Statement to the Colombian Consejo de Estado:
Application of the Precautionary Principle to the Fumigation Program in Colombia
Rachel Massey, MSc, MPA, Tufts University1
Joel Tickner, ScD, University of Massachusetts Lowell
Ted Schettler, MD, MPH, Science and Environmental Health Network, Greater Boston
Physicians for Social Responsibility, and Boston Medical Center
Vanessa Gray, PhD, University of Massachusetts Lowell
Jim Oldham, BA, Las Lianas Resource Center for Science, Culture, and Environment
September 18, 2003
We are submitting this statement in support of the precautionary decision by the
Tribunal Administrativo de Cundinamarca to suspend fumigations for drug crop
eradication, pending studies of the health and environmental impacts of such fumigations
and proof of compliance with the Environmental Management Plan that governs them.
We submit these comments in our capacities as scientists and environmental policy
analysts specializing in appropriate application of scientific knowledge and use of the
precautionary principle in environmental and public health decision making.
The precautionary principle states that when an activity poses a threat of harm to
human health or the environment, protective action should be taken even if scientific
information is incomplete. The precautionary principle has been codified in a variety of
international legal documents. In our comments, we review existing information on
hazards of herbicide use as well as key uncertainties that exist regarding the
environmental and human health effects of the fumigation campaigns. In this context, we
argue that precautionary action requires suspension of the fumigation program. We
emphasize that the failure to gather information on human health and environmental
effects of the program in no way demonstrates absence of harm to human health or the
environment.
Information Available
There are many open questions about how the herbicide spray campaigns in
Colombia are affecting human health, local economies, and delicate ecosystems, but a
substantial amount of information exists to support the view that these effects are
adverse. Existing information related to human health includes toxicity information on
the active ingredient, glyphosate, and some glyphosate-surfactant mixtures; case reports
1
Rachel Massey, MSc, MPA is Research Associate at the Global Development and Environment Institute,
Tufts University, Medford, MA. Joel Tickner, ScD, is Research Assistant Professor at the Center for
Sustainable Production, University of Massachusetts Lowell, and is an expert on improving science and
policy decisions on uncertainty and application of the precautionary principle in environmental and public
health policy decisions. Ted Schettler, MD, MPH, is Science Director of the Science and Environmental
Health Network and co-chair of Greater Boston Physicians for Social Responsibility. He is a physician at
Boston Medical Center, Boston, MA. Vanessa Gray, PhD, is Assistant Professor of Political Science,
University of Massachusetts Lowell. She specializes in bilateral U.S.-Colombia environmental politics. Jim
Oldham, BA, is Director, Las Lianas, Institute for Science and Culture, Amherst, MA.
of acute symptoms following exposure to glyphosate-surfactant mixtures; and
epidemiological data on links between exposure to glyphosate-containing herbicide
formulations and a variety of human health outcomes. For example, published case
reports on suicide attempts estimate the lethal dose of glyphosate-surfactant mixtures;2
laboratory data suggest that a glyphosate herbicide formulation can act as an endocrine
disrupter, blocking testosterone production;3 and epidemiological data suggest possible
links between exposure to glyphosate herbicides and adverse health effects including
reproductive problems.4
Existing information related to environmental effects includes the following.
Ample information is available on the broad-spectrum herbicidal activity of glyphosate
mixtures and on the likelihood of vegetation damage through herbicide drift. 5
Information is also available on the span of drift expected and observed under conditions
typical in Colombia. In its 2002 report to the U.S. State Department, the U.S.
Environmental Protection Agency (EPA) highlights the probability of spray drift and
likely damage to non-target plants. The Agency notes also that that under these
conditions, “adverse effects from the temporary loss of habitat in the spray area could
occur.”6 Numerous studies have documented adverse effects of glyphosate herbicides on
terrestrial and aquatic organisms, including soil microorganisms, in temperate climates.7
Lack of Information
Key information is absent in each of the main areas examined in a standard risk
assessment: hazard identification, toxicity evaluation, including dose-response
information, and exposure assessment. Hazard identification requires identification of all
See, for example, Y. Sawada et al., “Probable toxicity of surface-active agent in commercial herbicide
containing glyphosate.” The Lancet 1:8580 (1988), 299; R.L. Tominack, “Taiwan National Poison Center:
Survey of glyphosate-surfactant herbicide ingestions.” Clinical Toxicology 29:1 (1991), 91-109; A. R.
Talbot et al., “Acute poisoning with a glyphosate-surfactant herbicide (‘Roundup’): A review of 93 cases.”
Human Exp. Toxicol. 16 (1997), 596-599.
