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Action of the Week Archive

Action of the Week is intended to provide you, our supporters and network, with one concrete action that you can take each week to have your voice heard on governmental actions that are harmful to the environment and public and worker health, increase overall pesticide use, or undermine the advancement of organic, sustainable, and regenerative practices and policies. As an example, topics may include toxic chemical use, pollinator protection, organic agriculture and land use, global climate change, and regulatory or enforcement violations.

10/22/2021 — Tell EPA to Protect Endangered Species from Pesticides

The Environmental Protection Agency (EPA) is requesting public comments on its draft Biological Evaluations (BEs) for neonicotinoid insecticides imidacloprid, clothianidin, and thiamethoxam by 11:59 pm (EST) on Monday, October 25, 2021. The BEs will factor into EPA’s registration review decisions on the three bee-toxic insecticides. Written comments must be submitted through Regulations.gov. See Beyond Pesticides’ comments here.

>>Tell EPA to protect endangered species from pesticides.

EPA’s Biological Evaluations for these highly toxic chemicals make no agency conclusion or recommendation that would trigger a request to initiate formal Endangered Species Act (ESA) §7(a)(2) consultations with the U.S. Fish and Wildlife Service (USFWS) to determine a possible jeopardy finding for the listed species and requisite mandatory use restrictions of the relevant pesticide. This, despite the fact that for imidacloprid the agency’s draft Biological Evaluation made a May Affect determination for 89% of the 1821 species considered and 90% of the 791 critical habitats considered. Strikingly, a May Affect determination was made for 100% of amphibian and avian listed species and their critical habitat. It was also determined that imidacloprid is Likely to Adversely Affect 100% of the listed amphibian species exposed. The Biological Evaluation for each of the three neonicotinoids makes effects determinations—NE (no effect), MA (may affect), NLAA (not likely to adversely affect), or LAA (likely to adversely affect)—that could affect 1821 listed species, and 791 designated critical habitats.

These serious risk findings for endangered and threatened species made for imidacloprid, clothianidin, and thiamethoxam account for existing product labels and mitigation efforts. The Endangered Species Act requires, “Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency…is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species…”

The complete Biological Evaluations—with all determinations and species considered—must be included with the formal consultation request and not just the LAA determinations. This will allow USFWS to also corroborate the agency findings of NLAA and LAA as part of the consultation.

A No Effect determination was made for only 11% of listed species considered because these species have a limited geographic distribution and would likely not be exposed to imidacloprid under the existing label use and mitigation instructions. Thus, any species listed and exposed to imidacloprid is potentially adversely affected.         

For clothianidin, a similar May Affect determination was made for 86% of listed species considered and 83% of the critical habitats considered. Likely to Adversely Affect findings overall were made for 67% of listed species and 56% of critical habitats considered. As imidacloprid, 100% of listed amphibian species are likely to be adversely affected by clothianidin uses.

Thiamethoxam degrades to clothianidin and therefore shares similar fate and behavior in the environment. May Affect determinations were made for 88% of species and 89% of critical habitats considered. Likely to Adversely Affect findings overall were made for 77% of listed species and 81% of critical habitats considered. As reported for the other neonicotinoids, 100% of amphibian species and critical habitat are likely to be adversely affected.

EPA should also include the American bumble bee (Bombus pensylvanicus) in its revised Biological Evaluations for the neonicotinoid insecticides. Although this insect is not a currently listed species, the Fish and Wildlife Service has recently determined a petition including substantial scientific and commercial information indicating that listing the American bumble bee as an endangered or threatened species may be warranted. Bumble bee species are highly susceptible to neonicotinoid exposures and are likely jeopardized by continued use of these insecticides.

Must we wait until species are listed as threatened or endangered to protect them? Given the systemic character of neonicotinoids and their extreme toxicity to insects, EPA must assume that they will ultimately lead to the demise of insects that consume nectar, pollen, plant exudates, or plant tissues. The burden of proof is on the registrant(s) to demonstrate that these products will not further exacerbate the ongoing insect apocalypse—and lead to further biodiversity loss through decimation of this essential link in food webs.

Furthermore, EPA must use organic production as the standard against which pesticide “benefits” are weighed. Any crop that can be produced with chemical-intensive methods can be produced organically. Organic producers use very few synthetic pesticides and no neonicotinoids. Therefore, the potential jeopardy of extinction to the 1445+ species identified by these biological evaluations must be considered unreasonable under the definition in FIFRA.

EPA has determined unequivocally that neonicotinoids pose risks to the environment that cannot be acceptably mitigated in any long-term, sustainable way. The agency in its proposed interim decisions for these chemicals identifies several uses for imidacloprid and clothianidin that must be cancelled. However, EPA believes that the benefits of other uses outweigh these serious risks and is proposing limited or no mitigation measures. Given the frequency of detection in U.S. waterways, soil, and plants, the recognized acute and chronic risks posed to pollinators, aquatic invertebrates, vertebrate wildlife, and human health, the risk/benefit determination is pitifully insufficient, especially in light of the BEs identifying the majority of listed species as potentially jeopardized by these neonicotinoid insecticides. Therefore, EPA must quickly suspend all remaining neonicotinoid uses as it pursues the ESA §7(a)(2) consultations with the Services. Additional data to address existing uncertainties and gaps will not alter or lessen the environmental and health risks already unmistakably recognized.

>>Submit comments to EPA using Regulations.gov.

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste from the information above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)

10/18/2021 — Stop the Use of Toxic Pesticides in State Parks and Transition to Organic Land Management

The most recent science on pesticides raises serious health and environmental effects associated with pesticide use for lawn and landscape management. While the data is often not assembled in one place, updated factsheets bring together the science on the 40 commonly used pesticides used for conventional landscape management. Governors have the authority to stop the use of these hazardous materials that are used on parks and playgrounds, either by executive order or through their work with their state legislature, and transition land management to organic practices.

>>Tell your governor (mayor if you are in DC) to stop hazardous pesticide use on state lands and transition to organic land management.

The new factsheets document with scientific citations a wide range of diseases and ecological effects linked to pesticides. The underlying analysis supporting the adverse health and environmental effects identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases.

What do the factsheets disclose? Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects...

  • 26 are possible and/or known carcinogens
  • 24 have the potential to disrupt the endocrine (hormonal) system
  • 29 are linked to reproductive effects and sexual dysfunction
  • 21 have been linked to birth defects, 24 are neurotoxic
  • 32 can cause kidney or liver damage
  • 33 are sensitizers and/or irritants 

Regarding adverse environmental effects...

  • 21 are detected in groundwater
  • 24 have the ability to leach into drinking water sources
  • 39 are toxic to fish and other aquatic organisms vital to our ecosystem
  • 33 are toxic to bees, 18 are toxic to mammals
  • 28 are toxic to birds

In addition to the factsheets, Beyond Pesticides manages the Gateway on Pesticide Hazards and Safe Pest Management (Pesticide Gateway) and Pesticide-Induced Diseases Database to track the scientific literature and the federal and state regulatory process governing pesticides. Additionally, the organization manages a database, ManageSafe, to provide information on nontoxic methods for common pest management issues.

>>Tell your governor (mayor if you are in DC) to stop hazardous pesticide use on state lands and transition to organic land management.

The factsheets distill a large amount of scientific data. For example, the main chemical ingredient in “Roundup® — glyphosate — is the world's most widely used herbicide. The factsheet identifies glyphosate as a probable human carcinogen, based on findings from the World Health Organization's (W.H.O.) International Agency for Research on Cancer (IARC). Additionally, research has linked glyphosate to high rates of kidney disease in farming communities and to shortened pregnancy in a cohort of women in the Midwest. Animal studies and bioassays link it to endocrine disruption, DNA damage, decreased sperm function, disruption of the gut microbiome, and fatty liver disease. Glyphosate is also linked to environmental damage. The EPA warns that glyphosate can injure or kill 93% of U.S. endangered species. It is a primary driver of the decimation of monarch butterfly populations because it destroys the milkweed plants their young depend on. Recent research has also shown that glyphosate can disrupt honey bee gut microbiomes, affect larval development, increase colony vulnerability to pathogen infestation, reduce productivity, and impair honeybee navigation, linking the herbicide to declines in bee populations.

View the new factsheets for both Health and Environmental Effects of 40 commonly used lawn and landscape pesticides: Health Effects; Environmental Effects, as well as our infographic.

Letter to Governors

I am writing to urge you to use your leadership to require the management of our state parks with organic land management practices. My concern about the management of public spaces that are frequented by children and families, those with health vulnerabilities, pets, and wildlife stems from the hazardous nature of the pesticides that are commonly used. These adverse health and environmental effects are displayed in two easy-to-use factsheets, 40 Commonly Used Lawn Pesticides, available at bp-dc.org/lawnfactsheets. With this information, we urge you to issue an executive order to stop the use of these hazardous chemicals and transition park land to organic land management.

The new factsheets document with scientific citations a wide range of diseases and ecological effects linked to pesticides. The underlying analysis supporting the adverse health and environmental effects identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases.

