(Beyond Pesticides, February 14, 2024) The latest in a series of reports on the state of farmworker protection, released last December, highlights the long history of health threats, regulatory failures, and structural racism that is imbued in the chemical-intensive agricultural system that feeds the nation and world. The authors conclude that farmworkers “face a level of occupational risk unrivaled by most workers.” They continue: “From repeated exposure to pesticides and extreme heat, to injuries from machinery and repetitive motion, conditions on American farms involve myriad hazards. Meanwhile, a lack of access to healthcare and legal services, low wages, marginalization, language barriers, racism, and the threat of deportation among these largely immigrant communities compound their many challenges.” Describing the U.S. food system and the workers who serve as its foundation, Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety is the third publication in a series of reports on farmworker health and safety, led by the Center for Agriculture and Food Systems (CAFS) at Vermont Law and Graduate School and written with the Harvard Law School Food Law and Policy Clinic and the nonprofit group Farmworker Justice. Johns Hopkins Center for a Livable Future and Farmworker Justice partnered on the first and second reports, respectively. The report raises anew the question of whether continued use of petrochemical chemical pesticides and fertilizers in agriculture, with additional catastrophic threats to biodiversity, climate, and the general population, is justifiable in light of the commercial viability of organic agriculture in all food commodities.

The first report in the series, Essentially Unprotected, identifies gaps in U.S. laws and policies that put farmworkers at risk, specifically focusing on the workplace hazards of pesticide exposure and heat-related illness. The second report, Exposed and at Risk, in addition to highlighting the systemic racism of the country’s pesticide policies, outlines how state and federal enforcement of pesticide safety regulations are weak and unreliable—proposing policy solutions, given that the current “complex system of enforcement . . . lacks the capacity to effectively protect farmworkers. . . . [and] the cooperative agreement[s] between federal and state agencies makes it nearly impossible to ensure implementation of the federal Worker Protection Standard (WPS),” administered by the U.S. Environmental Protection Agency under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The new report focuses on states with significant farmworker populations, including California, Washington, Florida, Illinois, North Carolina, Oregon, and New York.

Challenges highlighted in the report focus on the shortcomings and compliance issues that undermine the WPS, including:

• Ineffective training: training does not reach the majority of workers, no measure to verify retention, no refresher trainings for trainers or workers;
• Access to information: lack of properly posted warnings, language barriers;
• Pesticide drift: Application Exclusion Zone (AEZ)—
  • Radius not sufficient, drift can enter worker housing, nearby workers not protected;
  • Employer confusion about obligations under changing regulatory standards;
• Exceptions to Restricted-Entry Interval (REI): working during periods when entry to treated areas should be restricted;
• Poor personal protective equipment (PPE): lack or insufficient, in high temperatures, workers can face increased medical risks while wearing PPE [more on Heat Related Illness (HRI)];
• Decontamination supplies: badly located, discouraged from using due to short or nonexistent breaks/workplace norms;
• Emergency Assistance: lack of knowledge for how to recognize and treat toxic exposure among workers—
  • Workers fear retaliation, termination of a work visa, or deportation if they seek medical attention, given that there is no guarantee of confidentiality when reporting a violation;
  • Workers often do not know their symptoms reflect pesticide illness (and if employers do not tell workers about an application, workers may not link symptoms to pesticide exposure);
  • Medical facilities sparse in rural areas, medical personnel lack training, language barrier.

The report also identifies factors contributing to the compliance problems, power dynamics, the fear of retaliation, low penalties for violations, and a large number of agricultural workers vulnerable to exploitation due to their immigration status as H2A Visa holders without an understanding of their rights. The authors point out that while the prohibition of pesticides on certified organic farms protects against exposure, organic standards do not include labor standards. To address this deficiency, the Agricultural Justice Project, founded in 1999, created the Food Justice Certification that serves as an add-on label to USDA organic. The standard addresses: fair contracts and fair pricing for farmers, fair wages and fair working conditions for workers, safe working conditions, environmental stewardship through organic practices, and truth in labeling.

Farmworkers’ toxic chemical exposure does not fall under the jurisdiction of the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) like almost every other worker in the U.S. The WPS was developed out of a series of field hearings and replaced a rule under a 1974 standard in EPA regulations that only instructed growers to keep workers out of pesticide-treated fields until the dusts had settled or sprays had dried. That standard was developed after field hearings in which EPA heard from growers but not farmworkers. With the threat of litigation from the National Association of Farmworker Organizations and Migrant Legal Action Program in the late 1970s, the Carter Administration funded an effort to reach out to workers and collect data on their experiences with pesticide exposure and poisoning in the fields. Jay Feldman, Beyond Pesticides’ executive director, involved in that effort, points out that, “Chemical-intensive growers viewed the discussion about worker protection as a threat to agricultural production and their livelihood and resisted calls for new standards.” So, it was not until nearly 15 years after the Carter Administration began the review that EPA in 1992 upgraded the 1974 “standard.”  EPA’s current day WPS is largely administered by states through “cooperative agreements—negotiated by EPA’s ten regional offices—allowing states, mostly under the authority of state agriculture departments, to enforce federal pesticide protections with mixed results.

Despite questions about the reliability of the data, the report provide some insight into compliance rates with WPS. According to the report, “In 2021, states inspected 3,092 facilities and recorded 1,491 violations (a 48% noncompliance rate); tribes inspected 40 facilities and noted one violation; and the EPA inspected no facilities.”

Among numerous recommendations, the authors call for the following:  

• Amend the federal pesticide law (FIFRA) to include a private right of action (individual or organization ability to sue for violations of the law) for WPS violations, with civil penalties recoverable by the workers put at risk.
• EPA administration of cooperative agreements: incorporate stakeholders and partnerships to ensure community-based organizations play a significant or lead role in steering project that aim to benefit the farmworker community.
• Support the education, training, and recruitment of bilingual inspectors and move toward making language skills a job requirement.
• Engage in a national campaign, tailored to each region, to raise awareness of these obligations and their importance.
• Evaluate the WPS overall and its individual components for protecting and promoting farmworker health and safety.

The report includes a section on “Organics” and discusses materials, although very few, that can have acute and respiratory effects to workers, including sulfur. Because of this, authors stress that organic farmers are responsible for complying with the WPS. In this regard, the authors suggest that organic regulations be amended to require, under the organic rules governing organic system plans (7 C.F.R. § 205.201), that growers using farm chemicals that trigger WPS requirements and certify their understanding of their obligations under the WPS.

Overall, however, the report notes, “Encouraging growers to transition to organic agriculture is a worthwhile strategy for mitigating the harm from the most toxic pesticides. Organic transitions can also mitigate concerns regarding pesticide drift from conventional operations onto organic operations. . .Farmworkers at organic agricultural establishments have been found to have lower concentrations of insecticide and fungicide metabolites in urine—an indicator of harmful pesticide exposure—compared to those working on conventional agricultural establishments. The National Organic Program’s (NOP) focus on promoting on-farm ecological balance by relying on mechanical, biological, and cultural practices rather than chemical applications can help reduce farmworkers’ exposure to harmful pesticides. Every certified-organic agricultural operation is required to develop an organic system plan (OSP), which specifies how farmers will control pests of concern, and submit it for approval to a third-party certifier. Thus, third-party certifiers can support the health and safety of farmworkers by emphasizing that pesticides should be considered only as a last resort and by ensuring that an OSP’s requirements remain rigorous and that the plan prioritizes techniques that promote ecological balance.”

The pesticide problem is not unique to farmworkers, but they and their families suffer a disproportionate burden of the hazards. Although choosing certified organic products in the marketplace eliminates nearly all of the hazardous pesticides on the farm, it does not ensure adequate working conditions, wages, and labor practices. The Agricultural Justice Project, and its Food Justice Certified labeling, address this gap in the organic marketplace, and producers should be encouraged by consumers to participate in this certification process .

Farmworkers need more protections, not industry-friendly compromises. Beyond Pesticides’ coverage of farmworker exposure to pesticides and resultant harms began in the late 1970s and continues to this day, with recent attention drawn to an incidence of kidney damage, systemic racism in EPA farmworker policies, and extra risks endured by farmworkers during the COVID-19 pandemic.

In addition, many farmworkers are migrant workers and subject to conditions that would not be permitted for U.S. citizens. The U.S. is not a signatory to the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard in this country to treat migrant workers with the same rights and dignities afforded U.S. citizens. 

To take action and protect those who grow our food, click here to tell EPA to strengthen pesticide rules to protect farmworkers and urge President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families. For more information, see Beyond Pesticides’ webpage on Disproportionate Risk

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source:
Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety, December 2023; Essential and in Crisis: A Review of the Public Health Threats Facing Farmworkers in the US, May 2021, Johns Hopkins Center for a Livable Future.

(Beyond Pesticides, February 13, 2024) Last week, the United States District Court for the District of Arizona struck down the U.S. Environmental Protection Agency’s (EPA) 2021 approval of three dicamba-based herbicides. This is the second lawsuit since 2020 to call out EPA’s violation to both the Endangered Species Act (ESA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to authorize the use of over-the-top (OTT) dicamba-based herbicide products from Bayer and other petrochemical pesticide companies. This rejection of dicamba-based herbicides fuels advocates’ push for stronger regulatory actions by EPA for all petrochemical pesticides and their push for the more widespread adoption of organic practices that do not use these chemicals. The case was filed by Center for Food Safety (CFS), Center for Biological Diversity, National Family Farm Coalition, and Pesticide Action Network North America. Beyond Pesticides has covered the dicamba tragedy for years, including the EPA Office of the Inspector General’s critical 2021 report, EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision. The report identifies EPA’s abandonment of science and assault on agency integrity.

In addition to citing adverse impact on nontarget crops and the environment, the Court zeroes in on EPA’s failure to adequately manage resistance and the devasting impact this failure has on farmers’ livelihoods. Pointing to 2021 survey data, the Court, with citations, writes, “new information about dicamba resistance that showed weed resistance was confirmed during the 2020 growing season and [] was becoming much more widespread [] suggesting that weed resistance is not being effectively managed by current training materials that are conditions of registration[]. ‘If weed resistance to dicamba were to follow the same trajectory as glyphosate, the value of dicamba for OTT uses and for other registered dicamba uses would be effectively lost, severely jeopardizing the ability of soybean and cotton producers to control problematic broadleaf weeds.’ [] ‘As dicamba resistance spreads, the benefits of the DT-crop system declines.’”[]

The Court recognizes widespread exposure not controlled by EPA’s attempt to mitigate risk, stating, “’While states indicate incidents may occur due to drift, several reported landscape level injuries], which indicates dicamba volatility was widespread,’ with some states reporting dicamba sources more than a mile away from the injured crop, and reported incidents suggesting people are being impacted for multiple years.”[]

The Court explains that it is taking dramatic action to halt dicamba’s use because of systemic failures in the regulation of pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). After grower groups argued that earlier EPA application restrictions (after an earlier Court decision) were “too restrictive,” the Court writes, “The Court finds that the administrative record for the 2020 Decision and registrations and the 2021 Report reflect the EPA is unlikely to issue the same registrations on remand if it follows FIFRA procedures for notice and comment and hears from all stakeholders, especially those who have from the inception of OTT dicamba use been subjected to the risks of OTT dicamba offsite movement.” The Court continues, “While the EPA has been highly confident control measures would eliminate any such risk to only a minimal effect, the incident reports filed year after year complaining of offsite movement of OTT dicamba reflect otherwise.” While focused on the individual pesticide dicamba, in effect, the Court is recognizing that the pesticide registration process as it currently exists fails to protect public health, the environment, and the farm economy.

According to a statement by George Kimbrell, CFS legal director and counsel for this case: “This is a vital victory for farmers and the environment. Time and time again, the evidence has shown that dicamba cannot be used without causing massive and unprecedented harm to farms as well as endangering plants and pollinators. The Court today resoundingly re-affirmed what we have always maintained: the EPA’s and Monsanto’s claims of dicamba’s safety were irresponsible and unlawful.” One of the most significant impacts that the case highlights is the effects of applying dicamba on farmers who do not plant genetically engineered, dicamba-tolerant seeds. In 2018, according to USDA data analyzed by CFS, “As much as 1 in every 6 acres of ultra-sensitive soybeans were injured by dicamba drift in 2018 alone, over 15 million acres.” Between 2021 and 2023, EPA received nearly 3,500 incident reports from farmers who claimed that more than 1 million acres of non-dicamba-tolerant soybeans and other nontargeted crops (including sugar beets) were damaged by herbicidal drift, according to reporting by Ag Week. The court found that EPA’s “circular approach to assessing risk, hinging on its high confidence that control measures will all but eliminate offsite movement, [led] to its corresponding failure to assess costs from offsite movement.”

Before delving into the human and ecological health impacts of dicamba, it is important to unpack the history of this case and the legacy of court actions against Monsanto (now owned by Bayer). The modern saga on dicamba began back in 2016 when the EPA registered a new formulation of dicamba to control weeds in cotton and soybean crops that have been genetically engineered (GE) to tolerate the chemical. In 2020, the Ninth Circuit nullified “EPA’s 2018 conditional registration of three dicamba weed killer products for use on an estimated 60 million acres of DT (dicamba-tolerant through genetic modification/engineering) soybeans and cotton.” The previous court case found that EPA did not adequately consider adverse health risks from over-the-top dicamba in approving the conditional registration. As of 2023, EPA estimates over 65 million acres of farmland plant dicamba-tolerant soybeans and cotton; however, dicamba products themselves are estimated to be sprayed on about 27 million acres as a form of defense against potential herbicidal drift. The spraying of dicamba products has been projected to increase twentyfold since the EPA reauthorized the use of three dicamba products (one each from Bayer, BASF, and Syngenta) in 2020 despite the court decision at the time.  

Dicamba and other types of herbicides have proven to pose stark adverse health risks to farmworkers and ecosystems, based on years of extensive reporting by Beyond Pesticides. For example, there is a strong association between dicamba use and increased risk of developing various cancers, including liver and intrahepatic bile duct cancer, chronic lymphocytic leukemia, and acute myeloid leukemia. In the Gateway on Pesticide Hazards and Safe Pest Management entry for Dicamba, there is a slew of medical studies detailing adverse health and environmental effects, including neurotoxicity, kidney/liver damage, sensitization/irritation, birth/developmental defects, reproductive damage, and respiratory illnesses. Dicamba has also been proven to have adverse health impacts on wildlife habitats, including the spraying of approximately 1,328 pounds in the National Wildlife Refuge in 2016 alone, impacting bird populations and pollinator species in particular. Dicamba is a poster child of a failed regulatory system that creates ecosystem imbalances by attempting to correct them, considering that the herbicidal drift of this herbicide has proven to lead to antibiotic resistance after testing sublethal traces on bacteria.

There is a long legacy of industry capture of pesticide regulatory efforts predating these court rulings, but also occurring in tandem with these wins. For example, “As [the Ninth Circuit in 2020] was being announced, new formulations of dicamba and new herbicide-tolerant crops were being brought on to the market.” Also in 2020, Bayer submitted a petition to the Animal and Plant Health Inspection Services in the EPA to deregulate “multi-herbicide tolerant MON 87429 [corn]”, which is tolerant to herbicides including dicamba and glyphosate. A report by the Midwest Center for Investigative Reporting uncovered damning information that, “Monsanto released and marketed its dicamba products knowing that dicamba would cause widespread damage to soybean and cotton crops that weren’t resistant to dicamba. They used ‘protection from your neighbors’ [messaging] as a way to sell more of their products. In doing so, the companies ignored years of warnings from independent academics, specialty crop growers and their own employees.” Bayer’s awareness of the toxicity of their pesticide products is analogous to the oil and natural gas industry’s internal research and subsequent cover-up of the long-term impacts of fossil fuel production on global temperature increases, ecological stability, and public health via anthropogenic, atmospheric carbon dioxide emissions. This pattern of corporate capture of institutions designed to serve the public emphasizes Beyond Pesticides’ belief in strengthening regulatory oversight by arming the public and advocates with the tools, science, and resources to prevent agency acquiescence to industry.

Beyond Pesticides continues to provide resources and support for local communities looking to learn more about how to protect their families and loved ones from pesticide residue exposure. For more information and scientific research on the compounding health impacts of petrochemical pesticides, please see the Pesticide-Induced Disease Database. To get involved in advocating for a more robust regulatory regime, click on the following link or image featured left to access last week’s Action of the Week.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: The Center for Food Safety

(Beyond Pesticides, February 12, 2024) Public Comments Due February 23, 2024. As the U.S. Environmental Protection (EPA) takes public comments on its updated scientific integrity policy (until February 23, 2024), Beyond Pesticides issued an action and reminds the agency that when it fails to carry out its mission to protect health and the environment—by allowing use of pesticides that are known to be hazardous and not fairly and scientifically evaluated, it is responsible for a toxic tragedy that has debilitating and deadly consequences for people and the ecosystems critical to sustaining life. Key to the recommendations Beyond Pesticides is urging EPA to consider are the following: (i) incorporate independent and emerging science into its chemical reviews; (ii) Update protocol to keep pace with new science; (iii) address vulnerabilities of those at highest risk, including those with preexisting health conditions; (iv) consider safer alternatives in calculating unreasonable risk; (v) disclose uncertainties associated with agency science or data gaps, and (vi) establish criminal penalties for EPA staff integrity violations.

In the wake of intense criticism of the U.S. Environmental Protection Agency’s (EPA) scientific integrity, the agency has announced updates to its scientific integrity guidelines. As the agency acknowledges in its 2012 Scientific Integrity Policy: “EPA’s ability to protect human health and the environment depends upon the integrity of the science on which it relies. The EPA Scientific Integrity Policy provides both a vision and a roadmap for scientific integrity at the Agency. Issued in 2012, the Policy builds upon EPA’s significant earlier scientific integrity efforts and addresses four areas: Promotion of a culture of scientific integrity at EPA; Release of scientific information to the public; Peer review and the use of federal advisory committees; Professional development of government scientists.” 

>>Tell EPA to address critical standards of scientific integrity at the agency.

It is one thing to have a policy—it is another to implement it with integrity. The EPA’s Office of the Inspector General last year (2023), in its report on perfluorobutane sulfonic acid (a PFAS chemical), concluded that EPA’s 2021 PFBS Toxicity Assessment failed to “uphold the agency’s commitments to scientific integrity and information quality,” and that the agency’s actions “left the public vulnerable to potential negative impacts on human health.” At the time of the report—The EPA’s January 2021 PFBS Toxicity Assessment Did Not Uphold the Agency’s Commitments to Scientific Integrity and Information Quality—agency officials disagreed with all five recommendations of the inspector general. However, EPA did provide very general aspirational responses to the OIG’s report, which include the updating of its scientific integrity policy in this latest proposal open to public comment. 

Earlier in 2021, Public Employees for Environmental Responsibility (PEER) had filed complaints with EPA’s Office of the Inspector General (OIG) on behalf of four EPA whistleblower scientists, who said that, during the Trump administration, risk assessments for both new and existing chemicals were improperly changed by agency managers to eliminate or reduce risk calculations. At the time, Beyond Pesticides covered a report in The Intercept that examined the multiple aspects of undue industry influence on the regulation of pesticide chemicals. While the PEER complaints address regulation of toxic chemicals not classified as pesticides, the misconduct identified by OIG and The Intercept represents an agency-wide problem. Nevertheless, EPA considers its updated proposed policy an enhancement of existing processes in place, saying, “This policy replaces the Environmental Protection Agency’s (EPA) 2012 Scientific Integrity Policy and reaffirms and reestablishes the expectations and procedures needed to maintain scientific integrity at EPA. It also reaffirms the scope and role of a Scientific Integrity Official (SIO), a standing committee of Agency-wide deputy SIOs (DSIOs), and establishes the role of the Chief Scientist.” 

EPA traces its history on scientific integrity back to 1983 and the “Fishbowl Memo” issued by the first EPA Administrator William Ruckelshaus. Mr. Ruckelshaus, according to the agency, established a culture of integrity and openness for all employees by promising EPA would operate “in a fishbowl” and would “attempt to communicate with everyone from the environmentalists to those we regulate, and we will do so as openly as possible.” Then, in 1999, EPA developed Principles of Scientific Integrity in consultation with a group, the National Partnership Council, which it describes as “a partnership of Agency labor unions and management.” This document, EPA says, “set forth the Agency’s commitment to conducting science objectively, presenting results fairly and accurately, and avoiding conflicts of interest.” Then, in 2003, EPA issued a policy and procedures to address “fabrication, falsification, and plagiarism.” The following events included a 2009 Presidential Memorandum on Scientific Integrity, a 2010 Office of Science and Technology, followed by the agency’s first Scientific Integrity Policy in 2012 and the appointment of the first full-time scientific integrity official in 2013. The SIO is a senior career employee who is tasked with championing and promoting “scientific integrity throughout the Agency, and to oversee implementation and iterative improvement of scientific integrity policies and processes.”

[The current SIO, since 2013, is Francesca Frifo, PhD—[email protected]—with office hours on Wednesdays from 11:30 AM – 1:30 PM Eastern.]

>>Tell EPA to address critical standards of scientific integrity at the agency.

Then, nearly a decade after the establishment of the scientific integrity office, there was the issuance of the 2022 National Science and Technology Council Scientific Integrity Fast Track Action Committee report, Protecting the Integrity of Government Science (SI-FTAC Report) and the National Science and Technology Council 2023 Framework for Federal Scientific Integrity Policy and Practice. Most recently, EPA has adopted the official federal definition of scientific integrity from the National Science and Technology Council’s 2023 Framework for Federal Scientific Integrity Policy and Practice:  

Scientific integrity is the adherence to professional practices, ethical behavior, and the principles of honesty and objectivity when conducting, managing, using the results of, and communicating about science and scientific activities. Inclusivity, transparency, and protection from inappropriate influence are hallmarks of scientific integrity. 

