06
Jul
Sign by Today, July 6, 4pmEDT: Tell EPA to Ban the Persistent Toxic Herbicide Clopyralid that Contaminates Compost
(Beyond Pesticides, July 6, 2020) EPA’s proposed interim decision (PID) on the weed killer clopyralid is inadequate to protect human health, property, nontarget plants, and pollinators from damage. Clopyralid poses unreasonable adverse effects that cannot be remedied by EPA’s proposed fixes. It should be banned.
Sign the petition by noon Monday, July 6! Tell EPA to ban the persistent toxic herbicide clopyralid.
Clopyralid is a toxic persistent herbicide used to control broadleaf weeds on lawns and turf, range, pastures, right-of ways, and on several crops. Approximately 1.6 million pounds of clopyralid is used on 20 million acres per year in the U.S. on agricultural land, but it is also commonly used to kill dandelions, clover, and thistles. Lawn care operators applied over a million pounds of clopyralid in 2013.
Clopyralid is notorious for causing damage to nontarget plants. The registration was modified in 2002 to delete residential turf uses from the clopyralid product label. Additionally, under the amended label professional applicators are required to notify property managers not to compost clippings from treated grass. EPA proposes to expand the prohibition to include school turf, but clopyralid products will continue to be used on golf courses and certain other forms of nonresidential turf, as well as farm, ranch, and forestry uses.
Clopyralid causes environmental and property damage through drift, runoff, use of treated plant material (such as straw or grass clippings) for mulch or compost, contaminated irrigation water, and urine or manure from animals consuming treated vegetation. Clopyralid is “considered volatile,” according to EPA, meaning that it can evaporate from foliage and soil after application, move away from the application site, and “adversely affect nontarget broadleaf plants.” EPA calculated that volatilization of only one percent of applied clopyralid would be enough to damage nontarget plants.
Clopyralid can cause damage to sensitive plants at levels of 10 parts per billion. It is not broken down in composting facilities, and composters are very concerned about carry-over of clopyralid and other persistent herbicides, such as aminopyralid, aminocyclopyrachlor, and picloram into compostable materials. Clopyralid can enter the composting facility through lawn clippings, hay, straw, crop residues, and manure. Compost facilities now test for residues of persistent herbicides, but such tests are time-intensive and expensive.
In November 2002, the registration of clopyralid for use on residential lawns was voluntarily cancelled by the registrant, Dow AgroSciences. However, compost feedstocks are contaminated by other uses that are still allowed. Residues from any of these uses may find their way to composting facilities. Grass clippings, hay, and straw may also be used as mulch, allowing direct transfer of the herbicide to susceptible plants.
The contaminated mulch and compost may be used by homeowners, landscapers, or organic farmers. In the case of homeowners, it can mean the loss of expensive plantings. Landscapers may be liable for damages. In the case of organic farmers, it can mean the loss of a crop and possibly the loss of organic certification.
Clopyralid is not metabolized by animals but passes through in urine and feces. Thus, farmers and composters are advised to avoid manure from animals that may have eaten hay or feed that may be contaminated with it or other persistent herbicides. EPA proposes label amendments to mitigate these problems. If these label restrictions are followed, they may minimize the spread of clopyralid residues into sensitive areas. Doing so, however, reduces the availability of organic nutrients for crops and compost makers, thus burdening organic farmers and composters. This places undue burdens on those who do not benefit from the use of the herbicide and makes agriculture less sustainable. Instead, registrations of clopyralid and other persistent herbicides should be cancelled.