What do the factsheets disclose? Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects, 26 are possible and/or known carcinogens, 24 have the potential to disrupt the endocrine (hormonal) system, 29 are linked to reproductive effects and sexual dysfunction, 21 have been linked to birth defects, 24 are neurotoxic, 32 can cause kidney or liver damage, and 33 are sensitizers and/or irritants. Regarding adverse environmental effects, 21 are detected in groundwater, 24 have the ability to leach into drinking water sources, 39 are toxic to fish and other aquatic organisms vital to our ecosystem, 33 are toxic to bees, 18 are toxic to mammals, and 28 are toxic to birds.
For more in-depth information on additional studies and regulatory information, please visit Beyond pesticides Gateway on Pesticide Hazards and Alternatives at bp-dc.org/gateway. And, the national organization, Beyond Pesticides, is offering to assist you and land managers of our state land to adopt organic land management practices. You can contact them at [email protected]

The factsheets distill a large amount of scientific data. For example, the main chemical ingredient in “Roundup® — glyphosate — is the world’s most widely used herbicide. The factsheet identifies glyphosate as a probable human carcinogen, based on findings from the World Health Organization’s (W.H.O.) International Agency for Research on Cancer (IARC). Additionally, research has linked glyphosate to high rates of kidney disease in farming communities and to shortened pregnancy in a cohort of women in the Midwest. Animal studies and bioassays link it to endocrine disruption, DNA damage, decreased sperm function, disruption of the gut microbiome, and fatty liver disease. Glyphosate is also linked to environmental damage. The EPA warns that glyphosate can injure or kill 93% of U.S. endangered species. It is a primary driver of the decimation of monarch butterfly populations because it destroys the milkweed plants their young depend on. Recent research has also shown that glyphosate can disrupt honey bee gut microbiomes, affect larval development, increase colony vulnerability to pathogen infestation, reduce productivity, and impair honeybee navigation, linking the herbicide to declines in bee populations.

Thank you for your attention to this critical public health and environmental issue. I look forward to your reply.

Letter to DC Mayor Muriel Bowser

I am writing to urge you to use your leadership to require the management of our DC parks with organic land management practices. My concern about the management of public spaces that are frequented by children and families, those with health vulnerabilities, pets, and wildlife stems from the hazardous nature of the pesticides that are commonly used. These adverse health and environmental effects are displayed in two easy-to-use factsheets, 40 Commonly Used Lawn Pesticides, available at bp-dc.org/lawnfactsheets. With this information, we urge you to issue an executive order to stop the use of these hazardous chemicals and transition park land to organic land management.

The new factsheets document with scientific citations a wide range of diseases and ecological effects linked to pesticides. The underlying analysis supporting the adverse health and environmental effects identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases.

What do the factsheets disclose? Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects, 26 are possible and/or known carcinogens, 24 have the potential to disrupt the endocrine (hormonal) system, 29 are linked to reproductive effects and sexual dysfunction, 21 have been linked to birth defects, 24 are neurotoxic, 32 can cause kidney or liver damage, and 33 are sensitizers and/or irritants. Regarding adverse environmental effects, 21 are detected in groundwater, 24 have the ability to leach into drinking water sources, 39 are toxic to fish and other aquatic organisms vital to our ecosystem, 33 are toxic to bees, 18 are toxic to mammals, and 28 are toxic to birds.
For more in-depth information on additional studies and regulatory information, please visit Beyond pesticides Gateway on Pesticide Hazards and Alternatives at bp-dc.org/gateway. And, the national organization, Beyond Pesticides, is offering to assist you and land managers of our state land to adopt organic land management practices. You can contact them at [email protected]

The factsheets distill a large amount of scientific data. For example, the main chemical ingredient in “Roundup® — glyphosate — is the world’s most widely used herbicide. The factsheet identifies glyphosate as a probable human carcinogen, based on findings from the World Health Organization’s (W.H.O.) International Agency for Research on Cancer (IARC). Additionally, research has linked glyphosate to high rates of kidney disease in farming communities and to shortened pregnancy in a cohort of women in the Midwest. Animal studies and bioassays link it to endocrine disruption, DNA damage, decreased sperm function, disruption of the gut microbiome, and fatty liver disease. Glyphosate is also linked to environmental damage. The EPA warns that glyphosate can injure or kill 93% of U.S. endangered species. It is a primary driver of the decimation of monarch butterfly populations because it destroys the milkweed plants their young depend on. Recent research has also shown that glyphosate can disrupt honey bee gut microbiomes, affect larval development, increase colony vulnerability to pathogen infestation, reduce productivity, and impair honeybee navigation, linking the herbicide to declines in bee populations.

Thank you for your attention to this critical public health and environmental issue. I look forward to your reply.

10/11/2021 — Reform or Whitewash? USDA Needs to Support Public Health and Biodiversity

>>Tell President Biden and Congress that there is no room for agriculture policies that are not in line with the Executive Memorandum and directive Modernizing Regulatory Review. USDA must remove all barriers to a national transition to organic agriculture.

One of President Biden's first actions, on the day of his inauguration, was the Executive Memorandum and directive Modernizing Regulatory Review, requiring the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This mandate should reverse the trend of regulatory review, which has so far protected the status quo, rather than advancing urgently needed change.

Why, then, do we see Secretary of the U.S. Department of Agriculture Tom Vilsack opposing moves in the direction laid out by the presidential directive? A recent Mother Jones article by Tom Philpott focuses on Mr. Vilsack's opposition to the “Farm to Fork” initiative in the European Union, which aims to “push the continent's agriculture in a healthier, more resilient direction, to reduce the use of toxic chemicals in farming, and encourage people to eat less meat.” 

As Mr. Philpott points out, “Vilsack's disdain for the EU's plan—which dates to last year when he worked as a dairy industry executive—cannot arise from a sense of U.S. superiority. Our diet-related public health troubles are deeper than Europe's; and climate change and widespread water pollution are ravaging our two most important farming regions, California's Central Valley and the Midwestern corn belt.”

Farm to Fork sets its sights on reducing reliance on polluting, energy-intensive agrochemicals by setting targets of reducing fertilizer use by 20% and pesticide use by 50% by 2030. It also calls for a 50% reduction in antibiotics in livestock—a major contributor to antibiotic resistance—and a reduction in red meat and processed food. These goals are eminently consistent with President Biden's goals as expressed in the Executive Memorandum. Is Secretary Vilsack out of step with his boss? Or is the directive just a whitewash concealing business as usual? For more background information, read our October 8 Daily News blog Ag Secretary Vilsack Pushes Petroleum Farming Inputs, Fights EU's Climate-Friendly Organic “Food to Fork' Initiative.

Mr. Philpott believes that clues lie in Mr. Vilsack's friendship with leaders of the United Arab Emirates (UAE) and Brazil. UAE, with its large reserves of oil and natural gas, provides the raw material for synthetic nitrogen fertilizer, a driver for chemical-intensive agriculture, as well as the basis for pesticide manufacture. Brazil is the world's third-largest user of pesticides (after China and the U.S.), is home to meatpacking giants JBS and Marfig that supply U.S. markets, and is known for its environmental and human rights abuses in transforming rainforests into industrial agriculture. UAE and Brazil may be ideal partners for promoting industrial agriculture, but their policies are antithetical to those advanced by the mandates issued by the president.

We urgently need a new direction for agriculture—one that moves toward organic agriculture and away from the use of pesticides, synthetic fertilizers, and abusive land practices. Mr. Vilsack should get with the president's agenda or get out!

>>Tell President Biden and Congress that there is no room for agriculture policies that are not in line with the Executive Memorandum and directive Modernizing Regulatory Review. USDA must remove all barriers to a national transition to organic agriculture.

Letter to President Biden

One of your first actions, on the day of your inauguration, was the Executive Memorandum and directive Modernizing Regulatory Review, requiring the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Directive should reverse the trend of regulatory review, which has so far protected the status quo, rather than advancing urgently needed change.

Why, then, do we see Secretary of the U.S. Department of Agriculture Tom Vilsack opposing moves in the direction laid out by the presidential directive? A recent Mother Jones article by Tom Philpott focuses on Mr. Vilsack’s opposition to the “Farm to Fork” initiative in the European Union, which aims to “push the continent’s agriculture in a healthier, more resilient direction, to reduce the use of toxic chemicals in farming, and encourage people to eat less meat.”

As Mr. Philpott points out, “Vilsack’s disdain for the EU’s plan—which dates to last year when he worked as a dairy industry executive—cannot arise from a sense of U.S. superiority. Our diet-related public health troubles are deeper than Europe’s; and climate change and widespread water pollution are ravaging our two most important farming regions, California’s Central Valley and the Midwestern corn belt.”

Farm to Fork sets its sights on reducing reliance on polluting, energy-intensive agrochemicals by setting targets of reducing fertilizer use by 20% and pesticide use by 50% by 2030. It also calls for a 50% reduction in antibiotics in livestock—a major contributor to antibiotic resistance—and a reduction in red meat and processed food. These goals are eminently consistent with your goals as expressed in the Executive Memorandum. Is Secretary Vilsack out of step with his boss? Or is the directive just a whitewash concealing business as usual?

Mr. Philpott believes that clues lie in Mr. Vilsack’s friendship with leaders of the United Arab Emirates (UAE) and Brazil. UAE, with its large reserves of oil and natural gas, provides the raw material for synthetic nitrogen fertilizer, a driver for chemical-intensive agriculture, as well as the basis for pesticide manufacture. Brazil is the world’s third-largest user of pesticides (after China and the U.S.), is home to meatpacking giants JBS and Marfig that supply U.S. markets and is known for its environmental and human rights abuses in transforming rainforests into industrial agriculture. UAE and Brazil may be ideal partners for promoting industrial agriculture, but their policies are antithetical to those advanced by the mandates issued by the president.

We urgently need a new direction for agriculture—one that moves towards organic agriculture and away from the use of pesticides, synthetic fertilizers, and abusive land practices. Mr. Vilsack should get with the agenda or get out!

Please insist that your Secretary of Agriculture moves USDA in the direction you set out in your Executive Memorandum, Modernizing Regulatory Review.

Thank you.

Letter to Congress

One of President Biden’s first actions, on the day of his inauguration, was the Executive Memorandum and directive Modernizing Regulatory Review, requiring the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Directive should reverse the trend of regulatory review, which has so far protected the status quo, rather than advancing urgently needed change.

Why, then, do we see Secretary of the U.S. Department of Agriculture Tom Vilsack opposing moves in the direction laid out by the Presidential directive? A recent Mother Jones article by Tom Philpott focuses on Mr. Vilsack’s opposition to the “Farm to Fork” initiative in the European Union, which aims to “push the continent’s agriculture in a healthier, more resilient direction, to reduce the use of toxic chemicals in farming, and encourage people to eat less meat.”

