Sunshine Project Backgrounder #14
September 2005
Risks of Using Biological Agents to Eradicate Drug Plants1. Introduction
2. Politics and Biological Escalation of the Drug War
2.1. The Controversy of 2000 - 2001
2.2. US Political Developments Since 2001
2.3. Happenings in Central Asia3. Fungus Facts: About the Agents and Strategies for Their Use
3.1. Fusarium – a fungus targeting coca and cannabis
3.2. Pleospora – a fungus targeting opium poppy
3.3. Others – insects and viruses4. Environmental Risks
4.1. The agents are likely to harm other plants
4.2. Ecosystem level impacts
4.3. Release into the environment is irreversible5. Human Health Risks
5.1. Fusarium infections - an emerging, life-threatening disease
5.2. Fungal toxins
5.3. Other direct health risks
5.4. Indirect health effects6. Violating the Ban on Biological Weapons
7. Economic risks – endangering legal production
1. IntroductionFive years after the issue last rose to international prominence, proponents of using biological weapons to eradicate drug crops are mounting a dangerous comeback. After a series of attempts since 2000, those in the US Congress that favour a biological war on drugs have recently introduced legislation that could quickly lead to a new crisis with environmental, health, and arms control implications. A proposed law under consideration by the US House of Representatives would require the US Drug Czar to put forward a plan for “expedited” testing of biological crop eradication agents within 90 days of the bill being signed into law. The result could be a dangerous biological escalation of the Drug War.
This paper reviews the policy, legal, environmental, and health issues associated with the use of biological agents in drug eradication, detailing recent political developments and relevant scientific research.[1]
Fungi that harm plants, dubbed Agent Green, have been developed over the past two decades for the purpose of destroying opium poppies, coca and cannabis plants. The fungi, as well as other biological agents under consideration (such as insects and viruses) pose severe risks to the environment and human health. The development and proposed use of these biological weapons, particularly in conflict zones such as Colombia and Afghanistan, is a threat to the global ban on biological warfare.
Facing a wave of domestic and international criticism and citing concerns about biological weapons proliferation, in 2000 US President Clinton halted US plans to field test biological eradication agents in Colombia. At the same time, other governments and the United Nations retreated from this highly controversial crop eradication strategy. But research and development have continued, and pressure on other governments to use these ill-advised and dangerous methods in drug eradication campaigns is again on the rise.
Since Agent Green last came to international prominence in 2000, technical and political contexts have changed. A ready-to-use fungus system has been developed for opium poppy eradication, shortening the time needed between a political decision and actual spraying. New leaders are in power in key countries including the US, Colombia, and Afghanistan. If the current proposal to field test biological crop eradication agents advances, either in its present form or attached to another law, a struggle will ensue between Agent Green proponents and non-governmental organizations, indigenous peoples, and others concerned about the environmental, health, and arms control impacts of this misguided drug war strategy.
2. The Politics of a Biological Escalation of the Drug War
2.1. The Controversy of 2000-2001
Use of Agent Green has been proposed as a more powerful alternative to chemical herbicides for the forcible eradiation of crops of coca, opium poppy, and cannabis, particularly in the Americas (especially Colombia and other Andean countries) and Central Asia (especially Afghanistan).
To eradicate coca, the US identified and developed a fungus (a strain of Fusarium oxysporum) and has put significant political pressure on the Colombian government to use it. Programs to develop eradication fungi date back to at least the early 1970s, when they were under the control of the Central Intelligence Agency (CIA). In 1998, the biological eradication program – which by that time had passed to the US Department of Agriculture – was stepped up when the US Congress appropriated US $23 million to finance the effort.
A confrontation over Agent Green ensued two years later, when the US Congress made US $1.3 billion in mainly military aid to Colombia contingent on Bogotá agreeing to field test the US-developed fungus. Aware that its effort to force the use biological agents in the Drug War would spur criticism, the US sought to involve the United Nations Drug Control Program (UNDCP), in the words of then Secretary of State Madeline Albright, “in order to avoid the perception that this is solely a US government initiative”.[2]
The leadership of the UN agency, now renamed the UN Office on Drugs and Crime (UNODC), was amenable to the US desire that it serve as an intergovernmental shield against criticism. UNODC lent a multilateral façade to the US-driven project by accepting US money, which it planned to pass to Colombia to finance field testing of the US developed fungus.[3] A draft contract was presented to Colombian authorities; but strong opposition appeared within Colombia, elsewhere in South America, and worldwide. Under pressure, the Colombian government stalled. It refused to sign the contract, without rejecting it outright.
While Bogotá said it was studying the issue, government and civil society pressure against Agent Green mounted. Citing biological weapons proliferation concerns, US President Clinton defused the conflict by signing a memorandum (waiver) that allowed the US aid to be distributed without the fungus field testing.[4] The Colombian Ministry of the Environment came down against the US fungus and UNODC announced that it would abandon the Colombian project.[5]
In parallel and half a world away in Central Asia, a different kind of fungus (Pleospora papaveracea) was under development for the eradication of opium poppies, the source of heroin and other drugs, both legal and illicit. The fungus had been isolated by the Institute of Genetics in Tashkent, Uzbekistan in the 1980s, when it was part of the former Soviet Union’s offensive biowarfare program and its efforts were dedicated to finding ways to destroy the West’s food and industrial crops.
Again, UNODC played a pivotal role in disguising a US driven effort as an international project. In February 1998, UNODC signed a contract[6] with the Uzbek Institute of Genetics to develop the fungus and related technology, including field tests in Central Asian countries. This contract was funded by the US and, in this case, a contribution from the UK. At the same time, significant research on the fungus was underway at the US Department of Agriculture’s laboratories in Beltsville, Maryland. Different from the situation in Colombia, little regional opposition was voiced in Central Asia at that time. UNODC did not abandon the Uzbek scheme, as it had done in Colombia, and research in Central Asia continued, including field tests.
Governments Opposed to Agent Green
When plans to use biological agents in drug eradication became public in the year 2000, strong opposition developed across the world, especially in South America. In September 2000, the Committee of Andean Environment Authorities (CAAM) rejected the use of biological eradication in any member state.[7] In addition, a variety of governments expressed their opposition or even initiated their own bans on the use of Agent Green:
- In March 2000, Peru banned the use of biological agents for drug eradication on its territory, to protect the environment and human health.[8]
- In July 2000, Ecuador enacted a law that “Prohibits the entry and use of the pathogen Fusarium oxysporum in the entire national territory...".[9]
- The Brazilian foreign minister expressed his opposition to Agent Green to the office of UN Secretary General Kofi Annan and senior Brazilian political leaders publicly voiced strong opposition.
