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Home » Under Secretary for Political
Affairs » Bureau of
International Narcotics and Law Enforcement Affairs » Remarks, Press Releases, Fact
Sheets, Newsletters, Reports » Reports » Aerial Eradication of
Illicit Coca in Colombia » 2003 » Updated Report on
Chemicals Used in the Colombian Aerial Eradication Program

Updated Report on Chemicals Used in the Colombian
Aerial Eradication Program

Report on Issues Related
to the Aerial Eradication of Illicit Coca in Colombia

Bureau of International
Narcotics and Law Enforcement Affairs

December
2003

On September 4, 2002, the Department of
State submitted to Congress the Secretary of State�s determination and report to
Congress on issues related to the eradication of illicit coca in Colombia in
accordance with the FY 2002 Foreign Operations, Export Financing, and Related
Programs Appropriations Act (P.L. 107-115). That document contained an
explanation of the chemicals and methods used for the eradication of coca in
Colombia and the safeguards in place to minimize the risk of harm to human
health and the environment. It also contained the results of the Department of
State�s consultations with the United States Environmental Protection Agency
(EPA), including EPA�s analysis of the risks to human health and the environment
that might be posed by coca eradication.

The Government of Colombia and the
Department of State have implemented several changes in the program to address
concerns raised by the EPA analysis. The first section of this document reviews
the Department of State response to EPA�s 2002 recommendation for additional
controls for the spray program. Sections two and three explain the changes
introduced by the Government of Colombia and the Department of State to respond
to EPA and Congressional concerns about other aspects of aerial eradication in
Colombia. A fourth section describes the changes in chemical composition and
spraying methods since the Department of State�s 2002 report. The final section
reviews the chemicals and methods used for opium poppy eradication in Colombia,
a part of the program that Congress did not ask the Department of State or EPA
to address in FY 2002.

1. EPA Recommendation to Change
Glyphosate Product Used by the Program

The EPA made one direct recommendation to
the Department of State related to spray program controls in its �Office of
Pesticide Programs Details of the Consultation for Department of State: Use of
Pesticide for Coca Eradication Program in Colombia.� On page 12 of that
document, EPA recommended that ��due to the acute eye irritation caused by the
concentrated glyphosate formulated product and the lack of acute toxicity data
on the tank mixture, the Agency recommends that DoS consider using an
alternative glyphosate product (with lower potential for acute toxicity) in
future coca and/or poppy aerial eradication programs.� This was addressed to the
possible risk of splashing the full-strength glyphosate into the eyes or onto
the skin of persons filling the spray tanks on the airplane. It was not directed
at potential risk to persons exposed to the spray mixture as actually applied by
the planes.

At the time that EPA made this
recommendation, there were no suitable replacement glyphosate formulations
registered for sale and use in Colombia that offered lower potential for acute
eye irritation. The Department of State worked with the program�s glyphosate
supplier to identify and to register for sale and use in Colombia a formulation
of glyphosate with reduced potential for eye irritation. As soon as that product
could be registered for sale and use in Colombia, the Department of State began
to purchase it for use in the spray program and it remains the formulation used
today.

Like the previous formulation, the new
formulation is also registered with the EPA for sale in the United States for
non-agricultural use. It also contains 41 percent glyphosate salt and 59 percent
inert ingredients. Like the previous formulation, the formulation now used is
made from a base material (glyphosate technical) that is produced by a
manufacturing plant that is registered in the United States even though the
formulation is produced and sold in Colombia. The glyphosate formulation now
used is mixed with water and surfactant in the same proportions as the previous
formulation to form the coca spray mixture.

The difference between the formulations is
that the current product has an overall category III toxicological rating
(�mildly toxic�) on the scale used by the EPA, whereas the previously used
glyphosate formulation was rated category I (�highly toxic�). The toxicity
reduction is due to a change in the surfactant used in the glyphosate
formulation. Of course, these ratings refer to the toxicological profile of the
glyphosate formulations in their point of sale, undiluted form, and not the
spray mixture (water, glyphosate formulation, and surfactant) that exits the
spray aircraft.