Despite the extensive efforts of EPA, as outlined above, scientific fraud in support of regulatory decisions has plagued the Office of Pesticide Programs for decades. During the 1970’s and 1980’s, there was the Industrial Biotest and Craven Laboratories scandals that brought to public attention fraudulent laboratory animal test data that supported the registration and tolerances (acceptable residues), respectively, of pesticides. At best, the scandals showed that EPA had inadequate oversight and audit procedures of those who produced the scientific data it used for pesticide registration. At worst, it represented EPA turning a blind eye to a culture of corruption. Things blew up in 1984 when Congress held hearings on another corruption blow-up dubbed the “cut-and-paste” scandal, where EPA staff were found to use verbatim chemical company toxicology review analyses, pasting them on to EPA letterhead as if they were independently reviewed by Office of Pesticide Programs staff.  

But, it is the more recent disclosure that raises modern-day concerns about scientific integrity at EPA. At the 2018 Beyond Pesticides 36th National Pesticide Forum, Carey Gilliam, a veteran journalist, then-research director for U.S. Right to Know, and author of Whitewash: The Story of a Weed Killer, Cancer, and the Corruption of Science, told participants:  

As a result of . . . litigation [associated with health effects of glyphosate/Roundup], Monsanto is forced to turn over millions of pages of internal reports, documents, emails, memos, and different studies. When you look at those along with documents that I and my colleagues at U.S. Right to Know have obtained through the Freedom of Information Act from EPA, the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA), and various state universities, it’s a pretty incredible picture of collusion, deception, and deceit. 

The documents show all of these different things: ghost-written research papers that assert glyphosate’s safety for publication and regulatory review; alternative assessments provided for studies that indicate harm. So if a regulator is looking at a study and says, “Gosh, this looks like it causes cancer,” Monsanto will then give them the rationale for how to interpret the data in a different way. They have networks of European and U.S. scientists that push the safety message to lawmakers and regulators. They appear to be independent, so they appear to be more authoritative and authentic. But behind the scenes we see documents that show that Monsanto is helping them or telling them what to say, or assigning them a task. 

They provide the EPA with talking points to address. That one got me when I saw that: “Talking points. From Monsanto to the EPA.” 

The influence that Monsanto has had over regulators and the stifling of independent science is, according to Ms. Gilliam, quite astounding. It plays out in successful attempts to squelch or slow down reviews. Click here to watch Ms. Gilliam’s Forum presentation.

Tell EPA to address critical standards of scientific integrity at the agency.

Comment to EPA

Much of what EPA establishes to nurture scientific integrity and honesty of EPA staff is critical to creating a culture of true independent science, which is essential to public trust in the decisions of the agency.  

Independent science—EPA’s Office of Pesticide Programs does not adequately incorporate into its protocol the independent scientific literature that informs a more robust analytical review of potential adverse health and environmental effects. The integrity of its work products, including the registration of pesticides and registration review, requires the agency to closely track and incorporate into its evaluation emerging science in the independent peer reviewed literature. 

Updating protocol to keep pace with new science—In 2018, then-director of the National Institute for Environmental Health Sciences Linda Birnbaum, PhD coauthored In PLOS Biology a review article of seven peer-reviewed studies of federal toxics regulation and found that “existing US regulations have not kept pace with scientific advances showing that widely used chemicals cause serious health problems at levels previously assumed to be safe.” The most vulnerable population, our children, face the highest risks.”

Addressing vulnerabilities of those at highest risk—Integrity requires attention to those who are disproportionately affected because of cumulative exposure and all vulnerabilities. For human threats, this requires an assessment of exposure associated with air, land, water, food, employment, location of residence and schools, and preexisting illnesses. Similarly, the constellation of ecosystem effects associated with endocrine disruptors, for example, requires EPA to address its failure to evaluate the full effect of pesticide use and disposal and undermines the scientific integrity of the agency’s registration of pesticides. The same holds for all pesticide active ingredients, inert ingredients, contaminants, and metabolites, if final agency actions are to be viewed as having scientific integrity. The lack of attention to synergistic effects adds to the limitations for which the agency is not transparent. Without a robust scientific review process, the value of the agency’s regulations and pesticide registrations lack integrity.

Safer alternatives in calculating unreasonable risk—Decisions that implement the standard to protect against unreasonable adverse effects under FIFRA must consider the availability of alternatives that may present lower risk. A failure to evaluate alternative practices and products to the proposed or existing pesticide registration results in a decision that lacks scientific integrity.

Disclose uncertainties associated with agency science or data gaps—Under the principle of transparency, a failure to disclose scientific uncertainties to the public lacks integrity.

Criminal penalties needed—The failure of EPA staff to meet the scientific integrity standards as set by agency policy, in light of the harm that is caused to human health and the environment, rises to the status of a criminal act and should be enforced as such.

Thank you for your consideration of these comments.

See EPA announcement: EPA-HQ-ORD-2023-0240-0001—on Regulations gov.

(Beyond Pesticides, February 9, 2024) EPA is accepting public comments through today, Friday February 9, on its long-held policy of exempting “treated objects,” including seeds and paint, from pesticide registration. Although EPA does not ask the most important question—“Should pesticide-treated seeds and paint be exempt from the scrutiny given pesticide products?”—this comment period offers an opportunity to respond to EPA’s questions and express concern about hazards associated with chemical use and product ingredients. Despite exposure patterns associated with the use of pesticides in treated objects that are linked to environmental contamination and human poisoning, EPA is focused on labeling and not regulation. Instead of focusing on the exposure and harm associated with the object’s use—whether treated seeds poison pollinators, soil, and water or whether paint treated with fungicides poisons people exposed to the paint—EPA takes the position that unless the manufacturer makes a pesticidal claim, the object is not regulated as a pesticide for its pesticidal effects. 

Beyond Pesticides states: At the very least, if EPA deems the hazards associated with the use of the pesticide in the treated article acceptable, then the agency should disclose the chemical used in the treatment (of the seed or the paint) and require labeling on the treated articles specifying the potential harm associated with exposure to the specific chemical-related hazards—including cancer, neurological and immunological effects, reproductive hazards, respiratory harm, endocrine disrupting effects, as well as a warning to those with any of these preexisting conditions or in treatment for these illnesses. EPA must consider gaseous inhalation exposure, exposure to bystanders, and disposal of residues from cleaning paint containers and application equipment.

>>Tell EPA not to exempt pesticide-treated seeds and paint from thorough examination.    

Coating seeds with pesticides is one of the most commonly used application methods—135.3 to 156.64 million acres of corn, soybean, and cotton acres were planted with insecticide and fungicide seed treatments in 2023, and approximately 46-57% of planted wheat seed was treated from 2012-2014. Seed treatments are used routinely and preventively—to protect the seed from rotting or, increasingly, as a systemic poison to protect the plant from insects. Routine pesticide applications promote resistance to the pesticide because the pest is constantly exposed, providing a high selection pressure. Preventive pesticide treatments are contrary to even the loosest definition of integrated pest management (IPM) (see Beyond Pesticides and EPA) because the pesticide is applied without knowing whether the pest is present or poses a threat to the crop. Nominally, EPA supports IPM. 

Although EPA points to the “comprehensive nature of assessments of pesticides that are intended for use in treating seeds which includes assessment of the impact with use of the treated seed,” its allowance of these poisoned seeds has wide-ranging impacts on all organisms and the entire ecosphere. Corn and soybean seed treatments represent the largest uses of neonicotinoids (neonics) in the U.S.—on somewhere between 34% and 50+% of the soybean crop and for nearly all field corn. This contrasts dramatically with metrics from the decade prior to the introduction of neonics to the marketplace, when a mere 5% of soybean acreage was treated with insecticides. Neonics are systemic pesticides that move through a plant’s vascular system and are expressed in pollen, nectar, and guttation droplets (drops of sap exuded on the tips or edges of leaves of some vascular plants). They can also persist in the environment—in soil and water—for extended periods and harm the aquatic food web (see here and here).  

Neonics have come under intensive scrutiny in the past decade because of their persistence in the soil, ability to leach into the environment, high water solubility, and potential negative health implications for non-target organisms such as pollinators—especially bees of all sorts—as well as butterflies, bats, and birds. Indeed, a recent Science publication from researchers in Canada demonstrates that “low-level neonic exposure may delay the migrations of songbirds and harm their chances of mating.” Beyond Pesticides’ video, Seeds That Poison, offers a succinct primer on the dangers of neonic-coated seeds. 

The actual utility of pesticides to achieve their purported goals is an under-recognized failing of the regulatory review of pesticide compounds for use. A study by Spyridon Mourtzinis et al. published in Scientific Reports exposes the faulty assumptions underlying the use of neonics—the most widely used category of insecticides worldwide. It examined a variety of factors in determining neonic efficacy, including weather patterns, soil pH, precipitation, pest abundance and timing, and yield for three experimental groups: soybeans treated with fungicides only, those treated with fungicides and neonicotinoids, and an untreated control group. Despite broad use, the practice of using fungicide-plus neonicotinoid seed treatment appears to have negligible benefit for most soybean producers. The researchers write, “These results demonstrate that the current widespread prophylactic use of NST [neonicotinoid seed treatment] in the key soybean-producing areas of the U.S. should be re-evaluated by producers and regulators alike.” 

>>Tell EPA not to exempt pesticide-treated seeds and paint from thorough examination.  

This research finding repeats some of the findings of a 2014 EPA report, which said that use of treated soybean seed provides little-to-no overall benefit in controlling insects or improving yield or quality in soybean production. It notes the lack of observed pest management benefits of planting treated seeds and the disconnect between perceived crop vulnerability and neonicotinoid utility: “throughout most soybean-producing regions of the U.S., the period of pest protection provided by [use of neonic-treated seeds] does not align with [the presence of] economically significant pest populations. Absent economic infestations of pests, there is no opportunity for this plant protection strategy to provide benefit to most producers.” 

Citing other recent studies that have reported “weak relationships between NST use and effectiveness in preserving crop yield,” the authors continue: “A recent multi-state study of management tactics for the key pest in the [Midwest] region, the soybean aphid . . . demonstrated that crop yield benefits and overall economic returns were marginally affected by NST.” 

Thus, if EPA is to truly assess the pesticides used in treating seeds, it must take into account not only biodiversity collapse, including the insect apocalypse, but also the lack of benefits provided by the pesticides. 

Furthermore, the failure of EPA to suggest a means of disposing of spilled and excess treated seed is a fatal flaw. Previously, EPA included additional labeling instructions for management of spilled and excess treated seed in Proposed Interim Decisions (PIDs) and Interim Decisions (IDs) of several chemicals. This labeling included instructions on the collection and burial of spilled treated seed, incorporation of treated seed into soil, limiting the broadcast planting of treated seed, and proper disposal of excess treated seed. Although EPA previously approved labels for oil seed crops that allowed for the use of excess treated seeds in ethanol production, it now believes these measures may not be sufficient to protect against pesticide buildup after ethanol production and its labeling instructions include language to prohibit the use of excess treated seeds for ethanol production. However, given the persistence of neonics and other pesticides in the soil, the incorporation of systemic pesticides into plants, and the subsequent impacts on primary and secondary consumers of those plants, as well as the known propensity to contaminate waterways, any disposal in the soil poses unreasonable adverse effects. 

In addition, this request for comments includes pesticide-treated paints. EPA says that the pesticides in paints are exempt from regulation as pesticides because they are present to protect the paint, and not as an ingredient to protect the painted surface. Regardless of the intention, the presence of the pesticide can be hazardous to the painter through inhalation of fumes (gas) or particulates (in the case of spray application). Others in the vicinity may also be exposed to off-gassing. Clean-up or reuse of paint containers and application equipment may pose an environmental hazard. All of these factors—as well as the need for the pesticide additive—must be considered in the decision of whether to allow the addition of the toxic material to the paint.

>>Tell EPA not to exempt pesticide-treated seeds and paint from thorough examination.  

[Comments are due through Regulations.gov by Friday, February 9, 2024. Document ID: EPA-HQ-OPP-2023-0420-0001]

Some Suggested Comments (Feel free to add your own.):

I am commenting as a citizen concerned about the impacts of pesticide-treated seeds and paints on health and the environment. I will address several of the questions posed by EPA.  

1. EPA asks whether the treated article exemption should be amended so that treated seed manufacturers would be subject to FIFRA section 7 registration and reporting requirements.

Treated seeds should not be exempt from registration requirements. They should not be used unless it is shown that there are no unreasonable adverse effects associated with their use. If EPA is to truly assess the pesticides used in treating seeds, it must consider not only biodiversity collapse, including the insect apocalypse, but also the lack of benefits provided by the pesticides, as shown by EPA and independent research.  

2. EPA asks about available data on the replacement or reduction of other types of pesticides with increasing use of treated seed, saying it would normally address replacement and use reduction on an individual chemical basis, taking into account alternative control strategies to seed treatment.

While many dangers posed by seed treatments are chemical-specific, they are accentuated by the sheer quantity of exposure to soil organisms, herbivores, and secondary consumers, as well as to the aquatic environment. Seed treatment also poses unique risks due to the routine and preventive nature of the application—such as increasing the threat of resistance and violating IPM principles. The near-universal treatment of certain types of seeds makes it almost impossible for organic producers to source untreated conventional seeds. Because EPA does not consider USDA-certified organic production practices and the efficacy of untreated seeds as alternatives, its evaluation of adverse effects associated is inadequate.   

3. EPA asks whether additional instructions for spilled seed are needed.

Disposal is a fatal flaw. Given the persistence of neonics and other pesticides in the soil, the incorporation of systemic pesticides into plants, and the subsequent impacts on primary and secondary consumers of those plants, as well as the known propensity to contaminate waterways, any instructions that permit disposal in soil, landfills, or by incineration allow unreasonable adverse effects.  

4. EPA requests comment on the severity of inhalation and dermal hazards of the chemicals in treated paint products and how to increase the clarity of the labeling and safe use for the end user and the environment. 

Exposure to registered pesticides in treated articles, whether in paint, hairbrushes, cutting boards, fabrics, or underwear, is not safe, but represents a risk like any other pesticide use. If EPA deems the hazards associated with the use of the pesticide in the treated article acceptable, then the agency must require labeling on the treated articles specifying the potential harm associated with exposure to the specific chemical-related hazards, including cancer, neurological and immunological effects, reproductive hazards, respiratory harm, endocrine disrupting effects, as well as a warning to those with any of these preexisting conditions or in treatment for these illnesses. EPA must consider gaseous inhalation exposure, exposure to bystanders, and disposal of residues from cleaning paint containers and application equipment.  

5. EPA asks whether use of FIFRA section 3(a) is necessary or appropriate to prevent unreasonable adverse effects on human health and the environment

Both because of the problems relating to enforceability and the need to determine that pesticide-treated seeds and paints meet the statutory requirement of no unreasonable adverse effects on humans and the environment, these products should not be exempt from the requirement of registration or registration review.

Thank you for this opportunity to comment. 

(Beyond Pesticides, February 8, 2024) A study published in Environmental Research finds an association between adverse neurodevelopment (brain function and development) among infants and exposure to the herbicide glyphosate during pregnancy (gestational). Moreover, neurodevelopment becomes more pronounced at 24 months or two years.

The increasing prevalence of neurodevelopmental disorders (NDDs) in the United States has raised concerns about the impact of toxic exposures on child development. Given the disproportionate exposure burden in the U.S., children from marginalized groups and low-income families are more likely to face a variety of harmful threats that can negatively affect childhood development. These disparities are linked to neurodevelopmental disorders. NDDs are defined as conditions related to the functioning of the nervous system and the brain, including attention-deficit/hyperactivity disorder (ADHD), autism, learning difficulties, intellectual disability (cognitive impairment), conduct disorders, cerebral palsy, and challenges related to vision and hearing. Therefore, the study notes, “Given glyphosate’s wide usage, further investigation into the impact of gestational glyphosate exposure on neurodevelopment is warranted.”

The study includes mother-child pairs in a Puerto Rican birth cohort called PROTECT-CRECE, which measures urinary glyphosate and aminomethylphosphonic acid (AMPA; a metabolite [breakdown product]) of glyphosate) levels from mother and child for analysis. The study collected samples from the mother up to three times during pregnancy. After birth, the researchers examined child neurodevelopment at six, 12, and 24 months using the Battelle Developmental Inventory, 2nd edition Spanish (BDI-2). The BDI-2 assessment scored children on adaptive, personal-social, communication, motor, and cognitive domains.

The results find a negative association between prenatal AMPA concentrations from the mother during pregnancy and child communication at 12 months. At 24 months, researchers find that AMPA is negatively associated with 4 BDI-2 scores, including adaptive, personal-social, communication, and cognitive skills. Additionally, glyphosate concentrations displayed similar trends in the negative association of BDI-2 scores.

Almost five decades of extensive glyphosate-based herbicide use (e.g., Roundup) has put human, animal, and environmental health at risk. The chemical’s ubiquity threatens 93 percent of all U.S. endangered species, resulting in biodiversity loss and ecosystem disruption (e.g., soil erosion and loss of services). Exposure to GBHs has implications for specific alterations in microbial gut composition and trophic cascades. Moreover, four out of five U.S. individuals over six years have detectable levels of glyphosate in their bodies. Similar to this paper, past studies find a strong association between glyphosate exposure and the development of various health anomalies, including cancer, Parkinson’s disease, and autism. Although the U.S. Environmental Protection Agency (EPA) classifies glyphosate herbicides as “not likely to be carcinogenic to humans,” stark evidence demonstrates links to various cancers, including non-Hodgkin lymphoma. With the ever-present environmental hazards, advocates argue that regulators act quickly and embrace a precautionary approach. Because of the disproportionate risk in people of color communities, the contamination and poisoning associated with glyphosate is an environmental justice issue. Not only do health officials warn that continuous use of glyphosate will perpetuate adverse health effects, but that use also highlights recent concerns over antibiotic resistance. Both human gut and environmental contamination can promote antibiotic resistance, triggering longer-lasting infections, higher medical expenses, and the inability to treat life-threatening illnesses.

This study adds to a multitude of research indicating the neurotoxic impacts of glyphosate-based herbicide exposure, especially regarding impairment of cognition and social behavioral skills among children. Despite many studies finding other adverse health impacts among children from glyphosate exposure, the study highlights the need for more research on the developmental toxicity of AMPA due to the lack of neurotoxicological investigation. However, a 2022 study found AMPA induces DNA damage through oxidative stress among subpopulations of primary school children in Cyprus. Moreover, studies highlight the susceptibility of children to glyphosate, with their higher propensity for absorption and retention, which is especially concerning. The possibility that even regulated levels of exposure may harbor unacknowledged dangers necessitates a more cautious approach to such chemicals.

Glyphosate-based herbicides’ impact on reproductive health is an increasingly common phenomenon, and this study adds to the growing scientific evidence that glyphosate is a reproductive toxicant. A recent University of Michigan study already demonstrates high levels of glyphosate in urine during the third trimester of pregnancy have significant associations with preterm birth outcomes. Thus, EPA’s classification perpetuates adverse impacts, especially among vulnerable individuals such as pregnant women and infants. Recent research detects over 100 chemicals, including glyphosate, in pregnant women’s bodies, with 89% of compounds of unknown origin or lacking adequate data. Many of these environmental pollutants (e.g., heavy metals, polychlorinated biphenyl, and pesticides) are chemicals that can move from the mother to the developing fetus at higher exposure rates. Hence, prenatal exposure to these chemicals may increase the prevalence of birth-related health consequences like natal abnormalities and learning/developmental disabilities. In 2017, Beyond Pesticides reported that prior research found detectable levels of glyphosate in 63 of 69 expectant mothers. Women with higher chemical levels have significantly shorter pregnancies and babies with lower birth weights. While studies are now finding associations, there has been evidence of glyphosate’s impact on birth outcomes for decades.

Beyond Pesticides challenges the registration of chemicals like glyphosate in court due to their impacts on soil, air, water, and our health. While legal battles press on, the agricultural system should eliminate the use of toxic synthetic herbicides to avoid the myriad of problems they cause. Chemical exposures have real, tangible impacts not only on individuals but on society as a whole. Pesticides impose what advocates characterize as unnecessary hazards on children’s health, given the availability of alternative practices and products. Early life exposures during “critical windows of vulnerability” can predict the likelihood or otherwise increase the chances of an individual encountering a range of pernicious diseases. Environmental disease in children costs an estimated $76.8 billion annually. Exposures that harm learning and development also impact future economic growth in the form of lost brain power, racking up a debt to society in the hundreds of billions of dollars. Therefore, it is essential to mitigate preventable exposure to disease-inducing pesticides. For more information about pesticides’ effects on human and animal health, see Beyond Pesticides’ Pesticide-Induced Diseases Database, including pages on immune system disorders (e.g., hepatitis [liver condition]), birth abnormalities, and brain and nervous system disorders.

One way to reduce human and environmental contamination from pesticides is to buy, grow, and support organic. Numerous studies show that switching to an organic diet can rapidly and drastically reduce the levels of synthetic pesticides in one’s body. A 2020 study found a one-week switch to an organic diet reduced an individual’s glyphosate body burden by 70%. Furthermore, given the wide availability of non-pesticidal alternative strategies, these methods can promote a safe and healthy environment, especially among chemically vulnerable individuals or those with health conditions. For more information on why organic is the right choice for consumers and the farmworkers that grow our food, see the Beyond Pesticides webpage, Health Benefits of Organic Agriculture.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Environmental Research

(Beyond Pesticides, February 7, 2024) Sun + Earth Certified (SEC), a West Coast third-party regenerative organic certifier of cannabis products, approved the first certification for an East Coast farm in Brattleboro, Vermont – Rebel Grown. The expansion of independent certifications amidst the ongoing legalization of recreational and medicinal marijuana usage raises questions on the regulation of toxic petrochemical pesticides found in a range of cannabis products.

SEC does establish, in its standards, the use of “biopesticides…[o]nly if the product brand name is approved for use in certified organic farming.” Additionally, the label goes beyond the stringency of the National Organic Program in its policy on potassium bicarbonate as an approved input. For example, SEC standards dictate that this input should be, “[f]or pest control as a last resort only… [and] only if the product brand name is approved for use in certified organic farming.” Rebel Grown– the new farm that acquired the SEC label – owner reported to Brattleboro Reformer, “Cannabis grown regeneratively, under the sun and in the soil, without toxic chemicals, is not only high quality but also the best for the earth.”

