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PARC meeting minutes May 17, 2006
Attendance
Board members present
Chris Kirby – PARC Board Administrator
Dale Mitchell – ODA Co-Chair
Michael Heumann – DHS Co-Chair
Gordon Simeral – OSFM
Brad Knotts – ODF
Garnet Cooke – OR/OSHA
Richard Kepler – ODF&W 

Board members absent
Gene Foster – DEQ
Sandy Giffin – OHSU/Poison Control 

Consultants present
Dr. Jeff Jenkins - OSU
Dr. Dan Sudakin – OSU 
Dr. Fred Berman – CROET
Joan Rothlein – CROET
Lauren Slusser – OSPH
Will Lackey – ODOT
Kaci Agle – ODA, PARC 

Guests present
Winston Ross – Eugene Register Guard
Amy Chapman – Lincoln County Health Department
Bill Emminger – Benton County Health Department
Paulette Pyle – Oregonians for Food & Shelter 

Introductions
  • All present were introduced. Called to order: 9:05 am.
  • Gordon Simeral introduced himself as the representative from OSFM, in lieu of Chris Kuenzi, perhaps indefinitely. His contact information will be added to the referral criteria and to the PARC contacts page.
  • Minutes from the March 15, 2006 meeting were tentatively accepted pending any comments submitted to Kaci Agle by May 24, 2006.


Old business
  • Update on securing a Memorandum of Agreement (MOA) with PARC Member Agencies: Chris Kirby provided this update, saying that all member agencies have either completed the process, or they have a version of the MOA in their possession with his signature, ready for theirs. Michael Heumann said, “the nagging will continue” until ODFW, OSFM and CROET complete the process, as all others have.
  • Referral Criteria: Kaci Agle said she received a few suggested changes from members responding to the draft distributed last week via email. Dr. Sudakin suggested that NPIC should be added as a conduit to OSU extension faculty including Dr. Jenkins and himself. Agle said she update the document again and provide to members via email when complete.
  • Old PARC Cases
    • AZM & Fruit Packing Houses – Hood River: As Gene Foster was unable to attend this meeting, this update was tabled until our next meeting.
    • Pudding River watershed: As Gene Foster was unable to attend this meeting, this update was tabled until our next meeting.
    • Walker Fish Case: Kaci Agle provided an update on the closure of this PARC case. It was classified by ODA and ODFW representatives with a certainty index of 4 (unlikely) and severity index of 1 (death). Rick Kepler provided his opinion, that a series of warm days lowered the DO (dissolved oxygen) content, then the application of copper sulfate “did them in.” Case summaries were made available.
    • Dallas community concerns: Michael Heumann said he invited TOSC staff to the meeting, but his calls were not returned. Brad Knotts said he got a letter from Kay Friedemann asking, essentially, “What do I have to say to make you care?” He reported she said she found ziram-containing products registered for forest uses in PICOL (Pesticide Information Center On-Line) and felt that she was misled. Dale Mitchell confirmed that there are no current registrations for ziram-containing products in forests in Oregon. Brad Knotts also said that there had been no notifications to the ODF regarding ziram-containing products in forests in Oregon. The group agreed that any online database can produce misleading results based on small changes in the search criteria. Agle asked what PARC may do if TOSC staff decides not to pursue a solution with Dallas community residents. Members agreed that a “Plan B” would be called for. However, Heumann said that TOSC has not officially “dropped it.”
    • Pitchfork Rebellion – Blachley area: Kaci Agle, Dale Mitchell and Brad Knotts discussed recent activity. They held a conference call in March with OSPH representatives, in part, to determine the residents’ history with each state agency. Only a few complaints had been received by one of the individuals named in the story, by the ODA related to a specific drift complaint that was not substantiated. Brad Knotts said the residents probably believe that state agencies will not respond to complaints. In any case- there seems to be a surge in herbicide-related concerns in the coastal mountains (see also Waldport petition). Garnet Cooke related a story about her friend and coworker (unnamed) who reported strange health patterns in the area, saying that doctors told women not to breast-feed because their “milk was bad.” She had encouraged the woman to report the “cancer cluster” to OSPH, and Catherine Thompson provided her with paperwork to collect initial surveys. Cooke said her friend backed down because the work would have been unpopular in timber communities. Dale Mitchell suggested we use the Resource Poster to make people aware of state resources. Jeff Jenkins cautioned that the article “Pitchfork Rebellion” was not a scientific article, and should not necessarily be assigned too much weight or value. Heumann said we couldn’t be sure; the reporter may have been giving voice to something real or selectively reporting to sensationalize the story. He agreed that there are no formal complaints. Mitchell suggested that these folks don’t want the government to get involved. Agle said it would be reasonable, in any case, to distribute Resource Posters and continue working to develop a website to educate Health Care Providers (HCPs) about pesticide poisoning.  Garnet asked for clarification of the process by which OSPH investigates cancer clusters. Heumann said he has been responding to this type of complaint for 22 years, and they receive 3-5 allegations per week. He said these claims are very rarely substantiated. OSPH does not have adequate resources to investigate each claim, so they “deputize” concerned citizens and ask them to collect initial survey information using a worksheet they provide. They also provide information and resources to concerned citizens. Heumann said that Oregon started a cancer registry in 1996 that is relatively comprehensive, estimating that 98% of cases are reported to the registry. However, finding something meaningful in that data is difficult.
    • Florence Case Recommendations – Kaci Agle introduced the topic and distributed a list of suggested recommendations, noting that the list is not exhaustive, and the list is open to other suggestions.
      • Recommendation #1 – Refer case to ODA for enforcement action, which may include counseling the applicator on entry times and the use of adequate ventilation in particular with the elderly and those more prone to a reaction to respiratory irritants and pesticides (originated with OSPH).

