gilliom R.J. et al. 1999 April. "Testing water quality for pesticide pollution," Environ Science and Technology News. xxiii EPA. "Unregulated Drinking Water Contaminants," Office of Ground Water and Drinking Water, http://www.epa.gov/safewater/dw unregcontaminants.html (accessed 8/8/05). xx`"U.S. General Accounting Office. 1997. Nonagricultural Pesticides:Risks and Regulations. GAO/RCED-86-97; EPA. 2002. Questions and Answers: Pesticides and Mosquito Control. Department of Prevention, Pesticides and Toxic Substances. http://www epa gov/pesticides/factsheets/pesticides4mosguitos.htm(accessed 7/2/04). xxv Beyond Pesticides Factsheet. 2005. State Preemption Laws. http://www.beyondpesticides.o[g/lawn/factsheets/Preemption Factsheet.pdf xxvi Spitzer, E., Attorney General of NY. 2000. The Secret Ingredients in Pesticides:Reducing Risk. Abrams, R., 1991. Attorney General of NY. "The Secret Hazards of Pesticides:Inert Ingredients." xxvii EPA. Inert Ingredients in Pesticide Products. http://www.eiDa.gov/opprd001/inerts/lists.htmi (accessed 6/7/05). xxvrii Spitzer, E., 2000. 4 United States National Exposure Environmental Protection Research Laboratory Agency Research Triangle Park, NC 27711 Research and Development EPA/600/SR-97/108 October 1997 ®" EPA Project Summary Simulation of Track-in of Lawn- Applied Pesticides from Turf to Home : Comparison of Dislodgeable Turf Residues with Carpet Dust and Carpet Surface Residues Marcia G. Nishioka, Hazel M. Burkholder, Marielle C. Brinkman;Sydney M. Gordon Macroenvironmental transport of results obtained under work assign- lawn-applied pesticides into the home ment 28 (WA28). via walking over treated turf (track-in) This Project Summary was developed was measured five different times up by EPA's National Exposure Research to 1 week after application. Pesticides Laboratory's Atmospheric Processes and application methods evaluated in- Research Division, Research Triangle cluded spray application of the herb! Park, NC, to announce key findings of cide acids dicamba and 2,4-dichlo- the research project that is fully docu- rophenoxyacetic acid (2,4-D), granular mented in a separate report of the same application of the insecticide chlorpyrifos, title (see project report ordering infor- and spray application of chlorpyrifos and mation at back). the fungicide chlorothalonil.A new sam- pling tool,the Polyurethane Foam(PUF) Introduction Roller,was used to collect dislodgeable Agricultural use of pesticides has stimu- residues from both turf and carpeting. lated numerous studies of pesticide trans- Replicate measurements of turf port and translocation through plants, soil, dislodgeable residues showed devia- water, and air.Although pesticide applica- tions of 2% to 60% percent from the tions are designed for deposition onto a mean, which is considered very good target surface (plant, soil, insect), stud- given the nonuniformity of a turf sur- ies have described spray drift, soil face. Turf dislodgeable residues were resuspension, phase redistribution, long- approximately 0.2% of applied levels range transport, and deposition from air to for nonvolatile pesticides and approxi- water, soil, fog, and rain as micro and mately 0.006% for volatile chlorpyrifos macroenvironmental transport mecha- at 4 to 8 hours after application. The nisms. transfer of turf dislodgeable residues Some of the most frequently used agri- to carpet dust was 2.6±0.8%(n=5);the cultural pesticides include: 2,4-D (post- transfer efficiency of turf dislodgeables emergence herbicide), pendimethalin to the carpet surface was 0.27 ±0.08% (preemergence herbicide), diazinon and (n,5). For herbicide acids, both carpet chlorpyrifos (insecticide). A recent survey dust levels and carpet surface of lawn care companies and retailers of dislodgeable residue levels were highly residential lawn care products in the Co- correlated with turf dislodgeable resi- lumbus, OH, area showed that these agri- due levels. cultural pesticides are also the pesticides This report was submitted in partial ofchoice for lawn care by professionals fulfillment of Contract No. 68-DO-0007 and homeowners in the Columbus area. by Battelle under the sponsorship of The same transport phenomena that the U.S. Environmental Protection occur for agricultural pesticides may also Agency. This report summarizes the be expected for lawn-applied pesticides. However, inadvertent deposition will not into the home under the conditions used The data for 2,4-D resulting from simu- be limited to neighboring crops and turf here. lated track-in from turf to home demon- but will include the indoor residential en- strate that both the dislodgeable carpet vironment. One transport route from turf Results residues and the carpet dust residues into the home that has not been investi- For the herbicide acids and chlorothalonil, track the profile of the dislodgeable turf gated thoroughly, and may be important dislodgeable turf residues increased slightly residues. The entry-way mats reduced in the residential setting, is track-in on between 4 hours and 8 hours after ap- dislodgeable carpet surface residues by shoes and feet. plication, possibly due to increased drying approximately 25% at 4 hours, 8 hours, Numerous pesticides have been identi- of the applied material. For chlorpyrifos, and 1 day after application. With volatile fied in house dust and indoor air. In some dislodgeable turf residues were lower at 8 chlorpyrifos, the entry-mats appeared to cases, the presence of insecticides (e.g. hours relative to 4 hours, presumably be- serve as a pool or sink from which resi- chlorpyrifos) can be ascribed to the in- cause of lower volatilization rates at that dues were carried onto the carpeting. Be- door use of whole-room foggers and time of day, i.e. evening. cause of this effect, the weighted sum of sprays. The presence of other pesticides For the herbicide acids, the reduction the carpet surface residue and the carpet indoors (e.g. chlordane, heptachlor) ap- in dislodgeable turf residues between 8 dust residue was the quantity correlated pears to be due to infiltration and migra- hours and 1 day after application was with turf dislodgeable residue levels tion into the home of materials that were approximately 50%. While some of the (r2=0.86 for the granular chlorpyrifos ap- originally applied to foundations.The pres- decrease between 8 hours and 1 day plication). ence of pesticides such as permethrin measurements may be attributable to rain, Turf dislodgeable chlorothalonil levels and carbaryl, which are often applied at decreasing amounts of dislodgeable turf were not as closely correlated (r2=0.43) sites distant from the house (e.g. gar- residues have been measured over time with carpet dust levels. The PUF Roller den), suggests that track-in of turf and without rain or irrigation. A second phe- turf dislodgeable residues decreased over soil residues may explain in part their nomenon due to rain was observed that time, but human track-in appeared con- presence indoors. Once these pesticides runs counter to the wash-off effect ob- stant. are brought indoors, carpeting, carpet served with the initial rain. In particular, dust, and home furnishings may become after two additional episodes of rain, slight Conclusions and long-term sinks, as environmental weath- increases in dislodgeable residue were Recommendations ering factors such as wind, rain, soil mi- observed for all analytes in subsequent This study demonstrated that track-in crobes, and sunlight are not available. sampling. Studies of pesticide dissipation on shoes is a reasonable mechanism by While pesticide formulations contain from soil have indicated that water in- which lawn-applied pesticides are carried materials to increase adhesion to the tar- creases dissipation by displacement of into the home. Environmental weathering get surface, a fraction of the formulation the analyte from the soil surface, and this played an important role in reducing turf will be "dislodgeable". Dislodgeable pes- effect may be occurring here, as well as, dislodgeable residues. Rain effectively re- ticide residues are typically measured to on turf. moved turf herbicide acid residues; in ascertain safe reentry times for workers For both chlorpyrifos and chlorothalonil, this study, dislodgeable turf residues af- or homeowners into pesticide-treated ar- turf dislodgeable residues decreased over ter the rain were 1% to 5% of those eas. Dislodgeable residues have been the 14-day sampling period, although the found at 4 to 8 hours after application. measured on turf, ornamental plants, and reduction in turf residues was greater Chlorpyrifos turf residues were lost pri- fruit, and in some cases the dislodgeable for the more volatile chlorpyrifos. De- marily through vaporization. Despite these levels have been compared with subse- spite volatilization losses of chlorpyrifos, losses of turf residues, track-in of resi- quent dermal and urinary levels. In those trace residues were collected from the dues was measured at 5 to 6 days after studies,the collection of dislodgeable resi- turf for 14 days. Track-in of nonvolatile application.These studies suggested that dues involved vigorous scrubbing of the chlorothalonil remained constant over limited contact with treated turf until rain treated vegetation. That approach to the 5 day track-in test period. has occurred or several days have sample collection may not be repre- The reproducibility of the PUF Roller passed, together with the use of entry sentative of actual human contact with method for collection of dislodgeable resi- mats, may decrease the amount of lawn the vegetation. dues was quite high. Analyte amounts pesticides tracked into the home. collected from the same turf plot showed This study also demonstrated the utility Objective good reproducibility (1% to 25% devia- of a simple mechanical device for collec- The study described here was con- tion from the mean for duplicate samples) tion of turf dislodgeable residues. In sev- ducted to determine the temporal profile given the expected variability of collec- eral cases, turf dislodgeable residue lev- of dislodgeable turf residues of four com- tion via contact with a nonuniform.sur- els were highly correlated with the dust- monly used pesticides (dicamba, 2,4-D, face. Deviation from the mean for dupli- bound residues and carpet surface chlorpyrifos, and chlorothalonil), and de- cate samples from chlorpyrifos and chloro- dislodgeable residues generated under termine whether these materials can be thalonil plots was 3%to 70%. The some- these simulation conditions. tracked into a home with normal walking what greater variability in duplicate Based on the results obtained in this and entry into the home. This study was samples from the granular-applied chlor= study, it is recommended that additional designed to evaluate a new dislodgeable pyrifos plot may reflect differences in the studies be conducted to evaluate the rela- residue collection method and determine extent to which chlorpyrifos was washed tive importance of different transport the comparability of dislodgeable turf resi- into the soil during the initial plot irriga- mechanisms from turf to the indoor due levels with levels that are tracked tion (used only for granular application). environment. 