28th September, 1997

Mr Ian Woodward
Director of Environment and and Land Management
Department of Environment and Land Management
188 Collins Street
HOBART Tas 7000

Robert and I received a copy of the advice you gave to Mr Tony Cannon of Forest Enterprises on Thursday 25th September, 1997. We now appeal your decision as a matter of urgency. The reasons are as follows:

You talk as if Roundup = Glyphosate. It's not! At the very least we expect the product planned for application next to our drinking water to be addressed. How safe is Roundup Biactive? Is it appropriate that this product (with all its chemical compenents) be applied 10 metres from our drinking water in a permanently wet land basin subject to heavy surface runoff from the proposed area to be sprayed? Why haven't you queried the toxicity and application of Roundup Biactive?

The control testing done with our tank and drinking water involved testing for glyphosate and simazine only. This is inadequate. We require tests to be done for the products that will actually be applied: Roundup Biactive and the complete Simazine product and their respective metabolites/chemical interractions.

We have not been advised of any ogoing testing program. We need to know what this is as aerial spraying in this area occurs on a regular basis, because:

1. residents tanks (including our own) are already contaminated
2. because of the extremely close proximity in which Roundup will be applied around our dam and
3. the persistent nature of Roundup and at least one metabolite.

We have sought assistance from the DPIF and from the Minister for Community and Health Services. The DPIF have not provided the information we seek regarding chemical safety nor did Dr Mark Jacobs (Director Environmental and Public Health) propose any action that the Forest Enterprises could take to protect our water and environment. I note that you have contacted the very same sources and they have again failed yet again to provide satisfactory answers. The Librarian from the NRA, Judith Wood, informed me last Tuesday that it would not be appropriate to give me the names of the chemicals used to make up the surfactant in Roundup Biactive, since it was sensitive commercial information. However, she then transferred me to Database Section who failed to respond to my call.

You have stated that glyphosate binds readily to the soil to become biologically inactive. There is no reference to glyphosate becoming "biologically inactive" in any information received from the Registrar of Chemicals (neither written by Monsanto nor the NRA). However, there is evidence of the opposite case below. Neither is there proof that glyphosate will stay bound to the soil and NOT move from its location. I refer to the following (which is repeated below in information received from the internet and sent to you before you made your decision last week).

Movement of Roundup and its Persistence: "Soil Contamination Index" Glyphosate, Humans and Toxicological Effect http://www.envirolink.org/orgs/hecweb/archive/glyphos2.htm http://www.envirolink.org/orgs/hecweb/archive/glyphos1.htm

Page 14 of 32: "Glyphosate is thought to be "readily bound to many soils and clay minerals" 1 and therefore "immobile or slightly mobile in many soils" 1 this means that glyphosate will be unlikely to move away from the application site and contaminate water or soil elsewhere. However, a new study 29 paints a different picture. The researchers found that glyphosate bound readily to the four soils studied. However, desorption, (when glyphosate unbinds from soil particles) also occurred readily. In one soil 80 per cent of the added glyphosate desorbed in a two hour period. The study concludes that "this herbicide can be extensively mobile in the soil environment.."29.

AND...regarding Roundups persistent biological activity/toxicity, I refer to the following:

Glyphosate, Humans and Toxicological Effect http://www.envirolink.org/orgs/hecweb/archive/glyphos2.htm http://www.envirolink.org/orgs/hecweb/archive/glyphos1.htm

Glyphosate, Part 1, Toxicology By Caroline Cox Journal of Pesticide Reform Volume 15, No3, Fall 1995 Northwest Coalition for Alternatives to Pesticides, Eugene, OR. (References: at Web site above and in roundup.txt file)

Page 13 of 32 Effects on Non Target Animals: "The International Organisation for Biological Control found that exposure to freshly dried Roundup killed over 50 percent of three species of beneficial insects: a parasitoid wasp, a lacewing and a ladybug..35 Over 80 percent of a fourth species, a predatory beetle, was killed. ...Similar impacts on beneficial insects have been shown in field studies...36, 37, 38, 39, 41, 35,43

Page 32 of 32 Introduction: "Glyphosate containing products are acutely toxic to animals, including humans....two serious cases of fraud have occured in laboratories conducting toxicology and residue testing for glyphosate and glyphosate containing products....

***NOTE: There are plenty of references to very marked toxicity of Roundup to humans and animals in this document but I have not quoted them here as the information appears not to relate to Roundup Biactive...ie the surfactant used in the normal Roundup is mentioned. It does hightlight however the need to know the toxicity (and other info) about the surfactant in Roundup Biactive.