3
L.P. Walsh et al. “Roundup inhibits steroidogenesis by disrupting steroidogenic acute regulatory (StAR)
protein expression.” Environmental Health Perspectives 108 (2000), 769-776.
4
See T.E. Arbuckle et al., “An exploratory analysis of the effect of pesticide exposure on the risk of
spontaneous abortion in an Ontario farm population.” Environmental Health Perspectives 109 (2001), 851857; D.A. Savitz et al., “Male pesticide exposure and pregnancy outcome,” American Journal of
Epidemiology 146 (1997), 1025-1036; V.F. Garry et al., “Birth defects, season of conception, and sex of
children born to pesticide applicators living in the Red River Valley of Minnesota, USA.” Environmental
Health Perspectives 110, Suppl. 3 (2002), 441-449.
5
See Nicholas J. Payne, "Off-Target Glyphosate from Aerial Silvicultural Applications, and Buffer Zones
Required around Sensitive Areas," Pesticide Science 34 (1992), 1-8; D. Atkinson, "Glyphosate damage
symptoms and the effects of drift," in E. Grossbard and D. Atkinson, eds, The Herbicide Glyphosate
(London: Butterworth Heinemann, 1985), 455-458.
6
U.S. EPA, "Consultation Review of the Use of Pesticide for Coca Eradication in Colombia," released by
the Bureau for International Narcotics and Law Enforcement Affairs, September 2002, Executive
Summary: Findings.
7
For a comprehensive review of relevant studies on aquatic and soil biota, see Jeremy Bigwood, “A Brief
Overview of the Scientific Literature Regarding Reported Deleterious Effects of Glyphosate Formulations
on Aquatic and Soil Biota.” Review prepared for the Ministry of the Environment of Ecuador, March 6,
2002.
2
chemical components of the herbicidal formulation. Toxicity evaluation requires
comprehensive toxicological evaluation for all relevant health endpoints of the chemical
components, both individually and in their final formulation. Finally, exposure
assessment requires accurate and comprehensive identification and analysis of exposure
pathways, including inhalation, dermal, and oral routes of exposure, and must take into
account the frequency of exposure, the concentration of the formulated product, and the
volume of exposure.
Important areas of uncertainty include the lack of baseline information on the
health profiles of affected populations; lack of epidemiological studies testing how these
populations have been affected by the spray campaigns; lack of information on the
cumulative effect of herbicide exposures with other stresses associated with acute poverty
and warfare; lack of information on the exact ingredients of the formulated product; lack
of information on the concentrations in which the product has been or will be applied;
lack of information on effects of glyphosate mixtures on tropical flora and fauna, and on
effects of temperature on glyphosate toxicity; and lack of information on whether or not
the label guidance is being followed in herbicide application. Again, the absence of
information on these key questions cannot be construed as evidence of no harm to human
health or the environment.
Lack of epidemiological data. No data exist to support the contention that the
herbicide spray campaigns in Colombia have no adverse human health effects. As the
U.S. Environmental Protection Agency has noted, no meaningful conclusions can be
drawn from the US Embassy-sponsored report on health effects in the Department of
Nariño. This report, on which we have commented in the past,8 examines just 29 case
reports, with no explanation of how these case reports were selected. This small number
of case reports is difficult to explain given that the health center from which they are
drawn is one of just three health centers serving a population of 17,000. In addition,
among other problems, the Nariño report compares real data from 1999 to estimated data
for 2000, and concludes from this comparison that no significant increase in morbidity
occurred between the two years.
Lack of exposure data. No data have been collected or presented on the extent and
nature of human exposure to the spray mixture. It is well known that the aerially applied
herbicide mixture can easily drift off target. In one well documented case, the late U.S.
Senator Paul Wellstone was sprayed directly during an exercise intended to demonstrate
the precise targeting of the spraying. In addition, reporters and international human rights
observers have documented instances of spraying occurring very close to populated areas,
including homes, schools, and agricultural fields.9
8
See Rachel Massey, "Critique of the 'Nariño Health Report,'" March 7, 2002. Available at:
http://www.usfumigation.org/narino_pdf.pdf.
9
See, for example, Juan Forero, "No Crops Spared in Colombia's Coca War," New York Times (January 31,
2001), and photographs collected by Witness for Peace, available at
http://www.witnessforpeace.org/colombia/photos.html (accessed September 2003).
An exposure assessment should consider the inhalation pathway as well as dermal
exposure through direct contact with the spray mixture and oral exposure via
contaminated water and food sources. Exposure via food may be a particular concern
when food crops are sprayed directly, as is known to occur. In the absence of alternative
food sources, affected communities may harvest and consume contaminated food crops
shortly after spraying occurs. In addition, no information is available on the cumulative
effects of exposure to the chemical mixture used in the crop eradication campaigns when
combined with a high burden of physical and psychological stress associated with living
in extreme poverty and in conditions of armed conflict.
