1 2012 SUSTAINABLE LANDSCAPE MAINTENANCE PROJECT Northern Arizona University, Flagstaff, Arizona USA A Green Fund project in cooperation with Facility Services Mission Statement The purpose of the Sustainable Landscape Maintenance Project is to identify environmentally-friendly landscaping practices which will reduce or eliminate the need for chemical inputs on the NAU campus. It seeks methods which are non-polluting, cost-effective, and result in an aesthetically pleasing landscape that does not pose a health risk to students, faculty, staff, and visitors. INTRODUCTION The 2012 research season of the Sustainable Landscape Maintenance Project continued to test alternative methods of landscape maintenance for turf and rock mulch sites on the Northern Arizona University (NAU) Flagstaff campus. These sites are under the care of the Grounds Department of Facility Services which utilizes a variety of techniques to maintain athletic fields, lawns, flower beds, shrubs, and trees spread across approximately 650 acres. Five synthetic herbicides -- Gallery 75 Dry Flowable, Pendulum AquaCap, Roundup/Razor Pro, Lontrel Turf and Ornamental, and Speedzone Southern Broadleaf -- are used on a regular basis throughout the growing season due to a university requirement to keep grass and rock mulch areas weed-free. Although Grounds uses these herbicides according to manufacturer’s recommendations, there is increasing evidence that these chemicals pose human health risks and can negatively affect local ecosystems, including damage to soils and water (for further information on the potential hazards of these products, see Appendix A: A Literature Review of Herbicide Toxicity to Humans). In 2007, the university established a Learning and Enterprise Strategic Plan which included the goal of “Stewardship and Sustainability of Place” (see Appendix B: Eliminating Herbicide Use on the NAU Campus - Proposal). One strategy within this goal is for NAU “to be a model of environmentally responsible and sustainable operations and education”. The elimination of potentially toxic herbicides is a critical first step towards environmental responsibility and sustainability. The landscapes of NAU provide the perfect setting to showcase alternative methods of lawn and garden maintenance and thus create an educational opportunity for students, faculty, staff, and the general public. Since 2011, the Sustainable Landscape Maintenance Project (SLM) has been testing non-toxic landscape maintenance treatments, including the hand-pulling of weeds in turf and rock mulch areas, improving soil health through the application of organically-approved amendments, and introducing native types of turfgrass.
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Abstract With the goal of reaching scientifically supported conclusions about the health effects of the five
herbicides used on Northern Arizona University’s campus, this literature search was carried out over a span of several months. Scientific databases, journals, and websites were searched through for relevant,
published, and peer-reviewed studies. The methodologies and results of these studies were documented. In conjunction with one another, the studies provide strong evidence of an association between exposure
to a majority of these herbicides and serious health problems.
Introduction This literature search was conducted
as a project of the Sustainable Environmental Practices Action Team of the
Environmental Caucus, with the intention of collecting and summarizing scientific data
on the effects on human health of the herbicides used on Northern Arizona
University’s Flagstaff campus: Roundup Pro, Lontrel Turf and Ornamental,
Pendulum Aquacap, Speedzone Southern Broadleaf, and Gallery 75 Dry Flowable. It
does not specifically address the possible environmental hazards of these herbicides.
Although the debate concerning herbicides’ safety related to human health is ongoing,
there is ample evidence of their toxicity. In 2004, the Ontario College of
Family Physicians released a literature review entitled “Pesticides Literature
Review“ which urges “that people reduce
their exposure to pesticides1
wherever possible,” for they found “consistent links to
serious illnesses such as cancer, reproductive problems and neurological
diseases, among others” (1). The report’s principle findings include:
1 Herbicides are a sub-category of pesticides.
“Many studies reviewed by the Ontario College show positive
associations between tumours and pesticide exposure […].”
“Previous studies have pointed to certain pesticides, such as [2,4-
dichlorophenoxyacetic acid] and related pesticides, as possible
precipitants of Non-Hodgkin’s Lymphoma […].”
“The review team uncovered a
remarkable consistency of findings of nervous system effects of
pesticide exposures.”
It was also consistently seen that children exposed to pesticides increasingly suffered
from various cancers, including Non-Hodgkin’s Lymphoma and Leukemia.
While the Ontario College reviewed studies of numerous pesticides, not just those found
on NAU’s campus, it reported negative health effects across all brands of commonly
used pesticides and herbicides. Each herbicide product is manufactured with
potent ingredients that fulfill a similar task: eradicating unwanted vegetation. A trend is
emerging that correlates the use of these chemicals with human illness, and this
literature review is meant to shed light on
40
the specific herbicides used on the NAU Flagstaff campus.
Methodology
The research resources available through the Northern Arizona University
Cline Library were extensively used, including the following databases: CSA
Illumina, ACS Publications, SciFinder, Web of Science, and Wiley Online Library.
Specific chemical names were searched for within these databases and the searches were
refined, if possible, to include results pertaining to toxicology. When utilizing the
SciFinder database, the Chemical Abstracts Service (CAS) registry numbers
2 for the
chemicals present in each of the five pesticides were obtained and used for
subsequent research. The list produced for each search was scoured for studies having
titles and summaries focusing primarily on the targeted herbicide; these studies were
then manually filtered through for definitive conclusions concerning the herbicide,
positive or negative. Additionally, the “Find Journals”
link was used from the Cline Library website. This tool offered another route for
the discovery of pertinent studies and information. Journals were sought out by
inserting words into the search bar that were contained within or completed the title of a
scientific journal (i.e. “toxicology”). A journal was selected and its issues were
examined for applicable studies and articles. Google Scholar was also used to find studies
by searching for specific chemicals as well as the marketed herbicides’ names. When
scientific studies simply could not be located for one herbicide, Gallery 75 Dry Flowable,
its Material Safety Data Sheet provided an array of determined facts about the nature of
its chemicals.