- Citing the Venezuelan Constitution's ban on biological weapons, the office of the Venezuelan Attorney General opposed the use of Fusarium oxysporum in Colombia as a biological weapon and because of potential damage to the environment and human health.[10]
- In July 2000, the German Parliament approved a resolution “against the use of new biological methods of eradication“.[11]
- Despite UK support for the research project in Uzbekistan, in September 2000 British Cabinet Minister Mo Mowlam stated that "Britain ... opposes employing biological agents the United States has urged Colombia to use."[12]
- In February 2001, the European Parliament voted overwhelmingly against the introduction of biological agents into the Drug War, citing human health and environmental concerns.[13]
Within Colombia, important sectors of the government were also opposed to the use of biological agents. A group of 18 Colombian senators and congressmen urged the government to abandon its plans, as did Colombia's Defender of the People (Defensor del Pueblo), a constitutionally mandated public interest ombudsman.[14]
2.2. US Political Developments Since 2001
Despite Clinton’s decision in 2000 to stop imminent field testing in Colombia, a small and determined group of US politicians and government officials have remained committed to a biological escalation of the drug war. In summer 2005 two US Congressmen[15] inserted an amendment into a bill that authorizes the activities of the US Office of National Drug Control Policy (ONDCP), better known as the US Drug Czar. The Agent Green amendment[16] would require the Drug Czar present a plan to Congress for “expedited” field testing of biological eradication agents “in a major drug producing nation” within ninety days. It will have legal force if the present bill is passed by the Congress and signed by the President. If this happens, pressure to use Agent Green will immediately escalate and a new crisis could quickly come about. The bill, referred to as the ONDCP Act, will be further discussed in the US Congress in the fall of 2005.
Although international concern about biological weapons has dramatically increased since 2000, political leadership has changed in Washington, Bogotá, and Kabul, and new administrations may prove more willing to resort to the biological eradication strategy than their predecessors.
This development comes at a time when new aid packages for Colombia and Afghanistan are under discussion. The US$ 1.3 billion program that started in 2000, dubbed Plan Colombia / Plan Patriota, ends in 2005. It can be anticipated that discussions in the US Congress for a renewal of aid to Colombia – the third largest recipient of US military aid after Israel and Egypt – will also be used by proponents of biological eradication to push their cause and introduce (as they did in 2000) legislative maneuvers to force use of the fungus by linking it to the availability of foreign aid.
The clutch of US politicians backing the fungus include Congressmen Burton and Souder, both of Indiana, who are behind the present amendment, as well as John Mica of Florida, Henry Hyde of Illinois, Dana Rohrabacher of California, and Senator Conrad Burns of Montana, all Republicans. In the Executive Branch, fungus cheerleaders have included Rand Beers[17] and Bobby Charles, both former State Department drug policy officials who have recently left government after serving in both the Clinton and George W. Bush administrations.
In December 2002 John Mica pushed for the use of biological agents in the drug war. At a televised Congressional hearing he argued, in reference to Agent Green, that “Things that have been studied for too long need to be put into action”.[18] In February 2004, Rohrabacher made his enthusiasm for biological agents clear during a hearing on Afghanistan, saying that he wishes to “see if new eradication alternatives can be used”, referring to Agent Green. At the same hearing, the then head of the US State Department drug control division, Bobby Charles, emphasized that he has been “rather aggressive about talking to the UNODC about that particular issue”. Rohrabacher concluded the discussion of Agent Green by making a surprise reference to classified activities. “Well, you know, we are watching this very closely…” said the Congressman, “It is a classified matter, but we will [look] into that some other time.” [19]
A few months later, in September 2004, Rohrabacher was again on the offensive. At a congressional hearing on Afghanistan, he remarked “Is there any reason we are not using that microherbicide,[20] which would dramatically eliminate the opium production in Afghanistan?”. Bobby Charles, again testifying, answered that doing so would require a decision by the government of Afghanistan, and that the fungus is still under research and not yet ready to deploy. It is questionable if the latter is correct, as scientific publications from both US and Uzbek researchers indicate that a method for mass production and deployment for opium-killing fungi has been successfully developed (see below). Rohrabacher finished the discussion by telling Charles that discussion on the issue in 2005 “is going to be tough”.[21]
Rohrabacher’s 2004 reference to classified Agent Green activities adds to an April 2002 report in the US magazine Newsweek. Citing anonymous sources, Newsweek wrote that the US government had set aside “black budget” (i.e. secret) funding for testing fungi on the coca crop in Colombia.[22] While this report was never confirmed by public sources, Rohrabacher’s quip is consistent with the Newsweek scoop and suggests that such activities may have continued at least through 2004. The size of this budget, the agency administering it, and the results of these reported efforts are unknown.
In October 2003, the US State Department sent a letter to Colombia’s ambassador in Washington, requesting that Colombia send a team to Washington including agriculture officials and a senior policymaker with access to Colombian President Uribe. The State Department said the purpose was to discuss the use of Agent Green, including US “research and development advances for the use of mycoherbicides against illicit crops”.[23] It is unclear what specific advances the State Department wanted to discuss, although given the back and forth on the issue between Bogotá and Washington in 2000, the context of the State Department’s 2003 letter suggests that the “advances” were achieved after Clinton pulled the plug on field testing in 2000.
In March 2003, the US sponsored a meeting at the Vienna offices of UNODC at which David Sands of Montana State University, the lead developer of Agent Green, gave a presentation on biological drug eradication.
UNODC played an ambiguous role at this meeting. On one hand it gave abundant space to discuss Agent Green, while on the other its chief scientist, Dr. Howard Stead, stressed that there “are gaps in the knowledge in the area of environmental safety… further research work is required to confirm findings, as current results do not justify immediate use of the fungus.“[24] This indicates that the UN’s drug control agency is not advocating near-term use of Agent Green. At the same time, and potentially contradictorily, the US account of the meeting says that it concluded that each country should decide on its own: “Experts agreed that ultimately countries would have to decide whether or not to research and develop this technology for use”.
2.3. Happenings in Central AsiaThe US and UK-funded opium poppy eradication research project in Uzbekistan started in 1998. At the 2003 meeting in Vienna, UNODC’s Stead presented information on the project and stated that it continued until 2002. According to newspaper reports, field tests in the region, including one in Tajikistan, were finished in 2002, whereupon the UN stopped its funding for the research.[25] At a scientific congress in 2004, Uzbek scientists reported that their research had been successfully concluded.[26]
Because a method to produce, formulate, and spray opium-killing fungi on large areas is apparently readily available, there is significant danger that this method could be quickly used. In fact, several late 2004 news reports suggested that opium poppy crops in Afghanistan had been sprayed from the air;[27] however, no independent verification of these reports was possible. Both the Afghan and the US government - which undoubtedly monitors all Afghan air traffic - denied having approved any spraying. Afghan President Hamid Karzai expressed opposition to aerial eradication, citing public health and environmental safety concerns. A coherent explanation of the reports has yet to emerge.
