Friday, May 1, 2015

New oyster permit substantially reduces toxics in Willapa Bay and Grays Harbor

UPDATE: On May 3, Ecology and the shellfish growers cancelled the pesticide spraying permit. 
Read the news release here: http://ecologywa.blogspot.com/2015/05/news-release-ecology-shellfish-growers.html

By Chase Gallagher, Southwest Region Communications Manager

We have heard from many people who read the recent Seattle Times column (and other articles) about a permit for imidacloprid use in Willapa Bay and Grays Harbor. We want to make sure you have the facts about the permit, the pesticide (and the label you’ve read about), and to set the record straight about our role.

We monitor, analyze and plan ways to clean and protect our state’s waters. This involves limiting and restricting the ways facilities, farms and others discharge any pollution into our waterways.

Two weeks ago we issued a water quality permit to the Willapa – Grays Harbor Oyster Growers Association for the use of imidacloprid – a widely used, common pesticide – on commercial shellfish beds in Willapa Bay and Grays Harbor. This is one of many aquatic pesticide permits we issue to ensure water quality is maintained during use of a pesticide to combat invasive species, mosquitoes, algae, or in this case, burrowing shrimp.

About burrowing shrimp

Burrowing shrimp are a native species to Willapa Bay and Grays Harbor. As their name suggests, they burrow into the mud in tidelands, loosening mud, causing it to soften and lose its integrity. For shrimp, that’s a good thing. But for an oyster or clam it means they’ll likely sink into the mud and suffocate. About 25 percent of our nation’s commercial oysters are produced from these two bays. The shrimp are more than a nuisance; they put the shellfish industry and economy at risk.

Shellfish growers have been combating the burrowing shrimp for more than 50 years 

From the 1960s until 2013 a pesticide called carbaryl was used in these same areas.

The Department of Ecology permitted the use of carbaryl in 2002, monitoring its impacts on water quality. In 2008, the shellfish industry began pursuing a less toxic way of controlling the burrowing shrimp population. A wide number of options were considered and tested, including:

  • Covering tideflats with gravel and shells
    • Organic insecticides such as:
    • Mustard seed meal
    • Habanero pepper extract
    • Garlic oil
  • Running all-terrain vehicles over shellfish beds to compact and cave-in burrows
  • Propane explosions within the infested mudflats
  • Injecting clay slurry into burrows
  • Electroshocking the mudflats
  • Releasing high-pressure sound waves into the mudflats 
  • Alternative shellfish culture systems
  • Plastic mesh barriers
  • Other chemicals 

The most effective method

It turns out that the most effective way to combat the burrowing shrimp was with imidacloprid, one of the most commonly used agricultural pesticides. It’s the active ingredient in most flea collars for your pets, is used on termites, and protects fruits and vegetables from insects that damage crops. 

It works by causing paralysis in an organism, like burrowing shrimp. It prevents them from being able to move, causing eventual death. It’s most effective against invertebrates, like the burrowing shrimp. It’s far less of a threat to fish or other, larger, vertebrate wildlife, like birds and humans. 

But what about the label saying you can’t use it on water?

Every pesticide is registered for a particular use. The bottle or package of imidacloprid consumers can buy at their local hardware store or garden center has been registered for use on land, not the water. The household label states that. That’s the type of imidacloprid the Seattle Times’ columnist wrote about



However, the product permitted for use in Willapa Bay and Grays Harbor to control burrowing shrimp in commercial shellfish beds is a different product with a different label.


While the active ingredient (imidacloprid) is the same, these are different products, registered for different uses. This one is explicitly registered by the U.S. EPA and the Washington Department of Agriculture for use on shellfish beds. The Seattle Times column failed to report this important distinction, and we think you should have the facts.

Limited use

For this permit, shellfish growers are limited to using imidacloprid only on commercial shellfish beds on no more than 1,500 acres in Willapa Bay and 500 acres of Grays Harbor. That’s less than 2% of the total area of the bays.

The most likely application will be from the air, during low tides, using helicopters to directly spray right on the shrimp burrows. Our rules prohibit any spraying during high tide, and when winds are stronger than 10 miles per hour to minimize drift. 

Applying the treatment at low tides directly targets the shrimp in their burrows. When the tide comes in, any residual material will be adequately diluted.

Reducing pesticide use by 95% -- less toxic and more effective

The previous pesticide used by shellfish growers, carbaryl, was applied at a rate of 8 pounds per acre. The new permit issued for imidacloprid limits application to 8 ounces, and it can only be applied once per year. 