        The group agreed that ODA has already initiated an investigation that may lead to enforcement action. Mitchell said that the case had been referred to EPA Region 10 and the two agencies were working together to determine the most appropriate strategy. The group agreed that this recommendation would likely be redundant, pending the outcome of the enforcement case.
      • Recommendation #2 – Consider advising the US Environmental Protection Agency that special populations (such as older occupants) may require longer re-entry times, or more active ventilation prior to re-entering treated spaces. Instruction with regard to “who” initiates ventilation (given probable exposure upon entry) should be reviewed. If deemed appropriate, a language change would be required on the product label (originated with OSPH).

        Chris Kirby said that the US EPA is the responsible party for label statements, and changes may be under consideration. He said the ODA is waiting for official interpretation. Rick Kepler said that it may be more than just sensitive individuals at risk because the responders also became ill. Michael Heumann presented some statistics that he compiled about indoor exposure incidents involving insecticides that contain pyrethroids or pyrethrins. He said that between 1998 and 2003, there were 133 such cases in Oregon that were considered possible, probable or confirmed. In the national database for pesticide incidents (SENSOR), there were 5872 incidents in the same time frame. He said that 1207 involved pyrethrins or pyrethroids, and of those 739 were inhalation exposures. Also, of the 1207, 118 were re-entry situations. He said there were no confirmed deaths in the data set. One suspected child death was not confirmed, and was not considered probable (probably not related to pesticides, then). He also reported looking at a California database, which contributed 20 or so cases to the national database. After talking with one of his contacts, he was able to determine that they had 62 cases that were re-entry related, with a similar spectrum of symptoms to those reported in the national database. The group discussed an expanded definition for “sensitive” in the context of the recommendation, to include the elderly, the young, and those with lung disease. In these cases, PARC may chose to recommend that the applicator initiate ventilation with protective equipment. Michael Heumann said that retired EPA official, Jerry Blondell, was looking into this issue as well, and provided two additional papers. Dr. Sudakin noted that it may be very difficult to find out what kind of ventilation was conducted by reading the short narratives that are included in many pesticide incident databases. He said that the California database may be easier than others. In addition, one might not be able to tell if the applications were broadcast or crack & crevice. The national database is not that specific. He also asked if the narratives were specific about allegations or confirmation of misapplication. With so much missing information, he asked how useful the data may be.

        Chris Kirby said there is a work in progress related to the EPA’s interpretation of “adequate ventilation.” Much of this discussion could be moot after the determination is issued. Dale Mitchell suggested that this recommendation be split into parts- 1) Who initiates ventilation, 2) What is adequate ventilation, and 3) What are, and what should be done about sensitive populations? Jeff Jenkins suggested that the group use the same term that EPA uses to describe this diverse group, which is “sensitive subpopulations.” The group agreed to be consistent on this. Jenkins said that FQPA (the Food Quality Protection Act) includes specific definition and precautions, which include the elderly, immuno-compromised, and pregnant women. In the most recent cancer risk assessment from EPA, they use a “cogent biological rationale” to determine whether sensitivity exists. Fred Berman asked whether the databases mentioned by Heumann include information about the product formulations. He said that they do, when possible; sometimes. Berman said it would be helpful to know if a certain formulation was problematic. Heumann said he would be willing to help dig for that information. He said he has plans to meet with a key person in California while at an epidemiological conference within a few days.