In contrast to Afghanistan's stated position, according to media reports, government officials from Kyrgyzstan have expressed a strong interest in Agent Green. On 5 August 2002, the Russian daily Pravda reported that “Representatives of the Kirghiz State Commission on Drug Control told journalists that they are hoping for a fungus that can destroy poppy crops.”[28]
Also in August 2002, a group of Central Asian scientists[29] invited to the US government’s Oak Ridge National Laboratory in Tennessee made a proposal for further development of fungi to eradicate opium poppy and cannabis in the region.[30] The proposal reflected detailed knowledge of the 1998-2002 UNODC-sponsored project in Uzbekistan, and indicated that both the UN agency and Michael Greaves, a British government scientist who worked as a UNODC consultant in Tashkent, would be asked to participate in the new project.
The Oak Ridge conference was part of a US government nonproliferation program designed to prevent scientists and institutions of the former Soviet Union’s offensive biological warfare program from selling their skills to “rogue states” or terrorists. The fate of the proposal is not publicly known. If the Central Asian research has been supported by the nonproliferation program, the latter would have radically parted ways from its “swords into ploughshares” intent.
It is difficult to assess how seriously Central Asian governments are currently considering use of the fungus. Several have been involved in the past in the Uzbek-led research project to develop the opium-killing fungus, but whether interest in it is restricted to scientific and/or drug control circles or is also mirrored on higher political levels is not known.
3. Fungus Facts: About the Agents and Strategies for UseA variety of agents have been considered and developed for use against drug producing plants. Most of them are fungi, which are scientifically termed “mycoherbicides”[31] if used to kill weeds. While several different fungal species – some of which target coca and cannabis plants, others targeting opium poppy – have been under development for many years, there have also been preliminary steps to investigate insects and viruses as potential drug plant killers.
3.1. Fusarium – a fungus targeting coca and cannabisFusarium oxysporum is a well-known plant pathogen causing damage and large losses in food and industrial crops worldwide. There are many different strains of F. oxysporum, and not all strains attack all plants equally (see box 2 below).
Work to isolate F. oxysporum strains to attack cannabis has been ongoing at least since the early 1970s, when the US government funded research at the University of California at Berkeley.[32] It appears that most of the early US work conducted on Fusarium was a project of the US Central Intelligence Agency. The CIA later passed control of the work to other government institutions, thereby allowing overt funding of the research.[33]
Since the 1980s, researchers of the US Department of Agriculture have honed the weapons, developing highly virulent strains that prefer to attack cannabis and coca plants. The coca-killing strain favoured by the US is named EN-4 and was isolated in 1987 during experiments at a government coca plantation in Hawaii that formerly belonged to the Coca-Cola Company.
F. oxysporum EN-4 was scheduled for field testing in Colombia 2000. A contract between the UN Drug Control Program UNDCP and the Colombian government suggests that at that time large scale production and dissemination techniques existed, most likely referring to those proposed by David Sands.[34] Despite strong US pressure on the Colombian government, worldwide opposition stopped field testing in 2000.
Fusarium oxysporum, a serious pest in agriculture
The pathogenic fungus Fusarium oxysporum includes many strains that cause wilt diseases on a broad range of agricultural and ornamental plants. Among the pathogenic forms of F. oxysporum, strains with the same host range are grouped together into a so called 'forma specialis' (f.sp.). More than 48 formae speciales have been described with F. oxysporum, such as the strains feeding preferably on tomato plants (f.sp. lycopersici) or banana (f.sp. cubense). The different strains vigorously attack their host plants and can have a devastating effect on agriculture. While some strains have a narrow range of preferred hosts, others have the potential to devastate a broad variety of agricultural crops. A lot of effort is undertaken worldwide to fight back this noxious plant pest.
Dispersal: The fungus can be grown in mass quantities and induced to produce hardened life forms, so called spores, that can be dispersed by different means. Under favourable conditions, the spores would germinate and infect and kill its host plants. A variety of different dispersal methods have been suggested. The most direct form would be aerial spraying of the spores. The lead US researcher that developed the EN-4 strain, David Sands, proposed to equip large transport aircraft to spray tons of F. oxysporum spores from specialized equipment attached to the bottom of the plane.
The idea to disperse the agent from a high altitude is intended to blanket large areas and to avoid ground-based gunfire. Forced eradication efforts – especially in war situations such as in Colombia or some Central Asian areas – are likely to meet armed resistance, and several chemical eradication pilots have been killed in the past. Sands favours spraying huge areas where coca is currently grown and, as a preventative measure, over areas where coca could be sown.[35] In 2004 Colombia’s net production of coca was about 80,000 hectares, after a total area of 139,000 ha was either chemically sprayed (130k ha) or manually eradicated (3k ha).[36]
Airplane spraying a coca field with chemical herbicide in Colombia. The photo betrays the "overspray" problem of aerial eradication, a problem that would be compounded by Agent Green, whose characteristics as a living organism and whose proposed method of spraying (from high altitude) make it even less likely to stay on target. (Source: Colombia Coca Cultivation Survey 2005, UNODC)
Such massive deployment of the microbes would expose not only persons and communities currently involved in coca cultivation, but people in rural areas over most of Colombia. Coca, traditionally a high altitude crop, is increasingly adapted to the lowlands. Thus, sweeping areas are targets – from the llanos (plains) shared by Colombia and Venezuela in the northeast, easterly almost to Brazil, from the Sierra Nevada de Santa Marta in Colombia's north, south to the Ecuadorian and Peruvian borders along the eastern foothills of the Andes in the Amazon Basin, and west across the Andes nearly to the Pacific.
In addition to direct spraying of the spores, it has also been suggested to coat plant seeds (other than coca) with fungal spores and disseminate these inoculated seeds on the target area. The seeds would germinate and disseminate the fungal spores throughout the soil as the grass roots grow. This method is favoured for dissemination of Fusarium oxysporum by co-workers of David Sands.[37] It should be noted here that this particular dispersal mechanism represents a serious environmental risk – the contaminated seeds will easily be picked up by migrating birds which can distribute them over a large area and beyond any borders within a very short time frame (see chapter 4.3 below).