2 CAS numbers are assigned to each chemical for ease of research concerning specific substances.
Initially, the “Beyond Pesticides” website was used as a source of accumulated
studies relating to the toxicology of pesticides. A number of these dealt with the
herbicides specific to Northern Arizona University’s campus, and were cited once
confirmed as peer-reviewed sources. Also, a list of scientific terms with unknown
definitions was compiled and Professor Betty Brown of NAU’s Health Sciences
faculty was consulted for their meanings so that each study could be understood more
thoroughly. In order to cite each source used
within the report, the American Chemical Society style of citation was used which
entails the following: Sources are listed numerically according to their order of
appearance in the report under References; in-text, they are labeled with said numbers
in parentheses.
Results
Roundup Pro (Active ingredient: isopropyl
amine salt of glyphosate: 50.2%) – Non-
selective herbicide The Occupational Safety and Health
Administration, or OSHA, according to its standard 29 CFR 1910.1200
3, classified
Roundup as “hazardous.” A product of Roundup’s combustion is carbon monoxide,
which is a toxic gas. Two studies (2, 3) connect an increased occurrence of the
cancer Non-Hodgkin’s Lymphoma with exposure to glyphosate, both of which
conducted case-control studies consisting of cancer registry members and randomly-
selected people from the general populace. Interviews performed by professionals were
held to obtain herbicide use information from each participant. Another study (4)
3 “Ensures that the hazards of all chemicals produced
or imported are evaluated, and that information
concerning their hazards is transmitted to employers and employees,” according to OSHA’s website.
41
found that certain pesticides, including glyphosate, are “significantly positively
associated with current Rhinitis,” or the inflammation of internal areas of the nose
which may hinder sleep and the ability to learn. The subjects of this study were over
2,000 pesticide applicators from the Agricultural Health Study, and it was
concluded that “exposure to pesticides may increase the risk of rhinitis.”
An additional study (5) “evaluated the toxicity of four glyphosate (G)-based
herbicides in Roundup (R) formulations” on human umbilical, embryonic, and placental
cells: “All [Roundup] formulations cause total cell death within 24 hours.” These
scientists concluded that “adjuvants4
in Roundup formulations are not inert,” but are
instead active. Another study investigating the effects of glyphosate on human placental
cells (6) found that it – especially in the Roundup mixture – is toxic to these
placental cells “within 18 hours with concentrations lower than those found with
agricultural use.” They conclude that “toxic effects of Roundup, not just glyphosate, can
be observed in mammals,” and that “the presence of Roundup adjuvants enhances
glyphosate bioavailability and/or bioaccumulation
5.”
Another study (7), citing that “cutaneous
6 exposure to a glyphosate-
containing herbicide has been postulated as contributing to Parkinsonism,” conducted an
experiment in which rats were orally administered single doses of glyphosate and
then tested through blood samples. It was concluded that “although the bioavailability
was low, glyphosate and its metabolite AMPA
7 were eliminated from plasma
4 Drugs or other substances that enhance the activity
of another. 5 The accumulation within living organisms of toxic
substances occurring in the environment. 6 Relating to or involving the skin. 7 Mimics AMPA receptor, which allows passage of calcium, sodium, and potassium.
slowly and therefore would be diffused to target tissues to exert systemic effects.”
However, the authors also state, “The toxicokinetic
8 characteristics of glyphosate
identified in this study warrant further research on possible mechanisms of toxicity
of this herbicide.” A different experiment (8) “studied the effect on cell cycle
regulation of the widely used glyphosate-containing pesticide Roundup,” using “sea
urchin embryonic first divisions following fertilization, which are appropriate for the
study of universal cell cycle regulation without interference with transcription.” It
was shown that “0.8% Roundup (containing 8 mM glyphosate) induces a delay in the
kinetic of the first cell cleavage9
of sea urchin embryos,” calling into question “the
safety of glyphosate and Roundup on human health.”
The only study (9) found in the literature search that suggested Roundup
presents no human health concern included studies “performed for regulatory purposes
as well as published research reports.” This study was conducted on behalf of Monsanto
– Roundup’s manufacturer – by Robert Kroes, Gary M. Williams and Ian C.
Munroe. According to the Aspartame Toxicity Info Center (10), Robert Kroes and
Gary M. Williams “joined with Ian C. Munoe, the president of the Cantox Health
Sciences International corporate advocacy group, to work with Monsanto to review its
herbicide, glyphosate” (10).
Lontrel Turf and Ornamental (Active
ingredients: “Clopyralid MEA Salt”:
40.9%; “isopropanol”: 5.0%; “ethylene
oxide, propylene oxide and di-sec-
butylphenol polymer”: 1.0%) – broad-
spectrum herbicide for thistle control in
vegetable cultivation
8 What rate a chemical will enter the body and what
happens to it once it is in the body. 9 Motion of the first cell separation.
42
As listed in the Material Safety Data Sheet (MSDS), OSHA refers to this
herbicide as a “Hazardous Chemical,” and its SARA Hazard Categories
10 are both
“Immediate Health Hazard” and “Delayed Health Hazard”. The standards held by
these organizations are listed in Appendix A. Few peer-reviewed scientific studies
reporting on the safety of Lontrel could be located. The one report (11) found with a
high caliber of credentials and data is titled “Teratologic Evaluation of 3,6-
Dichloropicolinic Acid in Rats and Rabbits,” 3,6-dichloropicolinic acid being known also
as Clopyralid. The report immediately divulges the fact that its authors “performed
these studies in the Toxicology Research Laboratory of The Dow Chemical
Company,” the manufacturer of Lontrel. Negative effects of exposure to Lontrel were
reported. Pregnant rats and rabbits were fed Clopyralid at various doses and the
consequences on their gestation were observed: “Pregnant rats in the 250-
mg/kg/day groups gained significantly less weight than controls on Days 6 through 15
of gestation,” and “the mean fetal body weight was significantly increased at the 75-
mg/kg/day dose level.” Additionally, there were numerous fetal alterations as a result of
exposure to Lontrel’s ingredient Clopyralid: “Examination of the fetuses for skeletal
alterations revealed a significant increase in the incidence of bilobed centra
11 of the
thoracic vertebra in the 15-mg/kg/day group”; “One fetus with a hemivertebra
12
and three fetuses with polydactyly13
were observed in the 250-mg/kg/day dose group.
