Comments from the Ontario Vegetation Management
Association on the Proposed
Cosmetic Use Pesticide Ban in Ontario
The Ontario Vegetation Management Association (OVMA) is seeking an
exemption for the use of pesticides for Industrial Vegetation Management.
The OVMA believes in the concept of Integrated Pest Management (IPM) which,
simply put, is the managing of vegetation utilizing a variety of legitimate
tools and methods that is supported by good science. Pest management should
be done integrating all aspects of the physical and social environment and
considering all components of the biological system. Integrated pest
management considers all options to arrive at the best approach to manage
the pest problem.
Herbicides are a legitimate and essential tool in this industry segment.
Herbicides are tested and registered by Health Canada and scheduled by the
Ontario Ministry of the Environment. The Pest Management Regulatory
Agency is the branch of Health Canada that is responsible for regulating
pesticide use in Canada. They have experts in pesticide chemistry,
toxicology, environmental fate of pesticides and related sciences.
Currently available pesticides were registered after analysis of their
relative risks and benefits. Pesticides are also periodically re-evaluated
to consider new information. New evidence of health or environmental
risk can trigger a review of a particular registration. This science-based
system has served Canada very well, balancing the needs of users with the
need to protect people and the environment.
Herbicides used for industrial vegetation control are applied by
professional applicators that undergo extensive training regarding their
use, storage and transportation. In most cases, this training is more
extensive then what is required in the agricultural sector and at least as
strict as those followed in the forestry and golf course industries.
These professional applicators follow strict application guidelines, use
suitable protective equipment and provide necessary public notification of
applications. Regular education of applicators is provided in-house or
through bi-yearly industry seminars presented by the OVMA as well as by
other organizations.
Herbicides used to control vegetation in industrial situations are
necessary for human safety and economic well-being and protection of
property. They are not a cosmetic use; and should therefore be
exempted from the proposed amendments to the Pesticides Act. A
detailed explanation of these industrial-uses follows:
Herbicide Use Summary for Industrial Vegetation Management
in Ontario
Brush Control
Utility transmission and distribution rights-of ways. The
removal of tall growing vegetation is vital to the safety and reliability of
electrical transmission and distribution systems. Herbicides are used
to completely remove a targeted tree problem, including the potential of
re-suckering root systems. Tree-to-wire interference causes fire,
wastes electrical power and can cause complete system failures. The
trigger for the 2003 blackout in NE US and Canada was due to tree-to-wire
interference on a right-of-way in Ohio. Utilities must maintain their
corridors to strict guidelines that were developed as a result of this
blackout, and most have to use a herbicide tool in this maintenance program
due to the sheer size of the area that must be maintained.
On pipeline rights-of-way, tall growing vegetation can limit access to
inspectors that routinely monitor for gas leaks and tree root systems can
interfere with underground pipe integrity.
Range control for Department of National Defense (DND) Properties.
Large training areas are required to be free of tall growing vegetation in
order to provide adequate grounds for soldier training, parachute landings,
etc.
Department of Transportation (DOT) - Sightlines. The
control of tall growing brush and vegetation and their potential root
suckers is important wherever sightlines maybe compromised by their
presence. This includes road intersections, merging lanes for highway
on-ramps, rail-to-road intersections, sharp corners, etc. Tall
vegetation can also hide road signs creating a risk to motorists and can
hide wildlife that may run out onto roadways increasing the hazard to
motorists.
Total Vegetation control (TVC) or Bareground
Applications
Utility transmission, distribution and facility substations – gravel
areas. Total Vegetation Control is an important part of facility
maintenance for reasons of security, maintaining structural integrity,
accessibility, and reducing potential for fire or electrical shock.
Vegetation holds water which increases shock hazard for workers and impedes
access to equipment by maintenance personnel. Desiccated vegetation
(drought, fall/spring) increases fire hazard.