Genetic engineering: As far as is publicly known, the EN-4 Fusarium strain intended for use against coca plants is not yet genetically engineered. But in recent years, USDA scientists have created genetically modified strains in the laboratory with the goal to increase the kill rate. The research group of Brian Bailey at the USDA laboratory in Beltsville, Maryland, used genetic engineering to increase the production of a fungal protein, called NEP1, which is known to play an important role in infecting plants. They were able to produce a Fusarium oxysporum strain that produces more than 100 times the normal amount of NEP1, but (thankfully) this strain was not any more infectious for coca plants than the non-genetically engineered fungus.[38]
While this approach towards a genetically engineered version of Agent Green obviously failed, others may still be pursued. For example, the UNODC’s proposed 2000 contract for the testing of EN-4 in Colombia contained vague language regarding the use of genetic engineering. In the section of 'project risks', the Colombian contract read "the project will provide for the development of a system of unequivocally assessing the [fungus] population density, probably relying on genetically unique tagging of the pathogen."[39] The type of the envisaged “genetic tagging‘ and how far relevant research projects have been pursued is unknown.
3.2. Pleospora – a fungus targeting opium poppy
Pleospora papaveracea (image at right) is a fungal pathogen that attacks opium poppy (Papaver somniferum). Candidate strains for use in crop eradication were isolated in the 1980s by the Institute of Genetics in Tashkent, Uzbekistan. At the time, the facility was part of the Soviet Union's offensive biological weapons program.[40] Another fungus that is sometimes mentioned in research papers on Agent Green development is Dendryphion penicillatum, but it seems to be that the research focus is mainly on Pleospora.
In February 1998, UNDCP signed a contract[41] with the Tashkent Institute of Genetics in Uzbekistan to develop the fungus and related technology, including mass production of fungal spores and field tests in four neighbouring countries. These field tests and the development of production systems have now been finished. According to a presentation given by Uzbek scientists at a 2004 scientific conference, a ‘semi-industrial’ method to produce Pleospora has been developed. The scientists selected highly aggressive strains from infected plants, purified them, developed a method to produce the fungus in liquid media, and dried the spores after production. The Uzbek scientists concluded: “On the basis of this technology [a] composition of mycoherbicides, which is highly effective for the biocontrol of illegal crops of opium poppy in natural conditions has been created.”[42]
According to a newspaper report, the Uzbek scientists cooperated with researchers in Tajikistan, where field testing of the fungus has been carried out. The news report quotes a spokesperson of the Tajik Drug Control Agency as saying the tests were carried out from 2000 through 2002 in the Hisor Valley and in high mountain regions of Tajikistan. According to the spokesperson, the fungus destroyed 90% of young flowers and 60% of ripe seed pods.[43] There are also indications that some research was conducted in Kyrgyzstan. The head of the Scientific Section of the UN Office on Drugs and Crime UNODC,[44] Howard Stead, indicated that the fungus was tested on 50 plant species in the natural environment in the Kyrgyz Republic.[45] It is unclear if these tests were conducted in the field or in a greenhouse.
In addition to the research in Central Asian countries, US scientists have conducted their own research into P. papaveracea at the US Department of Agriculture (USDA) laboratories in Beltsville, Maryland.[46] In 2004, they reported the successful development of a liquid fermentation method using a small benchtop unit to mass produce the fungi. The process included drying of the fungal spores, and inoculation tests showed that the formulation caused damage within 48 hours of application to opium poppy leaves.[47] It is not known how far this work has been scaled up for the production of large quantities of fungal spores. The same research group also developed additives to the fungal spores to enhance effects on opium poppies.[48]
3.3. Other agents: Insects and viruses
Some research has also been undertaken with insects and viruses by US researchers. Compared to the fungus work it appears to be limited in scale. It is, however, difficult to judge the current state of these projects, as they are actively concealed from public scrutiny. Websites that outlined research projects related to drug crop killing insects or viruses have been altered and details of the projects removed - probably in reaction to the criticism in 2000 and subsequent Freedom of Information Act efforts by The Sunshine Project and independent researcher Jeremy Bigwood..
Insects: As early as 1986, the USDA was interested in developing a system using insects to kill coca. This program included coca-eating moths, but was not considered to be very effective, and after bad publicity the first Bush administration decided to halt the effort.
In a more recent development, in 1999 the USDA initiated a new five-year project called “classical biological control of narcotic plants”[49] which aims at identifying and testing insect enemies of coca, opium poppy and marijuana. According to the ARS’ Annual Report 2001, research focused mainly on insects that feed on marijuana plants (Cannabis sativa).[50] The work involves scientists at the University of California at Davis and is supervised by Dr. Raymond Carruthers, head of a USDA research group on exotic and invasive weeds based in Albany, California. As of August 2005, the website of this research group still lists the research project on drug eradication, but no further information is provided.[51] Previously available annual reports have been deleted.
In 2000, the USDA group reported that it had established cooperation with scientists in India, Nepal, China and Kazakhstan, and that during a first field trip in Nepal and India, some insects that feed on marijuana plants were collected. A greenhouse was also constructed where insects’ appetites for cannabis could be tested. Part of the five-year project is also to determine the potential for mass production and field releases of these insects in the United States. Another part of the project is the development of a software programme that would model the behaviour of the insect and drug plant population.
USDA officials in California and Maryland are reticent to discuss the insect project for reasons that are unclear. On one hand, they have stated that the funds being spent on insects for drug eradication have been “reprogrammed” (i.e. taken away from) the even more controversial mycoherbicide efforts. Yet, on the other hand, USDA has responded to information requests by providing details that understate the extent of the project’s work as described in its formal reports. It is unclear if the low profile that USDA is trying to maintain for this project is because it wishes to avoid attention from hawks in the US Congress or criticism from non-governmental organizations, such as environmental groups, that may raise difficult questions about the ecological risks of introducing large populations of non-native insects.
In a surprising twist, in June 2005 the head of a Colombian network of botanical gardens floated a proposal to grow and release masses of a species of a coca-eating caterpillar, called Eloria noyesi, as an allegedly more environmentally-friendly method of coca eradication than the use of chemical herbicides (presently a concentrated mix of glyphosate and other chemicals).[52] The idea is not an original one. Devastating infestations of Eloria noyesi have ravaged coca production in Peru in the past, and Eloria noyesi was one ‘alternative’ idea for coca eradication mentioned by the Colombian Environment Ministry in 2000, when it was stalling the intense US pressure for field testing of Fusarium oxysporum.
Details of the new Eloria proposal are sketchy, although any widespread application of caterpillars or moths, particularly in the midst of Colombia’s widespread conflict, is fraught with many technical hurdles. It is difficult to imagine the botanists overcoming them, even in the unlikely event that they were to receive strong backing from the Colombian state.
Entomological warfare [53] Insects may be used for biological warfare either through their own destructive work or to transmit insect-born diseases. Both avenues have been pursued in past US offensive biowarfare programs. One of the first documented intentional use of insects as a weapon of war happened in the US Civil War (1861-1865) when the Union was accused of having introduced the harlequin bug (Murgantia histrionica) into the southern United States in the intention to destroy the crops of the Confederacy.
