Golf
Digest: How Green Is Golf?
Beyond Pesticides' response to EPA criticism
In May 2008 Golf
Digest published an article, "How Green
is Golf?," which asks the hard questions about the environmental
impact of golf in a series of in-depth interviews. The following is Beyond
Pesticides' response to EPA's criticism of executive director Jay Feldman's interview.
EPA’s “rebuttal”
by Debra Edwards, Ph.D., director of the Office of Pesticide Programs,
does not dispute most of the specifics outlined in the Feldman interview.
Instead, she uses her space on the Golf Digest website to offer a boilerplate
characterization of the pesticide registration program. “[E]PA bases
its decisions to register pesticides for use in the United States on scientific
data showing that the pesticides meet applicable safety standards to protect
human health and the environment when used as directed on product labeling,”
Dr. Edwards says. She refers to “rigorous risk assessment”
and “uncertainty factors” without addressing the deficiency
of false assumptions, such as children not playing golf, and lack of attention
to synergistic effects and mixtures. Without admitting that the agency
is years behind a statutory schedule to fully test pesticides for endocrine
disruption, she says “[W]e have now developed and will begin requiring
new studies to help us understand whether endocrine disruption is the
mechanism causing the effects,” but does not say when and how long
it will take. In her rebuttal, Dr. Edwards prefers to focus on the number
of completed reevaluations of existing pesticide food tolerances (9,721
over the past 12 years) rather than the quality or documented deficiencies
in those reviews. Dr. Edwards cites the agency’s support of integrated
pest management (with undefined toxic pesticide use) and reduced risk
pesticides, without ever questioning the real need for toxic chemicals
or advancing defined organic management systems not reliant on toxic pesticides.
On children and golf
course exposure, Dr. Edwards appears to dodge the agency’s failure
to fully address young children’s exposure to chlorpyrifos on golf
courses, by ignoring the original 2000 decision that dismissed all children’s
exposure and the more recent 2006 analysis that ignores children six and
under. Dr. Edwards writes, “[W]e estimated the potential exposure
and risks received not only by adults but also by both children aged 7-12
and teenagers in the chlorpyrifos risk assessment. The assessment of the
use of chlorpyrifos on golf courses shows that this use met our rigorous
safety standard.” However, first, as noted in EPA’s “Provisions
of the June 2000 Memorandum of Agreement,” the agency exempted golf
courses from the chlorpyrifos phase out with its decision: “Outdoor
areas in which children will not be exposed [to chlorpyrifos], including
only: golf course turf. . . “ Then, in its Memorandum entitled Finalization
of Interim Reregistration Eligibility Decision (IREDs) and Interim Tolerance
Reassessment and Risk Management Decision (TREDs) for the Organophosphate
Pesticides over six years later on July 31, 2006 (authored by Dr. Edwards),
EPA narrowed its definition of children, deciding it was not necessary
to evaluate children six and under. (p.41) Junior golf can certainly begin
at age 5, or before, exposing young children to a hazard that EPA assumes
does not need to be evaluated. Children are especially vulnerable to chlorpyrifos
and chemical exposure and suffer their greatest risk of adverse effect
during this period of life.
Some say that the
debate with EPA is becoming increasingly irrelevant as the market moves
ahead to address key issues of environmental health. This has happened
in the food and agriculture sector where organic food has grown to a $20
billion industry. The majority of non-golfers (66%), according to a 2007
Golf Digest survey, understands that pesticides used on golf courses can
be a health hazard. The number of golfers who understand this (40%) has
doubled since Golf Digest conducted a similar survey in 1994. A majority,
or 64%, of golfers is willing to “play golf under less manicured
conditions to minimize the use of pesticides on the course.” An
even greater majority, 85%, is willing to “sacrifice some level
of golf course landscape “perfection” to save water/prevent
groundwater pollution.” The growing number of concerned golfers
and the communities surrounding golf courses are having increasing influence
over golf course practices. Jeff Carlson, golf course superintendent at
the Vineyard Golf Club on Martha’s Vineyard, MA, interviewed in
the article, manages an organic course with a focus on cultural practices
and describes a number of approaches that he uses to manage insects, weeds
and fungus, as well as the importance of support from the club. Mr. Carlson
says that it is important that he is “. . .working with our members
and explaining this idea of great playability versus visual perfection.
We take the focus away from having every piece of fairway and rough perfectly
green. The members have to be on board, or the superintendent wouldn’t
last too long.” With a background in using chemical-intensive practices,
Mr. Carlson says, “I am just so surprised that so much of our golf
course is unaffected by not using pesticides. To see a course without
any at all is something I’m really proud of.”