A SCIENTIFIC CRITIQUE of NSW -EPA's SHORT-TERM (less than 1 YR) TESTING Of ONE Camphor laurel TREE Leaf CHEMISTRY (Julli et al., NSW-E.P.A.,2001).
Author: Joe A Friend, Camphor laurel Research-Centre P 0 Box 1518, Lismore. NSW. 2480 Author's Addresses: internet: camphorlaurel.com; camphorlaurel@nrg.com.au

SUMMARY:
Elementary toxicological tests were conducted by University of Technology, Sydney (Julli, Patra, Pablo, Sundaram & Chapman, Centre for Ecotoxicology -laboratories, published 06 April 2001.), for the New South Wales Environmental Protection Agency ('E.P.A')- using only leaves sampled from one known, old park, shade Camphor laurel near the central business district of Lismore, NSW Northern Rivers. A Report was written and published, with the single-year results concluding/suggesting that a Gum-tree(E. camaldulensis) leaf can, in dark, distilled water conditions be more toxic than a Camphor laurel leaf!....yet, under questioning, at a Camphor laurel Conference, also held in Lismore (2002), a co-researcher of Chapman has publicly stated that "all the Test-results of 2001 were confounded by the appearance and growth in-solution, of an apparently anaerobic microorganism" which was NOT identified! Nor were these salient, and central facts fully revealed in the publication-Report to the EPA by Julli et al.

DETAILED CRITICISM and REMARKS :

(1) New South Wales National Parks & Wildlife Service (NP&WS) has, as a result of its historical association (since the late 1980s) with Dr-Prof. H.Recher (and his co-researchers, Date & Ford, H.Dr.-also of UNE-Armidale) has not been supporting or undertaking any significant research into the chemistry or toxicology of exotic, and known-toxic Camphor laurel trees, (e.g. Overton (1901), Hiraizumi (1950), and Martindale(since 1950) -available in most streetside pharmacy stores, and substantive evidence for which is the lack of research into Camphor laurel chemistry at Southern Cross University from 1990 to 2000; plus the lack of an/y official MSDS' Safety Data Sheet that is in any way complete, or accepted officially by any one government anywhere in-the-world!# Also, in more recent times the NSW NP&WS is known (pers. comm's Melbourne-RMIT University 2003) to have provided sizeable amounts of dollar-funding to research or determine the toxin in other exotic plant species' known to have killed (just)a few wallabies, but 'zero' funding, AND shown zero-interest in submissions to-date (sent from the Camphor laurel Research Centre, Lismore, to NP & WS,1999-2003)for support-funding to investigate Camphor trees' toxins at leading Australian toxicological laboratories;

(2) ONLY THE LOWEST-Toxicity, OR 'LOW TOX1CITY' Chemotype (= TYPE) of Camphor laurel WAS (NOT RANDOMLY) SAMPLED /SELECTED; the NP & WS staff member who drove from Alstonville to Lismore to sample the single Camphor laurel tree was apparently provided with an instruction to:-

2.1 Take/sample Camphor laurel leaves only; not any other tree part; - in fact, it has been known, and scientifically published for over 50 years by the time of this work (Hiraizumi 1950) - in the most detailed piece of research published about Camphor laurel during the 20th century - in any part of the world, that the bark, esp. the root-bark of Camphor laurel trees is the most oil-rich, and toxin-rich (e.g. camphor, & safrole) part of the Camphor laurel trees; Additionally, as leaves have petioles, a nominal amount of bark (on the petioles) would have been included in-the-tests; this is not assessed by the Authors. So, only one limited-part of one Camphor' tree got sampled.....which is Not representative of the field situation!

2.2 NSW-NP & WS staffer/s quickly sampled the Camphor' leaves, (only older leaves? Not-stated) and sent them to the EPA-funded labs' in Sydney's Broadway , as a fresh 'bulked' sample - when, in fact, no more than one tree was sampled, - which would under normal scientific method/s be the basis of 'bulk sampling', that would then be (normally)subsampled upon reaching the laboratory-destination; but THIS DID NOT HAPPEN!

2.3 Sample a 'representative Camphor laurel tree' at Lismore, yet ( in all Apparency, not given instruction that more than 2 types exist/ed, nor Information by then made available to the NP & WS office at Alstonville ( Firth D.Dr. 1979 thesis, as well as in CRC-publication #1, by Friend, J A) that at least 2 types of Camphor laurel tree chemistries exist/ed, and that as Hiraizumi (1950 in 'Essential Oils' Vol 2) had determined for East Asian Camphor' trees, inter-hybridisation of Camphor laurels due to 'crossing' Chinese and Japanese subspecies result/ed in at least 8 discrete, and readily discernible, identifiable, as well as (named there 1950) hybrid types/chemotypes of Camphor laurel; additionally, NSW NP & WS had already been informed (CRC-Friend, to Alstonville office, 2000-2001) that the 'worst Camphor laurel tree-types' were the "new-generation, smaller trees" commonplace along waterway banks, and roadsides, of which some had already been analytically sampled & tested by NSW Agriculture, inc. ones that were found to be higher in safrole% than camphor%(bark oil) 'yellow type Camphor' - removed by 2001, by Far North Coast Weeds -, as well as 'High cineole% chemotype/s, on riverbanks & elsewhere; all evidence of which was totally ignored by NP & WS in their sampling of just one 'old, non-hybrid Camphor laurel in Lismore'