These alterations were considered to be
10 Superfund Amendments and Reauthorization
Act of 1986 Title III (Emergency Planning and
Community Right-to-Know Act of 1986). 11 The main vertebra dividing into two lobes. 12 Vertebra that is incompletely developed on one
side. 13 the presence of more than five digits on a hand or foot.
major malformations. Lastly, “A significant decrease in the incidence of delayed
ossification14
of centra of the cervical vertebrae,” or an unusual speeding up of
bone formation, “was observed in the 75- and 250-mg/kg/day dose groups,” but is “not
considered to be of toxicological significance.”
Pendulum Aquacap (Active ingredient:
“Pendimethalin”: 38.7%) – pre-emergent
broadleaf
The MSDS for this specific substance presents the following
information: “If product is heated above decomposition temperature, toxic vapours
will be released,” such as carbon monoxide and nitrogen oxides; Pendulum is “not
readily biodegradable”; and OSHA states, “Chronic target organ effects reported.”
One study (12) was performed in hopes of either confirming or refuting other studies’
conclusions about endocrine15
disrupting effects of different pesticides, as well as the
facts that the US Environmental Protection Agency classified pendimethalin as a
possible human carcinogen (group C)16
and as a ‘slightly toxic’ compound (toxicity class
III). These authors found that “the higher two doses of pendimethalin, 300 and
600 mg/kg/day, elicited a small but significant increase in absolute uterine
weight,” which is indicative of Pendulum’s ability to affect and disrupt pregnancy.
Another study (13) examined the damage done by certain pesticides and found that
“pendimethalin induced cytotoxicity17
in Chinese hamster ovary (CHO) cells treated
for 3 hours.” The report is ended with the relation of these findings to other analyses’
14 Bone formation. 15 Glands that secrete hormones directly into the
bloodstream. 16 See Appendix A, under EPA 17 The degree to which something is toxic to living cells.
43
declarations that “incidences of rectum and lung cancers are associated with
pendimethalin, and that DNA damage is one of the factors for carcinogenicity.”
A third study (14) evaluated “environmentally relevant, low-dose
exposures to agrochemicals and lawn-care pesticides for their direct effects on mouse
preimplantation embryo development,” using pendimethalin, but also using
dicamba, 2,4-dichlorophenoxyacetic acid (2,4-D), and mecoprop, or MCPP – all of
which are ingredients present in other herbicides used on the NAU campus. It was
found that “dicamba alone or combined with pendimethalin or 2,4-D and atrazine induced
significant levels of cell death18
.” Another study (15) focused on “the potential
associations between the use of a number of pesticides and pancreatic cancer” using the
Agricultural Health Study cohort, which consists of “over 89,000 participants
including pesticide applicators and their spouses.” It was discovered that
“applicators in the top half of lifetime pendimethalin use had a 3.0-fold (95% CI
1.3–7.2, p-trend = 0.01)19
risk compared with never users.” The confidence interval
(CI) relates that 95% of the time, a person’s risk of pancreatic cancer was multiplied by a
number in the given range (1.3 to 7.2); the p-trend says that this conclusion would be
disregarded if its probability was any less than .01, or 1%. The authors conclude their
report with the statement, “These findings suggest that herbicides, particularly
pendimethalin and EPTC20
, may be associated with pancreatic cancer.”
18 Technically, “apoptosis” or programmed cell
death; necessary cell death that, for example,
separates toes. 19 A study’s confidence interval (CI) shows the reliability of a study’s estimate; a study’s p-trend
value gives the probability of getting a test statistic
that is at least as extreme as the one observed (often
.01 or .05). 20 A different but unrelated pesticide.
Speedzone Southern Broadleaf (Active
ingredients: 2,4-Dichlorophenoxyacetic
acid (2,4-D): 10.49%; dicamba: 0.67%;
carfentrazone-ethyl: 0.54%; propionic acid
(MCPP): 2.66%) – post-emergent
broadleaf A facet of the WHO, called the
International Agency for Research on Cancer (IARC), has catalogued carcinogenic
substances and compounds. It classifies “chlorophenoxy herbicides” as “Possibly
carcinogenic to humans.” 2,4-D, a main ingredient of Speedzone, is a part of this
group. Additionally, the MSDS for
Speedzone contains the following information: OSHA refers to the substance
as “hazardous”; its SARA Hazard Categories are both “Immediate Health
Hazard” and “Delayed Health Hazard”; and its byproducts from combustion include
carbon monoxide and nitrogen oxides. One study (16) tested the effects of
phenoxyacetic acids on mice, including a mixture of 2,4-D and 2,4,5-
trichlorophenoxyacetic acid. “Subcutaneous injections were given from day 6 through
day 14 of pregnancy,” and various health levels were recorded. Ultimately, “It was
found that both preparations at the high dosage (110 mg/kg/day) were teratogenic
21
and embryotoxic22
.” A similar study (17) tested five herbicidal phenoxycarboxylic
acids, including 2,4-D and MCPP which are both found in Speedzone. These authors
found that “all 5 were embryotoxic and teratogenic.”
The same study (14) that applied to Pendulum’s ingredients also pertains to
Speedzone. Again, its authors evaluated “environmentally relevant, low-dose
21 Able to disturb the growth and development of an
embryo or fetus. 22 Adversely affecting the growth and/or development of an embryo.
3: De Roos, A. J. "Integrative Assessment of Multiple Pesticides as Risk Factors for Non-Hodgkin's Lymphoma among Men." Occupational and Environmental Medicine 60.9 (2003): 11e-11. Print.
4: Slager, R. E., J. A. Poole, T. D. LeVan, D. P. Sandler, M C R. Alavanja, and J. A. Hoppin. "Rhinitis
Associated with Pesticide Exposure among Commercial Pesticide Applicators in the Agricultural Health Study." Occupational and Environmental Medicine 66.11 (2009): 718-24. Print.
5: Benachour, Nora, and Gilles-Eric S ralini. Glyphosate Formulations Induce Apoptosis and Necrosis
in Human Umbilical, Embryonic, and Placental Cells." Chemical Research in Toxicology 22.1 (2009): 97-105. Print.