2 Marcia G.Nishioka,Hazel M.Burkholder,Marielle C.Brinkman,Sydney M.Gordon are with Battelle, Columbus, OH 43201-2693. Robert G.Lewis is the EPA Project Officer(see below). The complete report, entitled"Simulation of Track-in of Lawn-Applied Pesticides from Turf to Home:Comparison of Dislodgeable Turf Residues with Carpet Dust and Carpet Surface Residues,"(Order No. PB98-103120;Cost.$25.00,subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone:703-487-4650 The EPA Project Officer can be contacted at: Atmospheric Processes Research Division National Exposure Research Laboratory U.S. Environmental Protection Agency Research Triangle Park, NC 27711 United States Environmental Protection Agency BULK RATE POSTAGE & FEES PAID Center for Environmental Research Information (G-72) Cincinnati, OH 45268 EPAPERMIT No. G-35 Official Business Penalty for Private Use$300 EPA/600/SR-97/108 Y i US Army Corps of Engineers LEVEE OWNER'S MANUAL FOR NON-FEDERAL FLOOD CONTROL WORKS THE REHABILITATION AND INSPECTION PROGRAM PUBLIC LAW 84-99 MARCH 2006 2.8 Vegetation (Levee Specific) The Corps' policy for landscaping around levees, floodwalls, and embankment dams, is found in EM 1110-2-301. The requirements are sometimes seen as being excessive and out of touch with contemporary environmental concerns,but as the primary function of a levee is to protect communities from flooding, the Corps' maintenance requirements have been established to reduce the chance of catastrophic failures during high water. If you'd like a variance to the Corps' vegetation requirements (allowing additional vegetation on or around the levee) then you need to contact your local Corps district. A variance would be granted if the proposed vegetation is seen to preserve, protect, or enhance natural resources, or if it protects the rights of Native Americans. Such variances will only be granted if the vegetation retains the safety, structural integrity, and functionality of the levee; retains the accessibility for inspection and flood fighting purposes; and doesn't reduce the level of protection required by the National Flood Insurance Program or the RIP if the levee is a part of these programs. Specific items relating to the maintenance of levee vegetation include the maintenance of the grass or sod cover and the removal of unwanted bushes and trees. a. Maintaining and Promoting a Good Grass or Sod Cover Grass or sod cover is one of the most effective and economical means of protecting flood control levees and drainage swales against erosion caused by rain runoff, channel flows, and wave wash. As the public sponsor, you are required to ensure the grass cover has every opportunity to grow. This will require that you periodically fertilize, water, and mow the grasses as needed. In addition, every effort must be made to prevent unauthorized encroachments, grazing, vehicle traffic, the misuse of chemicals, or burning during inappropriate seasons. Failure to properly maintain the grass cover can result in unnecessary erosion and possible embankment failure. moon,, i Figure 2.29 M7VLWALLYACCEPTABLE. Thus photo shows cattle grazing on the levee. Cattle typically don't harm the sod cover to the extent that sheep or other animals do. in this case, the landowner and the public sponsor were informed of the Corps'policy that grazing is not permitted on levees or within the levee easement area. b. Mowing Periodic mowing is essential to maintaining a good ground cover. Levees should be mowed regularly in order to control weeds and to prevent the growth of brush and saplings. Long grasses and native prairie grasses are one of the many challenges facing the project inspector. Long grasses (greater then 12 inches in length) can make a visual inspection nearly impossible and can hide serious concerns such as rodent activity, levee slides, and cracking; all of which can lead to the failure of the levee. For these 16 reasons, the grass should be mowed to a minimum height of 3 inches. The last mowing of the season should be accomplished under conditions that will allow the grass to grow to approximately 8 to 10 inches by the winter season. It's important to ensure that the entire levee profile has been mowed, including zones extending 15 feet beyond the toes of the embankment, which should be free of all woody growth and should a be clear of other obstructions so that a K= truck could drive beside the levee if needed. C. Control of Trees, Brush, and Weeds If the public sponsor mows the levee at regular intervals,the growth of saplings, trees, and brush will not become a problem. However, if the levee is not Figure 230 UNACCEPTABLE levee with knee-high mowed regularly, the resulting growth grass, making visual inspection nearly impossible. will make it difficult to properly (MN) maintain and inspect the project. Trees and brush can also affect the stability of the structure and interfere with emergency operations during high- water conditions. All trees and brush must be cleared and disposed of away from the flood control project. The disposal of material on the riverward side of the levee or areas where flood Figure 2.31 UNACCEPTABLE. Levee is mowed but waters can carry the material trees and longer grasses within levee easement area. downstream is prohibited. In riprap Trees are greater than 2"in diameter. (MN) protected areas, ditches, or in other areas of the project where power mowing is impractical, the unwanted vegetation should be controlled with an 1 p* approved herbicide spray or should be cut by hand. Herbicides must be used in f accordance with state and local laws and regulations. Any trees that reach 2 inches in diameter or greater, and are located on the levee, riprapped areas, drainage channels, or within 15 feet of the toe of the levee must be cut down, the root ball removed, the voids filled Figure 2.32 UNACCEPTABLE long grasses and with impervious material, and the fill trees on levee side slopes. (ND) material firmly compacted and reseeded. 17 i DEPARTMENT OF THE ARMY ETL 1110-2-571 U.S. Army Corps Engineers CECW-CE Washington, DC 20314-1000 Technical Letter No. 1110-2-571 10 April 2009 EXPIRES 10 April 2014 Engineering and Design GUIDELINES FOR LANDSCAPE PLANTING AND VEGETATION MANAGEMENT AT LEVEES, FLOODWALLS, EMBANKMENT DAMS, AND APPURTENANT STRUCTURES 1 1. Purpose. This ETL provides guidelines to assure that landscape planting and vegetation management provide aesthetic and environmental benefits without compromising the reliability of levees, floodwalls, embankment dams, and appurtenant structures. It is important to note that all minimum guidelines presented herein are just that—minimums. The dimensions of the vegetation-free and root-free zones defined in this document provide the minimum acceptable buffer between vegetation and flood damage reduction structures. For each individual project, the design team must consider whether or not these minimums are adequate to the specific needs and conditions of the project. 2. Applicability. This ETL applies to all USACE Commands having Civil Works responsibilities and to all flood damage reduction projects for which USACE has responsibility for design, operation,maintenance, inspection, or certification. Applicability to non-federal projects is as follows: under the Rehabilitation and Inspection Program(RIP), the USACE performs inspections of non-federal projects (i.e,projects built by local communities then incorporated into the RIP)under ER 500-1-1 and the provisions of Public Law 84-99. i 3. Distribution. Approved for public release, distribution is unlimited. 4. General. Levees, floodwalls, embankment dams, and their appurtenant structures serve a common purpose in that they are designed to contain water and prevent flooding for varying lengths of time. They must also be readily accessible by equipment and personnel essential to reliable operation and maintenance. The possibility for long-term saturation of levee materials or levee and floodwall foundations, together with their specific operation and maintenance requirements, makes it necessary to exercise caution in the design of landscape planting and This ETL supersedes: i EM 1110-2-301, Guidelines for Landscape Planting and Vegetation Management at Floodwalls, Levees, and EmbanlcmentDams, 1 January 2000. Memorandum, Headquarters,United States Army Corps of Engineers (HQUSACE) (CECW- HS), MG Don T. Riley, Subject: Interim Vegetation Guidance for Control of Vegetation on Levees, 12 June 2007. ETL 1110-2-571 10 Apr 09 vegetation management at these structures. This ETL describes important characteristics of levees,floodwalls, embankment dams, and their appurtenant structures. I 5. Future Guidance. Planned research is intended to complement this guidance: future editions will include field studies of vegetation impacts to flood damage reduction structures and helpful information on the root system characteristics of various plant species. FOR THE COMMANDER: I AMES C. DALTON,P.E. Chief,Engineering and Construction Directorate of Civil Works i i i 2 DEPARTMENT OF THE ARMY ETL 1110-2-571 U.S. Army Corps Engineers CECW-CE Washington, DC 20314-1000 Technical Letter No. 1110-2-571 10 April 2009 i EXPIRES 10 April 2014 Engineering and Design GUIDELINES FOR LANDSCAPE PLANTING AND VEGETATION MANAGEMENT AT FLOODWALLS,LEVEES, EMBANKMENT DAMS, AND APPURTENANT STRUCTURES TABLE OF CONTENTS Subject Paragraph Page Chapter 1 Introduction Purpose.................................................................................................................... 1-1 1-1 References............................................................................................................... 1-2 1-1 Policy...................................................................................................................... 