In World War II, the US and several other countries investigated the use of Colorado potato beetle as a potential weapon. In 1962, US-Congress was informed that research was underway to develop insect mutants more resistant to cold and insecticides. An entomologist in the Crops Division at Fort Detrick was rewarded for his work on leafhoppers; studies were apparently underway to investigate pathogen transmission to plants by insects. Scientists at Fort Detrick were examining the potential of entomological weapons and carry out basic studies of effects of rearing procedures for various insects.
Viruses: In 2001 it became public that a US Department of Agriculture (USDA) team, headed by a plant pathologist at a facility in Fort Detrick, was experimenting with potyviruses to kill opium poppy. On 12 April 2001, the web page of this project included a description of the potyvirus work conducted by a USDA research team headed by Dr. Vernon Damsteegt. The website was soon thereafter edited to delete reference to the poppy-killing research, probably in response to publicity. Requests by the Sunshine Project under the US Freedom of Information Act were answered with a letter claiming that the work indicated on the USDA website was exploratory and had been terminated. The letter was accompanied by a large set of mostly illegible laboratory notes, allegedly the best copies available, that did little to clarify the research.
An important question around this project has to do with the history of a candidate potyvirus strain called D-437. Fort Detrick was a US military center for offensive biological warfare research before President Richard Nixon stopped the US program in 1969. According to USDA, before being recently thawed out, D-437 had been frozen in storage at Fort Detrick since that same year. Prior to 1969 Dr. Damsteegt worked at Fort Detrick on plant diseases for the US Army. He has since worked for USDA on controlling the spread of foreign plant diseases in the US. It appears that the USDA’s project involved a virus isolated in plant quarantine and sent to Detrick for evaluation by the then-offensive biological warfare program, an origin not dissimilar to that of the opium killing fungus Pleospora.
4. Environmental RisksBiological control of pests or weeds is certainly a worthwhile concept that has a tremendous potential to benefit agriculture. While the sound development of biocontrol agents is without doubt a valuable contribution for sustainable farming concepts around the world, it is important to note that a very careful environmental assessment on a case-by-case basis is of uttermost importance.
By definition biocontrol agents are detrimental to some plants or animals – that is the whole purpose of their release into the environment. Even after careful research and development efforts there is always the risk that a certain biocontrol agent may also harm non-target organisms, that it mutates and changes once released into a complex new environment and that it becomes a pest itself. A key element of biocontrol is therefore a close cooperation between the scientists developing a given agent and the farmers that will ultimately be using it. Biological control requires a careful monitoring of the effects on the ground throughout its use – and this will certainly not happen if the agents are released with a hostile purpose, with the people on the ground not knowing about the nature of the pest, and being harmed economically by it.
The whole concept of Agent Green, to forcibly use biological agents in a broad range of environments around the world, is a recipe for environmental disaster. Target specificity cannot be ensured, nor can ecosystem level impacts be closely monitored during use. This is especially worrying as any release of a biological agent is essentially irreversible – once spread in the environment, it will be impossible to recall if negative effects become apparent.
4.1. The agents are likely to harm other plantsThere is ample evidence that the fungi considered for use in drug plant eradication will harm a variety of other plants in the environment. While the proponents of Agent Green contend that the fungi are species specific and will only kill the target plants, their own research results indicate the opposite.
Testing of the fungi has been conducted with the primary objective to ensure effectiveness in killing plants, instead of their environmental and health safety. Testing of host specificity has been technically inadequate and very narrow in scope. It has not even included close relatives of target plants. Testing has disregarded complex and fragile ecosystems where the pathogens are intended to be released. With both F. oxysporum and P. papaveracea, tests have been limited to a range of cultivated (often horticultural) crops. No systematic testing has been conducted on wild relatives of coca and opium poppy.
Even in such an inadequate testing regime, the fungi have attacked both related and non-related species. Nevertheless, fungus proponents continue to implausibly insist that the candidate agents are “host-specific”, despite substantial evidence to the contrary.
Fusarium oxysporum: The strain of F. oxysporum that was developed to kill coca plants was not isolated from the species that is typically grown for cocaine extraction, Erythroxylum coca, but from a close relative, Erythroxylum novogranatense – hence the name EN-4. This is a first indication that this fungal strain is not as specific as claimed by the proponents. In addition, research commissioned by USDA revealed that at least two other species were attacked and killed in inoculation tests by the EN-4 fungus strain: meadowfoam (Limnanthes douglasii) and redstem filaree (Erodium cicutarium).[54] These two species are not at all closely related to coca plants, which strongly indicates that EN-4 might have a broad host range if deliberately released into a diverse ecosystem.
In the Erythroxylum genus there are over 200 species of wild relatives of coca, which might be affected by the fungus. In Colombia, four are listed as endangered.[55] US researchers have released no information that indicate they have researched the fungus' threat to these endangered species.
A frightening example from Peru illustrates that a Fusarium infection on coca plants may well spread over to other plants. Beginning in 1984, coca plantations in the Huallaga Valley in Peru were wiped out by a Fusarium oxysporum epidemic. When farmers tried to plant alternative crops on the same fields, these were also infected and killed by the same fungus.[56]
It should also be noted that even extensive and adequate testing may not guarantee continued target specificity of a Fusarium strain. As the head of the Florida Department of Environmental Protection pointed out: "Fusarium species are capable of evolving rapidly. Mutagenicity is by far the most disturbing factor in attempting to use a Fusarium species as a bioherbicide. It is difficult, if not impossible to control the spread of Fusarium species. The mutated fungi can cause disease in large number of crops, including tomatoes, peppers, flowers, corn and vines and are normally considered a threat to farmers as a pest, rather than as a pesticide. (…) Fusarium species are more active in warm soils and can stay resident in the soil for years. Their longevity and enhanced activity under Florida conditions are of concern, as this could lead to an increased risk of mutagenicity."[57]
Pleospora papaveracea: The host specificity of the fungus developed for use against opium poppy is similarly confused. US experts who analyzed the poppy pathogen concluded "the extent to which this fungus is found on hosts others than Papaver is unclear."[58] The genus Papaver includes 50 different wild species,[59] at least 7 of which are used as ornamentals, for hunting poisons, and for colouring.[60] No systematic attempt has been made to determine which Papaver species are subject to Pleospora infections.