        Joan Rothlein asked if Oregon’s numbers are unusually high (pesticide-related incidents). Dr. Sudakin said there was no way to know. Heumann asked if NPIC might have data to answer the question. Dr. Sudakin said that one would have to talk to Dr. Terry Miller about using NPIC data, but there were no known epidemiological statistics. Kaci Agle asked Dr. Sudakin if one might expect to see a rise in incidents related to pyrethrins and pyrethroids now that they are replacing the organophosphates for indoor pest control in homes. He said yes, that is one talking point they plan to highlight in the publication they’re preparing. He said that another talking point will be the difference in severity between organophosphate incidents and pyrethroid/pyrethrins incidents. He said the vast majority of the incidents related to pyrethroids and pyrethrins are low in severity or asymptomatic (no adverse symptoms reported). He said they will present their paper to the Board when it is finished.

        Heumann asked Agle to rewrite the recommendation in a segmented form, as Mitchell discussed. Chris Kirby said that the recommendation to EPA may be moot because that consultation is already taking place. Heumann said it was still important to formulate PARC’s recommendation. Kirby said that any recommendations from PARC to EPA would be channeled through ODA. Heumann suggested that revised recommendations be reviewed by the Board electronically before the next Board meeting. Agle agreed to draft them and send them to the Board via email.

        Joan Rothlein said, “When we review general questions regarding ventilation, doesn’t that impact other products as well?” Mitchell said that it might. Heumann indicated he didn’t want to make the issue bigger than it needs to be. Jenkins said that changing label language is a BIG deal, and perhaps a PARC bulletin or OSPH outreach brochure would be faster in getting any kind of message out. Heumann said he would rather see change at the national level. Kirby said that PARC has a history of successful requests for label modifications. Mitchell said that the registrant may be willing and receptive to change. Jenkins said that Oregon could take the lead here, and set precedent. Joan Rothlein added that state-specific pesticide labels are a possibility. Agle said that MANY registrants (pesticide manufacturers) would be involved; we’re not talking about 5 or 10 pyrethroid-containing products that are registered for indoor use. Jenkins said that pyrethroids have a very low vapor pressure; it makes sense to look at reentry times for indoor uses. Heumann agreed that the point is valid and important. He suggested education and outreach to home-users of pesticides (suggesting point-of-sale notices?) and commercial applicators (continuing education process, partnering with industry?). Someone asked what the difference in concentration might be between products designed for home use and products designed for use by professionals. Mitchell agreed to look into this question. Agle agreed to redraft this question, splitting it out into three questions.
      • Recommendation #3 – Recommend to the local response organizations that they evaluate existing PPE response protocols for emergency responders with regards to home or other indoor and confined space entry (originated with OSPH).
      • Recommendation #6 – Recommend that OR-OSHA develop and deliver targeted outreach, using this case as an example, to fire departments and other emergency responders re: entering potentially hazardous environments (originated with Chris Kirby).

        These two recommendations were discussed concurrently because they are so similar. Garnet Cooke suggested that OR-OSHA could do a “Hazard Alert” and use the case as a training tool. She said that emergency responders have a hard-wired response; if someone is down, they retrieve the person. In most confined space fatalities, there are two victims because the responder often becomes ill. Someone clarified that police responding to the Florence Case were not aware of an inhalation hazard, but they advised EMTs about it. Apparently the EMTs charged in without respiratory protection, even after being notified of a potential hazard. Garnet asked if they were equipped with SCBAs (self-contained breathing apparatuses). Gordon Simeral said that SCBAs are “standard issue.” He added that the OSFM maintains data about chemicals that are stored on site for businesses in Oregon, and that information is made available to emergency responders. Rick Kepler said it sounds like a training problem. Cooke agreed, if they had SCBAs and didn’t use them.