1-3 1-3 Environmental Quality and Aesthetics................................................................... 1-4 1-3 Chapter 2 Landscape Planting: Objectives and Engineering Requirements Background.............................................................................................................2-1 2-1 Vegetation-Free Zone ............................................................................................2-2 2-1 Vegetation-Management Zone................................................................................2-3 2-2 RootImpacts...........................................................................................................2-4 2-2 Root-Free Zone.......................................................................................................2-5 2-3 Water-Current and Wave-Action Barrier................................................................2-6 2-3 Chapter 3 Treatment of Levees, Floodwalls, Embankment Dams, and Appurtenant Structures General....................................................................................................................3-1 3-1 Levees..................................................................................................................... 3-2 3-1 Floodwalls...............................................................................................................3-3 3-2 Embankment Dams and Appurtenant Structures....................................................3-4 3-3 I i, Chapter 4 Design Considerations FeasibilityAnalysis.................................................................................................4-1 4-1 PlantingBerms........................................................................................................4-2 4-1 Planters....................................................................................................................4-3 4-2 IrrigationSystems...................................................................................................4-4 4-2 i i ETL 1110-2-571 10 Apr 09 Subject Paragraph Page Flood-Fighting and Structure Maintenance............................................................4-5 4-2 Maintenance of Plantings........................................................................................4-6 4-3 Selection of Plant Material......................................................................................4-7 4-3 Appropriate Ground Cover in the Vegetation-Free Zone.......................................4-8 4-3 Borrow Sites and Spoil Sites...................................................................................4-9 4-3 Chapter 5 Vegetation-Related Maintenance and Repair Maintenance of Ground Cover ............................................................................... 5-1 5-1 Operations and Maintenance Manual .................................................................... 5-2 5-1 Removal of Non-Compliant Vegetation ................................................................5-3 5-1 Repair of Animal Burrows......................................................................................5-4 5-2 Chapter 6 Illustrations General....................................................................................................................6-1 6-1 Figures1 through 25...............................................................................................6-2 6-1 Glossary ....................................................................................................................... Glossary-1 I i i i ii ETL 1110-2-571 10 Apr 09 CHAPTER 1 INTRODUCTION j 1-1. Purpose. This ETL provides guidelines to assure that landscape planting and vegetation management provide aesthetic and environmental benefits without compromising the reliability of levees, floodwalls, embankment dams, and appurtenant structures. It is intended as a guide for safe design and not as a restriction to the initiative of designers. These guidelines should be used with reasonable judgment and practicality, tailored to the specific requirements and conditions of each individual project. The integrated design of landscape plantings and vegetation management at flood damage reduction systems requires a coordinated, interdisciplinary effort involving the local sponsor and the following disciplines: civil engineer, landscape architect, levee and/or dam safety engineer, environmental engineer, geologist, biologist, and additional related disciplines, as appropriate. 1-2. References. a. USA CE publications 1 EC 1110-2-6061 Engineering and Design, Safety of Dams—Policy and Procedures, 30 April 2004 (Transmits Draft ER 1110-2-1156,Engineering and Design, Safety of Dams—Policy and Procedures, 30 April 2004). EM 1110-2-38 Environmental Quality in Design of Civil Works Projects, 3 May 1971. EM 1110-2-1205 i Environmental Engineering and Local Flood Control Channels, 15 Nov 1989 (Sections 4-8.d(4) and 5-1). EM 1110-2-1601 Hydraulic Design of Flood Control Channels, 1 July 1991, with Change 1, 30 June 1994 (Sections 3-3 and 3-5). EM 1110-2-1913 Design and Construction of Levees, 30 Apr 2000 (Sections 4-4 and 8-17). EM 1110-2-2300 General Design and Construction Considerations for Earth and Rock Fill Dams, 30 July 2004. EM 1110-2-2502 Retaining Walls andFloodwalls, 29 Sept 1989 (Section 7-16). EP 500-1-1 Emergency Employment of Army and Other Resources. Civil Emergency Management Program —Procedures, 30 Sep 2001 (Section 5.81 and Appendix E). 1-1 ETL 1110-2-571 10 Apr 09 ER 200-1-5 Policy for Integrated Application of U.S.Army Corps of Engineers (USACE) Environmental Operating Principles (EOP) and Doctrine, 30 Oct 2003. I ER 500-1-1 Emergency Employment of Army Resources, Civil Emergency Management Program, Chapter 5, Rehabilitation and Inspection Program, 30 Sept 2001 i ER 1110-1-12 Quality Management, Change 1, 30 Sept 2006. ER 1110-2-1150 Engineering and Design for Civil Works Projects, 31 August 1999. ER 1130-2-530 Project Operations -Flood Control Operations and Maintenance Policies, 30 October 1996. ETL 1110-2-570 Certification of Levee Systems for the National Flood Insurance Program (NFIP), draft. U.S. Army Corps of Engineers Levee Owner's Manual for Non-Federal Flood Control Works, March 2006. U.S. Army Corps of Engineers Policy and Procedural Guidance for the Approval of Modification and Alteration of Corps of Engineers Projects, CECW-PB Memorandum, 23 Oct 2006. b. FEMA publications FEMA 473 FEMA(2005a) Technical Manual for Dam Owners, Impacts of Animals on Earthen Dams, FEMA 473, Sept 2005. hqp://www.fema.gov/plan/prevent/damfailure/publications.shtm FEMA 534 FEMA (2005b) Technical Manual for Dam Owners, Impacts of Plants on Earthen Dams, FEMA 534, Sept 2005, http://www.fema.goy/plan/prevent/damfailure/l)ublications.shtm 44 CFR Chapter 65.10, 1 Oct 2006 Mapping of Areas Protected by Levee Systems c. Other publications Association of State Dam Safety Officials (2002) Association of State Dam Safety Officials (ASDSO) (2002)A Technical Manual on the Effects of Tree and Woody Vegetation Root Penetrations on the Safety of Earthen Dams, December 2002. 1-2 I ETL 1110-2-571 10 Apr 09 1-3. Policy. a. Where the safety of the structure is not compromised, and effective surveillance, monitoring, inspection, maintenance, and flood-fighting of the facility are not adversely impacted, appropriate landscape planting (trees, shrubs, vines, forbs, and grasses) may be incorporated into the design of all flood damage reduction projects, subject to the limitations set forth in this document. Because landscape plantings enhance the environment, with respect to both natural systems and human use, they are to be considered in all flood damage reduction project planning and design studies and will be fully presented in design documentation reports. For projects in which the maintenance of the completed facility will be the responsibility of the local sponsor, the landscape planting will be fully coordinated with the local sponsor during planning and design to determine the sponsor's desires and to obtain assurances that the sponsor is capable of, and committed to, the proper maintenance of the vegetation. b. In certain instances, to further enhance environmental values or to meet state or federal laws and/or regulations, the local sponsor may request a variance from the standard vegetation guidelines set forth in this ETL. Vegetation variances for either federal or non-federal flood damage reduction systems may be permitted. The vegetation variance must meet the following two criteria: (1) The variance must be shown to be necessary, and the only feasible means, to (a) preserve,protect, and enhance natural resources and/or(b)protect the rights of Native Americans, pursuant to treaty and statute. (2) With regard to flood damage reduction systems, the variance must assure that (a) safety, structural integrity, and functionality are retained, and(b) accessibility for maintenance, inspection,monitoring, and flood-fighting are retained. Note that, as used here, the term "retained"assumes a pre-variance condition that is fully consistent with the requirements set forth in this ETL, and any other applicable criteria. Periodic clearing of some types of vegetation,both woody (trees, shrubs, and vines) and non- woody (grasses and forbs), will be performed, as needed, to maintain the conditions described in the second criterion. The variance will not be a substitute for poor maintenance practices. See the following references regarding variances to levee vegetation standards: ER 500-1-1, for policy; EP 500-1-1, for the request and approval process; and, any other applicable guidance issued subsequent to this document. c. Any addition of landscape plantings to existing flood damage reduction systems must comply with the project's O&M manual. New plantings may not be approved without an i appropriately detailed and documented engineering evaluation to ensure that design intent and safety criteria are maintained as originally authorized. i 1-4. Environmental Quality and Aesthetics. Environmental quality and aesthetics are of special concern. The design and maintenance of flood damage reduction systems must fully consider the environmental implications of the proposed actions and ensure that they are 1-3 ETL 1110-2-571 10 Apr 09 consistent with the doctrine outlined in the Corps' Environmental Operating Principles. Project design should respond appropriately to the visual character of the project context with respect to the characteristics of both the natural and built landscapes. Landscape planting design should consider both human use and the environmental processes and characteristics of the entire area influenced by the project. While it is seldom feasible to preserve the natural setting intact, j design techniques and careful construction methods can protect and perhaps enhance local environmental and aesthetic values. I i i i I i I� 1-4 ETL 1110-2-571 j 10 Apr 09 CHAPTER 2 LANDSCAPE PLANTING: OBJECTIVES AND ENGINEERING REQUIREMENTS 2-1. Background. In flood damage reduction projects, the goal of landscape planting is to minimize and/or mitigate negative impacts to aesthetic, environmental, and ecological conditions, such that post-project conditions are equal to, or better than,pre-project conditions. Landscape planting objectives include the following: provide cover to prevent dust and erosion; provide ecological benefits, such as improved water quality and wildlife habitat; integrate the flood damage reduction system with the surrounding natural and human environment; separate activities; define zones of use; provide privacy; screen undesirable features or views; accentuate positive features or views; and create a pleasant environment for human use and recreation. These and any other project-specific landscape planting objectives must be consistent with both the policy set forth in Paragraph 1-3 and the engineering requirements detailed in this chapter. 