Environmental Engineering Reference
In-Depth Information
carcasses. The reader can fi nd a more complete list of known kills, especially those that occurred
in the United States, in the US EPA Docket Offi ce (Phone number:01-703-305-5805) (http://www
.regulations.gov/search/Regs/home.html#docketDetail?R
EPA-HQ-OPP-2005-0162).
The increasing number of reported kills over time is not an indication of greater carbofuran
usage. Actually, the kill reports peaked at a time when use of Furadan 10G in corn had already
dropped considerably (US EPA 1989). Rather, the increase in reported kills was directly linked to
the EPA's Special Review of the granular products in that country. In response to the Special Review,
some (but clearly not all) State agencies became aware of the importance of reporting die-offs to
the EPA. Similarly, some US FWS fi eld personnel also learned that the EPA was actively seeking
data that documented both the risks and benefi ts associated with granular carbofuran. It is notewor-
thy that few reports of kills are available relative to the large area annually treated with carbofuran.
However, systematic research by FMC and others (refer back to Section 8.2.1) has conclusively
shown that bird kills occurring after the use of carbofuran granules are largely unavoidable. The US
FWS offered the following opinion in response to a proposal by the US EPA to grant an emergency
request to reintroduce carbofuran in rice:
The Service does not believe that granular carbofuran can be used without impacts to
nontarget organisms, notably trust resources protected under the Endangered Species
Act, the Bald and Golden Eagle Protection Act, and the Migratory Bird Treaty Act.
[Note from the author: The words 'trust resource' refer to a natural resource protected by federal
legislation.]
(Kenneth Stansell, Acting Deputy Director, Fish and Wildlife Service, United States Department
of the Interior in Letter to Jim Jones, Director, Offi ce of Pesticide programs, US Environmental
Protection Agency, 16 March 2006).
This echoed a position of the US FWS, established more than a decade earlier:
Adverse effects to birds and other fauna associated with fl owable carbofuran have
been established in the laboratory, in the fi eld, and in the courts. As with granular
formulations, there are no known conditions under which fl owable carbofuran can be
used without resulting in unreasonable adverse effects to non-target organisms.
(Richard N. Smith, Deputy Director, Fish and Wildlife Service, United States Department of the
Interior in Letter to Linda Fischer, Assistant Administrator, Offi ce of Pesticides and Toxic Substances,
US Environmental Protection Agency, 10 March 1992).
As a result of the Special Review, some farmers in the US have reported observations of mass
mortality notwithstanding that FMC asked farmers to support the product (Mineau 1993). Clearly,
the absolute number of incidents involving carbofuran that have come to the attention of US or
Canadian authorities is only a crude gauge of the wildlife loss resulting from the use of this insec-
ticide. Therefore, one should not consider kill reports as a quantitative measure of the number of
birds killed by carbofuran. Rather, these reports provide a qualitative indication of the wide breadth
of circumstances (e.g., bird species, crops and geographic areas) whereby investigators have docu-
mented die-offs. The following reports also exclude intentional misuses of carbofuran in which
the evidence indicates that people used the chemical specifi cally to kill vertebrate 'nuisance' spe-
cies. We summarise the issue of intentional misuses in a separate section of this review (refer to
Section 8.6, and this subject is extensively detailed elsewhere in this topic). Other cases fall into a
category that one might consider to be 'technical misuses'. These are situations whereby farmers
did not follow the label to the letter, although there was no obvious intent of harm on their part. For
example, if a US farmer or applicator was not certifi ed to use 'Restricted Use' products (a category
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