Page 30 of 32: "The mode of action of glyphosate is'not known at this time' 4 according to EPA....glyphosate also affects the enzyme systems found in animals and humans 14...

Page 28 of 32: Here a reference to lack of toxicological studies of commercial Glyphosate formulations. "When toxicology testing is not done using the product as it is actually used it is impossible to accurately assess its hazards.....

Page 28 of 32: Acute Toxicitiy to Laboratory Animals: "Commercial glyphosate-containing products are more acutely toxic than glyphosate alone 18,19...

Page 26 of 32..."Glyphosate is also toxic in long term studies...31,2

Page 25of 42.." Carcinogenity: There are no studies available to NCAP evaluating the carcinogenity of Roundup or other Glyphosate containing products. Without such tests the carcinogenity of glyphosate-containing products is unknown...

Mutagenicity: Laboratory studies of a variety of organisms have shown that glyphosate-containing products cause genetic damage 37

Page 24, 23 of 32..Reproductive: Laboratory studies have demonstrated a large number of effects of glyphosate on reproduction, including effects on mothers, fathers and offspring."29, 2, 42,4

Toxicology of glyphosate's major metabolite: (aminomethylphosphonic acid or AMPA) ...in subchronic tests on rats AMPA caused decreased weight gain in males; an increase in the acidity of urine in both males and females; an increase in the activity of an enzyme (lactic dehydrogenase) in both sexes; a decrease in liver weight in males at all doses tested; and excessive cell division in the lining of the urinary bladder and in part of the kidney in both sexes...... Persistance of AMPA: AMPA is much more persistent than glyphosate..studies found half life between 119 and 958 days.

Quality of Toxicological Testing of Glyphosate and Glyphosate-Containing Products Page 23 of 32: "Tests done on glyphosate to meet registration requirements have been associated with fraudulent practices 44, 46, 47, 48, 49,50 Although test of glysophate identified as fraudulent have been replaced these practices cast a shadow on the entire registration process.

Movement of Roundup and its Persistence: "Soil Contamination Index" Page 14 of 32: "Glyphosate is thought to be "readily bound to many soils and clay minerals" 1 and therefore "immobile or slightly mobile in many soils" 1 this means that glyphosate will be unlikely to move away from the application site and contaminate water or soil elsewhere. However, a new study 29 paints a different picture. The researchers found that glyphosate bound readily to the four soils studied. However, desorption, (when glyphosate unbinds from soil particles) also occurred readily. In one soil 80 per cent of the added glyphosate desorbed in a two hour period. The study concludes that "this herbicide can be extensively mobile in the soil environment.."29.

**************************_________***************************

I refer to a letter sent to Minister Bill Bonde by Annie Willock from the Clean Water Network. Lorinna dated 9th September, 1997. In her letter she states: "Monsanto, during their PR visit to Tasmania in 1995, admitted that while the glyphosate component of Roundup was tested for its toxicological effects, Roundup in its complete formulation remained untested".....she goes on to say: "The threat of contamination with metabolites of Roundup, including N-nitrosoglyphosate when combined with the soluble fertilisers possibly destined for use on the same plantation, seem to be dismissed by you, along with the concerns of the local residents..."

And from the internet last week action taken by the US Attorney General against Monsanto for misleading advertising of Roundup:

January 10, 1997

Monsanto Agrees to Change Ads and EPA Fines Northrup King

Monsanto Co. agreed to change its advertising for glyphosate- based products, including Roundup, in response to complaints by the New York Attorney General's office that the ads were misleading. Based on their investigation, the Attorney General's office felt that the advertising inaccurately portrayed Monsanto's glyphosate-containing products as safe and as not causing any harmful effects to people or the environment. According to the state, the ads also implied

that the risks of products such as Roundup are the same as those of the active ingredient, glyphosate, and do not take into account the possible risks associated with the product's inert ingredients.

As part of the agreement, Monsanto will discontinue the use of terms such as "biodegradable" and "environmentally friendly" in all advertising of glyphosate-containing products in New York state and will pay $50,000 toward the state's costs of pursuing the case. The Attorney General has been challenging the ads since 1991.

According to a 1993 report published by the School of Public Health at the University of California, Berkeley, glyphosate was the third most commonly-reported cause of pesticide illness among agricultural workers. Another study from the School of Public Health found that glyphosate was the most commonly reported cause of pesticide illness among landscape maintenance workers. (Both studies were based on data collected between 1984 and 1990.)