It has been common knowledge for 50 years that Pleospora papaveracea attacks plant species other than opium poppy. German researcher Maria Meffert found in 1950 that the fungus can be isolated from Papaver argemone, P. setigerum and P. rhoeas, the corn poppy. Under laboratory conditions, even a plant from another genus, Chelidonium, was infected with the fungus.[61]
This was confirmed in UNODC's own research: "An isolate of P. papaveracea has been obtained from a diseased plant of corn poppy (P. rhoeas). This indicates that the specificity of this fungal species is not absolute."[62] And a list of potential anti-poppy mycoherbicides isolated by US government researchers indicates that USDA isolated candidate P. papaveracea strains not only from opium poppy; but also from Papaver bracteatum, a species grown to produce thebaine, a source of pharmaceuticals including codeine.[63]
Altogether, there is abundant evidence, both from independent researchers as well of those developing Agent Green, that a broad variety of non-target relatives of poppy will also be infected by this fungus.
Insects: The concern about non-target effects holds also true for other biological agents that are considered for use in drug eradication campaigns. Excepting Eloria, the participating researchers have not released the name and nature of the insects they are considering as agents for drug plant eradication. A detailed environmental assessment based on scientific literature is not possible at this time, but there are abundant examples in the literature of insects used as biological control agents running wild.
Musk thistle weevil, Rhinocyllus conicus has been introduced across the United States since 1968 to control musk thistle a serious weed of rangeland. The musk thistle weevil has been found to expand its host range to five native thistle species in the U.S. National Parks.[64]
The weevil Larinus planus was introduced in the US in 1992 to control the weed Canada thistle. Today it is preferably feeding on a native thistle in the Gunnison National Forest of Colorado. It is important to note that this weevil was evaluated for release in 1990, using contemporary protocols intended to prevent harm to native species. It turned out that those protocols were not stringent enough to protect native species.
4.2. Ecosystem level impactsOther environmental concerns are related to the difficulty to predict indirect effects on a given ecosystem. The pathogens are intended for release in complex and fragile ecosystems, and their overall impact needs to be taken into consideration. Some valuable species depend on wild relatives of narcotic species, and they are threatened by the wide and indiscriminate spread of the pathogen in the environment.
For example, one ecosystem level impacts concerns insect species that feed on coca plants and its relatives. Some of the most highly prized butterflies in the world, the strikingly beautiful species of the Agrias genus, are completely dependent on wild relatives of coca. Each kind of Agrias relies on a different species of wild coca as its host. Several species are endangered. If F. oxysporum attacks coca's wild relatives, reducing populations of wild cocas, the Agrias will also suffer.
Similarly, the agents could have a negative impact on microbial biodiversity in soils, which is very poorly understood. Russian researchers found, for example, that a F. oxysporum strain considered for use as a biocontrol agent killed other fungi in the soil. This led to an increase of other soil fungi that can produce detrimental toxins. After this discovery, the researchers recommended against using a strain of F. oxysporum as a biocontrol of broomrapes.[65]
A call for caution has been made by Colombian scientists regarding the massive introduction of the pathogen in the fragile tropical rainforest. According to the scientists; "the equilibrium of any ecosystem is based on processes such as selection, mutation and dispersion. The introduction and/or increase of any population brings an impact on all components of such ecosystem. Therefore, the introduction and/or increase of Fusarium oxysporum f. sp. Erythroxyli would bring modifications, not yet measurable on all forest's live populations including soil and aerial micro-organisms, birds, plants, arthropods, etc."[66]
4.3. Release into the environment is irreversibleLike any other biological agent, the fungi will be very difficult to control after a release into the environment. They are infectious agents that spread beyond the target area, and once the fungal genie is out of the bottle, it is impossible to put it back. The impossibility to control these fungi in space and time became apparent in the first experiments with Agent Green in Asia and Hawaii.
In Central Asia, when greenhouse tests were conducted on cannabis fusarium pathogens, control plants became unintentionally infected with the fungus. The scientists sheepish explanation shows just how easily the Fusaria can be carried beyond human control: "this [spread] can probably attributed to the bloom in fungus knats [sic] and shore flies that occurred in the greenhouse. These insects land in the inoculum and fly from plant to plant probably carrying spores in their bodies".[67]
Similar problems appear to have occurred when the USDA first field tested the EN4 strain in Hawaii. According to the lead fungus researcher, the Fusarium strain "was highly aggressive and was disseminated rapidly throughout the original infested field… containment of the fungus proved challenging". The strain then apparently jumped from experiment area to control plots that had not been deliberately infested.[68]
But the fungi will evade human control not only beyond its target space, but also in time, because of their long persistence in the soil. Fusarium oxysporum spores are very resistant in the soil. The fungus build survival structures (chlamydospores) that may survive indefinitely if the fungus fits into the soil ecology. US researchers estimate the survivability of these spores to be in the range of 40 years.
5. Risks to Human HealthThe health risks associated with use of fungal pathogens in crop eradication are many. Human Fusarium infection (fusariosis) is an emerging, life threatening disease with a mortality rate as high as 70%. As early as 1989, researchers developing a Fusarium oxysporum strain for use against drug plants admitted in a letter to the US Drug Enforcement Agency that F. oxysporum is "a problem in immunocompromised patients."[69] Concentrated aerosols of fungal spores are known to cause dermal and respiratory difficulties in humans. Some strains of Fusarium oxysporum produce mycotoxins with deleterious effects on animals and humans.
In addition to the direct human health risks, a widespread use of Agent Green may have also some indirect effects, for example on traditional medicine, a nutritional impact due to crop loss, and unanticipated effects due to environmental modification.
5.1. Fusarium infections: an emerging, life-threatening diseaseFusarium species have emerged as a major cause for fungal infections.[70] The first invasive fusariosis was reported in a child in 1973.[71] Invasive Fusarium infections represent an increasing cause of infectious morbidity and mortality in patients with blood cancer.[72] While aspergillosis remains the most common mycosis, Fusarium is the most frequently occurring new opportunistic pathogen that causes life-threatening infections.[73]
In a recent study at a cancer center in the USA, the mortality rate of patients with a Fusarium infection was between 52-70%.[74] Other researchers reported mortality rates between 70% and 76%.[75] Even treated appropriately in a well-equipped hospital, Fusarium infections prove to be deadly.[76] Fusarium infections are especially dangerous and difficult to treat[77] as they disseminate easily due to the ability of the fungus to build new, infectious spores within the body.[78]
One theory holds that Fusarium infections are on the rise mainly because the number of risk patients with a compromised immune system has been increasing for the past two decades. Patients after organ transplants or bone marrow grafts, persons treated with cytostatic drugs or immunosuppressive therapy, and HIV infected persons are most vulnerable to fungal infections.[79]
The lead researchers involved in developing F. oxysporum for use in the drug war were well informed about the infection risks, but have played them down by maintaining that only a narrowly defined group of immunocompromised persons are vulnerable. A report by the US drug czar's office claims that only immune-suppressed cancer patients, who are already vulnerable to almost any microbe, could be affected. But, even then, according to the US drug czar, there is little reason to worry since these patients "would be hospitalized and quarantined and not exposed to coca spraying."[80]
This view disregards not only the fact that several other illnesses – including diabetes or AIDS – can strongly compromise a patient's immune system, but also that the health status of those exposed to Fusarium spraying may be very different than that of US government researchers in Washington, DC.
