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In view of the many issues

scientifically–reported concerning
the safety of quintozene,
to both the environment
and desirable turfgrasses,
observers have commented that
it is INCOMPREHENSIBLE that
Canadian Golf Superintendents Association
would SQUANDER its resources
and DAMAGE its CREDIBILITY
in order to SAVE QUINTOZENE by
CONCOCTING a NON–EXISTENT CRISIS
Quintozene Crisis ?

What Crisis ?

June 24 t h , 2010

Health Canada

Re–evaluation Decision RVD2010–06 Quintozene

Selected and adapted excerpts

Q UINTOZENE F UNGICIDE
R E –E VALUATION D ECISION
BY H EALTH C ANADA

ACC ORDING TO P E S T M AN AG EM EN T R EG UL A TO R Y A G EN C Y OF H EA L TH
C AN A D A ―

After a re–evaluation of the fungicide quintozene , Pest Management Regulatory


Agency of Health Canada ( PMRA ), under the authority of the Pest Control
Products Act ( PCPA ) and Regulations, is granting continued registration of
certain uses while requiring a P H A S E – O UT of other uses of quintozene products
for sale and use in Canada .
Products containing quintozene used on C O L E C R OP S and for OR N AM EN T AL
B U LB D I P TR E A TM EN T S do N O T pose unacceptable risk to human health or the
environment, and have an agricultural value when used according to the label
directions.

All other uses of quintozene are being phased–out due to the health and / or
environmental concerns. A L L T UR F AN D OR N AM EN T AL U S E S A R E P H A S ED –
O U T.

BACKG RO UND I NF O RMAT IO N F ROM AN I NDEPENDENT PERSPECT I VE ―

De spi t e sci ent i f i c report s, C ana di an G o lf Superi nt ende nt s A ssoci at i on


( CG SA ) l eader s an d st af f deci ded t o SAVE Q UI NT O Z ENE.

I n order t o conv i nce Pest Manag em ent Reg ul at ory Agency of Heal t h Cana da
t hat a qui nt ozen e ph a se– out wa s UN NECES SARY, CG SA organi zed a l et t er–
wri t i ng cam pai gn. Mem bers were enco urag e d t o bl i ndl y wri t e a l et t er i n sup-
port of t he CG SA subm i ssi on of March 23 r d , 2009.

CG SA l eaders a nd st af f deci ded t o CO NCO CT A Q UI NT O Z ENE CRI SI S.

O bserv ers cl ai m t hat t he cam pai gn t o SAV E Q UI NT O Z ENE wa s d el i berat el y


MI SG UI DED, MI SLEADI NG, and I NCO MPET ENT .

Con se que nt l y, CG SA SEVERELY DAMAG ED i t s credi bi l it y i n Publi c Poli cy.

C ANADIAN G OLF S UPER INTENDENT S A SSOC IAT IO N


U NSUBSTANT IATE D A LLEGAT IO NS C ONCERNING THE I MPACT
C AUSED BY THE P HASE –O UT OF Q UINTOZENE F UNG IC IDE

A C C O R D I N G TO P ES T M AN AG EM EN T R EG UL A TOR Y A G EN C Y OF H EA L TH C AN -
A D A , comments regarding the value of quintozene were received from various
stake–holders.

Over 200 letters were received from representatives of turfgrass and golf asso-
ciations. Most blindly agreed with the CGSA SUB M I S SI ON of March 23 r d , 2009 ,
ACC ORDING T O TH E M I S G UI D E D AN D M I S L E ADI N G CG SA S UB M I SSI ON ―

Repeat applications of alternative active ingredients would be required to pro-


vide a prolonged period of protection equivalent to that of one application of
quintozene .
[ W rong ! ]

ACC ORDING T O TH E M I S G UI D E D AN D M I S L E ADI N G CG SA S UB M I SSI ON ―

Quintozene is a cost effective pest management tool for turf management.


Its loss as a turf pest management tool will result in a greater damage to turf
from Snow Molds .
[ W rong ! ]

ACC ORDING T O TH E M I S G UI D E D AN D M I S L E ADI N G CG SA S UB M I SSI ON ―

Damage to turf from Snow Molds will result in lost income as a direct result
of ―

• a reduced period of playability to greens and tees.


[ ?! ?!?! ]

• additional turf maintenance costs.