As Mr. Philpott points out, “Vilsack’s disdain for the EU’s plan—which dates to last year when he worked as a dairy industry executive—cannot arise from a sense of U.S. superiority. Our diet-related public health troubles are deeper than Europe’s; and climate change and widespread water pollution are ravaging our two most important farming regions, California’s Central Valley and the Midwestern corn belt.”

Farm to Fork sets its sights on reducing reliance on polluting, energy-intensive agrochemicals by setting targets of reducing fertilizer use by 20% and pesticide use by 50% by 2030. It also calls for a 50% reduction in antibiotics in livestock—a major contributor to antibiotic resistance—and a reduction in red meat and processed food. These goals are eminently consistent with President Biden’s goals as expressed in the Executive Memorandum. Is Secretary Vilsack out of step with his boss? Or is the Executive Memorandum just a whitewash concealing business as usual?

Mr. Philpott believes that clues lie in Mr. Vilsack’s friendship with leaders of the United Arab Emirates (UAE) and Brazil. UAE, with its large reserves of oil and natural gas, provides the raw material for synthetic nitrogen fertilizer, a driver for chemical-intensive agriculture, as well as the basis for pesticide manufacture. Brazil is the world’s third-largest user of pesticides (after China and the U.S.), is home to meatpacking giants JBS and Marfig that supply U.S. markets and is known for its environmental and human rights abuses in transforming rainforests into industrial agriculture. UAE and Brazil may be ideal partners for promoting industrial agriculture, but their policies are antithetical to those advanced by the mandates issued by the president.

We urgently need a new direction for agriculture—one that moves toward organic agriculture and away from the use of pesticides, synthetic fertilizers, and abusive land practices. Mr. Vilsack should get with the agenda or get out!

Please insist that the Secretary of Agriculture moves USDA in the direction set out in the president's Executive Memorandum, Modernizing Regulatory Review.

Thank you.

10/04/2021 — Tell EPA and Congress to Protect the Integrity of Minimum Risk Pesticides

Recent findings of high levels of toxic pesticides in products permitted to be used as “minimum risk pesticides” point to the need for greater oversight of these products and more severe penalties for violations. Pesticides classified as minimum risk are allowed under Section 25(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) [40 CFR 152.25(f)] to be used without going through EPA's pesticide registration process. These products are limited to a specific list of ingredients, and all ingredients, including “inert” ingredients, are required to be listed on the label. 

Minimum risk pesticides are used by organic growers, municipalities, and others who are not permitted to use, or choose to avoid, toxic chemicals. 

>>Tell EPA and Congress to protect the integrity of minimum risk pesticides.

Organic growers can lose their organic certification if they apply materials that are prohibited, which include the toxic ingredients glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl, found by the state of California in dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Contamination of these products came to light in late July, when the California Department of Food and Agriculture's (CDFA) State Organic Program issued a Stop Use Notice to farmers, alerting them to adulteration of Eco-MIGHT and W.O.W products. The California Department of Pesticide Regulation (the state's primary enforcement agent for pesticides) sent a warning letter to EcoMIGHT LLC, which produces both of the products in question, alerting them that they “may be in violation” of state law. EPA sent a similar advisory letter to the company indicating that it may be in violation of FIFRA by misbranding, selling an unregistered pesticide (given the presence of ingredients disallowed in 25(b) minimum risk products), and false and misleading label statements, which could make the company “subject to penalties of not more than $7,500 for each independently assessable violation.”

While these warning letters may be the first step in criminal enforcement action, they are inadequate to protect the organic farmers and other users who depend on the integrity of the products as represented by the company. The process for action is slow, the initial penalties are inconsequential, and real people will be hurt as a result. 

EPA must initiate better oversight over the manufacture and sale of minimum risk pesticides. It must take immediate action to stop sale of products misbranded as minimum risk pesticides. There must be real penalties—severe enough to incentivize against fraudulent practices—assessed against violators.

>>Tell EPA and Congress to protect the integrity of minimum risk pesticides.

Letter to EPA

Recent findings of high levels of toxic pesticides in products permitted to be used as “minimum risk pesticides” point to the need for greater oversight of these products and more severe penalties for violations. Pesticides classified as minimum risk are allowed under Section 25(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) [40 CFR 152.25(f)] to be used without going through EPA’s pesticide registration process. These products are limited to a specific list of ingredients, and all ingredients, including “inert” ingredients, are required to be listed on the label.

Minimum risk pesticides are used by organic growers, municipalities, and others who are not permitted to, or choose to avoid, toxic chemicals.

Organic growers can lose their organic certification if they apply materials that are prohibited, which include the toxic ingredients glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl, found by the state of California in dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Contamination of these products came to light in late July, when the California Department of Food and Agriculture’s (CDFA) State Organic Program issued a Stop Use Notice to farmers, alerting them to adulteration in Eco-MIGHT and W.O.W products. The California Department of Pesticide Regulation (the state’s primary enforcement agent for pesticides) sent a warning letter to EcoMIGHT LLC, which produces both of the products in question, alerting them that they may be in violation of state law. EPA sent a similar advisory letter to the company indicating that it “may be in violation” of FIFRA by misbranding, selling an unregistered pesticide (given the presence of ingredients disallowed in 25(b) minimum risk products), and false and misleading label statements, which could make the company “subject to penalties of not more than $7,500 for each independently assessable violation.”

While these warning letters may be the first step in criminal enforcement action, they are inadequate to protect the organic farmers and other users who depend on the integrity of the products as represented by the company. The process for action is slow, the initial penalties are inconsequential, and real people will be hurt as a result

EPA must initiate better oversight over the manufacture and sale of minimum risk pesticides. It must take immediate action to stop sale of products misbranded as minimum risk pesticides. There must be real penalties—severe enough to incentivize against fraudulent practices—assessed against violators. If penalties in FIFRA are not sufficient, then EPA should request Congress to increase the penalties.

Thank you for your consideration of this important issue.

Letter to Congress

Recent findings of high levels of toxic pesticides in products permitted to be used as “minimum risk pesticides” point to the need for greater oversight of these products and more severe penalties for violations. Pesticides classified as minimum risk are allowed under Section 25(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) [40 CFR 152.25(f)] to be used without going through EPA’s pesticide registration process. These products are limited to a specific list of ingredients, and all ingredients, including “inert” ingredients, are required to be listed on the label.

Minimum risk pesticides are used by organic growers, municipalities, and others who are not permitted to, or choose to avoid, toxic chemicals.

Organic growers can lose their organic certification if they apply materials that are prohibited, which include the toxic ingredients glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl, found by the state of California in dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Contamination of these products came to light in late July, when the California Department of Food and Agriculture’s (CDFA) State Organic Program issued a Stop Use Notice to farmers, alerting them to adulteration in Eco-MIGHT and W.O.W products. The California Department of Pesticide Regulation (the state’s primary enforcement agent for pesticides) sent a warning letter to EcoMIGHT LLC, which produces both of the products in question, alerting them that they may be in violation of state law. EPA sent a similar advisory letter to the company indicating that it “may be in violation” of FIFRA by misbranding, selling an unregistered pesticide (given the presence of ingredients disallowed in 25(b) minimum risk products), and false and misleading label statements, which could make the company “subject to penalties of not more than $7,500 for each independently assessable violation.”

While these warning letters may be the first step in criminal enforcement action, they are inadequate to protect the organic farmers and other users who depend on the integrity of the products as represented by the company. The process for action is slow, the initial penalties are inconsequential, and real people will be hurt as a result.

EPA must initiate better oversight over the manufacture and sale of minimum risk pesticides. It must take immediate action to stop sale of products misbranded as minimum risk pesticides. There must be real penalties—severe enough to incentivize against fraudulent practices—assessed against violators.

Congress must ensure that penalties in FIFRA are sufficient to eliminate abuse of Section 25(b).

Thank you for your consideration of this important issue.

09/27/2021 — Last Chance to Protect Organic this Fall—Submit Comments by September 30!

The National Organic Standards Board (NOSB) is receiving written comments from the public through September 30. This precedes the upcoming public comment webinar on October 13-14 and online meeting October 19-21—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov.

As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong (KOS) and the Fall 2021 issues page. In the spirit of “continuous improvement,” we urge you to submit comments (please feel free to use our comments on the KOS page) that contribute to an increasingly improved organic production system.

The Organic Foods Production Act (OFPA) requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. Among the issues up for consideration at this meeting is a material that the National Organic Program (NOP) has taken off the NOSB’s sunset agenda for several years—sodium nitrate. There are also issues affecting organic integrity that need to be addressed—systemic fraud and plastic—as well as decisions about other materials that are described on the Fall 2021 issues page. We earlier conducted an action on priority issues. The issues below add to the earlier list, if you have the time.

Sodium nitrate (aka Chilean nitrate) is a mined mineral that is used as a highly soluble nitrogen source in agriculture. In recognition of the fact that its high solubility makes it inconsistent with organic production, which “feeds the soil, not the plant,” it was added to the National List of Allowed and Prohibited Materials, originally with the annotation as prohibited “unless use is restricted to no more than 20 percent of the crop’s total nitrogen requirement.” In 2011, the NOSB voted to remove the annotation, thus making sodium nitrate a prohibited natural. NOP never acted on this recommendation, nor did it allow the NOSB to vote on the listing during five-year sunset evaluations. OFPA requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. It also requires that the National List be “based on” recommendations of the NOSB. The NOSB is considering whether to back down on its 2011 recommendation. It must stand firm and tell NOP to follow the recommendation that the board made 10 years ago.

