"When one tugs at a single thing in nature, he finds it attached to the rest of the world." --John Muir

"A thing is right when it tends to preserve the integrity, stability and beauty of the biotic community. It is wrong when it tends otherwise." --Aldo Leopoldt

"The idea of a 'safe' amount of a carcinogen is a fallacy." --Ruth Shearer, M.D., molecular geneticist

"If the Bill of Rights contains no guarantee that a citizen shall be secure against lethal poisons distributed whether by private individuals or by public officials, it is surely only because our forefathers, despite their considerable wisdom and foresight, could conceive of no such problem." --Rachel Carson

"The BLM's belief ['belief' italicized in original statement] that its herbicides are safe does not relieve it from discussing the possibility that they are not, when its own experts admit that there is substantial uncertainty. When uncertainty exists, it must be exposed." --Ninth Circuit Court in Southern Oregon Citizens Against Toxic Sprays (SOCATS) v. Clark, 1983.

"Fewer than 10% of the approximately 70,000 chemicals now in commercial use have been tested for their possible adverse effects on the nervous system and only a handful have been evaluated thoroughly, according to the National Research Council." --from Bodies In Protest: Environmental Illness and The Struggle Over Medical Knowledge, by Steve Kroll-Smith and H. Hugh Floyd, New York University Press, New York, 1997.

In 1948, some of the first experiments with phenoxy herbicides in forest management were conducted by the U.S. Forest Service and Oregon State College on land in the Siuslaw National Forest. These experiments showed widespread drift of aerially applied herbicides and researchers noted substantial damage to crop trees at all concentrations of the herbicide 2,4-D.¹ Military development of herbicides continued. By the mid 1950s, the United States Department of Agriculture (of which the Forest Service a part) was involved in Army chemical and biological warfare research.2

In the early 1960s, the U.S. Air Force had began to spray Agent Orange to defoliate the Vietnamese jungle. The most widely used defoliant in Vietnam, Agent Orange, was a 50/50 mixture of 2,4-D and 2,4,5-T -- the same mixture most commonly used as a forestry herbicide in the U.S.³ Between 1961 and 1971, the US sprayed enough herbicide to cover 30,305 square miles (equal to 23.8% of the total area of Vietnam) in one spraying. Since the 1970s, hundreds of thousands of acres on Forest Service, Bureau of Land Management, State of Oregon, and private lands have been sprayed with herbicides and pesticides, most of it aerial spraying.4

Many of the chemicals used -- including Agent Orange-have been extremely toxic to wildlife and humans.⁵ After a series of lawsuits and public expressions of concern in the 1970s, mulches and other manual methods began to be used on federal forestlands; unfortunately, private and state foresters continue to spray forests with harmful chemicals. Chemicals are used on forests for commercial reasons: to prepare a site to be a tree farm before it is clearcut, and to control competing vegetation before it is reforested with seedlings. (Insecticides are also used sometimes to control unwanted insects, such as the Western spruce budworm.)

The Oregon Department of Forestry's Pacific Northwest Weed Control Handbook unequivocally states: "Undesirable woody and herbaceous plants are problems in commercial forests. In a typical old-growth forest, many species of trees, plants and wildlife co-exist."⁶ But on tree farms, seedlings are considered crops, and just one species, like the Douglas fir, is planted for commercial production. "Weeds" such as ferns, blackberry, scotch broom, even alder and willow trees are destroyed so that one species, such as Douglas fir, can be planted, and not have to compete with other vegetation for space, sunlight, moisture and soil nutrients.

According to Craig Thomas of Friends Aware of Wildlife Needs (FWN), the use of herbicides is primarily for shortening the log rotation cycle. Without herbicides, harvest rotation may be between 110-150 years. With treatment, the rotation is cut to approximately 75 years. Yet tree farming is still forestry. An important principle of ecological forestry is the importance of maintaining biodiversity. Pesticides destroy the ecological balance and diversity of native forests.⁷