2-2. Vegetation-Free Zone. i a. The vegetation-free zone is a three-dimensional corridor surrounding all levees, floodwalls, embankment dams, and critical appurtenant structures in all flood damage reduction systems. The vegetation-free zone applies to all vegetation except grass. Grass species are permitted, as described in Paragraph 4-8, for the purpose of erosion control. b. The primary purpose of the vegetation-free zone is to provide a reliable corridor of access to, and along, levees, floodwalls, embankment dams, and appurtenant structures. This corridor must be free of obstructions to assure adequate access by personnel and equipment for surveillance, inspection, maintenance, monitoring, and flood-fighting. In the case of flood- fighting, this access corridor must also provide the unobstructed space needed for the construction of temporary flood-control structures. Access is typically by four-wheel-drive vehicle, but for some purposes, such as maintenance and flood-fighting, access is required for larger equipment, such as tractors, bulldozers, dump trucks, and helicopters. Accessibility is essential to the reliability of flood damage reduction systems. c. The vegetation-free zone must be wide enough, and tall enough, to accommodate all likely access requirements. The minimum allowable vegetation-free zone dimensions are based on lessons learned from flood-fighting experience and are illustrated in Chapter 6, for a variety of flood damage reduction system configurations. The general rule is as follows: (1) The minimum height of the corridor shall be 8 feet, measured vertically from any point on the ground. (2) The minimum width of the corridor shall be the width of the levee, floodwall, or embankment dam, including all critical appurtenant structures,plus 15 feet on each side, measured from the outer edge of the outermost critical structure. In the case of a planting berm (Figures 13, 14, and 15), the 15 feet is measured from the point at which the top surface of the planting berm meets the levee section. i i i 2-1 ETL 1110-2-571 10 Apr 09 (3) No vegetation, other than approved grasses, may penetrate the vegetation-free zone, with two exceptions, as illustrated in Figure 2: (a) Tree trunks are measured to their centerline, so one half of the tree trunk may be within the vegetation-free zone. (b) Newly planted trees, whose crowns can be expected to grow, or be pruned, clear of the vegetation-free zone within 10 years. d. The minimum vegetation-free zone dimensions may not be diminished without a formal variance(see Paragraph 1-3b). Due to specific site conditions and project requirements, many levees, floodwalls, embankment dams, and appurtenant structures will be determined, by the project design team, to require a vegetation-free zone larger than the minimum described here. e. Paragraph 2-2 has established the minimum acceptable width of the vegetation-free zone at 15 feet. Other than by variance, as described above, the single exception to this 15-foot minimum requirement arises in the case of an existing project where the width of the existing real estate interest for the project is less than 15 feet. In such a case, the vegetation-free zone width shall be the maximum attainable within the existing real estate interest. 2-3. Vegetation-Management Zone. A recommended alternative to enlarging the vegetation- free zone is the addition of an adjacent vegetation-management zone (see Figure 22). A vegetation-management zone provides greater opportunity to include vegetation by reserving the option to manage it selectively, as needed. Two of many possible scenarios are presented below. a. Several trees,just outside the vegetation-free zone, are inhibiting grass growth, through light deprivation and/or the production of their own natural herbicides that limit competition for moisture and nutrients. These trees should be either removed or modified, as appropriate, to assure that grasses thrive and continue to provide effective erosion control. b. A large tree, outside the vegetation-free zone,becomes a hazard tree when its root system is severely damaged by construction activity, thereby increasing its susceptibility to windthrow and the associated risk of damage to a floodwall. This tree should be removed. 2-4. Root Impacts. As stated in Paragraph 2-2,the primary purpose of the vegetation-free zone is access. However, it also serves a secondary purpose: it provides distance between root systems and levees, floodwalls, embankment dams, and appurtenant structures, thereby moderating reliability risks associated with the following two situations: potential piping and seepage due to root penetration; and structural damage (a hole in the ground, surrounded by an area of disturbed earth) resulting from a wind-driven tree overturning. Though not adequate for all situations, this 15-foot zone does provide a measure of risk reduction, as follows: a. Root size and numbers diminish with distance from the tree trunk. b. The hole and its surrounding area of disturbed earth, created by a tree overturning, typically has a radius ranging from 6 to 12 feet. This secondary effect of the vegetation-free i 2-2 ETL 1110-2-571 10 Apr 09 zone is important to the reliability of flood damage reduction systems; it is not a root-free zone but it is a zone of reduced root impact. i 2-5. Root-Free Zone. Planting design must consider the possible implications to foundation strength and performance. The integrity of the foundation could be compromised if potential seepage paths were created by root penetration and/or root decay. The root-free zone provides a margin of safety between the greatest expected extent of plant roots and the beginning face of any structure that is critical to the performance and reliability of the flood damage reduction system. The list of such structures includes levees, floodwalls, embankment dams, seepage berms, seepage drains, toe drains, pressure relief wells, and cut-off trenches. These critical structures must be root-free, as illustrated in Figures 13, 14, 15, 17, and 19. The rooting habit of each plant selected for use near a root-free zone must be predictably understood with respect to its potential to invade the root-free zone and compromise the reliability of the flood damage reduction system. Landscape planting plans will reflect full recognition of the importance of selecting appropriate plant species and varieties. Root barriers may be used to provide an added measure of assurance, but they should not be a substitute for adequate distance between plantings and root-free zones. Root barriers shall not retard groundwater or seepage flow. Some root barriers include herbicides to enhance effectiveness; in every case,these shall be evaluated prior to use to assure against negative environmental impacts. 2-6. Water-Current and Wave-Action Barrier. The use of suitable vegetation, such as shrub forms of Salix (willow), riverward of the vegetation-free zone is encouraged as an environmentally beneficial means to moderate the erosive potential of water currents and wave action. i I i I, 2-3 i I '� ,' i ETL 1110-2-571 10 Apr 09 CHAPTER TREATMENT OF LEVEES,FLOODWALLS, EMBANKMENT DAMS, AND APPURTENANT STRUCTURES I 3-1. General. i a. The integrity of levees, floodwalls, embankment dams, and appurtenant structures is paramount to the public health, safety, and welfare. The presence of undesirable vegetation can undermine that integrity and lead to failure if not corrected. b. Trees and other woody vegetation, such as shrubs and vines, can create both structural and seepage instabilities,prevent adequate inspection, and create obstacles to maintenance and flood-fighting/flood-control activities. Vegetation must be controlled for the following reasons: (1) To allow proper inspection, surveillance, and monitoring of all structures and adjacent areas for seepage, cracking, sinkholes, settlement, displacement, and other signs of distress. (2) To allow access for normal and emergency Operations and Maintenance activities. (3) To prevent root-related damage to structures, such as shortened seepage paths through embankments and/or foundations; voids in embankments and/or foundations due to decayed roots or fallen trees; clogged seepage collector systems; and expansion of cracks or joints in concrete walls, spillway floors, and canal linings. (4) To limit those habitat characteristics that encourage the creation of animal burrows. (5) To allow full design-discharge capability of waterways, spillway inlet and outlet channels, outlet-works discharge channels, and other open conveyance channels. (6) To avoid any incidental growth and subsequent presence of endangered species that might prohibit activities necessary for operations, maintenance, or access. c. This document establishes minimum dimensions for both vegetation-free zones and root-free zones; however, for any specific project, those minimum dimensions may be increased by levee and/or dam-safety engineering personnel due to site-specific considerations such as topography,phreatic surfaces within the structure and abutments, geological features, historical embankment and/or foundation seepage or issues, stability issues, and foundation characteristics. i 3-2. Levees. i a. Levees are usually constructed of compacted earth fill. In some cases, internal drainage or under-seepage treatment is incorporated into the levee. When a planting berm is used to allow vegetation nearer to the levee centerline, the internal blanket drain and/or toe drain must be extended, as shown in Figures 14 and 15. Any such extension must be assessed by the design team for impact to the seepage control system. i 3-1 ETL 1110-2-571 j 10 Apr 09 b. All levees must have effective and reliable erosion protection; the appropriate use of grasses is described in Paragraph 4-8. Where opportunities exist, environmental improvements l should be considered. Project design shall address the following criteria: (1) Urban levees. Because levee projects have the potential to dominate these high- visibility landscapes,planting is often desirable,particularly in high-visibility locations, such as at and along major thoroughfares,parks, and waterfront developments. 