Before delving into the weeds, there is important legal context on current regulations regarding marijuana in the United States at the national and state levels. Marijuana use is legal for recreational use in 24 states, two territories, and the District of Columbia, and medicinal use in 38 states, three territories, and the District of Columbia as of 2023, according to the National Conference of State Legislatures. However, marijuana products cannot employ the USDA organic label even if growers and distributors abide by or exceed the National Organic Program standards because of the federal government’s assignment of cannabis as a Schedule I narcotic. As laid out in Beyond Pesticides’ previous reporting, there has been some state-level action to address this regulatory gap: “[A]ny state permitting of a pesticide not evaluated for its potential health impacts concerns health advocates. A few states (Connecticut, Maine, Minnesota, New Hampshire, and Massachusetts) and the District of Columbia have adopted regulations that focus on less-toxic approaches to cannabis cultivation, with some focus on ensuring growing practices that avoid or prohibit the use of pesticides. Critically, the federal ‘limbo’ provides an important opportunity for states to incentivize this developing industry to anchor its production practices — and perhaps its identity — in protocols that do not rely on toxic pesticides.”

A series of 2018 laws enacted in California mandated the testing of pesticide residue on cannabis products, marking a change in regulatory posture at the state-level. In addition, the California Department of Food and Agriculture (CDFA) and California Department of Public Health (CDPH) established the OCal Registration Program for Manufactured Cannabis Products in 2021 as a comparable-to-organic standard with the goal to support consumer trust in marijuana products grown and developed in the state. One of the lingering challenges Beyond Pesticides acknowledges regarding this type of program is, “the inhalation route of exposure, particularly as it concerns medical patients, requires an additional level of scrutiny, and, according to advocates, California state consumers would be well-served by the establishment of a state-level OCal Standards Board to further review whether certain pesticides and other processing materials should be restricted in the context of cannabis consumption.” A standards board was not established during the rule-making period for this program. Jay Feldman, Executive Director of Beyond Pesticides, speaks to the importance of filling gaps in data collection for aggregated risk assessments relating to pesticide residue exposure for inhalable cannabis products in Environmental Health Perspectives: “If [the California Department of Pesticide Regulation] does not have this kind of data, which is extremely expensive to produce and to evaluate, then it should use its statutory authority to embrace a precautionary approach. They are establishing a false sense of security regarding the allowed residues, given that they have not looked at the aggregate cumulative risk of dietary and nondietary exposure in combination with cannabis residue.”

Beyond Pesticides has covered the hazards associated with pesticide-intensive cannabis production in previous Daily News entries and a 2014 Pesticides and You journal entry: Pesticide Use in Marijuana Production: Safety Issues and Sustainable Options. According to guidelines by the U.S. Environmental Protection Agency (EPA), while the agency has not registered any pesticides for cannabis production, cannabis falls under “unspecified food crops, home gardens, and herbs,” despite the lack of an exposure assessment that would otherwise be conducted in setting tolerances (allowable residues) for pesticides used in crop production. In other words, “EPA-permitted pesticide labels do not contain allowances for pesticide use in cannabis production.” The Pesticides and You piece goes on to explain that: “The label on a pesticide product delineates the legal uses, application rates, and other restrictions, such as protection of agricultural workers and others who handle pesticides, limitations regarding threatened and endangered species (in coordination with the Endangered Species Act), and other special use and disposal requirements. Because EPA is barred from registering a pesticide for use on cannabis or setting (or exempting from) tolerance limits for pesticide residues on cannabis crops, and given the plant’s classification as a narcotic, the evaluation of pesticide use, assessment of exposure hazards, and the setting of pesticide use restrictions by EPA is also prohibited at the federal level.”

Numerous scientific reports indicate the market-wide exposure consumers face from a variety of cannabis and cannabis-related products. For example, studies have found that over 90 percent of rolling paper products contain heavy metals, such as lead and at least 16 percent contain pesticides such as chlorpyrifos. In other words, there is still a risk of pesticide and heavy metal exposure even if the cannabis itself follows regenerative organic practices. Advocates have also raised concerns over the growth of black-market marijuana vaping cartridges leading to at least 23 reported deaths and 1,100 illnesses as of 2019. In a study commissioned by NBC News, all 18 black market cartridges tested by the commissioned laboratory contained traces of pesticides, including myclobutanil, fipronil, piperonyl butoxide, permethrin, malathion, and others for lung damage. The same study found that, “no heavy metals, pesticides, [and] residual solvents” were found in cartridges sold through medical dispensaries. However, just last year Washington Liquor and Cannabis Board issued administrative holds on 18 licenses to legal marijuana businesses due to pesticide contamination.

To learn more about the impacts of pesticide residues in marijuana products to your health, see our report: Pushing for Organic Cannabis as Industry Grows. If you are concerned that you or a loved one was exposed to pesticides, see Pesticide Emergencies. To learn more information about the impacts of herbicide, insecticide, rodenticide, or fungicide exposure to your health, see the attached links. For additional information on crop production, see the Beyond Pesticides organic agriculture webpage. And to get involved in ensuring that organic standards comply with the principles, values, and letter of the Organic Foods Production Act, see Keeping Organic Strong (KOS). Through KOS, Beyond Pesticides makes it easy for the public to comment on critical issues before the National Organic Standards Board and the National Organic Program/U.S. Department of Agriculture.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Brattleboro Reformer

(Beyond Pesticides, February  6, 2024) A study published in Occupational and Environmental Medicine finds that pesticide exposure, especially during puberty, can play a role in ovarian cancer development among female farmers. Although there are many studies that evaluate the risk for cancers among farmers, very few pieces of literature cover the risk of ovarian cancer from pesticide exposure. Additionally, this study notes suggests the role of hormones in ovarian cancer prognosis and development, highlighting an association with endocrine disruption. Exposure to past and current-use endocrine-disrupting chemicals (EDCs), like pesticides, has a long history of severe adverse human health effects. Endocrine disruptors are xenobiotics (i.e., chemical substances like toxic pesticides foreign to an organism or ecosystem) present in nearly all organisms and ecosystems. The World Health Organization (WHO), European Union (EU), and endocrine disruptor expert (deceased) Theo Colborn, Ph.D., classify over 55 to 177 chemical compounds as endocrine disruptors, including various household products like detergents, disinfectants, plastics, and pesticides. Endocrine disruption can lead to several health problems, including hormone-related cancer development (e.g., thyroid, breast, ovarian, prostate, testicular), reproductive dysfunction, and diabetes/obesity that can span generations. Therefore, studies related to pesticides and endocrine disruption help scientists understand the underlying mechanisms that indirectly or directly cause cancer, among other health issues.

The study evaluates a group of 59,391 female farmers with lifelong exposure to pesticides through agriculture and reproductive health. The participants are from an AGRIculture and CANcer (AGRICAN) cohort, a large prospective cohort of subjects in agriculture with links to cancer among active and retired males and females, farm owners and workers, living in areas with a population-based cancer registry. The study investigates the role that hormonal factors (e.g., endocrine disruption) from pesticide exposure plays in reproductive health issues, including ovarian cancer, during specifically sensitive exposure windows (i.e., children, puberty, menopause). The results find 262 incidences of ovarian cancer over a 10-to-12-year period. Women in agriculture working with pigs have the highest risk of ovarian cancer, followed by women growing fruit and women applying potato seed treatments. Exposure during puberty does have a positive association with ovarian cancer risk. Although the risk of ovarian cancer is reduced among women born on farms growing grain cereal or breeding pigs, the risk of other cancer and health issues remains. 

The connection between pesticides and associated cancer risks is not a new finding. Many pesticides are “known or probable” carcinogens (cancer-causing agents), and widespread uses only amplify chemical hazards, adversely affecting human health. Several studies link pesticide use and residue to various cancers, from the more prevalent breast cancer to the rare kidney cancer, nephroblastoma (Wilms’ tumor). Sixty-six percent of all cancers have links to environmental factors, especially in occupations of high chemical use. At least 45 different cancers have associations with work-related chemical exposure. Although the link between agricultural practices and pesticide-related illnesses is stark, over 63 percent of commonly used lawn pesticides and 70 percent of commonly used school pesticides have links to cancer. U.S. National Institutes of Health’s National Cancer Institute also finds many cancer-causing substances are endocrine disruptors. The entire endocrine system directly affects traditional endocrine glands and their hormones and receptors (i.e., estrogens, anti-androgens, thyroid hormones), greatly influencing hormone cancer incidents among humans (e.g., breast, prostate, and thyroid cancers). Several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with hormone-related cancer risk. There are grave concerns over exposure to endocrine (hormone) disrupting chemicals and pollutants that produce adverse health effects. Over 296 chemicals in consumer products can increase breast cancer risk through endocrine disruption, so it is essential to understand how chemical exposure impacts chronic disease occurrence. 

This study is one of the first to comprehensively assess the association between specific agricultural exposures among female farmers and ovarian cancer. Adding data on agricultural exposure, including duration and intensity of exposure, adds a new perspective on how these chemicals impact female farmers’ health. The study also points to hormonal factors (i.e., endocrine disruption) increasing ovarian cancer risk.  The connection between cancers and EDCs is historically established by the International Agency for Research on Cancer (IARC) and the U.S. National Toxicology Program (NTP), classifies many EDCs as possible carcinogens based on epidemiological studies. Despite women in agriculture using fewer pesticides than men, the risk of pesticide exposure remains significant enough to call for further investigation of how these chemical exposures increase the risk of all health issues.

There is a lack of understanding of the etiology of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiological data. Exposure to pesticides can increase the risk of developing chronic illnesses that may be rare and disproportionately impact various populations. Cancer is one of the leading causes of death worldwide, with over eight million people succumbing to the disease every year. Notably,  IARC predicts an increase in new cancer cases from 19.3 million to 30.2 million per year by 2040. Therefore, studies related to pesticides and cancer will aid in understanding the underlying mechanisms that cause the disease.

Understanding the health implications of pesticide use and exposure for humans is essential, particularly when pesticides increase chronic disease risk. Beyond Pesticides tracks the most recent news and studies on pesticides and related topics through the Daily News Blog and Pesticide-Induced Diseases Database (PIDD). For more information on the adverse effects of pesticides on human health, see PIDD pages on cancer (including ovarian cancer), endocrine disruption, and other diseases.

Moreover, proper prevention practices, like buying, growing, and supporting organics, can eliminate exposure to toxic pesticides. Organic agriculture has many health and environmental benefits, as it curtails the need for chemical-intensive agricultural practices. Regenerative organic agriculture nurtures soil health through organic carbon sequestration, preventing pests and generating a higher return than chemical-intensive agriculture. For more information on why organic is the right choice, see the Beyond Pesticides webpage, Health Benefits of Organic Agriculture. 

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Occupational and Environmental Medicine

(Beyond Pesticides, February 5, 2024) Public Comment Period Ends February 26, 2024. The U.S. Environmental Protection Agency (EPA) never completed protocol for testing pesticides that disrupt the fundamental functioning of organisms, including humans, causing a range of chronic adverse health effects that defy the common misconception that dose makes the poison (“a little bit won’t hurt you”)—when, in fact, minuscule doses (exposure) wreak havoc with biological systems. After a nearly two decade defiance of a federal mandate to institute pesticide registration requirements for endocrine disruptors, EPA has now opened a public comment period ending February 26, 2024 and advocates are criticizing the agency’s proposed evaluation as too narrow.

A detailed examination of EPA’s proposal can be found in draft comments by Beyond Pesticides. 

Endocrine disruption as a phenomenon affecting humans and other species has been critically reviewed by many authors. Endocrine disruptors are chemicals that can, even at extremely low exposure levels, disrupt normal hormonal (endocrine) function. Such endocrine disrupting compounds (EDC) include many pesticides, exposures to which have been linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. EPA and its Endocrine Disruptor Screening Program (EDSP) began then virtually stopped its review and regulation of endocrine disrupting pesticides, despite a mandate in the 1996 Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA), as well as the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Safe Drinking Water Act (SDWA), to develop a screening program within two years and then begin regulating.

>>Tell EPA that it must complete comprehensive data analysis concerning endocrine disruption and not register pesticides without it.

“Because of its limited scope, the EPA’s proposed framework for review of endocrine disrupting properties of pesticides is an abrogation of its responsibilities,” said Beyond Pesticides. The limitations in EPA’s proposal cited, despite Congressional intent and statutory mandates, include: (i) applying EDSP to humans only; (ii) focusing on certain pesticide active ingredients only, and; (iii) restricting the types of data used to assess endocrine disruption (ED). The proposal also reverses advice of EPA’s Endocrine Disruptor Screening and Testing Advisory Committee (EDSTAC) and the agency’s original EDSP implementation policy and science decisions.

Under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. Moreover, if the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until it has sufficient data to demonstrate that the pesticide’s registration is in compliance with the statutory standard, which is no “unreasonable adverse risk” of endocrine disruption.

According to Beyond Pesticides, EPA cannot develop a strategy for evaluating pesticides without understanding the history and status of endocrine disruption research, which are summarized in Beyond Pesticides’ draft comments. Evidence that synthetic chemicals can mimic or otherwise interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it soon became apparent that the homeostatic (stable) function of the endocrine system—which regulates and balances physiological functions—can be disrupted at many sites and hormone systems.

Endocrine pathways are largely conserved (identical or similar) across species and, thus, are not species—or taxa—specific. It is well known that thyroid endocrinology in particular is well conserved across vertebrate taxa. This includes aspects of thyroid hormone synthesis, metabolism, and mechanisms of action. Thyroid hormones are derived from the thyroid gland through regulation of the hypothalamic-pituitary-thyroid (HPT) axis, which is controlled through a complex mechanism of positive and negative feedback regulation. Multiple pathways contribute to the synthesis of thyroid-releasing hormone, including thyroid hormone signaling through feedback mechanisms; leptin and melanocortin signaling; body temperature regulation; and cardiovascular physiology. Each pathway directly targets thyroid-releasing hormone neurons. Based on the similarities sensitivity and requirements of endocrine pathways across vertebrate species, it is well understood that the ecological assays (the frog assay in particular) are often more sensitive and equally relevant to mammalian assays in informing risk assessors of whether a chemical can perturb and cause adverse endocrine outcomes in the human population and vice versa.

FQPA essentially amends FIFRA to ensure potential endocrine disrupting effects are considered in agency risk assessments to fulfill the FIFRA mandate that a pesticide registration will not cause unreasonable adverse effects. This applies to humans and wildlife and to all pesticide chemicals as defined in FIFRA, including “all active and pesticide inert ingredients of such pesticide” (21 U.S.C. 231(q)(1)). SDWA adds drinking water contaminants as well.

In summary, the agency cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements enumerated in FIFRA, FQPA, and SDWA. EPA should make use of all available scientifically relevant endocrine disruption research findings and also be wary of deviating from established international efforts for screening/testing endocrine disruptors that incorporate human and wildlife relevant studies.

Recognizing that mammalian data inform potential endocrine disruption in other vertebrate taxa (avian, amphibian, fish) and vice versa, the agency should not decouple the mammalian from other vertebrate assays in EDSP screening.  There are more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development (OECD) Conceptual Framework for screening/testing endocrine disrupting effects, and there are additional assays being developed for consideration as well. So, the agency should not limit the range or types of data to be used, but, as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” While currently required data may meet the needs of human risk assessment, it is inadequate to evaluate endocrine effects on wildlife species. It should also be understood that under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk per the mandate in FIFRA. Further, it is not the agency but pesticide registrants (manufacturers) that have the burden to demonstrate with adequate data that their products will not pose unreasonable adverse effects, including the inherently presumed endocrine disrupting effects.

Submit comments to Regulations.gov before February 26, 2024.
[Document ID # EPA-HQ-OPP-2023-0474-0005]

Due to updates to the Regulations website, we are now able to offer a click-and-submit form to the Regulations docket! Please fill out the form linked to submit!

Suggested comments to EPA:
EPA’s proposed endocrine disruptor strategy (EDSP) abrogates its responsibilities under the Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and Safe Drinking Water Act (SDWA). Limiting the scope of the EDSP to humans, certain pesticide active ingredients only, and limiting the types of data to assess endocrine disruption (ED) effects is contrary to the Congressional intent and requirements in these statutes. It is also a reversal of the Endocrine Disruptor Screening and Testing Advisory Committee advice and EPA’s original EDSP implementation policy and science decisions.

EPA’s strategy for evaluating pesticides requires understanding the history and status of endocrine disruption research. Evidence that synthetic chemicals can interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it was soon apparent that the homeostatic function of the endocrine system can be disrupted at many sites and hormone systems.

Many authors have documented that endocrine-disrupting chemicals (EDCs) may be pervasive in contaminating the ecosphere. A pandemic of endocrine-related disorders—attention deficit and hyperactivity disorder (ADHD), autism, diabetes, obesity, childhood cancers, testicular cancer in young men, infertility, male dysgenesis syndrome, hypospadias, low sperm count, loss of semen volume and sperm quality, and increased risk of testicular and prostate cancer—may be related to EDCs.

Endocrine pathways are largely conserved across species and thus are not species—or taxa—specific. Therefore, it is well understood that the ecological assays (the frog assay in particular) are often more sensitive and equally relevant to mammalian assays in determining whether a chemical can perturb and cause adverse endocrine outcomes in the human population and vice versa.

In summary, EPA cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements of FIFRA, FQPA, and SDWA. EPA must use all available scientifically relevant endocrine disruption research findings and avoid deviating from established international efforts that incorporate human and wildlife studies.

Recognizing that mammalian data inform potential endocrine disruption in other vertebrates (avian, amphibian, fish) and vice versa, the agency should not decouple the mammalian from other vertebrate assays in EDSP screening. With more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development Conceptual Framework for screening/testing endocrine disrupting effects and additional assays in development, EPA must not limit the range or types of data to be used, but as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” Currently required data may meet the needs of human risk assessment but is inadequate to evaluate endocrine effects on wildlife species.

FQPA amends FIFRA to ensure potential endocrine disrupting effects are considered in risk assessments to fulfill the FIFRA mandate that pesticide use will not cause unreasonable adverse effects. This applies to humans and wildlife and to all pesticide chemicals as defined in FIFRA, including all active and inert ingredients. Under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If EPA lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk.

Thank you.

(Beyond Pesticides, February 2, 2024) Last March, the European Union (EU) Parliament passed a measure to prevent greenwashing in the EU. As public concern about both human and ecosystem health rises, so does greenwashing—corporate efforts to mislead the public with label and marketing language for products and services that is outright dishonest or contains misrepresentations. And so, there has been an explosion of products or practices that are characterized in the market as “eco-friendly,” “green,” “carbon-neutral,” “regenerative,” “sustainable,” “natural,” and “safe”—all with a lack of uniform definition, compliance criteria, and enforcement. To the contrary, in crop/plant production and processing, “organic” does have a legal definition, subject to public review, certification, and enforcement. However, with greenwashing, many corporations aggressively try to gain a share of the $60 billion organic food market and nearly $22 billion organic personal care product market in the U.S.

According to ESG Today, the new law passed by the EU Parliament arose because a European Commission-sponsored study found that more than half of green claims are vague or misleading, and another 40% could produce no supporting evidence at all. EU member states have two years to incorporate the measure into their own laws.

There is already an EU law stating that “bio” and “eco” can be used only with reference to organic products, according to Organic Insider Newsletter. However, the EU has seen a proliferation of so-called certifiers that both violate EU law and provide weak or non-existent standards. The new law will permit sustainability labels only if the certifiers are approved by official authorities.

Europe is by no means alone with respect to greenwashing. The U.S. has the same problem. The U.S. Department of Agriculture’s National Organic Program (NOP) prohibits the use of most synthetic pesticides and soil amendments and requires that livestock environments be humane. Of course, these provisions, and enforcement of the organic standards, are less than perfect in their application, and deceptive claims do occur, as advocates call for more aggressive enforcement.

Beyond Pesticides Executive Director Jay Feldman says, “We take the position that the mislabeling of products as ‘natural’ even though that are produced with pesticide inputs, or categorizing such products as safe for the environment,” misleads people into thinking there is no difference between “organic”-labeled products” and those not so labeled. Beyond Pesticides supports organic land management using a systems management approach that builds organic matter and sustains biological organisms as the best way to manage recreational areas, lawns, and croplands without using life-threatening chemicals.”

Beyond Pesticides and numerous other advocacy groups have sued companies over agencies’ weak enforcement and sued companies for their greenwashing practices. In 2020 Beyond Pesticides sued TruGreen for misrepresenting the chemicals it uses on lawns. The company has claimed it uses only products that are not carcinogens, do not disturb immune systems, and are generally known to be safe. The complaint in the suit stated that TruGreen uses the likely carcinogen glyphosate, the allergen chlorophenoxy, (Tri-Power), and the neurotoxic organophosphate triclorfon (Dylox). TruGreen withdrew the language in its advertising.

As environmental advocates witnessed the spread of greenwashing, they began working out ways for consumers to separate the healthy sheep from the toxic goats. For example, the Regenerative Organic Alliance created a regenerative organic certificate in 2019 to complement USDA organic policy by incorporating soil health, animal welfare and social fairness into the regenerative standard. The Alliance has certified nearly 6 million acres, almost 400 crop types, and more than a thousand products. Sustainable America maintains a list of certification labels for consumer goods such as food (USDA National Organic Program), textiles (Global Organic Textile Standard and Oeko-Tex), personal care and household products (Leaping Bunny).

The National Organic Program began in 2002, but there has been significant erosion of its power since. In 2021 the Cornucopia Institute issued a Guide to Domestic USDA Accredited Certifiers, which reveals that many certifiers either violated some standards or failed to provide information about some or all of their certification criteria. The Institute also released a report on the inhumane practices in many organic dairy operations. In 2017 and 2023, the Washington Post published articles detailing the sorry state of organic standards enforcement. Finally, in 2023, USDA revised its guidelines for organic labeling. The new rules expand the types of businesses that must be certified to include brokers and traders. It also increases inspections of certified operations and requires certification of all imported products claiming to be organic.