Monsanto say that the average soil half-life (time for half of the applied amount of glyphosate to degrade) is about 60 days. (Reference: Roundup Health and Environmental Safety Bulletin p.4) I would presume that if a product has not broken down it is still biologically active.

A photocopied page received from Dr Rod Oliver (headed p.1340 Chapter 20 Herbicides) states "The Environmental Protection Agency has classified glyphosate as a Category C (possible human) carcinogen (National Research Council, 1987)." It adds that this category comes about because of "a tumorigenic response to one species".

And from: E X T O X N E T EXTENSION TOXICOLOGY NETWORK http://www.extoxnet.edu

A Pesticide Information Project of Cooperative Extension Offices at Cornell University, Michigan State University, Oregon State University, and University of California at Davis

"Glyphosate is a moderately toxic herbicide.... it can cause significant eye irritation.... Roundup was more toxic to fish than was glyphosate..... The time it takes for half of the product to break down ranges from 1 to 174 days.... The herbicide could move when attached to soil particles in erosion run-off...."

We are still waiting for the names of the chemicals used as surfactants, their toxicity, the toxicity of their breakdown products and environmental fate. Also any chemical interractions that may occur between all of these chemicals and any fertiliser that Forest Enterprises may be planning to apply. What information has been sent comes via Monsanto and the National Registration Authority and has gaps in it a mile wide (and obviously does not address the information we are now seeking). We want clear and unequivocal evidence of the safety of these chemicals.

You have not acknowledged the information we gave you (via John Dobson) detailing concerns about the safety of Roundup and Glyphosate to HUMANS and the video sent clearly showing surface water runoff from the cultivated mounds into the dam that occurred two weeks ago. This runoff occurs repeatedly in wet weather. We need to know why you did not accept this information as evidence of sufficient hazard to our water supply when you made your decision to approve Forest Enterprises' spray plan. If you regard thisevidence as inadequate then we require that you inform us of your reasons and provide adequate evidence of the safety of the spraying plan.

We reiterate that we do not want any fertiliser applied around our dam. Please acknowledge this request and your decision and reasons for any decision in this matter. I forward to you information clearly stating the effects that nitrates have on human health.

What is your response the muddy runoff occuring from the cultivated area (targetted for spraying) into the permanent creek in front of our house? Surely, if it is true that glyphosate binds to soil it will surely go with the soil into the water bodies! Why has Roundup not been explicity banned from this area?

We are still seeking the fulfillment of orders from the Forest Practices Board for Forest Enterprises to remedy the heavy and muddy runoff occuring from the access track into our dam.

Again, we request the above information to satisy our concerns that the spray program submitted by Forest Enterprises incorporates measures that ensure lack of contamination of our drinking water. You have failed to do this to date. We ask that the company be prevented from applying the chemicals in this catchment until our concerns are addressed adequately.

Yours faithfully

Brenda Rosser and Rob Kildare
923 West Calder Road
WYNYARD 7325
Phone: (03) 64384185 home
Fax: Same as phone number but need to ring beforehand to allow modem to be setup.
Email: brendro@students.nwit.dve.tas.gov.au (Monday/Tuesday)
or brenda.rosser@employment.gov.au (Wednesday/Thursday/Friday)

Enc info on nitrates.
Envirolink Roundup/Glyphosate file
Forest Practices file...re storm conditions

Leter to David Parsley requesting information

cc: Susan Gunter, solicitor, Environmental Defenders Office, Hobart Dr Rod Oliver, Registrar of Chemicals, DPIF, Launceston. Mr Tony Cannon Forest Enterprises (Tasmania) Pty Ltd Margaret Dekker and Rod Smith, 7NT, Burnie, Tasmania Lara Giddings, Shadow Minister for the Environment, Tasmania Brenton Best, MLA, Tasmania Mr Mike Gard, ALP, Burnie Tasmania Mr Peter Hodman, Minister for the Environment, Tasmania Mr John Beswick, Minister for Forests, Tasmania Ms Peg Putt, Shadow Minister for Forests Ms Christine Milne, Leader of the Greens, Tasmania Luned James and Bill Meldrum, The Advocate newspaper, Burnie, Tasmania Ms Annie Willock, Clean Water Network, Lorinna, Tasmania Doctor Alison Turner, CEO, National Registration Authority