1 (2) Rural or agricultural levees. Although these are typically not high-visibility areas, both human use and environmental needs should be considered during design. Plantings are particularly appropriate for the following areas,provided they are consistent with site-specific engineering requirements: high-visibility pumping installations, public road crossings, near residences, and at other project locations where landscape plantings could protect or restore valued environmental characteristics. c. Minimum vegetation-free and minimum root-free zones are established for levees, as illustrated in Chapter 6. 3-3. Floodwalls. a. Floodwalls are most often used in urban areas, where land or access is constrained. These walls are subject to hydraulic forces on one side, which may be resisted by little or no earth-loading forces on the other side. Landscape planting should be addressed in floodwall design,particularly where walls encroach on, or change, existing scenic values, e.g., where the wall becomes a visual barrier along a street or near dwellings,parks, and existing or anticipated commercial developments. b. The minimum vegetation-free zone provides for access, but there are two additional areas of concern with respect to floodwalls. (1) Large trees can be a threat to project reliability. Planting design and maintenance must take into account the potential for overturning trees to damage floodwalls. The following factors can be used, alone or in combination, to limit potential for such damage: (a) Distance between a tree and the wall. (b) Tree species selection, favoring trees with a low potential for breaking and overturning. (c) Tree monitoring and maintenance to address hazard trees. (d) Intervening obstacles, such as other trees, that would reliably restrain a falling tree. Where other factors are unreliable, the distance between a tree and the wall must be adequate: e.g. a minimum distance of one-half of the mature tree height. i (2) Planting design and maintenance must also take into account the three potential means by which tree roots may damage floodwalls: I 3-2 ETL 1110-2-571 10 Apr 09 (a) Large tree roots can damage concrete structures bYjacking (lifting) them which can � cause cracking and separation at joints. Further, if a floodwall is lifted, a seepage path could form along the structure/foundation contact. Smaller(lighter) floodwalls are more susceptible than larger(heavier) structures. (b) Roots may also grow into and through wall joints, loosening and eroding wall-joint seals, thus damaging the water-proof characteristics. I (c) A floodwall may have a toe drainage system to check and control piping and boils; to control seepage that may result from roofing, where piles are used; and to control uplift pressures. These drainage systems must be protected from invasion by roots, which could clog them. c. Although there are several types of floodwalls, the two most common are the inverted-T type reinforced concrete wall and the cantilever-I type sheet piling wall. The vegetation impact concerns are similar for both types. For all the reasons cited above, minimum vegetation-free and minimum root-free zones are established for floodwalls, as illustrated in Figures 16-19. 3-4. Embankment Dams and Appurtenant Structures. a. Purpose. "Tree and woody-vegetation penetrations of earthen dams and their appurtenances have been demonstrated to cause serious structural deterioration and distress that can result in failure of earthen dams" (Association of State Dam Safety Officials 2002). Proper establishment and control of vegetation is critical to dam safety. This Paragraph establishes minimum requirements for landscape planting and vegetation management at embankment dams (earth fill,rock fill, or earth and rock fill), including multipurpose projects with both concrete and embankment dam structures (wing dams) and perimeter saddle dams (dikes); abutments; and appurtenances, such as spillways, outlet works, and inlet and/or outlet channels. b. Policy. The following five areas are vegetation-free zones: (1) The dam or the dam-toe area. (2) In or around seepage monitoring systems or critical downstream areas where seepage observation must be vigilant and continuous. i (3) Groin abutments and areas immediately adjacent. (4) Spillways and spillway channels, including spillway slopes and approaches to spillways where vegetation could, in any way, impede the efficient operation of the spillway. (5) The outlet-works discharge channel. c. Vegetation-Free Zones. Vegetation-free zones shall, when dry,be mowed to a height of 3-6 inches at any time the grass reaches a height of 12 inches. Mowing shall be triggered by grass heights of less than 12 inches if important to the health maintenance of the particular grass 3-3 ETL 1110-2-571 10 Apr 09 species. The maximum height of grasses shall be 12 inches. The minimum vegetation-free zone i requirements for specific structures are described below. (1) Embankment Dams. At a minimum, for"dry"reservoirs, the entire dam embanlanent surface, including upstream impervious blankets and the upstream and downstream areas within 50 feet of the embankment toe, shall be a vegetation-free zone(see Figure 20). For"normal pool' conditions, the entire embankment surface from the upstream toe of the dam or from the upstream limit of the impervious blanket, as applicable, to a minimum distance of 50 feet from the downstream toe shall be a vegetation-free zone (see Figure 21). i (2) Dam Abutments. The dam abutment is defined as the part of a natural valley side-wall against which a dam is constructed. At a minimum, the vegetation-free zone shall extend for a horizontal distance of 15 feet beyond the embankment/abutment contact line (i.e. groin). (3) Spillways. The safety of embankment dams requires the unobstructed operation of spillways. The minimum vegetation-free zone shall include the spillways and spillway channels, including spillway slopes and approaches. (4) Outlet-Works Discharge Channels. The minimum vegetation-free zone shall include the entire outlet channel, outlet structure headwalls and wingwalls, and surrounding areas to a distance of 50 feet from the top of the bank of the outlet channel. i i 3-4 ETL 1110-2-571 10 Apr 09 CHAPTER 4 DESIGN CONSIDERATIONS i 4-1. Feasibility Analysis. During design, an analysis shall be made of the flood damage reduction system to determine if and where landscape planting can be permitted. Not all projects will have a satisfactory combination of conditions to permit planting of trees, shrubs, vines, forbs, and grasses. In some cases, only shrub planting may be feasible, while in other cases planting may be limited to grasses. Site conditions, engineering design criteria, and operation and maintenance requirements should determine the appropriate planting scheme. However, environmental objectives shall be considered in all projects, and the engineering design should seek to accommodate appropriate plantings. Some important site considerations are described below. a. Types of Construction Material. The type of construction material is an important factor in determining suitability for landscape planting. Rock, sand, and many types of compacted clay embankments are examples of poor plant-growing media. The roots of some plant species, under some conditions, may penetrate a great distance into a sand levee, potentially providing a path for piping through the structure. Plants must be selected very carefully with regard to the type of construction materials used to ensure survival of the plant and prevent damage to the structure. b. Project Alignment. Project alignment can be a complex exercise involving multiple, often conflicting criteria and requiring a coordinated effort by the project delivery team. The role of the landscape architect is to identify opportunities and constraints to human use relative to project alignment. For example, in an urban area, a relatively minor adjustment to a proposed alignment might allow for plant screening between residences and the structure or provide space for a park or other community green space. Often, those segments of the alignment that are otherwise arbitrary may be turned to advantage with respect to human use. c. Environmental Factors. The types of vegetation suited to a site are a function of a number of environmental factors. Local climate (precipitation,temperature, dates of earliest and last frost, etc.) can limit the types of vegetation that survive in a particular region. Soil type,pH, nutrient character, exposure to sunlight, flood and drought duration, and depth to groundwater are additional conditions that can influence the potential for a site to support vegetation. Because one important functional characteristic of vegetative groundcovers is the ability to provide erosion control, it is necessary to confirm that the proposed cover can withstand the energy environment under flood conditions. This may require an assessment of local velocities and shear stresses and comparison of predicted values under flood conditions against thresholds for various types of vegetation. 