Preventing Fraud. The NOSB is asking for comments on proposals to “modernize supply chain traceability” in order to reduce fraud in organic production. While improved technology can contribute to increased compliance, the most important barriers to organic integrity are systemic. We offer as an example the plight of organic dairy farmers who have been left high and dry after being abandoned by their main processor, Danone/Horizon, which has announced that it is terminating its contracts with 89 small-to-medium-sized organic dairy producers in the Northeast as of August 2022. At that point, all of Horizon’s contracted organic dairy farms in Vermont, New Hampshire, Maine, and northern New York may well have no buyers for their milk and will likely face a very uncertain future. Why is Danone cancelling contracts as organic milk production in the Northeast is increasing? In Danone’s words, the company “will be supporting new partners that better align with our manufacturing footprint.” In other words, the company doesn’t need to depend on local fresh milk suppliers when low cost, ultra-pasteurized milk that is easily transported and warehoused has become a staple on the organic shelf. More importantly for the future of organic dairy is the expectation that USDA will promulgate a weak regulation on origin of livestock—that will allow the massive loophole of being able to sell or transfer transitioned animals as certified organic. Such a regulation, in combination with the continued failure to enforce rules requiring organic livestock to have access to pasture, makes it profitable to produce “organic” milk in industrial concentrated animal feeding operations (CAFOs), where cows are fed cheap imported “organic” grain instead of pasture. Organic consumers do not want CAFO milk, but many will have no other choice without strong regulations. In other words, this serious problem of fraud in organic grain and dairy is not due to a lack of “tools” available to certifiers and inspectors, but to the systematic problems—caused by a system that creates incentives to replace pasture with imported grain. Better enforcement tools can assist in returning integrity to organic dairy, but only if NOP and certifiers enforce access to pasture and promulgate a strong regulation on origin of livestock that closes the loophole allowing dairies to sell or transfer transitioned animals as certified organic.

Plastic is increasingly identified as a source of environmental and health problems, and therefore, should be eliminated in organic production and packaging. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Some studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Soil organisms and edible plants have been shown to ingest microplastic particles. Earthworms can move microplastics through the soil, and microplastics can move through the food chain to human food. Microplastics can have a wide range of negative impacts on the soil, which are only beginning to be studied, but include reduction in growth and reproduction of soil microfauna. Microplastics can serve as hotspots of gene exchange between phylogenetically different microorganisms by introducing additional surface, thus having a potential to increase the spread of antibiotic resistance gene] and antibiotic resistant pathogens in water and sediments. Plastic mulches, including those called Biodegradable Biobased Mulch Film (which do not fully degrade), should be replaced with natural mulches such as straw, hay, wood chips, and cover crops that add organic matter to the soil. Replacement of plastic in packaging should be a research priority.

SUBMIT COMMENTS NOW.

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the four comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)

09/20/2021 — Can We End the Sixth Extinction?

Scientists warn that humanity is causing the sixth mass extinction in the planet's history. A series of reports from the United Nations Environment Program (UNEP) highlights how human activities threaten the healthy functioning of ecosystems that produce food and water, as well as one million species now at risk of extinction. The UNEP report, Food System Impacts on Biodiversity Loss, identifies the global food system as the primary driver of biodiversity loss. The report points to the conversion of natural ecosystems to crop production and pasture, with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases. 

In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow use of chemicals that it recognizes will contribute to the problems.

The United Nations Convention on Biological Diversity (CBD) is the international legal instrument for "the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources." It has been ratified by 196 nations—all the members of the United Nations except the United States and the Vatican. The CBD includes 21 action targets to be achieved by 2030, including reducing pesticide use by two-thirds, eliminating plastic waste, and “fully integrating biodiversity values into policies, regulations, planning, development processes, poverty reduction strategies, accounts, and assessments of environmental impacts at all levels of government and across all sectors of the economy, ensuring that all activities and financial flows are aligned with biodiversity values.”

>>Tell Congress to ratify the Convention on Biological Diversity. Tell EPA to incorporate CBD targets into its programs.

Letter to Congress

Scientists warn that humanity is causing the sixth mass extinction in the planet’s history. A series of reports from the United Nations Environment Program (UNEP) highlights how human activities threaten the healthy functioning of ecosystems that produce food and water, as well as one million species now at risk of extinction. The UNEP report Food System Impacts on Biodiversity Loss identifies the global food system as the primary driver of biodiversity loss. The report points to the conversion of natural ecosystems to crop production and pasture, with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases.

In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow use of chemicals that it recognizes will contribute to the problems.

The United Nations Convention on Biological Diversity (CBD) is the international legal instrument for "the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources." It has been ratified by 196 nations—all the members of the United Nations except the United States and the Vatican. The CBD includes 21 action targets to be achieved by 2030, including reducing pesticide use by two-thirds, eliminating plastic waste, and “fully integrating biodiversity values into policies, regulations, planning, development processes, poverty reduction strategies, accounts, and assessments of environmental impacts at all levels of government and across all sectors of the economy, ensuring that all activities and financial flows are aligned with biodiversity values.”

Please ensure that the United States becomes a party to the CBD.

Thank you.

Letter to EPA

Scientists warn that humanity is causing the sixth mass extinction in the planet’s history. A series of reports from the United Nations Environment Program highlights how human activities threaten the healthy functioning of ecosystems that produce food and water, as well as one million species now at risk of extinction. The UNEP report Food System Impacts on Biodiversity Loss identifies the global food system as the primary driver of biodiversity loss. The report points to the conversion of natural ecosystems to crop production and pasture, with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases.

In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow use of chemicals that it recognizes will contribute to the problems.

The United Nations Convention on Biological Diversity (CBD) is the international legal instrument for "the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources." It has been ratified by 196 nations—all the members of the United Nations except the United States and the Vatican. The CBD includes 21 action targets to be achieved by 2030, including reducing pesticide use by two-thirds, eliminating plastic waste, and “fully integrating biodiversity values into policies, regulations, planning, development processes, poverty reduction strategies, accounts, and assessments of environmental impacts at all levels of government and across all sectors of the economy, ensuring that all activities and financial flows are aligned with biodiversity values.”

Until Congress acts to make the United States a party to the CBD, EPA should, as an agency, take actions that are consistent with the action targets of the CBD. In particular, registrations of all pesticides that threaten pollinators, threatened and endangered species, or the functioning of ecosystems should be cancelled as soon as possible.

Thank you.

09/18/2021 — Organic Must Lead the Way in Environmental and Health Protection

The National Organic Standards Board (NOSB) is receiving written comments from the public through September 30. This precedes the upcoming public comment webinar on October 13-14 and online meeting October 19-21—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov.

As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong (KOS) and the Fall 2021 issues page. In the spirit of “continuous improvement,” we urge you to submit comments (please feel free to use our comments on the KOS page) that contribute to an increasingly improved organic production system.

The Organic Foods Production Act (OFPA) requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. Among those up for sunset review this Fall are some controversial materials—copper sulfate, carrageenan, and list 3 “inerts.” In addition, the NOSB is once more considering a petition to allow the antibiotic kasugamycin in fruit production.

Copper sulfate is used in organic rice production to control algae and an invertebrate known as tadpole shrimp. It poses health threats, particularly to workers—including damage to the gastrointestinal tract, liver, kidneys, and the immune system resulting from inhalation exposure. Respiratory effects have been seen in animals exposed to copper sulfate aerosols (such as might be experienced by workers). Copper is considered the etiologic agent in the occupational disease referred to as “vineyard sprayer’s lung.” Copper sulfate is also a reproductive toxicant.

Copper sulfate is hazardous to aquatic plants, animals, and aquatic ecosystems. This is particularly important in rice production, where rice paddies replace natural wetlands and provide alternative habitat for animals threatened by the loss of wetlands. For example, one animal inhabiting rice paddies is the western toad (Bufo boreas).  Tadpoles of the western toad feed on filamentous algae, detritus, and may even scavenge carrion. Application rates of copper sulfate exceed levels that are lethal to tadpoles of Bufo boreas by up to two orders of magnitude. Other amphibians at risk are the bullfrog and Pacific treefrog, whose tadpoles consume algae, organic debris, and small aquatic invertebrates.

The negative impacts on amphibians found in rice fields not only have a negative impact on biodiversity, but they also reduce possibilities for biological control of algae and tadpole shrimp.  Thus, the use of copper sulfate in an aquatic environment like a rice field is inconsistent with a system of organic and sustainable agriculture. In addition, since copper sulfate is water soluble, when the fields are drained, it is released through drainage ditches to streams, and ultimately, the ocean.

The NOSB has previously discussed alternative growing systems that would eliminate the need for copper sulfate and made such alternatives a research priority. Most of the world transplants rice seedlings into paddies. Dryland rice is also grown. Neither of these systems requires killing algae and tadpole shrimp—in fact tadpole shrimp are regarded as a biological control for algae. It is time to eliminate the use of copper sulfate, bringing organic rice production in line with organic principles.

List 3 “inerts” should be removed from the National List. One of the most egregious failures of the National Organic Program (NOP) has been its repeated lack of action on so-called “inert” ingredients. Because of that failure, every sunset brings to a new NOSB a listing that has not been changed in response to over a decade of NOSB recommendations. Fifteen years ago, EPA stopped updating the “inerts” lists upon which the NOP relies. Ever since EPA’s action in 2006, the NOSB has been recommending the review of individual “inert” ingredients, but has instead been given the option by NOP of relisting the outdated lists.

In 2012, the NOSB has already recommended an expiration date for these chemicals, but NOP refused—in violation of the law—to codify this recommendation. The NOSB identified the “inerts” formerly on List 3 that were covered by this listing. They are BHT (antioxidant), 2-Hydroxy-4-n-octyloxybenzophenone (UV absorber), and 2-(2-Hydroxy-3-tert-butyl-5-methylphenyl)-chlorobenzotriazole (UV stabilizer). In addition to the three List 3 “inerts” identified in 2012, a fourth chemical formerly on List 3 has been identified as being in use in passive pheromone dispensers in organic production—benzaldehyde, CAS #100-52-7. Benzaldehyde is not approved for food use. It is approved for nonfood use and as a fragrance in nonfood uses. The addition of another chemical to the known List 3 “inerts” used in organic production shows a hazard of delaying the review of these chemicals as recommended by the NOSB. The NOSB must insist that List 3 “inerts” be delisted and that the individual chemicals be specifically reviewed.

