A Few Comments about the OAS-CICAD Study of the Impact of Glyphosate used in the Eradication of Illicit Crops in Colombia
TNI Website, 30 May 2005
See also CIDAD Study on Glyphosate
- The evaluation included no studies of the risk of direct exposure for farmers and others susceptible to the effects of aerial spraying.
To address this point, according to the report:
"Human exposures to glyphosate were estimated from extensive and well-documented studies in other jurisdictions and are judged to be accurate with respect to bystanders who are directly over-sprayed. Exposures were judged to be small and, in all cases, considerably below thresholds of concern." (1)
- The document does not identify the sources of these "extensive and well-documented studies in other jurisdictions;" given the shortcomings of this evaluation's assessment of the risk to people who have been exposed, this constitutes a basic error, as the reference is used to compensate for the lack of field studies by the authors of the report.
- A question arises from the CICAD team's inference: Under what parameters is exposure considered small? And if that is the case, why are these exposures taken as a valid reference for evaluating exposure risk?
The conclusion is that the report suffers from severe shortcomings in this area, and the effort to fill the gaps reveals serious deficiencies in the use and analysis of the reference documentation, as shown by the cited text.
There is no mention of field research in Colombia, in a tropical environment, on the behavior of the mixture used in the spraying; instead, the report alludes to experiments carried out in other environments, and it is not clear whether those experiments were done with the same mixture or with the ingredients and surfactants separately.
Data regarding the chemicals used in coca and poppy production and processing are from the National Narcotics Office (Dirección Nacional de Estupefacientes, DNE), which to date has produced no serious study of impacts, beyond a list of the chemicals believed to be used in these processes. Nor is there updated information about the use of chemicals, an area that is constantly changing. In other words, reference is made to a source that includes many generalities and has little credibility.
Unsupported statements are made, such as "experience with spray equipment of the type used in Colombia suggests (sic) that spray drift will be minimal," and reference is made to a document dating back to 1990, when spraying conditions, droplet size, altitude, glyphosate concentration, etc., were very different. In addition, specific information is not provided about how the sample, supposedly of 22 fields, used for measuring errors in spraying (in 2002) was selected. Because complaints from the affected population, which in general terms almost always refers to errors because of herbicide spraying over extensive areas of pasture and other legal crops, are not taken into consideration, this leaves much to be desired as a solid argument for "demonstrating" that there have been no major errors and that it can therefore be assumed that there never will be any. (2)
Discussion of risks from glyphosate exposure is based on secondary sources under test conditions that certainly differ in such characteristics as the physical conditions of children and colonists, with an unbalanced diet and exposure to tropical diseases (malaria, diarrhea, fever, etc.), a scenario in which the specific health effects of exposure to the indiscriminate use of this mixture should be established. There is no in-depth analysis under these conditions, and the study refers to an ideal type of person that bears no resemblance to these characteristics.
With regard to the impact of spraying over surface water used for consumption, the following conclusion is drawn:
"Exposures from drinking of untreated surface waters in areas where eradication spraying takes place are judged to be small and infrequent." (3)
Nonetheless, in light of the deficient sample used for the surface water analysis, that is, in areas peripheral to the zones where spraying has taken place, it is surprising that such a broad conclusion is drawn.
These shortcomings are acknowledged in the report when it states that:
"Uncertainties in the exposure characterization lie in lack of precise measurements of the proximity of sprayed fields to surface waters and the proportion of treated areas that are in close proximity to these surface waters. The sampling of the surface waters only took place for a period of 24 weeks and only 5 locations were sampled in this way. Although two of these were scheduled to be sprayed, only one location was treated during the sampling period. For logistical reasons, it was also not possible to sample close to the application sites. If sampling had been conducted at more sites closer to the sprayed fields and over a longer time period, residues may have been detected more frequently." (4)
The study shows no correlation among the occupation of land by coca farmers, population size, the use of surface water for consumption, the relationship between crop areas and the location of this water (all of which requires mapping showing these relationships, which the study does not present), so as to develop tests based on samples of this water and arrive at conclusions that are really based on field study.
The study was done under highly politicized circumstances and under pressure to show the mixture used for aerial spraying of illegal crops in Colombia to be harmless. An attempt is made to resolve this issue under an obsolete premise of "scientific rigor," which is reduced to separating the social, economic and political problems involved on the grounds that they (in themselves) do not quality for scientific treatment. This premise undermines the seriousness of the report. By setting this standard of scientific rigor and making an effort to measure the phenomenon, it leaves out aspects closely related to the policy, such as the serious problem of the movement of crops, which leads to expanded spraying, resulting in deforestation and the burning of fragile soil and increasing environmental damage. In other words, "science" is stripped of its objectivity and serves - in itself - as the court that will determine who is right in this debate. In practice, however, the evaluators serve as judge and jury, since the evaluation in no way constitutes an independent exercise, but, as indicated throughout this document, seeks only to establish the harmlessness of the Round Up used for spraying illegal crops.
Finally, to suggest that the spraying program can be reduced to the act of spraying glyphosate is a glaring error. Spraying in Colombia also implies the presence of five armed combat helicopters, which could be explained by the presence of armed groups in the fields of illegal crops, but which do not justify the climate of war also being waged against farmers. Spraying occurs in Colombia within the context of the fight against terrorism, and this places it in a specific political context that affects the civilian population and discredits peaceful alternatives, such as manual eradication; this technique has been tacitly dismissed in the report, as its conclusions do not take into account this form of eradication, which is currently not used in Colombia. This type of eradication creates the least environmental and health impact for farmers and, in general, for all people exposed. This is such a "scientific" study - done in the name of alleged "neutrality" - that it ends up being extremely political, to the extent that it actually takes a position in favor of chemical warfare, completely ignoring its effects in comparison to those of other techniques, such as manual eradication.
While the reference source for establishing the effects of consumption of untreated water affected by spraying is North America, the authors believed that they had adjusted their analysis for Colombia's characteristics of Colombia merely by taking as a reference the increased dosage used in that country. Once again, characteristics of the US environment are extrapolated, without taking into account environmental conditions, the health of the coca-growing population or other factors, and these circumstances are "adjusted" only with regard to the dosage used.
In addition, the concentration of glyphosate in the mixture used on illegal crops is not taken into account; this invalidates any inference drawn from the formulations used in the United States or for agricultural purposes.
Translated by Barbara Fraser
1. See "Environmental and Human Health Assessment of the Aerial Spray Program for Coca and Poppy Control in Colombia." Report prepared by the Inter-American Drug Abuse Control Commission (CICAD), a division of the Organization of American States (OAS), March 31, 2005, Page 92.
2. OAS-CICAD report, page 32.
3. IIbid., pages 41-42.
4. Ibid., page 92.