4-2. Planting Berms. i a. Beyond the minimum section needed to satisfy stability requirements, it is sometimes desirable to add additional earth fill to a levee or embankment dam to create a planting berm, in order to better accommodate differing types of public use and related landscape planting approaches (see Figures 13, 14, and 15). The appropriate dimensions of the planting berm i 4-1 ETL 1110-2-571 10 Apr 09 should be determined by the landscape architect in consultation with the design team. Additional j rights-of-way may be necessary to accommodate the additional fill material and flatter slopes. Except in approved planters, vegetation is not permitted on any overbuild that has a system- reliability function. Planting berms may be considered for use on the land side only. i b. Planting layout and plant material characteristics shall be coordinated with the design team to assure adequate access between the levee crown and the toe for two purposes: visual access is required for inspection of the toe area; and physical access is required for flood-fighting activities involving personnel and heavy equipment. In all cases, the planting berm must be of sufficient depth to accommodate any proposed vegetation while precluding root penetration into any root-free zone. Design must include adequate consideration of any internal drainage or seepage control system(see Figures 14 and 15). c. Additional design requirements for planting berms include the following. For new projects, engineering and design shall be in accordance with ER 1110-2-1150,Engineering and Design for Civil Works Projects, and all related guidance. For existing projects, engineering and design shall be in accordance with CECW-PB memorandum dated 23 Oct 2006,Policy and Procedural Guidance for the Approval of Modification and Alteration of Corps of Engineers Projects. 4-3. Planters. a. In overbuild areas,permanent plant containers, such as concrete planters, may be considered. Planters must not impact the designed dam or levee section, or appurtenant structures, such as berms, drains, ditches and wells. Planter design and layout must allow for adequate access up and down the embankment as required for inspection and flood-fighting activities and must be approved by the Dam or Levee Safety Officer. b. Planters and containerized plants should be used selectively and should be considered only when normal planting is not practical. The initial cost and the ability of the sponsor to maintain this type of planting should be considered during design. Plants selected for use in planters should have mature heights of not more than approximately 20 feet. 4-4. Irrigation Systems. Irrigation systems within the vegetation-free zone pose two potential threats to system reliability: pressurized waterlines may fail, resulting in damage to the engineered embankment section; and irrigation water may impair visual inspection by obscuring wet areas that are actually due to seepage. Any irrigation system that targets the vegetation-free zone shall be engineered so as to address these issues and meet the approval of the District dam or levee safety officer. Designs may include features such as double-walled piping and leakage detection systems. 4-5. Flood-Fighting and Structure Maintenance. Flood-fighting and maintenance operations for levees, floodwalls, embankment dams, and appurtenant structures can be complex. These operations must not be impacted by the layout and physical characteristics of landscape plantings. Landscape plantings will be designed to permit inspection of structures from moving j vehicles. Access requirements for emergency repair and replacement associated with flood- fighting efforts shall also be considered. i 4-2 ETL 1110-2-571 10 Apr 09 4-6. Maintenance of Plantings. Planting designs must be consistent with the capacity of the project sponsor to maintain them. Maintenance shall include the control and/or removal of invasive species. Low-maintenance plant materials are often the most appropriate choice. i 4-7. Selection of Plant Material. Plants will be selected from approved plant lists prepared jointly by Division and District landscape architects in conjunction with the local sponsor or j resource agencies. The list will include trees, shrubs, vines, forbs, sedges, and grasses that are native to the region and well adapted to the climactic, soil, and hydrologic conditions of the site. Plant lists should be appropriate to the specific structural conditions and requirements of each project. As the project site experiences fluctuations in various environmental conditions over time, such as water level, precipitation, and herbivory, some plants or species will not survive but others may thrive. A diverse array of plant species is essential to a riparian system's resiliency and its ability to provide and sustain a number of functions. A botanist familiar with local flora should be enlisted to select those species from the approved list most likely to meet project objectives. 4-8. Appropriate Ground Cover in the Vegetation-Free Zone. a. The only acceptable vegetative ground cover in the vegetation-free zone shall be perennial grasses. Their primary function shall be to reliably protect against erosion. They shall be maintained as necessary to ensure the health and vigor of the primary species providing erosion protection. The species selected for each project shall be appropriate to the local climate, conditions, and surrounding or adjacent land uses. Preference should be given to the use of native species. Invasive or weed species shall not be acceptable. The species selected must be able to tolerate mowing to heights as low as 3 inches, as follows: at least once each year for inspection; and in anticipation of flood conditions and associated monitoring and flood-fighting activities. b. If the local climate, hydraulic and hydrologic environment, soils, or other conditions will not support such grass species, then non-vegetative means of erosion control shall be employed, e.g. riprap,pavement, articulating concrete mats, or other engineered surface. e. A maximum grass height is specified for embarkment dams and their appurtenant structures (see Paragraph 3-4c, Vegetation-Free Zones). 4-9. Borrow Sites and Spoil Sites. Borrow sites and spoil sites shall be restored through proper regrading and revegetation. i i 4-3 1 i i i i ETL 1110-2-571 10 Apr 09 i CHAPTER 5 VEGETATION-RELATED MAINTENANCE AND REPAIR I 5-1. Maintenance of Ground Cover. As ground cover in a flood damage reduction system, the primary purpose of grasses is the effective prevention of erosion; therefore, maintenance must assure a healthy, vigorous stand that is substantially free of weeds and bare spots. It will { generally be necessary to periodically mow, graze, or burn grasses to permit proper inspection, manage pests, inhibit weed growth, or otherwise maintain the health and vigor of the plant stand. The appropriate time of year in which to conduct these maintenance activities will be a function of the species utilized as well as the motivating factor for the maintenance activity. For example, mowing to prohibit weed establishment may best be undertaken before the weed seeds become viable each year. The annual inspection may be scheduled to coincide with this period. 5-2. Operations and Maintenance Manual. For each project, it is important that the operations and maintenance manual include an annual maintenance program to control animal burrows and vegetative growth. It is also important that vegetation be managed in such a manner as to avoid the need for mechanized removal and associated embankment repair, and avoid any incidental growth and subsequent presence of endangered species that might prohibit access and activities necessary for operations or maintenance. 5-3. Removal of Non-Compliant Vegetation. i a. All vegetation not in compliance with this ETL shall be removed. A detailed removal plan shall be submitted to the local USACE District Levee Safety Officer for review and comment prior to removal of vegetation. The removal plan shall expand on the following basic requirements. (1) By excavation, remove the trunk(or stem), stump, rootball and all roots greater than 1/2 inch in diameter—all such roots in, or within 15 feet of, the flood damage reduction structure shall be completely removed. (2) Assure that the resulting void is free of organic debris. (3) Fill and compact the void according to the original soil and compaction specifications: or, if no specifications exist, match adjacent soil and compaction. b. Removal of non-compliant vegetation can create significant issues for the owner/operator, as maintenance may require environmental permits. The local sponsor must coordinate with the Corps and other appropriate agencies and obtain all the required environmental permits (including Corps of Engineers 404 permits)before conducting work within the levees. Mechanized land clearing below the plane of the "Ordinary High Water Mark" (defined at 33 CFR Part 328.3(e); in this document, see Figure 23 in Chapter 6 and the glossary in Chapter 7) will normally require Clean Water Act permits before work can commence. In regions with endangered or threatened species, and/or their critical habitat, vegetation removal of any kind may require clearance through the U.S. Fish and Wildlife Service or the National Marine Fisheries Service under the Endangered Species Act. I 5-1 ETL 1110-2-571 10 Apr 09 I 5-4. Repair of Animal Burrows. For proper procedures for the repair of animal burrows, refer to the latest edition of FEMA publication 473, Technical Manual for Dam Owners, Impacts of Animals on Earthen Dams. I I i i SII I i I i i I I 5-2 i ETL 1110-2-571 10 Apr 09 CHAPTER 6 ILLUSTRATIONS 6-1. General. a. The figures presented here are cross-sections and are organized as follows. Figure 1 illustrates the minimum vegetation-free zone required for a basic levee section and serves as an introductory example for use in Figure 2. Figure 2 illustrates the proper application of the vegetation-free zone with regard to various vegetation types and stages of development. Figures 3 through 23 provide additional examples, illustrating the minimum vegetation-free zone required for each of various flood damage reduction system configurations. Root-free zones are indicated in Figures 13, 14, 15, 17, and 19. Vegetation-free zone requirements for embankment dams and their appurtenant structures are illustrated in Figures 20 and 21 and are presented in greater detail in Paragraph 3-4. Figure 22 illustrates the vegetation-management zone. Figure 23 illustrates a levee section with the ordinary high water mark above the riverside toe. b. For clarity, Figures 1 through 23 are not drawn to scale; however, Figures 24 and 25 are drawn to scale,using trees in the medium to large size range. The purpose of these two proportionally correct figures is to clearly illustrate realistic spatial relationships between trees (and their root systems) and levees. c. Note that the minimum vegetation-free zone is not influenced by the type of erosion protection used, so figures are not specific in that regard, e.g., riprap is not shown. 