This is vital data for anyone living in the areas where the California Department of Food and Agriculture (CDFA) intends to use twist ties in their unwarranted ‘eradication’ of the harmless bug known as the light brown apple moth, or LBAM.

It was announced today that a second moth has been found in Sonoma County out near the end of Arnold Drive in Sonoma. This is one of California’s most desert-like regions of alcohol industry sprawl with nothing but vineyards as far as the eye can see. CDFA intends to carry out their twist tie program in Sonoma County, and I believe in Santa Barbara as well. It is likely that these twist ties will be used in many of the ten counties in addition to the aerial spraying of pesticides.

What is the plan?

CDFA intends to place 250 toxic twist ties per acre anywhere that the LBAM is found. 250! They will be placed in trees - the habitat of birds, squirrels, and the playing grounds of children and cats. Anything that climbs trees or perches in them will be in serious danger.

It is the intention of the CDFA to put as many as 30-40 twist ties on private household property wherever they find the moth. They can come onto your private land, without your permission, and festoon your trees with toxic twist ties.

What’s on the twist ties?

The twist ties are coated with a pheromone pesticide called Isomate-LBAM PLUS. The ingredients are similar to the aerial spray compound. Here is the Material Safety Data Sheet for this product. Bearing in mind that Material Safety Data Sheets are prepared by pesticide manufacturers and therefore not very trustworthy, here are several salient points to notice on the data sheet:

1) 33.48% of the ingredients in the twist ties are secret. They do not have to be disclosed to the public because of laws which protect trade secrets rather than public health.

2) The product is being listed as harmful if absorbed through skin and dangerous to the eyes. People exposed to the product are instructed to contact a poison control center and go to a doctor.

3) You are supposed to bring the container for the toxic twist tie with you to the doctor. You will not have the container if you are poisoned by LBAM twist ties.

4) Because 33.48% of the ingredients on the twist ties are secret, your doctor will have no idea what you were poisoned by.

5) The MSDS says that this poison must not be applied to water or areas where water surface is present. In other words, you must not put it near creeks, ponds, coasts, reservoirs, rivers, or any other type of watershed. The sheet says do not contaminate water when disposing of this product. From this, we understand that Isomate-LBAM PLUS twist ties contaminate water.

6) This is an unregistered product that has been approved for use in California only. It has not gone through the normal battery of tests required of registered products.

How could you be exposed to the poisons in the twist ties?

Let’s look at a couple of quick scenarios illustrating how human beings will be exposed to poisons where thousands of these twist ties are polluting the trees.

Scenario 1
Your child or pet climbs a tree and begins playing with the twist ties. Suddenly, you notice this happening. In rescuing the victim, whose skin and eyes have now come into contact with this dangerous substance, you too are exposed to the chemicals. Now you have to make a choice. Are you going to handle the twist ties in order to bring one to your doctor or vet? You are not supposed to touch these toxic objects. What will you do?

Scenario 2
Most counties in California get a lot of rain every year. The rain will fall on the trees, washing the toxins down onto roofs, yards, and anyone who happens to be walking in the area. Once the poisonous ingredients are on the ground, they will leach into groundwater sources and run off into ditches, down street drains, into creeks, etc. The chemicals from thousands of twist ties (250 per acre) will be illegally introduced into the watershed in flagrant opposition to the warning on the product label. This is extremely dangerous.

Wildlife can’t read warning labels

While people living out in the populous Arnold Drive area of Sonoma may be able to read this article, our precious wildlife are being given no warning and no protection from exposure to Isomate-LBAM PLUS. How do you tell a family of deer not to sleep beneath the trees at night? How do you tell migratory birds not to roost in trees during their long flights north and south? How do you tell nesting birds not to use the twist ties as their nesting material? They will, you know. The scrub jays in my yard use everything they can find to build homes for their young. These twist ties will end up in birds’ nests. How do you tell inquisitive squirrels not to inspect and gnaw on these toxic twist ties? How do you tell our endangered frogs not to live in the creeks and ponds where CDFA has created a toxic chemical disaster?

The answer is, of course, that you cannot tell the birds, animals, and insects. I intend to begin looking into the Migratory Bird Act and the Endangered Species Act to see if there is any option available for protecting the world’s threatened wildlife from further chemical trespass.

It is also important to note that one of the ingredients in the twist ties, (E)-11-Tetradecen-l-yl Acetate, is a synthetic pheromone designed to disrupt the life cycle of the light brown apple moth. However, at least 13 other leaf-roller moths create the natural pheromone that this chemical is a mimic of. Therefore, we can expect these twist ties to adversely affect populations not only of the LBAM, but of many other equally harmless local moths. This is so unacceptable!

Last of all, I want to remind people that moths are a major food source for birds, bats, and frogs. Birds, bats, and frogs are crucial guardians of our environment. They consume billions of insects annually, keeping insect populations in proper balance. If you are afraid of mosquito-borne diseases like West Nile virus, birds, bats, and frogs are your best friends.

It is with absolute horror that I realized that the aerially-sprayed CheckMate was toxic to aquatic life and was responsible for killing hundreds of birds. These are the very creatures in the environment that prevent overpopulation of one insect or another. When the environment is healthy, an abundance of birds, bats, and frogs keep nature in excellent balance.

But what will happen to the birds, bats, and frogs who are eating the moths being affected by this chemical compound on the twist ties? The answer to that vital question is that nobody knows. No one has bothered to study what will happen to the food chain once acres of land have been blanketed in chemical twist ties. It seems like an obvious thing you’d worry about, but with their characteristic and criminally-negligent haste, CDFA has failed to offer any studies on this crucial subject.

Lack of testing and data is making it unclear to me exactly what will happen to the wild birds and animals who touch and consume these twist ties. However, there is one thing that is for certain. Animals who are unwell are immediately at greater risk for predation. For example, if a cedar waxwing like the one in my illustration were to get Isomate-LBAM PLUS in its eyes and because of this, it couldn’t see well (and obviously would not be able to wash its eyes), its ability to hide itself from predators, and protect its young will be severely lessened. It may risk death from starvation or exposure to the elements simply because it has been poisoned or harmed by the chemicals on the twist ties.

As a person whose life has been immeasurably enriched by tree-dwelling creatures like birds and squirrels, I urge you not to think of toxic twist ties as a good alternative to aerial spraying. Unfortunately, many people living in zones where only ground applications are being done are feeling relieved that no aerial spraying is set to happen. I urge you not to have a complacent attitude about these ground-based actions of CDFA’s, which will fill our environment with dangerous and unwarranted chemicals.

The bottom line is that the light brown apple moth has done zero damage to agriculture, and does only negligible cosmetic damage to leaves. It is not a threat to agriculture, native or ornamental plants. Everywhere else in the world that it lives, it is considered a forgettable bug.

We do not need to do a single thing about this moth. We do not need a single aerial application, or twist tie. We do not need stingless wasps or permethrin-coated telephone poles. Our environment is already laden with a burden of pesticides and synthetic chemicals that are causing epidemic illness in people and wildlife. We need to tell CDFA that we are already overrun with toxins. Their inexcusable, experimental chemical actions are not acceptable.

I urge you to get your local Audubon Society, environmental group, neighborhood, or any other community to which you belong to read the Material Safety Data Sheet for the toxic twist ties and to demand that CDFA not be allowed to poison your neighborhood with their unnecessary chemicals.

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