        Heumann said that OSPH has an Emergency Management System that sets criteria for training. Some elements have not yet been completed. Gordon Simeral said that it would be important to include information about the Incident Command Structure (ICS).  Kirby said that recommendations #3 and #6 say essentially the same thing, and we can agree that OSPH, OR-OSHA and OSFM should be involved. Simeral said that OSFM is implementing a training (on a disk) that will target fire departments. Phase 2 will involve incident response and working with other agencies. Agle suggested that we finalize this combined recommendation via email before the next PARC Board meeting, that the three agencies work together to develop the concept, and we’ll revisit the issue in four months to evaluate progress.
      • Recommendation #4 – Evaluate the indoor use of pyrethrins/pyrethroids, especially in mixtures, for vulnerable populations (Originated with OSPH).
      • Recommendation #5 – Review PARC data with respect to vulnerable populations and experience with pyrethroids/pyrethrins (Originated with OSPH).
      • Heumann introduced this topic. See the discussion of Recommendation #2, which includes some data that Heumann has already been able to collect from various sources. He framed the question as follows, “What do we know, what can we find out about USE patterns?” He suggested using PURS (Pesticide Use Reporting System), Industry sources, state associations, and extension resources. Kirby said that the appropriate state association to contact would be the Pest Control Operators of Oregon. Dale Mitchell said he was a bit confused about how the data would be collected since there is no “standard” combination of pesticides that are used indoors. Fred Berman said there must be a combination or two that is commonly used, and is known to work well. Will Lackey agreed that there are standard combinations in right-of-way applications. Heumann suggested we find out what combinations are the “standard” for indoor pest control. Agle and Simeral commented that some may consider their product choices (and combinations) to be proprietary, and they may not be willing to share the information openly. Jenkins asked why OSPH would expect mixtures to be of importance in this case (indoor pyrethroid/pyrethins applications). Fred Berman suggested that pyrethrins may be more likely to cause respiratory symptoms when combined. Dr. Sudakin encouraged the group to avoid characterizing respiratory reactions to pyrethroids and pyrethrins as allergy-related. He said the data for allergenicity of pyrethrum (the crude extract from chrysanthemum flowers) is compelling, but the data are much less compelling for p yrethroids and pyrethrins. Jenkins noted that pyrethroids were developed to have a longer residual period than pyrethrins, and they developed two types (Type 1 and Type 2). Heumann said that this conversation provides fodder for university research that is beyond the scope of PARC. Heumann reminded the group that OSPH already began collecting data to initiate research. He said that PARC has a history of initiating research. Kirby said that this case involved a mixture; others may also. He wondered if combing through the data would focus the question. Rothlein said that we could look at the pre-existing data and evaluate research needs by conducting some sort of meta-analysis. Heumann said that his office will do some meta-analysis. He said they would ask the question, “What are common practices?” Heumann said they already started searching PARC data for data related to sensitivity. He said the most common finding was “not asked,”; other common findings were “asthma” or “allergies.” Since data evaluation has already begun, a recommendation from PARC may not be necessary, or it should be broadly worded as a need to identify research priorities.  
      • Recommendation #7 – Recommend that PARC staff develop and deliver targeted outreach to medical examiners and/or other audiences re: risk characterization and communication (originated by Joan Rothlein).
        Dr. Sudakin suggested that we make an effort to clarify what PARC is, what each of its member agencies do, whenever we have contacts with medical examiners. Others agreed that we should do anything we can to enhance the relationship and the channels of communication. Kirby asked if OSPH has a unit that works with medical examiners; Heumann said the unit was moved over to the Office of State Police. He added that he would want to work with Sudakin to get a message out there. Mitchell said that we should identify an avenue to get a message to medical examiners re: PARC. Rothlein said the message should be about risk communication, not PARC, really. Mitchell and Heumann discussed an upcoming course taught by Alvin Chun of the US EPA on Risk Communicaiton. Agle agreed to follow up and try to disseminate a notice about the training to medical examiners.


New business
  • Alsea/Waldport Petition: Dale Mitchell introduced the topic. The Governor’s office received a petition, without signatures, as we understand. An advisor to the Governor, Jessica Hamilton, contacted Mitchell and asked if PARC would be an appropriate forum to address the issues raised. The petition outlines a history of birth defects, cancer, and other maladies that the authors attribute to herbicide applications in coastal range forests. He said this is an area with a substantial history related to 2,4,5-T, having brought about changes in its registration status back in the 1970’s.