(3) LEAVES LET-to-DRY for WEEKS PRIOR TO Analytical Testing Upon enquiry, and telephone investigation/s, (Friend to Chapman, 2001, and 2002), it was revealed that a significant and considerable number of weeks elapsed in Sydney before the Camphor laurel leaves, that were merely left-to-dry were finally 'looked at' for sub-sampling and insertion in the test-glass containers. When questioned if he (Chapman) was concerned about the "loss of volatile toxins such as camphor, and naphthalene, and benzene-derivatives due to drying-out the leaves (not in a refrigerator at low temp.), and not immediately commencing/testing the leaves upon their arrival at the EPA Lab. in Broadway-Sydney, Dr Chapman merely stated: " We were only capable of doing the tests after all the prior test/ing of other specimens etc. was complete/d"; in-short, by drying the leaves for a significant time-period before beginning the laboratory tests, only some(species) of the leaf microflora can be supposed/assumed to have survived - the desiccation; a representative range of the most-active (anaerobic) organisms living in-leaf, and known by observation/s to exist in-the-field cannot be expected to have been properly-tested by the relatively 'lackadaisical' method/s adopted by Julli et al., under the supervision of Dr J.Chapman at UTS laboratories in Sydney.

(4) IN VITRO TESTING ONLY CONDUCTED for a SHORT-TERM TIMESPAN: The number of weeks that the Camphor laurel leaves were left in-solution, in-the-dark, was not indicative of a typical riverine/riparian situation, where it is usual for the leaves to be both there for many months, even years before a flood or 'fresh' washes them away, AND to be mixed-up with mud, silt, and other nutrient fractions, supporting a wide array of native anaerobic organisms. That is, the leaves placed into (distilled/sterile?) water by Chapman et al. could in no way be expected to simulate any one Northern Rivers' riverine situation.

(5) THE MICROORGANISM CONFOUNDING THE IN-VITRO RESULTS WAS MERELY & UNSCIENTIFICALLY DISCARDED. Rather than professionally send-on a sample of the microbe sighted, and photographed by Chapman et al. - as shown publicly at the First Australian Scientific Conference on Camphor laurel, held at Lismore City Council (2002), With a view to establishing what type of organism lived-on, or can be presumed to live-on, and help degrade Camphor laurel leaves anaerobically (in-solution), It was found by questioning Dr Chapman directly (Friend-Chapman , telephone comm's 2002) that "all the samples, and specimens were thrown-out" i.e.discarded important scientific specimens.......apparently on-the-assumption or false-assumption that what happens/occurs to or with Camphor laurel leaves underwater in just several weeks, would also be the same or identical to what would biochemically occur over 6 months or a year, or more in-water. (In fact, recent PhD research at Southern Cross Univ.-Lismore, by J.Schenk now proves that longer-term laboratory studies reveal, and confirm the field-findings and observations of Friend-CRC, in community published texts already available in many national, and state libraries -, inc. (with photographs) the demise of entire creek systems, involving complex oxidation, and chemical reactions that result in the formation of slimy 'sterol/sterol-like' compounds' covering entire shallow waterways( less than 25 cms depth), with compounds that totally thwart the observed biotic health of the aquatic ecosystems that they represent. Schenk found(to date) "orange precipitates" accruing underwater with Camphor chemotype extracts/oils from Type-A Camphor laurel trees, and a "lemon/y coloured precipitate' accruing and slaking on-water in the presence of leaves in water solubilising with Type-B Camphor laurel tree extract/oil (the commonly termed 'cineole-type Camphor' tree (after Firth 1979), Summary: Throwing-out important scientific samples can be construed as 'Negligence' , especially in-the-light of the repeated-years of unsuccessful attempts (1999-2003) {Friend to EPA-Grafton & Sydney offices, 'Emergency Hotline/s), to have EPA Officers come and inspect the "dying creeks" in and around The Channon in particular ; on-top of the stated fact that NSW Fisheries officers would also not visit or inspect the (said)observed dying creek tributaries of Terania Creek, upstream and downstream of The Channon, all (3) creeks of which are in direct association with almost total-cover by Camphor laurel canopies, including negligible native species still growing there with the Camphors', and which native species are usually observed stunted or totally overgrown/out-competed by the (hybrid) 20 - 35 year old Camphor laurels. In brief, the short-termist scientific work of Chapman et al. needs to be ignored.

(6) MOST IMPORTANT REFERENCES NOT INCLUDED by Chapman: Some of the most important texts internationally-available on the chemistry of Camphor laurel trees, and including one accessible to-all at the Sydney Royal Botanic Gardens , 'The Poisonous Plants of New South Wales' (1942), by the NSW Government's own 'Poisonous Plants Committee' were NOT AT ALL referenced by Chapman, Julli or their co-workers; other significant international scientific references omitted include those readily available in the Sydney Royal Botanic Gardens library (e.g. Watt and Beyer- Brandwijk (1962) 'Poisonous Plants of Southern Africa', indicating that hydrocyanic acid, amongst other listed toxins are commonly found in the biochemistry of Camphor laurel leaves; in fact, Julli et al. provide NO international literature review of the chemistry or toxicity of Camphor laurel leaves, that would be normally be expected - or at least, a Summary of same.

DATED: 21 June 2004 @ Lismore, NSW.

FOOTNOTES : # Both R.M.I.T.University-Melboume(in 2003), and Southern Cross University(in 2000) are known to have rapidly stopped all attempts, and commencements of detailed toxicity, or toxicological assessments of Camphor laurel oils, or oils and extracts made from various parts of the different, discrete types of Camphor laurel trees.
(Refs: Friend J A -CRC, personal investigations to Dr D.Leach/ 'scu', & at R.M.I.T. Friend- Dr.P.Wright, Centre for Toxicology, by email and in-person, May 2003).
I Declare this to be a True and Accurate Account of investigations conducted over the Last 4.5 years in the NSW Northern Rivers' Region, especially in connection with the known 'killer type' Camphor laurel trees (Kew Botanic Gardens, London, correspondence), now 'common' or abundant on many streams of NSW Northern River tributaries.