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Journal of Cleaner Production 17 (2009) 318–320

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Journal of Cleaner Production

journal homepage: www.elsevier .com/locate/ jc lepro

Letter to the editor

Rebuttal to letter to the journal of cleaner production

1 DairyGains Victoria, Management of dairy effluent, 2008.

Our paper on evaluating and controlling pharmaceutical emis-sions from dairy farms was initiated to identify pharmaceuticalpollutants, notably antibiotics, being discharged from the intensedairy farming area of the Macalister Irrigation District with theaim of improving management practices and minimising suchdischarges to the Ramsar listed Gippsland Lakes chain in VictoriaAustralia. These lakes are showing clear signs of serious environ-mental damage with a persistent algal bloom, dolphin deaths,and dead seagrass.

Comments to the Journal on the paper, before it was printed, byan Australian State Government department overseeing primaryindustry, are rather unusual and obviously not intended to beconstructive as illustrated by the extremely detailed search forminor errors. Unfortunately, the opportunity to enlist the expertisethat resides in the Department to the cause of protecting this lakesystem appears to have been passed up. That runs to adding tothe specific suggestions for bettering dairy farm practices accordingto the principles of continuous improvement, central to the notionof cleaner production. It most certainly would have been appreci-ated if scientific comment had been offered that contributed toachieving the objectives of the paper.

Indeed it is a worry that those with such obviously detailedknowledge are not working to get governments to tighten upcontrols to fix the problem, instead of defending the old wayswhen it is time for the new.

Whilst the recorded drug concentrations might be ‘‘minute’’ interms of conventional contaminants they are at or in excess oflevels which are regarded to be of concern by leading environ-mental regulators such as the USEPA, EEA, etc. All samples weretaken from within the irrigation area, some within sight of dairysheds, so the claim that the chemicals identified were not fromdairy farms is both defensive and nonsensical. Moreover, a numberof overseas studies identified in the References have reportedsimilar findings coupled with the observations of Kolpin repro-duced in the paper, thus . There’s a whole other source of pharma-ceutical pollution that really needs attention, and that’s livestock use,which generates an estimated 500 million tons of waste each year and. that livestock manure is full of antibiotics, synthetic and biogenichormones, and other veterinary medicines.

The Department has been at such pains to counter the researchfindings that it has ended up downplaying the seriousness of resis-tant bacteria – even querying whether there are in fact, superbugs?The absurdity of its position is evidenced by the growing expres-sions of alarm in the medical fraternity – around the time theDepartmental letter was being drafted the president of the

0959-6526/$ – see front matter � 2008 Elsevier Ltd. All rights reserved.doi:10.1016/j.jclepro.2008.09.002

Australian Society for Microbiology, Keryn Christiansen, waswarning that – contrary to the public idea of superbugs being an infec-tion caught while in hospital – strains of MRSA circulating in thecommunity were more virulent and caused more severe disease thanthe types usually found on wards. And, now (September 2008) thereis a new strain of a superbug which began in Queensland and hasspread throughout Australia, but which this time affects young,healthy people as well. There is a similar belief that these type ofbugs may lead to unhealed lesions if open wounds come intocontact with them such as in waterways, indeed such feral strainscould threaten the very microbiological foundations of aquaticand soil ecosystems (various references are cited pointing to thispossibility). Whilst it cannot be proven at this time that this isthe case, coupled with new findings on chemical mixtures, thereis reason to invoke the precautionary principle by identifying andtaking decisive preventative action.

Part of the environmental burden of the industry has derivedfrom historic cost pressures which have driven dairying more andmore into the factory farm mould. One consequence has been fewerfarms, larger herd sizes and greater stocking rates. Efficiency isconceived of as an increased throughput through a fixed infrastruc-ture. In the Macalister Irrigation District alone properties areapproaching feedlot proportions with no store cattle. There is notreatment of the effluent that leaches from the paddocks into drainsand watercourses (infested with Carp that mobilise otherwise trap-ped sediment contaminants into the water column) while theretention ponds to capture dairy shed effluent are generally under-sized and/or poorly maintained. Recently released guidelines forthe Management of Dairy Effluent1 in referring to such ponds, over-look the fact that annual rainfall is now far more peaked underclimate change and this can see them quickly overflow even thoughthey may have been adequate to cope with an evener rainfallpattern of the past. (There are also stipulations governing the recy-cling of nutrients by spraying effluent back onto paddocks – a some-what unwise action in the light of a likely re-concentration of drugsand salt.)