One of the more egregious “fake names” that triggered deceptive labeling litigation was the 2012 case of Werdebaugh v. Blue Diamond Growers, in which the plaintiff alleged that Blue Diamond violated California’s consumer protection laws. Blue Diamond claimed its almond milk products were “all natural” when they actually contained numerous artificial colors, ingredients, synthetic chemicals and preservatives, according to the watchdog group ClassAction.org. Specifically, the ingredient list for Blue Diamond’s almond milk included “evaporated cane juice.” According to Beverage Daily, the Food and Drug Administration (FDA) had already instructed companies that the term is false and misleading—several times. A spate of similar lawsuits followed against Trader Joe’s, Wallaby Yogurt Company, Odwalla, Chobani, and others, all of which had listed “evaporated cane juice” as an ingredient. The FDA’s 2016 guidance states, “the term “evaporated cane juice” is not the common or usual name of any type of sweetener…[it] is false or misleading because it suggests that the sweetener is “juice” or is made from “juice” and does not reveal that its basic nature and characterizing properties are those of a sugar.”

There are some initiatives among companies, investors and even regulators to clarify and stabilize their commitments to sustainability. The Federal Trade Commission (FTC) leaves regulation of “organic” to the USDA’s National Organic Program, but it publishes Green Guides to help businesses avoid violating the FTC’s anti-greenwashing policies regarding false advertising, consumer protection, and unlawful business practices. The FTC last revised the Green Guides in 2012, and is currently updating them. It is expected to address the use of terms including “sustainability,” “climate change” and “carbon,” “recyclability,” “compostability,” “non-toxicity,” and misleading claims about product origins. According to a National Law Journal article, the FTC may revisit terms like “recyclable,” “reusable,” “renewable,” and “net zero” that it declined to consider in 2012.

In addition to the agriculture sector, change is emerging at the level of businesses and investors in the form of environmental, social and governance (ESG) standards. Training programs for individuals to earn a certificate in ESG are burgeoning. But again, as in product labeling, ESG certification could devolve into window dressing. How the ESG movement directly affects consumer labeling is unclear, but there is an effort to establish international standards for living up to environmental claims so that investors can trust the sustainability statements of the projects they invest in. The Sustainability Accounting Standards Board, a nonprofit group, includes a “Selling Practices and Product Labeling” component in its Sustainable Industry Classification System.

There is political pushback against attempts to adopt transparency and commitment to environmental values in publicly traded companies, pension funds, asset managers and the like. In an attempt to drag the world into the past and return to the policies of Milton Friedman, ESG opponents argue that companies are obligated to privilege profitability over all other values and goals. The solution to this toxic deception is the same as the one that environmental advocates press for in agriculture and consumer products: regulation of “eco” claims and enforcement of anti-greenwashing policies. Advocates, while endorsing corporate responsibility and the value of companies that are making a difference, state that anyone who identifies a practice or product as “green” in some way must be required to prove it, and should not be able to procure a spurious and weak certificate of virtue if they are not practicing what they preach.

The issues of these deceptive practices and greenwashing certification would be serious enough if they were merely everyday consumer product manipulation. But the cynical exploitation of social instruments that are important ways to effect a real paradigm change makes the effort to develop a truly healthy food system and preserve ecosystem functionality much more difficult.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Sources:

EU Parliament Approves New Law Banning Misleading Product Sustainability Claims. ESG Today January 18, 2024, https://www.esgtoday.com/eu-parliament-approves-law-banning-misleading-product-sustainability-claims/; EU Launches Green Claims Rules to Protect Consumers from Greenwashing. ESG Today March 22, 2023, https://www.esgtoday.com/eu-launches-green-claim-rules-to-protect-consumers-from-greenwashing/; “Sustainable” Certifications are Siphoning Billions from Organic. Business Insider May 10, 2023, https://organicinsider.com/newsletter/sustainable-certifications-leading-harvest-eco-score-your-weekly-organic-insider/; Regenerative Organic Alliance
https://regenorganic.org/; Lawsuit Challenges TruGreen Chemical Lawn Care Company for Deceptive Safety Claims; Pesticide Applications Stopped by Some States During COVID-19 Crisis as Nonessential Beyond Pesticides March 30, 2020, https://beyondpesticides.org/dailynewsblog/2020/03/lawsuit-challenges-trugreen-chemical-lawn-care-company-for-deceptive-safety-claims-pesticide-applications-stopped-by-some-states-during-covid-19-crisis-as-nonessential/; Unnatural Products: “Natural” Mislabeling Roundup. October 15, 2013, https://www.classaction.org/blog/unnatural-products-natural-mislabeling-roundup; SASB Standards Materiality Finder,  https://sasb.org/standards/materiality-finder/

Overview

Not What You Think → Your Weekly Organic Insider

Regenerative Organic Alliance

https://regenorganic.org/

Lawsuit Challenges TruGreen Chemical Lawn Care Company for Deceptive Safety Claims; Pesticide Applications Stopped by Some States During COVID-19 Crisis as Nonessential Beyond Pesticides March 30, 2020

https://beyondpesticides.org/dailynewsblog/2020/03/lawsuit-challenges-trugreen-chemical-lawn-care-company-for-deceptive-safety-claims-pesticide-applications-stopped-by-some-states-during-covid-19-crisis-as-nonessential/

Unnatural Products: “Natural” Mislabeling Roundup. October 15, 2013

https://www.classaction.org/blog/unnatural-products-natural-mislabeling-roundup

SASB Standards Materiality Finder

Overview

(Beyond Pesticides, February 1, 2024) A study published in Science of The Total Environment finds an insecticide ban would be economically beneficial in preventing Parkinson’s disease (PD). Despite differing pesticide exposure scenarios, PD risk lowers without pesticide exposure, especially insecticides that elicit neurotoxicity. In fact, a study published in 2023 notes high exposure to household pesticides, which are primarily insecticides, increases the risk of developing Parkinson’s disease (PD) two-fold.

There is a multitude of epidemiologic research on Parkinson’s disease demonstrating several risk factors, including specific genetic mutations and external/environmental triggers (e.g., pesticide use, pollutant exposure, etc.). However, several studies find exposure to chemical toxicants, like pesticides, has neurotoxic effects or exacerbates preexisting chemical damage to the nervous system. Studies suggest neurological damage from oxidative stress, cell dysfunction, and synapse impairment, among others, can increase the incidence of PD following pesticide exposure. Despite the widespread commercialized use of household pesticides among the general population, few epidemiologic studies examine the influence household pesticides, mainly insecticides or disinfectants, have on the risk of PD. Additionally, many studies demonstrate the association between PD onset and occupational (work-related) pesticide exposure patterns.

Parkinson’s disease is the second most common neurodegenerative disease, with at least one million Americans living with PD and about 50,000 new diagnoses annually. Alzheimer’s ranks first. The disease affects 50 percent more men than women, and individuals with PD have a variety of symptoms, including loss of muscle control and trembling, anxiety and depression, constipation and urinary difficulties, dementia, and sleep disturbances. Over time, symptoms intensify, but there is no current cure for this fatal disease. While only 10 to 15 percent of PD incidents are genetic, PD is quickly becoming the world’s fastest-growing brain disease. Therefore, research like this highlights the need to examine alternate risk factors for disease development, especially if disease triggers are overwhelmingly nonhereditary.

The study evaluated whether the of banning specific insecticides to reduce the PD burden in three counties in Central California (CA) is cost-effective. Researchers applied a cost-effectiveness analysis to estimate the impact and costs of banning seven insecticides (methomyl, dimethoate, carbaryl, acephate, malathion, naled, or oxydemeton-methyl) linked to PD in these counties. The analysis also investigated mixed exposures of these pesticides. The cohort included 65- and 66-year-olds living in these CA counties and estimated their incidence, costs, and reduction in quality-adjusted life-years (QALY) from developing PD over 20 years. After applying various scenarios, the analysis finds banning insecticides to reduce the occurrence of PD in three Central CA counties would be cost-effective compared to not prohibiting the insecticides. For the worst-case scenario depicting exposure to one insecticide, exposure to methomyl would result in a 12 percent increase in PD cases, increasing health-related costs by $72 million, with each additional PD patient incurring $109,327 in costs per QALY loss from PD. Overall, the highest PD burden and the cost associated with PD occurs from exposure to multiple pesticides simultaneously, particularly for oxydemeton-methyl, dimethoate, and carbaryl.

Parkinson’s disease occurs when there is damage to dopaminergic nerve cells (i.e., those activated by or sensitive to dopamine) in the brain responsible for dopamine production, one of the primary neurotransmitters mediating motor function. Although the cause of dopaminergic cell damage remains unknown, evidence suggests that pesticide exposure, especially chronic exposure, may be the culprit. Data is increasingly showing that cumulative exposures over one’s life increase the risk of developing Parkinson’s disease, and other factors such as genetics and exposure to other chemicals further elevate the threat. Strong links to this chronic condition are incredibly concerning, given emerging evidence of a Parkinson’s pandemic, predicting that rates of the disease will double between now and 2040. Occupational exposure poses a unique risk, as pesticide exposure is direct via handling and application. A 2017 study finds that occupational use of pesticides (i.e., fungicides, herbicides, or insecticides) increases PD risk by 110 to 211 percent. Even more concerning, some personal protection equipment (PPE) may not protect workers from chemical exposure during application. However, indirect nonoccupational (residential) exposure to pesticides, such as proximity to pesticide-treated areas, can also increase the risk of PD. A Louisiana State University study finds that residents living adjacent to pesticide-treated pasture and forest land by the agriculture and timber industry have a higher incidence of PD. Furthermore, pesticide residues in waterways and on produce present an alternate route for residential pesticide exposure to increase the risk for PD via ingestion. In addition to PD, pesticide exposure can cause severe health problems even at low residue levels, including endocrine disruption, cancers, reproductive dysfunction, respiratory problems (e.g., asthma, bronchitis), and other neurological impacts. Nevertheless, direct occupational and indirect nonoccupational pesticide exposure can increase the risk of PD. 

This study is one of the first to assess the cost-effectiveness of banning insecticides to reduce PD burden. However, a 2021 cost-effective analysis has already shown that a ban on highly hazardous pesticides can reduce pesticide-related suicides by 28,000 deaths each year, at $0.007 per capita globally. Therefore, model-based cost-effectiveness analyses can help to estimate long-term cost benefits from reducing health effects from environmental hazards.

The analysis’s focus on insecticides is important as insecticides are the most commonly used household pesticides, and a history of high exposure to household pesticides increases the risk of PD regardless of the age at PD onset. However, herbicides like glyphosate, 2,4-D, and paraquat and fungicides like maneb can also increase the risk of PD, demonstrating that PD risk can occur regardless of pesticide category.

The cost-effectiveness analysis in this study is essential in comparing the impacts of banning pesticides according to different exposure scenarios, as it helps inform policymakers and stakeholders on regulatory decisions based on economic and long-term health consequences. Banning the seven insecticides in this analysis is a cost-effective solution when considering PD-associated costs, suggesting that reducing PD burden costs offsets the ban’s cost. However, the study may underestimate the impact of multiple insecticide exposures. Thus, the cost-effectiveness of withdrawing insecticides would be even more significant since it would reduce PD risk from single pesticide exposure while eliminating the interaction with other pesticides.

The study highlights that farmers and the agricultural industry may experience immediate financial loss when eliminating insecticide use to switch to another product, which needs to be evaluated against the long-term health benefits and the costs or burden of disease. Thus, the researchers note that “a real-world-based cost-effectiveness analysis is crucial for guiding policies that balance public health priorities and less apparent long-term benefits against economic aspects related to agricultural practices.”

The study concludes, “[T]he population-level long-term health benefits and health savings would outweigh the financial losses due to the pesticide ban. [This] study adds a financial dimension to the understanding of environmental health impacts, particularly on vulnerable populations like the elderly in rural communities. Policymakers and agricultural industries should consider healthcare costs when deciding to continue using certain pesticides and consider immediate action to reduce harm. [… The researchers would] like to highlight the necessity for further research to expand these findings to other geographic areas and pollutants to enrich and support a broader discourse concerning pesticide regulation and public health.”

Parkinson’s disease has no cure, but preventive practices, like organic agriculture or Parks for a Sustainable Future, eliminate exposure to toxic PD-inducing pesticides, especially as a 2023 study points to PD as a predominantly environmentally induced disease. Considering health officials expect Parkinson’s disease diagnosis to double over the next 20 years, mitigating preventable exposure from disease-inducing pesticides becomes increasingly essential. For more information on the effects of pesticide exposure on neurological health, see the Pesticide-Induced Diseases Database (PIDD)  pages on Parkinson’s disease, dementia-like diseases, such as Alzheimer’s, and other impacts on cognitive function. 

Organic agriculture represents a safer, healthier approach to crop production that does not necessitate toxic pesticide use. Beyond Pesticides encourages farmers to embrace regenerative, organic practices and consumers to purchase organically grown food. A complement to buying organic is contacting various organic farming organizations to learn more about what you can do. Those affected by pesticide drift can refer to Beyond Pesticides’ webpage on What to Do in a Pesticide Emergency and contact the organization for additional information. Furthermore, see Beyond Pesticides’ Parkinson’s Disease article from the Spring 2008 issue of Pesticides and You.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Science of The Total Environment

(Beyond Pesticides, January 31, 2024) A report published in December 2023 by the European Environment Agency (EEA) details opportunities and challenges to European organic farming targets for 2030. The European Union (EU) has set ambitious targets in its environmental policy—including the Farm to Fork Strategy (F2F) and European Green Deal (EGD)—with the goal to have at least 25 percent of European farmland run on organic land management practices by 2030. The EU’s approach to organic farming and pesticide regulation on agricultural land in comparison to public and private land offers insightful lessons for advocates in the United States to apply to their campaigns.

Some countries are ahead of the 25 percent by 2030 target, such as Austria, Estonia, and Sweden, with 20 percent of agriculture organically managed as of 2021. The German government is preparing to exceed the EU goal when the new coalition government presented a strategy last November outlining a 30 percent goal for 2030. Meanwhile, some countries are vastly underperforming—with Poland adding virtually zero farmland to organic production between 2012 and 2021. Overall, approximately 9.9 percent of total EU farmland follows organic standards as of 2021. At this rate, the EU will only meet 15 percent rather than 25 percent by 2030. France has taken a leading role in pesticide bans on public landscapes and private land that is frequently employed for public use, enforcing a strict ban on all pesticides in these areas in 2022. Under previous law, which is now the EU-wide regulation via F2F, France had the target of reducing overall pesticide use by 50 percent by 2030.

In response to the introduction of pesticide bans and EU climate policies included in the EGD, news outlets such as France24 have reported a groundswell of mass protests from farmers in France, Romania, and Germany who view these policies and the associated upfront costs of transitioning away from petrochemical pesticide use as an affront to their financial stability. France24 reports, “Frustration is…. mounting among farmers across Europe. They are unhappy about bans on pesticides cleared for use in other parts of the world and what they view as unfair competition from Ukrainian grain imports.” Meanwhile, farmers in South Africa have expressed outrage at the “hypocritical tactics European agrochemical companies use to sell products in developing nations, even when those products are deemed unsafe in their home countries.” This break between the interests of farmers and climate policy goals in the European Union demonstrates the significance of U.S. reluctance to commit to a full transition in coordination with F2F in a broader organic farming strategy, as Beyond Pesticides has recently reported. For context, USDA announced its Organic Transition Initiative last year providing $300 million USD in technical, insurance, and mentoring support for existing and transitional organic farms in the United States; however, the OTI did not establish an organic farming target akin to the EU approach.

Despite the different approaches in the U.S. versus EU, public health and environmental advocates and advocacy groups generally support F2F and the Common Agricultural Policy as a vessel for advancing organic land management across all EU member states. Certain policy decisions regarding the stringency of targets and administrative roadblocks to tougher pesticide regulations are compounded by widespread pushback from pesticide-dependent farmers across the European Union, which may explain current lags to reaching the 2030 goal. For example, after hearing a petition from representatives of the European Citizens’ Initiative to establish binding targets of 80 percent overall pesticide reduction and total pesticide ban by 2035, the European Commission rejected the proposal “citing economic costs for farmers and consumers,” according to reporting by EurActiv. This move is not a surprise given the findings of a 2022 study published in the National Library of Medicine. The authors point out that the reduction of herbicide use poses a unique challenge to EGD’s stated goal of 50 percent pesticide reduction by 2030, given the decrease in alternatives in recent years and mixed understandings of concepts such as herbicidal resistance.

Additionally, Beyond Pesticides indicated in an article last year that EU and U.S. Pesticide Regulators Ignore Developmental Neurotoxicity of Pesticides as investigative journalists report that, “Of the nine undisclosed DNT [developmental neurotoxicity] studies [‘submitted to the U.S. Environmental Protection Agency (EPA) but were not disclosed to EU authorities’], three were sponsored by Bayer and performed in their own laboratory. Three studies were sponsored by Syngenta and performed in their Central Toxicology Laboratory. One study each was sponsored by Nissan Chemicals and Ishihara Sangyo Kaisha (ISK), and these were performed at Huntingdon Life Sciences. For the remaining study, the sponsor and laboratory are unknown to us.” The article continues, “In both the U.S. and the E.U., companies registering pesticides must provide evidence from toxicological studies to support their marketing plans. But in both countries, there is a built-in conflict of interest in the way the science is used to justify commercial ends, and the fox should not be the party rationalizing its presence in the henhouse.”

The groundswell of grassroots action in both the EU and the U.S. demonstrates growing public awareness of regulatory capture by the petrochemical pesticide industry and the pitfalls of these dangerous pesticides on food supply chain resilience, public health, and biodiversity protections. In the U.S. context in recent years, there has been recent movement in pesticide bans on public property, such as prohibiting day-time applications of pesticides on the grounds of Illinois public schools. State-level action on pesticide bans and actions builds upon the legacy of over 200 cities, counties, and municipalities that have some level of pesticide application restrictions on private and public land. As the Farm Bill negotiations continue, there are still opportunities to contact local elected officials as well as Congress to protect local and state authority to regulate pesticide use.

Given escalating existential crises in public health threats, biodiversity collapse, and climate, Beyond Pesticides calls for the elimination of petrochemical pesticides and fertilizers by 2032 with the transition to organic land management. (See Transformative Change: Informed by Science, Policy, an Action.) For a discussion of critical issues on the crises and their relationship to petrochemical pesticides and fertilizers, see our National Forum—Meeting the Health, Biodiversity, and Climate Crises with a Path for Livable Future (2022).

Beyond Pesticides has compiled numerous studies that indicate a plethora of benefits that emerge from the production, distribution, and consumption of organic food products. For example, research conducted by the Environmental Pollution journal, “found that children who ate organic food displayed higher scores measuring fluid intelligence and working memory. Lower scores on fluid intelligence tests were associated with children’s fast food intake, house crowding, and exposure to tobacco smoke. Lower scores on working memory tests were associated with exposure to poor indoor air quality.” For more information on the health benefits of organic farming, see our sections on Health Benefits of Organic Agriculture and Eating With a Conscience for breakdowns on the public health, environmental justice, and ecological benefits of organic food.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: European Environment Agency

(Beyond Pesticides, January 30, 2024) The City Council of Brighton and Hove (England) is preparing to expand the use of glyphosate after widespread public complaints over the growth of Japanese knotweed and a program of manual clearance. This imminent local land management decision flies in the face of substantial research on the health and ecological impacts of glyphosate-based herbicides, including from Aaron Blair, PhD—former chair of the International Agency for Research on Cancer (IARC) working group on glyphosate and former branch chief (now scientist emeritus) of the Occupational Studies Section, National Cancer Institute (NCI). Advocates are concerned that the city council is basing this rationale on the fact that the European Commission reapproved use of glyphosate in 2023 for a ten-year period and not the body of scientific literature on health and ecosystem effects as well as alternative practices and products.

According to a recent ENDS Report, “The [City of Brighton and Hove] council banned the use of glyphosate in 2019 – with an exception for killing invasive species [‘in exceptional cases’] such as Japanese Knotweed – after it was linked to health concerns and a decline in bee populations. As part of this it was agreed that the removal of weeds in parks and on hard surfaces would be undertaken manually as an alternative approach to using pesticides.” After a January 23 city council meeting, it appears that councilors are leaning toward a “controlled-droplet application of glyphosate” as of January 18, 2024. This move would broaden the existing policy of applying glyphosate to allow certain exceptions to its institution as a general practice. While the existing policy does not universally ban glyphosate, the city relied on manual weed management for the past five years.

There is much more in this piece on the specifics of the City of Brighton and Hove’s ordinance and the compelling science that has supported the elimination of glyphosate use in communities around the U.S. and around the world, in addition to large awards from jury verdicts for those exposed and harmed. Before getting to that, it should be noted that the demand for glyphosate use typically does not address the question of holistic Japanese Knotweed management strategies, which are critical to this “invasive” plant as well as all unwanted plants and the impact that control strategies have on ecosystem health and ecological balance. While eradication has been a driving force for many land managers and members of the public, those in the field have increasingly come to question the viability of that strategy. Eric Burkhart, PhD, a botanist, ethnobotanist, and agroforester from Shaver’s Creek Environmental Center (in Penn State University’s experimental forest) and associate professor at Penn State, says the following about a holistic management strategy: “After more than 25 years of trying to control this invasive species, I have acquired a great deal of respect for this herculean plant. I’m resolved not to concoct any fanciful notion of ever eradicating it. Invasive knotweed is here to stay.” From his experience using glyphosate and other elimination strategies, he learned that, “I had not carefully considered trying to restore what once grew where the knotweed intruded.” Experience has brought Dr. Burkhart to recommend the following: “. . .re-planting areas with vigorous native woody shrubs and trees such as dogwoods and willows. Live staking is reported by many sources to be a good option. Knotweed is less vigorous in shade, so establishing an overstory or other competition will help to suppress growth.” More on this can found at a Penn State Extension webpage. Beyond Pesticides notes that initial clearing of an area can be achieved with managed goat grazing, and chemicals are counterproductive to ecological balance and a restorative and regenerative strategy. While Beyond Pesticides does not recommend specific companies, Browsing Green Goats and Goat Guardian explain a strategy of clearance that is being used across the country. There are too many examples of sustainable land management with goats to list here, but a few to check out include South Portland, Maine, and Connecticut College. For more background on managed goat grazing, see Beyond Pesticides’ goat demonstration at the 36^th National Forum, Organic Neighborhoods: For healthy children, families, and ecology, Irvine, California.

