Thursday, June 20, 2024

APA should pause ProcellaCOR permits to assess herbicide’s safety

Invasive Eurasian watermilfoil.

Re: Moratorium on ProcellaCOR Permitting Pending PFAS and Human Health and Ecological Impact Concerns  

Dear Adirondack Park Agency Executive Director Barbara Rice, 

The undersigned are writing to express our deep concern regarding the recently disclosed Minnesota Department of Agriculture (MDA) information on per- and polyfluoroalkyl substances (PFAS) within  pesticides, including florpyrauxifen-benzyl which is the active chemical ingredient in ProcellaCOR EC and  SE. As the Adirondack Park Agency is aware, ProcellaCOR EC is the less concentrated form of  ProcellaCOR SE, both of which are manufactured by the SePRO Corporation, the former of which has  been recently approved for use in several lakes in the Adirondacks.  

Partners call on the Adirondack Park Agency to place a moratorium on the issuance of additional permits  until further science can be reviewed and conducted to assess the impacts ProcellaCOR will have on the Adirondack waters that Park-residents and New York depend on for clean water.  

ProcellaCOR is part of a new class of plant growth hormones called synthetic auxins, which mimic plant  hormones, that have been engineered to be absorbed by target species such as Eurasian watermilfoil  (EWM). It differs from other herbicides because it causes the plant to undergo an accelerated rate of  growth by elongating a plant’s cells. This process eventually kills the plant rather than more traditional  herbicides, which poison a plant. ProcellaCOR was registered by the US Environmental Protection Agency (EPA) in 2018 as a Group 4 herbicide. 

In 2022, the EPA removed 12 chemicals found to contain PFAS from their list of registered inert  ingredients, which merely are all ingredients that are not the active ingredient in a given pesticide and  does not mean they are non-toxic, approved for use in nonfood pesticide products. None of the 12  chemicals were reported as currently being used in pesticides as inert ingredients, though the EPA  removed them to “prevent the introduction of these PFAS into pesticide formulations without additional  EPA review.” In addition, nine new PFAS were listed last year and seven new PFAS were listed in January  of this year. This demonstrates a rapidly emerging public health crisis that merits further research  before any additional ProcellaCOR permits are approved and are able to pose irreversible harm to our  water, wildlife, and to human health. 

PFAS are colloquially known as “forever chemicals” given their long-term persistence in the  environment. PFAS are defined as “a class of fluorinated chemicals containing at least one fully  fluorinated carbon atom” per the 2019 National Defense Act, Department of Environmental  Conservation (DEC), and the MDA definitions. The MDA expands the PFAS interpretation of a “fully  fluorinated carbon” to also describe unsaturated carbon bonds such as one fluorine atom on a benzene  ring, which ProcellaCOR exhibits. While this is not congruent with the current EPA interpretation from  US law, which does not clarify whether carbon atoms must be saturated or part of an alkyl chain, it is  consistent with emerging literature for a framework by which pharmaceuticals may be determined to contain PFAS1. A 2023 EPA explainer flyer warns, “The more we learn about PFAS chemicals, the more  we learn that certain PFAS can cause health risks even at very low levels. This is why anything we can do  to reduce PFAS in water, soil, and air, can have a meaningful impact on health.” 

We recognize the addition of testing concentrations at or near lake bottom depths post-treatment to  assess that concentrations are below recommended levels. However, this is not enough as impacts  beyond target areas require further study when wind and water carry the herbicide outside of the  application area and have impacts to native plant communities2. There is also concern for  bioaccumulation as the chemical is fat soluble and can persist in the environment for longer than  claimed because they bind to microplastics, which are present in Adirondack waters.  

Given these concerns and the unknown nature of its potential threats to environmental and human  health, the undersigned call for a moratorium on issuing any new permits for ProcellaCOR and other  possible PFAS-containing aquatic pesticides until more comprehensive information is available.

We urge the APA to reinforce long-term lake management plans containing a history of active management,  assess site suitability, and protect wetlands more rigorously through approaches that include hand  harvesting or DASH before and after treatment when applying herbicides.  

