2004 Department of State Report to EPA on Human Health and Environmental Monitoring Related to the Colombian Illicit Crop Eradication Program
Human Health Studies
The Government of Colombia, with the assistance of the Department of State, is conducting an epidemiological study to explore the possible effects of glyphosate on human health as a result of the aerial spraying. The study was initiated in part as a response to EPA recommendations in EPA's "2002 Analysis," and is also required by the Government of Colombia's Environmental Management Plan for Aerial Eradication (EMP). The study was designed under the supervision of the Government of Colombia's Ministry of Social Protection and the National Institute of Health (INS). The INS Laboratory of Environmental Health is conducting epidemiological research through descriptive case studies of the populations of areas where spraying takes place. The specific goals of the study are to describe the clinical symptoms of human exposure to glyphosate from aerial spraying; to estimate the exposure of human populations of areas sprayed; and to detect possible cases of acute pesticide poisoning from other pesticides used in areas where aerial spraying takes place.
As part of the epidemiological study, INS and Embassy-hired toxicologists train physicians and environmental health personnel who serve the populations of these areas. The training takes place in weeklong workshops that cover toxicology, classification of pesticides, prevention, diagnosis and recognition of pesticide poisoning, clinical management, epidemiological considerations and procedures for the study of an outbreak, glyphosate toxicological facts, and a risk assessment of aerial application of glyphosate for people and the environment. As of the end of July 2004, this initiative has trained 473 health care professionals in these seminars.
A document outlining the scope of work and methodology for the INS epidemiological study is included as Attachment 1. Attachment 2 is a copy of the INS Advance Report of the Evaluation of Human Health Effects of Glyphosate And Other Pesticides in Zones of Influence of the Illicit Crop Eradication Program, which provides a status report of the program's activities. Attachment 3 is a copy of the survey used by INS officials to evaluate potential participants and Attachment 4 is an English language version of one of the presentations used for training of public health officials.
In addition, the U.S. Embassy continues to investigate any and all cases of human health damage related to the spray program that are brought to the attention of the Embassy with sufficient details to permit follow-up research. To date, no relation of reported human health problems to spraying has been substantiated by the rigorous evaluations of toxicologists hired by the Embassy's Narcotics Affairs Section (NAS). Since the April 9, 2003 State Department submission of materials to EPA for EPA's 2003 analysis, there have only been two such cases of human health complaints. The first was a complaint of poisoning from coca spraying in San Pablo (Bolivar Department). The toxicologist's report from this investigation was included in the Secretary's 2003 Certification to Congress but the complaint and follow-up study took place after the Department's submission of materials to EPA. After review of the clinical files, laboratory tests, and interviews with attending physicians, the toxicologist concluded that the patient died from symptoms unrelated to possible glyphosate poisoning. His report is enclosed as Attachment 5.
The second complaint -- alleging human health (and legal crop) damage from spraying of coca in Orito (Putumayo Department) -- was reported in Colombia's leading daily newspaper, "El Tiempo" on May 10, 2004. The Embassy immediately responded by sending a verification team to Orito on May 11 to speak with the individuals interviewed in the newspaper article. This team, composed of representatives from NAS, an Embassy-hired toxicologist, the Government of Colombia's Alternative Development Agency (PDA), the Colombian National Police, and local government representatives, found that the allegations were unfounded and that interviewees misled the reporter to discredit the spray program and discourage further law enforcement activity against illicit crops in the area. A May 12 letter from the PDA Alternative Development Director to NAS thanking the Embassy for its rapid attention to this complaint is included as Attachment 6.
Spray Program Soil and Water Studies
As part of the spray program's compliance with the Government of Colombia's Environmental Management Plan for the Aerial Eradication of Illicit Crops (EMP), NAS and the Government of Colombia conduct analyses of soils and water in areas where coca is sprayed. The purpose of these studies is twofold. Initial tests determine the levels of glyphosate and AMPA (amino-methyl phosphonic acid - the principal metabolite of glyphosate and an indicator of the natural degradation of that herbicide in soils) to understand the persistence of glyphosate in the Colombian soils and water in sprayed areas. In addition, further studies assess the physio-chemical properties of the samples (percentages of sand, clay, and mud, pH level, percentage of interchangeable acid saturation, total phosphate and usable phosphate content, percentage of organic material, total nitrogen level, catatonic interchange capacity, mineralization index, and nitrate, ammonium, calcium, magnesium, potassium, and sodium content).
These studies increase the public's understanding of glyphosate's transformation and rate of decay in Colombian soil and help answer questions about any significant modification of the properties of the soil associated with the spray program. The soil analyses determined that soils contained acceptable levels of glyphosate and AMPA even shortly after spraying, that glyphosate degrades over time in Colombian soils, and that there are no appreciable significant changes in the properties of the soil due to the glyphosate used by the spray program.
An inter-agency committee of Government of Colombia agencies, including the Ministry of Environment, Housing, and Territorial Development (MMA), the Institute of Agriculture and Husbandry (ICA), the National Directorate of Dangerous Drugs (DNE), and the Colombian National Police (CNP), collected soil and water samples in the field. The laboratory studies were conducted by three different labs: the USDA Agricultural Research Service (USDA-ARS) laboratory at the University of Mississippi conducted glyphosate and AMPA analysis in soils; the Government of Colombia's Augustin Codazzi Geographic Institute (IGAC) National Soils Laboratory Division conducted physio-chemical analysis of soil samples, and the Government of Colombia's National Institute of Health (INS) conducted glyphosate and AMPA analysis of water samples.