[ ?! ?!?! ]

• an increase in pesticide expenditures ― the registered alternative


products to the quintozene products are more costly, and will require
more than one application. [ W rong ! ]

BACKG RO UND I NF O RMAT IO N F ROM AN I NDEPENDENT PERSPECT I VE ―

Q ui nt ozene i s NO T t he best di sea se co nt rol product av ai l abl e t o t he G olf I n-


du st ry. Rai n and m el t i ng sno w sev erel y af f ect t he perf orm ance of qui nt ozene,
m ore so t han v i rt ual l y ev ery alt ernat iv e.
ACC ORDING T O TH E M I S G UI D E D AN D M I S L E ADI N G CG SA S UB M I SSI ON ―

Quintozene is needed for rotation with registered alternative active ingredients


with different Modes of Action to delay the development of resistance.
[ ?! ?! ?! ]

Most of the recently–registered alternative active ingredients to quintozene


have a S I N G L E – SI T E mode of action.
[ ?! ?! ?! ]

Greater use of active ingredients with a single–site mode of action will increase
the risk of developing resistance.
[ ?! ?! ?! ]

ACC ORDING T O TH E M I S G UI D E D AN D M I S L E ADI N G CG SA S UB M I SSI ON ―

Quintozene acts as a contact fungicide ― this is critical for control of Snow


Molds as A L T ER N A TI V E systemic fungicides will be less effective since turf is
dormant when these pests are active.
[ W rong ! ]

ACC ORDING TO P ES T M AN AG EM EN T R EG UL A TOR Y A G EN C Y OF H EA L TH C AN -


A D A . ..

... viable A L T E R N A TI V E active ingredients to quintozene are currently regis-


tered for the control of turf diseases.

BACKG RO UND I NF O RMAT IO N F ROM AN I NDEPENDENT PERSPECT I VE ―

I n addi t i on t o sup port i ng a pro duct t hat i s pl agued wi t h heal t h a nd env i ron-
m ent al i ssue s, a nd t h at i s co nt am i nat ed wi t h cont rov ersi al di oxi ns, t he l ead er-
shi p an d st af f of Canadi an G ol f Superi nt endent s A ssoci at i on end or se s t h e
PRO HI BI T IO N of pest cont rol prod uct s and su pport s t h e pol i ci es of Env i ron-
m ent al –T error–O rgani zat i ons. T h e se di sgu st i ng a nd u nacce pt abl e d eci si on s
were NEVER rat i f i ed by t he 1, 500 prof essi on al m em bers of CG SA.
March 23, 2009

John W organ
Director General
Re–Evaluation Management Directorate
Pest Management Regulatory Agency
Tupper Building C390,
Health Canada AL 6603B
2720 Riverside Drive
Ottawa ON
K1A 0K9

Re : Response to the Proposed Re–evaluation Decision Document of Quintoz-


ene.

Dear Mr. W organ.

On behalf of the Canadian Golf Superintendents Association ( CGSA ) , please


accept our thanks for the opportunity to respond to the proposed re–evaluation
decision document for quintozene, particularly as it relates to the use of this
ingredient on golf course turf.

As you are no doubt aware, quintozene, the active ingredient in Ter raclor F low-
able , Terraclor 75W P and various fertilizer combination products, is an impor-
tant tool for the control of snow mould [ sic ].

Snow mould [ sic ] is the most prevalent and potentially most devastating of
all turf diseases in Canada.

Our long Canadian winters with abundant snow fall provide the perfect condi-
tions for the development of snow mould [ sic ].

Therefore, golf courses across Canada must apply a fungicide or run the risk of
facing significant turf loss once the snow recedes in the spring.

Turf loss or death results in unacceptable playing conditions which, in turn,


results in lost revenue until such time as the conditions are repaired.

Repairing the turf requires time and significant, unbudgeted, input costs
( seed, fertilizer, labour, etc. ) to re–establish damaged areas.
To summarize, excessive snow mould [ sic ] damage can have a dramatic eco-
nomic impact on a golf course operation.

Further, the snow mould [ sic ] application is the most costly of all applica-
tions made during the season.

Therefore, it is imperative that golf course superintendents have reliable and


cost effective options available. [ The alternatives are unreliable ?! ?!?! ]

The quintozene–based products provide consistent disease control at prices


that are significantly more cost effective than alternative chemistries currently
registered for snow mould [ sic ].

