Introduction[1]

The environmental and health hazards caused by aerial fumigation —which have for the past quarter of a century proven to be a total failure towards controlling narcotics trafficking— compound the negative effects of the widespread use of pesticides for common agricultural purposes. Namely, the legal use given to these products as of the agricultural-production model known as the "Green Revolution," which has been fostered by states throughout the past century on the basis of one-crop farming and are dependent on an intensive use of toxic agrochemicals licensed for sale. Consequently, it is inconsistent for the government to justify illicit-crop "eradication" on the basis of the pollution generated by the use of pesticides since these same pesticides are used on licit crops all over the country and will, unfortunately, continue being used in an irrational manner as long as governments do not implement efficient policies to control the agrotoxin market and begin to foster organic, ecological production models.

When illicit crops are sprayed from the air with wide-spectrum herbicides, simultaneously, neighboring and intercalated staple crops are being fumigated as well as water sources, cattle, pets, schools, laborers, men, women, the elderly, children, wild animal and plant life from bordering jungle areas. No pilot, no matter how well-trained he is, can avoid indiscriminate fumigation when spraying with pesticides from a plane over areas which are inhabited by living beings.

This study focuses primarily on the potential health hazards —through a comparison of doses and acute toxicity problems— resulting from aerial fumigation with Roundup used in the forced eradication of illicit crops. After having carried out comparative analyses regarding

a) Results of studies on the acute toxicity generated by Roundup in animals;

b) Acute effects known to be caused by Roundup in humans, and;

c) The doses of Roundup Ultra and surfactants which are currently being applied.

we can sustain that there is no scientific precedent for the herbicidal aerial fumigation of illicit crops which is being carried out in Colombia.

This initial approach has demonstrated that aerial fumigations DO constitute a severe health hazard for humans and animals. It is therefore urgent that this degrading and failed policy be suspended immediately and that socially-concerted sustainable solutions —that lead to the gradual but true reduction of planting of crops considered illicit— be implemented.

General Characteristics of Roundup (glyphosate)

Its most commonly-known trademark name is the Monsanto Roundup, which has various formulations, commonly characterized by the content of 480 g/L of glyphosate IPA salt and the surfactant POEA (polyethoxylated tallow amine). The differences could lie in the varying concentration of these ingredientes and, in the case of the POEA —of the family of the polyethoxilated syntethized alkylamines from animal derived fatty acids. In some cases, it may contain additional surfactants. (Dinham, 1999; EPA, 1999; Green Peace, 1997; Meister, 2000; Williams et. al., 2000)

In Colombia, apart from being used as an herbicide for agricultural purposes, it is also used as a dessicator for grains and, aerially, to ripen sugar cane as well as in the forced eradication of crops qualified as illicit. Roundup[2] used commonly in agriculture contains 41% of glyphosate IPA salt while Roundup Ultra —used for eradicating illicit crops— contains 43,9% of the active ingredient.

It has been reported that the surfactant POEA contained in the formulation causes gastrointestinal disorders, damages the central nervous system, generates respiratory problems and destroys human red blood cells. POEA is contaminated by 1,4 dioxane, which has caused cancer in animals and liver and kidney harm in humans.

The main metabolite in glyphosate degradation in soil environment is aminomethylphosphonic acid (AMPA), which is also toxic.

Glyphosate can contain traces of N-nitrous glyphosate or this compound can be formed in the atmosphere when combining with nitrate (found in human saliva or in fertilizers.) Most N-nitrous are carcinogenic and there are no secure levels of exposure to carcinogenics. Formaldehyde, another known carcinogenic, is also a product of descomposing glyphosate (glyphosate ? AMPA ? Methylamine ? Formaldehyde). (Cox, 1995; Dinham, 1999; Williams et. al., 2000)

Minimal amounts of this herbicide can harm crops. One of Monsanto's first technical Newletters (MON-057-1-71) affirmed that "aerial application should be avoided where there is danger of the chemical coming into contact with desireable species deseables". Currently, the Monsanto label for Colombia states that "[R]isks of hazards for neighboring crops are considerably reduced when application is carried out under calm winds and when aimed at weeds using a protective shield to keep aspersion drops from falling on the green areas of desirable plants.”