All herbicides, especially those targeting broadleaved plants, pose the risk of removing plants that provide food and habitat for pollinators. Some of those pollinators may be threatened or endangered species. As EPA admits, it has not evaluated risks to threatened and endangered species. Nor has it completed endocrine disruption evaluation. Since both of these are very sensitive consequences—that may result from much lower exposures than those evaluated thus far—reregistration must not proceed until those evaluations—including consultation with U.S. Fish and Wildlife Service and National Marine Fisheries Service—are complete.Â
Although EPA downplays them, clopyralid does present human health risks. Clopyralid is classified by EPA in acute toxicity class III as slightly toxic. Laboratory studies have shown that clopyralid is a severe eye irritant and dermal irritation has also been noted, which can lead to skin sensitization for prolonged skin exposures. Some developmental and reproductive effects have been observed in laboratory animals. The livers and kidneys of rats as well as the livers of dogs were affected by changes in weight and decreased red blood cell counts. Another study found that weights of rabbit fetuses decreased at both low and high doses of clopyralid. Skeletal abnormalities were also observed in these fetuses at all doses. Clopyralid products also contain toxic contaminants and “inert†or “other†ingredients.
Resistance to herbicides is an expected consequence of their use, so any perceived benefit of using an herbicide must be discounted by its reduced lifespan as an effective weed control. There are currently 514 unique cases (combinations of species and sites of action) of herbicide resistant weeds globally, with 262 species (152 dicots and 110 monocots). Weeds have evolved resistance to 23 of the 26 known herbicide sites of action and to 167 different herbicides. Herbicide resistant weeds have been reported in 93 crops in 70 countries. Resistance to clopyralid is known in four species, and resistance to other synthetic auxins has been documented in other species.Â
The growth of organic agriculture demonstrates the viability of nontoxic alternatives in agriculture. Nonorganic producers are looking to organic practices for help in dealing with the problem of herbicide resistance. In turf systems, managers are increasingly successful using organic systems, often mandated by local ordinances.
The use of clopyralid poses risks to human health, property, and the environment that are borne mostly by those who do not receive any benefit from the use of the herbicide. The risks are not outweighed by benefits, so the registration of clopyralid should be cancelled.
See Beyond Pesticides comments for more details and references.
Sign the petition by noon Monday, July 6! Tell EPA to ban the persistent toxic herbicide clopyralid.
Thank you!
The Beyond Pesticides Team
PETITION TOÂ EPA
Docket ID # EPA-HQ-OPP-2014-0167
The undersigned oppose the continued registration of clopyralid.
EPA’s proposed interim decision (PID) on clopyralid is inadequate to protect human health, property, nontarget plants, and pollinators from damage. Clopyralid poses unreasonable adverse effects that cannot be remedied by EPA’s proposed fixes. It should be banned.
Clopyralid is toxic persistent herbicide used to control broadleaf weeds on lawns and turf, range, pastures, right-of ways and on several crops. Approximately 1.6 million pounds of clopyralid is used on 20 million acres per year in the U.S. on agricultural land, but it is also commonly used to kill dandelions, clover, and thistles. Lawn care operators applied over a million pounds of clopyralid in 2013.
Clopyralid is notorious for causing damage to nontarget plants. The registration was modified in 2002 to delete residential turf uses from the clopyralid product label. Additionally, under the amended label professional applicators are required to notify property managers not to compost clippings from treated grass. EPA proposes to expand the prohibition to include school turf, but clopyralid products will continue to be used on golf courses and certain other forms of nonresidential turf, as well as farm, ranch, and forestry uses.
Clopyralid causes environmental and property damage through drift, runoff, use of treated plant material (such as straw or grass clippings) for mulch or compost, contaminated irrigation water, and urine or manure from animals consuming treated vegetation. Clopyralid is “considered volatile,” according to EPA, meaning that it can evaporate from foliage and soil after application, move away from the application site, and “adversely affect nontarget broadleaf plants.” EPA calculated that volatilization of only one percent of applied clopyralid would be enough to damage nontarget plants.
Clopyralid can cause damage to sensitive plants at levels of 10 parts per billion. It is not broken down in composting facilities, and composters are very concerned about carry-over of clopyralid and other persistent herbicides, such as aminopyralid, aminocyclopyrachlor, and picloram into compostable materials. Clopyralid can enter the composting facility through lawn clippings, hay, straw, crop residues, and manure. Compost facilities now test for residues of persistent herbicides, but such tests are time-intensive and expensive.