Vulnerable populations. No information exists on exposures of vulnerable
populations such as children and the elderly. Fetuses, infants, and children are uniquely
susceptible to toxic exposures. Children breathe more air, drink more water, and eat more
food than adults per unit body weight; in addition, some detoxification mechanisms are
underdeveloped in children, so that even low exposures without any discernible effects in
adults may have serious effects on children. Even low dose, single or occasional
exposures can have long term adverse effects, sometimes leading to permanent disability,
if these exposures occur during a critical window of fetal, infant, and child development.
Given the proximity of target areas to homes and schools, exposure of fetuses, infants,
and children is a particular concern in this case. To our knowledge, no official efforts
have been made to assess effects of the spray campaigns on fetal, infant, and child health.
Lack of toxicological data. A full toxicity evaluation requires assessment of a
variety of health endpoints, including reproductive effects, developmental effects, and
carcinogenesis, and must be applied to the formulated product. The chemical mixture that
is being used in Colombia has not, to our knowledge, undergone such testing. This
mixture is reported to consist of a glyphosate herbicide, possibly Roundup Ultra, plus the
adjuvant “Cosmo-Flux 411F.” This lack of information was highlighted by the U.S. EPA
when it conducted a review of the spray programs in 2002. The Agency noted that it
cannot “fully assess” the likely health effects of the tank mix in Colombia because the
adjuvant is not used in the U.S.10 EPA also noted that the State Department had “agreed
to supply the Agency with a full battery of the six acute toxicity tests on the tank mix”
but that the Agency received no such tests during the period in which it was reviewing
data on the spray campaigns.11
Lack of environmental impact data. Little information exists on the ecological
effects of glyphosate formulations in tropical climates, although the toxicity of a
glyphosate herbicide formulation has been found to increase with water temperature for
some species.12 Again, the U.S. EPA highlighted this lack of information, saying that the
lack of information limited the Agency’s ability to make meaningful statements about
likely effects of the spray campaigns. EPA noted that “laboratory and field estimates of
the environmental fate of pesticides, including potential surface-water contamination, are
10
U.S. EPA 2002, Section 3 (Review of Glyphosate Incident Reports): Background.
U.S. EPA 2002, Section 2 (Human Health): X (Risk Characterization).
12
World Health Organization, International Programme on Chemical Safety, International Labour
Organization, Glyphosate. Environmental Health Criteria #159, (1994). Geneva, Switzerland, pp. 110-112.
11
performed with North American soils, hydrology and climate data.”13 No data have been
collected or presented on the range of animal and plant species affected by the spray
campaigns; this omission is particularly serious given that spraying is now allowed within
national parks, and given the high proportion of endangered species in the affected areas.
A polyethoxylate surfactant produced severe adverse effects in salmon smolt in New
Brunswick during a spruce budworm eradication program;14 if the formulated product
contains a polyethoxylate, the possibility of similar effects in Colombia must be
considered.
Recommendations: A Precautionary Approach
The fumigation program in Colombia poses clear threats to human health and the
environment, though there is substantial uncertainty about the magnitude and precise
nature of these threats. Unanswered questions about effects include: What are the
toxicological properties of the tank mixture? What is the geographical, community, and
individual extent of exposure? To what extent have human drinking water sources been
contaminated? What species are endemic in the sprayed areas, and what is the
vulnerability of these species to toxic effects of glyphosate formulations? What are the
effects of the fumigation program on known populations of threatened or endangered
flora and fauna? There is an urgent need for collection of credible data on these
questions. However, a precautionary approach dictates that in the absence of definitive
answers, action must be taken to address the threats posed by the fumigations. The
absence of information on these key questions does not constitute evidence of no adverse
effects.
Closely related to the precautionary principle is the concept of alternatives
assessment, which requires consideration of the full range of alternatives to a hazardous
activity, including no action. Manual crop eradication accomplishes the same goal as
fumigation, without the attendant hazards to human health and the environment.
Alternative development programs offer promising options for transforming rural
economies, although some of these programs have now been destroyed by the herbicide
spray campaigns. Consistent with the precautionary principle, we urge a prompt halt to
the spray campaigns and an examination of the full range of alternative policies available.
13
U.S. EPA 2002, Section 4 (Ecological Risk Assessment): VI (Risk Characterization).
Fairchild WL, Swansburg EO, Arsenault JT, Brown SB. “Does an association between pesticide use and
subsequent declines in catch of Atlantic salmon (Salmo salar) represent a case of endocrine disruption?”
Environmental Health Perspectives 107:5 (May 1999), 349-58.
14