According to the Roundup label, the herbicide that falls to the ground is immediately inactivated through a chemical reaction which occurs with clay soils, without leaving residues which might affect later plantings nor penetrate the roots of already-rooted crops. However, several researchers sustain that glyphosate can be easily desorbed in certain types of soil, in other words, that in some types of soils, it can break loose from the particles becoming quite mobile in the soil. In one type of soil, 80% of the added glyphosate desorbed or came loose within a two-hour lapse. (Cox,1995)

The losses due to volatilization or photodecomposition are considered insignificant, but it can be decomposed by micro-organisms, showing average life span in soils (lapse required for half of the compound to disappear from the environment) ranging from approximately 60 days (2 months), according to the US Environmental Protection Agency (EPA), up to 1 or 3 years, according to studies carried out in Canada and Sweden. The EPA adds that, in field studies, residues are found a year later. (Dinham, 1998; Cox 1995) According to complaints lodged with the Defensoría del Pueblo en Colombia (Ombudsman), food crops are totally destroyed by aerial fumigation with Roundup, and latter plantings are also affected.

Glyphosate is highly soluble in water with a solubility of 12 grams/liter at 25ºC. Due to its ionic state in water it is not expected to volatilize in water nor soils. Its persistence in waters is shorter than in soils due to its ability to adsorb to suspended particles such as organic and mineral material, sediments and probably due to microbial decomposition. In Canada it's been found to persist from 12 to 60 days in pond waters, but it lasts much longer in the sediments at the bottom. Average life span in sediments was 120 days, according to a study in Missouri, USA. Persistence was over a year in sediments in Michigan and in Oregon.

Glyphosate has been found to be contaminating surface and underground waters. For example, it contaminated through run-off two ponds in farms in Canada, one from agricultural treatment and the other from a spill; it polluted surface waters in Holland; and seven ponds in the USA (one in Texas and six in Virginia) were found to be polluted with glyphosate. In the United Kingdom, the Welsh Water Company has detected levels of glyphosate since 1993, above the permissible levels allowed by the European Union. The EPA has found that, exposure to glyphosate residues in water for human consumption above the maximal 0.7 mg/L authorized limit, can cause accelerated breathing and pulmonary congestion, kidney damage and hazards to human reproduction. (Dinham, 1999)

Mode of action and some effects on plants

Glyphosate can also affect other enzymes which are not related to chychemical-acid pathways. In sugar cane it reduces the activity of one of the enzymes involved in sugar metabolism, invertase acid. This reduction seems to be measured by auxins, plant hormones.

Glyphosate, since it is a wide-spectrum herbicide, has toxic effects on most plant species, and can jeopardize endangered species if applied in the areas they inhabit. According to EPA information, reported by PAN Asia Pacific, over 74 endangered species in the united States might be endangered because of the use of glyphosate. The same source ads that sub lethal doses of glyphosate can increase the susceptibility of some plants (i.e. apple, barley, soya, tomatos) to disease caused by fungus.

Glyphosate can inhibit beneficial fungi that help plants to absorb nutrients and water. For example, in one study it inhibited the formation treble nitrogen-fixing nodules 120 days' after treatment. In sub lethal doses it can interfere with some metabolic processes in plants: en kidney beans it can inhibit absorption of potassium and sodium and in asparagus and linseed it can diminish the production of lignin.

According to studies reported by Williams et. al. (2000), Roundup can produce chromosomal aberrations in onion the end cells, suggesting that this chromosomal effect might be due to the surfactant. Glyphosate's effect on the end of hyacinth roots, concluding that the inhibiting effect —depending on the doses— on the formation of mitotic figures with prolonged exposure, was due to an effect on the spindle apparatus, leading thus to chromosomal disorganization in the anaphase.

Acute Toxicity and Poisoning Symptoms of Roundup

In cases of poisoning studied by Japanese doctors, most of them due to accidental or voluntary ingestion of Roundup, but also due to occupational exposure, acute poisoning symptoms were reported as including gastrointestinal pain, massive loss of gastrointestinal liquid, vomit, excess pulmonary fluid, lung congestion or dysfunction, pneumonia, fainting and red blood cell destruction, abnormal electrocardiograms, low blood pressure and kidney failure or damage.