6-2. Figures 1 through 25 LEtIEE RIVERSIDE CROWN�LANDSIDE 15 1S it MIPLdF MIN. MIMMUM VEGETATION-FREE ZO 1 ** F � I 16 OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS �k k IN THIS b'X T TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS Q NORMAL WATER.SURFACE Figure 1: Levee Section—Basic. j 6-1 ETL 1110-2-571 10 Apr 09 I I i� TREES WITH LOW LIMBS OR CROWN,SUCH AS ACONIFEROUS TREE,MUST HAVE TRUNK CENTERLINE SUFFICIENTLY DISTANT FROM THE ZONE THAT NO PART OF THE TREE IS IN THE ZONE.IF THIS TREE WERE TO GROW INTO THE ZONE,IT WOULD HAVE TO BE EITHER PRUNED OR REMOVED— TREE TRUNK CENTERLINE MAY BE ON TWE j EDGE OF,BUT NOT INSIDE OF,THE ZONE TREE LIMBS AND CROWN MAY BE ABOVE,BUT NOT IN,THE ZONE ' ` 6 MINIMUM . .VEGETATION-FREEZONE I' .ArAr"m .n. I I I `_-NO PORTION OF THE SHRUB MAYBE IN THE 70NE I I I i a. MATURE TREES AND SHRUB I I I t i i i !—THESE LIMBS AND CROWN ARE ACCEPTABLEAS TEMPORARY INTRUSIONS INTO THE ZONE.AS THE 1 TREE DEVELOPS IT SHAD.GROW,OR BE PRUNED, j CLEAR OF THE ZONE.HOWEVER.DURING j f DEVELOPMENT,IF EMERGENCY ACCESS REQUIRES, I THE TREE MAY HAVE TO BE REMOVED ! I 'aTA7TON•FREEZONE L 3 f --VEGETATION THAT IS EXPECTED TO MAINTAIN ALOW 1 CROWN,MUST BE LOCATED SUFFICIENTLY DISTANT FROM THE ZONE SO THAT IT WILL NOT INTRUDE AT MATURITY -- b. NEWLY PLANTED TREES AND SHRUB NOTE: THE MIRROR IMAGE OF THIS FIGURE WOULD BE EQUALLY CORRECT,REGARDLESS OF WHICH SIDE IS THE RIVERSIDE i Figure 2: Proper Application of the Vegetation-Free Zone. 6-2 I ETL 1110-2-571 j 10 Apr 09 LEVEE —, RIVERSIDE CROWN LANDSIDE ! RIVERSIDE �- I MINI* ( ; MINIMUM ; ! MIN. i V�GEI'AT O<!-FFA I . ZONE � TO _ E n9" * 16 OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS ie# IN THIS 4`XrTRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN 35 ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS 17 NORMAL WATER SURFACE Figure 3: Levee Section—Basic,with Floodwall on Crown. i LEVEE _—.• — ----------- RIVERSIDE CROWN. LANDSIDE 15 15, sw., MW W MINIMUM MIN, ON.FREEZtINE � temv.ve v i .. Y 4lr it BLANKET DRAIN 15'OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS �k^# IN THIS v X r TRAN$ITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS `\7 NORMAL WATER SURFACE Figure 4: Levee Section with Blanket Drain. i, j 6-3 I i ETL 1110-2-571 j 10 Apr 09 LEWE RIVERSIDE CROWN LANDSIDE j BERM MIN.* MIN. MINIMUM VEGETATION-FREEZONE k ik TOE . ' gym .n\a: .. �lk _ n� VI a fia fi l7a.'Y4 .»-' h k I V OR DISTANCE TO EDGE OF NORMAL WATERSURFACE,IF LESS *ie IN THIS 4'X7'TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS 17 NORMAL WATERSURFACE Figure 5: Levee Section with Seepage or Stability Berm. LEVEE RIVERSIDE CROWN LANDSIDEP? MIN.ic MINIMUMMIN. ' .;VEGETATION-FREEZONE .... I TRENCH x cm n� 1S OR UISTANCE TO EDGE OF NORMAL WATER SURFACE.IF LESS ik* IN THIS 4'X r TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS NORMAL WATER SURFACE Figure 6: Levee Section with Pervious Toe Trench. 6-4 j I ETL 1110-2-571 10 Apr 09 i LEVEE RIVERSID CROWN LNNUSIDE I 15 15' MK* VEGETAMOWFREE ZONE, _ WIN RELIEF WELL OR PIEZOMETER iF 15 OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS 'kYt IN THIS 4'XT TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN. IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS �7 NORMAI.WATERSURFACE Figure 7: Levee Section with Relief Well or Piezometer. M LEVEE RIVERSIDE CROWNDSIDE �A_N- 15' DITCH 15' 1 MK* MIIV MINIMUM VEGETATION-FREE ZtIE ,a, q ,naa.-� � .�'n.n� -"pmt .a i ,•.�. � s a�.e "ta,a�w k :. ELL EZOMED:R 15'OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS IN THIS 4'X7'TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS NORMAL WATER SURFACE Figure 8: Levee Section with Relief Well or Piezometer and Seepage Collector Ditch. i i I I I� 6-5 ETL 1110-2-571 10 Apr 09 i I LEVEE RIVEITSJOE CROWN LANDSIDE SUB LEVEE is MI MINIMUM MIN.* VEGETATION-FREEZONE .i TOE * gp _ �s.,gym.a�`rt n`� a� w,..� nd ,•n, •FR . j n� * 15 OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS ** IN THIS 4`X T TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LAMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 1U YEARS P NORMAL WATER SURFACE Figure 9: Levee Section with Sub-Levee. ------LEVEE--------H BERM RIVERSIDE GROWN L.ANDSIDE 15 _ � I .MINIMUM I MIN, VEGETATION-FREE ZONE . �•- " � TOEt-- � z * I V OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS ** IN THIS 4'XTTRANSITION ZONE,TEMPORARY OBSTRUCTION BYLIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS NORMAL WATER SURFACE Figure 10: Levee Section with Stability Berm. i i 6-6 ETL 1110-2-571 10 Apr 09 LEVEE BERMICAP RIVERSIDE CROWN LANDSID MIN,k MINIM UM MIN. VEGUATION-FREE ZCN9, m stir- TOE!** 1 `'--CUT-OFF WALL * iS OR DISTANCE TO EDGE OF NORMAL WATER.SURFACE,IF LESS ** IN THIS R X7'TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN ISALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UPTO 10 YEARS V NORMAL WATER.SURFACE Figure 11: Levee Section with Cut-Off Wall and Impervious Berm. LEVEE RIVERSIDE CROWN LANDSIDE MINIMUM MIN. � Y: *VEGE7ATICFRE�EZONE t TCNE �tdr_ i CONSTRUCTED IMPERVIOUS BLANKET `IV OR DISTANCE TO MOE OF NORMAL WATER SURFACE,IF LESS IN THIS 4'XTTRANSITION ZONE,TEMP'ORARYOBSTRUCTIONBYLIMBSAND CROWN WALLOWED DURING DEVELOPMENT OF NEW PLANINGS,FOR UPTO 10 YEARS Q NORMALWATER.SURFACE Figure 12: Levee Section with Constructed Impervious Blanket. 1 I i 6-7 ETL 1110-2-571 10 Apr 09 _ LEVEE _ RIVERSIDE CROWN LANDSIDE i PLANTING BERM 15` � MIN- TS' _ I VEGETATION-FREE ZONE min� i \ ROOT FREE ZONE 1MIN.31- a * 15'OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS '1k* IN THIS 4'X7'TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN ISALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 14 YEARS CJ NORMAL.WATER SURFACE Figure 13: Levee Section with Planting Berm. LEVEE I RIVERSIDE CROWN LANDSIDE� -- - PLANTING BERM 15 E 1S ( 1S 1 `"'----------M' � MIN �.m.__,_ � � MIN. 1S �-r- MZN* MLiaiMUM �t ! VEMATIoNFREEz E , I 9E is n 'v"`'` " MINIMUM =° aY do YEUM J'1GM .. m FREE ZONE =.,. R4M7FFREE ZONE IMI N.3')—�` DRAIN--- I IT RAM=IS'OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS i ie ie IN THIS V X T TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 14 YEARS NORMAL WATER SURFACE Figure 14: Levee Section with Planting Berm and Collector Drain. I 6-8 ETL 1110-2-571 i 10 Apr 09 LEVEE RIVERSIDE CROW��LANTiSIDE I i € PLANTING BERM i r 15' --MMIN. j i I � I; � MIN.* vEGEi-atlaN-FrtEE zoNE , '' j ... _ it�k MINIMUM ik T VEGETATION .... Z FREE ZONE ,�546A1nAS15'v A: .A .el A n �A A �.. A l?V� ROOT FREE ZONE(MIN.7)— —BLANKET DRAIN. c # 1$OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS is* IN THIS NX r TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS CJ NORMAL WATER SURFACE Figure 15: Levee Section with Planting Berm and Blanket Drain. I I I i 6-9 I ETL 1110-2-571 10 Apr 09 i MIN.® WAIL I � I i -.----- . '.4 ----- MINIMUM A _ . 'MINIMUM VEaGEfATION-FREEZONE VEGETATION-FREEZONE,- fi\ M n�\`�/n^, :tfi\ ?` WALLFOUNDATION R 3°3 • 1 ! i I } 3 _ a, a' ie IS OR DISTANCE TO EDGE OF NORMAN..WATFR SURFACE,IF LESS zY IN THIS 4'X T TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS �j NORMAL WATER SURFACE Figure 16: Inverted-T Type Floodwall. i I i ! 6-10 ETL 1110-2-571 10 Apr 09 MIN.4e WALL i I MINIMUM a "MINIMUM VEoEmnoN-FREE ZONE', ` "VEGETATION-FREEZomE :ft�41A1�tjMlIAM E , .A ,\:f�\fh ,U• 'r �,�Ifr v� WALL FOUNDATION DRAIN --'" .! j :I 60 j ' MINIMUM i RQOTditEEZONE f L 0� 0 i MIN. MIN. MIN, 7h 15'OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS IN THIS VXT TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND GROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UPTO 10 YEAR 57 NORMAL WATER SURFACE NOTE: THE HORIZONTAL DIMENSION OF THE MINIMUM VEGETAXION-FREE ZONE SHALL BETHE GREATER OF: (A) THE 15-FOOT MINIMUM,AS DIMENSIONED ABOVE GRADE;OR (B) AS DIMENSIONED FROM THE BELOW-GRADE STRUMM Figure 17: Inverted-T Type Floodwall with Drain. i i 6-11 ETL 1110-2-571 10 Apr 09 1s° 15 I ' W ALL MINIMUM MINIMUM VEGETATEGETATION-FREE-� IIi d� ZQNE ,� ✓ ��`/��'�ty1`\�✓r\U�E:✓,c b; i. ,�lrUi; �Y✓�,�7✓�.�I,�` il�;;'i. -� a i j WNL FOUNDATION k a SHEET PILING * 15°OR DISTANCE TO EDGE OF NORMAL WATERSURFACE,IF LESS sir 9h IN THIS 44 X T TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS L7 NORMAL WATER SURFACE Figure 18: Cantilever-I Type Sheet-Piling Floodwall. i 6-12 ETL 1110-2-571 10 Apr 09 I 15'------------- MK* MIN. I i WALL i I -.ife* ick. L m Z MINIMIftd _ MINIMUM . VEGETATION FREE ZONE. .n' VEGETATION+TkEE ZONE i DRAIN WALL FOUNDATION I � 9 Ill4 \ SHEET PILING MINIMUM ROOT-FREE ZONE � S MIN. 15`OR DISTANCE TO EDGE OF NORMAL WATER SURFACE,IF LESS ' #'➢t IN THIS 4`X r TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN I$ALLOWED DURING DEVELOPMENT OF NEW PLANTINOS,FOR UP TO 10 YEARS 17 NORMAL WATER SURFACE NOTE: THE HORIZONTAL DIMENSION OF THE MINIMUMVEGIEATION-FREEZONE SHALL BE THE GREATER OF: ATHE 115-FOOT MINIMUM,AS DIMENSIONED ABOVE GRADE;OR AS DIMENSIONED FROM THE BELOW-GRADE STRUCTURE Figure 19: Cantilever-I Type Sheet-Piling Floodwall with Drain. i I I i I 6-13 ETL 1110-2-571 10 Apr 09 1 DAM UPSTREAM ..CROWN 13OWNSTFTEAM, � - MIN_�__®� MINiMUM VGGECAnDNFREEZONE . � _ k k EMBANKMENT &fir DAM ll/ S.@aaA'z%§ >Go- _A,. CWti"b44�v�'A d 31Ha\At,. PnVrA4 a. EMBANKMENT DAM WITH DRY RESERVOIR i DAM UPStREAM .,.CROWN DOWNSTREAM sm so' MIN. MlN. "MINIMUM V'E,GE.ATION-FREE Z,OIE y JF ' EMBANKMENT "q. 4 T DAM CONSTRUCTED IMPERVIOUS BLANKET b. EMBANKMENT DAM WITH DRY RESERVOIR AND CONSTRUCTED IMPERVIOUS BLANKET IN THIS V X T TRANSITION ZONE:TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS Figure 20: Embankment Dam(Earth Fill, Rock Fill, or Earth and Rock Fill). i i I j i I 6-14 ETL 1110-2-571 10 Apr 09 I DAM UPSTREAM �CROWN DOWNSTREAM I � i — - MIN.---- �, VEGETATION-FREE ZONE.. . EMBANKMENT 1P DAM +b�, a. EMBANKMENT WITH E I H NORMAL POOL I DAM UPSTREAM CROWN. DOWNSTREAM I � MIN. MINIMUM ` ., I VEGETATiON+REE`Z N1E c . EMBANKMENT DAM 6v:r Beim.` -\.Q-AN11. A. L,l CONSTRUCTED IMPERVIOUS BLANKET b. EMBANKMENT DAM WITH NORMAL POOL AND CONSTRUCTED IMPERVIOUS BLANKET it IN THIS N X?'TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN 19 ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS NORMALPOOL Figure 21: Embankment Dam(Earth Fill, Rock Fill, or Earth and Rock Fill). 