The loss of quintozene will significantly limit the ability of some golf courses to
adequately protect their courses from this disease. [ ?! ?!?! ]

Although there are alternative fungicides available to golf superintendents for


snow mould [ sic ] control, quintozene is a major tool in a resistance man-
agement program. [ ?! ?!?! ]

Quintozene is one of only a few contact fungicides, and has a multi–site mode
of action. [ So what ?! ]

Most of the newer fungicides have a single site mode of action. [ ?!?! ?! ]

If quintozene is no longer available these single site products will have to be


used more often. [ W rong ! ]

This will cause a significant increase in the risk of resistance occurring.


[ I t shoul d b e not e d t hat t he re si st a nce of f ungi ci des t o Sno w Mol d di sea se s i s a
RARE occurr ence, and i t i s UNLI KELY t hat A NY t urf m anager wi l l EVER enco unt er r e-
si st a nce t o any p e st cont rol prod uct at any t im e t hroughout hi s/ h er care er. ]

The loss of quintozene would have dramatic financial and agronomic impacts
on golf courses across Canada . [ ?! ?! ?! ]

The CGSA respectfully requests that, as part of the re–evaluation process, the
PMRA give consideration to the value of quintozene within the turf industry
and to the continuation of its availability to the golf course sector.
Letter draf ted by Canadian Golf Superintendents
Association to be used blindly by its members ―

P LACE YOUR LETTER HEAD H ERE

March 23, 2009

John W organ
Director General
Re–evaluation Management Directorate
Pest Management Regulatory Agency
Tupper Building C390, Health Canada AL 6603B
2720 Riverside Drive
Ottawa ON
K1A 0K9

Re : Response to the Proposed Re–evaluation Decision Document of Quintoz-


ene.

Dear Mr. W organ.

Please be advised that I have reviewed the letter submitted by the Canadian
Golf Superintendents Association regarding the proposed re–evaluation deci-
sion document for Quintozene, and I concur with the submission of the CGSA .

Please include my support in your consideration of this decision.

Yours truly,

Your Name

Your Title

Your Company
This may possibly be
THE VERY LAST TIME
that a Government Agency
will rely upon information from
Canadian Golf Superintendents Association

This trade association has


SEVERELY DAMAGED
its credibility in Public Policy

Observers claim that the campaign


to SAVE QUINTOZENE
was deliberately MISGUIDED
MISLEADING and INCOMPETENT

Observers have concluded


that the leaders and staff of
Canadian Golf Superintendents Association
are truly NOT COMPETENT ENOUGH
to provide Technical Information
concerning pest control products
W IT H D R A W A L OF QUINTOZENE

Quintozene will be withdrawn from the Canadian market as of December 31st, 2010.

It has also been withdrawn from the United States ( U.S. ) market.

Moreover, quintozene has been withdrawn or suspended in Austria ( 1988 ), Finland ( 1996 ), Ger-
many ( 1988 ), the European Union ( 2000 ), and Australia ( 2010 ).

Q U IN T O Z E N E C A N C E L L A T I O N S C H E D U L E

On July 14th, 2010, the Pest Management Regulatory Association of Health Canada updated Canadian
Golf Superintendents Association ( CGSA ) about the STATUS of the golf course fungicide quintozene
in Canada ―

« Recently, [ CGSA was ] notified of the release of Health Canada’s decision document
( RVD2010–06 ) regarding quintozene use in Canada. We received several inquiries regarding the im-
plementation details of the decision for turf uses, which are as follows ― »

« As of December 31, 2010, all turf uses of quintozene fungicide will be cancelled. After that date, no
product with turf use claims will be allowed to be imported, sold, or used in Canada. »

[ Hence, stockpiling will NOT be permitted. ]

« Canadian fungicide registrants will be responsible for replacing all end–use product labels with re-
vised labels in the marketplace by December 31, 2010. »

« The Canadian quintozene technical registrant, Amvac, will be responsible for disposing of any re-
maining product ( labelled with cancelled uses ) from the Canadian distribution system and in the
hands of users. »

« With regards to fertilizer–quintozene combination products, PMRA is currently in discussion with


Canada Food Inspection Agency regarding appropriate timeframes for implementing this decision. We
will provide an update as soon as this is available. »

DESCR IPTION OF Q U IN T O Z E N E

Quintozene is a FUNGICIDE that is also known as PCNB.

This active ingredient has been used in the Golf Industry in very affordable products like Terraclor and
FF II.