In studies with animals secondary effects were reported in addition to gastrointestinal irritation, such a reduced consumption of food and diminished weight gain in rats and dogs, and diarrhea and weight loss in cattle. (Cox, 1995; Dinham, 1999; Greenpeace, 1997; Moses, 1993; Williams et. al., 2000)

According to Williams et. al (2000)[3], the herbicide Roundup's cute toxicity in rats —as that of glyphosate— is very low, with oral and dermal LD₅₀[4] values of over 5000 mg/kg of body weight (apparently in the rats' case the POEA surfactant has no influence), and the CL₅₀[5] inhaled for 4 hours by the rats was 3.18 mg/L. According to Monsanto's technical sheet (1992) oral LD₅₀ for rats is 5.600 mg/kg.

POEA surfactant's acute toxicity (contained in the formulation) is from 4 to 5 times higher than that of glyphosate and Roundup. The oral LD₅₀ (rats) and dermal (rabbits) is reported from ~1200 and >1260 mg/kg respectively. On the basis of these LD₅₀ (without considering effects to eyes and skin), Roundup and POEA are classified in the following toxicological categories:

Glyphosate,Roundup and POEA toxicological classification (see attachment 1)

Accidental exposure for humans, according to Williams et. al. (2000), results in most cases in slight effects without death being reported. Nonetheless, the authors report that intentional swallowing of large quantities in cases of attempted suicide has produced severe effects including severe hypotension, kidney failure and in some case has killed. In those cases that have resulted in death, the person generally dies a few days after having ingested the product. In a review of intoxications which have occurred, it was estimated that the amount of concentrated Roundup intentionally swallowed in lethal cases was 184 mL (rang from 85 to 200), although it was noted that ingestion of greater amounts in other cases merely resulted in slight or moderate symptoms. Other studies report that average ingestion of 104 and 120 mL was not fatal, while ingestion of 206 and 263 mL caused death. On the basis of this information, Williams et. al (2000) conclude that “la toxicidad aguda de Roundup en humanos es baja y es consistente con lo que se prevé a partir de los resultados de estudios de toxicidad aguda en ratas”.

This assessment of the risks and dangers for humans is perplexing since there is no comparison between average lethal doses for rats (LD₅₀) and the known doses of Roundup which is deadly for humans. This would lead us to think that the conclusions are not reliable since they are not based on facts. Considering that 41% of the glyphosate that is contained in the Roundup formulation is in the form of isoprophylamine (IPA) salt; that it contains 480 g of glyphosate/L IPA salt; and the average weight for an adult (human male and female) used in safety and risk evaluations is that of 65,4 Kg, the lethal doses of glyphosate in mg/kg of body weight in the cases described are as follows:

Putting much-compared acute toxicity levels into perspective in the cases of humans, we find the following:

These evidences explain why Roundup ranks among the first pesticides that causes occupational poisoning in various countries.

Classification by hazard risk to eyes and/or skin

In studies reported by Williams et.al. (2000) regarding exposure of rabbits to the concentrated herbicide Roundup, it was proven to be a severe eye irritant and slight skin irritant, and when, a concentration commonly used in most aspersion applications (~1%), was diluted Roundup was seen to be only slightly irritating to the eyes and, essentially, not irritating to the skin.

POEA was reported by the same authors to be severely irritating to the skin and highly corrosive to the eyes, when tested in rabbits. POEA potential irritation levels is consistent with the active surface properties of surfactants in general. Considering these irritant or corrosive properties of POEA, and having proven that it can increase Roundup's acute oral toxicity in humans from 7 to 22 times (compared with glyphosate toxicity in rats), it can be assumed that it also contributes to making Roundup significantly risky as an eye and skin irritant in humans.

Concentration of Roundup Ultra in Applications on Illicit Crops

According to official information presented in national and international forums by the members and advisors to the Consejo Nacional de Estupefacientes de Colombia (National Narcotics Council), the mixture currently being used is a formulation which contains 38,6% of the active ingredient as an acid, equivalent to 43,9% of glyphosate IPA salt, and not the 41% contained in the Roundup which is commonly marketed. Furthermore, the POEA in Roundup Ultra might have been modified with respect to Roundup, in order to increase the biological action ability of the glyphosate contained in the formulation.