    Amy Chapman, an environmental health specialist in the Lincoln County Health Department, said that many of the same people are still residents of the county, and they’re still concerned. She said they plan to hold a public meeting on May 27, 2006, which she plans to attend. She said she met one person, whose son is still very sick, ever since herbicide spraying back in the 70’s.

    Chris Kirby was with ODA during that controversy, too. He said this was a huge issue back then, and the EPA actually held hearings related to 2,4,5-T in Lane County in the 70’s. The chemical’s use was discontinued.

    Chapman said the residents believe the chemicals persist and their breakdown products are still present in drinking water and sediments.

    Michael Heumann asked if there was a recent soil or sludge samples; the DEQ representative on the Board was not present to speak to this question. A request to DEQ will be made to determine if soil or sludge sample data exist.

    Chapman said this is 2006, and she’ll understand more about their reasoning after the public meeting.

    Kirby said he considers this to be a draft petition, as it has not been signed yet.

    Chapman said that the meeting on the 27th was designed to collect signatures.

    Kirby said that silvex and 2,4,5-T were herbicides with significantly different chemistries than we work with today.

    Dr. Fred Berman said he has received calls indicating there is a huge sensitivity to spraying activity in the Alsea/Waldport area.

    Chapman asked who does the spraying.

    Will Lackey spoke about road-side spraying conducted on state roads by ODOT.

    Brad Knotts said that most use is on private land in Lane County.

    Dr. Jeff Jenkins said that public land is typically not sprayed in that area.

    Berman said that anecdotal information is spread by rumor, and feeds the concern.

    Jenkins said that a monitoring project to determine the level of dioxin contamination would be out of reach, and perhaps unwarranted, based on the expected exposure.

    Chapman said that residents in the area believe that Agent Orange was invented at Oregon State University, experimentally sprayed “all over” Lincoln and Benton Counties, and excess stores of it were dumped in undisclosed locations of the coastal mountains.

    Kaci Agle said that Agent Orange was developed and manufactured by the Dow Chemical Company in Midland County, Michigan. A class action lawsuit is currently in progress, alleging decreased property values in the Tittabawassee River watershed due to dioxin contamination. Jenkins concurred, saying he was involved in sampling the Tittabawassee River watershed (in Midland and Saginaw Counties) for dioxins back in the 1970’s. He also said there was no reliable method for detecting low levels of dioxins back then.

    Chris Kirby said that even today, the method is expensive and difficult. However, there is a lot of information available from the previous study of the Alsea area. It’s not as though no one has ever looked at this issue.

    Michael Heumann said he asked Mike Watson, of EPA Region 10, for a copy of that historic data (studies called Alsea One and Alsea Two) and would share it if it became available.

    Berman asked if there was any more recent data. He suggested that Gene Foster, of DEQ, may have data from sediments in Alsea Bay from the late 1990’s.

    Jenkins said that degradation could be very slow in sediments of Alsea Bay because it’s very cold, and could be facultatively anaerobic.

    Heumann asked “what about wildlife?” Different agencies have different data capabilities. Perhaps a workgroup should be formed to determine: What do we know about herbicide use and occurrence in the Alsea River watershed? Can we develop an accessible document to communicate those facts?

    Jenkins said that he had to know all about this study for his oral examination before being granted his PhD. He said EPA’s final decision about 2,4,5-T was partially based on the study of birth defects in Alsea. What if there was some sort of epidemiological follow-up survey/study?

    Heumann said there is currently no birth defects registry in Oregon. OSPH hopes to have funding to work on this in the next few years.

    Chapman presented one page of information indicating that five women from the Five Rivers area experienced spontaneous abortions of first trimester pregnancies very soon after three days of spraying within 1.5 miles of their homes. The data came from 1979.

    Kirby said that these data and others were involved in the case back in the 70’s.

    Chapman said there was a survey of 70+ people reporting health effects.

    Rothlein asked if the allegations were actually about acute poisonings.

    Chapman said, “If you want reports, here they are,” pointing to the five women in 1970.

    Jenkins said that Dr. Sheldon Wagner (Dr. Sudakin’s predecessor) and Dr. Jim Whit did an epidemiologic study as a follow-up to the 1979 controversy and found that there was no significant difference in the rate of spontaneous abortions between Alsea OR (where potential exposure to forest herbicides was high) and Ontario, OR (where potential exposure to forest herbicides was very low).

    Chapman said, “It’s not alarming to see these data with spray dates associated?”