The Council Committee on Weed Management in the Environment, Sea Downs, and The Sea in Brighton and Hove City Council put forward an ordinance change to consider controlled-droplet application or conventional application of glyphosate:

• Recommendation 4: Subject to approval at Budget Council, to amend the current policy to support the use of glyphosate to manage weeds on all hard surfaces and instruct the council’s City Environmental Management Services to engage with contractors to use a controlled-droplet application to manage and remove weeds from across the city in 2024, as described more fully in paragraphs 3.21 to 3.24 and 3.28 to 3.29. Further to this, Committee agrees to delegate authority to the Executive Director – Economy, Environment & Culture, in consultation with the Committee Chair, to determine the most effective approach for weed management in future years based on the outcomes achieved in 2024.

OR

• Recommendation 5: Subject to approval from Budget Council, to amend the current policy to support the use of glyphosate to manage weeds on all hard surfaces and instruct the council’s City Environmental Management Services to engage with contractors to use traditional glyphosate to manage and remove weeds from across the city in 2024, as described more fully in paragraphs 3.25 to 3.29. This will be subject to a review in winter 2024 to see if there is an option to move to a controlled-droplet application for 2025. Further to this, Committee agrees to delegate authority to the Executive Director – Economy, Environment & Culture, in consultation with the Committee Chair, to determine the most effective approach for weed management in future years based on the outcomes achieved in 2024.

While the mainstream press has focused on the cancer effects of glyphosate/Roundup and the jury verdicts against Monsanto/Bayer, the manufacturer of glyphosate/Roundup, the scientific literature on glyphosate has raised a range of serious adverse health and ecosystem effects.

As time passes since the IARC decision, a review of the science that links glyphosate/Roundup to science may be helpful. As a keynote speaker at Beyond Pesticides’ 34^th National Pesticide Forum in Portland, Maine, Dr. Blair discussed IARC’s research on the linkage between the herbicide glyphosate and cancer. Dr. Blair, who has published  over 450 scientific and medical journal articles on environmental and occupational causes of cancer, discussed in detail the methodological approach and scientific background on.”

The methodology for the 2015 study includes data from rodent bioassays, mechanistic data, and epidemiological studies. The rodent bioassays found a relationship between glyphosate exposure and the diagnosis of rare cancers, including renal tubule carcinoma, hemangiosarcoma, pancreatic islet-cell adenoma, and skin cancer. The mechanistic studies found evidence of DNA and chromosomal damage, as well as oxidative stress—all of which are indicators of cancer. Meanwhile, the epidemiological studies found an association with non-Hodgkins’s lymphoma in case-control studies from the United States, Canada, and Sweden (but not in the Agricultural Health Study that Dr. Blair was part of in Iowa and North Carolina—Dr. Blair mentioned at the Forum that “epidemiological studies….[are] not always that clear-cut [with human data]” and scientists, “have to look at the totality of what is going on.”) The IARC evaluation process includes the composition of working groups of between 15 to 30 scientists from diverse disciplines going through a literature review of publicly available research from epidemiological, bioassay, mechanistic, and exposure studies. Out of the four levels of classification, Dr. Blair’s IARC working group assigned glyphosate under category 2A, which determines the assigned pesticide or chemical as “probably carcinogenic to humans.” “You usually [get to probable cause assessment through] limited evidence in human… and sufficient evidence in animal [studies].” To listen to Dr. Aaron Blair’s full keynote, click the link here. [Timestamp: 22:00]

Understanding the scientific process that led to IARC’s 2015 assessment is important for advocates who wish to challenge claims made by the petrochemical industry, the Environmental Protection Agency (EPA), and more recently the European Union that disputes the connection between glyphosate and human health. Reports such as “Merchants of Poison” uncover Monsanto’s (now owned by Bayer) efforts to interfere in scientific analysis, media coverage, philanthropic involvement, and higher education efforts to spread disinformation and misinformation on the health impacts of glyphosate. EPA staff and managers have also been found to have an “unholy alliance” with industry actors such as Bayer. Beyond Pesticides has also reported on industry efforts on dicamba and atrazine in which Bayer and BSF, “engaged in a variety of deceitful, unethical, and possibly fraudulent practices to enable [their] use.” In 2022, the EPA revisited their 2017 decision declaring their conclusion that glyphosate is not carcinogenic after, “the Court of Appeals for the Ninth Circuit handed down a ruling that held EPA’s 2020 approval of glyphosate was unlawful.“ According to an “independent evaluation of available data for glyphosate”, the EPA found “no risks of concern to human health from current uses of glyphosate,” “no indication that children are more sensitive to glyphosate,” “no evidence that glyphosate causes cancer in humans,” and “no indication that glyphosate is an endocrine disruptor.”

Advocates are concerned that the use of glyphosate is a self-fulfilling prophecy in that this approach aims to create ecosystem imbalance to address ecosystem imbalance. Beyond IARC’s work, there is extensive scientific evidence linking glyphosate to a range of human and ecological health effects. Regarding human health, see the article Scientists Express Concern Over Widespread Use of Glyphosate-Based Herbicides where, “Following the carcinogenic classification by IARC, a research study published in Environmental Health linked long-term, ultra-low dose exposure to glyphosate in drinking water to adverse impacts on the health of liver and kidneys.” Adding to the body of science, more studies in the last year corroborate the health risks posed by glyphosate exposure to male reproductive systems, behavioral and gut health, and neurodegenerative disease and sleep function.

Beyond Pesticides—through ManageSafe, ManageSafe’s resources on Japanese Knotweed, and previous reporting on glyphosate health, safety, and environmental justice impacts across the supply chain— has a plethora of resources underscoring the danger of pesticide application exemptions in creating wiggle room for state and local authority to spray glyphosate and harmful petrochemical pesticides in local communities.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.  

Source: ENDS Report

(Beyond Pesticides, January 29, 2024) With its draft Biological Evaluation of the impacts of rodenticides open for public comment until February 13, advocates are warning the U.S. Environmental Protection Agency (EPA) that its inadequate review is unconscionable in view of the looming biodiversity collapse. “This is not a moment for business as usual and weak reviews that lead to wholly inadequate regulations in a time of crisis,” said Jay Feldman, executive director of Beyond Pesticides. Beyond Pesticides has tracked the scientific literature on the threat of rodenticides to wildlife, including an important study on contamination of eagles with rodenticides. Central to the concern about the deficiencies in EPA’s biological evaluation is the inadequate focus on secondary poisoning of listed endangered species fish and aquatic reptiles associated with predation of animals poisoned with rodenticides. In 2020, California passed the California Ecosystems Protection Act, AB 1788, which mostly bans on state lands rodenticides associated with secondary poisonings and initiated a broader review.

Tell EPA to improve its protection of endangered species from rodenticides.

In announcing the  2022 COP15 conference — the United Nation’s (UN’s) Conference of the Parties to the Convention on Biological Diversity (CBD), the UN Development Programme set out the context for the summit: “Despite ongoing efforts, biodiversity is deteriorating worldwide, and this decline is projected to worsen with business-as-usual. The loss of biodiversity comes at a great cost for human well-being and the global economy.” Mr. Feldman said, “EPA either wants to be a part of the solution or a part of the problem. Unfortunately, this biological evaluation clearly exemplifies the agency is a part of the problem.” Meanwhile, the U.S. has never joined the world community in ratifying a national commitment to protecting biodiversity as a signatory to the United Nations Convention on Biological Diversity (CBD), signed by 196 nations. [In addition to commenting on the rodenticide biological evaluation, the public can continue to: Tell Congress to ratify the Convention on Biological Diversity. Tell EPA to incorporate CBD targets into its programs.]

The rodenticide comments due by February 13, EPA’s Draft Biological Evaluation (BE), Effects Determinations, and Mitigation Strategy for Federally Listed and Proposed Endangered and Threatened Species and Designated and Proposed Critical Habitats for 11 Rodenticides, are an opportunity for the public to urge the agency to evaluate pesticide impacts on the environment more holistically under its statutory mandate. Beyond Pesticides has stated, “The BE is inadequate, both in its evaluation of risk and measures to mitigate risk and should not be used as the basis for registration of these rodenticides.” A detailed examination can be found in draft comments by Beyond Pesticides.

The rodenticide biological evaluation is to be conducted under the Endangered Species Act (ESA), one of the most effective conservation laws globally, protecting 1,662 species in the U.S. and 638 species elsewhere on Earth. Over the past five decades, the ESA has played a pivotal role in preventing these extinctions by safeguarding the most critically endangered species within biological communities. The ESA establishes a framework to categorize species as “endangered” or “threatened,” granting them specific protections, but the goal of the ESA is to address the broader issue of biodiversity loss by protecting habitats of species most at risk, or, as stated in the ESA, to “Provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions set forth in subsection (a) of this section.”

Under the ESA, EPA is required to consult with relevant agencies when registering chemicals to assess their impact on endangered species. Unfortunately, according to advocates, EPA has consistently fallen short in fulfilling this statutory obligation, as highlighted over years of reporting by Beyond Pesticides. EPA admits that its Pesticide Program “has been unable to keep pace with its ESA workload, resulting not only in inadequate protections for listed species but also litigation against the Agency.”

Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first to the ways it has created the crisis in the first place.

In this BE, EPA predicts the potential likelihood of future jeopardy for only 73 of the 136 species it judged may be affected and the potential likelihood of future adverse modification for only four of the 38 “likely to be adversely affected” critical habitats. It predicted potential jeopardy for 24 mammal species for bait station use, 31 for burrow use, and 35 for broadcast applications. For birds, EPA predicts jeopardy for six species from bait station use, one for burrow use, and 30 for broadcast applications. For reptiles, EPA predicts jeopardy for just four species from bait station use, and just one species for broadcast applications. EPA made “no effect” determinations for all aquatic and terrestrial plants, aquatic and terrestrial invertebrates, and aquatic vertebrates for which no direct effects or effects on prey, pollination, habitat, or dispersal are expected from the use of the 11 rodenticides.

Tell EPA to improve its protection of endangered species from rodenticides.

Despite data to the contrary, EPA has made no effect (NE) determinations for all species under the jurisdiction of the National Marine Fisheries Service (NMFS) because no consequences relevant to direct toxicity of these species or their prey, pollination, habitat, or dispersal are expected by EPA from the use of these rodenticides. These categorical NE determinations by EPA for all aquatic vertebrates, including those under the jurisdiction of NMFS, are not warranted. Anticoagulant rodenticides (ARs), contrary to the agency’s assertions, can be transported to the aquatic environment (freshwater and marine). Recent detections in raw and treated wastewater, sewage sludge, estuarine sediments, suspended particulate matter, and liver tissue of sampled fish demonstrate that the aquatic environment experiences a greater risk of anticoagulant rodenticide exposure than previously thought. One AR, brodifacoum, revealed an enduring persistence (>3 years) in a marine environment after broadcast treatment in an island eradication project. Monitoring studies have also demonstrated that second-generation ARs bioaccumulate in fish liver under environmentally realistic conditions and exposure scenarios. Island eradication programs also provide for increased drift and runoff potential due to the broader treatment area and amplified application rates. Fish sampled after broadcast applications of AR bait pellets during monitored island eradication operations (Palmyra Atoll and Lehua Island, Hawaii) were found to have consumed treated pellets. The fish, as well as other animals that consumed the bait, were killed.

Secondary poisoning in listed endangered species fish and aquatic reptiles is similarly possible from ingesting poisoned animals. Some invertebrates (e.g., insects, mollusks, and annelid worms) can consume poisoned baits and transfer the poison via food web to various susceptible vertebrates. Target and nontarget small mammals that have consumed poisoned baits will not always stay sedentary or concealed—many roam openly and often seek water. Those who become moribund or die in sewers, culverts, drainage ditches, or similar conduits can be swept into riparian zones or directly into water bodies (streams, rivers, lakes, tidal basins, estuaries) where they can be consumed by aquatic predators and scavengers. Encounter and ingestion of a poisoned and sickened rodent could prove fatal to aquatic vertebrate species. Mice have been reported to be consumed by listed species such as alligator snapping turtle, bull trout, Atlantic salmon, and steelhead trout. These four listed species should be considered “may be affected” and their potential jeopardy considered by the Services (U.S. Fish and Wildlife Services-USFWS and NMFS) in the required formal consultation. Additionally, marine mammals may be at serious risk from existing and planned island eradication projects and should be considered in a revised BE.

As discussed above, fish are exposed through primary routes in the consumption of bait pellets/grains that may be washed or transported into waters. They may also consume invertebrates or small mammals that have ingested poisoned baits and moved into their habitat. However, EPA lacks dietary toxicity data for fish and cannot confidently assess the extent of risk from this route of exposure in these aquatic vertebrates. EPA must seek additional toxicity data from registrants to better evaluate rodenticide toxicity from dietary exposures of fish. In addition to lacking dietary toxicity data for rodenticides, the agency also lacks reproduction and chronic (life cycle) toxicity data on aquatic vertebrates.

In conclusion, the draft BE is unsatisfactory and must be revised before proceeding to formal ESA §7(a)(2) consultations with the Services (Fish and Wildlife Service and National Marine Fisheries Service). The flawed draft BE erroneously disregards potential aquatic exposure and fails to identify additional listed species (alligator snapping turtle, bull trout, Atlantic salmon, steelhead trout) that may be adversely affected. Aquatic animals, including fish are exposed, as previously discussed, through primary routes in the consumption of bait pellets/grains that may be washed or transported into waters from broadcast application or improperly disposed bait stations. Secondary routes are also possible from consuming invertebrates or small mammals that have ingested poisoned bait and moved into their habitat. However, EPA lacks dietary toxicity data for fish and cannot confidently assess the extent of risk from this route of exposure.

EPA must seek additional toxicity data from registrants to better evaluate rodenticide toxicity from dietary exposures of fish. In addition to lacking dietary toxicity data for rodenticides, the agency also lacks reproduction and chronic (life cycle) toxicity data on aquatic vertebrates. Since this draft BE is intended to be a comprehensive review and analysis of all currently registered uses of 11 rodenticides, the island eradication programs special use labels should also be considered in the rodenticide BE and not solely dependent on expected USDA Animal Plant Health Inspection (APHIS) ESA consultations.

Source document: Document ID EPA-HQ-OPP-2023-0567-0001.

Tell EPA to improve its protection of endangered species from rodenticides.

Comment to EPA

The Draft Biological Evaluation (BE) is inadequate and should not be used to support the registration of the 11 rodenticides under review. Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. EPA must reverse these trends.

The BE predicts the potential likelihood of future jeopardy for only 73 of the 136 species that “may be affected” and the potential likelihood of future adverse modification for only 4 of the 38 “likely to be adversely affected” critical habitats. EPA made “no effect” determinations for all aquatic and terrestrial plants, aquatic and terrestrial invertebrates, and aquatic vertebrates for which it expects no direct effects or effects on prey, pollination, habitat, or dispersal from the use of the 11 rodenticides.

EPA made “no effect” (NE) determinations for species under the jurisdiction of the National Marine Fisheries Service (NMFS). These categorical NE determinations by EPA for all aquatic vertebrates are not warranted. Anticoagulant rodenticides (ARs) can be transported to freshwater and marine environments—as shown by recent detections in raw and treated wastewater, sewage sludge, estuarine sediments, suspended particulate matter, and liver tissue of fish. One AR, brodifacoum, persisted at least 3 years in a marine environment after broadcast treatment in an island eradication project (Palmyra Atoll and Lehua Island, Hawaii). Studies also show that second-generation ARs bioaccumulate in fish liver. Island eradication programs provide increased drift and runoff potential due to the broad treatment area and high application rates. Fish sampled after broadcast applications of AR bait pellets during monitored island eradication operations were found to have consumed treated pellets. The fish and other animals that consumed the bait were killed.

Secondary poisoning in listed endangered species aquatic species may occur by ingesting poisoned animals. Invertebrates such as insects, mollusks, and annelid worms can consume poisoned baits and transfer the poison via food web to susceptible vertebrates who may end up in water bodies where they can be consumed by aquatic predators and scavengers. Ingestion of a poisoned and sickened rodent could prove fatal to aquatic vertebrates. Mice are consumed by listed species such as alligator snapping turtle, bull trout, Atlantic salmon, and steelhead trout. These four listed species should be “may be affected” and their potential jeopardy considered by the Services (USFWS and NMFS) in the required formal consultation. Additionally, marine mammals may be at serious risk from existing and planned island eradication projects and should be considered in a revised BE.

In conclusion, the draft BE is flawed and must be revised before proceeding to formal consultations with the Services. The draft BE erroneously disregards potential aquatic exposure and fails to identify additional listed species (alligator snapping turtle, bull trout, Atlantic salmon, steelhead trout) as well as marine mammals that may be adversely affected. Aquatic animals are exposed through primary routes and secondary routes. EPA must seek additional data from registrants on dietary and chronic toxicity to aquatic vertebrates, which it currently lacks. Since this draft BE is intended to be a comprehensive review and analysis of all currently registered uses of 11 rodenticides, the island eradication programs special use labels should also be considered in the rodenticide BE and not wait on expected APHIS consultations.

Thank you for considering these comments.

(Beyond Pesticides, January 26, 2024) In addition to maternal (mothers) exposure, children experience exposure to pyrethroid insecticides earlier in life as levels significantly increase post-natal (after birth), according to a study published in Frontiers in Public Health. This study is one of the few studies to investigate pyrethroid exposure concentrations in the urine of newborns and children within their first year of life. However, this research reiterates what many other studies demonstrate on pyrethroids’ impacts on children’s health, primarily due to their notorious neurotoxic properties. The findings indicate that exposure to pyrethroids during pregnancy and early childhood exposure has links to adverse health effects, including neurodevelopmental delays (e.g., autism), behavioral issues (e.g., attention deficit [hyperactivity] disorder), and endocrine disruption (e.g., delay in puberty). Pesticide exposure during pregnancy is of specific concern as health effects for all life stages can be long-lasting. Just as nutrients are transferable between mother and fetus, so are chemical contaminants. Studies find pesticide compounds in the mother’s blood can transfer to the fetus via the umbilical cord. Therefore, pesticide exposure during pregnancy affects both the mother and child’s health.

Beyond Pesticides has covered a variety of pregnancy risks from pesticides and other toxic chemicals, including these in just the last three years: pesticides and children’s sleep disorders; prenatal exposures to a multitude of chemicals; insecticides and childhood leukemia; and insecticides and Attention Deficit/Hyperactivity Disorder.

The study evaluated concentrations of pyrethroid insecticides from exposure among 142 pregnant women in Rio de Janeiro, Brazil, and their children during birth and in the first, third, and sixth months of life. Researchers measured pyrethroid concentrations in urine via metabolites (breakdown products) of the insecticides 3-phenoxy benzoic acid (3-PBA) and 4-fluoro-3-phenoxybenzyl acid (4-FPBA). The results find 3-PBA more frequently in the urinalysis of pregnant women (47 percent) as it is the metabolite of more common pyrethroids used in Brazil, like cypermethrin, cyhalothrin, deltamethrin esfenvalerate, and permethrin, compared to 4-FPBA, a metabolite of cyfluthrin, in 11 percent of pregnant women. Ten percent of children’s urine samples have detachable 3-PBA levels after birth. However, the levels of 3-PBA increase with age, as 21 percent of the children’s urine samples during the third and sixth months of life contain detectable levels of pyrethroids.

The study highlights that the presence of pyrethroids in newborn urine indicates exposure through the mother during gestation (pregnancy), and continued exposure through the first year of the child’s life can be due to exposure through breast milk, food consumption, and the use of pyrethroid-based insecticides indoors.

Prenatal and early-life exposure to environmental toxicants increases susceptibility to disease, as women living near agricultural areas experience higher exposure rates that increase the risk of birthing a baby with abnormalities, including brain malformations. A 2011 study found that children exposed to higher levels of synthetic pyrethroids are three times as likely to have mental delays compared to less exposed children. Additionally, a 2014 study associates proximity to pesticide-treated agricultural fields in pregnancy with an increased risk of autism in children of exposed mothers. Two studies published in 2015 found that deltamethrin increases the risk of attention-deficit/hyperactivity disorder (ADHD) in children, with one study finding impacts specifically on boys. Studies published in 2017 found that synthetic pyrethroid exposure increases the risk of premature puberty in boys, and another associated the chemicals with externalizing and internalizing disorders. The impacts seen are not all developmental. A 2012 study associates pyrethroid exposure before, during, and after pregnancy with an increased risk of infant leukemia, with a 2013 finding exposure to permethrin (a pyrethroid) in utero is linked to an increased risk of infant leukemia diagnosed before age two. More recently, a 2022 study finds that synthetic pyrethroid exposure during mosquito control operations increases the risk of respiratory disease and specific allergies.

This study highlights that people living within the study area have used household pesticides within the previous year, with over 80 percent of those household pesticides containing pyrethroids. Thus, the rampant use of these chemicals can account for their presence in breast milk, transferring from mother to child through nursing. With this study being one of the few to assess urinary concentrations of pyrethroids in newborns and children during the first year of life, the results are relatively concerning. The increase in pyrethroid metabolite concentrations in urine after birth highlights the potential adverse impacts on newborns, who are more vulnerable to the toxic effects of pollutants due to their immature immune systems. This conclusion supports long-known concepts regarding the hazards of pesticides to children’s health. Early life exposures during “critical windows of vulnerability” can predict the likelihood or otherwise increase the chances of an individual encountering a range of pernicious diseases. 

There is a strong consensus among pediatricians that pregnant mothers and young children should avoid pesticide exposure during critical windows of development. However, the general population should follow this advice as the effects of pesticide exposure can affect every individual. Beyond Pesticides tracks the most recent studies on pesticide exposure through the Pesticide Induced Diseases Database (PIDD). This database supports the need for strategic action to shift away from pesticide dependency. For more information on the multiple harms of pesticide exposure, see PIDD pages on learning/developmental disorders, Birth/Fetal Effects, Sexual and Reproductive Dysfunction, Body Burdens, and other diseases. Additionally, learn more about the hazards to children’s health through Beyond Pesticide’s Pesticide and You Journal article, “Children and Pesticides Don’t Mix.”