It is classified as a Group 14 fungicide and an organo–chlorine.

Quintozene is a product that was brought to market fifty years ago, in the mid–Twentieth Century.

The first Canadian registration date for Quintozene 75% Wettable Powder Fungicide was 1959.
USE OF Q U IN T O Z E N E

Quintozene is used to control diseases like the Snow Molds, which are located in the thatch and soil,
as well as on the foliage.

Best results are obtained when quintozene is used in a PREVENTIVE application program.

It is sometimes recommended that quintozene be watered lightly as a SOIL DRENCH to wash the
chemical down into the soil.

PROB LEMS ASSOC IATED W ITH Q U IN T O Z E N E

Turf managers have claimed to experience several problems when using quintozene, especially when
maximum rates are used.

Here are some examples ―

● Chemical root–pruning of desirable grasses, especially after continuous and repeated use for sev-
eral years

● Death of turfgrasses in areas of application over–lap

● Increased injury from specific diseases, such as Take–All

● Phyto–toxic tip burn of turfgrass leaves

● SENSITIVITY TO RAIN AND MELTING–SNOW, leading to a poor DURATION OF CONTROL and the
need for an increased frequency of application

EFFEC TS OF C L IM A T E ON Q U IN T O Z E N E

In recent years, quintozene was NOT the best disease control product available to the Golf Industry.

Rain and melting snow severely affect the performance of quintozene.

A single application of this, or any other fungicide product, will NOT always provide sufficient always
provide a sufficient level of control of the Snow Mold diseases of turf.

In Eastern Canada, fungicide applications may need to be repeated several times for the control of
Snow Mold, in at least FOUR distinct periods of time ―

● During winter, after a mid–winter thaw

● Early in the spring, immediately after snow–melt

● Early winter, just prior to the first permanent snow–fall

● Late in the fall, during periods of high rain fall


COMPAR ISON W ITH MO DERN F UNG IC IDES

For the control of Snow Mold diseases, the DURATION OF FUNGICIDE CONTROL will be ADVERSELY
AFFECTED when ...

● humid conditions are caused by UNCEASING RAIN and MELTING SNOW, or

● when foliage does not stop growing.

In both situations, the amount of fungicide remaining on the foliage may be insufficient to provide
adequate control against the Snow Mold diseases.

The amount of fungicide applied late in the fall, JUST PRIOR TO THE FIRST PERMANENT SNOW FALL,
must persist until snow–melt, and preferably until early spring.

Some fungicides will persist longer than others.

For example, more modern Twenty–First Century fungicides, like iprodione ( Rovral Green ) and espe-
cially Instrata, will tend to REMAIN LONGER on foliage than older chemicals like quintozene.

In general, practical field experience has indicated that iprodione, and many other modern ingredi-
ents, have a LOW SENSITIVITY to rain or melting–snow, tolerating up to FIVE–INCHES of accumulated
rain.

On the other hand, quintozene may have a HIGHER SENSITIVITY to rain or melting snow, tolerating
NO MORE THAN THREE–INCHES of accumulated rain.

ADVANTAGES OF QUINTOZENE

Some turf managers claim that quintozene provides a major advantage over other more conventional
fungicides, since its mode of action is multi–site.

Many modern fungicides are classified as single–site, and hence, have been deemed as higher in risk
for problems of disease resistance to the product.

It should be noted that the resistance of fungicides to Snow Mold diseases is a RARE occurrence, and
it is UNLIKELY that ANY turf manager will EVER encounter resistance to any pest control product at
any time throughout his/her career.

Some turf managers select quintozene because it is AFFORDABLE.

However, affordability is inconsequential once the problems associated with quintozene are put into
perspective.

A M E R IC A ’ S D E C IS I O N R E G A R D I N G Q U IN T O Z E N E

In the United States, the Environmental Protection Agency ( EPA ) concluded that the risks when using
quintozene were SUBSTANTIAL from an environmental standpoint.
The major concerns cited are [ the EMPHASIS is our own. ] ...

● Quintozene is PERSISTENT IN THE ENVIRONMENT, with aerobic and an anaerobic soil metabolism
half–life of 189 and 30 DAYS, respectively

● Quintozene BIOACCUMULATES in the aquatic food chain. It persists in the environment ( half–life
in soil of greater than 60 days ), accumulates in human and other species ( bio–concentration factor
greater than 1000 days ), and is toxic to fish and invertebrates on acute exposure basis

● Quintozene is HIGHLY VOLATILE, and may be carried by long–range atmospheric transport. For
example, significant quintozene residues have been detected in regions where the product was never
been extensively used, such as Saskatchewan.