6: Richard, Sophie, Safa Moslemi, Herbert Sipahutar, Nora Benachour, and Gilles-Eric Seralini.
"Differential Effects of Glyphosate and Roundup on Human Placental Cells and Aromatase."
Environmental Health Perspectives 113.6 (2005). Print.
7: Anadón, A., M.R. Martínez-Larrañaga, M.A. Martínez, V.J. Castellano, M. Martínez, M.T. Martin,
M.J. Nozal, and J.L. Bernal. "Toxicokinetics of Glyphosate and Its Metabolite Aminomethyl
Phosphonic Acid in Rats." Toxicology Letters 190.1 (2009): 91-95. Print.
8: Marc, J., O. Mulner-Lorillon, S. Boulben, D. Hureau, and R. Bellé. "Pesticide Roundup Provokes
Cell Division Dysfunction at the Level of CDK1/cyclin B Activation." Chemical Research in Toxicology 15.3 (2002): 326-31. Web. 4 Jan. 2011.
9: Williams, Gary M., Robert Kroes, and Ian C. Munro. "Safety Evaluation and Risk Assessment of the
Herbicide Roundup and Its Active Ingredient, Glyphosate, for Humans." Regulatory Toxicology and Pharmacology 31.2 (2000): 117-65. Print.
10: Aspartame and Manufacturer-Funded Scientific Reviews." Holistic Medicine Web Page. Web. 04
11: Hayes, W. C., F. A. Smith, J. A. John, and K. S. Rao. "Teratologic Evaluation of 3,6-Dichloropicolinic Acid in Rats and Rabbits." Toxicological Sciences 4.1 (1984): 91-97. Print.
49
12: Ündeğer, U., M. Schlumpf, and W. Lichtensteiger. Effect of the Herbicide Pendimethalin on Rat Uterine Weight and Gene Expression and in Silico Receptor Binding Analysis." Science Direct. Feb.
2010. Web. 5 Nov. 2010.
13: Patel, Sushila, Mahima Bajpayee, Alok Kumar Pandey, Devendra Parmar, and Alok Dhawan. "In Vitro Induction of Cytotoxicity and DNA Strand Breaks in CHO Cells Exposed to Cypermethrin,
Pendimethalin and Dichlorvos." Toxicology in Vitro 21.8 (2007): 1409-418. Print.
14: Greenlee, Anne R., Tammy M. Ellis, and Richard L. Berg. "Low-Dose Agrochemicals and Lawn Care Pesticides Induce Developmental Toxicity in Murine Preimplantation Embryos." Environmental
Health Perspectives (2004). Print.
15: Andreotti, Gabriella, Laura E. Beane Freeman, Lifang Hou, Joseph Coble, Jennifer Rusiecki, Jane A. Hoppin, Debra T. Silverman, and Michael C.R. Alavanja. "Agricultural Pesticide Use and Pancreatic
Cancer Risk in the Agricultural Health Study Cohort." International Journal of Cancer 124.10 (2009): 2495-500. Print.
16: Båge, Gertrud, Eva Cekanova, and K. S. Larsson. "Teratogenic and Embryotoxic Effects of the
Herbicides Di- and Trichlorophenoxyacetic Acids (2, 4D and 2, 4, 5-T)." Basic and Clinical Pharmacology and Toxicology 32.6 (1973): 408-16. Print.
17: Roll, R., and G. Matthiaschk. "10. Comparative Studies on the Embryotoxicity of 2-methyl-4-
chlorophenoxyacetic Acid, Mecoprop and Dichlorprop in NMRI Mice." Arzneimittel-Forschung 33.10 (1983): 1479. Print.
18: Cavieres, Maria F., James Jaeger, and Warren Porter. "Developmental Toxicity of a Commercial
Herbicide Mixture in Mice: I. Effects on Embryo Implantation and Litter Size." Environmental Health Perspectives (2002). BNET. Web. 2 Jan. 2011.
19: "Health Effects of 30 Commonly Used Lawn Pesticides." Beyond Pesticides/NCAMP, Apr. 2005.
20: "PAN International List of Highly Hazardous Pesticides." Pesticide Action Network International. PAN Germany for PAN International, Jan. 2009. Web. 12 Nov. 2010.
50
Appendix A: Organization Backgrounds and Standards (Information obtained from organizations’ respective websites)
Pesticide Action Network (PAN)
1. “Since its founding in 1982, Pesticide Action Network (PAN) has been the civil society organisation (CSO) most steadily and continuously calling for effective international action
towards the elimination of hazardous pesticides.” 2. “For the FAO [Food and Agriculture Organization] initiative supported by the FAO Council, the
COAG [Committee on Agriculture], the FAO/WHO Panel of Experts for Pesticide Management and others, there needs to be clarification of when the progressive ban of highly hazardous
pesticides (HHP) should happen, and who should make it happen. These are questions not being dealt with in this publication.”
3. “A pesticide is considered to be highly hazardous by PAN if it has one of the following characteristics,
high acute toxicity (including inhalative toxicity) and/or,
long-term toxic effects at chronic exposure (carcinogenicity, mutagenicity, reproductive toxicity,
endocrine disruption) and/or,
high environmental concern either through ubiquitous exposure, bioaccumulation or toxicity, and/or
known to cause a high incidence of severe or irreversible adverse effects on human health or the environment”
World Health Organization (WHO)
1. General Statement: “Pesticides are chemical compounds that are used to kill pests, including insects, rodents, fungi and unwanted plants (weeds). Pesticides are used in public health to kill
vectors of disease, such as mosquitoes, and in agriculture, to kill pests that damage crops. By their nature, pesticides are potentially toxic to other organisms, including humans, and need to be
used safely and disposed of properly.” 2. WHO Pesticide Evaluation Scheme (WHOPES)
a. “The WHO Pesticide Evaluation Scheme (WHOPES) was set up in 1960. WHOPES promotes and coordinates the testing and evaluation of pesticides for public health. It
functions through the participation of representatives of governments, manufacturers of pesticides and pesticide application equipment, WHO Collaborating Centres and research
institutions, as well as other WHO programmes, notably the International Programme on Chemical Safety.”