Fortunately, the wide availability of non-pesticidal and nontoxic alternative strategies allows for choices in residential and agricultural management to promote a safe and healthy environment, especially among chemically vulnerable individuals. For instance, buying, growing, and supporting organic land management reduces human and environmental contamination from pesticides. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices. Numerous studies find that pesticide metabolite levels in urine significantly decrease when switching to an all-organic diet. For more information on how organic is the right choice for consumers and the farmworkers that grow our food, see the Beyond Pesticides webpage on the Health Benefits of Organic Agriculture.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Frontiers in Public Health

(Beyond Pesticides, January 25, 2024) Legislative efforts to curtail some life-threatening pesticides associated with birds and bees (and other pollinators) decline were weakened in New York State at the end of December 2023 as the governor negotiated and stripped elements of a bill relating to agriculture that had passed the legislature—again illustrating the grip of the agrichemical industry on public policy intended to begin to address the crisis in ecosystem collapse. (See “Study Cites Insect Extinction and Ecological Collapse.”) In passing the Birds and Bees Protection Act, New York joined New Jersey, Nevada, and Maine in banning most nonagricultural uses of neonicotinoid (neonic) insecticides, but, in last-minute changes to avoid the governor’s veto, failed to phase out corn, soybean, and wheat seeds coated with these chemicals. [Pointing to an exemption in federal law that has been challenged by advocates, the U.S. Environmental Protection Agency (EPA) does not regulate treated or coated seeds as pesticides despite their toxic pesticidal properties.] In New York State, the governor can, in consultation with the leadership of the legislative branch, negotiate language changes (called Chapter Amendments) in legislature-passed legislation (originally enacted) before deciding to sign it into law or can simply choose to veto the legislation. In the case of S. 1856-A and A. 7640, the Birds and Bees Protection Act, the governor stripped out major legislative advances and crafted a negotiation process for determining the status of coated seed use that runs through 2029. [Note: The changes can be seen in the linked (above) line-edited version of the new law—green text is law and red text is the originally enacted legislation.]

“Clearly, while the Senate and Assembly of New York State recognize the importance of removing from the agricultural market seeds coated with deadly pesticides that are wreaking havoc with the ecosystem at a crucial time when scientists have warned us about ecosystem collapse, the governor is playing politics with environmental systems essential to sustaining life,” said Jay Feldman, executive director of Beyond Pesticides. “The delay and waiver provisions for continued ecosystem-toxic chemical use through 2029 and beyond unfortunately do not meet the challenge of our time to eliminate petrochemical pesticides that are known to be harmful and unnecessary in light of the availability of productive and profitable organic agricultural practices,” Mr. Feldman continued, saying, “These chemicals are the poster children for a failed EPA pesticide regulatory process.” Like New York, state and local governments are increasingly stepping in to restrict pesticides given what they view as inadequate protection from EPA.

Advocates note that the major difference between the originally enacted Birds and Bees Protection Act and the governor-amended law is the stripping out of unequivocal statutory mandates that are intended to force institutional change to meet a crisis—and their replacement with language deferential to regulatory bodies with a history of advancing pesticide dependency. Agencies like these that are given broad discretionary power (and thus under pressure from those regulated) tend to maintain the status quo. The fact that the law signed by the governor opens the door to the regulation of seeds coated with ecosystem-toxic pesticides is in theory an important step. However, advocates argue that key to addressing the life-threatening petrochemical pesticide threats of the current day are statutory mandates that are unequivocal in eliminating known toxics without broad waiver provisions and are implemented in reasonable time frames with a serious investment in alternatives practices and products.

Starting January 1, 2027, New York will join Nevada, New Jersey, and Maine, with the strongest state laws that eliminate all outdoor (nonagricultural) uses of bee-toxic neonicotinoid (neonic) insecticides, except for outdoor uses around structures for structural pests. Previously, New York Department of Environmental Conservation (NY DEC) took action to limit certain products containing the neonicotinoid (neonic) insecticides imidacloprid, thiamethoxam, and acetamiprid by reclassifying their use to “restricted use,” meaning applications were limited to trained pesticide applicators in specific situations. In 2023, Minnesota banned neonicotinoid use on state lands and granted its home-rule subdivisions the authority to ban “pollinator-lethal pesticides” (those with bee warning labels) under its state law, which otherwise preempts local authority to restrict pesticides.

An analysis of the Birds and Bees Protection Act can be divided into two parts, its restrictions on residential and agricultural use. In the area of typical residential use, the bill incorporates language, adopted in numerous states across the U.S., that prohibits people generally from applying five neonicotinoids and related compounds (clothianidin, imidacloprid, thiamethoxam, acetamiprid, and dinotefuran). A provision added by the governor exempts from the law ”structural commercial applications within one foot of a building foundation perimeter to manage structural pests provided that the application is not conducted on any blooming plant.” Because the neonicotinoids are systemic pesticides that move through the vascular system of plants and because of the adverse impact of the chemical on soil organisms, this provision has broad implications for destructive ecosystem exposure. The language contains a one-year (without restrictions on renewals) use exemption for an “environmental emergency,” which is defined as “an occurrence of any pest which presents a significant risk of harm or injury to the environment. . . , including, but not limited to, any exotic or foreign pest.” The Department of Environmental Conservation (DEC) is required to determine efficacy of the neonicotinoid to be used and make a finding that “no other, less harmful pesticide or pest management practice would be effective in addressing the environmental emergency.” Certified applicators, or those operating under their supervision, are permitted to use the chemicals on “invasive species affecting woody plants.”

On the agricultural provisions, delayed until 2029, DEC, in consultation with the Department of Agriculture and Markets, is given broad mandated authority to promulgate any appropriate regulations” in implementing a two-year renewable waiver  “to sell, offer for sale or use, or distribute within the state any corn, soybean or wheat seeds coated or treated” with clothianidin, imidacloprid, thiamethoxam, or any other neonicotinoid as determined by the department in regulation. The originally enacted legislation included two related compounds, acetamiprid and dinotefuran, whose uses in agriculture will continue under the law. Prerequisites for the waiver include: farm owners must complete an integrated pest management (IPM) training and complete a “pest risk assessment” and report. Agricultural uses are also covered by the “environmental emergency” provision cited above in the case of “significant harm, injury, or loss to agricultural crops.” Advocates point out that chemical-intensive agriculture that ignores ecosystem services leads to crops threatened with “significant harm” from pests and disease and a cycle of chemical dependency to sustain yields. In this context, statutory support is needed to assist farmers in getting off the chemical treadmill to eliminate reliance on neonicotinoids and other pesticides. Otherwise, emergency provisions like that in the law will be triggered repeatedly.

Recordkeeping for coated seed use is required and subject to DEC review. This waiver process dramatically changes the originally enacted version of the bill, which provided for a temporary one-year waiver period only in the case of a finding by the DEC and Department of Agriculture and Markets that untreated seeds are not commercially available or the purchase of untreated seeds “would result in undue financial hardship to agricultural producers.” Commercial availability clauses in law tend to incentivize the market to increase availability of the alternative to the banned chemical, so the expectation is that the language jettisoned by the governor would have increased the market for untreated seed.

The fingerprints of the agrichemical industry on this bill, although obvious throughout, is especially clear in the deletion of the “State University of New York College of Environmental Science and Forestry” (according to their website: “focused on the study of the environment, developing renewable technologies, and building a sustainable future”) from the list of consultants on a mandated alternatives study. The law requires the DEC and Department of Agriculture and Markets “to identify practicable and feasible alternatives” to the use of clothianidin, imidacloprid, thiamethoxam, dinotefuran, or acetamiprid, only with the New York state’s land grant university.

As reported in the Wellsville Sun, New York State Farm Bureau President David Fisher lauded Governor Hochul for the changes she negotiated to the legislation, stating that “the new legislation is a product of good faith negotiations between NY agricultural interests and the Governor.” Despite scientific findings of no benefit associated with treated soybean seed (see here and here), the ranking member of the Senate Agriculture Committee said the bill “dealt another blow to struggling New York farmers,” saying that seed treatment technology has “helped farmers optimize crop yield and quality.” 

The longest-running—four-decade—investigation comparing organic and conventional grain-cropping approaches in North America is reporting impressive results for organic. The Rodale Institute’s Farming Systems Trial—40-Year Report, released in 2022, highlighted these outcomes: (1) organic systems achieve 3–6 times the profit of conventional production; (2) yields for the organic approach are competitive with those of conventional systems (after a five-year transition period); (3) organic yields during stressful drought periods are 40% higher than conventional yields; (4, 5, and 6) organic systems leach no toxic compounds into nearby waterways (unlike pesticide-intensive conventional farming), use 45% less energy than conventional, and emit 40% less carbon into the atmosphere. Beyond Pesticides reported in 2019 on similar results, from the institute’s 30-year project mark, which have been borne out by another three years of trials. (See Daily News.)

For additional discussion on the importance of ecosystem health and organic agriculture, view a talk by David Goulson, PhD, and André Leu, DSc, at the 40^th National Forum, Forging a Future with Nature.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Birds and Bees Protection Act, S. 1856-A and A. 7640

(Beyond Pesticides, January 24, 2024) A study published in Environmental Sciences Europe finds that 2,4-D, pyrethroid (PRY), and organophosphate (OP) pesticides increase the risk of cancer through oxidative stress (OS). The study highlights that pesticides that increase cancer risk also raise inflammation biomarkers that indicate damage to organs (e.g., liver) via oxidative stress. Additionally, different cancers show different sensitivities to pesticides; thus, cancer risk changes with exposure concentration and pattern. Despite a plethora of studies linking cancer and pesticide exposure, very few cover the mechanisms involved in cancer development, including OS.

Only five to ten percent of cancers are hereditary. However, environmental or lifestyle factors, like chemical exposure, can make an individual more susceptible to cancer development through gene mutation. In fact, a vast amalgamation of research links cancer risk to pesticide exposure, which augments the risk of developing both common and rare cancers. Therefore, studies like this highlight the importance of understanding how pesticide use can increase the risk of latent diseases, which do not readily develop upon initial exposure.

Using data from the National Health and Nutrition Examination Survey (NHANES), researchers investigated the link between the risk of several cancers and pesticide exposure. The researchers also thoroughly evaluated the mechanism’s impact on cancer development and oxidative stress. The study focuses on six types of cancers: breast, colon, cervical, prostate, melanoma, and non-melanoma skin cancer. Individuals who have cancer were the case group, while individuals without cancer were the control. To determine pesticide exposure, researchers measured the concentration of pesticide metabolites in urine, with the most detectable being used in the study, including metabolites of OPs (oxypyrimidine [diazinon], paranitrophenol [parathion], and dichlorovnl-dimeth prop carboacid [dichlorvos]), pyrethroids (4-fluoro-3-phenoxybenzoic acid, 3-phenoxybenzoic acid), and 2,4-D. From blood samples, oxidative stress measurements used eight biological markers (biomarkers), and inflammatory measurements used two biological markers. The results find that each pesticide increases the risk of at least three of the six cancers. Markers for oxidative stress from pesticide exposure, including iron, aspartate aminotransferase (AST—an enzyme found in the liver, muscle, and other organs), and gamma-glutamyl transferase (GGT—another enzyme found in the liver and throughout the body), have a positive association with cancer risk.

The connection between pesticides and associated cancer risks is not a new finding. Many pesticides are “known or probable” carcinogens (cancer-causing agents), and widespread uses only amplify chemical hazards, adversely affecting human health. Several studies link pesticide use and residue to various cancers, from the more prevalent breast cancer to the rare kidney cancer, nephroblastoma (Wilms’ tumor). Sixty-six percent of all cancers have links to environmental factors, especially in occupations of high chemical use. At least 45 different cancers have associations with work-related chemical exposure. Although the link between agricultural practices and pesticide-related illnesses is stark, over 63 percent of commonly used lawn pesticides and 70 percent of commonly used school pesticides have links to cancer. Many cancer-causing substances are endocrine disruptors, directly affecting traditional endocrine glands and their hormones and receptors (e.g., estrogens, anti-androgens, thyroid hormones) while greatly influencing hormone cancer incidents among humans (e.g., unrein, breast, prostate, and thyroid cancers). Moreover, several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with hormone-related cancer risk. 

All chemicals in this study produce different biological markers of oxidative stress, and the concentrations of oxidative stress biological markers can indicate an increased risk of cancer. Many of the study’s patients with cancer had a history of exposure to 2,4-D, PYRs, and OPs (like parathion), with prostate cancer being the most significant. However, the oxidative stress biological marker AST demonstrated an increased cancer risk of colon, prostate, breast, and cervical cancers among patients exposed to 2,4-D and melanoma, prostate cancer, and breast cancer among patients exposed to the OP diazinon. This study considers the role oxidative stress from pesticide exposure plays a role in cancer development, highlighting how previous studies tend to focus on the endocrine-disrupting effects of pesticide exposure on cancer development. Discovering additional mechanisms involved in pesticide-mediated cancers can give researchers a holistic understanding of disease risk from chemical exposure.

There is a limited understanding of the etiology of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiological data. Exposure to pesticides can increase the risk of developing chronic illnesses. Cancer is one of the leading causes of death worldwide, with over eight million people succumbing to the disease every year. Notably, IARC predicts an increase in new cancer cases from 19.3 million to 30.2 million per year by 2040. Therefore, studies related to pesticides and cancer will aid in understanding the underlying mechanisms that cause the disease. Consequently, it is essential to understand the health implications of pesticide use and exposure for humans, particularly when pesticides increase chronic disease risk. Beyond Pesticides tracks the most recent news and studies on pesticides and related topics through the Daily News Blog and Pesticide-Induced Diseases Database (PIDD). For more information on the adverse effects of pesticides on human health, see PIDD pages on cancer, endocrine disruption, and other diseases.

Moreover, proper prevention practices, like buying, growing, and supporting organics, can eliminate exposure to toxic pesticides. Organic agriculture has many health and environmental benefits, as it curtails the need for chemical-intensive agricultural practices. Regenerative organic agriculture nurtures soil health through organic carbon sequestration, preventing pests and generating a higher return than chemical-intensive agriculture. For more information on why organic is the right choice, see the Beyond Pesticides webpage, Health Benefits of Organic Agriculture. 

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Environmental Sciences Europe

(Beyond Pesticides, January 23, 2024) Earlier this month, a coalition of over 140 local and state elected officials from over 30 states sent a letter to ranking members of the House and Senate Agriculture committees to reject the proposed Agricultural Labeling Uniformity Act (H.R. 4288), which would preempt local governments’ authority to protect their constituents from toxic pesticides. Members of Congress are negotiating language in the Farm Bill that would preempt local and state authority to restrict pesticides.

“We write to express our strong opposition to any efforts to limit longstanding state and local authority to protect people, animals, and the environment by regulating pesticides,” says the signatories. “As Congress considers legislation related to agriculture, including the reauthorization of the Farm Bill and Fiscal Year 2024 appropriations bills, we urge you to ensure that state, county, and local governments retain the right to protect their communities and set policies that best suit our local needs.”

The question of local rights to adopt more stringent restrictions on pesticide use has historically been left to the states. However, after the U.S. Supreme Court (Wisconsin v. Mortier, 1991) affirmed the rights of local communities under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), most states stepped in to take away local pesticide control authority. However, multiple state legislatures have been grappling with state preemption reform with mixed results, including in Colorado, Illinois, Wisconsin, and West Virginia, underscoring what advocates see as an important citizen-led advocacy movement to hold elected officials in state legislatures accountable to the local democratic process.

In 2023, Illinois successfully passed SB 171, establishing the Pesticide Application at Schools Act (PASA). PASA prohibits schools “serving students grades kindergarten through 8th grade… from scheduling pesticide applications on school grounds during the school day, including during a partial day, when students are in attendance at school for instructional purposes.” This is a big change to state policy that did not enforce any requirements for pesticide spraying within school zones. PASA will enter into force starting July 1^st, 2024.

Last year, the Wisconsin legislature deliberated over several legislative items that would expand exemptions to state law that currently prevent local pesticide ordinances. Senate Bill 359 and Assembly Bill 358 would provide an additional exemption permitting local governments to prohibit pesticide spraying “for the purpose of protecting pollinator or pollinator habitats.” Senate Bill 322 and Assembly Bill 289 would permit local governments to ban pesticide use on private lawns. These bills did not get to a vote and expired as the 2024 legislative session begins, but they both represent a decades-long commitment by local elected officials to regulate pesticide use under their jurisdictions. Pesticide industry group Responsible Industry for a Sound Environment (RISE), an agrichemical industry-aligned association, sued Dane County back in December 2005 (See court finding.) over its decision to institute a ban on the use of synthetic lawn fertilizers that contain phosphorus due to its pollution of local lakes—what is considered the restricted the use of “weed and feed” products that combine synthetic fertilizers and herbicides. The U.S. 6th Circuit Court of Appeals upheld Dane County’s fertilizer ordinance in December 2005, finding that the law does not preempt local authority to regulate fertilizers containing pesticides. Jurisdictions in states that preempt local authority to restrict pesticides can in most cases institute synthetic fertilizer restrictions that limit “weed and feed” products containing pesticides.

Colorado legislators recently failed to reverse state preemption when enacting Senate Bill 192, allowing the state to continue preventing counties from issuing pesticide ordinances, rules, and actions through 2034. A similar move had previously failed to authorize local governments to regulate pesticides at the county level in 2020.  

Democracy is under attack in West Virginia with the rushed passage of SB 171, which would prevent county commissions from setting more stringent standards, ordinances, rules, or other actions that “prohibits the purchase, or alters the permissible use or application, of any federally or 40 state-registered pesticide, herbicide, or insecticide product.” The Senate Bill was initially introduced in the 2023 legislative session but failed because it was held up in the House of Delegates Judiciary Committee. State senators reintroduced the bill on the first legislative day of the 2024 calendar year and voted unanimously in favor just two days later without going through the Senate Agriculture and Natural Resources Committee, disregarding any input from local elected officials. The Charleston Gazette-Mail interviewed Hardy County officials, including Commissioner Steven Schetrom, who expressed his concerns “about the implications of this bill.” Mr. Schetrom hopes to continue discussions with state elected officials before the next vote so “that the key decision makers are able to make choices that lead to the best health outcomes for West Virginians.” West Virginia had previously adopted preemption of local pesticide control authority in its state pesticide law.

Was Congress not supposed to pass the Farm Bill in 2023? History seems to repeat itself as yet another continuing resolution (CR) passed last week to keep the government from shutting down in March. This has significant implications for the fate of the preemption regulatory paradigm that stifles community ownership of their own health outcomes. Please see “Pesticide Lobby Pushes Farm Bill Amendment to Strip Localities and States From Restricting Pesticides” on the legacy of federal deference of pesticide management to state agencies through the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). This article discusses the impact of state preemption language on the longstanding legacy of local governments to regulate related issues, including dog waste and trash cleanup.

Local governance of pesticide regulation has been vital to community health because of concerns such as pesticide drift from private to public land. Beyond Pesticides has extensively explored the heightened impact of chemical exposure to sensitive populations, including children, pregnant women, and immunocompromised individuals. There is a history of studies tying pesticide drift to increased rates of childhood leukemia, neurodevelopmental challenges, and various forms of cancer. Pesticide drift into riverways, groundwater, and soil has also jeopardized the health of birds, amphibians, and tropical mammals.

Beyond Pesticides has provided numerous resources on the history of insidious state preemption efforts conducted by the petrochemical industry. Some of these resources include a detailed map of distinctions between all 50 states and their relevance to state lawn pesticide notification laws. There are also many ways to act that are proven to mobilize grassroots momentum. The recently released letter represents the culmination of community leaders such as you who successfully reached out to public officials through a previous call to action to protect local democracy in the upcoming Farm Bill. You can still share these resources with your elected officials in the lead-up to the Farm Bill.

There is still time to contact your U.S. Representative or Senator directly to oppose inclusion in the Farm Bill of the Agricultural Labeling Uniformity Act (H.R. 4288), which would amend FIFRA to mandate, “uniformity in national pesticide labeling, and prohibit any State, instrumentality or political subdivision thereof, or a court from directly or indirectly imposing or continuing in effect any requirement… different from the labeling or packaging approved by the Administrator.” Rather than treat FIFRA as the minimum level of protection guaranteed by the federal government, H.R. 4288 provisions would alter the standards to treat FIFRA language as a ceiling for pesticide management under the guise of concern over labeling consistency.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Environmental Working Group

(Beyond Pesticides, January 22, 2024) Today, Monday, January 22, is the last day for public comment on a three-year extension of U.S. Department of Agriculture’s (through its Agricultural Marketing Service’s National Organic Program (NOP)) authority to collect information from certifiers entrusted with ensuring compliance with organic standards. Beyond Pesticides, along with allied organizations and organic advocates, is urging USDA to use this process to clarify the need for USDA to collect key information needed to verify compliance with key language in OFPA (Section 6513(b))—a provision that requires farming practices that “foster soil fertility.”

Advocates maintain that information on organic farmers’ practices to foster soil fertility, required in the law, is critical to organic integrity, public trust in the organic label, and certifier responsibility. As USDA states, “The Organic Foods Production Act of 1990 (OFPA), as amended (7 U.S.C. 6501–6524), authorized the Secretary of Agriculture to establish the National Organic Program (NOP) and accredit certifying agents to certify that farms and businesses meet national organic standards. Under OFPA, the purpose of the NOP is to: (1) establish national standards governing the marketing of certain agricultural products as organically produced products; (2) assure consumers that organically produced products meet a consistent standard; and (3) facilitate interstate commerce in fresh and processed food that is organically produced (7 U.S.C. 6501).”

Advocates cite a failure of NOP to consistently require the collection of information on soil-building practices for certification of organic farms, which they say presents a serious threat to organic integrity and compliance with organic law. As a result of this failure, some growers using hydroponic and other practices that do not build the soil are allowed to sell produce as organic. And, consumers are not able to distinguish growing practices because produce is not required to be labeled as “hydroponic” or “container-grown.”

Organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on environmentally beneficial methods such as green manure, crop rotation, and biological pest management.

Tell USDA to protect organic integrity and follow organic law by fostering soil fertility for ALL organic labeled products.

The Earth needs many more real organic farms that support soil health, help sequester carbon dioxide, and avoid the use of materials like soluble nitrogen fertilizers that contribute many times as much warming potential as carbon dioxide. By a decisive vote in 2010, the USDA National Organic Standards Board determined that hydroponic and aquaponic operations are inconsistent with OFPA and do not qualify for organic certification.