● Quintozene is immobile in most soils, but potentially able to partition to organic matter in the soils,
and move to surface water through erosion. Therefore, the surface water was FOUND MORE LIKELY
TO BE CONTAMINATED.

The Environmental Protection Agency concluded that the re–registration of quintozene was acceptable
provided that ALL TURF USES WERE TERMINATED.

It is not surprising that Pest Management Regulatory Agency of Health Canada ( PMRA ) followed with
the same decision, by PROHIBITING the SALE and USE of quintozene beyond 2010.

CG S A A T T E M P T TO S A V E – QU I NTOZE NE

Incredibly, some trade associations have SQUANDERED an enormous amount of their resources in the
pointless attempt to SAVE–QUINTOZENE.

For example, Canadian Golf Superintendents Association ( CGSA ) petitioned the Pest Management
Regulatory Agency of Health Canada ( PMRA ) concerning the future of quintozene in the market
place.

Here is an excerpt from the CGSA petition on March 23rd, 2009 ―

« [ ... ] the snow mould [ sic ] application is the most costly of all applications made during the
season. Therefore, it is imperative that golf course superintendents have reliable and cost effective
options available. The quintozene–based products provide consistent disease control at prices that are
significantly more cost effective than alternative chemistries currently registered for snow mould
[ sic ]. The loss of quintozene will significantly limit the ability of some golf courses to adequately pro-
tect their courses from this disease. »

« Although there are alternative fungicides available to golf superintendents for snow mould [ sic ]
control, quintozene is a major tool in a resistance management program. Quintozene is one of only a
few contact fungicides and has a multi–site mode of action. Most of the newer fungicides have a sin-
gle site mode of action. If quintozene is no longer available, these single site products will have to be
used more often. [ ?!?! ] »

« This will cause a significant INCREASE IN THE RISK OF RESISTANCE occurring. [ ?!?! ] »

« The loss of quintozene would have DRAMATIC FINANCIAL AND AGRONOMIC IMPACTS ON GOLF
COURSES ACROSS CANADA [ ?!?! ]. »
« The CGSA respectfully requests that, as part of the re–evaluation process, the PMRA give consid-
eration to the value of quintozene within the turf industry and to the continuation of its availability to
the golf course sector. »

PU TT ING FUNG IC IDE USE IN T O PERSPECTIVE

The CGSA may have EXAGGERATED the financial impact associated with the loss of quintozene.

Overall, fungicide usage on the golf course represents LESS THAN TEN PER CENT of a golf course
maintenance budget, whereas employee remuneration and fertilizers may be as high as EIGHTY PER
CENT of the budget.

It can be argued that efforts to tighten the golf course budget can be more effectively focused on
manpower and nutrients.

DEPEN DEN CE ON Q U IN T O Z E N E

It should also be noted that in Canadian regions that are severely prone to the development of Fusa-
rium Patch disease ( a form of Snow Mold ), particularly in the Pacific Northwest, quintozene is the
product of choice ― IN GRANULAR FORM.

Granular quintozene is applied with ordinary rotary or drop spreaders.

The DEPENDENCE of the Golf Industry on this formulation is a direct result of the REFUSAL of many
turf managers to purchase and operate modern LIQUID spray application equipment.

The loss of quintozene will likely represent an opportunity for many turf managers to advance them-
selves with modern Twenty–First Century application equipment with modern Twenty–First Century
products.

After the complete withdrawal of quintozene, all fungicides available for the control of Snow Molds will
need to be applied WITH A SPRAYER.

CG S A S Q U A N D E R IN G OF RESO UR CES ON Q U IN T O Z E N E

In view of the many questions concerning the safety of quintozene, to both the environment and de-
sirable turfgrasses, observers have commented that it is INCOMPREHENSIBLE that Canadian Golf Su-
perintendents Association ( CGSA ) would SQUANDER its resources in order to SAVE–QUINTOZENE.

Observers have also pointed out that CGSA should devote its resources to more serious issues con-
cerning pest control products, such as the imminent threat of a NATION–WIDE PROHIBITION of pest
control products, and the predictable REVOCATION of the Golf Industry Exception Status.

