Is the City of Madison Following Its Pesticide Policies?
While in Warner Park on September 8 2014, I saw a Madison Parks employee spraying Roundup near the Warner Park Community Recreation Center (WPCRC), including along sidewalks just a few feet from the center’s bike racks, where many people, including young children, walk, bike, and play. It was a breezy day.
A few hours later, biking through the park again on my way home, I didn’t see any standard warning signs. Two days later, walking through the park, I noticed one sign, under some shrubs, near a raingarden in a corner of the parking lot hundreds of feet from the center’s entrance and bike racks where I had seen Roundup applied two days earlier. It was not at all “readily visible,” as required by the policy. The raingarden was fenced off, and it appeared as if plants in the raingarden were sprayed (presumably to eradicate non-native and/or invasive plants). I walked around the raingarden and saw no other signs.
Madison’s Pesticide Policies
Citizens in many U.S. cities, including New York City, have questioned the use of Roundup and other pesticides in parks and other public places because of growing evidence of their toxic effects on animals, plants, and insects, which can lead to cascading effects on whole ecosystems over the long-term, and the health risks they pose to pets and people (e.g., see here, here, here and here and many more…).
Since at least 1991, Madison citizens have advocated for –and elected officials have passed—various policies restricting pesticides in the city. Unfortunately, it seems that these policies are being ignored, are not enforced, and/or are perhaps “forgotten” over time.
In 1991, the Madison Common Council passed Resolution 47.702, which called for limits on the use of pesticides in Madison. In 2002, citizens raised concerns about the rising use of Roundup in city parks, after which Mayor Bauman issued a moratorium on its use and directed several city committees to review the use and safety of Roundup.
We haven’t yet located records of exactly what these committees decided, but presumably their reviews led to the development of the city’s Integrated Pest Management (IPM) policy in 2004. That year, the Public Health Commission also recommended the formation of a “subcommittee of pesticide experts that could assist staff with the evaluation of plans and pesticide use reports.” This subcommittee was directed, per Madison General Ordinance (MGO) 7.01(1)(a), to meet every year to review agencies pesticide use reports to see how well they complied with the city’s IPM policy and submit these reports to the Board of Health.
It appears that the IPM policy developed in 2004 is still Madison’s current pesticide policy (though the subcommittee was recently dissolved—see below). The purpose of this policy is described as follows:
“The purpose of this policy is to eliminate or reduce pesticide use to the greatest possible extent. The City of Madison agrees with the US EPA that “all pesticides are toxic to some degree, and the commonplace, widespread use of pesticides is both a major environmental problem and a public health issue.” For this reason, all departments will evaluate and give preference to non-pesticide management practices and use reasonably available alternative pest control methods, will minimize their pesticide use through Integrated Pest Management, and will use least risky pesticides as a last resort.” (highlights added).
Further elaborating on the conditions in which pesticides may be used (as a last resort), the document notes, “Chemical pesticide may be considered if: a. The non-toxic methods of pest control, such as Cultural Controls, Physical Controls, Mechanical Controls, and Biological Controls have been shown to be ineffective; And; b. Monitoring has indicated that the pest will cause unacceptable health or safety hazards, or an unacceptable reduction in the intended use of the property.”
Will the small plants growing on the edge of the Warner Park parking lots cause “unacceptable health or safety hazards or an unacceptable reduction in the intended use of the property”? It’s hard to imagine how they would do so. Our guess is that these Roundup applications were done for aesthetic reasons, which is not in line with an IPM approach.
Did Parks staff consider and/or try alternative methods to eradicate the harmless vegetation before resorting to Roundup? Parks staff and volunteers did use alternatives in the past. According to the 2009 IPM report for the Madison Parks Department (see bottom of pg. 17) in 2009 an organic herbicide called Ground Force (made of citric acid, garlic extract vinegar and yucca extract) was used for weeds in the WPCRC parking lot. No synthetic pesticides were used on the WPCRC property at all. What organic alternatives, or other types of strategies, were tried this year before resorting to Roundup?
Regardless of Parks’ rationale for using Roundup in this context, if it was following IPM policy, the non-chemical alternatives that were attempted before resorting to Roundup, and the success/failure of these attempts, should have been recorded. Moreover, the amounts and types of pesticides used in the recent treatment—as well as the amounts of types of all pesticides used during 2014 (to date) in Warner Park and previous years—would be recorded. Were they?
Pesticide Policy Committee eliminated in 2013
It’s not clear how well city agencies are following IPM policies currently, especially since the ongoing oversight process established 2004 is no longer in place. In May 2013, Mayor Soglin and Public Health Madison Dane County decided to eliminate the Pesticide Policy Committee, repealing MGO 7.01(1)(a). A May 30 2013 PHMDC document explains the reason for eliminating the committee:
“The Pesticide Management Advisory Subcommittee has been a great help to the Board of Health and PHMDC staff. With the subcommittee’s help, most City of Madison agencies have become more adept at applying integrated pest management (IPM) principles and have sought out pesticide professionals that support these principles.”