At the present time, the NOP accredits certifying agents that certify soil-based crop producers who comply with the soil fertility requirements of OFPA and regulations. Simultaneously, the NOP accredits certifying agents that certify hydroponic, container, and other soilless crop production systems that do not comply with the soil fertility requirements of OFPA and NOP regulations.

Soil-based organic production systems sequester carbon, fix nitrogen, build soil health, increase the water-holding capacity of soils, prevent soil erosion, foster the cycling of resources, promote ecological balance, conserve biodiversity and provide numerous ecological services. Hydroponic, aquaponic, and other soilless container growing systems do not sequester carbon, fix nitrogen, increase the water-holding capacity of soils, recycle nutrients, prevent erosion, enhance biological diversity, or protect ecological balance, yet the USDA currently allows such operations to be certified “organic.”

There are significant differences between soil-based and soilless crop production systems, but there is no data available to determine how much of the U.S. organic market is comprised of the products from these two different production systems, since the products of both systems are labeled “organic” and allowed to carry the “USDA Organic” logo. Likewise, USDA has no data to research and compare the environmental and health impacts of these systems, since the products of both systems are labeled the same.

This comment period provides an opportunity to tell USDA that its failure to require data that can support an organic farm’s compliance with the soil-building requirements of OFPA undermines organic consumers’ trust in the integrity of the organic market.

Tell USDA to protect organic integrity and follow organic law by fostering soil fertility for ALL organic labeled products.

Letter to USDA, National Organic Progam

The Earth needs many more real organic farms to support soil health, help sequester carbon dioxide, and avoid the use of materials that contribute many times as much warming potential as carbon dioxide. USDA’s failure to require information to ensure consistent application of the Organic Foods Production Act (OFPA) threatens the integrity of organic products upon which I depend.

At 6513(b)(1), OFPA states, “An organic plan shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” OFPA 6513(g) states, “An organic plan shall not include any production or handling practices that are inconsistent with this chapter.”

NOP now accredits certifying agents that certify soil-based crop producers who comply with the soil fertility requirements of OFPA 6513(b)(1) and 7 CFR sections 205.2, Natural Resource Protection; 205.203 Soil Fertility and Nutrient Management; and 205.205 Crop Rotation. NOP also accredits certifying agents that certify hydroponic, container, and other soilless crop producers who do not comply with those same requirements.

Soil-based organic production systems sequester carbon, fix nitrogen, build soil health, increase the water-holding capacity of soils, prevent soil erosion, foster the cycling of resources, promote ecological balance, conserve biodiversity, and provide numerous ecological services, while hydroponic, aquaponic, and other soilless container growing systems do not, yet USDA allows such operations to be certified “organic.”

Despite significant differences between soil-based and soilless crop production systems, USDA has no data to determine or research how much of the U.S. organic market is comprised of the products from these two different production systems, since the products of both systems are labeled “organic” and allowed to carry the “USDA Organic” logo and compare the environmental and health impacts of these systems.

NOP must collect data on the type of production system used by certified organic crop producers to determine the number of soil-based vs soilless crop production operations and products, both foreign and domestic, that are being certified as “organic” under NOP. Accredited certifying agents must ask specific questions to assess all crop operations’ compliance with OFPA 6513(b)(1), since the law states that organic crop plans “shall contain provisions designed to foster soil fertility.”

In order to “assure consumers that organically produced products meet a consistent standard,” NOP must require that accredited certifying agents who certify hydroponic, aquaponic, and other soilless container systems provide data to NOP—and make it publicly available—on the number of such operations that they certify; the amount of acreage or square footage in soilless production; the types and quantities of crops produced using soilless production methods; the expected vs actual yields from soilless operations; the value of the crops produced using soilless production methods; the labels and brand names used on all such products; the countries of origin; and the markets where these products are sold.

The U.S. is the only country where soilless crop production systems are being certified as “organic,” so collection of the information cited above is needed to verify compliance with trade agreements in international organic markets. 

USDA has issued no rules governing the soilless production of “organic” crops, so it is incumbent on USDA to collect accurate and detailed information on both soil-based and soilless crop production systems that are being certified as “organic,” in order to comply with OFPA Sections 6501(2), 6513(b), and 6513(g), and 7 CFR Part 205.2, 205.203, and 205.205.

Thank you.

Source: Notice of Intent to Extend and Revise a Previously Approved Information Collection (2024)
Document ID: AMS-NOP-23-0052-0001

(Beyond Pesticides, January 19, 2024) A study published in Environmental Health Perspective is one of the first to indicate a link between exposure to the herbicides 2,4-D and glyphosate and the impairment of behavioral performance (i.e., attention/inhibitory control, memory/learning, language, visuospatial processing, and social perception). These adverse effects associated with the neurotoxic impacts of pesticides on behavior have been previously documented. For example, a study in August 2023 finds oral intake (e.g., eating contaminated foods), inhalation, and dermal exposure to glyphosate lowered cognitive function scores, increased the likelihood of severe depressive symptoms, and impaired auditory (hearing) function. Although previous studies find neurotoxic effects from exposure to these herbicides, very few until now have evaluated how this neurotoxic exposure impacts neurotypical behavior among youth (children and teenagers).

The ubiquitous use of glyphosate and 2,4-D use in agriculture—which leaves residues of the toxic chemicals in food and in public areas (e.g., parks and walkways) creates a creates a significant risk for exposure. Glyphosate is already implicated in or proven to lead to the development of numerous health anomalies, including cancer, while 2,4-D also has a range of potential hazards, including cancer. Therefore, studies like this help local and government officials make holistic decisions regarding the use of pesticides that adversely affect human health, especially among adolescents.

Principal investigator José Ricardo Suarez-Lopez, MD, PhD, associate professor at the Herbert Wertheim School of Public Health and Human Longevity Science at the University of California, San Diego (UCSD), expresses the importance of studying these pesticides for other effects like hormone disruption, mental health, inflammation, and additional health systems, and says, “Our study will allow us to evaluate the toxicity potential of these and other chemicals assessed from childhood through adulthood.”

The neurological system, including the brain, spinal cord, and a vast network of nerves and neurons, is responsible for many bodily functions—from behavior to movement. However, pesticides play various roles in causing or exacerbating adverse health outcomes, including neurotoxic effects and chemical damage to the brain. Numerous pesticides impair neurological function, especially for chronically exposed individuals (e.g., farmworkers) or during critical windows of vulnerability and development (e.g., childhood, pregnancy).

The study evaluates 519 adolescent individuals between the ages of 11 and 17 years, living in Ecuadorian agricultural communities for concentration of glyphosate, two N, N-diethyl-meta-toluamide (DEET), 2,4-D, and their metabolites (breakdown products) in urine samples. Upon collection of samples, researchers also assess the neurobehavioral performance of the adolescent participants through five areas: attention/inhibitory control, memory/learning, language, visuospatial processing, and social perception. Overall, glyphosate is detectable in 98.3 percent of participant urine samples, 2,4-D in 66.2 percent of participants, and DCBA (the metabolite of DEET) in 63.3 percent of participants. Although DEET lacks an association with neurobehavioral performance in this study, 2,4-D and glyphosate are negatively associated with neurobehavioral performance. 2,4-D has the highest association with negative neurobehavioral performance for all five areas, with the most significant impacts on attention/inhibition control, language, and memory/learning, respectively. On the other hand, glyphosate only has a significant negative association with social perception. Unlike previous studies, these chemicals do not impact neurobehavioral differences among gender and adrenal hormone function.

Glyphosate is the most commonly used active ingredient worldwide, appearing in many herbicide formulations and readily contaminates soil, water, food, and other resources. Decades of extensive glyphosate herbicide use (e.g., Roundup) have put human, animal, and environmental health at risk. Four out of five U.S. individuals over six years of age have detectable levels of glyphosate in their bodies. Exposure to glyphosate has implications for the development of various health issues, like cancer, Parkinson’s disease, developmental and birth disorders, and autism. Although the U.S. Environmental Protection Agency (EPA) classifies glyphosate herbicides as “not likely to be carcinogenic to humans,” stark evidence demonstrates links to various cancers, including non-Hodgkin lymphoma. EPA’s classification perpetuates adverse impacts, especially among vulnerable individuals, like pregnant women, infants, children, and the elderly. Like glyphosate, 2,4-D is ubiquitous in the environment from decades of extensive use in agricultural and residential areas. Current research describes a range of serious hazards from 2,4-D exposure, including the International Agency for Research on Cancer (IARC) finding that the chemical is a possible human carcinogen (e.g., soft tissue sarcoma and non-Hodgkin lymphoma). Moreover, exposure to 2,4-D can cause neurotoxic health issues like the development of amyotrophic lateral sclerosis (ALS) and loss of smell, as well as kidney/liver damage and endocrine disruption. The U.S. Environmental Protection Agency (EPA) finds babies born near areas of high 2,4-D use, such as farming communities, have higher rates of birth abnormalities, respiratory and cardiovascular issues, and developmental defects.

Although glyphosate replaced much 2,4-D herbicide use during the late 1990s and early 2000s, increasing glyphosate resistance is shifting the market back to heavy 2,4-D use. However, 2,4-D has striking similarities to glyphosate with growing weed resistance to the chemical and its contribution to the growth of antibiotic resistance in human pathogenic bacteria. Scientists even note 2,4-D’s similarities to glyphosate as the commercial formulation presented more severe health outcomes than the technical grade or pure chemical alone. Moreover, products containing glyphosate and 2,4-D to combat growing herbicide resistance are becoming increasingly popular, as 2,4-D, like glyphosate, has become integral to genetically engineered crops. Considering the agricultural industry is now heading toward multi-herbicide-tolerant cropping systems, public and environmental health is at greater risk from chemical input threats from this cropping system.

This study is among the first to find a significant association between negative neurobehavioral performance and the two herbicides 2,4-D and glyphosate among youth. This research also highlights an increased rate of toxic body burden among adolescents, especially as prior studies note adolescents have higher bodily concentrations of glyphosate than adults, a significant concern for the onset of chronic disease. Moreover, studies like this are essential because 2,4-D and glyphosate are often formulated together in the market herbicide products. This study highlights that combined concentrations of 2,4-D and glyphosate are associated with worsened neurobehavioral performance among all five areas (i.e., attention/inhibitory control, memory/learning, language, visuospatial processing, and social perception). However, the researchers urge further assessments of herbicide mixtures’ joint (synergistic) effects among various pediatric and adult populations.

There is a lack of complete understanding of the etiology of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiological data. Pesticides themselves can possess the ability to disrupt neurological function. Pesticides’ effect on the brain is mainly of concern for chronically exposed individuals or during critical windows of vulnerability and development. Therefore, studies related to pesticides and neurological disorders can help scientists understand the underlying mechanisms that cause neurodegenerative diseases. Although occupational and environmental factors, like pesticide exposure, adversely affect human health, regulatory reviews are plagued by numerous limitations in defining real-world poisoning, as captured by epidemiologic studies in Beyond Pesticides’ Pesticide-Induced Diseases Database (PIDD) and Daily News Blog. Pesticides’ adverse health effects, exposure, and aggregate or cumulative risk showcase a need for a precautionary approach to regulating pesticides, as more precise research is conducted on occupational and residential pesticide exposure—allowing more complete determinations. Existing information, including this study, supports the clear need for a strategic shift away from pesticide dependency. For more information on the effects of pesticide exposure on neurological health, see Beyond Pesticides’ PIDD pages on brain and nervous system disorders and other impacts on cognitive function. 

Organic agriculture represents a safer, healthier approach to crop production that does not necessitate pesticide use. Beyond Pesticides encourages farmers to embrace regenerative, organic practices, consumers to purchase organic, and gardeners and municipalities to adopt organic land management practices. A complement to buying organic is contacting various organic farming organizations to learn more about what you can do. 

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Environmental Health Perspective (study), Environmental Health Perspective (article)

(Beyond Pesticides, January 18, 2024) Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. A study published by researchers at Columbia and Rutgers universities (see article in the Proceedings of the National Academy of Sciences, January 2024) reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million tiny plastic pieces, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Last December, researchers at Norway’s MicroLEACH project published a study that analyzes the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys and balloons. (See summary.)

The researchers found, like in previous studies, that many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products. This suggests that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown.

Like pesticides, plastics—mostly derived from fossil fuels—are exerting a heavy drag on the health of ecosystems and human beings. An estimated 8,300 million metric tons have been created since plastic production skyrocketed during World War II. Annual global production of plastic has reached 400 million metric tons, according to one estimate, with some 13,000 chemicals used in their manufacture, of which only one percent is regulated. In a January report, Consumer Reports, in The Plastic Chemicals Hiding in Your Food, reports that, “Our tests of nearly 100 foods found that despite growing evidence of potential health threats, bisphenols and phthalates remain widespread in our food.” Key among the chemicals found in plastics are plasticizers (most commonly phthalates used to increase flexibility and softness) and bisphenols (including BPA used in can liners, bottle caps, and water bottles). Phthalates and BPA are endocrine disruptors, linked to developmental problems and cancer. In improving organic production and processing to address current use of plastic, Beyond Pesticides has called for an end to use of plastics in certified organic.

Recent concern has turned to microplastics, including those at nanoscale—measuring billionths of a meter, or 70 times smaller than the width of a human hair. Microplastics are tiny particles broken up and ground very fine by natural processes like friction and heat. Their small size enables easy travel in air and water. Nanoplastics are now distributed over the entire globe. They are found in sandy beaches and in ocean sediments, as fibers floating in the stratosphere, in bottled water, and in the tissues of living creatures. Whereas numerous adverse effects of fossil-derived pesticides and plastic exposures at the macroscale are relatively well known, very little research has focused on those of microplastics.

The rapid spread of macroscale plastic trash has been unintentional. But agricultural and pharmaceutical interests are also intentionally researching nanoscale materials, including plastics, as the next big thing in their respective technological revolutions. Development of nanomaterials to distribute pesticides and deliver drugs and other medical treatments is proceeding at breakneck pace with very little oversight or public awareness. Agricultural and medical innovators see mostly the wondrous applications nanomaterials promise, but seem unaware of the risks.

Most plastics are polymers—long chains of often identical or very similar smaller molecules called monomers. Humans naturally make a number of polymers, including collagen, DNA and fibrinogen. The molecular structure of a polymer makes it flexible and able to maintain structural integrity under mechanical stress. Synthetic polymers also have those qualities, which is why plastic is so popular. One medical review of nanomaterials described polymers optimistically as “biocompatible, biodegradable, non-toxic, and popular in medical applications such as drug delivery, wound plug dressings, stents, and tissue engineering.”

Nanoplastics are attractive to pesticide proponents as a way to increase bioavailability, reduce product degradation, and increase water solubility. Timed release of the pesticide from the nanoparticle can be controlled, and some methods can make release contingent on exposure to light. These qualities are presented as advantages and purportedly reduce the amount of pesticide needed to control pests, helping the pesticide “exhibit extended pest control capabilities.”

Of course, while pesticide volume may be reduced using nanoparticle delivery, the payload is still usually a highly toxic substance derived from fossil fuels. Further, little is known about how the delivery medium, especially plastic, will affect the environment, but there is already evidence that micro- and nanoscale plastics can increase the toxicity of some pesticides. They can also carry other contaminants into the bodies of organisms, a process called the “Trojan horse effect.” Studies of micro- and nanoplastics have shown associations with damage to genes, neurotransmission, development and reproduction, feeding, and predatory competence.

Policymakers have yet to face up to the presence of nanoplastics leaching from packaging into many other products. The process of leaching begins as soon as a plastic is exposed to water—but because the plastic particles are so small, they go undetected by consumers.

In the Columbia/Rutgers study, the researchers checked for seven types of plastic, but they were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. (Tap water also contains microplastics in many places, although in much lower concentrations.) The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.” The Norwegian scientists also exposed cod eggs, embryos and larvae to water containing microplastics. The toxic effects they observed include spinal deformities reminiscent of scoliosis in humans.

Beyond Pesticides covered a 2022 Danish study of reusable plastic sports bottles. The researchers tested two groups of plastic bottles: one set of newly purchased bottles and another of bottles that had been used for about a year, with a control group of glass bottles. They rinsed the new bottles with tap water and discarded it before refilling with tap water and storing for 24 hours. Next they ran all the bottles through a dishwasher for an hour, during which the water temperature reached about 150 degrees Fahrenheit. Finally, they put all the bottles through two more rounds of rinsing, refilling and storing for a day.

The results were dramatic. When they tested the final stored water, they found more than 400 substances associated with the plastic and more than 3,500 dishwashing compounds. Water from the new bottles held 350 unique chemicals, 230 of which were removed by the dishwasher and by rinsing. The used bottles contained 3,436 chemicals, about two-thirds of which were removed by dishwashing. It was clear that the dishwashing produced far more leached chemicals than simply rinsing with tap water and left an enormous residue of its own chemicals. In addition to the expected chemicals from the plastic and the dishwasher soap, the researchers found a number of chemicals they were unable to precisely identify and had never been reported in plastic.

There are many other problems inherent in nanoscale materials that should act as red flags in the development of nanoscale pesticides and their modes of delivery. Nanoscale objects have some qualities owing to their physical characteristics and others stemming from their chemistry. In fact, one group of researchers proposed that nanoscale plastics in the environment must be treated as distinct from both natural and engineered nanomaterials because of their “high particle heterogeneity and their potential for rapid further fragmentation in the environment. These characteristics impact environmental fate, potential effects on biota and human health, sampling and analysis.”

Nanoscale objects can go anywhere. In the environment, plastic clothing fibers spread even farther and faster than spherical particles. When inhaled, nanoplastics can penetrate lung and intestinal tissue and reach the circulatory system quickly. They can cross the blood-brain barrier, one of the strongest protections the body provides to protect the brain. They can also travel up the olfactory nerve from the nose to the brain.

3-D printing is a prime example of the failure to anticipate and control nanoplastic exposure. In many high-end research and manufacturing contexts, a variety of materials such as metal powders are used to build machines and parts according to specified digital instructions. But down at the low end of the cost spectrum, consumer 3-D printers use primarily ABS plastic: Acrylonitrile-butadiene-styrene filaments. There are even plastic children’s 3-D printers printing ABS plastic objects. Each component of ABS plastic is a either a known or probable carcinogen in its own right. Further, ABS, like most plastics, is a mixture rather than a compound of its ingredients, meaning the components are not chemically bonded and are easily separated. In 3-D printers, ABS heats up enough to separate into its component parts. The 3-D process releases nanoscale particles into the room unless the printer is enclosed, which many are not. In the best-case scenario, the nanoscale plastic particles are vented to the outside air.

Another problem with nanomaterials is their surface area. The smaller something is, the more surface area it has compared to its volume. Thus, a nanoparticle of a pesticide or a nanoparticle of a plastic medium for pesticide delivery will have much greater surface area than a macroscale unit. This makes nanoparticles much more chemically reactive than macroscale materials. The chemical reactivity of nanomaterials may be one reason why the studies discussed above found so many unidentified chemicals in water and water bottles.

The Norwegian researchers tested whether it was the shape and size of the particles or their chemistry that was responsible for the damage to their aquatic test animals. They exposed the cod to particles of the same shape and size but without known toxic effects and found that with plastics, it is definitely the chemistry that does the damage. Flexible plastics and combinations of toxic compounds seemed to have the worst effects.

There are a few lights on the horizon hinting that we may eventually be able to capture and render harmless the trillions of tons of plastic already blanketing the globe. In 2022, for the first time, the United Nations Environment Assembly adopted a resolution entitled “End plastic pollution: Towards an international legally binding instrument.” The Assembly hopes to reach a final agreement by the end of this year. In April 2023 the U.S. EPA produced a similar Draft National Strategy to Prevent Plastic Pollution.

A major step forward both nationally and internationally would be a public policy and legal structure that would prevent the chemical industry from merely making small changes to problematic formulas and declaring the result a new, safe chemical. The Endocrine Society published a statement on the UN resolution noting that once bisphenol A (BPA) was shown to be an endocrine disrupter, the industry switched to bisphenol B and several other closely related compounds, resulting in what became a “regrettable substitution” that was not an improvement on the original problem.

Mother Nature may eventually provide a little help. Knowable Magazine reports that there are numerous efforts around the world to develop enzymes, insects, and bacteria into useful ways to cope with the Sorcerer’s Apprentice plague of plastics threatening human and ecosystem survival.

In the meantime, let your elected officials know that the combined problem of pesticides and plastics stems from the vast use of fossil fuels, that organic agriculture can feed the world without these scourges, and that it is past time to regulate them honestly. See Beyond Pesticides webpage on organic agriculture, as well as our advocacy efforts to continually improve organic standards at our Keeping Organic Strong page.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Sources: Researchers surprised at levels of toxicity in standard plastic products, Christina Benjaminsen, Norwegian University of Science and Technology, https://phys.org/news/2023-12-toxicity-standard-plastic-products.html; MicroLEACH (Microplastics – Long-term Effects of plastics and Additive Chemicals on marine organisms), https://www.niva.no/en/projects/microleach; Bottled water can contain hundreds of thousands of previously uncounted tiny plastic bits, study finds A new microscopic technique zeroes in on the poorly explored world of nanoplastics, which can pass into blood, cells and your brain COLUMBIA CLIMATE SCHOOL, https://www.eurekalert.org/news-releases/1030312; Exposure to petroleum-derived and biopolymer microplastics affect fast start escape performance and aerobic metabolism in a marine fish,  https://www.sciencedirect.com/science/article/pii/S0048969723060503?via%3Dihub; The living things that feast on plastic https://knowablemagazine.org/content/article/food-environment/2023/how-to-recycle-plastic-with-enzymes, The Global Plastics Treaty: An Endocrinologist’s Assessment Marina Olga Fernandez, Leonardo Trasande, https://academic.oup.com/jes/article/8/1/bvad141/7420190.

(Beyond Pesticides, January 17, 2024) Science continues to find a link between mental health and occupational (work-related) chemical exposure, with a study published in Toxicology finding an increased risk of depression among farmers exposed to pesticides. Conventional, chemical-intensive farming is a profession notorious for higher-than-average pesticide exposure occurrences, thus explaining why the study concludes that individuals within this occupation can suffer from chemically induced oxidative stress, inflammation, and lower education-based cognition that exacerbate depressive symptoms. However, besides psychological symptoms, the study indicates potential physiological issues from pesticide exposure, such as renal (kidney) and hepatic (liver) issues. Studies like this one can directly pinpoint risks of developing depression, especially among agricultural workers and landscapers who use pesticides.