Soil is a complex, dynamic, living "organ" of the ecosystem whose importance to forest health and productivity is crucial. Soil organic matter is not only a reservoir of nutrients, it is an energy source for soil microbes and animals and provides the structure that gives soil good water-retention characteristics and adequate aeration. Soil has much more than an immediate influence on tree growth. It is the connecting link between a forest that can be destroyed by harvest or natural processes (e.g., fire). One forester has remarked that 15 years after clearcutting, the brush is dominated by trees. "In a number of clearcuts done in the 1970s," he said, "the brush came back and these sites were considered unsuccessful. But I walked some of these sites and many are thoroughly stocked [with trees]."⁸

The U.S. Forest Service writes, in a brochure handed out to the public, that, "Tree branches and logs found on the forest floor were once viewed as "waste wood." But now we know they have several valuable purposes. They cycle nutrients back into forest ecosystems, serve as water reservoirs, shelter tree seedlings, and give animals homes. In short, the right amount of logs and woody debris help the next forest community get started."⁹

So why do foresters clearcut? Why spray the area so that the woody debris is poisoned, impoverishing the soil? Pesticides and herbicides are poisons. Most are intended to kill by interfering with biochemical processes essential for life. Nor do they selectively kill one or a few unwanted life forms. To the extent that these basic life processes (e.g., respiration, DNA, synthesis, transmission of nerve impulses) are shared by many forms of life, pesticides are life poisons. Some pesticides are very toxic to particular group of organisms because of a chemical or structural feature or behavior peculiar to those organisms.¹⁰

Only a tiny percentage of applied pesticides actually reach the targeted pest. It's been estimated that as little as .03 percent of insecticides and fungicides reach the pest and slightly more than that for herbicides.¹¹

When routine spraying of forests west of the Cascades began in the early 1970s, a growing number of rural residents -- who sometimes lived miles from the sprayed trees -- experienced a range of inexplicable ailments, including: respiratory ailments, convulsions, skin rashes and sores, chest pains, miscarriages, hemorrhaging, even cancer. A disturbing number of babies were born with birth defects. Some family pets and livestock died; others were unable to produce healthy offspring.

Complaints to elected officials and the Oregon State Department of Forestry, Forest Service and BLM about the damaging effects of herbicides, and pesticides sprayed -- in water irrigation districts and forests -- were typically met with disbelief. "We're sure that the pesticides we use don't cause problems," officials said. "They've all been approved by the Environmental Protection Agency."¹²

In 1947, the U.S. pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) was enacted. It was not intended to protect human or environmental health. It was a product reliability law designed to assure farmers that pesticides would actually perform as manufacturers claimed, and that they were not acutely toxic.¹³

In 1972, FIFRA was amended and, for the first time, required chronic toxicity and environmental concerns to be included in registration. In addition to registering new pesticides, the EPA was to "reregister" the 50,000 products that were already on the market.¹⁴

The new FIFRA amendments required that the EPA register pesticides if they do not pose "unreasonable risks to man or the environment, taking into account the economic, social and environmental costs and benefits of the use of any pesticide."¹⁵ In other words, if a pesticide offers enough economic benefits, it can be registered, no matter how hazardous or potentially hazardous. The risks are born primarily by animals, plants, micro-organisms and humans who are exposed to the chemical.

However, there is no satisfactory way to weigh the costs of millions of dead birds, or children born with birth defects, against the profit margins of chemical manufacturing companies. While the registration process is cumbersome and extremely expensive, it misses or ignores many important effects. Pesticides are registered while important health and safety data are still being generated; reevaluations of old pesticides -- mandated by laws passed in the 1970s -- are still incomplete. Pesticides may continue to be used after evidence of their hazards is given to the EPA.¹⁶

Even now, little progress has been made in reregistering pesticides. In addition to the new pesticides that come on the market annually -- which are not subject to the reregistration process -- EPA can allow "conditional registration" of new pesticide products, even though health and safety tests are missing. Requiring completion of all the tests, EPA contends, would put new products at an economic disadvantage to older pesticides. Reregistration does not mean that a pesticide is "safe" in the usual meaning of the word.

Even though a large number of tests are required, registration leaves many important questions about pesticide hazards unanswered. For example, most chronic toxicity testing required for EPA registration is done on the active ingredient only. The "inert" ingredients, added to the pesticide to make it more potent or easier to use, are not necessarily chemically or toxicologically inactive, but are usually claimed as trade secrets. Recently, NCAP won a major court victory, requiring that so called "inert" ingredients in pesticide be studied for their toxicity and made public.