The Department of State took these steps
in part to address public concerns about the toxicity of the spray mixture and
allegations that the combination of glyphosate and surfactant would pose a
threat to human and environmental health. In that regard, the Department of
State also contracted with an independent United States laboratory to determine
the toxicity of the spray mixture (e.g., the glyphosate formulation with water
and surfactant added), exactly as it is mixed in the field. Because final drafts
of those toxicology tests were not completed in time for EPA�s assessment in
2002, copies of the toxicology tests on the spray mixture currently used for
coca eradication are enclosed as Attachment A. These tests show that the spray
mixture rates a category III (�mildly toxic�) for eye irritation and category
IV, or �slightly toxic,� in all other categories (e.g., acute oral, acute
dermal, acute inhalation, skin irritation, sensitization).

2. EPA Advice Regarding Tracking
Reported Health Complaints

EPA�s �Office of Pesticide Programs
Details of the Consultation for Department of State: Use of Pesticide for Coca
Eradication Program in Colombia� also advised (on page 32) that: �(p)rospective
tracking of reports of health complaints, documenting times of exposure and
onset of symptoms, are recommended during future spray operations to evaluate
any potential health effects and ameliorate or prevent their occurrence.�
Although this recommendation is not related to spray program controls, the
Department of State has increased its efforts to track reported health
complaints and to investigate any possible connection between any such
complaints and the eradication of illicit crops.

The spray program tracks human health
complaints in two ways. The first is to initiate an immediate investigation,
often including clinical evaluation of the patient(s), upon notice to the U.S.
Embassy of a problem. The Embassy�s Narcotics Affairs Section (NAS) learns about
cases through letters directed to the Embassy or GOC entities, from local
counternarcotics base commanders, and from the members of the media. To
investigate complaints of toxic exposure allegedly caused by spraying, NAS
retains the services of two of Colombia's leading toxicologists, including the
director of Colombia�s national poison control center, the Uribe Cualla Centro
de Asesoramiento Toxicol�gico.

Since submission to Congress of the FY2002
�Report on Issues Related to the Eradication of Illicit Coca in Colombia,� two
such complaints have been reported to the U.S. Embassy. In September 2002, the
Embassy received a complaint of multiple cases of poisoning from spraying of
coca in Puerto As�s (Putumayo department). A visit to the hospital and
interviews with doctors there revealed no cases of poisoning or illness
attributable to spray chemicals. The toxicologist learned of two hospitalized
children who could have been the source of the complaint, and he reviewed their
cases. One of those children was suffering from poisoning by an organophosphate
insecticide. The other child was suffering from asthma. An English language
version of the toxicologist�s report from this investigation is enclosed as
Attachment B.

In February 2003, a news report in the
Bogot� daily �El Tiempo� attributed the spread of tuberculosis and cases of
harelip and cleft palate in newborns to aerial spraying of coca in Tib� (Norte
de Santander department). A toxicological review showed cleft palate and harelip
to be a genetically inherited defect that has never been reported in humans as a
result of exposure to any chemical substance. Tuberculosis is an infectious
disease passed from person to person, and is also unrelated to any potential
exposure to spray chemicals.

The Government of Colombia and the U.S.
Embassy Bogot� have also taken a proactive approach to investigating any human
health concerns manifest in areas where the spraying takes place. Both
governments have collaborated to create a robust Medical Civic Action Program
(Medcap) to search out cases of harm to health allegedly caused by the spraying.
During these public health interventions that are timed to take place in areas
where coca eradication has recently taken place, U.S. Embassy-contracted
toxicologists talk to patients and talk to local medical personnel, looking for
spray-related cases. As outlined in the chart below, a total of 1,029 patients
made themselves available for Medcap medical personnel, had their medical
conditions assessed, and received complimentary health care. Although Medcap
personnel have encountered cases that were claimed to be spray-related, reviews
of these cases have determined that events unrelated to eradication spraying had
caused them. Through Medcap and other medical investigations, the U.S. Embassy
has never found an instance of spray-related harm to human health. This is an
ongoing program and the next Medcap is planned for the end of April in Caquet�,
a few weeks into the spray campaign in that region.