Carrageenan is a controversial food additive that most organic processors have removed from their products. The NOSB voted in 2016 to remove carrageenan from the National List. In 2018, NOP announced that it was refusing to remove carrageenan. The Organic Foods Production Act (OFPA) §6517(d)(1) requires that, “The National List established by the Secretary shall be based upon a proposed national list or proposed amendments to the National List developed by the National Organic Standards Board.” The National List is not “based on” the recommendations of the NOSB if it is directly contradictory to those recommendations. NOP based its decision on testimony received by the NOSB and should not be second-guessing the advisory board for which establishing the National List is an expressly stated statutory responsibility.

The NOSB should insist that carrageenan be removed from the National List. The evidence summarized by the 2015 Technical Review came up with a verdict of mixed results on virtually every issue regarding food grade (high molecular weight) carrageenan. However, there is widespread agreement that poligeenan, which contaminates food grade carrageenan at unknown and uncontrollable levels, does cause adverse effects, including cancer. The production causes adverse environmental impacts. And it is not necessary–organic processors have been moving away from the use of carrageen because of consumer pressure since it was last considered for sunset. This is made more urgent by the fact that NOP ignored the recommendation of the NOSB in spring of 2012 to remove carrageenan from infant foods, as well as the 2016 recommendation to remove carrageenan from the National List altogether.

Kasugamycin is an antibiotic used in fruit production. The NOSB is considering a petition to allow it to be used in organic apple and pear production. Earlier NOSB members struggled long and hard to erase the stigma of antibiotic use in organic fruit production—something that was left over from the transition of so many chemical-intensive fruit orchards after the Alar “scare” in which apple and apple products were contaminated with the cancer-causing plant growth regulator daminozide. Do we now want to step on that treadmill again? The reasons for rejecting the kasugamycin petition are the same as the reasons for eliminating the antibiotics streptomycin and tetracycline in crop production.

Now that we have learned what a pandemic looks and feels like, with the astounding levels of infection, hospitalization, and death from COVID-19, we must take serious steps to prevent another pandemic on the horizon—this one tied to bacterial resistance to antibiotics. An important article in The Lancet points to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”

When streptomycin and tetracycline were presented for their final votes by the Crops Subcommittee, the committee was unanimous that the antibiotics needed to go—the question was how fast. How fast could growers of these crops get over their dependence on these antibiotics that pose threats to human health and the environment and are unpopular with organic consumers? Streptomycin and tetracycline are gone, and we do not need another antibiotic.

We said “No!” to antibiotics in organic fruit, and now we must affirm that we mean it. Kasugamycin does not meet any of the OFPA criteria for the National List—it poses health and environmental dangers, is not necessary, and is incompatible with organic practices.

Submit Comments Now.

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the four comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)

Thank you for keeping organic strong!

09/07/2021 — Save Organic Dairy, Family Farms and Consumer Support for Organic

If regulations concerning “origin of organic livestock” and “access to pasture” seem beyond your comprehension as an organic consumer, think again. Lacking enforcement of strong regulations on these topics, organic dairy is in imminent danger

Multinational food conglomerate Danone, owner of Horizon Organic, has just sent notice to 89 organic milk producers in Maine, Vermont, New Hampshire and at least three counties (Clinton, Franklin and Saint Lawrence) in New York that it is cancelling their contracts. While this action is devastating to the affected farms and the economies of those states, it has much broader implications.

Why is Danone cancelling contracts as organic milk production in the Northeast is increasing? In Danone's words, the company “will be supporting new partners that better align with our manufacturing footprint.” Ed Maltby, executive director of the Northeast Organic Dairy Producers, explains this “footprint,” with reference to low cost, ultra-pasteurized milk that is easily transported and warehoused, which has become a staple on the organic shelf. More importantly for the future of organic dairy is the expectation that USDA will promulgate a weak regulation on origin of livestock—that “will allow the massive loophole of being able to sell or transfer transitioned animals as certified organic.” Such a regulation, in combination with the continued failure to enforce rules requiring organic livestock to have access to pasture, makes it profitable to produce “organic” milk in industrial confined animal feeding operations (CAFOs), where cows are fed cheap imported “organic” grain instead of pasture. Organic consumers do not want CAFO [concentrated animal feeding operation] milk, but many will have no other choice without strong regulations.

>>Tell USDA that strong regulations are essential to protect organic dairy and consumer support for organic.

Letter to USDA

As an organic consumer, I am very concerned about the future of organic dairy. Multinational food conglomerate Danone, owner of Horizon Organic, has just sent notice to 89 organic milk producers in Maine, Vermont, New Hampshire and at least three counties (Clinton, Franklin and Saint Lawrence) in New York that it is cancelling their contracts. While this action is devastating to the affected farms and the economies of those states, it has much broader implications that affect all organic consumers.

Why is Danone cancelling contracts as organic milk production in the Northeast is increasing? In Danone’s words, the company “will be supporting new partners that better align with our manufacturing footprint.” What is this “footprint”? Low cost, ultra-pasteurized milk that is easily transported and warehoused has become a staple on the organic shelf. That doesn’t live up to my expectations as an organic consumer.

But more importantly for the future of organic dairy is the expectation that USDA will promulgate a weak regulation on origin of livestock—that will allow the massive loophole of being able to sell or transfer transitioned animals as certified organic. Such a regulation, in combination with the continued failure to enforce rules requiring organic livestock to have access to pasture, makes it profitable to produce “organic” milk in industrial concentrated animal feeding operations (CAFOs), where cows are fed cheap imported “organic” grain instead of pasture. Organic consumers do not want CAFO milk, but many of us will have no other choice without strong regulations.

Please do the following:

  • Adopt strong regulations governing origin of organic livestock that do not allow transitioned animals to retain their organic certification for milk when they are transferred or sold. The recent loss of Northeast organic dairy family farms can be blamed partly on USDA who created an un-level playing field with its failure to publish the regulation during the last decade.
  • Enforce regulations requiring access to pasture. The recent loss of Northeast organic dairy family farms can be blamed partly on USDA, which allows some certifiers to fail to interpret or enforce the access to pasture regulation in their definition of the grazing season.

We pay a premium for organic milk because we want milk from farms that follow strict organic practices. Without strong enforcement, the organic label is a farce and will lose its value in the marketplace.

Thank you.

08/30/2021 — Tell EPA to Finish the Job in Banning Chlorpyrifos

As with other actions on pesticides, EPA's chlorpyrifos decision is filled with exceptions that respond to vested interests seeking to ignore or deflect the science. EPA, since announcing its decision in 1999 to ban “residential” uses of chlorpyrifos, continues to allow the following uses: (i) Residential use of containerized baits; (ii) Indoor areas where children will not be exposed, including only ship holds, railroad boxcars, industrial plants, manufacturing plants, or food processing plants; (iii) Outdoor areas where children will not be exposed, including only: golf courses, road medians, Industrial plant sites; (iv) Non-structural wood treatments including: fenceposts, utility poles, railroad ties, landscape timers, logs, pallets, wooden containers, poles, posts, and processed wood products; (v) Public health uses: Fire ant mounds (drench and granular treatment); (vi) nurseries and greenhouses; and (vii) Mosquito control. These uses are unaffected by EPA's announcement.

>>We need to finish the chlorpyrifos job. Tell EPA to ban all uses of chlorpyrifos.

The collective effort to remove this one chemical is a tremendous feat in eliminating one exposure to a hazardous material for children. Achieving the ban on food uses required an enormously resource-intensive effort at a time in history when we are running against the clock in an urgent race to transition our society and global community away from the use of petroleum-based, toxic pesticides—to move to meaningful practices that sustain, nurture, and regenerate life.

EPA was forced into its decision by a court order that was precipitated by an agency decision to reverse course after proposing to stop food uses of chlorpyrifos in 2017. Despite a mountain of scientific data challenging chlorpyrifos's safety, it was embraced by industrial agriculture, the golf industry, and others, and deemed too valuable to the bottom line of its manufacturer, Corteva (formerly Dow AgroSciences). Pesticide manufacturers are also motivated to steer EPA away from adverse health and environmental effects findings on their products in order to avoid potential litigation by those harmed. The U.S. Court of Appeals for the 9th Circuit in San Francisco in its ruling in May, 2021, in which it mandated EPA action, said, “The EPA has had nearly 14 years to publish a legally sufficient response to the 2007 Petition [filed by environmental and farmworker groups].” The court continued, “During that time, the EPA's egregious delay exposed a generation of American children to unsafe levels of chlorpyrifos.”

But before all the recent activity, in 1999, EPA had negotiated a compromise with Dow that stopped most residential uses of chlorpyrifos. Why? For the same reason that EPA finally acted on food. This neurotoxic chemical is harmful to children. That was 22 years ago and followed a campaign by Beyond Pesticides and others to remove Dursban/chlorpyrifos from the market because of indoor ambient air contamination of homes and buildings and lawn and landscape exposure. It should be noted that Dursban had been viewed with promise by regulators as the alternative to the organochlorine insecticide chlordane, which Beyond Pesticides sued to remove from the termite use market—a remaining use after the agricultural, lawn, and garden uses were finally taken off the market in 1983, with decades of review by numerous agencies. Its cancer-causing properties and ecological effects could no longer be defended. The cancellation of termite use followed in 1988 after millions of homes were potentially contaminated, with high risk factors for cancer.

It all comes down to this: Do we want a society that is science-based, public health-oriented, occupational safety focused, children-concerned, ecologically protective or one that allows the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? Should victims of poisoning have to plead with regulators to protect them? Should organizations have to fight chemical-by-chemical to achieve basic levels of protection from individual neurotoxic, cancer-causing, endocrine-disrupting pesticides? Of course not. This is exactly what has happened with the insecticide chlorpyrifos and continues to occur with other pesticides. There's no question, we need an EPA that doesn't play politics with health and the environment.