According to Dr. Oswaldo Jave, a physician at the Hospital Dos de Mayo in Lima, Peru (the 2nd largest hospital in Peru and a major public teaching institution), immunocompromised illness in the rural Andes is not typically due to the same reasons or found in the same proportions as in the North and wealthy urban areas. In the rural Andes, viral hepatitis infection and incidents of consumption of methyl alcohol, for example, are common. Both problems lead to hepatic cirrhosis - an immunocompromising illness. In addition, while epidemiological data is incomplete, an estimated 5% of the Latin American population suffers from asthma. Many of these people take corticoids, rendering them an easier target for Fusarium.
Malnutrition, particularly among children, could also be a factor. Chronic undernourishment may suppress the immune system and increase the possibility of opportunistic infections. In many countries, malnutrition is especially prevalent in remote rural areas where illicit crops are grown. In Colombia, one in five children in rural areas suffers from malnutrition. In Peru, government statistics show that nearly 60% of children in rural areas suffer from malnutrition, compared to 21% in urban areas.[81] Afghanistan, the world's largest producer of opium poppy, is also one of the world's most malnourished countries, with an estimated 70% of the entire population lacking basic food security.[82]
While the immune status of the victim appears to be important, the extent of exposure to the fungus is another critical factor[83]. The more fungal spores an individual is exposed to, the higher the risk. It can be anticipated that exposure will be extraordinary high during deliberate spraying of Fusarium spores in drug eradication programs. In addition, it should be noted that fusariosis is not restricted to the immunocompromised. Recently, an immunocompetent patient in Germany died of a Fusarium oxysporum infection.[84] A similar report from India also suggests that F. oxysporum infections can occur even in patients that are not severely immunocompromised.[85]
Health facilities in regions where illicit crops are cultivated are generally not equipped to quickly conduct procedures to diagnose fusariosis. Nor are personnel trained to recognize invasive fungal infections, increasing the chance that patients may be erroneously diagnosed with more common diseases, such as tuberculosis or pneumonia. In such cases, treatment is unlikely to be effective and would be erroneously reported in to authorities in epidemiological reports. Even in cases where patients are promptly and correctly diagnosed, rural health care facilities in the Andes generally do not have the intensive care equipment (artificial respirators, cardiopulmonary monitoring and resuscitation equipment, etc.) and appropriate medicines to treat fusariosis. Even if such equipment and diagnostic training and protocols existed, few residents of coca-growing regions would be able to pay for the treatment.
5.2. Fungal toxinsSome fungi are capable of producing poisonous substances, known as mycotoxins, which have serious impacts on human and animal health. It is well known that some strains of Fusarium oxysporum can produce an array of highly toxic compounds, including trichothecenes and fumonisins.[86]
Trichothecenes belong to the most dangerous mycotoxins and are toxic enough to be considered typical biological warfare agents.[87] According to WHO, certain trichothecenes have an immunodepressive effect in animals, resulting in decreased resistance to secondary infections. The T-2 toxin, which is also embryotoxic and teratogenic, is one of the most toxic trichothecenes, with an oral LD50 in mice of 10.5 mg/kg body weight.[88]
Several outbreaks of trichothecenes-related disease in humans have been reported. Two outbreaks in China (1984) and India (1987) were caused by consumption of contaminated cereal products. Animal feed contaminated with Trichothecenes has repeatedly caused lethal poisoning in horses, poultry, hogs and cattle.[89]
According to WHO, Fumonisin B1 is toxic to the liver and kidneys in a variety of laboratory animals and is suspected to be carcinogenic to humans.[90] In domestic animals, fumonisins have been identified to cause a neurological disease in horses, pulmonary edema in swine, hepatotoxic and nephrotoxic effects in other domestic animals, and carcinogenesis in laboratory animals.[91] Neuropharmacological effects of Fusarium oxysporum extracts have been observed, including an increased aggressive behaviour in rats[92].
Not all strains of Fusarium produce all types of mycotoxins. The metabolism of fungi and thus the production of mycotoxins is dependent on environmental parameters. According to the WHO, the metabolites produced by F. oxysporum may vary depending on the growth substrate, the temperature and humidity.[93] Similarly, deadly mycotoxins might be produced only under specific stress situations in the natural environment, situations not reproduced under laboratory conditions.
Fusarium species have a high degree of mutagenicity, i.e. even if a specific strain is tested and does not produce mycotoxins at a given time under laboratory or small-scale field testing conditions, it may well mutate and change its species host range and/or its potential to produce mycotoxins. This phenomenon was the basis of the Environmental Protection Agency of the US State of Florida's rejection of a proposal to use a strain on Fusarium oxysporum for cannabis eradication.
Amazingly, neither UNDCP nor US researchers have even attempted to test the fungi for production of mycotoxins, although USDA researchers are well aware of the risk.
5.3. Other direct health risks
Fusarium species have long been recognized as a cause of cutaneous infections.[94] F. oxysporum can also cause keratitis, an infection of the eye.[95] The percentage of Fusarium involvement in eye infections varies according to geographical location. In some areas, 98% of keratitis is bacterial. In other regions, for example the southern United States, roughly a third of all keratitis cases are fungal, and a third of these are caused by F. oxysporum. These infections are difficult to treat and may result in severe damage to vision or even eye loss.[96]
Most scientific data on the health risks of Agent Green is related to Fusarium oxysporum, because Fusarium has been widely investigated as a contaminant in many crops, foods and feedstuffs. Only very limited research has been done on other agents such as Pleospora, but the comparative lack of data for Pleospora should not be interpreted as an absence of risk. There are indications that Pleospora has an allergenic potential: Pleospora species are listed as potential allergens.[97]
One of UNDCP's own research reports indicates that staff at the Tashkent Institute of Genetics "have already complained of symptoms of dermatitis and respiratory difficulties after exposure to the high concentrations of the fungus."[98] UNDCP officials did not react with alarm for possible impacts on the thousands of farmers and their families who would be exposed to the fungus if it were used in a field. Instead, they merely recommended the acquisition of a safety cabinet to protect the scientists.
5.4. Indirect health effectsIn considering the impacts of using fungi to eradicate crops, or any forced crop eradication program targeting traditional cultivars, it is necessary to consider secondary or spillover effects on health, and traditional health care and nutrition in particular.
