In regards to application for Investigation - Fisheries and Ontario Water Resources Act




You will recall that we spoke about this issue. I was very disappointed to see a document designed to affect public policy that so deliberately disregards the weight of objective scientific evidence about herbicide use in the forest. I strongly believe that those trying to influence public policy have an ethical obligation to become fully informed and to objectively present all available data about an issue. This document is so one-sided that it is not defensible in any reasonable public forum.


If your cup is already full, do not ask for more tea.


Bob Wagner

Robert G. Wagner
Henry W. Saunders Distinguished Professor in Forestry
Director, Cooperative Forestry Research Unit
5755 Nutting Hall
University of Maine
Orono, ME 04469-5755

Phone: 207-581-2903
Fax: 207-581-2833

From: Joel Theriault []
Sent: Tuesday, July 24, 2007 7:40 PM
To: 'Bob Wagner'
Subject: RE: Saving Northern Ontario from Chemical Contamination




Thank you for the comments.  I sent it to you for a reason, to get some input.  Realize you were working w/ VMAP and the program ended over a decade ago.  But if you do have the time, please pick apart the argument a little and send me some thoughts.  I’ll post those thoughts up in the forum to “balance” the issue a little more.  Show me what’s wrong with thinking that the way forestry was done pre herbicides was inadequate.  Progress shouldn’t come at the cost of environmental degradation right?  I understand that herbicides are one of many tools and at the time VMAP ended, they were selected as being the most cost effective tool.  Also at that time, much less was known about the health / environmental effects of this particular tool. 


Understandably you feel herbicides are totally safe.  The Ontario College of Family Physicians and most other medical groups feel the contrary to be demonstrated by the empirical evidence. 


Always appreciate your input and looking forward to it ;)





You overstate my support for herbicides being “totally” safety. Nothing is total, but many things are acceptable.


Context and scientific understanding is everything in the pesticide debate. Herbicides in school yards and in the forest are completely different discussions. Rational social decisions about this issue MUST be made by good scientific information and quantitative risk analyses that include the social benefits of their use. If not, these important decisions are made based on superstition rather than science. There have been numerous quantitative risk analyses on the use of herbicides in the forest over the past several decades. These analyses, both environmental and especially human health, have clearly shown that both risks are astronomically low when currently registered forest herbicides are used appropriately. This kind of analysis should not be confused with the kind of distorted selection of “facts and findings” that are presented in your document and on numerous anti-pesticide web sites.


Despite this body of scientific evidence, one can find all manner of public concerns about herbicide use. I was so fascinated by this topic that I researched it about 10 years ago in Ontario (see attached). I find it fascinating that people want public policy decisions to be based on good science, but then reject the science-based decisions when it conflicts with their perceptions (superstitions). The science about the health and environmental risks of herbicide use in the forest is stronger than most all other things we do in the forest, yet the public perceptions are contrary to it. The risks of the alternatives to herbicides are far less understood than for herbicides, yet people persist in advocating their use. If you care about human health and environmental protection, then you should be aware that the use of cutting tools, mechanical equipment, and fire as frequently advocated alternatives to herbicides can present significantly higher risks to both people and the environment.   


Re: medical professional objections to herbicide use. I have encountered a few physicians over the years that object to herbicide use. I have pointed out to them that the toxicological science used to evaluate the safety of pesticides is exactly the same science that they use when safely prescribing pharmaceuticals to people. It is an amazing contradiction that they accept the science when exposing their patients to very risky drugs, but then reject it when evaluating pesticide safety to those same patients in the community. I find these physicians to be more interesting than their opinions on the subject.


I am under no delusion that you will see my point of view on this difficult topic. My view has evolved over the past 25 years of being directly involved in forest research on this topic. When I was a young forest ecology graduate student, I bought into all the same anti-pesticide propaganda that you are peddling. This is easy to do because it is so compatible with human perceptions of risk on this topic. Few people will put in the work required to understand the technical aspects of this issue, hence your views will prevail in most public forums.


If you care at all about successful regeneration of softwood trees following harvest in northern Ontario, then you should be very interested in the benefits of vegetation management, including the use of herbicides, in those forests. Regeneration failure is a huge problem across the boreal forest in Canada.


I can accept your objection to pesticide use on philosophical grounds. It is a rational and understandable position. However, do not confuse philosophical objections with scientific understanding of the risks. The objective weight-of-evidence science simply does not support your position on this issue.


Bob Wagner


From: Joel Theriault []
Sent: Saturday, July 28, 2007 2:54 PM
To: 'Bob Wagner'
Subject: RE: Saving Northern Ontario from Chemical Contamination


It’s a great argument you make below and it will be posted up to equalize the debate a little more.  Just a random thought, how do feel about spraying herbicides for the sake of re-growing jack pines in Ontario knowing that the pine beetle has jumped the Rockies and has a clear path to Ontario?  Then I suppose we’ll have to spray insecticides as well as herbicides to keep our forests “healthy” right?

