2,4-D, 2-Ethylhexyl Ester
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Application for Temporary Derogation – 2,4-D, 2-ethylhexyl ester July 23, 2014 This is a joint application for a temporary derogation to use a ‘Highly Hazardous’ Pesticide on FSC- certified forestland. The summary below provides a high level overview of the demonstrated need of the pesticide and will include stakeholder consultation feedback following the close of the consultation period. Each forest management certificate holder has submitted a separate application providing more specific information that demonstrates the need for the pesticide in their certified forest operations as well as explaining their considerations of alternative control methods and preventative measures. The applications for derogation can be found at the end of this document as it was submitted by the forest manager. Summary The joint application has been submitted by the following forest managers for a temporary derogation to use herbicide formulations containing the active ingredient of 2,4-D, 2-ethylhexyl ester, and each application submitted can be found by navigating to the corresponding page number provided within the list below. Certificate Holder Application Page Collins Almanor Forest 4 Collins Lakeview Forest 14 Coquille Indian Tribe 21 Red River Forests and Shasta Forests 33 Roseburg Resource Company 62 The forest managers applying for this derogation manage certified forest operations in California and Oregon, and use herbicide formulations containing the active ingredient 2,4-D, 2-ethylhexyl ester for conifer release from competition with other vegetation. The use of 2,4-D, 2-ethylhexyl ester has proven to be the only economically, environmentally, socially and technically feasible way of controlling specific organisms which are causing severe damage in natural forests. 2,4-D Ester Overview The common herbicide 2,4-D (2,4-dichlorophenoxyacetic acid) is included in the FSC-supported definition of chlorinated hydrocarbon and therefore is identified as a highly hazardous pesticide. There is much evidence supporting the claims that 2,4-D ester formulations are generally safe for use in forestry situations and apart from being a chlorinated hydrocarbon does not otherwise meet thresholds for highly hazardous as included in Annex 1 of FSC-GUI-30-001. 2,4-D is a broadleaf herbicide. Many grasses and grass crops are not affected by 2,4-D, and, thus, it is used extensively in lawn care products (e.g. “weed and feed”) and with grass crops such as barley and wheat. 2,4-D is the most commonly used pesticide in the non-agriculture sectors (Home and Garden and Industry/Commercial/Government) (estimated 24-39 million pounds annually). In the agricultural sector, it is the fourth most commonly used herbicide (28-33 million pounds annually). Ester formulations of 2,4-D pose a different suite of concerns compared to amine formulations. Ester formulations are highly volatile and can drift from target sites for several days after application. Many, but not all, states have banned the use of high-volatile ester formulations and have discouraged use of lower volatile esters in sensitive areas. Demonstrated Need Herbicide treatments containing the 2,4-D formulation 2-ethylhexyl ester have proven to be the most effective way for forest managers in California and Oregon to release conifer seedlings from competition with broadleaf brush and weeds, in particular manzanita. Following a stand replacing event, such as a fire or harvest, manzanita and other brush vegetation tend to move in and dominate the available water and nutrient resources; overtopping the young conifer seedlings blocking out sunlight. In unchecked situations where brush vegetation is not controlled, the conifer seedlings struggle to survive due to a moisture stress and increased susceptibility to insect and disease. This in turn leaves the forests in poor health and in non-forested conditions where natural forest should normally occur. Herbicide applications of 2,4-D, 2-ethylhexyl ester are able to selectively target manzanita and other unwanted brush vegetation while not harming the young conifer regrowth. The selectivity and effectiveness of 2,4-D, 2-ethylhexyl ester is the preferable option compared to other less effective herbicide formulations. 2,4-D, 2-ethylhexyl ester does not harm the desirable plant community species and applications only need to be done once or twice during the lifetime of the stand. Other herbicide formulations that have been tested as alternatives tend to need a higher frequency of applications at higher concentrations and volumes and ultimately they do not do as good a job of selectively targeting broadleaf brush. Often seedlings are also harmed and left stressed due to the herbicide treatments when other chemicals are used. Specified Controls to Mitigate the Hazard US federal, state, and county laws strictly regulate the use of pesticides. The regulations include specific requirements around concentration levels, human health and safety precautions, and environmental protections. 