Usually, research on pesticide-induced diseases commonly investigates pesticide exposure concerning the development of various physical illnesses. However, previous studies show that occupational risks of developing depression are high in agriculture, where pesticide use is rampant. Acute exposure to chemicals, including organophosphate, organochlorine, triazine, and carbamate pesticides, tends to put farmers at greater risk of suicide than the general population. There is a lack of information connecting pesticide exposure to the subsequent psychological (psychiatric) effects on the general population.

Although the etiology of depression—and many other psychiatric disorders—is often genetic, studies suggest that other etiological factors, like pesticide exposure, play a role in depression incidents. Poor mental health has a tangible influence on physical health (e.g., depression and cardiovascular disease); therefore, the combination of pesticide exposure and mental illness worsens the adverse effects on human health. Since pesticide exposure can exacerbate psychiatric symptoms, it is essential to evaluate how pesticide exposure affects mental health in addition to physical health. This research highlights the significance of researching potential mental health detriments resulting from pesticide exposure, especially as society tends to rank mental health risks second to physical health. 

The study notes, “…[T]he impact of occupational pesticide exposure on the mental health of rural workers… [the] underuse of PPEs [personal protective equipment] and the link between depressive symptoms, inflammation, and oxidative stress underscore the urgent need for improved safety measures in agricultural practices. Addressing these issues will contribute to a deeper understanding of the intricate relationship between environmental exposures and mental health outcomes.”

The study assesses the oxidative and inflammatory profiles and mental health of Brazilian farmers exposed to pesticides and compares the results to the control group lacking occupational exposure to pesticides. Researchers gathered data on sociodemographic factors (i.e., age, race, ethnicity, language, economic status), work history, and medical records. Using the State-Trait Anxiety Inventory (STAI) and Beck Depression Inventory (BDI), the researchers evaluate emotional states to determine mental health status. Researchers collected blood samples from the participants to measure redox (oxidative) and inflammatory profiles. The physiological results identify that BDI scores are higher among the pesticide-exposed group (farmers), with these individuals experiencing more severe cases of depression. Physically, the same farmers have increased lipid peroxidation and superoxide dismutase activity, among other oxidative stress markers, and elevated levels of inflammatory signaling cells (cytokines) indicating inflammation. The study notes that the herbicide glyphosate is the most commonly used pesticide among farmers, which may play a role in elevating the enzyme levels in the liver and kidneys of pesticide-exposed participants. Additionally, the results highlight a particularly stark issue concerning the underuse of PPE among farmers and the disparity in education among farmers. Education is pivotal in fostering safety practices, comprehending technical information about pesticide handling, and using PPE.

Within the past two and a half decades, research concerning pesticide exposure and psychiatric disorders, such as depression, has grown, especially for farmworkers. Exposure to agricultural pesticides puts farmers at a six times greater risk of exhibiting depressive symptoms, including chronic anxiety, irritability, restlessness, and sadness. For instance, exposure to organochlorines and fumigants (highly toxic, gaseous pesticides) heighten an individual’s risk of depression by 90% and 80%, respectively. Linear models reveal an association between lifelong pesticide poisoning episodes and the increased risk of developing mental disorders among tobacco farmers, with farmers using organophosphate pesticides (notorious for neurotoxicity) having a higher prevalence of minor psychiatric disorders. Although individuals suffering from occupational pesticide exposure face a disproportionate risk of developing depression, pesticide exposure from nearby agricultural fields remains a threat to residential (nonoccupational) human health. Previous studies find that populations living near farms are more likely to have high depressive symptoms. Similarly, a 2019 study found that teens and adolescents living in agricultural areas, where organophosphate exposure is prevalent, are at higher risk of depression. Uniquely, gender (female), physical health, and age (young adult) indicate the likelihood of having depressive symptoms, with the most adverse effects on women, those in poor physical health, and children under 14. Regardless of pesticide exposure frequency, duration, intensity, type, and location, the development of depression symptoms remains of concern.

The study highlights the interplay of multiple factors contributing to the prevalence of depression among pesticide-exposed farmers. Despite the study location being in Brazil, the results have implications for farmers across the globe, especially in regions where pesticide policies and practices do little to protect workers. Understanding the mental health implications of conventional pesticide exposure can help identify the various physiological mechanisms attributed to psychiatric disorders. Notably, this study calls for the continued investigation of pesticide neurotoxicity mechanisms and the association between mental health disorders. This and other studies indicate that farmers and those in agricultural communities are at disproportional risk of mental health problems due to pesticide use. Therefore, the study advocates “for comprehensive strategies to improve the mental and physical well-being of rural workers exposed to pesticides, including education, preventive measures, and ongoing research efforts to safeguard the health of those who play a vital role in our agricultural communities.”

Mental health is just as—if not more–important than physical health, and reviews such as this highlight the importance of knowing pesticide implications beyond physical ailments. According to the World Health Organization (WHO), depression affects 322 million people globally, with the number of diagnosed patients increasing by 18.4% from 2005 to 2015. Annually, only half of Americans with a depression diagnosis seek treatment for symptoms. Untreated symptoms of depression can increase the risk of suicide, a severe sign of depression. Commonalities between occupational and household pesticide exposure are suicidal thoughts and pesticide provocation as a suicide agent. WHO scientists recognize pesticide self-poisoning as one of the most significant global methods of suicide, as increases in pesticide toxicity make them potentially lethal substances. 

Beyond Pesticides tracks the most recent news and studies related to pesticide exposure through our Daily News (DN) Blog and Pesticide Induced Diseases Database (PIDD). For more information on the multiple harms of pesticides, see our DNs on Pesticides and Depression and PIDD pages on brain and nervous system disorders, endocrine disruption, and other diseases.  Additionally, buying, growing, and supporting organic can help eliminate the extensive use of pesticides in the environment. It also reduces demand for toxic pesticides in areas where farmer suicides are alarmingly high. Coupled with evidence from past studies that link pesticide exposure to suicidal ideations and depression, even in developed countries, this research strongly supports a ban on toxic pesticides in favor of organic practices. Our choices encourage the protection of the people who help put food on our table daily by purchasing organic products. For more information on how organic is the right choice for consumers and the farmworkers that grow our food, see the Beyond Pesticides’ webpage, Health Benefits of Organic Agriculture. 

Lastly, suicide is the tenth leading cause of death among adults (3rd for adolescents) in the U.S., with more than 34,000 individuals succumbing to the disease annually. Suicidal thoughts and behaviors are dangerous and harmful and are therefore considered a psychiatric emergency. An individual experiencing these thoughts should seek immediate assistance from a health or mental health care provider. If you or someone you know is in an emergency, call the National Suicide Prevention Lifeline at 1-800-273-TALK (8255) or 911 immediately.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Toxicology

(Beyond Pesticides, January 16, 2024) The U.S. Environmental Protection Agency (EPA) has long been criticized for its failure to evaluate the effectiveness (or efficacy) of all the pesticides it registers. A petition, for which there is now an open public comment period (submit comments by January 22, 2024), challenges what advocates call a basic failure of the agency to evaluate the claimed benefits of pesticides. Because of this long-standing situation, those who purchase pesticides do not know that the pesticides they buy will meet expectations for control. For farmers, that means that EPA has not evaluated whether the pesticide’s use actually increases productivity of the treated crops and/or whether over time the target pest (weed, insect, fungus) will become resistant. For consumers, it also means that there is not an independent analysis of whether the pesticide products work. As EPA implements the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), not only is there no agency assessment of whether the pesticide’s use will achieve its intended purpose, there is not a determination as to whether there is a less toxic way of achieving the pest management goal.

As Beyond Pesticides cited last year, a piece published in the Proceedings of the National Academy of Sciences Journal (2020) sums it up well: “[N]eonicotinoid [widely used insecticide] exposure is far higher than necessary to achieve plant protection and yield objectives. Neonicotinoid seed coatings rarely improve crop yield, and neonicotinoids are applied preventively to vast areas of turf, which cover more land in the United States than any other irrigated crop, even when pests are absent or below thresholds. . . . Risks to many terrestrial, aquatic, and detrital organisms and ecosystems have been documented. Considering these risks, advocacy groups have frequently promoted outright bans on all neonicotinoids in all circumstances, and this stance seems easy to justify.” Nearly ten years agon, “Heavy Costs—Weighing the Value of Neonicotinoid insecticides in Agriculture” (Center for Food Safety, 2014) concluded that, “EPA should suspend all existing registrations of neonicotinoid seed treatment products whose costs and benefits have not been adequately weighed until this accounting is completed.

The petition open for public comment is requesting the adoption of rules that require efficacy data be submitted for systemic insecticides by manufacturers registering these pesticides with EPA.   

>>EPA must require submission of efficacy data and make findings based on evidence that benefits outweigh risks before registering a pesticide.

Petitioners ask that manufacturers of neonicotinoids (neonics) or other systemic insecticides be required to prove that they work as intended and do not “subject species, ecosystems, and people to abject devastation with no benefit to users.” In fact, Section 3(c)(5) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires that EPA determine whether the pesticide will perform its intended function, when used “in accordance with widespread and commonly recognized practice,” without “unreasonable adverse effects on the environment.” “Unreasonable adverse effects on the environment” means “any unreasonable risk to man or the environment, taking into account the economic, social, and environmental costs and benefits of the use of any pesticide.” 

The petitioners submit support for their contention that systemic insecticides are not effective and that they cause widespread harm to the environment, including birds, honey bees, aquatic ecosystems, and wildlife. The petition says, “The species impacted include all amphibians, and the majority of endangered fish, birds, and mammals, as well as pollinators and the plants they pollinate.”  

The petitioners also point to results showing lack of benefits—including a report by EPA’s Biological and Economic Analysis Division (BEAD) showing that systemic insecticides generally do not provide benefits when used to protect soybeans. 

Thus, the petitioners make a case that registration should be denied to these systemic insecticides, since FIFRA Section 3(c)(6) requires EPA to deny registration if “the Administrator determines that the requirements of paragraph (5) for registration are not satisfied.” 

But how can EPA make any determination without efficacy data? The petitioners say that because the case they make shows that systemic insecticides do not meet the criteria for registration, EPA must request efficacy data for those pesticides. However, the same is true for all pesticides. EPA cannot meet the statutory prerequisite for registration without weighing data on both risks and benefits. Instead, as pointed out by the petitioners, EPA says, “rather than require efficacy data the Agency presumes that benefits exceed risks.” 

In 2021, a coalition of groups, including PEER and Beyond Pesticides, issued a scathing critique of the performance of EPA’s Office of Pesticide Programs — embedded in the groups’ advocacy for a series of 25 reforms. The petition tackles one specific aspect of EPA’s process on one class of insecticides. The agency’s track record, on so many pesticides, is to deal with one compound (under a narrow range of circumstances and/or narrow time frame and/or specific exposure levels) at a time. Beyond Pesticides has dubbed this the “whack-a-mole” struggle on pesticides. 

Each regulatory baby step at EPA represents small, incremental advances on a pesticide problem that is vast in scope—an approach that is wholly inadequate to the devastation that toxic pesticides are causing, and it continues the “collision course” we are on re: human health and well-being, biodiversity collapse, and the climate crisis. A precautionary approach—captured in organic, regenerative agriculture and land management protocols—is far more suited to the task of genuinely protecting public health and the environment than EPA’s current, industry-friendly, piecemeal approach. 

The availability of alternative materials and practices that prevent (or vastly reduce) toxic hazards, as are used in organic management, makes the dependence on synthetic chemical pesticides even more reprehensible. A genuinely protective approach to pests (floral or faunal) in agriculture and land management starts with transitioning from chemical dependency to organic land management in food production, and parks, playing fields, and all recreational and public spaces. In the meantime, efforts to push EPA will continue to move the needle, however slowly and haltingly. EPA should take seriously its mission: to protect human health and the environment. 

>>EPA must require submission of efficacy data and make findings based on evidence that benefits outweigh risks before registering a pesticide.

The target for this Action is the U.S. Environmental Protection Agency via Regulations.gov.  

Letter to EPA

I am writing to support the petition  asking that manufacturers of neonicotinoids (neonics) or other systemic insecticides be required to prove that they work as intended and do not “subject species, ecosystems, and people to abject devastation with no benefit to users.” In fact, Section 3(c)(5) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires that EPA determine whether the pesticide will perform its intended function, when used “in accordance with widespread and commonly recognized practice,” without “unreasonable adverse effects on the environment.” “Unreasonable adverse effects on the environment” means “any unreasonable risk to man or the environment, taking into account the economic, social, and environmental costs and benefits of the use of any pesticide.”

It has been shown that systemic insecticides are not effective in soybean production and that they cause widespread harm to the environment, including birds, honey bees, aquatic ecosystems, and wildlife. The petition says, “The species impacted include all amphibians, and the majority of endangered fish, birds, and mammals, as well as pollinators and the plants they pollinate.” The petitioners point to results showing lack of benefits—including a report by EPA’s Biological and Economic Analysis Division (BEAD) showing that systemic insecticides generally do not provide benefits when used to protect soybeans.

Thus, the petitioners make a case that registration should be denied to these systemic insecticides, since FIFRA Section 3(c)(6) requires EPA to deny registration if “the Administrator determines that the requirements of paragraph (5) for registration are not satisfied.”

But how can EPA make any determination without efficacy data? The petitioners say that because the case they make shows that systemic insecticides do not meet the criteria for registration, EPA must request efficacy data for those pesticides. The same is true for all pesticides. EPA cannot meet the statutory prerequisite for registration without weighing data on both risks and benefits. Instead, as pointed out by the petitioners, EPA says, “rather than require efficacy data the Agency presumes that benefits exceed risks.”

Each regulatory baby step at EPA represents small, incremental advances on a pesticide problem that is now vast in scope—an approach that is wholly inadequate to the devastation that toxic pesticides are causing, and it continues the “collision course” we are on re: human health and well-being, biodiversity collapse, and the climate crisis. A precautionary approach — captured in alternatives like organic, regenerative agriculture and land management protocols — is far more suited to the task of genuinely protecting public health and the environment than EPA’s current, industry friendly, piecemeal approach. This approach is viable under the “unreasonable adverse effects” standard of review under FIFRA.

The availability of alternative materials and practices that prevent (or vastly reduce) toxic hazards, as are used in organic management, makes the dependence on synthetic chemical pesticides even more reprehensible and “unreasonable.” A genuinely protective approach to pests (floral or faunal) in agriculture and land management starts with transitioning from chemical dependency to organic land management in food production, and parks, playing fields, and all recreational and public spaces. In the meantime, the petitions request for efficacy review will push the pesticide registration review process to move the needle, however slowly and haltingly. EPA should take seriously its mission: to protect human health and the environment.

Thank you for your consideration of these comments.

(Beyond Pesticides, January 12, 2024) As we commemorate Dr. Martin Luther King Jr.—an inspiration for taking on the challenges of justice, equity, and safety as a central part of all our work for a sustainable future—through a day that stands for equality, justice, and the pursuit of a better world, it is crucial to reflect on issues that impact the health and well-being of communities. One such issue that echoes the spirit of Dr. King’s vision is the pervasive use of pesticides and the associated health risks. Drawing insights from prior articles on Beyond Pesticides’ Daily News, we delve into the intersection of environmental justice, public health, and the ongoing struggle for a safer and healthier world. 

The Invisible Threat with Visible Consequence: Pesticides and Health. 

Beyond Pesticides sheds light on the hidden dangers of pesticide exposure and the disproportionate impact it has on marginalized communities. Communities of color and economically disadvantaged areas bear a heavier burden of pesticide exposure, leading to higher rates of health issues, including respiratory problems, developmental disorders, and certain cancers.  From agricultural workers to residents of low-income neighborhoods, the adverse health effects of pesticides are not evenly distributed. The use of pesticides without adequate consideration for their health impacts constitutes a form of environmental injustice. This resonates with Dr. King’s vision of equity, as these communities often face the brunt of environmental injustices. Dr. King said, “Injustice anywhere is a threat to justice everywhere.”  

Connecting the Dots: MLK’s Legacy and Environmental Advocacy.  

Dr. King’s legacy extends beyond civil rights, encompassing a vision of justice that encompasses all aspects of life. The Beyond Pesticides article underscores the importance of connecting MLK’s teachings with environmental advocacy. By advocating for alternatives to harmful pesticides and promoting sustainable practices, we honor Dr. King’s call for justice and equality. 

Community-Led Initiatives for Social Justice. 

Community-led initiatives featured on Beyond Pesticides’ blog, where individuals and groups have taken the initiative to address pesticide-related health risks. From local activism to policy advocacy, these stories showcase the power of grassroots movements in effecting positive change, aligning with Dr. King’s belief in the strength of communities to drive transformation. 

Beyond Pesticides works to advance systemic change seeks to identify underlying policies that codify dispropor­tionate harm, such as federal pesticide law that is built on a foundation that allows elevated and disproportionate risk to workers. They are excluded from EPA’s cumulative risk assessment (under the Food Quality Protection Act amendments to the Fed­eral Food, Drug and Cosmetic Act and the Federal Insecticide, Fungicide, and Rodenticide Act), which aggregates dietary and non-dietary, but explicitly not occupational, exposure to pesticides, while in­cluding a mandate to protect children. With this, the law effectively requires EPA to allow higher rates of harm for workers, particularly farmworkers, land­scapers (workers who are disproportionately people of color), and others occupationally exposed to pes­ticides. In response, Beyond Pesticides is reimagin­ing legislative proposals that effect a transformation to an organic society that eliminates toxic pesticides, respects the complexity of life and the ecosystems that sustain us, and put an end to institutional biases that codify environmental racism.  

Beyond Pesticides also works with grassroots groups, like The Black Institute and other grassroots organizations, across the nation to ban toxic pesticides in city, town, and county parks, playgrounds, and playing fields, as part of an organic transition. Children and people of color face disproportionate harm from pesticide exposure. To make matters worse, the hazards associated with the toxic chemicals inflict multi-generational diseases like diabetes, asthma and respiratory illness, and learning disabilities. 

Educating: A Cornerstone of Change.  

Here are some of the pieces covered by Beyond Pesticides over the last year that paint a stark picture of disproportionate harm to people of color, translating to a pattern of injustice that must be corrected in the adoption of a transformative path forward. 

—A study published on April 18 finds that people in U.S. BIPOC (Black, Indigenous and People of Color) communities, as well as those living in low-income communities, endure a very disproportionate rate of exposure to pesticides, and of subsequent risks of harm. It finds that such disparities exist in both urban and rural communities, and at all points in the pesticide “life cycle,” from manufacture to application. A section of Beyond Pesticides’ recent mega-issue of Pesticides and You, “Retrospective 2021: A Call to Urgent Action,” is devoted to such inequities. Section IV, “Disproportionate Pesticide Harm Is Racial Injustice: Documenting Victimization: Structural Racism,” reprises Beyond Pesticides’ 2021 coverage of environmental injustices. It also calls for urgent action re: federal and state “evaluations that go into toxic chemical regulation . . . to reform and replace the current regulatory decision-making process, which is empirically racist, with one that acknowledges and cares for those with the highest real-world vulnerabilities and exposure[s].” [See Black, Indigenous, and People of Color Community at Disproportionate Risk from Pesticides, Study Finds] 

On Juneteenth Day, we commemorate the abolition of slavery and celebrate human freedom. At the same time, we recognize that we have significant work to do to eliminate systemic racism and advance environmental justice. We strive to ensure that people of color are not disproportionately harmed by pesticides and other toxic chemicals—from production, use, to disposal—and that all people have access to sustainable and organic food and organically managed communities. Acute and chronic exposure to chemicals like pesticides cause a plethora of harmful effects, including (but not limited to) brain and nervous system disorders, birth abnormalities, cancer, developmental and learning disorders, endocrine disruption, immune disorder, and reproductive dysfunction, among others. However, people of color may experience more severe health effects from exposure, resulting in elevated rates of diseases. Communities of color and those living in low-socioeconomic conditions experience an inequitable number of hazards, including toxic waste plants, garbage dumps, and other sources of environmental pollution and odors that lower the quality of life. Therefore, these populations experience greater exposure to harmful chemicals and suffer from health outcomes that affect their ability to work and learn. When discussing health disparities and environmental justice, we need to focus on those most impacted by toxic chemical use. [See This Juneteenth, We Celebrate Those Who Made this Country] 

Beyond Pesticides’ Daily News serves as a valuable resource for educating individuals and communities about the risks associated with pesticides and the viability of organic practices that eliminate petrochemical pesticides and fertilizers. By empowering people with knowledge, we can foster a collective commitment to healthier alternatives and advocate for policies that prioritize both human health and environmental sustainability. 

As we reflect on Martin Luther King Jr. Day, it is crucial to recognize the interconnectedness of social justice, environmental advocacy, and public health. Beyond Pesticides’ Daily News provides a platform for understanding and addressing the health risks posed by pesticides, aligning with Dr. King’s vision of a just and equitable world. Let us draw inspiration from his teachings to work toward a future where everyone, regardless of their background, can enjoy the benefits of a healthy and sustainable environment. 

Beyond Pesticides continues to emphasize its commitment to advancing systemic change that can address the depth and extent of the institutional biases that allow environmental racism to continue, as well as the complexity of the “moving parts” of the food, health, environmental, and governance sectors that allow the persistence of disproportionate impacts. For example, campaigns to eliminate individual pesticides (or other chemicals) are insufficient to the gravity and extent of the threats; a precautionary approach and standards are needed to meet and remedy ongoing and escalating threats. 

We at Beyond Pesticides are looking forward to working with people and organizations in communities nationwide to tackle what often seems like insurmountable problems, but problems that have real solutions that are within our reach, when we tap into the power of working together. Please join, reach out, act locally and regionally, and — in honor of Dr. King — help build a healthy and thriving “network of mutuality, tied into a single garment of destiny” for all people. 

Thank you, Martin Luther King, Jr. 

Sign up for Beyond Pesticides Action of the Week and Weekly News Update to stay informed on these issues and take action. 

All unattributed positions and opinions in this piece are those of Beyond Pesticides.