Railway ballast (gravel-bed) areas. Total vegetation control
for mainline and yard ballast areas. This is important to maintain
structural integrity, accessibility, and asset protection. Vegetation
speeds the rotting of wooden ties, slows the ballasts ability to shed water
and impedes the movement of machinery (switches, rail cars) and access to
equipment by railway personnel. Desiccated vegetation (drought,
fall/spring) increases fire hazard.
Industrial installations and facilities – gravel areas.
Total vegetation control is necessary in and around industrial installations
such as oil refinery’s, gas facilities, steel mills and anywhere an
industrial complex contains a “gravel area”. Control is required for
several reasons but of particular importance are fire protection, asset
protection and access to equipment.
Fire breaks for Department of National Defense (DND) Properties.
Firing ranges on DND properties frequently require vegetation-free zones to
limit the spread of fires caused by exploding ordinance.
Department of Transportation (DOT) corridors and structures.
Total vegetation control along guard rails and medians (to protect assets
and improve visibility to the driving public). Vegetation in the
cracks of asphalt and concrete and highway shoulder areas excels asset
deterioration and erosion.
Herbaceous Weed Control
Rough Turf such as roadsides and other transportation corridors.
Control of broadleaf weeds that spread along transportation corridor
rights-of ways (i.e. seeds moved by vehicle/train traffic) is an important
consideration. As indicated for brush, the control of tall growing
vegetation and their potential root suckers is important wherever sightlines
maybe compromised by their presence. This includes road intersections,
merging lanes for highway on-ramps, rail-to-road intersections, sharp
corners, etc. Tall vegetation can also hide road signs creating a risk
to motorists and can hide wildlife that may run out onto roadways increasing
the hazard to motorists. Typically, roadside spray programs also target
broadleaf weeds that, if left uncontrolled, can potentially spread into
farmer’s fields and livestock grazing land. This practice also limits
the spread of noxious and/or invasive weeds.
Range and Pasture. The use of herbicides in range in
pastureland to control broadleaf weeds, reduces grass competition and
increases grazing productivity.
Facility Renovation. Renovation of severely weedy properties
requires the use of herbicides to remove vegetation. Without this
tool, reestablishment of cover is almost impossible due to the competition
of the weeds and the persistent seed bank in the soil.
Noxious and Invasive Weed Control. Herbicides are used in
utility and industrial corridors to control noxious and/or invasive plants
that tend to prefer the disturbed soil conditions that occur. Examples are
facilities yards, roadsides, gas and power line rights-of-way. The
prevalence and occurrence of invasive plants is on the rise due to human
activity and changing climatic conditions.
Many invasive plants have human health impacts and threaten endangered
species, rare native plant communities and native plants. For example,
dog-strangling vine threatens alvars and tall-grass prairie communities. As
another example, common reed (Phragmites) has displaced native plants,
causing the loss of habitat for many bird species. Other examples that
pose serious health risks for the public and utility workers are giant
hogweed and wild parsnip, two invasive weeds, and poison ivy and buckthorn,
two noxious weeds. Invasive weed species severely limit efforts or
make it impossible to re-establish forest cover and native plant communities
in parks and urban lands due to severe competition to seedlings and young
transplants.
The use of herbicides for control of invasive and noxious plant species
control should be allowed. Many of these invasive plant species are
difficult to control even with the use of herbicides and require specific
herbicide programs. For this reason, use of the most effective products and
programs should be permitted.
Aquatic Weed and Algae control
A small number of herbicides are registered to provide weed and algae
control in aquatic environments. Aquatic weed pressure is on the rise
due to a number of factors. Zebra mussels filter water that, in turn,
allows sunlight to reach deeper and provide more light for plant growth.
Warming water bodies and increased human activity (farming, septic tanks,
etc) introduce nutrients that speed weed growth and cause algae blooms.
Invasive water weeds from southern regions are becoming established further
north due to seed transportation by human activity. Aquatic weeds can
interfere with water intake systems, clog marinas and other boating
navigational channels as well as limit recreational uses.
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