    Heumann said, “Not necessarily.” Heumann said that spontaneous abortions are frequent, especially in the early stages of pregnancy. He said many factors may contribute, including a woman’s history of prior occurrences and possibly outside exposures. Heumann asked, “What are the residents’ current questions about, abortions?”

    Chapman said she wasn’t sure. She wasn’t sure if area residents knew that PARC was available, and what it could do.

    Heumann said that Carol Van Strum is aware that PARC was founded, but questioned her confidence in the state agencies.

    Kirby said she was also concerned about gypsy moth eradication activities in 2004.

    Chapman said that the EPA never got back to people in the Five Rivers area after they collected data and samples for Alsea One and Alsea Two. She wondered if the lack of confidence might be related to this lack of communication.

    Bill Emminger, of the Lincoln County Department of Health said he had a “mountain of data” related to the birth defects and spontaneous abortions in Alsea in the 70’s, but not the completed studies, Alsea One and Two.

    Jenkins said there was a detailed account of events in the Federal Register.

    Dale Mitchell suggested that these puzzle pieces might best be dealt with in a workgroup of PARC- to determine: What was done? How is it related to modern times? Is there a recommended action?

    Volunteers for the workgroup included representatives of ODA, OSPH, ODF, DEQ, ODFW, ODOT, OSU (Dr. Jenkins, perhaps Dr. Sudakin), EPA and the two local Health Departments.
    Agle asked the group if it was they also understood that 2,4-D does not contain 2,3,7,8-TCDD. Many concurred, and Agle encouraged Chapman to communicate this fact during the community meeting.

    Chapman asked if the older one (presumably 2,4,5-T) contained 2,3,7,8-TCDD, and the group agreed that it had contained very small amounts.

    Chapman said she planned to listen at the meeting, find out the group’s priority (priorities) and communicate these items to the workgroup. Agle suggested a few dates, and the group agreed to tentatively schedule the workgroup’s first meeting for the second week in June.
  • New incidents/cases (3/15-5/17):
    • Agle suggested that each agency send a summary of new cases to the rest of the Board via email, in the interest of saving time.
    • Brad Knotts said that he recently attended a meeting in the Siletz area, where the Siletz tribe did some monitoring for 2,4-D. Informal monitoring, using ELISA kits, detected 2,4-D at “unremarkable levels.” The results apparently prompte the Audubon Society to host a community meeting to discuss next steps, and talked about getting more organized. Concern is elevating the issue, and no further information is available.
    • Michael Heumann said that Siletz, Alsea and Blachley are all in the coastal mountain range, and share a common, growing concern about herbicide applications. If nothing else, he said there is a new need for educational materials related to herbicide spraying.
    • Garnet Cooke provided copies of OR-OSHA’s Pesticide Emphasis Program’s annual report to the Board and interested parties.
    • Michael Heumann said that George Evans took a job at Los Alamos Laboratory in New Mexico, and would no longer be working with OSPH as of May 19, 2006.
  • Multiple Chemical Sensitivities (MCS) or Idiopathic Environmental Intolerance (IEI): Discussion and presentation postponed until the next meeting on July 19, 2006.
  • Public Comments: Heumann asked if Paulette Pile wanted to add anything before the Board adjourned. She said she was just listening in general. But she asked what was driving the current surge in concern in the coastal mountains? No one knows.

References
1. Agle and Lauren Slusser are working to develop a website that will include resources to help HCPs understand, recognize and treat pesticide poisoning cases. It would include links to the Oregon Poison Center, Dr. Sudakin’s training materials, NPIC, and EPA resources like the book, Recognition & Management of Pesticide Poisonings. 
 
Materials Distributed – Copies are available from the contact person listed.

  • Case Summary, The Walker Fish case: Kaci Agle (503) 986-4655
  • OR-OSHA Pesticide Emphasis Program 2005 Annual Report: Garnet Cooke (503) 378-4730
  • ODF Aerial Pesticide Application Monitoring Final Report (March 2000), Forest Herbicide Application Water Sampling Study (January 1992), Summaries of herbicide sampling in water, soil, and other media (1970-1986), USDA-FS Summary of Phenoxy Herbicide Residues in Water (1974-1978) and USDA-FS Final Report titled “Analysis of Reports on 2,4,5-T Residues Found in Water During and After Operational Projects. (1974-1978): Brad Knotts (503) 945-7484