Another serious flaw in the federal registration process is that the EPA requires testing for effects that have already been identified as problems, but misses potential new problems. For example, tests for cancer, genetic damage and effects on reproduction were not required until the 1960s and 1970s, after these problems had been documented in pesticides first used in the 1940s and 1950s. Tests for the potential to contaminate ground and surface water were very limited until after such contamination was widespread.¹⁷

No tests are required to determine if pesticides affect plant reproduction; under the Food Quality Protection Act, pesticides are required to be tested for their ability to disrupt the normal functioning or hormone systems (endocrine disruption). However, protocols are just beginning to be developed and it will be years before testing is completed.¹⁸ Also, no tests of the effects of a pesticide on sperm production are required, although effects on male reproduction have been documented for over 60 currently used pesticides. (A study of otters in the Columbia River Basin found that young otters exposed to environmental pesticides had sex organs half the normal size.19

While science, industry and government continue to ignore or dismiss the growing anecdotal and scientific evidence of herbicide effects on exposed populations, they continue to make decisions based on laboratory data known to be invalid. Pesticide chemicals are presumed innocent until dramatic evidence of human harm proves otherwise. Yet, it is virtually impossible for laboratory studies -- upon which scientists base their conclusions -- to exactly reproduce the conditions under which humans and animals are exposed to a chemical or number of chemicals, particularly when symptoms in an illness such as cancer are delayed for years.

Cheating on the chemical tests

Though the chemical industry has succeeded in perpetuating a scientific tradition that requires unequivocal proof of cause and effect in its experimental methods, testing fraud is common. For example, in 1983, three toxicologists were convicted of mail fraud after faking toxicity studies of drugs and pesticides.²⁰ These three were top officials at Industrial-Biotest Laboratories, one of the largest and oldest of the independent testing laboratories that conduct toxicity tests for pesticide manufacturers.21 How many other tests have been falsified or distorted in order to get approval for the use of dangerous pesticides?

An EPA review showed that over 800 significant toxicity tests for 140 pesticides had been done by IBT.²² EPA then began an audit program to help ensure that this kind of situation would not occur again. Yet, in 1994, Craven Laboratories was fined over $15 million and its president sentenced to five years in jail for falsifying residue data.23

There are more loopholes in the pesticide registration law. Section 5 of FIFRA allows EPA to issue experimental use permits for new, unregistered pesticides. Another section specifies several alternative registration processes that allow a pesticide to bypass most of FIFRA's standard registration requirements. Section 18 authorized exemptions from any provisions of FIFRA "if emergency conditions exist." Section 24(c) authorizes a state to register additional (not federally registered) uses of a pesticide to meet "special local needs." What about the health needs of people and wildlife in local communities?

California, Oregon and Washington, frequently use emergency exemptions.²⁴ Also, a lengthy regulatory process called 'Special Review' provides another loophole for hazardous pesticides. Special Reviews are initiated when EFA has data to show that the use of a pesticide is causing unreasonable damage.

During Special Review, the pesticide continues to be sold and used while EPA conducts a risk/benefit analysis and explores possibilities for "risk reduction" measures. The average Special Review takes over seven years to complete!²⁵

Oregon Forest Practices safeguards lacking

Meanwhile, the hazards of pesticide use continue. Over and over again, the registration process has not been protective of human or environmental health. In Oregon, forest activity on industrial and private forest lands is regulated by the Oregon Forest Practices Act. Sprayers file notifications for a particular amount of acres, but since the Oregon Department of Forestry (ODF) doesn't require them to account for total acreage sprayed, additional areas might be sprayed. Sprayers are not required to report the amounts and types of chemicals used during an operation, only general information about what they intend to use is requested by ODF.

The Oregon Forest Practices Act states that the ODF must apply for permits to harvest, spray, thin trees, or build roads. Under the Act, a private landowner is required to maintain equipment in a leak-proof condition; protect streams and areas of open water; make sure spray stays the appropriate distance from inhabited dwellings; apply chemicals in accordance with temperature, humidity and wind factors; ensure that daily chemical application records are kept by the landowner and the landowner complies with the necessary waiting periods required before an operation begins.