Moreover, by defending a product associated with serious health, environmental, and turf phyto–
toxicity issues, the CGSA has WEAKENED its credibility as a public affairs spokesman for the Golf In-
dustry.
Why did CGSA leaders even attempt to SAVE–QUINTOZENE ? Rather than deal with more legitimate
issues, CGSA leaders seemingly prefer to WAG–THE–DOG.

DESCR IPTION OF CG S A A C T I O N S TO W A G – THE – DOG

The leaders of Canadian Golf Superintendents Association ( CGSA ) are seemingly OBLIVIOUS to the
LOOMING SHIPWRECK which is on a COLLISION COURSE with Golf Industry PROHIBITION of its pest
control products.

CGSA leaders prefer to WAG–THE–DOG.

Furthermore, the leaders of CGSA have decided to ENDORSE the PROHIBITION of pest control prod-
ucts, and SUPPORT the policies of Environmental–Terror–Organizations ... as long as the Golf Indus-
try is provided with an Exception Status.

The 1500 professional members of CGSA NEVER ratified this DISGUSTING and UNACCEPTABLE DECI-
SION.

This will ultimately lead to their DOOM !

Moreover, CGSA leaders continue to deceive its DOOMED members with statements like ―

« The Province of British Columbia is currently conducting a consultation exercise to determine if it


should adopt legislation prohibiting the use of pesticides for cosmetic purposes on both private and
public lands. [ ... ] »

« There is no indication that golf will be included in the prohibition. [ ... ] Golf’s use of Health Can-
ada approved pesticide products is not cosmetic. »

CRI S I S – ?– WH A T– CRI S IS – ?

There are jurisdictions in British Columbia and Prince Edward Island that are already considering RE-
VOKING the Golf Industry Exception Status.

The leaders of Canadian Golf Superintendents Association ( CGSA ) do NOT understand that they are
now living in THE 9/11 ERA OF ENVIRONMENTAL TERROR, which will STRIKE AGAINST the Golf Indus-
try.

Rather than deal with the LOOMING GOLF INDUSTRY SHIPWRECK, CGSA leaders prefer to WAG–
THE–DOG.

The Enviro–Terrorist THREAT against the Golf Industry is LOOMING !

CG S A W AG – TH E– DOG W IT H Q U IN T O Z E N E

The motivation of CGSA leaders to SAVE–QUINTOZENE may be seen as an example of a trade asso-
ciation performing what is called WAG–THE–DOG.
WAG–THE–DOG is best known as a 1997 film starring Robert De Niro and Dustin Hoffman.

This film was based on the novel AMERICAN HERO.

It is the story of a group of people who attempt to DISTRACT the U.S. electorate from a presidential
sex scandal by hiring a Hollywood producer to fabricate a fake war with Albania.

This event was CONCOCTED in order to take political pressure away from the sex scandal.

Real–life recent political examples of WAG–THE–DOG include the following ...

● Premiers of Quebec CONCOCTED Referendums for Separation, which were used to DISTRACT the
electorate from problems with the economy

● President Bill Clinton CONCOCTED the NATO bombing of Kosovo, which was used to DISTRACT the
electorate from his sex scandal with Monica Lewinski

● President George H. W. Bush CONCOCTED Operation Desert Storm

● President Jimmy Carter CONCOCTED Operation Eagle Claw, which was used to DISTRACT the elec-
torate from his weaknesses as President

● The leaders of Canadian Golf Superintendents Association CONCOCTED SAVE–QUINTOZENE to


DISTRACT its membership from the LOOMING SHIPWRECK which is on a COLLISION COURSE with
Golf Industry PROHIBITION of ALL pest control products, including those used in the Golf Industry

Rather than deal with the LOOMING GOLF INDUSTRY SHIPWRECK, CGSA leaders clearly prefer to
WAG–THE–DOG.

To implement a doomed operation to SAVE–QUINTOZENE is a means of diverting negative attention


away from the more serious and complex issues surrounding the PROHIBITION of pest control prod-
ucts that are FEDERALLY LEGAL, SCIENTIFICALLY SAFE, and TOTALLY IRREPLACEABLE.

L E A D E R S R E S P O N S IB L E FOR W A G – TH E– DOG

Observers do not necessarily hold the elected CGSA leadership responsible for the DISGUSTING and
UNACCEPTABLE DECISIONS of CGSA.