b. “In its present form, WHOPES comprises a four-phase evaluation and testing programme, studying the safety, efficacy and operational acceptability of public health
pesticides and developing specifications for quality control and international trade.” 3. International Programme on Chemical Safety (IPCS)
a. “The objective of chemicals assessment is to provide a consensus scientific description of the risks of chemical exposures. These descriptions are published in assessment reports
and other related documents so that governments and international and national organizations can use them as the basis for taking preventive actions against adverse
health and environmental impacts.” 4. International Agency for Research on Cancer
a. Website: http://monographs.iarc.fr/ENG/Classification/
51
b. Page titled “Evaluation of Carcinogenic Risks to Humans” lists commercial products deemed harmful and cancer-causing
c. Listed according to hazard strength
Occupational Safety and Health Administration (OSHA)
1. “Congress created the Occupational Safety and Health Administration (OSHA) to ensure safe
and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.”
a. Standard 29 CFR 1910.1200 (Toxic and Hazardous Substances) i. "Health hazard" means a chemical for which there is statistically significant
evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed
employees. The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers,
hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.”
b. Appendix A (Health Hazard Definitions) i. “The determination of occupational health hazards is complicated by the fact that
many of the effects or signs and symptoms occur commonly in non-occupationally exposed populations, so that effects of exposure are difficult to
separate from normally occurring illnesses. […] The situation is further complicated by the fact that most chemicals have not been adequately tested to
determine their health hazard potential, and data do not exist to substantiate these effects.”
c. Appendix B (Hazard Determination) i. “The hazard determination requirement of this standard is performance-oriented.
Chemical manufacturers, importers, and employers evaluating chemicals are not required to follow any specific methods for determining hazards, but they must be
able to demonstrate that they have adequately ascertained the hazards of the chemicals produced or imported in accordance with the criteria set forth in this
publications/corrected-2010-cancer-report-public.pdf 2. “EPA was established to consolidate in one agency a variety of federal research, monitoring,
standard-setting and enforcement activities to ensure environmental protection. EPA's mission is to protect human health and to safeguard the natural environment—air, water, and land—upon
which life depends.” 3. Superfund Amendments and Reauthorization Act (SARA)
a. “Amended the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)”
b. “SARA reflected EPA's experience in administering the complex Superfund program during its first six years and made several important changes and additions to the
c. “SARA also required EPA to revise the Hazard Ranking System (HRS) to ensure that it accurately assessed the relative degree of risk to human health and the environment posed
by uncontrolled hazardous waste sites that may be placed on the National Priorities List (NPL).”
4. Group C: “Possible Human Carcinogen”/“Suggestive evidence of carcinogenic potential” a. “There is limited evidence that it can cause cancer in animals in the absence of
b. human data, but at present it is not conclusive.”
An opportunity to advance the Strategic Plan Prepared by Paul Gazda, 28 February 2007
Updated 13 April 2007
For the latest version of this document, see: www2.nau.edu/~pag/HerbicideElimination.pdf
Executive Summary
Goal 3 of NAU’s new Learning and Enterprise Strategic Plan, Stewardship and Sustainability of Place, calls on the
NAU community to “elevate the environmental…vitality of our communities through collaborative stewardship
of place.” Eliminating herbicide use on the Mountain Campus offers an opportunity to answer this call in an
important way.
There is increasing evidence of the toxicity of herbicides and pesticides to humans and animals. A 2004 literature
review by the Ontario [Canada] College of Family Physicians concluded that exposure to all the commonly used
pesticides has shown positive associations with adverse health effects. A recent study reported in Scientific
American showed that individually “safe” levels of these chemicals can inflict serious harm on the ecosystem
when combined. With growing evidence of the negative human and environmental impact of herbicides, how
can their continued use be in keeping with NAU’s goal of providing leadership in sustainable practices?
The Learning and Enterprise Strategic Plan provides a framework within which we can provide leadership in the
global efforts to eliminate toxic herbicide use by learning from those who have already begun to address this
problem and then contributing back to this knowledge base our own locally developed practices. By using the
practical problem of finding an effective alternative to herbicides as a springboard for research and focused
education, NAU can have a broad positive impact. Local communities that are struggling with the issue of
herbicide use can look to NAU for help in finding viable non-toxic alternatives. Not only will such leadership
provide a great service to surrounding communities, but it will garner goodwill in the process. Students,
parents, faculty and staff would enthusiastically support NAU’s elimination of herbicides. It is a sign of a
university that truly cares about its community. Eliminating herbicide use on the NAU campus provides an
excellent fit with Goal 3 of our Learning and Enterprise Strategic Plan. It addresses both Strategies and eight of
the twelve Initiatives under Goal 3, and should therefore be given a high priority for implementation.
Recommendations
1. That NAU set a goal of eliminating herbicide use on its Mountain Campus. 2. That a project be undertaken to find viable alternatives to herbicides such that the appearance and
health of campus grounds can be maintained in a non-toxic manner. 3. That a steering committee consisting of staff, faculty and students be established to guide this project,
set a timeline for complete herbicide elimination, and facilitate project collaboration amongst interested campus groups.
4. That NAU’s successes in this effort be shared with the broader community to help eliminate herbicides on a regional scale.
Background
Goal 3 of NAU’s new Learning and Enterprise Strategic Plan, Stewardship and Sustainability of Place, calls on the
NAU community to “elevate the environmental…vitality of our communities through collaborative stewardship
of place.” Eliminating herbicide use on the Mountain Campus offers an opportunity to answer this call in an
important way.
There is increasing evidence of the toxicity of herbicides and pesticides to humans and animals. A recent study
documented in the May 2006 Scientific American showed that individually “safe” levels of these chemicals can
inflict serious harm on the ecosystem when combined. The multiple herbicides that NAU uses combine with
what the rest of Flagstaff uses when they run off and accumulate in streams, rivers and ponds, thus endangering
aquatic life as well as the animals and humans that eventually drink the water.