Negative, defensive responses to calls for lifting environmentalperformance are entirely unnecessary: Best practice philosophiesand measures that have been built up since the dawn of cleanerproduction thinking, wait application. We have identified buta few. Given the positive mood within the local industry stemming

2 Marten Scheffer, Stearpenter, Jonathan A. Foley, Carl Folke & Brian Walker Cata-strophic shifts in ecosystems, Nature 413, 591–596 (2001).

Letter to the editor / Journal of Cleaner Production 17 (2009) 318–320 319

from the current boom for dairy products, it would seem no bettertime for it to begin a step-change.

In what follows we address further technical issues raised by theDepartment.

� The antibiotic sulphasalazine is not available from veterinarysurgeons and is never used on dairy farms. Our farming sourcesadvise otherwise.

� Enrofloxacin, nalidixic acid and sulphasalazine are antibioticsused only for human treatments or for pets. They are not fromdairy farms. Sorry: but our tests were taken in the middle ofan irrigated dairy area at the peak of the calving season. Amedical colleague comments .‘‘Sulphasalazine is in fact ananti inflammatory drug used for inflammatory bowel diseaselike Crohn’s disease.it would make sense to use it for Johne’sdisease. It is a combination of a drug (antibiotic) and aspirin(salycilate).’’

� DEET is not commonly used on dairy farms. Fly repellents arewidely used in dairy sheds and on cows to settle them downat milking time

� Australian Government assesses all ag/vet chemicals. Correct, but itdoes not monitor for their impacts on the watershed/environment.

� Demonstrate any relationship between the traces of antibiotics andthe impact on the aquatic environment. See esp. Ref No. 9 (Con-stanzo Simon, Murby John, Bates John. Ecosystems response toantibiotics entering the aquatic environment. Marine PollutionBulletin 2005;51: 218–23) as well as Nos. 31, 32, 35-38.

� Fires/floods causing algal blooms – due to ash/nutrient flow. Thefire/flood event was not comprehensively monitored; webelieve that most contamination was from West Gippsland;and it wasn’t monitored either.

� Pasture based dairying requires additional nutrients and supple-mentary feed. The Department is suggesting that this is cleanerthan overseas practice; but Macalister Irrigation District farmsare approaching feed lot status without the controls.

� Scours. Sulpha drugs are used; but if calves are in a weakenedstate (viz. a lowered immune system) it leaves them susceptibleto secondary infection; hence the application of antibiotics. Thisweakened state also leaves them susceptible to Coccidiosis.

� Calves are shedded for 4–6 weeks; This is usually the practice of‘‘syndicated or larger shared dairies’’. It is common for calvesto be shedded for up to 2 weeks, and then allowed to roam ina small paddock equipped with a shelter shed and mobilefeeders. Scouring calves are susceptible to disease and adminis-tered antibiotics.

� Calves are not a vector for Johne’s disease. Our sources advise thatcalves get Johne’s at about 12–18 months.

� Flies. Dairy sheds are sprayed out; and cattle are treated with anapplication poured along their back. Flies are a big problemaround dairy sheds

� Black Mamitus or Black Mastitis is a situation where bloodvessels in the udder burst. The condition can be a secondaryfactor to mastitis and is sometimes prevalent in high milk pro-cessing beef-dairy cross females which are much sought afterfor ‘‘vealer’’ production. Such females need to be prudently scru-tinised especially for uniform teat size. We are advised thatcopious quantities of antibiotics – penicillins – are administeredto fight this infection. It can be transferred by unhygienicprocedures.

� Coccidiosis is not a bacterium.An error in translation but it’sstill a microbe.