Further, the Forest Practices Act requires landowners to provide copies of chemical application notices to certain individuals. Holders of valid, filed surface water rights will be provided free copies of notifications for all chemical operations within ten upstream miles, but only if a request for the service is submitted to the department in writing. In addition, any citizen may request copies of notices for all forest operations within a geographic area of interest by paying a subscription fee to cover copying expenses.²⁶

Neighbors must subscribe (for a fee) to ODF data operations in order to receive notification of spraying by mail. Why must people pay to find out when they are being poisoned? Drinking water for many Oregon communities originates on forest lands. But these water sources are not adequately protected from spray residues.

Unintended consequences of chemical spraying

Because drift is nearly unavoidable with aerial spraying and because pesticides move through the watershed, buffers are required by law, depending on stream size. A large, fish-bearing stream requires a sixty-foot buffer for aerial spraying; for hand application, there is only a ten-foot buffer.

There is a civil penalty process for leaving less of a buffer while spraying pesticides. The first violation is a $1000 fine, and increases with each violation. In 1997, the state legislature passed a law to increase the amount with each offense; beyond a yet unidentified number of offenses, offenders cannot operate in the state anymore.²⁷

Private foresters are not required to monitor levels of the chemical left in the soil or water after spraying. The ODF monitoring crew collects a 24-hour water collection on about 15 sites, which amounts to spot checking of thousands of operations. One Forestry Practices Operations Analyst said that industry claims if they themselves did the monitoring, people wouldn't believe the results. Private foresters say that since they pay a timber harvest tax -- which partially funds the ODF -- they're already paying for such service.

Citizen action has strengthened pesticide rules

The laws we have in place -- though inadequate -- are due largely to the efforts of citizen activists and the lawsuits by groups such as Northwest Coalition Against Pesticides (NCAP), Southern Oregon Citizens Against Toxic Sprays (SOCATS), Save Our ecoSystems (SOS) and Oregon Environmental Council.

In just one nine-month period in 1983-84, for example, Northwest federal courts issued six decisions finding federal agency programs in violation of laws that ensure sensible, reasoned decisions on spraying by public officials.²⁸ Courts clearly stated that irreparable harm to the environment must be presumed when the National Environmental Policy Act (NEPA) is violated. Citizens' groups have been successful in obtaining court injunctions and suspensions against spraying on many federal lands in Oregon, and have alerted the public to health hazards of many herbicides and pesticides. However, spraying continues on state and private lands.

In 1979, when the EPA put in an emergency suspension of 2,4,5-T (a form of dioxin), the Forest Service merely substituted 2,4-D and picloram in its Siuslaw National Forest spraying applications. A court injunction banned the use of herbicides in federal lands in Oregon and Washington in 1984. But in 1989, a mediated agreement was reached which stated that herbicides could be used as a "last choice" alternative on Forest Service lands, when other methods were not effective or costs were unreasonable.²⁹ Chemical herbicides spraying is still prohibited on BLM lands in Oregon.

Clearcutting and the spraying of pesticides and herbicides are clearly linked to damage of forests and their watersheds. OLIFE is sponsoring a citizens' initiative, for November 1998, to ban clearcutting and herbicide and pesticide use on all of Oregon's forestlands. The campaign promotes non-toxic weed and pest controls to protect humans, wildlife and fish. This would maintain clean water, preserve the genetic diversity of native plants, and continue the economic opportunities forests have provided for hundreds of years to Northwest communities. Those who dismiss activists as simply alarmists or tree-huggers ought to note that the 1997-98 General Assembly of the State of Vermont imposed a moratorium on the aerial or other broadcast application of herbicides in order to protect the public's health.

Though the use of chemicals is subject to change, most brush and "weed-tree" control in forests is done with 2,4-D, glyphosate, imazapyr, picloram or triclopyr. Atrazine, pronamide, 2,4-D, sulfometron and hexazinone are used to control herbaceous weeds in tree plantations.³⁰ Below are descriptions of the chemicals currently used in the Northwest forests and their registration status:

1. 2,4-D (not re-registered): -- 2,4-D is one of the two chemicals comprising Agent Orange (the other is 2,4,5-T, banned in 1979). A study of the health effect of phenoxyherbicides, begun in 1963, but not released until 1969, showed 2,4-D capable of causing birth defects at doses lower than lethal amounts.31 A recent study by the National Cancer Institute and University of Kansas linking exposure to herbicides with non-Hodgkins lymphoma and lymphatic cancers points up 2,4-D as a cause of cancer.32

