For at least ten years the state has violated licensing requirements, 333CMR, and MGL 132B in using a chemical herbicide in the Crane Wildlife areas located off Rte.151. The larger main area abuts the MMR and the smaller Quail area off Hayway Road, both of which are administered by the Massachusetts Division of Fisheries & Wildlife. The use of unlicensed Division employees, with no training in application and without any personal protection or proper application equiptment as required by the Code of Federal Regulations ( Worker Protection Standard, 40 CFR part 170 ) would seem a major violation of law, ( industrial accident, or perhaps at the least, due to total disregard for safety, criminal negligence ), not to mention the enviromental impact to the underlying aquifer and the possible hazards to persons using this area, but will the state penalize those responsible? Certainly not, as any adverse findings would pose a liability to the state. The Southeast District office with three supervisors, a District Manager, Wildlife Manager, Fisheries Manager/Safety Officer, overseeing four employees an "accident" of this nature should not happen. With 1.3 employees per supervisor it makes you wonder about the state's "financial problem".
Even though the MA Pesticide Bureau lists this material on their web site as a restricted use product subject to license requirements, and during their investigation documented 104 illegal applications in only a four year period which could result in $2,600,000 in fines and/or 104 years incarceration, the Massachusetts Attorney General's Office has refused to investigate this matter, and is in fact defending those responsible. Is this any wonder, as the Environmental Police comprise the Attorney General's Environmental Strike Force, and they are a section of the Massachusetts Department of Fisheries, Wildlife & Environmental Law Enforcement. Another violation not addressed is the purchase without a license from Arborchem Products Co.in Mechanicsburg PA, and the subsequent violations of Federal Law, the transportation of the material across state lines. Many private companies receive large penalties for far less serious violations. Sure does give new meaning to the phrase,"Justice is blind". Your tax dollars at work !!
The material used is an organophosphate chemical manufactured by Dow Chemical (dowagro.com/ivm) and distributed under the trade name of Pathway. The composition of the material is Dichlorophenoxyacetic acid (2,4-D), Picloram, ethylene glycol, isopropal alcohol, triisopropanolamine, and additional "inert" ingredients. Both 2,4-D (banned from use on Veterans Administration property) and Picloram are known to be contaminated during manufacture, 2,4-D with one of the dioxin family of compounds (CCD's) and Picloram with Hexachlorobenzene. The combination of 2,4-D and Picloram has been used in the past, in Viet Nam where it was known as Tordon101 or Agent White. Originally the organophosphate group of chemicals were developed as nerve agents in the early 1900's, and are known for their nuerotoxic properties in addition to their ability to affect celluar structure as edocrine disrupters. Have we forgetten the lessons learned from the Viet Nam era? Even Dow cautions that Pathway "is not appropriate for use on sand to sandy loam types of soil, since it will seek out underlying ground water". In addition Hexachlorobenzene breaks down to Pentachlorophenol contaminating the soil. Both of these are suspected to be carcinogens, yet neither dioxins or Hexachlorobenzene are required to be listed as ingredients, since they are byproducts of manfacture.
To use this material in areas that are frequented by many different groups for recreation, from hunters to persons walkig their animals, people involved in horse and dog trials, to people just enjoying nature is a travesty. This is an insidious material that may have taken an unknown toll over the years. Restricted Entry warning signs,required by law were never posted which may have led to unknown exposure. Is this acceceptable to you and those you care about ? Is it acceptable to have a massive cleanup operation at the Military Reservation, and yet continue to pollute the adjacant land areas over the major aquifer, the Cape's primary water resource ? If not, it is time for citizens to demand an investigation and to hold those responsible accountable for their actions. Massachusetts new web site uses the catchphrase "Your Government, Your Way." Perhaps it should read "Your Government, Our Way,"like it or not!
To those interested in this subjuct I have created an additional page at www.angelfire.com/ma3/pollution That page can be found also by a Google search for "Cape Cod Pollution" and will be the first hit found. That page has multiple links that may be of interest.
If it can kill a tree, imagine what it could do to you !!!!
Consider this, in most cases of a tree being struck by a vehicle, the tree survives. Could you ?