In November 2002, the registration of clopyralid for use on residential lawns was voluntarily cancelled by the registrant, Dow AgroSciences. However, compost feedstocks are contaminated by other uses that are still allowed. Residues from any of these uses may find their way to composting facilities. Grass clippings, hay, and straw may also be used as mulch, allowing direct transfer of the herbicide to susceptible plants.
The contaminated mulch and compost may be used by homeowners, landscapers, or organic farmers. In the case of homeowners, it can mean the loss of expensive plantings. Landscapers may be liable for damages. In the case of organic farmers, it can mean the loss of a crop and possibly the loss of organic certification.
Clopyralid is not metabolized by animals, but passes through in urine and feces. Thus, farmers and composters are advised to avoid manure from animals that may have eaten hay or feed that may be contaminated with it or other persistent herbicides. EPA proposes label amendments to mitigate these problems. If these label restrictions are followed, they may minimize the spread of clopyralid residues into sensitive areas. Doing so, however, reduces the availability of organic nutrients for crops and compost makers, thus burdening organic farmers and composters. This places undue burdens on those who do not benefit from the use of the herbicide and makes agriculture less sustainable. Instead, registrations of clopyralid and other persistent herbicides should be cancelled.
All herbicides, especially those targeting broadleaved plants, pose the risk of removing plants that provide food and habitat for pollinators. Some of those pollinators may be threatened or endangered species. As EPA admits, it has not evaluated risks to threatened and endangered species. Nor has it completed endocrine disruption evaluation. Since both of these are very sensitive consequences—that may result from much lower exposures than those evaluated thus far—reregistration must not proceed until those evaluations—including consultation with U.S. Fish and Wildlife Service and National Marine Fisheries Service—are complete.Â
Although EPA downplays them, clopyralid does present human health risks. Clopyralid is classified by EPA in acute toxicity class III as slightly toxic. Laboratory studies have shown that clopyralid is a severe eye irritant and dermal irritation has also been noted which can lead to skin sensitization for prolonged skin exposures. Some developmental and reproductive effects have been observed in laboratory animals. The livers and kidneys of rats as well as the livers of dogs were affected by changes in weight and decreased red blood cell counts. Another study found that weights of rabbit fetuses decreased at both low and high doses of clopyralid. Skeletal abnormalities were also observed in these fetuses at all doses. Clopyralid products also contain toxic contaminants and “inert†or “other†ingredients.
Resistance to herbicides is an expected consequence of their use, so any perceived benefit of using an herbicide must be discounted by its reduced lifespan as an effective weed control. There are currently 514 unique cases (combinations of species and sites of action) of herbicide resistant weeds globally, with 262 species (152 dicots and 110 monocots). Weeds have evolved resistance to 23 of the 26 known herbicide sites of action and to 167 different herbicides. Herbicide resistant weeds have been reported in 93 crops in 70 countries. Resistance to clopyralid is known in four species, and resistance to other synthetic auxins has been documented in other species.Â
The growth of organic agriculture demonstrates the viability of nontoxic alternatives in agriculture. Nonorganic producers are looking to organic practices for help in dealing with the problem of herbicide resistance. In turf systems, managers are increasingly successful using organic systems, often mandated by local ordinances.
The use of clopyralid poses risks to human health, property, and the environment that are borne mostly by those who do not receive any benefit from the use of the herbicide. The risks are not outweighed by benefits, so the registration of clopyralid should be cancelled.
Please see Beyond Pesticides comments for more details and citations.
Thank you for your consideration of these comments.                                                                                           Â
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This is devastating peoples gardens and harvests!
July 6th, 2020 at 4:08 pmplease let me know how to help to get these herbicides restricted or banned
July 1st, 2022 at 12:26 pm