2. Picloram: -- EPA completed its Reregistration Eligibility Decision (RED), despite comments from scientists like the following: "Due to the extreme phytotoxicity, its persistence under typical environmental conditions, and its extreme propensity to leach into groundwater in all soil types, the Ecological Effects Branch (of the EPA) is strongly recommending against the reregistration of all active ingredients of Picloram."33 Picloram, one of the most persistent herbicides known, is considered by biologist Dr. Arthur Galston of Yale University to be "a herbicidal analogue of DDT."34

3. Pronamide (re-registered March 1994): -- An herbicide used either before weeds emerge (pre-emergence) and/or after weeds come up (post-emergence). Pronamide is classified by the EPA as a slightly poisonous chemical. Pronamide has been found to be oncogenic -- causing tumors -- in male mice and has been tentatively classified as a Group C oncogen (possible human carcinogen), pending consideration of additional data. Pronamide is practically non-toxic to birds, mammals and fish, and possibly as much as moderately toxic to aquatic invertebrates.35

4. Imazapyr (not re-registered): -- An herbicide -- its primary uses in the U.S. are for vegetation control in forests and rights-of-way. Imazapyr can persist in soil for over a year. Studies suggest that imazapyr residues damage plants at concentrations that are not detectable by laboratory analysis. Imazapyr has contaminated surface and ground water following aerial and ground forestry applications. Ozone degradation, a treatment used to remove pesticides from drinking water, is not successful with imazapyr, removing only about half the imazapyr present.36

5. Sulfometuron Methyl (not reregistered): -- this is a "potent inhibitor of plant root and shoot growth."37 Marketed as Oust, it has both acute and chronic toxicity to animals. In laboratory animals, it has caused eye and skin irritation and anemia and has also reduced fertility of both males and females. As an herbicide, Oust has the potential to have a substantial direct impact on the diversity of plant species in a treated area. A study of Florida slash pine forests showed that annual applications of Oust, together with other broad spectrum herbicides, caused a "dramatic shift" in the distribution and diversity of plants.38 The significance of this research is perhaps best illustrated by the U.S. Fish and Wildlife's list of 25 plants in 13 states (including Oregon) jeopardized by the use of Oust along right-of-ways. Because of the limited populations of many of these plant species, a local spraying program could virtually destroy the entire species.39

6. Hexazinone (Reregistered September 1994): -- Residues have been detected in surface waters in treated watersheds long after application -- even a year later. According to one researcher, hexazinone has affected vegetation beyond the site of application because of its mobility in soils and surface run-off. This herbicide, therefore, has the potential to affect stream-side vegetation and possibly destroy important salmon habitat."40

7. Triclopyr (not reregistered): -- this phenoxyherbicde (phenoxy herbicides damage mainly broadleaf plants) differs from 2,3,5-T by one atom. Triclopyr is a slight eye irritant, placing in Toxicity Category III (Caution) in the EPA's classification system.41 There are no publicly available chronic toxicity tests of triclopyr products as they are used, only tests on triclopyr itself. These tests have revealed indications of organ damage, possible reproductive and cancer-causing effects and genetic damage.42 Many of the "inert" ingredients in triclopyr products are called trade secrets by it's manufacturer, Dow Elanco. But kerosene, a skin irritant and element that may adversely affect the central nervous system, is known to be present in one triclopyr product; diesel oil, highly toxic to freshwater fish, is present in other formulations.43 Very few of the toxicology studies about triclopyr have been done by independent researchers; therefore, it's difficult to obtain a clear assessment its dangers.