With all this as context for the chemical treadmill, next up after chlorpyrifos may be the insecticide bifenthrin, a synthetic pyrethroid. It too is a neurotoxic, cancer-causing, endocrine-disrupting pesticide. And if that is not enough, there are others waiting in the wings. 

>>But first we need to finish the chlorpyrifos job. Tell EPA to ban all uses of chlorpyrifos.

Letter to EPA

I am writing to ask EPA to finish the chlorpyrifos job. Ban all uses of chlorpyrifos.

Does a science-based, public health-oriented, occupational safety focused, children-concerned, ecologically protective society allow the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? Should victims of poisoning have to plead with regulators to protect them? Should organizations have to fight chemical-by-chemical to achieve basic levels of protection from individual neurotoxic, cancer causing, endocrine disrupting pesticides? Of course not. Yet, this is exactly what has happened with the insecticide chlorpyrifos and continues to occur with other pesticides. The U.S. Environmental Protection Agency’s (EPA) announcement that the food uses of the chlorpyrifos will be banned after being registered 65 years ago should be cause to end its remaining uses.

As with other actions on pesticides, EPA’s chlorpyrifos decision is filled with exceptions that respond to vested interests seeking to ignore or deflect the science. EPA, since announcing its decision in 1999 to ban “residential” uses of chlorpyrifos, continues to allow the following uses: (i) Residential use of containerized baits; (ii) Indoor areas where children will not be exposed, including only ship holds, railroad boxcars, industrial plants, manufacturing plants, or food processing plants; (iii) Outdoor areas where children will not be exposed, including only: golf courses, road medians, Industrial plant sites; (iv) Non-structural wood treatments including: fenceposts, utility poles, railroad ties, landscape timers, logs, pallets, wooden containers, poles, posts, and processed wood products; (v) Public health uses: Fire ant mounds (drench and granular treatment); (vi) nurseries and greenhouses; and (vii) Mosquito control. These uses are unaffected by EPA’s announcement.

EPA was forced into its decision by a court order that was precipitated by an agency decision to reverse course after proposing to stop food uses of chlorpyrifos in 2017. Despite a mountain of scientific data challenging chlorpyrifos’s safety, it was embraced by industrial agriculture, the golf industry, and others, and deemed too valuable to the bottom line of its manufacturer, Corteva (formerly Dow AgroSciences). The U.S. Court of Appeals for the 9th Circuit in San Francisco in its ruling in May, 2021, in which it mandated EPA action, said, “The EPA has had nearly 14 years to publish a legally sufficient response to the 2007 Petition [filed by environmental and farmworker groups].” The court continued, “During that time, the EPA’s egregious delay exposed a generation of American children to unsafe levels of chlorpyrifos.”

But before all the recent activity, in 1999, EPA had negotiated a compromise with Dow that stopped most residential uses of chlorpyrifos. Why? For the same reason that EPA finally acted on food. This neurotoxic chemical is harmful to children. That was 22 years ago, and followed a campaign by Beyond Pesticides and others to remove Dursban/chlorpyrifos from the market because of indoor ambient air contamination of homes and buildings and lawn and landscape exposure. It should be noted that Dursban had been viewed with promise by regulators as the alternative to the organochlorine insecticide chlordane, which Beyond Pesticides sued to remove from the termite use market—a remaining use after the agricultural, lawn, and garden uses were finally taken off the market in 1983, with decades of review by numerous agencies. Its cancer-causing properties and ecological effects could no longer be defended. The cancellation of termite use followed in 1988 after millions of homes were potentially contaminated, with high risk factors for cancer.

It is time to ban all uses of chlorpyrifos.

Thank you.

08/23/2021 — Tell EPA Biopesticides Must be Redefined

“Biopesticides”—widely regarded as an alternative to chemical pesticides and hence given a special status in regulation—need a better definition. “Biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term can be misleading and mixes contradictory approaches. It is troublesome when we continue to look for product replacements or substitutions for agricultural practices that are clearly ineffective, and in the process avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions.

The U.S. Environmental Protection Agency (EPA) uses the following definition for “biopesticides”:

  • Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals);
  • Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient;
  • Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce.

>>Tell EPA it's time to redefine “biopesticide.” It is deceptive and misleading. The definition should not include genetically modified organisms or synthetic analogs of naturally occurring biochemicals.

EPA requires much less data to register a biopesticide and registers it in much less time. There are currently 390 biochemical and microbial active ingredients registered as biopesticides and 34 PIP active ingredients. In effect, EPA encourages their use by regulating them less stringently, characterizing them in the following ways: (i) they are “usually inherently less toxic,” (ii) that they “generally affect only the target pest and closely related organisms,” (iii) that they “often are effective in very small quantities and often decompose quickly,” and (iv) that “used as a component of Integrated Pest Management (IPM) programs, biopesticides can greatly reduce the use of conventional pesticides” [emphasis added]. The broad category “biopesticides” and waffle words used by EPA reflect hidden hazards.

For example, PIPs are certain to result in pesticide resistance because they are incorporated into plant tissue, thus exposing insects to the pesticide regardless of whether the plant is under serious attack. These certainly should not be part of IPM because their use is prophylactic. The vast majority of PIPs incorporate Bacillus thuringiensis, which has resulted in widespread resistance to a relatively innocuous biological insecticide, making it unusable as a rescue treatment. PIPs occur throughout the plant, resulting in broad exposure—principally to livestock, but sometimes to humans—to not only the active ingredient, but the “genetic material necessary for its production.” Little is known about the persistence of these genetic bits in the environment, nor what their impacts on ecosystems might be.

With less data required, we have less information concerning potential hazards of biopesticides. Besides genetically engineered organisms, these include synthetic analogues of naturally occurring biochemicals. Synthetic pheromones have effects on human health that depend on the application method, “inert ingredients,” and retrieval/disposal. In addition, only a small fraction of known insect pheromones (which have effects that are mimicked by commercially available synthetic pheromones) have been thoroughly examined for their toxic or other pharmacological effects on non-target (including mammalian) species. Pheromones as used in pest management are synthetic analogs of parts of the pheromones found in nature. Because they lack the complexity of natural pheromones, they also lack the specificity of those pheromones. Thus, some pheromone products designed to disrupt the mating of pest insects can affect the behavior of many non-pests. In addition, microencapsulated pheromones may be a hazard to honeybees.

Some bioprotectant products may be ecologically sound and nontoxic; indeed, some fungi appear to hold great promise. Despite the lack of specificity, pheromone products have permitted growers to avoid the use of more toxic controls. They can be used in a way that complements alternative pest management methods, but synthetic analogs must be fully tested.

>>Tell EPA it's time to redefine “biopesticide” and remove genetically modified organisms from this category. It is deceptive and misleading. Synthetic analogs of naturally occurring biochemicals should not be included in the definition.

Letter to EPA

“Biopesticides” are widely regarded as an alternative to chemical pesticides and hence given a special status in regulation. However, “biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term is misleading in that it does not, as defined by EPA or others, denote a group of materials that naturally produced. It is also troublesome to encourage product replacements or substitutions and, in the process, avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions.

The U.S. Environmental Protection Agency (EPA) includes as “biopesticides”:

1) Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals);

2) Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient;

3) Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce.

EPA requires much less data and time to register a biopesticide. In effect, EPA encourages their use by regulating them less stringently, characterizing them in the following ways: (i) they are “usually inherently less toxic,” (ii) that they “generally affect only the target pest and closely related organisms,” (iii) that they “often are effective in very small quantities and often decompose quickly,” and (iv) that “used as a component of Integrated Pest Management (IPM) programs, biopesticides can greatly reduce the use of conventional pesticides.” The broad category “biopesticides” and waffle words used by EPA reflect hidden hazards.

For example, PIPs are certain to result in pesticide resistance because they are incorporated into plant tissue, thus exposing insects to the pesticide regardless of whether the plant is under serious attack. These certainly should not be part of IPM because their use is prophylactic. The use of PIPs incorporating Bacillus thuringiensis has resulted in widespread resistance to a relatively innocuous biological insecticide, making it unusable as a rescue treatment. PIPs occur throughout the plant, resulting in broad exposure—principally to livestock, but sometimes to humans—to not only the active ingredient, but the “genetic material necessary for its production.” Little is known about the persistence of these genetic bits in the environment, nor what their impacts on ecosystems might be.

With less data required, we have less information concerning potential hazards of biopesticides. Besides genetically engineered organisms, these include synthetic analogs of naturally occurring biochemicals. Only a small fraction of known insect pheromones (or the synthetic analogs in commercially available synthetic pheromones) have been thoroughly examined for their toxic or other pharmacological effects on non-target species. Pheromones as used in pest management lack the complexity and specificity of natural pheromones. Thus, some pheromone products designed to disrupt the mating of pest insects can affect the behavior of many non-pests. In addition, microencapsulated pheromones may be a hazard to honeybees.

Some bioprotectant products may be ecologically sound and nontoxic. Indeed, some fungi appear to hold great promise. Despite the lack of specificity, pheromone products have permitted growers to avoid the use of more toxic controls and can complement alternative pest management methods, but synthetic analogs must be fully tested.

It's time for EPA to redefine “biopesticide.” It is deceptive and misleading. The definition should not include genetically modified organisms or synthetic analogs of naturally occurring biochemicals.

Thank you.

08/16/2021 — EPA Must Ban Pesticides Unless Shown Not to be Endocrine Disruptors

The failure of EPA to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine-disrupting chemicals must end. The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) has issued a damning report on the agency's progress in protecting the population from potentially damaging endocrine disruption impacts of exposures to synthetic chemical pesticides (and other chemicals of concern) that shows the situation to be even worse than previously reported. The OIG's summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” As a result, according to the OIG, “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.”

>>Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.