Some observers blame the Administrative Staff of CGSA.

As is the case within many trade associations, the administrators frequently dictate policy for the
elected officials.

Unfortunately, observers have concluded that CGSA Administrative Staff is perhaps NOT SUITED for
the task of Public Affairs.

Nor does CGSA Administrative Staff seem to understand the issues regarding DIOXIN, which is a con-
taminant in quintozene.

In fact, observers strongly recommend that CGSA Administrative Staff be removed from the functions
of Public Affairs. They are NOT COMPETENT to represent the Golf Industry.

Distractions like CRISIS–?–WHAT–CRISIS–? and WAG–THE–DOG must end !


O bserv ers hav e concl uded t hat . . .
Force Of Nature presents THE WHOLE TRUTH FROM AN INDEPENDENT PERSPECTIVE from National Organization Responding Against HUJE
that seek to harm the Green Space Industry (NORAHG). It is a series of Reports destined for the Green Space Industry, the Environmental
Terror Movement, Governments, and the Media, nationwide across Canada, the United States, and overseas. The information presented in
Force Of Nature has been developed for the education and entertainment of the reader by providing a sequence of historical events WITH
COMMENTARY. The neutrality of these Reports might be disputed. Don’t thank us. It’s a public service. And we are glad to do it.

HUJE are identified on the basis of their statements, activities, affiliations, and whereabouts. Even though each Enviro Maniac Culprit is a
misguided adversary, each still deserves our respect. The use of the terms Maniac, Culprit, Terrorist, or Basterd are not accusations of any
legal wrong doing. Force Of Nature is simply holding Enviro Maniac Activists accountable for conspiring to change public policies that TER-
RORIZE, HARM, and THREATEN the Green Space Industry.

HUJE is a term used to describe Enviro Maniac Activists that routinely concoct FEAR MONGERING, FRAUDULENT LIES, MISCONCEPTIONS,
COERCION, THREATS, DECEPTIONS, TERROR, and PARANOID CONSPIRACIES that are DESIGNED to SCAM and DECEIVE the public into
believing there is some NON–EXISTENT danger with conventional pest control products. HUJE also SCAM and DECEIVE Government Offi-
cials into the NEEDLESS, SENSELESS, and MALICIOUS CONSPIRACY to PROHIBIT conventional pest control products that are FEDERALLY
LEGAL, SCIENTIFICALLY SAFE, TOTALLY IRREPLACEABLE, and ABSOLUTELY INDISPENSABLE.

HUJE have created LOSS OF REVENUES, BUSINESS FAILURES, BANKRUPTCY, and UNEMPLOYMENT, inflicting DESPAIR and DESTITUTION
for THOUSANDS of hapless victims throughout the Green Space Industry. The DEPRAVED INDIFFERENCE of Maniac Culprit Terrorist Bas-
terd HUJE is viewed as a form of TERROR, HARM, and THREAT against the Green Space Industry.

This Report provides NO guarantee regarding accuracy or completeness. In no event shall Force Of Nature be liable for any incidental or
consequential damages, lost profits, or any indirect damages. Force Of Nature is TOTALLY INDEPENDENT of any trade association or busi-
ness operating within the Green Space Industry. The events, characters, companies, and organizations, depicted in this Report are not al-
ways fictitious. Any similarity to actual persons, living or dead, may not be coincidental. All information, excerpts, and pictures contained
in this Report were found somewhere on the Internet, and may be considered in the public domain, serving one of the following purposes
― archive, education, promotion, publicity, or press release.

Force Of Nature, and its various incarnations, is the brainchild of William H. Gathercole and his colleagues. Mr. Gathercole is a principal
FOUNDER of the Modern Professional Lawn Care Industry in BOTH Ontario and Quebec. He holds a degree in Horticulture from the UNI-
VERSITY OF GUELPH, and another pure and applied science degree from McGILL UNIVERSITY. He has worked in virtually all aspects of the
Green Space Industry, including GOLF, PROFESSIONAL LAWN CARE, and CHEMICAL INDUSTRY, and has served in environmental compli-
ance, government negotiations, public affairs, and workplace safety. Mr. Gathercole has supervised, consulted, programmed, and/or over-
seen the successful and safe execution of HUNDREDS OF THOUSANDS of pest control applications in the urban landscape. He has trained,
instructed, and consulted with THOUSANDS of turf managers and technicians. Mr. Gathercole has also been an agricultural agronomist.
For many years, Mr. Gathercole was a contributing columnist for TURF & Recreation Magazine, Canada’s Turf and Grounds Maintenance Au-
thority.