The current lack of in situ research is troubling and merits a long-term mesocosm-to-field study  encompassing benthic aquatic invertebrates, native plant species, and aquatic predators. The  mesocosm study must include hydrodynamic processes and lake characteristics to ascertain the impacts  of ProcellaCOR and its degradates on the ecology of aquatic systems in a more holistic sense. These  assessments must address bioaccumulation, food webs and predator/prey relationships, changes to  foraging behaviors, and shifts in food availability. This type of study shows the importance of chemicals  studied in their natural ecological contexts and can illuminate altered trophic cascades that may drive  biodiversity loss4. The undersigned groups request that the APA address these concerns at an upcoming  presentation to the board on ProcellaCOR. 

As federal guidelines and listings change, agencies in states such as Minnesota and Maine are taking the  lead as protectors of waters and health, and New York must follow suit. Invasive species such as  Eurasian water milfoil are threats to our waterways, but forever chemicals pose a threat to all. 

Sincerely, 

Raul J. Aguirre, Executive Director, Adirondack Council 

Adrienne Esposito, Executive Director, Citizens Campaign for the Environment 

Tracy Frisch, Chair, Clean Air Action Network of Glens Falls 

Bobbi Wilding, MS, Executive Director, Clean+Healthy 

Dr. John E. Kelly III, Chair, Lake George Association 

Chris Navitsky, PE, Lake George Waterkeeper 

Kathleen A. Curtis, LPN, Founder and President, Moms for a Nontoxic New York

Caitlin Ferrante, Conservation Program Manager, Sierra Club Atlantic Chapter 

Photo at top: Invasive Eurasian watermilfoil. Explorer file photo by Mike Lynch

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The Adirondack Almanack publishes occasional guest essays from Adirondack residents, visitors, and those with an interest in the Adirondack Park. Submissions should be directed to Almanack editor Melissa Hart at editor@adirondackalmanack.com




12 Responses

  1. Todd Eastman says:

    Shouldn’t the DEC the lead agency be the lead agencies in determining the safety and use of herbicides in state waters?

  2. Paul says:

    So, this is not just asking for an adjudicatory hearing at the APA to further review the current science behind this but for additional studies that would take decades? These kinds of groups are usually supportive of a science based approach. Here they are just outright saying that they do not trust the federal government. Interesting…

  3. AdirondackAl says:

    Does anyone know PFAS concentrations of Lake George WWTP effluent prior to discharge into the sand beds?

  4. Anthony says:

    DO NOT POISON OUR LAKES. This PFAs sounds just like when PFOA was being found out about in the teflon scare with dupont. Don’t let this happen again. Major companies care more about making money than they do the healthy ecosystem of our lakes. Also, who knows what the health effects could be on humans as well. Let’s come together and stop this nonsense.

  5. Stuart Cartwright says:

    Google “US EPA, Pesticide Product Label, Procellacor”. Read the product use instructions. From the manufacturer. It is scary. Keep it away from your vegetable gardens and compost piles, wear all kinds of protective gear to apply it, “fish suffocation” may happen, don’t use in a greenhouse or nursery, triple-rinse application containers after using then recycle, etc. Pretty scary warnings all around.

    Not to mention the “forever chemicals” PFAS in the product, that states are now saying 0.0% is the allowable amount. Good letter from this distinguished group. Hope it has some effect, and the APA or the Governor can come to a sensible “Wait and Study” decision on the class AA waters of Lake George.

  6. Paul says:

    This is enough articles with the same information. You must be self-plagiarizing yourself here. We have all the information we need. Most of the data written about it here supports the use anyway. The rest is just speculation on possible unidentified, unproven, non-existent data. I don’t even care if they do this. This mob type mentality just drives me crazy. The APA based their decision on the science. It’s approved. There is no basis for the lawsuit that will follow. Case closed. They only have 10 days. A judge will have to throw it out quickly.

    • ADKresident2 says:

      Why the rush to pollute?

      • Ben Franklin says:

        Dollars!

      • Paul says:

        It’s not pollution, just because people who don’t have any data to show that it is – say that it is, doesn’t make it so. This is where calmer and more informed heads prevail. Glad to see that these agencies and LGPC are doing what they can to protect the lake from invasives despite having to deal with all this ill informed backlash.

        • Benjamin Franklin says:

          No it is not pollution. Instead it is poison. What skin do you have in this game? Why are you so eager to see ProcellaCor used?

  7. Martin Lindsay says:

    Pausing the use of these things is most appropriate. So would be the rendition into common language of “illuminated altered trophic…biodiversity loss4”

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