Over recent decades, evidence has mounted showing that many pesticides interfere with hormones—and are therefore endocrine-disrupting chemicals (EDCs). In 1996, the promise of screening pesticides for endocrine disruption generated support from environmentalists and public health advocates for the Food Quality Protection Act (FQPA), which traded the absolute prohibition of carcinogens in food of the Delaney Clause for a risk assessment standard that is subject to manipulation and an underestimation of real-life hazards. And now, 25 years later, we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.

The endocrine system consists of a set of glands (thyroid, gonads, adrenal and pituitary) and the hormones they produce (thyroxine, estrogen, testosterone and adrenaline), which are responsible for the activation, regulation, and de-activation of a huge variety of functions in, especially, development, reproduction, growth, metabolism, the cardiac and circulatory system, sleep, mood, and behavior, among others. Hormones are signaling molecules that travel through the bloodstream and elicit responses in other parts of the body. The hormones secreted by the endocrine glands travel through the bloodstream to various organs and tissues, where they communicate critical regulatory messages.

The ingredients in many pesticides (and in many consumer products) act as endocrine disruptors in humans and other animals in several ways. They may: (1) mimic actions of hormones the body produces (e.g., estrogen or testosterone), causing reactions similar to those generated by the naturally produced hormones; (2) block hormone receptor cells, thereby preventing the actions of natural hormones; or (3) affect the synthesis, transport, metabolism, and/or excretion of hormones, thus altering the concentrations of natural hormones in tissues or at receptor sites. 

As the OIG report notes, “Small disturbances in endocrine function, particularly during certain highly sensitive stages of the life cycle, such as pregnancy and lactation, can lead to profound and lasting effects. Adverse endocrine-related effects in humans may include breast cancer, diabetes, obesity, infertility, and learning disabilities.” In addition, there are both direct and indirect implications of EDCs, such as other cancers, Parkinson's disease, multiple reproductive disorders and anomalies (e.g., polycystic ovary syndrome, testicular dysgenesis syndrome, endometriosis, and reduced sperm count), alteration of the gut biome and resultant dysfunction, and metabolic disorders apart from diagnosable diabetes. 

The OIG report finds that EPA's Office of Chemical Safety and Pollution Prevention (OCSPP), which is responsible for testing all pesticide chemicals for endocrine-disrupting activity in humans, has failed to implement a section of the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by the 1996 Food Quality Protection Act — the legislation that requires such testing. In addition, the report states that OCSPP's Office of Pesticide Programs (OPP) has not implemented a 2015 recommendation that 17 pesticides undergo additional testing as EDCs in wildlife so that an ecological risk assessment could be effectively conducted.

The report indicates that EPA has not created the tools (e.g., strategic guidance documents or performance measures) necessary to implement effectively the agency's Endocrine Disruptor Screening Program (EDSP), created in 1998. In particular, EDSP has not “conducted annual internal program reviews to monitor or assess progress in fulfilling regulatory requirements, and the EDSP has not effectively communicated with internal and external stakeholders. Moreover, previous OCSPP leadership provided acceptable corrective actions to meet the recommendations in a 2011 EPA Office of Inspector General report regarding the EDSP, yet failed to actually implement those corrective actions beyond an initial period of compliance with them. Lastly, some EPA staff indicated that they were instructed to function as if the EDSP was eliminated from the EPA's budget. Because the EDSP has not had effective internal controls in place since 2015, it cannot have reasonable assurance that the objectives of the program will be accomplished and that resources will be allocated efficiently and effectively.”

In 2017, Europe's Pesticide Action Network refined an earlier estimate by the European Union that more than 50 pesticide active ingredients operate as endocrine disruptors. (That earlier list included those identified by TEDX, The Endocrine Disruption Exchange, which was launched by pioneering ED scientist Theo Colborn, PhD.) The update short-listed 37 pesticides of ED concern out of the nearly 500 on the market in Europe in 2015. In 2009, EPA created an EDSP “List 1” of 67 pesticides and “high production volume chemicals” used as pesticide inert ingredients that the agency deemed should be evaluated first for ED impacts. (EPA later reduced this list to 52 chemicals because 15 were subsequently canceled or discontinued.)

It is not only humans who are affected. Hermaphroditic frogs, polar bears with penis-like stumps, panthers with atrophied testicles and intersex fish with immature eggs in their testicles have all been linked to endocrine disruption. The popular herbicide atrazine chemically castrates and feminizes exposed male tadpoles. The mosquito-killing S-methoprene larvicide alters early frog embryo development. Distorted sex organ development and function in alligators is linked to the organochlorine insecticide dicofol. The ubiquitous antibacterial chemical triclosan alters thyroid function in frogs, while its chemical cousin triclocarban enhances sex hormones in rats and in human cells. In her book, Our Stolen Future, Dr. Colborn states that the decline of animal species can no longer be simply explained by habitat destruction and human disturbance, but also by reproductive failures within populations brought on by the influence of endocrine-disrupting chemicals.

The OIG report documents the repeated failures of EPA to meet deadlines set by Congress to develop and implement EDC testing. OIG findings are consistent with those reported by Sharon Lerner in her The Intercept article, “Whistleblowers Expose Corruption in EPA Chemical Safety Office.” The article evinced not only laxity and managerial allegiance to industry interests, but also, downright corruption on the part of some managers at EPA.

EPA now issues Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption.

The report concludes: “In 1996, Congress directed the EPA to establish the EDSP, and the program received approximately $7.5 million in funding in fiscal year 2021. Yet, the EDSP can show only limited results. Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.”

The OIG report issued a series of 10 recommendations, directed to OCSPP Assistant Administrator Freedhoff, that address:

  • tiered testing for ED impacts
  • timelines for such testing
  • strategic planning
  • development of performance metrics
  • improved communication, including to the public
  • internal program review
  • improved transparencyns

>>Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.

Letter to EPA

I am writing to ask you to act now to meet a statutory mandate to protect humans and wildlife from dire health consequences. The failure of EPA to meet its statutory responsibility to protect against exposure to endocrine-disrupting chemicals (EDCs) must end. The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) has issued a damning report on the agency’s progress in protecting the population from EDCs used as pesticides, as mandated by the Food Quality Protection Act (FQPA) of 1996, which required EPA to establish a program to screen and test pesticides and other widespread chemical substances for endocrine-disrupting effects. The OIG’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” As a result, according to the OIG, “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.”

As the OIG report notes, “Small disturbances in endocrine function, particularly during certain highly sensitive stages of the life cycle, such as pregnancy and lactation, can lead to profound and lasting effects. Adverse endocrine-related effects in humans may include breast cancer, diabetes, obesity, infertility, and learning disabilities.” There are other direct and indirect implications of EDCs, such as other cancers, Parkinson’s disease, multiple reproductive disorders and anomalies (e.g., polycystic ovary syndrome, testicular dysgenesis syndrome, endometriosis, and reduced sperm count), alteration of the gut biome and resultant dysfunction, and metabolic disorders apart from diagnosable diabetes.

The OIG report finds that EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP), which is responsible for testing all pesticide chemicals for endocrine-disrupting activity in humans, has failed to implement the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by the 1996 Food Quality Protection Act. In addition, the report states that OCSPP’s Office of Pesticide Programs (OPP) has not implemented a 2015 recommendation that 17 pesticides undergo additional testing as EDCs in wildlife so that an ecological risk assessment could be effectively conducted.

The report indicates that EPA has not created the tools necessary to implement the agency’s Endocrine Disruptor Screening Program (EDSP), created in 1998. The OIG report documents the repeated failures of EPA to meet deadlines set by Congress to develop and implement EDC testing. “In 1996, Congress directed the EPA to establish the EDSP, and the program received approximately $7.5 million in funding in fiscal year 2021. Yet, the EDSP can show only limited results. Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.”

The OIG statement that “some EPA staff indicated that they were instructed to function as if the EDSP was eliminated from the EPA’s budget” is consistent with those reported by Sharon Lerner in her The Intercept article, “Whistleblowers Expose Corruption in EPA Chemical Safety Office,” which showed not only laxity and managerial allegiance to industry interests, but also downright corruption on the part of some managers at EPA.

The OIG report issued a series of 10 recommendations that address:
• tiered testing for ED impacts
• timelines for such testing
• strategic planning
• development of performance metrics
• improved communication, including to the public
• internal program review
• improved transparency

Please ensure that your agency meets its responsibility to protect the health of people and wildlife.

Thank you.

08/09/2021 — Biden EPA Must Hold Pesticide Manufacturers Accountable for Poisoning!

What's going on at the Environmental Protection Agency (EPA)? Last month, Bayer/Monsanto announced it would voluntarily cancel “residential lawn and garden” uses of glyphosate products, “exclusively to manage litigation risk and not because of any safety concerns.” EPA has done virtually nothing to restrict glyphosate/Roundup since the World Health Organization/International Agency for Research on Cancer in 2015 classified the chemical as probably carcinogenic. It is now expected, as with other voluntary cancellations, that EPA will make no health or environmental findings that could affect other uses (e.g., agricultural) of glyphosate, but will accept the action by Bayer/Monsanto. The company refers to its action as “risk mitigation”—that's risk to the company's profitability, economic viability, and shareholder investment, not public health or environmental protection. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.

The Biden administration began with high hopes for the environment. Combating climate change is a priority. On his first day in office, President Biden issued an executive memorandum, Modernizing Regulatory Review, that appears to establish a new framework supporting healthy people and ecosystems, as it directs the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations.

But what's happening at EPA? The announced voluntary cancellation of glyphosate products highlights EPA's failure to correct dangerous decisions made under the Trump administration. EPA has not corrected actions on chlorpyrifos, atrazine, dicamba, or neonicotinoids that allow poisonings of humans, pollinators, and others to continue.

>> Tell EPA to stop allowing the pesticide industry free rein to regulate itself based on financial risks instead of the risks to health and environment that the law requires to drive decisions. 