� Hormones. Hormones are used to ‘‘synchronise’’ herds in some(usually larger) dairies. Hormones are also used to induce earlybirthing of herd tail-enders. This results in underweight calves,and calves with a reduced immune system.

� Synthetic prostaglandins are almost never used to abort cowfoetuses. It is common practice in the livestock industry to usesynthetic prostaglandins to deliver calves prematurely; thiscan be labelled ‘‘induced’’ or ‘‘abort ’’.

It is not doubted that agricultural and veterinary chemicalsare assessed for potential environmental impacts; but the aimof this paper was to identify those chemicals that did notremain on farm, and to provide evidence that may induce theState Governments of Australia to implement comprehensivecatchment wide water quality monitoring and targetted finitetesting. The risk to human health and the environment posedby antibiotics used in agriculture is not low; but it will not beaccurately determined and quantified until Australiacommences water quality testing in line with Europe and theUSA.

The Department is correct in asserting that no evidence existsbetween antibiotics found in the MID drains and the impact onthe aquatic environment; simply because the Victorian EPA isdenied funding to enable it do this research. What we can confirmhowever is that following the 2007 flood event that cleaned outthe MID farming area, a ‘‘witches brew’’ of nutrients, pesticideshormones, antibiotics and other farm drugs headed to the Gipps-land Lakes. Not long after there followed the death of all filterfeeders. At the time of this event two more dolphins died,bringing the total in a little over twelve months to nine, and 40per cent of the dolphin population developed skin lesions. Thatsame event was not monitored for the chemicals mentionedabove.

Flat denial that the situation is grave indicates a poor grasp ofthe subtleties of ecosystems and the way they can be steadily weak-ened by continual stress possibly leading to their collapse – the‘‘drip-drip effect’’. This gap in comprehension surfaces in the asser-tions of a local identity that . the lakes are not dead or dying butrather many of these problems have been decades, if not a century,in the making and will take decades of concerted and sustained actionto fix. Quite apart from their failure to acknowledge that the stressesof climate change may work against any so called recovery – we’vealready witnessed a devastating wildfire – such statements areunmindful of the fact that catastrophic shifts can typically occurquite unannounced in ecosystems, and early-warning signals ofapproaching catastrophic change are difficult to obtain. Indeed,the apparent resilience of such systems can lull authorities intoa false sense of security.

Schaefer et al. has some especially interesting observations onlakes in a major Review Paper for Nature2:

One of the best-studied and most dramatic state shifts is thesudden loss of transparency and vegetation observed in shallowlakes subject to human-induced eutrophication. The pristine stateof most shallow lakes is probably one of clear water and a richsubmerged vegetation. Nutrient loading has changed this situationin many cases. Remarkably, water clarity often seems to be hardlyaffected by increased nutrient concentrations until a criticalthreshold is passed, at which the lake shifts abruptly from clear toturbid. With this increase in turbidity, submerged plants largelydisappear. Associated loss of animal diversity and reduction of thehigh algal biomass makes this state undesired. Reduction of nutrientconcentrations is often insufficient to restore the vegetated clearstate. Indeed, the restoration of clear water happens at substantiallylower nutrient levels than those at which the collapse of the vege-tation occurred.

Letter to the editor / Journal of Cleaner Production 17 (2009) 318–320320

Finally, the claim that the Australian dairy industry is ‘‘clean andgreen’’ is not supported by sound scientific evidence, but rather bythe industry’s PR machine. As stated, there is much room forimprovement in the industry, and this can be assisted with open,honest and comprehensive water quality monitoring of the Gipps-land Lakes and its feeder streams. Only then can pollutants andpolluters be identified and remedial management practicesimplemented.

Peter M.J. Fisher*

Ross ScottCentral Queensland University, Faculty of Sciences, Engineering &

Health, Bryan Jordan Drive, Gladstone, Queensland 4680, Australia� Corresponding author. Tel.: þ61 3 9387 2107.

E-mail address: pmjfisher@bigpond.com (P.M.J. Fisher)

Available online 21 October 2008