Place and Date

Patients
Assessed

Cartagena del Chair� (Caquet�)

May 11, 2002

250

Solano (Caquet�)
August 7,
2002

120

Santa Ana (Putumayo)
September
21, 2002

260

Puerto As�s (Putumayo)
November
9, 2002

250

San Vicente del Cagu�n
(Caquet�)
February 1, 2003

149

To further address public and
Congressional concerns about the possibility of human health and environmental
harm potentially caused by spraying, the Department of State is working with the
Government of Colombia and Garzon Ingenieros Asociados Ltda, an accredited
Colombian laboratory, to analyze water taken from areas where the spray program
operates. Technology for monitoring soil is not available in Colombia, so the
Department of State is working with the Government of Colombia and the U.S.
Department of Agriculture Agricultural Research Service to analyze soil samples
at the USDA/ARS laboratory at the University of Mississippi. The Department of
State is paying for technicians from two Colombian government laboratories and
the Ministry of the Environment to travel to Mississippi in April to learn how
to perform the analysis. The soil and water analyses will determine the degree
of persistence of glyphosate and its byproducts in Colombian soil and water, in
the unlikely event there is something unique about Colombian soil and water that
would invalidate the many studies done on the residual effects of glyphosate in
other parts of the world. The Department of State, the Government of Colombia
and a private Colombian university (Universidad de Los Andes) are developing
demonstration plots in the five distinct environmental regions of the country to
study glyphosate persistence and the regeneration of natural vegetation and
other ecological dynamics following aerial eradication of illicit crops.

3. EPA Comment Regarding Spray
Drift

Although not addressed to the Department
of State as a recommendation, EPA also noted in its consultation with the
Department of State some concern for spray drift and the potential for
non-targeted, desirable vegetation to suffer from the spraying of nearby coca
(or opium poppy). Informed of EPA�s and Congressional concern, the Department of
State and the Government of Colombia have incorporated several measures into the
spray program to assist us with evaluation and control of spray drift.

The first of these steps was to reinforce
the environmental safety component of spray pilot training. All pilots, both
fixed wing spray pilots and rotary wing escort helicopter pilots, will receive
briefings on the potential negative impact that spraying may have on the
environment and techniques to minimize potential collateral damage to legal
crops and the environment. These briefings will be conducted semi-annually, will
emphasize the unique aspects of the Colombian operational theatre, and will
solicit feedback from pilots on techniques to maximize application effectiveness
and avoid damage to non-target vegetation. An outline of this briefing is
included as Attachment C. Search and rescue helicopter crews that accompany each
spray flight have also been directed to monitor drift patterns from above. They
now assist in ensuring that spray does not drift beyond target crops and notify
the spray aircraft flight lead when conditions might merit canceling a spray
flight. A copy of the directive from the Department of State�s Bureau of
International Narcotics and Law Enforcement Affairs (INL) Office of Aviation to
the eradication contractor that formalizes these new spray regulations is
included as Attachment D.

The Department of State�s Assistant
Secretary for INL also directed the team of United States Department of
Agriculture (USDA) and Government of Colombia scientists, responsible for the
ground truth verification missions, to incorporate an analysis and
quantification of overspray into ground truth verification exercises. While past
verification missions sought out and noted cases of overspray, documenting the
existence and extent of any damage to crops or foliage not targeted for
eradication, this is now a formal component of the ground truthing exercise. The
most recent ground truth verification mission (December 9-20, 2002) found that
incidences of overspray were minor. The USDA Agricultural Research Service
report from this verification exercise has not yet been completed, and INL will
forward a complete copy to EPA as soon as the Department of State receives the
report.

4. Changes in Chemical Composition
and Spraying Methods Since 2002 Report

Apart from changing to a more benign
formulation of glyphosate spray mixture, as discussed earlier, there have been
no changes to any of the components of the spray mixture. For some time in 2002,
the Government of Colombia lowered the application rate of glyphosate for coca
eradication from the traditional application rate of 10.4 liters per hectare to
8.0 liters per hectare. After extensive ground truth evaluation, it was
determined that the lower rate was ineffective for killing coca. Thus the
application rate was returned to its former rate of 10.4 liters per hectare,
which was the rate reported in the Department�s Report on Issues Related to the
Eradication of Illicit Coca in Colombia in 2002 -- the rate that EPA evaluated
when analyzing the potential for risks of adverse effects on human health and
the environment posed by the coca eradication program.