In 2004, the Ontario [Canada] College of Family Physicians published a comprehensive summary of all peer-
reviewed studies published between 1992 and 2003 that investigated the human health effects of pesticides
[including herbicides]. The report concludes that exposure to all the commonly used pesticides has shown
positive associations with adverse health effects including cancerous tumors, non-Hodgkin’s lymphoma,
leukemia, and genetic damage.
According to a 1996 report by the Attorney General of New York State, the chemicals used as “inert ingredients”
in herbicides and pesticides “include some of the most dangerous substances known. Some of these chemicals
are suspected carcinogens and have been linked to other long-term health problems like central nervous system
disorders, liver and kidney damage and birth defects.”
With growing evidence of the negative human and environmental impact of herbicides, how can their continued
use be in keeping with NAU’s goal of providing leadership in sustainable practices? Furthermore, how can NAU
be accountable for providing a safe working and learning environment by spraying herbicide on the grass where
students often lie down to study? We are told herbicides are harmless once they dry, but ask yourself if you
would lie down in the grass where herbicide had recently been sprayed and eat your lunch or read a book. I
know of one instance where a small child came into a campus building with her parents, holding a dandelion to
her mouth and licking it, the same day dandelion spraying had been done around that building. Finally, is it fair
to chemically sensitive employees to force them to remain at home and make up lost work time or use vacation
time so they can have a safe working environment when herbicides are sprayed around their buildings?
Opportunities for Leadership
Eliminating herbicide use on the NAU campus provides an excellent fit with Goal 3 of our Learning and
Enterprise Strategic Plan. It addresses both Strategies and eight of the twelve Initiatives under Goal 3, and
should therefore be given a high priority for implementation.
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Goal 3: Stewardship and Sustainability of Place.
Strategy 2: Be a model of environmentally responsible and sustainable operations and education.
Initiatives:
Partner with individuals, institutions, and communities to advance…sustainable practices.
A growing number of universities and cities are eliminating herbicide use. NAU should learn from those who
have already addressed this problem and then contribute back to this knowledge base our own locally
developed practices. For example, Seattle University, ranked among the top 10 schools in the West by U.S. News
and World Report, has not used herbicides or pesticides on its campus for over 20 years. Tufts University has
undertaken a pilot project to manage a portion of campus grounds organically. A detailed report on this
program is available on their web site.
Enhance sustainable business practices in areas such as…landscaping….
Proactive planning to eliminate weed problems through creative landscaping and the use of geo-textile and
plastic weed barriers would reduce the size of weed-vulnerable areas.
Use the “campus as ecosystem” concept across the curriculum to educate faculty and students about the
scientific…and ethical dimensions of sustainability.
…and…
Implement issue-oriented education focusing on topics such…water issues….
…and…
Improve the collection and analysis of environmentally-related data…and use the data strategically in making
environmental…decisions.
By using the practical problem of finding an effective alternative to herbicides as a springboard for research and
focused education, NAU can have a broad positive impact. Hundreds of millions of pounds of herbicides and
pesticides are applied nationally each year. There is increasing concern by citizens over their use, and increasing
evidence of their toxicity; but lack of practical alternatives is a major stumbling block to their elimination. NAU
can make a major contribution to human and environmental health by using our campus as a testing and
proving ground for non-toxic methods of weed control.
Expand awareness of the university’s sustainability initiatives….
Students, parents, faculty and staff would enthusiastically support NAU’s elimination of herbicides. It is a sign of
a university that truly cares about its community. This could be used as an effective marketing tool to increase
enrollment.
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Opportunities for Leadership (cont.)
Strategy 1: Support innovation, stewardship, and engagement in our communities.
Initiatives
Promote scholarship that increases engagement with local communities and addresses key global challenges.
…and…
Engage with partners to address regional…environmental stewardship…priorities.
Local communities are struggling with the issue of herbicide use. Last year, a citizen petition forced the Sedona
City Council to suspend herbicide use for one year. However, having no one with expertise to turn to, the city
failed to implement an alternative program, and the council voted to resume herbicide use, angering and
worrying many residents. The Grounds Department of Seattle University sees its commitment to fostering an
organic and environmentally friendly campus as part of the university’s mission of educating the whole person
and the community. Tufts University states that, “A college campus is an ideal place to pursue environmentally
sound grounds management, offering a model of environmental responsibility for the broader community.” So,
too, can NAU help fulfill its regional and global stewardship goal by providing leadership in finding non-toxic
solutions to the growing problem of herbicide use. Not only will such leadership provide a great service to
surrounding communities, but it will garner enthusiastic regional support in the process.
Recommendations
1. That NAU set a goal of eliminating herbicide use on its Mountain Campus. 2. That a project be undertaken to find viable alternatives to herbicides such that the appearance and
health of campus grounds can be maintained in a non-toxic manner. 3. That a steering committee consisting of staff, faculty and students be established to guide this project,
set a timeline for complete herbicide elimination, and facilitate project collaboration amongst interested campus groups.
4. That NAU’s successes in this effort be shared with the broader community to help eliminate herbicides on a regional scale.
Appendix A: see “2012 APPENDIX B” found on pages 53 – 57 of this document
Appendix B:
Green Fund Project Proposal for Sustainable Landscape Maintenance Pilot Project
Overview The NAU Grounds Department is required to keep the campus grounds free of weeds while working with limited human and material resources. The only way they have found to accomplish this is through the use of toxic herbicides, which have been linked to cancer and other diseases as well as ecosystem disruption. Although Grounds uses the minimum amount necessary, which is often less than the manufacturer’s suggested concentration, it is not in keeping with NAU’s sustainability goals to continue to use toxic chemicals indefinitely. In the Climate Action Plan, the Grounds Department has set a goal of testing non-toxic grounds maintenance methods until a successful method is discovered and herbicide use on campus can be reduced. Although Grounds is willing to put forth the effort to test new methods, their resources are severely limited and they have not been able to fund the people and materials necessary for a pilot project to test new methods. We are asking the Green Fund to make it possible to conduct a pilot project to study alternative non-toxic landscape maintenance methods. A pilot project is an extremely important first step, without which NAU will not be able to move toward its goal of reducing herbicide use on campus. In the proposed pilot project, several campus lawn and rock mulch areas will be designated as sustainable landscape maintenance areas. These will be maintained using the best organic, non-toxic practices available, and compared with control areas maintained with the Grounds Department’s standard procedures using toxic weed control chemicals. Collaboration with SSLUG to provide organic nutrients will be pursued. Signage will educate the public on the nature of the project and refer to a web site with more information on the process and benefits of non-toxic landscape maintenance. The project will run from spring through fall of 2011 and include a project report with background, procedure, findings and recommendations. The cost of the project will include a paid student intern each semester to plan, coordinate and evaluate the project in cooperation with the Grounds Department, additional hours for student workers to assist with landscape maintenance activities, and the cost of seeds, soil amendments, etc.