6-15 ETL 1110-2-571 V 10 Apr 09 j I i VEGETATION LEVEE -_- VEGETATION MANAGEMENT RIVERSIDE CROWN�L7�� 15 MANAGEMENT MIN.# MINIMUM " MIN. VEG rAT[OWFR ZONE E.. � I tk 1TORDISTANCE TOEDGE OFNORMAL WATER SURFACE,IFLESS * IN THIS 4'X 7'TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS C7 NORMALWATERSURFACE NOTES: 1. THE VEGETAMOWMANAGEMENTZONE ALLOWS FORACCESS,FOR THE PURPOSE OF INSPECTION,AND MODIFICATION OR REMOVAL OF ANY PLANT WHOSE LIMB, FOILAGE.OR ROOT BEHAVIORS BECOME ATHREATTO PROJECT RELIABILITY, 2. THE APPROPRIATE WIDTH OF THE VEGETATION-MANAGEMENT ZONE SHALL BE DETERMINED BY THE DESIGN TEAM:35 FEE'WILL BE SUFFICIENT IN MOST CASES, 3. THE VEGETATION-MANAGEMENT ZONE MAYBE ESTABLISHED BY EASEMENT 4. THIS FIGURE SHOWS THE VEGETATION-MANAGEMENT ZONE IN THE CASE OF A LEVEE:HOW€,-VER,IT IS EQUALLY APPROPRIATE IN THE CASE OF ANY OTHER FLOOD DAMAGE REDUCTION STRUCTURE ORAPPURTENANCE:TI'S USUAL RELATIONSHIP IS TO THE VEGETATION-FREE ZONE. Figure 22: Vegetation-Management Zone. I I 6-16 ETL 1110-2-571 10 Apr 09 I LEVEE RIVERSIDE CROWN LANDSIDE Is Is MIN, "f MINIMUM i MIN. VEGETATION-FREE _ i ZONE ; i 4:.#'iAliV 'llT hlN LW1ml is* IN THIS 4'X T TRANSITION ZONE,TEMPORARY OBSTRUCTION BY LIMBS AND CROWN IS ALLOWED DURING DEVELOPMENT OF NEW PLANTINGS,FOR UP TO 10 YEARS ' i V WATER SURFACE ELEVATION AT ORDINARY HIGH WATER MARK VEGETATION-FREE ZONE BELOW THE ORDINARY HIGH WATER MARK NOTE: MECHANIZED LAND-CLEARING ACTIVITIES BY THE PROJECT SPONSOR,BELOW THE ORDINARY HIGH WATER MARK(OHWM),MUST BE PERMITTED IN ACCORDANCE WITH REGULATIONS UNDER SECTION 404 OF THE CLEAN WATER ACT HOWEVER,.SIMPLE:. CLEARING OF VEGETAMON USING HAND TOOLS(CHAIN SAWS,ETC)AND REMOVAL OF TREES USING CRANE r{OR OTHER TYPES OF HEAVY MACHINERY!WOULD NOT GENERALLY REQUIREAS ON 404 PERMIT,PROVIDEDVEGETATI IS REMOVED IN SUCH A MANNERAS TO NOT DISTURB THE SOIL;BUT,THESE ACTRUIES MAY REQUIRE CONSULTATION WITH THE US FISH AND WILDLIFE SERVICE OR NATIONAL MARINE FISHERIES SERVICE UNDER THE ENDANGERED SPECIES ACT REGULATIONS. THE CORPS RECOMMENDS THAT THE SPONSOR CONDUCT COORDINATION MEETINGS WITH THE CORPS AND OTHER APPROPRIATE AGENCIES BEFORE WORK IS CONDUCTED. SEE PARAGRAPH 6.3,REMOVAL OF NON-COMPLIANT VEGETATION, Figure 23: Levee Section with Ordinary High Water Mark Above the Riverside Toe. i I i 6-17 ETL 1110-2-571 10 Apr 09 I, THIS PROPORTIONALLY CORRECT FIGURE USES TREES IN THE MEDIUM TO LARGE SIZE RANGE TO ILLUSTRATE REALISTIC SPATIAL RELATIONSHIP'S BETWEEN TREES(AND THEIR ROOT SYSTEMS)AND LEVEES. i t i i k y �-APPROXIMATE TYPICAL HORIZONTAL EXTENT OF ROOT SYSTEM(CROWN RADIUS X 1.75)_' a. TREES(50'TALL,50'SPREAD LOCATED AT EDGES OF VEGETATION FREE ZONE (TRUNKCENTERAT 15'FROMM LEVEE TOE) 777 APPROXIMATE TYPICAL HORIZONTAL EXTENT J�.., OF ROOT SYSTEM(CROWN RADIUS X 1.75)--J b. TREES(100'TALL, 100'SPREAD)LOCATED AT EDGES OF VEGETATION FREE ZONE (TRUNK CENTERAT 16 FROM LEVEE TOE) i Figure 24: Levee (20 feet tall, 3:1 side slopes) with Trees, as Noted Above. i 6-18 ETL 1110-2-571 10 Apr 09 I I THIS PROPORTIONALLY CORRECT FIGURE USES TREES IN THE MEDIUM TO LARGE SIZE RANGE TO ILLUSTRATE REALISTIC SPATIAL RELATIONSHIPS BETWEEN TREES(AND THEIR ROOT SYSTEMS)AND LEVEES. i 17 .....APPROXIMATE TYPICAL HORIZONTAL EXTENT , OF ROOT SYSTEM(CROWN RADIUS X 1.75) a TREES(50'TALL,50'SPREA%LOCATED AT EDGES OF VEGETATION FREE ZONE (TRUNKCENTERATIS'FRO LEVEE TOE) APPROXIMATE TYPICAL HORIZON AL EX'I,ENI�f OF ROOT SYSTEM(CROWN RADIUS X 1.75) b. TREES(100'TALL, 100'SPREAD}LOCATED AT EDGES OF VEGETATION FREE ZONE (TRUNK CENTER AT 15'FROM LEVEE TOE) I Figure 25: Levee (10 feet tall, 3:1 side slopes) with Trees, as Noted Above. I i i i I 6-19 i i i i i i i ETL 1110-2-571 10 Apr 09 GLOSSARY a Critical Structure A critical structure is any component of a flood damage reduction system that contributes to _ system reliability. Flood Damage Reduction (FDR) System A flood damage reduction system is made up of one or more flood damage reduction segments i that collectively provide flood damage reduction to a defined area. Failure of one segment within a system constitutes failure of the entire system. Failure of one system does not affect another system. Forb A forb is an herbaceous (non-woody) annual, biennial, or perennial plant, other than grass, sedges, and rushes (e.g. alfalfa, clover, vetch). Herbivory Herbivory is the consumption of vegetation by animals. Ordinary High Water Mark(OHWM) The Regulatory definition of the OHWM is provided at 33 CFR Part 328.3(e) and states: "The term`ordinary high water mark' means that line on the shore established by the fluctuations of water and indicated by physical characteristics such as clear, natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas." The OHWM determines the lateral extent of the jurisdiction of the Corps within Waters of the United States (see Figure 23). j Overbuild Beyond the normal engineered cross-section of a levee, dam or appurtenant soil structure, overbuild is additional soil mass, fulfilling flood-damage-reduction design criteria and therefore subject to vegetation-free and root-free requirements. Variance A variance is a Corps-approved exemption from compliance with specific standards. II I i i Glossary-1 i a i ¢ 1 DEPARTMENT OF THE ARMY ROCK ISLAND DISTRICT, CORPS OF ENGINEERS CLOCK TOWER BUILDING-P.O. BOX 2004 ROCK ISLAND, ILLINOIS 61204-2004 REPLYTO ATTENTION OF March 3, 2015 Emergency Management Division Mr. John Klostermann Dubuque, Iowa Flood Damage Reduction System 925 Kerper Court Dubuque, Iowa 52001 Dear Mr. Klostermann: This letter is in reference to the Dubuque, Iowa Flood Damage Reduction System (FDRS) Continuing Eligibility Inspection performed on November 17, 2014. The overall general condition for the levee system is considered Acceptable as defined by Public Law (PL) 84-99 project maintenance standards. The system is considered Active in the PL 84-99 Rehabilitation and Inspection Program following interim guidelines in the USACE Policy Guidance for Determining Eligibility Status of Flood Risk Management Projects issued March 21, 2014. As noted in the enclosed report, deficiency item of encroachment issues are the items that must be corrected. The attached report, photos and map provide a detailed listing of these deficiencies. Deficiencies listed as minimally acceptable must be repaired within two years of original identification or be submitted and approved as an appropriate alteration to the levee system. All unacceptable rated line items must be repaired prior to the next flood season. Procedures for submitting alterations of the Flood Damage Reduction System can be viewed at the Rock Island District's Levee Safety Program website. The United States Army Corps of Engineers Engineering Technical Letter (ETL) 110-2-583 is available to guide sponsors in the identification of specific vegetation removal when unacceptable growth is within the Vegetation Free Zone (VFZ). The following conditions must be adhered to when removing vegetation: vegetation to be removed must be within the real estate interest (maintenance easement) of the levee system; removal of vegetation must be in compliance with regulatory programs; and removal of vegetation will not increase risk to the FDRS. Approximate boundaries of lands owned by the Federal Government are available upon request. 2 I If you have any questions about the inspection process or would like an electronic copy of the report, please contact Mr. Cory Haberman at (309)794-5325, or by email at Cory.J.Haberman@usace.army.mil. Sincerely, 1 Rodney L. Delp Chief, Emergency Management Division Enclosure i I I o � c °, w � •cay ° o o c c z � � 3 K 0 N n n 7 D $ y < E3 x F v o' '. cm o o n G a m O W N y o �o p e o e m eke ° e o o 0 rt w m w ' N G O C• (yD p O C� d Oil 7 ' o o m m P ,b x B ''' a N w e m m O 3 'O Iwo = y A Oo a F/ F a m m A � m ewe O 00 NJ o •+ ,p m za '� Zrn m - 'Z O O .y m �0 � ° 7 3 ^ � O m O m N N W �$ � �• 91 O V� UQ 9 N w y m m tlG m O O a '� rn a ° rn 2 m p p y C y m o • � ° m o ao "n m. a p y a eM cpizDm� o n o E.. n 7J m n O ° 0 y b (E rn �' d m 9 ^ O O °7 aK3 < = smb m m ° O :4 ° � m a. d m rn o 3 o y � c a d d ° ° a Day -C ., < '�;o< '-� ? two m ❑ - °- RR ' O-nom o tw o �c ° '^mom 5c Cot. ` p cw toy = o o 0 23 0 - ^ ao W ^^.• IJ r 'i9 V > mlm CA 0 .y m OG O � ^' A a. o n T n 6 E` O R Oiy dOEff E; O N g m 3 O S d 'x2s E g 5 R 5.0^ 3 3 ~ c° $ 5' 6 A O A N N f �� d n a c El T w w - o°o El o A 3 � o w 3.O. X1 rye oA A � rFS �I O H��J IYVl w 3_ m S 3 3q m 8.0 w 3 0 T A a D w o � v m � 0 A A � n O a m& �� =+3 m� y A A a a a a n w - d r 7 I °i 3 " m ° fi 3 �. ? 3 a 3 o m n ?; �, O� C 4, � m N Ro � o0A � .3E � � w .°» x g o � $' � o � o oe D W T :. �� o, N £m$' m � �+°w o 'O "p" A � e ap (p DLEI do 2 = ^ a < m, c 0� O O ,y 3 c �' E. m m v p' w w ° o a..o A e a c m o: n@Q@ a e =O N e m n I n S g.F' e 0 a E w a 4 A=. °°° n m °°° z 3 w 7 CD O o w O CO wq OR �.E '° « o m G. R m d m i 6 N w n n n 6 y 1�1 9 c2 O IMry l�Y on 19 tS 42° a O• � 2 O R d yO F��1 `r tv.a Com 'Q w a y y EL n n O w O � ~ O M ELo � 0 S y o C 3 pi v O R S n O i N O_ M b w � _ w m O m ° W n = m � M 0 e � w 3 Z J O-�� D � �D� e � � O' 3 � o � ®� c rt a e a as z m m e n e z a 3 f] 0 Ti � o m o �' a a O A 3 a v v � P � � C '�' L q c n a !� ? e e n `a = off ' C c m � ^''3 A � 0 A 3 -a m 0 m 9 m 7 .�. d c A � N SJ O � 'f w 3 2 � E ! ( ; ■ y [ § � \ \ m) } \ ; � e ] ` ; i > ! 22E , ; f am ) k \ \ \ ± ; { ; ; „ § US / \\ \ / f � � ! \\ \ \ � { } \ ! \ ! | 12/21/2015) Kevin Firnstahl - Request to address the Cit Council 2015.12.21 From: Carolyn Pettit -Lange <wannabejizo@gmail.com> To: <kfirnsta@cityofdubuque.org> CC: Carolyn Pettit -Lange <wannabejizo@gmail.com> Date: 12/21/2015 10:10 AM Subject: Request to address the City Council 2015.12.21 Dear Mr. Firnstahl, I respectfully request permission to briefly address the City Council on behalf of the advocacy group known as Dubuque Poison Free Parks regarding action item #4 at tonight's City Council meeting. Late last week, the Parks and Recreation Department initiated a process to create an Integrated Pest Management Policy workgroup. Our group feels we can offer valuable support for this process. We are seeking inclusion on this workgroup. Thank you for considering our request. Sincerely, Carolyn Pettit -Lange Dubuque Poison Free Parks 549 Almond Street Dubuque, IA 52001 563-564-3506 Click https://www.mailcontrol.com/sr/QhOcGdkdCVLGX2PQPOmvUmI+xXZX6IbgNPuseEn!bBNmRn4L14rEPP 1 E5aXuOypppzmwuPL8114NCU1!U1Tbvw== to report this email as spam.