Mr. Gathercole and his colleagues have followed the evolution of ENVIRONMENTAL TERRORISM for over a quarter century. For FIFTEEN
YEARS, the strategies designed and implemented by Mr. Gathercole and his colleagues guaranteed the control of the VERMIN OF ENVI-
RONMENTAL TERROR for the entire Modern Green Space Industry across Canada. Their involvement in Environmental Issues reached a
fevered pitch in the 1990s, when he orchestrated, with his colleagues, legal action against the Forces of Environmental Evil in the Town of
Hudson, Quebec.

Today, Mr. Gathercole is the ONLY TRUE RELIABLE WITNESS of the Hudson Affair. Mr. Gathercole is personally credited for crafting the
Golf Industry Exception Status that endures to this day. He is also the creator of the signs that are now used for posting after application.
His vast knowledge of our long journey with Environmental Issues is UNDENIABLE ― hopefully ! Mr. Gathercole is now retired, although
his name continues to appear as FOUNDER of Force Of Nature.

THE LIBRARY OF REPORTS • A LOOK AT Technical Information for the Green Space Industry • Agriculture • Bee Colony Collapse
Disorder • BOGUS Green Alternatives • BRITISH COLUMBIA Enviro Terror Conspiracy • CALGARY (Alberta) Enviro Terror STOPPED
• Canadian Association of Physicians for the Environment • Canadian Cancer Society • Canadian Environmental Law Association •
CARNAGE Caused by Prohibition • CONSEQUENCES of Prohibition • Cottam & Ghost Writers • Culprits Who Conspired to Prohibit •
David Suzuki Foundation • Dating Services for Enviro Maniacs • DDT and Politicized Science • Environmental Terrorists UNMASKED
• Enviro PROFIT Accumulated by Greedy & Avaricious Enviro Maniacs • Environmental Terror Organizations • Environmental Terror
That NEVER Ends • Famous Quotations • FERTILIZER Enviro Terror • Global Warming • GOLF INDUSTRY Looming Shipwreck &
Collision Course • Green Space Industry • Health Canada • HEROES Speaking Out Against Enviro Terror • History of the Envi-
ronmental Terror Movement • June Irwin, the Clown of Junk Science • Landscape Trades CAPITULATE • In VIOLATION of Federal
Law • Lying Sacks of (Enviro Maniac) CWAP • Myth Busting • NATIONAL Enviro Terror Conspiracy • Needless Hysteria • NEW
BRUNSWICK Enviro Terror Conspiracy • NOVA SCOTIA Enviro Terror Conspiracy • ONTARIO Haven for Environmental Terror • Or-
ganic Fertilizers • Paranoid Theories • Paul Tukey, The Bin Laden of Environmental Terror • Pests and Disorders of Ornamental
Plants • Pests and Disorders of Turfgrasses • Pesticide Free BC • Pesticide Q & A (Questions & Answers) • Positive Waves (The
Green Space Industry Responds with Outstanding and Innovative Ideas) • TWISTED Precautionary Principle • PRINCE EDWARD IS-
LAND Enviro Terror Conspiracy • QUEBEC Enviro Terror Conspiracy • RACHEL CARSON, the Queen of Junk Science • SASKATCHE-
WAN Enviro Terror Infestation • Satire, Laughs & Insanity • TERROR Talk & Weasel Words • The 9/11 Era of Environmental Terror
• The FAILURE of Integrated Pest Management • The FAILURE of Pesticide Free Parks • The Industry STRIKES BACK Against Envi-
ronmental Terror • The MISCONCEPTIONS About Cancer • The National Annihilation of the Modern Green Space Industry • The
Wisdom of Bill Bell • The Wisdom of Drysdale • The Wisdom of Health Canada • The Wisdom of Hepworth • The Wisdom of Hol-
land • The Wisdom of Lowes • The Wisdom of Mains • The Wisdom of Milloy • The Wisdom of the Solomons • The Wisdom of
Whelan • Update • Using Children, Pets, & Death as WEAPONS OF ULTIMATE TERROR • U.S. Enviro Terror Conspiracy • 2,4–D
• Warning

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