The 2004 NAS/CNP report from the soil and water sampling field study is enclosed as Attachment 7. The USDA-ARS soil sampling results and the IGAC National Soils Laboratory Division soil analysis results are attachments to that report. Attachment 8 is the protocol followed for soil sampling for glyphosate and AMPA residue analysis, developed by the MMA's Institute Of Hydrology, Meteorology, and Environmental Studies (IDEAM). Attachment 9 is the protocol followed for water sampling for analysis of glyphosate and AMPA residue, developed by the Government of Colombia's Institute of Agriculture and Husbandry (ICA).
Independent Soil and Water Analysis:
For several months in 2002, the Government of Colombia temporarily reduced the level of glyphosate in the spray mixture used to eradicate coca, based on a determination from ICA that the 10.4 liters per hectare used by the spray program was excessive and that 8.0 liters per hectare was sufficient to effectively control the coca crop. The CNP and NAS appealed that decision based on USDA and Government of Colombia field research to determine the appropriate glyphosate dose for Colombia's illicit crop eradication program and on years of subsequent field verifications. The Government of Colombia authorized a reversion to the 10.4 liters per hectare on January 30, 2002, with the condition that further analysis be performed by a competent independent entity within the next 12 months. In June 2004, the Sociedad de Palmas, an agricultural consulting firm, completed this review of the efficacy of illicit coca spraying using both the 8.0 liters per hectare and 10.4 liters per hectare doses. This assessment determined that under actual field conditions, 8.0 liters per hectare is insufficient to effectively control coca and 10.4 liters per hectare is more appropriate. The study also determined through soil and water tests that the 10.4 liters per hectare dose does not cause contamination of the soil, water or adjacent native plant life. Attachment 10 is an English language version of the final report from the Sociedad las Palmas from that company's efficacy test of the doses of glyphosate on illicit crops.
Spray Program Compliance with the EMP
The 2004 Appropriations Act also requires that the Department of State consult with EPA on whether the spray program is being carried out in accordance with the Government of Colombia's Environmental Management Plan for the Aerial Eradication of Illicit Crops (EMP). The Department of State provided EPA an English language version of the EMP in late 2003. EPA responded to the Department of State in a February 23, 2004 letter: "we believe the Plan contains appropriate types of activities for a pesticide spray program. The information in the EMP is generally in agreement with information provided to EPA for the previous consultations and discussed in EPA's 2002 and 2003 written assessments." This letter is enclosed as Attachment 11.The conditions that allowed EPA to make this judgment remain in place at the current time, and on July 26, 2004 the Minister of the Environment, Housing, and Territorial Development ruled that the illicit crop eradication project is being conducted in compliance with the EMP. That Ruling No. 707 (an English version of which is enclosed as Attachment 12) reads:
The entities responsible for executing the Illicit Crop Eradication Program Using Aerial Spraying with the Herbicide Glyphosate - PECIG - are currently complying with the measures established in the Environmental Management Plan imposed by this Ministry, the purpose of which is preventing, mitigating, controlling, offsetting, and correcting any possible negative environmental effects or impacts which might result from eradicating illicit crops. (p. 26)
EPA's letter of February 23, 2003 provided two specific comments to State regarding the EMP. In the first, EPA recommended that State investigate with the manufacturer and the Government of Colombia methods for properly disposing of empty glyphosate containers. As a response to this recommendation, State is currently working with the glyphosate supplier and the Government of Colombia to establish a new mechanism for retrieval and safe disposal of empty barrels according to Colombian law.
The second comment suggested a revision of EMP language regarding glyphosate's effect on non-target vegetation. Although EPA acknowledged in its 2003 analysis of the Colombian illicit crop eradication program that the spray program employs best management practices to avoid off target drift, EPA also recommend that the EMP be changed to reflect that glyphosate is a non-selective herbicide with potential to damage where it is applied. The Department of State has forwarded EPA's recommendation to the Government of Colombia and recommended that such an adjustment be included in any subsequent modification of the EMP.
"The Evaluation of Human Health Effects of Glyphosate and Other Pesticides in Zones of Influence of the Illicit Crop Eradication Program," The Government of Colombia's National Institute of Health, Bogota, July 2003.
"Advance Report of the Evaluation of Human Health Effects of Glyphosate and Other Pesticides in Zones of Influence of the Illicit Crop Eradication Program," The Government of Colombia's National Institute of Health, Bogota, July 2004.
Survey to Evaluate the Effects of Glyphosate and other Pesticides on Human Health in Zones of Influence of the Illicit Crop Eradication Program, The Government of Colombia's National Institute of Health, Bogota, 2003.
English language version of one of the Government of Colombia's National Institute of Health presentations used for training of public health officials in pesticide poisoning, December 2003.
Toxicologist's Report from Investigation of a Complaint of Poisoning From the Spraying of Coca in San Pablo (Bolivar Department), July 4, 2003.
Letter from the Government of Colombia's Alternative Development Agency (PDA) to Embassy Bogota's Narcotics Affairs Section, June 4, 2004.
Report from Interagency Soil and Water Sampling Field Study, U.S. Embassy Narcotics Affairs Section and CNP, 2004. [not available online]
USDA-ARS soil sampling results [Excel file]
Protocol for Water Sampling for Glyphosate and AMPA Residue Analysis, the Government of Colombia's Institute of Agriculture and Husbandry (ICA), Bogota, 2003.
Protocol for Soil Sampling for Glyphosate and AMPA Residue Analysis, the Government of Colombia's Ministry of the Environment's Institute of Hydrology, Meteorology And Environmental Studies (IDEAM), Bogota, 2003.
"Final Report: Agronomy Efficacy Test of the Doses of Glyphosate on Illicit Crops," Sociedad las Palmas, Bogota, June 2004. [PDF file]
EPA letter to INL regarding the spray program's compliance with the Government of Colombia's Environmental Management Plan for Illicit Crop Eradication, February 23, 2004.