According to the technical parameters of the Consejo Nacional de Estupefacientes for aerial fumigation of illicit crops, contained in its Informe de actividades y funciones de auditoría ambiental ("Environmental Auditing Activities and Functions Report") of November 1999, the following amounts are applied in the mixture:

Consequently, concepts regarding environmental and health safety, made on the basis of risk characterization and assessment as of the estimated “normal conditions recommended for its use” in the country of the North, have no scientific ground in our environment since in Colombia the glyphosate being applied to illicit crops and all of the surrounding areas, is done by aerial means and with concentrations which are up to 26 times higher. That which is further aggravated by the addition of the Cosmo-Flux 411F surfactant, which can multiply the biological effect of Roundup by up to four times. Added to this regrettable situation is something even more perverse, related to the accusation as to the fact that the planes spray several times over the same areas when fumigating peasant zones, spraying the same field up to 4, 6 or even up to 12 times. (Information received by the Defensoría del Pueblo Ombudsman)

Coadjuvant Surfactants

Aspersion oils are products of mineral and vegetable oils, which improve adherence reducing washing away by rain and limiting evaporation thus permitting greater retention, deeper penetration and increased coverage of microdrops.

Surfactants are tensoactive coadjuvants or active surface agents used to modify the formulation or mixture's superficial[6] tension[7], contributing to improving the pesticide's biological activity.

Tensoactive substances or active surface agents are bi-acting agents or ambivalent materials that accumulate in the interphases of two inmisicible substances, establishing essential interaction between the continuous phase and the discontinuous or disperse part. They can be DETERGENTS or NON-DETERGENTS. Detergency is defined as a cleaning process, where stains and dirt are left in suspension or dissolved. By deterging is meant cleaning and object without producing abrasion nor corrosion. Therefore, surfactants used for agricultural purposes do not include industrial cleaners nor those commonly used for housecleaning, detergents for washing machines and others such as softners, shampoos, and bath products. (Parra, 1995)

Consequently, the conclusions by Williams et. al. (2000) regarding acute irritation, cumulative irritation, photoirritation, and allergic and photoallergic irritation from normal doses of Roundup with baby shampoo or detergents for washing machines —mentioned to conclude regarding the safety of using a mixture of Roundup Ultra (glyphosate + POEA) + Cosmo-Flux 411F, by aerial aspersion in forced "eradication" of illicit crops— are not relevant. Furthermore, up to date, there has been no report in scientific literature regarding research carried out to assess the risks of said mixture.

Plant leaves' waxy surfaces keep salts and polar or hydrosoluble compounds, such as glyphosate, from penetrating; but this limitation can be overcome by non-detergent surfactants (such as POEA and Cosmo-Flux 411F), which interact with both phases, alter the wax of the foliar cuticle and broaden the hydrophyllic canals, making way for the toxin . Similar actions occur with insecticides, surfactants and insect cuticles. (Parra, 1995; Penagos, 2001)

According to Williams, et. al. (2000), due to their physical-chemical properties, POEA and the other surfactants interact and solubilize the lipidic components which characterize skin and mucous membranes. In accordance with this statement, and with the effects of surfactants on insects' foliar and cuticle surfaces as described by Parra (1995), one can deduce that, if the mixture pesticide-surfactant comes into contact with skin and mucous —as is particularly occurring in illicit-crops areas in Colombia, where a mixture of Roundup Ultra (containing POEA) plus the surfactant Cosmo-Flux 411F, with glyphosate concentrations 26 times higher than those normally recommended is being applied through aerial spraying— acute toxic effects of contact as well as glyphosate's penetration and systemic action might be dramatically increased. According to the dermatologist Doctor Homero Penagos (2001), Roundup has caused burns and ulcers in those who labor in the banana plantings in Panamá, where there have been accidental spills; this same doctor has also had to deal with acute intoxication with systemic effects.

Parra (1995) summarizes the effects of surfactants or active non-detergent surface agents on leaves' waxy surface and on insects' cuticle (that which can be assimilated to effects upon skin and mucous) as follows:

1. “Greater foliar humidity and expansion of drops, which leads to quicker absorption of active agents by the surfaces they moisten, penetrating the aimed at microstructure in a rapid manner and avoiding dispersion.”
2. “Retention of the disperser on the target, achieving greater adhesion of the 'small drops'.”
3. “Reduction of the size of the particles in the sprinkler since large drops are not well retained by target surface while small drops stick better.”
4. “Increased drying time and water retention —at different humicity levels— active ingredients may adhere for longer time spans permitting greater control (agglomeration) of insects or fungi, longer-lasting action of the Active Ingredient on weeds or higher probability of absorption of the fertilizer by the leaf.”
5. “NON-IONINC coadjuvants can influence the size and form of dry active ingredient crystals. The size of pesticide particles, in some active ingredients, may have considerable effects on its action and persistence.”
6. “NON-IONINC coadjuvants increase pesticide solubility, particularly that of "small drops" during the drying process. These coadjuvants' concentration increases and allows for greater solubility of active ingredients due to micellization; thus these ingredients can penetrate the target more easily, through hydrophilic pathways (The Micelle is a particle which measures from 0,001 y 0,3 micras; it is formed by an aggregate of resembling molecules and constitutes a colloidal system.)
7. “Improved physical compatibility of the different pesticide formulations in the mixing tank. Formulation incompatibility may detract from active ingredient function, harming plants and destabilizing the emulsion and dispersion.”
8. “NON-IONINC coadjuvants influence increased biological activity as well penetration of plant by active ingredients applied. Humidity in healthy leaves increases penetration probability since coadjuvants can modify and dissolve cuticle wax, expanding ducts. Coadjuvants increase active ingredients acting ability but excessive levels of coadjuvant or high ethyl oxide contents can block translocation of active ingredient inside the plant.”

Coadyuvant Cosmo-Flux 411-F: According to Cosmoagro, a Colombian company located in Palmira, in its technical sheet 313.03 of May 30/94, the spraying additive for the Cosmo-Flux 411F agrochemical agent —formulated by said company— is chemically described as a mixture of mineral oil and specialized non-ionics surfactants with coupling agents. The active ingredient, described as a mixture of hexitan esters, is supplied by ICI Specialty Chemicals. Active ingredient additives formed by liquid isoparaffin can be bought from Esso or Exxon. These ingredients are described as follows:

Active ingredient: Mixture of hexitan esters (lineal alcohols + extoxilated aryl) - Mixtures of tensoactive estereoespecific non-iónicos based on lineal alcohols etoxilados propoxilados with small quantities of extoxilated aryl composite.

Additive ingredients: Liquid isoparaffins - High-purity isoparafinic oil.

Cosmo-Flux 411-F's effectiveness is considered four (4) times higher than that of conventional aspersion oils due to the synergism between the paraffinic oil and the specialized tensoactive. This result is similar to that reported on by Collins, R. y Helling, Ch. in his research paper: “Increased control of Erythroxylum sp. by glyphosate utilizing various surfactants” (carried out in hothouses in Maryland, USA and in fields in Hawaii from 1995 to 1997), study which experimented with several cationic and non-ionic surfactants on the effectiveness of glyphosate in the destruction of coca plants.

The non-ionic included Silwet L-77 and Agri-Dex, which, when used individually, did not increase the activity of glyphosate. But, which, when combined 1:1(in volume) in the mixture called AL-77, were the most effective, multiplying by four glyphosate's toxicity for coca, compared to Roundup's commercial formulation. These surfactants chemical compositions are described thus: Silwet L-77: Polialkileneoxido-modificado heptametiltrisiloxano; Agri-Dex: Mixture of polietoxilated derivatives of petroleum oil on the basis of paraffin, emulsifiers based on ester sorbitan.

Animal and Human Intoxications

However, aerial fumigation in illicit-crop areas in Colombia differ greatly from recommended agricultural use in the USA. As previously mentioned, effective discharges of 23.4 L/ha of Roundup Ultra (10.3 L/ha of glyphosate), are the equivalent of a concentration 26 times higher than that recommended (~1%), and the mixture with the Cosmoflux 411F surfactant can increase fourfold the herbicide's biological action, bringing forth relative exposure levels which are 104 times higher than the recommended doses for normal agricultural applications in the United States; doses which, according to the study mentioned, can intoxicate and even kill ruminants, more so if we consider that the planes repeatedly cover the same ground fumigating it several times over, as denounced with the Ombudsman, Defensoría del Pueblo in Colombia.

The above approaches might help to explain, partially[8], why there is an increasing number of complaints being lodged from the zones being fumigated regarding human and animal intoxication, mortality of cattle, horses, pigs, dogs, guinea pigs, ducks, hens and fish. Up to February 21st 2001, the consolidated reports from the Police of the Guamués Valley in the Putumayo, informed of 4.289 persons affected, 178.377 animals affected, and 7.252 hectares of crops affected (plantain, manioc, corn, pasturelands, mountains, stubble, coca and others,) by the spraying which was initiated towards the end of the month of December of the same year. During the months of January and February of the year 2001, the Personerías, jurisdictional authorities, of the San Miguel and Guamués Valley municipalities received 1.443 complaints by heads of households of which 1.164 (80%) indicated that one or various members of the family had suffered harmful health symptoms which they attributed to the fumigations.

