Table 6.

Soil

Residues of 2,4,5-T (lb/A) in soil at 0 to 12 months after application of 2 lb/A August 20, 1968, to Watershed 2.

Months after application

Table 7.

Residues of picloram (lb/A) in soil 0 to 12 months after application of 2 lb/A August 20, 1968 to Watershed 2.

Senator HART. May I thank all who assisted in the development of this very informative hearing. We stand adjourned.

(Whereupon, at 5:15 p.m., the subcommittee was adjourned.) (The following material was subsequently received for the record:)

STATEMENT OF HON. LEE METCALF, U.S. SENATOR FROM MONTANA

Mr. Chairman, I appreciate the opportunity to outline briefly a few of the special problems which arise from the use of herbicides such as 2,4,5,-T in Montana.

I will not go into the potential health dangers involved with the widespread use of 2,4,5,-T and other insufficiently tested herbicides. Others, far better qualified than I to assess these dangers, have already presented their professional opinions to the Subcommittee. What I would like to bring to the Subcommittee's attention, however, is the particular impact the use of herbicides has upon a vast agricultural State such as Montana.

Montana, as you know, is in the unique situation of lying at the head of three major international drainages which carry waters into the Gulf of Mexico and the Pacific and Arctic Oceans. The river systems whose headwaters lie in Montana, the Columbia, the Missouri-Mississippi, and the Saskatchewan, pass through over half of the land area of our nation and part of that of Canada.

Into these drainages enormous quantities of herbicides and pesticides are sprayed each year. Forests, grazing lands, grain fields, power line rights of way, and highway shoulders are sprayed with a wide variety of chemical poisons. Herbicides are used by Federal agencies, State agencies, private companies, farmers, and home gardeners. The State undergoes a veritable deluge every year. I hardy need to point out the potentially dangerous effects of such chemicals, if they are found to persist and collect in water supplies and in the food chain. Ecologists have pointed out that the little understood processes of accumulation, biological magnification, and synergism can bring about completely unexpected results from commonplace chemicals.

One would assume because of the pervasive use of 2,4,5,-T and other herbicides and because of the harmful side effects which have already been discovered to result from some group of these chemicals, that truly exhaustive tests would be required to be run on any new candidate for herbicidal use. Unfortunately, this is not the case. To our astonishment we have been told in effect that the burden of proof is on the public to prove that a proposed substance is dangerous rather than on the supplier to prove that it is not.

The result of this convoluted notion of regulation is that enormous amounts of potentially dangerous herbicides are spread about our land, they eventually find their way into water systems and merge with others as they travel their way to the oceans. Once the Department of Agriculture places its seal of approval on a chemical, the substance can be sprayed with impunity. Whatever detrimental effects may result are thereafter extremely hard to ascertain. The unfortunate results may in fact only become visible years from the time they are used.

The Montana State Legislature is now considering a new Pesticide Commission which would provide much better regulatory machinery at the State level. However, due to the problem of human and financial resources, such State commissions will always have to take their cue from the Federal regulatory bodies. And as it now stands, the Federal regulating process is a very confused and weak one.

What is vitally needed, Mr. Chairman, is a clearly delineated Federal regulatory policy in the field of pesticides, herbicides, and defoliants which would:

1. Place the burden of proof of the safety of a product upon the manufacturer;

2. Provide for thorough, independent testing in government laboratories; 3. Place the sole responsibility for the approval of the health dangers of a product with the Secretary of the Department of Health, Education and Welfare;

4. Substantially strengthen the enforcement machinery in the agencies which control pesticides; and

5. Create a national policy for the use of pesticides by Federal agencies. Concerning the final point, I think it is extremely important that the use of these chemicals in national parks be critically examined. Our national parks and primitive areas were set up specifically in order to sector off the few small, un

spoiled areas which remain in our industrialized country to be preserved as natural regions. I was dismayed to learn recently that a 20-foot wide strip through the middle of one of our most beautiful national parks has been defoliated with another herbicide, picloram.

Mr. Chairman, it is incredible to me that Glacier-Waterton International Peace Park should be subjected to defoliants for the creation of a "North American DMZ" through its center. It is an unpleasant irony that a park which was established to commemorate the peaceful relationship between two nations and to preserve a unique glacial wilderness must be divided in two by a senseless and ugly defoliated strip. Moreover, even less is known about the possible teratogenic and carcinogenic effects of this chemical picloram than about 2,4,5-T, the agent under immediate suspicion.

Our lack of a national policy in the area of herbicides and pesticides reaches its ultimate absurdity in this defoliated strip in Glacier Park. I urge the Subcommittee to consider the far-reaching measures which are necessary to control all aspects of the use of pesticides. Only a comprehensive approach to the problem will enable us to avoid mistakes such as DDT and 2,4,5,-t.

OFFICE OF THE SECRETARY of Defense,

Hon. PHILIP A. HART,

Washington, D.C., April 21, 1970.

Chairman, Subcommittee on Energy, Natural Resources, and the Environment, Committee on Commerce, U.S. Senate, Washington, D.C.

DEAR MR. CHAIRMAN: The following information is provided for the record in response to a staff request from your Subcommittee:

Deputy Secretary of Defense David Packard on April 15 ordered the immediate suspension of the use of 2,4,5-T within the Defense establishment pending a more thorough evaluation of the system. Sincerely,

J. F. LAWRENCE,
Brigadier General, USMC,

Deputy Assistant to the Secretary for Legislative Affairs.

DEPARTMENT OF AGRICULTURE,

OFFICE OF THE SECRETARY, Washington, D.C., April 21, 1970.

Mr. LEONARD BICKWIT,

Staff Counsel, Subcommittee on Energy, Natural Resources, and the Environment, U.S. Senate, Washington, D.C.

DEAR MR. BICKWIT: The following comments on the April 15 joint U.S. Department of Agriculture, U.S. Department of Health, Education, and Welfare, and U.S. Department of the Interior release "Home Uses of 2,4,5-T Suspended" are offered for the record of the Hearings of the Committee.

The release is not clear on the cancellation of registered uses of 2,4,5-T on food crops. The action to be taken is the cancellation of all registered uses of 2,4,5-T on apples, blueberries, barley, corn, oats, rice, rye, and sugarcane.

The term "cancellation" as here used means that each registrant will be notified that his registered products subject to this action shall cease to move in interstate commerce 30 days after notification of cancellation. During this 30-day period, the registrant may correct the labels on his cancelled products to delete the cancelled uses. The registrant may appeal the cancellation action and ask for an advisory committee or public hearing. In such case, the registrant's cancelled products may move in interstate commerce until action on the appeal is completed.

The term "suspension" as used in the release with reference to action to suspend all registered uses of liquid formulations around the home and all registered uses of 2,4,5-T on lakes, ponds, and ditch banks, means that such suspended products shall cease to move in interstate commerce upon receipt of notice of the order of suspension by the registrant. The registrant may appeal the suspension action but in such case the suspended products cannot move in interstate commerce while action on the appeal is in process.

Sincerely,

T. C. BYERLY, Assistant Director, Science and Education.