Additionally, the U.S. EPA says that oysters are safe to harvest just 30 days after a treatment of imidacloprid – instead of having to wait an entire year after a treatment of carbaryl. 



In our testing we’ve found that the most sensitive creatures that live in the mud, known as benthic invertebrates, return to normal levels just two weeks after a treatment. 

Studies and public process

With its widespread use in agriculture, imidacloprid has been studied extensively for use on land. But this is the first time it’s being permitted for use on shellfish beds, and we undertook an extensive scientific review and public involvement process. 

We began studying the effects of imidacloprid on water quality five years ago (in 2010). We started the environmental impact study process in January 2014, and held a public meeting in South Bend in February. Public comments have helped shape what was included in our draft Environmental Impact Study (EIS) released in October 2014. The final EIS was released last month.

Everything throughout the process was posted on our website

Monitoring

The permit we issued on April 16 is valid for five years. It includes monitoring requirements, and the WSU Long Beach Extension is supporting some of the sampling required this year. Over the next five years, we’ll review the annual monitoring data, and identify any adverse impacts to the sediment in the bays and water quality.

If for some reason the effects don’t match our scientific findings, we included conditions to reevaluate the permit at any time.  

For some it may seem counter intuitive – the state’s environmental agency allowing the use of a pesticide on shellfish beds. But our job is to protect the water and environment for all of us in Washington. If there’s an opportunity to reduce toxics in the water, we’re going to take it, and that’s what this permit does. 

18 comments:

4 chemical free oysters said...

The manufacturer of the product states it shouldn't be applied to water, you bought that product and created a new label for it yourself. The shrimp are native to that area, while the oysters are not native to that area (at least not the one which makes all of the money). This decision is based totally on greed and money and not environmental protection. I love oysters, but if if Taylor et al spray this chemical on the shrimp, I will not only stop buying oysters, but all of their products, and they have some tasty products. I hope every state in the country boycotts oysters that have been contaminated with this chemical.

Birdlover said...

Different product for different use with EXACTLY the same ingredients? So the second manufacturer, with EPA's blessing, skipped the part about "don't use in water" and that makes it OK to use in water? I am confused. Please explain.

BLG said...

Wow. A very earnest (one can assume) effort to convince us that the lesser of two evils is not evil, but instead good! Unfortunately it fails the smell test. Neurotoxins are neurotoxins. Nuff said.

BLG said...

Wow. A very earnest (one can assume) effort to convince us that the lesser of two evils is not evil, but instead good! Unfortunately it fails the smell test. Neurotoxins are neurotoxins. Nuff said.

Mike Coday said...

what makes this form of imidacloprid ok to spray on waterways if the same chemical is definitely supposed to be sprayed on waterways?

Clean water said...

From the Govenor who gets massive inkind donations and money from industry to Ecology who is nothing more than a mouth piece to industry , that would be any industry that gives to the so called environmental Gov.

Andy said...

Shame on you Dept. of Ecology. This blog post is misleading and factually incorrect. The ACTIVE ingredient in Merit 2F and Protector 2F is exactly the same. Yes, they are different products by trade name but the CHEMICAL...the TOXIN is the same. Why don't you show in your blog WHO Protector 2F is licensed to? The Willapa-Grays Harbor Oyster Association. The final paragraph of your blog says your job is to protect the water and environment for all of us in Washington. Clearly this isn't true...this action benefits the Oyster grower and ONLY the oyster growers. Yes...less Carbaryl is good, but replacing one toxin with another is not the answer.

VIVIAN Johnston said...

Please explain how the products are different. I can Google Merit 2 and find the msds but could not for Protector 2F

Spedis Owl said...

Having given this a quick read, I’m not especially impressed. The write-up doesn’t seem to address the toxicity of nerve agents to a wide range of invertebrates. The collateral damage is bound to be extensive.

The frequent claim that this pesticide is ‘widely used’ is misleading and not really relevant. As I understand it, this compound is not used in aquatic applications anywhere else in the country. I also don’t see any mention of toxicity or other effects to species beyond ghost shrimp. Like fish. Like shorebirds and other birds that feed on invertebrates – alive or dead.

A fairly straight-forward approach would be the use of artificial substrates for spat and oyster culture. Certainly Ecology and the growers could work at ways to fund and permit the construction of raised substrates / artificial reefs.