8. Glysophate (Reregistered September 1993): -- Glyphosate-containing products are acutely toxic to animals, including humans, having caused eye and skin irritation, cardiac depression, vomiting, diarrhea; and thyroid, pancreas and liver tumors. In laboratory tests, glyphosate has caused reduced sperm counts in male rats, a lengthened estrous cycle in female rats, and an increase in fetal loss, together with a decrease in birth weights in offspring.44 In large amounts, Glyphosate is acutely toxic to birds, because glyphosate kills plants and changes the structure of the plant community. This can affect bird populations, since the birds depend on the plants for food and shelter.45

9. Atrazine (not re-registered): -- has been widely used in the U.S. since 1958 and is one of the most commonly found contaminants of water. It is classified as a possible human carcinogen, based on the increased incidence of mammary tumors in female rates. Chronic toxicity tests have demonstrated diminished weight gain, increased irritability and probably anemia in rats. Chronic feeding studies in dogs demonstrated increased mortality, decreased food consumption and weight gain. Tests of atrazine's ability to cause cancer in rats using technical atrazine (the active ingredient only, not formulated products), found dose-related breast tumors in females, tumors in the testicles of males and an increase in the cancer of the uterus.46

In the Fall of 1997, the Northwest Coalition for Alternatives to Pesticides issued a report citing scientific studies that link pesticides with hormone-related disorders, such as male infertility and breast cancer. It drew largely upon a 1996 U.S. Geological Survey study that discovered 48 pesticides at 40 sites tested in the Willamette River basin. The report found that 10 of the 25 most commonly found pesticides in the Willamette River -- which serves as recreation and drinking water for many communities -- are those that have been associated with possible disruption of the hormone system. The chemicals are found in relatively small doses in the river, but repeated exposure over the long term can be harmful.47 As more research is done on chemical pollution in the Willamette River, both citizens and public officials are demanding action to curb sources of the pollution.

Alternative weed and pest controls

When foresters want to practice "weed control management," there are alternatives to herbicides.⁴⁸ Strong reliance on manual cutting continues, though it is seen as more costly and time-consuming. Mulching is another method, as are grubbing and the judicious use of fire. Successful prescribed burning requires an understanding of forest ecosystem dynamics, as plants in the Pacific Northwest forests have evolved to survive the natural fires that occurred in their habitats.

According to one silviculturist employed by the Waldport Ranger District in the Siuslaw National Forest, the change from chemical to manual methods has not resulted in significant changes in growth and survival of seedlings. Before the legal judgment against the Forest Service in 1985, the Siuslaw National Forest had chemically treated an average of 5,150 acres each year. Analysis of 3-year data collected from staked rows of conifers indicates that the survival rate prior to 1984 was 81%. After 1984, when manual methods were more uniformly adopted, it was 86%. Analysis of data from a reforestation survey showed that 5-year height growth was 6.4 feet prior to 1984; and 6.2 feet after 1984.⁴⁹

In addition, the impact of manual weed control on wildlife has been beneficial; discontinuing use of chemicals has resulted in more rapid recovery of vegetation, thus providing more cover and forage. And discontinuing the use of herbicides resulted in an increase in contracts, thereby creating new jobs for unskilled labor and a wider distribution of money. Wages from these jobs tended to go into more hands and more communities than formerly. The loss of herbicides on the Siuslaw National Forest has been far less traumatic than anyone expected. "This loss," says Edmund Obermeyer, "required us to look at new alternatives in vegetation management that would otherwise have taken years to develop or may never have been developed at all."⁵⁰

Forests are more than just trees. They are complex systems with many critically important components, from the micro-fungi and lichens to forest insects, birds and mammals. Forests provide many important "ecological services," such as regulating climate, protecting aquatic ecosystems in streams and rivers and providing fish and wildlife habitat. Chemical poisons such as chemical pesticides and herbicides are neither desirable, nor necessary, for forest management.

What you can do

1. Northwest Coalition for Alternatives to Pesticides (NCAP) offers publications about pesticides. NCAP also publishes a packet: "Spray and Sampling Guidelines: What To Do If You Are Sprayed."
2. Let individual timber companies, city and county vegetation management agencies, BLM, Forest Service and State Department of Forestry know of your concerns about pesticides and questions about chemical pesticides.
3. Registered Oregon voters can sign and circulate OLIFE's statewide citizen initiative petition (for the November 1998 ballot) to prohibit clearcut logging and chemical spraying on Oregon's forestlands. Bring additional petitions to work, school, your neighborhood, etc., before June 20, 1998.
4. Pesticides and their alternatives need to be openly debated. Bring up the topic with friends, neighbors, medical practitioners, newspaper editors, etc.

References and notes

Copyright © 1997-98 OLIFE -- Oregonians for Labor Intensive Forest Economics.
All rights reserved.