After highlighting this apparent success in implementing IPM, however, the document goes on to hint at problems assuring that all agencies complied with the policy, in part because the subcommittee had little power: “However, PHMDC staff and subcommittee members have been frustrated at times when City agencies have not made changes or improvements identified in the annual reports. The current policy places the responsibility for change on the board, committee, or commission that has oversight over the agency in question (Paragraph 5d). If this body does not support change in the agencies practice based on recommendations of the subcommittee, neither PHMDC nor the subcommittee have authority to pursue further action to ensure compliance.”
Recent documents indicate that the pesticide policy is still in effect despite the dissolution of the committee. The Pesticide Management Report for 2012-2013 states the following:
“…Reduction of pesticide use is important because misuse or overuse of pesticides is both an environmental problem and a public health issue…The Policy on Pesticide Use on City Property will remain in effect and Departments will be required to submit annual use reports/plans to Health, but review of the reports will be internal within Health. The plan for the future will be a more informal review and to make the reports available for public comment/review, most likely online….While not perfect, it was felt that the majority of City Agencies have adopted IPM principles and practices since the Policy was implemented in 2004, and formal oversight by the committee was not needed. Also factoring, was the difficulty in maintaining a full committee in recent years.” (underlining added)
If most agencies “have adopted IPM principles and practices” and “formal oversight by the committee” is “not needed,” then PHMDC should have detailed reports of their pesticide uses and amounts for 2014 and previous years, as well as alternatives attempted. We located only one fairly thorough report online from Parks for 2009 (linked to above), but no others. For other departments and years since 2004, we were only able obtain electronic copies of “Pesticide Management Reports.” These reports are not available to the public online as far as we can tell.
Further, the “Pesticide Management Reports” are not IPM reports; they are very brief summaries by PHMDC staff that do not include any pesticide use details. For instance, the 2012-2013 Pesticide Management Report (linked to above), which is similar to all the other reports, simply states “yes” under compliance for the Parks Division, and under “Successes and Commendations” it says “Good use volunteer efforts in non-chemical control.” Under “Concerns,” it says “none.” In 2014, as we recently witnessed, Parks decided that Roundup should be used around Warner Park Center parking lots and raingardens and it is not clear whether non-chemical controls were attempted. We would like to know what the rationale was for these applications, what alternative were considered, what quantities of pesticides were used, and where they were applied.
In sum, if IPM is indeed being followed by City of Madison agencies, then reports with specific IPM details should be available to the public online, with opportunities for the public to comment and provide input on them–the “plan for the future” stated by PHMDC in the 2012-2013 document cited above. At this point we are not aware of online IPM reports or opportunities for citizen comments.
We look forward to online, detailed IPM reports for City of Madison agencies, as well as opportunities to provide comments and input on them. Hopefully this plan will be implemented soon.
 The applicator told me what she was spraying. The pesticide applicator was wearing shorts, a short-sleeved shirt, and no protective gear (not even gloves). This seems inadequate to protect the applicator from dermal, eye, and/or inhalation exposures from pesticide spills or aerial drift. Typical guidelines usually wear latex/rubber gloves, protective eyewear, long pants, long-sleeved shirts, etc. According to Madison’s IPM policy, “A standard notification plan that provides, at a minimum, readily visible posting for a period of 24 hours prior to a pesticide application (when possible) and a minimum of 48 hours following the application. These time intervals may be extended based on health or safety concerns. For areas that receive pesticide applications on a regular basis, permanent signs will be posted.” Raingardens are created to facilitate the infiltration of water downward to groundwater—in part, to prevent potentially harmful runoff from going into surface water. It is a good thing to keep pesticides from running off into surface water, but if pesticides are sprayed on raingarden plants (native or not), they and/or their breakdown products (often just as if not more toxic than the active pesticidal ingredients) may filter down into groundwater. This is a troubling tradeoff. What quantities of pesticides were sprayed on this raingarden? What alternatives were attempted? The details of this policy are uncertain. Some newspaper articles give the impression it restricted pesticide use in the entire city, and others suggest it restricted use only on Madison Metropolitan School District properties. We are still doing research to learn the specifics of this past policy. According to Madison’s 2004 IPM Policy: All departments will maintain appropriate records on pest monitoring data collected, pest control actions attempted (both non-chemical and chemical), and results of pest control activity. All departments will submit by February 1st an annual report to the Public Health Commission. This report will contain the following information:
a. Completed Pesticide Application Summary for all pesticide applications made in the previous year. Application data must include: purpose, location, and amount of each pesticide product applied, including the amount of active ingredient.
b. Annual summary of non-chemical pest control activities.
c. Estimated size of the total area managed for each pest problem in a given year. The area managed will likely exceed the area treated.
d. A summary of any complaints received regarding use or the perceived need for use of pesticides, including the date complaint(s) was (were) received and thenature of the complaint(s).
e. A pest management plan for the coming year. The plan will contain the following information for each type of pest problem:
1. Definition of Roles. Identify who will: serve as the IPM Coordinator, perform pest monitoring, evaluate pest control alternatives, decide which pest control alternative to use, and implement pest control measures.
2. Pest Management Objectives. Identify the action thresholds (i.e., pest population levels) to be used to decide when some type of action should be taken to control the pest problem.
3. Monitoring Plan. Describe the methods to be used to monitor the pests and the frequency of monitoring.
4. Control Method Selection. Describe the types of pest control methods to be evaluated and the criteria used to choose the appropriate control method.