The ‘reducing pesticide use by 95%’ section compares only the mass application rates, which is pretty much meaningless – as we know that the potency of the poison is the key variable.

After trying to poison ghost shrimp into submission for 50 years and failing, doesn't it seem logical that other approaches need to take precedence?

Mike Coday said...

So Protector 2F is over 21% imidacloprid and Merit 2F is less than 1% imidacloprid, correct? So Protector 2F is about 40 times as potent as a nerve poison application than Merit 2F, correct?

If that is the case and the weak Merit 2F is not safe to apply to waterways, how is the much stronger nerve poison formulation safe for application on watersays?

Stacia said...

It's not counter intuitive that the government department responsible for protecting the environment and ecology is only concerned with protecting the wealthy, and consistently values economic interests over the health of both people and the environment. It's completely expected and the sole reason why there are so many health-conscious, environmentally concerned citizens filling the void your department leaves behind. If the DOE ever aligns itself with the majority of independent, scientific fact and the well-being of the citizens and environment you're paid to represent, you'll know...you'll stop having to write letters like this.

Stacia said...

It's not counter intuitive that the government department responsible for protecting the environment and ecology is only concerned with protecting the wealthy, and consistently value economic interests over the health of both people and the environment. It's completely expected and the sole reason why there are so many health conscious, environmentally concerned citizens filling the void your department leaves behind. If the DOE ever aligns itself with the majority of scientific fact and the well-being of the citizens and environment you're paid to represent, you'll know...you'll stop having to write letters like this.

tom e said...

Hey Chase, I couldn't find your name in the Pesticide and SPI Licensing search- I also found a lot of what you wrote here to be extremely misleading or lacking in basic understanding of pesticide designation and use. Feel free to look my name up though, Thomas Erler. Note that I have an Aquatics endorsement. You should get one if you are going to be explaining these issues to the public on behalf of DOE. It was really easy to get.

Corbie said...

This sounds disturbingly similar to the boons granted to DDT...prior to discovering its ill-effects. "DDT is the single most effective agent ever developed for saving human life.”
- British politician Dick Taverne

Pity that it was also horribly effective at almost wiping out the Bald Eagle population. The chemical may not (or may--who knows about long-term issues?) hurt humans, but what about the effect on other oceanic flora and fauna?

The US Fish and Wildlife Service are saying, "Don't do this". NOAA is saying, "Don't do this". What on earth makes you think this is a good idea? Why the rush to spread a neurotoxin on our shorelines? How about remembering the the State's ecology, as well as its shoreline, belongs to all of us and not just to the few making a buck off of it.

Tuman Homes said...

I can't believe this is coming from the Department of Ecology... Maybe from Monsanto or another chemical manufacturer, but not a governmental unit which is designed to protect our rather fragile environment. I'm delighted to see that Taylor will not use this, but you are still promoting the use. I'm so disappointed.

Glen Buschmann said...

It is sloppy science to suggest that 1 pound of one product is equivalent to 1 pound of another product and imply that less weight is obviously less poison. A kilo of sugar is not the same as a kilo of Sarin, and an gram of carbaryl does not equal a gram of imidacloprid. Be honest and not clever.

Glen Buschmann said...

I've already criticized some of the sloppy reporting in this report. But two products can have the same "active" ingredient and be very different depending upon the "inert" ingredients that make up the other 95% of the product.

Inerts are not regulated in the same way, (sometimes barely at all, can have secret proprietary ingredients -- that is its own discussion). A common example of an inert ingredients is the "sticker-spreader" that helps hold a poison on the leaf, often a "soap".

Even a product with ZERO "active" ingredients can be safe on land but toxic in water. Consider dish soap. It is safe for people to spray a soap solution onto leaves to kill aphids, and unpleasant but relatively safe if someone swallows it, but highly toxic to spill that same soap into a stream or pond, because of how a soap affects oxygen uptake by aquatic animals etc. Latex paint similar.

So an aquatic poison may be formulated in a gel that sinks to the bottom where the product is absorbed into the soil rather than diluted thru-out the entire water column.

Mike S said...

No matter the technicalities, thanks again to the Seattle times , I happen to get my tires changed that day and saw the newspaper.

These chemicals have persistent impact on the environment with unintended effects. Lakes and rivers are loaded with the stuff (based on state EMP data), and the soil is so deeply penetrated that insects can't grow so birds can't feed, and the product label is just permission for somebody to sleep at night while harming more than helping.