USDA EA Public Comment Period is Due NOW!
- San Jose to be sprayed with Bacillus thuringiensis kurstaki – BT [comments should be received no later than May 23, 2008]
- Sonoma will be subjected to contamination with toxic twist ties [comments should be received no later than May 30, 2008]
- Pescadero, California (June Treatment) [comment should be received no later than June 20, 2008]
The time to make your public comments as part of the Environmental Assessment is now.
Who to Contact:
U.S. Department of Agriculture
Animal and Plant Health Inspection Service
Plant Protection and Quarantine
Emergency and Domestic Programs Emergency Management
4700 River Road, Unit 134
ATTN: Carole Johnson
Riverdale, MD 20737Â–1236
Director, Emergency Management
Emergency and Domestic Programs
Animal Plant Health Inspection Service
U.S. Department of Agriculture
4700 River Rd. Unit 134
Riverdale, MD 20737
CC your comments to:
Vegan Reader’s Letter Regarding Toxic Twist Ties in Sonoma:
I am writing to take the opportunity of the call for public comments regarding the proposed treatment of Sonoma in California for the Light Brown Apple Moth.
I was very concerned, upon reading the proposal, that guarantees of human and environmental safety appear to be based on the concept that the twist ties will only be present for a given time and that they will then be removed. This is not a sensible argument for safety, as clearly, public concern hinges on the time during which the ties will be in use – not when they will be taken away.
I would like to list my concerns regarding the contamination of Sonoma with Isomate-LBAM Plus twist ties.
1) The twist ties are being placed in the habitat of wild birds, wildlife and children. Every day the twist ties are present in the environment is an opportunity for birds, wildlife and children to come in contact with them. To touch them, play with them, get the chemicals in their mouths and eyes.
2) According to the Material Safety Data Sheet for the twist ties, they are considered an eye and skin irritant, and contact with them requires calling Poison Control or a Doctor. Unfortunately, because 38% of the ingredients in which the twist ties are soaked are being kept a secret from the public, neither the doctor nor poison control will be able to accurately determine what a child, pet or wild animal has been exposed to, causing chemical injury and illness. This is clearly not safe and the lack of transparency regarding the chemical makeup of the twist ties displays a disturbing disregard for public or environmental health.
3) If a child, pet, wild bird or animal is poisoned or injured by the twist ties, the MSDS instructs the responsible party to present the product package to the doctor. Of course, residents and tourists in the twist tie zone will not have access to the packaging of the twist ties, so again, cause of chemical injury will be impossible for a physician, paramedic or vet to determine.
4) The MSDS says that the ingredients in Isomate-LBAM Plus twist ties 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. As you know, there are several creeks and important watershed sources in this area of Sonoma. CDFA would be violating the MSDS by applying these products where their chemicals will get into the watershed. Rain is an obvious vehicle for the chemicals on the twist ties getting into groundwater, creeks and other watershed bodies. Less obvious is the danger of the ties, themselves, being removed from trees by wild animals like inquisitive raccoons or birds. The ties may be dropped on the ground and, from there, directly into bodies of water. Again, CDFA is intending to violate the MSDS by placing 250 of these contaminating twist ties per acre in regions where water is present.
5) As a long-time birder and author of one of Sonoma County’s key birding publications, I feel it is imperative to add that I am seriously alarmed by a proposal which introduces toxins and irritants into wild bird habitat. Many of our wild bird populations have been cut in numbers by 50% or more over the past couple of decades due to chemical exposure and habitat loss. Trees, bushes and fences are vital life habitat for birds. It will be the nature of birds to investigate the twist ties which will festoon their breeding, perching and nesting areas. Certain species, like the Western Bluebird which lives in the quarantine zone and which is only just now beginning to recover from near-extinction due to DDT, are likely to view man-made materials in their habitat as potential nesting material. Diminished and endangered birds may pry the twist ties from their hangers and take them back to their nests, thus exposing vulnerable hatchlings to dangerous chemicals. Chemical injury is not merely a threat to the physical health of birds, but chemical injuries to the eyes also increase the likelihood of death by predation. A bird with burned, blurred or damaged eyes loses its ability to protect itself from predators, and of course, unlike human beings, wild birds cannot flush their eyes with water in an attempt to relieve pain or chemical injury. Introducing toxins like Isomate-LBAM plus will, in my educated opinion, lead to increased risk of disease and death for our already-threatened wild bird populations. This is not acceptable.
6) LBAM Isomate Plus twist ties present a danger to children who climb trees or who will be walking or playing around the toxic product. Children may pick up twist ties that have been pulled out of trees by wildlife, or they may simply handle them walking past shrubs, fences and bushes. An additional concern is that humans will be walking on ground into which the listed and secret ingredients of the ties have leached via rain or other vehicles. The chemicals will then be tracked into homes on the shoes. The chemicals will then be transferred from shoes to the carpet where infants play. Infants may become dangerously ill without parents or physicians having any way of determining of the cause because of this accidental tracking of toxins into the home.
7) Isomate-LBAM Plus twist ties are 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. I find it extremely disturbing that a portion of Sonoma will be blanketed with a chemical product which has not been tested for acute or long term effects on human or environmental health. This is a negligent and dangerous disservice to residents and public agencies should not be allowed to discount public health in their quest for profits.
8 ) The above reason should be sufficient cause for choosing not to infect human or animal habitat with known and secret chemicals. However, I will also add that it is the opinion of numerous eminent UC scientists, invasion biologist and entomologists that eradication of the light brown apple moth is not feasible in California. CDFA has recently admitted that the moth has been here for at least 6 or 7 years, despite their earlier insistence that it arrived here last year. In that time, the LBAM has done zero damage to crops and is considered a negligible bug everywhere else it lives in the world. According to UC scientists, not being funded by the USDA, the light brown apple moth is not only of no threat to agriculture, but it is also much too widespread to make it a candidate for eradication. Rather, we can rely on natural predators like birds and bats to keep populations of this harmless leaf roller moth at healthy levels…so long as we do no injure or kill those natural predators with chemicals. As the people of California have learned, the CDFA is conducting several scores of so-called ‘eradication’ programs that have been going on for more than 20 years! They are attempting to exterminate insect populations which cannot be exterminated, and in so doing, are exposing millions of humans and billions of creatures to body burdens of serious and fatal toxins. It is the considered opinion of UC experts that CDFA will fail to eradicate the LBAM, just as they have failed to eradicate the majority of the insects they claim to be exterminating, but for which they are receiving billions of dollars in federal funding. The LBAM program is unnecessary, not based in sound science and a severe danger to public and environmental health. By contrast, the little light brown apple moth represents no danger to humans, our food or water supply. It is CDFA, not LBAM, that is the public menace.
I request that my comments be registered as part of the Environmental Assessment. Thank you.