1. Visibility Our project proposes several test sites and will be visible throughout campus. We have chosen sites that are well seen. The North side of the SBS West building on campus, which is right next to the busiest bus stop on South Campus, beside Ardrey Auditorium, which is also beside a busy bus stop as well as across from the Union, and in front of the Eastburn Education Center which is easily seen from the road and a busy sidewalk. These test plots will have signage on them, which will allow students to understand and read about what we are doing and why.
They will be able to visibly see and support what their tuition money is going towards; which as a student myself, is very important. The project will also include an educational component via a related web site which will encourage students to do research and learn about what we are trying to accomplish, become more aware of the project and hopefully become involved as well. The test plots will increase student awareness that there are toxic herbicides and pesticides on campus and that there are other, non-toxic and environmentally friendly ways to go about treating the grounds at NAU. Information about the pilot could also be featured on Earth Day and possibly tied into a campus cleanup event that includes weeding of the test plots.
2. Meets Student Priorities
This project meets following priorities based on the survey results.
Survey: How strongly do you agree/disagree? Integrating sustainable practices (such as use of renewable energy and energy efficiency) into university life is worthwhile. 74% strongly agree. 22.6% somewhat agree. Sustainable practices on campus are a low priority for students. 53.5% somewhat or strongly disagree.
This project deals with the campus landscape which student see and use every day. They sit on grass to eat, read and socialize, play recreational games, stage events, etc. Students will benefit from knowing the importance of clean and sustainable landscape maintenance practices to their daily life. Twenty-first century jobs increasingly rely on professionals who are aware of sustainable practices. 37.7% strongly agree. 47.9% somewhat agree. Learning about sustainable practices is irrelevant to my college experience. 31.3% somewhat disagreed. 45.4% strongly disagreed. The educational component of this project will make students in all disciplines more aware of sustainability issues. Survey: What should Green Fund support? Grants for student research and sustainability projects applicable to all areas of study 41.3% very important. 35.8% somewhat important.
A variety of majors and disciplines can take part- from the sciences such as biology, chemistry or environmental sciences, in which students can help monitor and use the plots for research and observation on how chemicals may or may not effect the grass test plots, to communication majors who will be able to report, photograph, write about, and help promote our cause to eliminate the toxic chemicals used on campus. Other sustainability initiatives (such as recycle bin purchase, Yellow Bike Program expansion) 55.2% very important. 29.3 somewhat important.
This project can tie in with other sustainability initiatives on campus such as composting and SSLUG organic gardening.
3. Economically Feasible/Sustainable Purpose of this project is to develop, examine and evaluate alternatives. Will end with a report including recommendations on further action. If viable alternatives are found, it is hoped that funding could be taken over by the ongoing Operations budget or some other central fund of NAU rather than the Green Fund. At this point, NAU Operations will be providing staff for routine maintenance such as grass mowing, litter pick up, etc. The Green Fund is being asked to provide funds for organic materials, non-toxic pre-emergent treatment, extra grass seed, the student intern responsible for the research aspect of the project, and additional student worker hours for manual weed removal.
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4. Program Longevity
If viable sustainable methods are proven in this project, it is hoped that NAU Operations would take over the project and merge with their ongoing grounds maintenance program.
5. Reasonable Timeline
The project is specifically planned for one full landscape maintenance cycle from spring through fall of 2011. It should be possible to see results and trends by then, but due to the desired outcome of building sustainable soil and plant health, it may take longer for the pilot plots to become self-sustaining. It may be desirable to extend the project for additional semesters if additional time is needed to draw conclusions regarding the long term characteristics of the methods being studied. Whether it would be desirable to extend the study will not be known until the fall semester 2011.
6. Campus Community Involvement Our project involves students in several ways and different aspects to include a wide variety of people at NAU. With the proposed test plots, there will be attention from the student population and interest in what we are trying to accomplish. These plots also need maintenance and monitoring. We hope to bring other students, student run organizations and disciplines such as SSLUG and the ART groups of the Master’s in Sustainability Communities, internships and capstone projects into the process to help us achieve our final goal, which is to eliminate toxic herbicides and pesticides on campus. There are an endless number of students that can choose to participate with this project and the more the better!
7. Impact The costs are for labor, seed, organic fertilizers, etc. to build a healthy soil in which plants and microorganism can establish themselves and become self-sustaining. The benefits are achieving a clean, sustainable landscape that does not require endless application of toxic chemicals which accumulate in the environment. This project could be integrated as field study with classes related to the sciences (biology, botany, environmental science, etc.). The signage and educational website will provide information to student of all disciplines on sustainability as it relates to their daily lives.
8. Meets Campus Sustainability Goals
Climate Action Section 3 - Operations
Goal 2 Reduce the impact of chemicals used on campus. Action
Continue to use Green Seal Certified cleaning products. Continue test-plot research on non-toxic grounds maintenance methods until a successful method is discovered and herbicide use on campus can be reduced. Responsible Party
The Director of Operations will oversee these efforts. Measure of Success
The reduction of chemicals used on campus.
Green Fund Project Budget for Sustainable Landscape Maintenance Pilot Project Notes: In consultation with the Grounds Department, we have addressed your concerns about the budget of our
proposal, and have been able to reduce the budget from $34,627 to $26,952. The following are the steps we
took.