2,4-D, 2-ethylhexyl ester has been approved for use in forestry practice by the Environmental Protection Agency (EPA), the California Department of Pesticide Regulation (CDPR) and the Oregon Department of Agriculture. All forest managers applying for the temporary derogation follow all laws required by these agencies during the application of the herbicide treatment. Environmental impacts to water are mitigated through the use of buffer zones during application. Licensed applicators are trained and instructed on how to correctly apply the herbicide to the target species as well as how to keep out of protected sensitive areas and buffer zones around water features. Post application monitoring is conducted to ensure environmental impacts are minimized and/or negated. Program to Identify Alternatives Two research organizations in California were formed to assist forest managers in researching alternatives to the use of pesticides containing active ingredients found on the FSC ‘Highly Hazardous’ Pesticides list. The two organizations are the Sierra Cascade Intensive Forest Management Research Cooperative and the Certified Forests Cooperative. Numerous studies and research has been conducted on alternative chemical treatment methods as well as mechanical treatment. The research has shown that while there are similar herbicide treatments available for the release of conifers, these herbicides are less effective and less selective. Using other herbicides leads to higher amounts and frequency with which the herbicides need to be applied as well as significantly higher costs. Mechanical treatments are not only impractical due to the high cost but the treatments are ineffective as the target species readily resprouts after treatment. Mechanical treatments can also cause great environmental degradation on the landscape due to repeated entry into the stand. At this time, herbicide applications containing 2,4-D, 2-ethylhexyl ester remains the most effective tool available to release conifer seedlings. Stakeholder support Stakeholders are asked to comment on the joint application and submit them to Lori Knosalla at FSC US at [email protected]. At this time, the section for stakeholder comments remains blank. Once comments are received following the close of the consultation, all comments will be included within this section of the application. Collins Almanor Forest – Application form for a temporary derogation to use 2,4-D, 2-ethylhexyl ester A. General Requirements Application Submission 7/01/14 for public consultation Date: SCS GLOBAL SERVICES Name, and contact details Brendan Grady of certification body 2000 Powell Street, Ste. 600 requesting a temporary Emeryville, CA 94608 USA derogation: [email protected] www.SCSglobalServices.com 2,4-D, 2-ethylhexyl ester Active ingredient for which a derogation is being requested: Weedone LV6 EC (liquid emulsifiable concentrate, 6 lb. acid equivalent) Trade name and Weedone LV4 EC (liquid emulsifiable concentrate, 4 lb. acid equivalent) formulation type of the Solve 2,4-D, 2-ethylhexyl ester (liquid low volatile ester, 4 lb. acid active ingredient or equivalent) formulation: Aerial – broadcast application (using helicopter). Method of application and Ground – back pack (broadcast and spot treatments). application equipment: Target species generally include grasses, forbs, and various brush species. Common and scientific Typical brush species targeted for control may include one, or a name of the pest species: combination, of the following: pinemat manzanita (Arctostaphylos nevadensis) greenleaf manzanita (Arctostaphylos patula), chinkapin (Castanopsis sempervirens), deerbrush (Ceanothus integerrimus), snow brush (Ceanothus velutinus), huckleberry oak (Quercus vaccinifolia), Pacific Dogwood (Cornus nuttallii), mountain whitethorn (Ceanothus cordulatus), and squaw carpet (Ceanothus prostrates). Collins Almanor Forest Name and FSC certification SCS-FM/COC-00006N codes of certificate holders for which a temporary derogation is being requested: Scope for which a temporary derogation is being requested: Collins Almanor Forest (Cub Fire 2008) The purpose of herbicide use on CAF lands is not to eliminate brush, forb and weed species from the landscape. Rather, herbicides are needed to give seedlings an opportunity to outgrow these competitors and get up to a superior height where the trees are able to control the site by the natural process of dominating available sunlight and water. Herbicide use remains a tool to be utilized in the management