The authorities in charge of the fumigations tend to underestimate these complaints, qualifying them as “orchestrated and induced” by the narcotics-traffic and insurgent organizations, assessment which is based on the US State Department's "scientific" reports regarding the innocuous effects of glyphosate on human and animal health, when used under "normal" conditions. (Pérez, 2001)

If we view the situation from the perspective of effects on human beings, Roundup is more toxic for humans than for cows, since all of the doses (in mg of Roundup/kg of body weight) given to cows in this study were deadly for the people who swallowed them intentionally, according to the data from Williams et. al., 2000. Consequently, the estimate of an exposure to glyphosate 104 times greater due to aerial application of Roundup Ultra + Cosmoflux 411F, raises the significance to dramatic proportions in the case of human beings.

This analysis coincides with that which has been observed by the medical personnel in the hospitals in the South of Colombia, who have affirmed that as of the first fumigations, there was a noticeable increase in consultations due to severe eye and skin irritations, abscesses, impetigo, gastrointestinal complaints (abdominal pains, diarrhea, nauseas, vomiting), acute respiratory infections (bronchitis, influenza, asthma), and conjunctivitis.

Intoxications are even more severe in the case of children due to various circumstances, among which the following can be mentioned (Nivia, 2000; Williams et.al., 2000):

1. Due to their smaller size they are poisoned by smaller quantities of pesticide than adults.
2. Due to immature development they are more susceptible than adults to the effects of poisons.
3. The are more exposed in their diets since they eat proportionally more food per kilogram of body weight than other age groups.
4. Frequently, children's liver and other organs are not capable of decomposing certain pesticides.
5. Children's immunologic system is not wholly developed thus increasing risks of illness.
6. Children that live in the countryside are in contact with pesticides used in agriculture and incur therefore more risks of increased potential exposure.

Foodstuff Contamination

Although washing foodstuff is supposed to reduce the hydrosoluble residues deposited on the surface, no assessment has been made regarding the degree to which surfactants' incremental adherence effect might reduce the efficacy of washing; just as the effect of washing with highly contaminated has not been taken into account.

Glyphosate and AMPA residues —which penetrate plant tissues— are not eliminated by washing or peeling the edible parts. According to the World Health Organization , using Roundup as a dessecator[9] prior to harvesting wheat crops leads to "significant residues" in the grain; the bran might contain residues from 2 to 4 times greater than the whole grain, and these do not disappear after toasting. Residues in barley might be transferred to beer (Dinham, 1999; PAN/Asia y el Pacífico[10].) The Colombian National Sugar Cane Research Center (Centro Nacional de Investigación de la Caña de Azúcar en Colombia -Cenicaña), reports that residues have been analyzed through a thin layerand liquid chromatography in its own laboratory and in samples sent to the United States in order to determine possible contamination of sugar, and that no residues of glyphosate have been detected. [11]

The use of glyphosate on forage and animal feed may result in residues in kidney, meat, milk and eggs. These residues are stable for up to a year in plant materials and in water, and for up to two years in products stored for animals. In wildlife environments they may persist for long periods: in a study reported by PAN/Asia Pacific 45 mg/kg were found in lichen 270 days after application. Analyses of wild cherries after application in wooded areas indicated that residues lasted over 0,1 ppm for at least 61 days.

Glyphosate and AMPA metabolite residues may be a hazardous for consumers and for this reason tolerance levels or maximal limits of glyphosate residues have been established for different foodstuff. Following are some of the limits which are currently stipulated for North America:

Precautions and Warnings of Use on the Roundup Label in Colombia

• Do not store nor carry together with seeds and foodstuff for human or animal consumption.
• Do not store in living quarters.
• Use protective glasses, gloves, rubber boots and clothing when handling and applying this product.
• Do not smoke, eat or drink while preparing or applying this product.
• Apply when wind is calm.
• Avoid contact with eyes and skin. This causes irritation.
• When finished, change clothes and bathe with abundant soap and water.
• Do not contaminate water sources.
• Do not apply nor pour leftover portions of this product directly in water bodies.
• During application keep product from falling on leaves or green parts of plant stem.
• Suspend application if rains are imminent.

Attachement No. 1

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