Will touch base on the note below sooner ;)


From: Bob Wagner []
Sent: Saturday, July 28, 2007 3:32 PM
To: 'Joel Theriault'
Subject: RE: Saving Northern Ontario from Chemical Contamination

I suspect spraying would have done little to avoid the BC and Alberta lodgepole problem. Questionable whether jack pine has a chance of being affected given that the problems in the Rockies are likely due to regional climate issues, for now any way. Insecticides have been used by the OMNR on the spruce budworm and other pests with good success over the years. The forests were “healthier” by conventional definitions in most cases.

Are you against BT too? How do you feel about naturally-derived pesticides? You might find it interesting that plants and animals have evolved pesticides naturally throughout evolution. Allelopathy is basically plants playing the herbicide game. Pesticides are not recent to humans either. The Egyptians used hemlock & aconite in 1200 B.C. Homer (1000 B.C.) describes how Odysseus “fumigated the hall, house and court with burning sulfur to control pests”. The ancient Romans (100 A.D.) killed rodents and insects with hellebore, and the Chinese (800 A.D.) mixed arsenic with water to control insects. Modern chemistry and environmental science has made us much better at the game biology and human cultures have been playing for millennia. So, pesticides are not something invented by big corporations to poison us all.

By the way, soap is nothing more than a pesticide for bacteria. Didn’t your mother tell you to wash your hands in pesticide (soap) before eating? Chlorine in water is the use of a pesticide – required by law by the way and any physician will tell you is the primary reason for dramatic increases in public health over the past century. Where is the uproar about using spermicide to directly eliminate humans, well half-humans?

Just some food for thought.




Saturday September 15, 2007


I apologize for taking soo long to get back to you on your discussion points. 

As I understand the issue, the debate has passed the point of recognizing that the chemicals being applied (glyphosate and 2,4-D based herbicides) pose a potential human health risk.  The position in the email below seems less condemning than other literature I’ve seen but it is still on point.

From: Irene Gallagher (Division Office) [mailto:IGallagher@ONTARIO.CANCER.CA]
Sent: Thursday, September 06, 2007 4:40 PM
Subject: Re: The Canadian Cancer Society's position on the non-essential exposure to glyphosate and 2,4-D

Dear Mr. Theriault,
Thank you for your August 30, 2007 e-mail enquiry regarding the Canadian Cancer Society’s position on glyphosate and 2, 4-D.
The Society strongly believes that Canadians should not be exposed to known or probable cancer-causing substances at home, at work, or in their environment. Exposure should be reduced if it cannot be eliminated. Wherever possible, safer alternatives should be used.
We support the principle of Community Right to Know. We believe people have the right to know what substances in the environment they are being exposed to and how to help them make informed decisions about their health. In particular, we believe people have the right to know if they are being exposed to substances that are known or probable carcinogens. 
In the case of pesticides, the Society does not support the ornamental use of pesticides. Some substances used in pesticides are known, probably or possible carcinogens. The ornamental use of pesticides has no countervailing health benefit and has the potential to cause harm. The Society is calling for a 100% ban on the use of pesticides on private lawns and gardens as well as public parks, recreational facilities and golf courses for the purpose of enhancing their appearance.

We are aware of concerns about the potential carcinogenicity of glyphosate and 2,4-D, which are found in some pesticides.
The Society is committed to providing accurate and evidence-based information. We continue to closely monitor research on the link between pesticides and cancer.
Please do not hesitate to contact me should you have any further questions regarding the Society’s position on the use of ornamental pesticides at 800 268-8874 x 2231.
Kindest Regards,

Irene Gallagher
Manager, Public Issues
Canadian Cancer Society, Ontario Division
1639 Yonge Street
Toronto, Ontario
M4T 2W6
Tel: (416) 488-5402 press "1" ext. 2231
Fax: (416) 488-2872

The medical community seems to be saying (from all organizations) that we should limit our exposure as much as possible to these chemicals, citing health and environmental concerns.  If the chemicals aren’t safe for backyards in municipalities across the country, why would I possibly want them sprayed in my backyard up north?  The issue seems to be the quantity, and there is no science to speak on point with any certainty regarding the “safe” exposure level.  Have you seen any science regarding the health / environmental impacts when exposure occurs to both 2,4-D and glyphosate?

Regarding BT, its not an issue I’ve ever addressed … but any info you might have would be appreciated.  Regarding naturally derived pesticides, I guess it would be fact specific.  I’m not certain I’d want arsenic and water sprayed all over like the Chinese were doing to control pests.  Again, if you have some info on BT, I’d appreciate it.

I think the real issue here is that we’ve selected a means of vegetation management here in Ontario with fundamental problems.  Clear cutting and spraying herbicides can’t begin to mimic a forest fire.  We really don’t have the long term cumulative impacts from the chemicals we now choose to apply, but what we do know is troubling.  Medical officers across the country are urging their cities to put a stop to the non-essential exposure of their residents to these chemicals.  The “safe” exposure level seems to be at issue … and the government “safe” levels seem to be getting lower and lower.  Does that mean that the former “safe” levels weren’t actually safe for us?

I will continue to think about the issues you raised.

Best regards ….

Joel Theriault