Coca, opium poppy, and cannabis have legitimate, traditional uses for many indigenous people and rural communities across the world. Indeed, it is through millennia of work by these peoples that the plants were domesticated, developed, and came into use in medicine worldwide. Each – especially coca and opium poppy – have been of incalculable value for global public health as sources of analgesic drugs. Currently, these uses are expanding. Cannabis is finding increased popularity as an effective and inexpensive treatment for the effects of chemotherapy and as a painkiller in terminally ill patients. The plants also find use in industry (hemp fabrics), animal husbandry (fodder), and foods (including the world's best-known brand name, Coca-Cola).
Targeted crops are also the direct or indirect source of nutrition and well being. Roasted coca leaves are a staple food for many indigenous peoples in South America and an important source of minerals and vitamins.[99] Loss of this nutritional source could be devastating to some peoples.
If governments accept that forced crop eradication is an acceptable and effective tactic in the Drug War (and many do not), sadly, the pilot of a high-flying C-130 or even a small plane, much less the unintelligent fungus itself, cannot distinguish crops planted for traditional use from those sown for the purpose of manufacturing narcotics. Once sprayed across an area, the persistent fungi will attack indigenous people, small farmers, and everyone else alike.
Other, unanticipated human health effects of fungal agents cannot be ruled out. One is the physical dislocation of populations from cultivated areas as a result of spraying (and accompanying anti-narcotics and/or counterinsurgency efforts). If fungal eradication separates farmers from their food crops by, for example, coating nearby maize with fungus and its spray mix, food security will deteriorate, rendering families susceptible to disease or even starvation, and creating refugees. This problem is already experienced in Colombia, where chemical crop eradication is displacing families in coca-growing regions (some across international borders), sending them to camps and rendering them dependent on food assistance.
Other health effects relate to questions about the host specificity of P. papaveracea and F. oxysporum. That is, which plants it will attack. It is possible they may affect other crops or wild plants, animals, and soil biodiversity, with unforeseen consequences including possible effects on human health. For example, coca pescado ( "fish coca", a close relative of cultivated coca) is very valuable for indigenous peoples in the western Amazon. Growing beside water, coca pescado's vegetation provides cool shade and its falling fruit food for fish, especially on nutrient-poor blackwater rivers. As a consequence, the plant is a well-known fisherman's friend. Fish from near the coca pescado often provide human dinners. If F. oxysporum attacked coca pescado, indigenous people would lose a valuable aid to their food security.[100]
6. Violating the ban on biological weaponsFrom the outset of its program, US policymakers have appropriated the language of a legitimate branch of science and used the term “biological control” to describe the biological eradication research.[101] By equating biological control with biological warfare, the US program has put the reputation of a promising field of research at risk. Legitimate biological control protects cultivated crops from pests;[102] but fungal eradication kills the crop instead of the pest. According to a statement circulated in 2000 and endorsed by dozens of scientists:
"Labeling these programs as "biological control" puts the reputation of our field of research at risk, as the growing opposition could be turned against all biocontrol research. We strongly reject any equation of legitimate biological control and the use of biological agents in drug eradication and want to emphasize that legitimate biological control is environmentally safe and should never be used without the consent of farmers and ranchers, an aspect ignored by those promoting biological eradication of plants."[103]
Despite the obvious difference between biological control and crop eradication, a trick of language used by proponents of Fusarium and Pleospora is to call target crops "noxious" or "weeds", equating them with invasive species or plants that interfere with crops. According to the scientists statement: "the term "noxious organism" solely relates to organisms that are noxious in the context of agriculture or food storage/processing. While manufacturing illicit narcotics from certain plants is certainly undesirable, to kill a drug producing plant for the sole reason that it produces a narcotic substance does not qualify it as a noxious plant in an agricultural sense and therefore they are not a legitimate target of biological control. Programs to kill drug producing plants with biological agents are not "biological control" by any scientific definition. In fact such practice goes against the fundamental principles of the science of biological control: to work with and not against nature, and to involve farmers in the practice of the approach.”
Yet the inventor of the coca-killing fungus, David Sands, favoured forcible use of Agent Green, even without the consent of the target country, much less inhabitants of areas to be sprayed. And he admitted that this would constitute an act of biological warfare (see box below).
The Biological and Toxin Weapons Convention (BTWC) bans any development or production of biological agents for hostile purposes.[104] By UNODC's admission, the biggest areas of coca and opium poppy cultivation are combat zones. Under circumstances such as those found in rural Colombia and Afghanistan, law enforcement and military action are inseparably intertwined. But even States with no civil war or open conflict, the biological agents would still be used on rural communities by force.
The arguments of fungus supporters that law enforcement authorities should be allowed to supplement the legal tactic of manual eradication (pulling plants up by hand) with forced biological eradication runs into difficulty with the BTWC. There is no exemption in the Biological and Toxin Weapons Convention for the use of biological weapons in to forcibly eradicate illicit crops. Countries North and South recognize that prohibiting any use of biological weapons is critically important to stop arms proliferation, uphold treaty commitments, and protect human health and the environment. The development and use of Agent Green threatens to undermine the global consensus against biological weapons.
In a remarkable memorandum on August 22, 2000, former US President Bill Clinton conceded that the US plan to use microbial agents to eradicate drug crops may have an impact on biological weapons proliferation. Clinton wrote that his administration would not require the Colombian government to use Agent Green until "a broader national security assessment, including consideration of the potential impact on biological weapons proliferation and terrorism, provides a solid foundation for concluding that the use of this particular drug control tool is in our national interest.”[105]
In an interview with BBC Panorama[106] the inventor of the coca-killing fungus, David Sands, favoured forcible use of Agent Green, including without the consent of the target country.
And he agreed that this would constitute an act biological warfare:
SANDS: This fungus is the closest thing I've ever seen to a silver bullet ... I have seen it take out 99% of plants in a field. I think that's incredible and I think people should know that this technology exists ... This would be a green kind of warfare ...
BBC: Okay, but we're talking semantics here. You call it green warfare. Other people call it biological warfare. That is semantically correct, it is biological warfare.
SANDS: That can be right. It's biological warfare or green warfare. I just want you to understand my opinion is it's a good thing if it's done to eradicate something that the entire world feels is noxious.
BBC: What happens if consent is not forthcoming ... I put to you a hypothetical - you never get consent - what should happen then?
SANDS: You're saying that two countries [Colombia and Afghanistan] that knowingly are unleashing a chemical, a drug, on our children, an addictive drug, that they are consenting to do that and they are not consenting to do biological control, I think they should suffer the consequences of that decision.
BBC: Which means that we should go in without consent.
SANDS: I think somebody should.
BBC: And it should be treated as an act of counter terrorism?
SANDS: Well it's a pretty high stakes game. Just go to any rehab clinic and check it out yourself.
BBC: You're saying yes?
SANDS: Yes. –