The only changes in the methodology used
to spray coca since the time of the last report is the addition of a new type of
spray aircraft to the spray fleet. Four Air Tractor Model 802 (AT-802) aircraft
are currently being used to spray coca, and another four will be delivered this
year. These aircraft are manufactured in the United States for agricultural crop
spraying and utilize the identical nozzles (same brand and diameter) in the
identical configuration (nozzle angle, droplet size, calibration methods) as the
OV-10 and T-65 spray aircraft. AT-802 flight speed during eradication operations
is 165 m.p.h.

5. Differences Between Opium Poppy
Spraying and Coca Spraying

The Secretary of State was not
required to determine and report to Congress on any aspects of the opium poppy
eradication program in FY2002, and thus the Department did not provide
information to EPA on the chemicals and methodology of poppy spraying. Like the
coca spray mixture described in the �Report on Issues Related to the Eradication
of Illicit Coca in Colombia,� the opium poppy spray mixture contains three
components: water, an EPA-registered formulation of the herbicide glyphosate,
and a surfactant (Cosmo-Flux 411F). Because the opium poppy is not a woody,
hard-to-control species like the coca bush, opium poppy eradication uses a spray
mixture with a substantially lower glyphosate content than the spray mixture
used for coca eradication (see Attachment E). For opium poppy spraying, water,
formulated glyphosate, and surfactant are combined into a spray mixture in the
following percentages: 94 percent water, 5 percent glyphosate formulation, and 1
percent Cosmo-Flux 411F. This diluted mixture is applied to opium poppy at the
rate of 50.0 liters/hectare (or 5.46 gallons per acre). This application rate is
within the glyphosate manufacturer's label recommendations for both the amount
of concentrated formulation per acre and the amount of total spray volume per
acre.

Opium poppy spraying differs from coca
spraying in several ways. Because Colombia cultivates much less opium poppy than
coca and spray program resources are limited, aircraft spray much more coca than
opium poppy, therefore expending more spray chemicals in coca growing areas than
in areas where opium poppy is cultivated. For example, in 2002, eradication
aircraft sprayed totals of 122,700 hectares of coca and 3,000 hectares of opium
poppy. Opium poppy is generally cultivated in plots that are smaller than the
average coca field. While difficult to quantify precisely, opium poppy fields
generally range from 0.5 to 5 hectares. Opium poppy is ordinarily cultivated at
a higher altitude than coca, and thus opium poppy often is cultivated and
sprayed in hilly to mountainous terrain. For these reasons, the T-65 is the only
aircraft used to spray opium poppy because it has a smaller wingspan (and spray
swath) than the OV-10 or AT-802 and because it is a more agile aircraft capable
of staying close to the ground in more steeply graded, rugged terrain.

Because of the challenges of mountain
spraying, pilots undergo an extended training program before they are qualified
to perform actual opium poppy spray operations in Colombia. As the Department of
State reported in 2002, coca eradication pilots must have approximately 3,000
total flight hours before they are considered for the spray program and can
receive preliminary training in illicit crop eradication. Most of these pilots
also have at least 1,500 hours of commercial aerial application (crop dusting)
experience. In addition to these requirements, opium poppy spray pilots must
undergo 40 hours of follow-on training specific to the topography, wind
conditions, and cloud cover that they will experience in their area of
operations.

Attachments

Toxicological testing results for coca
spray mixture (Purity Analysis for Glyphosate, Acute Oral Toxicity Study,
Acute Dermal Toxicity Study, Acute Nose-Only Inhalation Toxicity Study,
Primary Eye Irritation Study, Primary Skin Irritation Study, Dermal
Sensitization Study).

�Investigative Report on Cases of
Possible Human Health Effects in Puerto As�s,� Jorge Hern�n Botero Tob�n, M.D.
Bogot�, Colombia, September 19, 2002.

Outline of Spray Pilot Semi-Annual
Briefing.

Memo from INL Office of Aviation
Director of Operations to DynCorp Operations Manager re: Aerial Eradication
Procedures, December 13, 2002.

Coca and Opium Poppy Spray Mixtures
Comparison Graph.

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