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Page 4
However, significant facts are omitted in the State Department's claims. These facts may help to explain the adverse effects reported so widely in Colombia.
1. The scientific review article cited by the State Department as justification for the spray campaigns assesses the hazards from "present and expected conditions of use" of glyphosate herbicides. 31 However, the term "present and expected conditions of use" implies adherence to the manufacturer's recommendations. For example, the Manufacturer's label for Roundup Ultra warns against applying the herbicide "in a way that will contact workers or other persons, either directly or through drift." The label also calls for the removal of livestock prior to spraying and waiting periods of 2 to 8 weeks before harvesting crops or using sprayed areas for grazing. The label warns against contact of the "herbicide with foliage, green stems, exposed non-woody roots or fruit of crops...desirable plants and trees, because severe injury or destruction may result." 32 These conditions are not met in Colombia, where airplanes apply herbicides over acres at a time with no prior warning to land owners. In the U.S., such failure to follow the label instructions would be a violation of Federal law. 33
2. Even assuming application according to U.S.-approved label instructions, the label and product safety information make it clear that spraying with Roundup Ultra can cause: 34
- skin and eye irritation in people who are sprayed directly or contaminated by drift, or who come into contact with sprayed crops immediately after crop dusting;
- illness and gastrointestinal irritation in people or animals if they ingest large quantities of the crops or other contaminated materials shortly after spraying;
- fish kills and ecological harm to aquatic ecosystems that are contaminated or sprayed; and
- death of non-target plants, and associated environmental damage.
3. The State Department defense of the herbicide spraying focuses on the active ingredient, glyphosate. However, 14.5% of Roundup Ultra is a surfactant. (The manufacturer describes the surfactant as "a phosphate ester neutralized polyethoxylated tallowamine mixture," 35 but has not disclosed its precise identity.) Surfactants can be a significant source of toxicity of glyphosate herbicides. For example, a Japanese study of attempted and successful suicides through ingestion of Roundup herbicide concluded that the surfactant was probably the main cause of Roundup's toxic effects. 36
4. The label for Roundup Ultra warns that "this is an end-use product. Monsanto does not intend and has not registered it for reformulation." 37 Yet in Colombia at least one other additive-an additional surfactant known by the brand name Cosmo-Flux 411F-is added to the chemical mix. 38 Since neither the U.S. nor the Colombian government has made available any studies on these additives' effects, alone or in combination with Roundup Ultra, there is no basis for assuming that these products are safe when sprayed in the vicinity of rural populations, their food crops and water sources. In June 2001, the British chemical company ICI, manufacturer of one ingredient of Cosmo-Flux, refused permission for its use in the spraying program, responding to concerns about health effects from this unintended use of its product. 39
5. The herbicides used against coca crops in Colombia are both more concentrated and applied in greater doses than the maximum levels recommended by the manufacturer on the U.S. EPA-approved label. Sources in both the U.S. and Colombia indicate that the spray mixture contains 44% by volume of the commercial herbicide. 40 In contrast, the U.S. label for Roundup Ultra allows concentrations of 1.6% to 7.7%.41 In addition, the EPA-approved label states that in most situations aerial application should not exceed 1 quart per acre of the formulated product; 42 in Colombia, the rate is almost 4 1/2 times that amount. 43
6. In addition to hazards from oral and dermal exposure to the chemical mix, aerial spraying over residential and farming land creates conditions for inhalation exposure. 44 Laboratory studies suggest that inhalation of Roundup can be significantly more dangerous than ingestion of the same formulations. In one study, the exposure level required to kill 100% of the test animals through inhalation was just 4% that required to kill 100% of the test animals through ingestion. 45 Therefore, the tests and studies cited as justification for the spray campaigns may significantly underestimate the severity of likely health effects, both for people and for animals.
Summary
In sum, the herbicides being sprayed over Colombia are a chemical mixture that has never been tested. They are being sprayed in concentrations in excess of the manufacturer's recommendations, in combination with other additives not approved for use in the U.S., and, in many if not all cases, with methods that would be illegal in the U.S.
31 Gary M. Williams et al., "Safety Evaluation and Risk Assessment of the Herbicide Roundup and its Active Ingredient, Glyphosate, for Humans," Regulatory Toxicology and Pharmacology 31, (2000) pp. 117-165.
32 Roundup Ultra sample label, 1999. (current as of January 13, 1999), available at http://www.cdms.net/ldat/ld178005.pdf (visited March 12, 2002).
33 Roundup Ultra sample label, 1999.
34 Roundup Ultra sample label.
35 Monsanto company website, "Information About Roundup Ultra TM Ingredients," Available at http://www.monsanto.com/monsanto/media/backgrounders/00mar22_ultra.html, visited January 31, 2002.
36 Sawada, Y., et al., " Probable toxicity of surface-active agent in commercial herbicide containing glyphosate," The Lancet 1:8580 (1988), p. 299.
37 Roundup Ultra sample label, 1999.
38 U.S. State Department, written answer to questions from U.S. Representative McGovern Op. Cit. Also see Eduardo Cifuentes Muñoz, Colombian Human Rights Ombudsman, Letter to Rómulo González Trujillo, Colombian Minister of Justice (July 12, 2001).
39 Antony Barnett and Solomon Hughes, "ICI pulls out of cocaine war," The Observer (July 1, 2001).
40 U.S. State Department, written answer to questions from U.S. Representative McGovern Op. Cit. See also Narcotics Division of the Colombian National Police. "Dosis De Aplicación y Composición de la Mezcla Utilizada Según Tipo de Cultivo" (table provided to members of the Colombian Congress, reproduced in Anna Cederstav, "Rejoinder to the State Department's Nariño Study," http://www.usfumigation.org, visited March 1, 2002.)
41 Roundup Ultra sample label, 1999, p.3. Section 7.1. (The label calls for mixing one quart of herbicide with 3 to 15 gallons of water "unless otherwise specified in this label." None of the exceptions appear to apply to the wide ranging, aerial spraying of coca crops as carried out in Colombia.)
42 Ibid.
43 U.S. State Department, written answer to questions from U.S. Representative McGovern Op. Cit. See also Narcotics Division of the Colombian National Police. Op. Cit.
44 Linda Farley, Pesticides and Birds Campaign, American Bird Conservancy, "The Environmental Effects of Glyphosate, "Roundup" on Colombian Ecosystems," (November 20, 2000), available at http://www.usfumigation.org/NovPressConfSpeakers/LindaFarley/LindaFarley.htm (visited November 7, 2001).
45 T.T. Martinez, W.C. Long, and R. Hiller, "Comparison of the Toxicology of the Herbicide Roundup by Oral and Pulmonary Routes of Exposure," Proc. West. Pharmacol. Soc. 33 (1990), pp. 193-197.