First, we considered partnering with SEED, SSLUG, Eco House, or Botany for student volunteer workers, or
perhaps for academic credit/internships, for manual weed removal on the test plots. The Grounds department has
concerns about the reliability of volunteers for a project of this duration, and the additional supervision and
coordination it would require from their staff. With their mandate to keep these highly visible areas free of weeds
for a full year, they felt that volunteers would not be a reliable option. However, as an alternative, we agreed that
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an academic credit internship could be posted each semester for manual weed removal along with data collection
and other duties related to the research aspect of the project. The budget does not assume that the internship
would be filled each semester, since it may be difficult to find students to fill the internship for all three semesters;
but for each semester that an intern is found, the student worker budget would be reduced accordingly.
After discussions with Jacqueline Vaughn, who coordinates internships for Environmental Studies, we feel that
the originally proposed paid internship for a student to lead the research aspect of the project must remain a paid
internship due to the time commitment and level of responsibility of the position. The paid internship is of highest
importance for the success of the project, and it is felt that offering payment plus the possibility of academic credit
is necessary to attract a student each semester to that position. Although it is possible that the same student
could continue for more than one semester, we are assuming that different students would fill the paid and
academic credit internships each semester due to limits on internship credits, and to make the opportunity
available to more students. Draft descriptions of the internships are included with this application.
Second, we looked at the total area test of 53,000 square feet. We realized that by switching the test area at the
largest site (Eastburn Education building) from larger north segment to the smaller south segment (a sidewalk
provides a natural divider), a major reduction to 24,000 square feet could be achieved. This significantly reduces
the labor and material costs, while maintaining a large enough test area to retain the visibility and effectiveness of
the research aspect of the project.
Third, we have discussed partnering with Gardens for Humanity, a registered non-profit, to obtain donations of
corn gluten, organic fertilizer, sulfur etc, for the project. The President of Gardens for Humanity has expressed
support for the idea, but formal approval would be required by their board once a specific donation proposal is
received. We have thus far approached five different companies regarding donating some of the materials
required by the project, and have thus far received a reply from one company indicating they are not willing to
donate. We will continue to pursue this option, and any donations will reduce the budget request accordingly.
Fourth, we will look into grants to help fund this project. There is not time to locate and apply for grants before the
start of spring semester, but we will look for grants throughout the duration of the project. Any grants received will
reduce the amount needed from the Green Fund. If we miss the spring semester window, the project will probably
have to be delayed a full year until spring 2012 since it depends on the growing season and herbicide application
cycle. So we would like to proceed on the basis that we will look for grants to replace Green Fund money
throughout the life of the project. The grant search and application process will be part of the student interns’
work.
In summary, this revised budget request represents a reduction of $7,675 from the originally proposed budget. It
should be considered a “worst case” budget. We will look for ways to reduce the Green Fund budget through
student interns, material donations and grant funding throughout the life of the project. Costs will be tracked
throughout the project. Any budgeted funds that are not used, or are replaced by the options mentioned above,
Chemical Applicators, Staff for Corn Gluten, Seed, Sulfur and Fertilizer Application, Airification, etc - $6,076
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Student Worker Costs:
Student Workers for Manual Weed Pulling, monitoring, etc. - $8,416
Miscellaneous Tools and use of State Vehicles for Students: $2,200
Student Intern to plan and conduct research component of project:
150 hrs @ $12/hour = $1,800/semester for fall, summer, spring 2011 semesters.
Total student intern cost: $1,800 x 3 semesters = $5,400
Total cost (spring, summer, fall 2011): $26,952
Total Costs per Semester: $8,984
Green Fund Project Timeline for Sustainable Landscape Maintenance Pilot Project Spring semester 2011 – Research existing documents and new sources to confirm best methods for sustainable
landscape maintenance; develop detailed maintenance plan; develop methods to document processes and measure results; begin application of methods to pilot plots; document processes and measure results; maintain complete and accurate project documentation. Summer semester 2011 – Continue application of methods to pilot plots; document processes and measure results; maintain complete and accurate documentation; begin drafting project report. Summer semester 2011 – Finish application of methods to pilot plots; document processes and measure results;
maintain complete and accurate project documentation; produce final project report.
Green Fund Project Maintenance and Operations Plan for Sustainable Landscape Maintenance Pilot Project
A) What maintenance will be needed (how often and for how long)? This project is a variation on ongoing landscape maintenance operations that occur every year. Only the details of the methods used will be different for purposes of this project.
B) Who is responsible for the maintenance? NAU Grounds department.
C) What costs are associated with the maintenance and where will funding come from? All additional costs for special procedures of this project are accounted for in the project budget. Depending on the results of the pilot project, NAU Grounds may continue with the modified methodology or revert to standard methods.
Appendix C: 1
Plot Measuring
Each plot was measured using a measuring wheel calibrated in feet. The plots were walked on the inside of the
cement surrounding it. Each side was measured and drawn on paper. To get the angles of each area within a plot,
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the corners were measured on each side (a and b) and then the distance between the endpoints on each side was
measured (c). These measurements for the sides and width were placed into Equation 1 to calculate the angle:
Equation 1
Equation 1 is made true by the Law of Cosines, which is an extension of the Pythagorean Theorem. This equation
was chosen because it has been proven to be correct since the 19th
century, which means that the equation does
work and by rearranging the law of cosines you can solve for any side or angle needed. This equation is based off
of Figure 1: in this picture, the angle γ (gamma) is shown along with the measured sides and width.
Figure 1
Figure 1 shows a triangle with sides of length a, b, and c and, angles of α, β, and γ respectively, where a and b are
the outside lengths of the corner and c is the width and γ is the angle we solved for. There was slight error within
the measuring of the sides and width of each corner. For one inch there was a 6% range of error present.
To find the area of each plot, the lengths of all sides and angles were drawn into Devinci: Almode, an appraisal
program which automatically calculates the area when the drawing is finished. Each of the plots were very
different sizes and shapes which meant that some semi-circular corners needed to be changed to 90 degree corners
to aid in the drawing of the plots. This had to be done because there is no formula to calculate the radius of the
semi-circular corners, and they could not be accurately measured. The program need to have each line and angle
added separately; thus, by making the angles 90 degrees instead of semi-circles, it made the measurements more
accurate. However, making the side lengths more accurate made the areas slightly inaccurate. Each area has an