A report by the Office of the Inspector General for EPA concludes that scientific analyses by the agency were altered so as to favor top Trump administration officials' policy choices in the 2018 reapproval of the highly toxic and problematic pesticide, dicamba. The report, “EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision,” was publicly released on May 24. It confirms aspects of what Beyond Pesticides and many others in the science, advocacy, public health, and environmental communities have been saying and reporting since 2016: The Trump administration executed a wholesale assault on scientific integrity in federal decision-making. But where is the Biden EPA correction of the Trump policy?

An article in The Intercept reveals how far EPA's credibility has slipped, in view of sloppy or corrupt science, a well-greased revolving door between EPA and the pesticide industry, responsiveness to political pressure from pesticide companies, and actions that lag behind other countries. If EPA is to fulfill its statutory responsibilities, it must reverse these realities, re-examine Trump-era decisions, and act on behalf of the public and the environment.

EPA must not continue to allow pesticide manufacturers to regulate themselves based on financial risk. While they may have been forced in courts to pay damages for certain uses—generally those where exposure to specific people can be proven—these same pesticides continue to harm others, from neighboring chemical-intensive and organic farmers, to those living near production plants and those with pre-existing conditions, to bees and frogs, to consumers. When a company seeks to voluntarily cancel uses of a pesticide, EPA should immediately suspend all registrations and begin cancellation proceedings for all uses.

>> Tell EPA to stop allowing the pesticide industry free rein to regulate itself based on financial risks instead of the risks to health and environment that the law requires to drive decisions.

Letter to EPA Administrator

I am writing to express profound disappointment with the Biden EPA’s record on pesticide regulation. Bayer/Monsanto just announced that it would voluntarily cancel “residential” uses of glyphosate products, “exclusively to manage litigation risk and not because of any safety concerns.” If the past is prologue, EPA will accept Bayer’s voluntary cancellation of residential uses and make no findings that could affect other uses (e.g., agricultural) of glyphosate. The company refers to its action as “risk mitigation”—that’s risk to the company’s profitability, economic viability, and shareholder investment, not public health or environmental protection. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, a shield from liability, and unencumbered international marketing.

The administration began with high hopes for the environment. Combating climate change is a priority. On his first day in office, President Biden issued an executive order, “Modernizing Regulatory Review,” that appears to establish a new framework promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations.

But what’s happening at EPA? EPA is allowing the pesticide industry free rein to regulate itself based on financial risks instead of the hazards to health and environment that the law requires to drive decisions. Accepting a voluntary cancellation without a rigorous review of the science and the threats will only serve to highlight EPA’s failure to correct dangerous decisions made under the Trump administration. EPA, to date, has not corrected actions on chlorpyrifos, atrazine, dicamba, or neonicotinoids that allow poisoning to continue.

A report by the Office of the Inspector General for EPA “EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision,” concludes that scientific analyses by the agency were altered to favor top Trump administration officials’ policy choices in the 2018 reapproval of the highly toxic and problematic pesticide dicamba, as the Trump administration executed a wholesale assault on scientific integrity in federal decision making. Where is the Biden EPA correction of Trump policy?

An article in The Intercept reveals how far EPA’s credibility has slipped, in view of sloppy or corrupt science, a well-greased revolving door between EPA and industry, responsiveness to political pressure from pesticide companies, and actions that lag behind other countries. If EPA is to fulfill its statutory responsibilities, it must reverse these trends, re-examine Trump-era decisions, and act on behalf of the public and the environment.

EPA must not continue to allow pesticide manufacturers to regulate themselves based on financial risk. While they may have been forced in the courts to pay damages for certain uses—generally those where exposure to specific humans can be proven—these same pesticides continue to harm others, from neighboring chemical-intensive and organic farmers, to those living near production plants and those with pre-existing conditions, to bees and frogs, to consumers. When a company seeks to voluntarily cancel uses of a pesticide, EPA should immediately suspend all registrations and begin cancellation proceedings for all uses.

  • Please take the following actions:
    Adopt conflict-of-interest policies that eliminate the revolving door between EPA and the pesticide industry.
  • Re-examine Trump-era decisions to allow use of dangerous pesticides and act on behalf of the public and the environment.
  • Stop the self-regulation of pesticide manufacturers based on financial risk. A proposal to voluntarily cancel uses of a pesticide should trigger immediate suspension and cancellation proceedings for all uses.

Thank you for your immediate attention to this critical public health and environmental issue.

08/02/2021 — Tell USDA to Ensure that Organic Farming Protects Ecosystems

Sign this Petition by September 20, 2021

One reason to eat organic food is to join with a crucial national and global campaign to eliminate toxic, petroleum-based pesticides and fertilizers and protect ecosystems in the urgent fight to curtail the climate crisis and biodiversity decline—in addition to local and immediate health and environmental benefits. Despite an important and timely vote by the National Organic Standards Board (NOSB) in 2018 to protect native ecosystems as a critical tool in sequestering carbon and improving environmental resiliency, and despite the Biden Adminstration's stated commitment to fighting the climate crisis, the U.S. Department of Agriculture and its National Organic Program (NOP) have not acted to put this recommendation in force.

As our understanding of the connection between protecting intact ecosystems and combating climate change has grown, the urgency to implement this recommendation cannot be overstated. We must act now!

>> Sign the petition to tell the National Organic Program (NOP) to take action to finalize the National Organic Standards Board (NOSB) recommended rulemaking that will protect Native Ecosystems and thereby preserve the integrity of the organic seal, help reverse the biodiversity crisis, and reduce global climate change. Sign by September 20, 2021.

The Organic Foods Production Act (OFPA) and implementing regulations and guidance issued by the NOP contain several provisions to increase biodiversity on organic farms. Consistent with consumer expectations of organic, these provisions mandate protection of the natural resources present on an organic operation, including the physical, hydrological, and biological features of the farm. The soil, water, wetlands, woodlands, and wildlife must be maintained or improved by the organic operator. Three of the NOSB members must have expertise in areas of environmental protection and resource conservation. 

Biodiversity is essential to organic farming, but all farming inherently reduces biodiversity from natural ecosystems. These natural ecosystems contain ecological communities that are diverse and resilient because of their coevolution over millennia. In addition, they are more effective in sequestering carbon than any form of agriculture. Unfortunately, the requirement in OFPA that no prohibited substance be applied within three years of harvesting certified organic crops encourages prospective organic growers to plow up land containing native ecosystems.

The NOSB voted nearly unanimously to recommend policy changes to remove the incentive to convert native ecosystems to organic farms. Wild Farm Alliance, Beyond Pesticides, and others supported these policy changes. So far, NOP has not acted to put this recommendation into the regulations. Again, the organic solution is within our grasp as a key part in taking on the existential environmental crises in front of us. It is a travesty that the Biden Administration is not acting on this now using its executive powers and responsibility to carry out this critical recommendation of the NOSB.

>> Sign the petition to tell the National Organic Program (NOP) to take action to finalize the National Organic Standards Board (NOSB) recommended rulemaking that will protect Native Ecosystems and thereby preserve the integrity of the organic seal, help reverse the biodiversity crisis, and reduce global climate change. Sign by September 20, 2021.

PETITION:
YES! I want the National Organic Program (NOP) to take action to finalize the National Organic Standards Board (NOSB) recommended rulemaking that will protect Native Ecosystems and thereby preserve the integrity of the organic seal, help reverse the biodiversity crisis, and reduce global climate change. 
In 2018 the NOSB voted near unanimously to protect native ecosystems and, in so doing, leading the national effort to take on the existential threats of the climate crisis and biodiversity decline. The NOSB sought to change the current perverse regulation that incentivizes the immediate destruction of native ecosystems and conversion to organic production as a cheaper and faster option than transitioning existing conventional farmland over a three-year period.

Protecting native ecosystems slows climate change. Native ecosystems store carbon in woody plants, in the soil's duff layer and its deeper horizons. Native grassland and forest soils contain 20 to 50 tons of organic carbon per acre in about the top three feet of soil, which is so much more than farmers can ever hope to store in converted cropland.

Native ecosystems can be used in organic production, including low-impact grazing, mushrooms, maple syrup production, and other kinds of wild crop harvesting.

Organic consumers are distressed to learn that the NOP rules incentivize native ecosystem destruction. Organic farmers don't think it is fair that this loophole allows immediate certification, when many have waited three years to transition conventional land. 

Wendell Berry has said “Land destruction is easy. For it only requires ignorance and violence. But to restore the land, and to conserve it, requires humanity in its highest, completest sense.” 

Please immediately initiate rulemaking to remove the incentive to convert native ecosystems to organic farms.

07/19/2021 — Schools Must Provide and Encourage Organic Food

As yet another study, “Early life multiple exposures and child cognitive function: A multi-centric birth cohort study in six European countries,” draws attention to the benefits of organic food for the learning young mind, it is important that schools provide organic food to students. The study, conducted by Spanish researchers based at the Barcelona Institute for Global Health, looks at a totality of all environmental hazards that children encounter, rather than individual lifestyle factors. As study co-author Jordi Júlvez, PhD, notes, “Healthy diets, including organic diets, are richer than fast food diets in nutrients necessary for the brain, such as fatty acids, vitamins and antioxidants, which together may enhance cognitive function in childhood.”

>>Tell your Governor and USDA/Food and Nutrition Service to provide organic school lunches and information for parents.

Researchers find that children who eat organic food display higher scores measuring fluid intelligence and working memory. Lower scores on fluid intelligence tests are 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.

This study adds to prior research finding that eating a conventional, chemical-intensive diet increases the presence of pesticides and their metabolites in an individual's urine, including higher pesticide body burden from eating foods grown in chemical-intensive systems. In fact, because of their smaller size, children carry higher levels of glyphosate and other toxic pesticides in their body. Coupled with this research are multiple studies showing that many common pesticides result in developmental problems in children. Most recently, a 2019 Danish study found that higher concentrations of pyrethroid insecticides corresponded to higher rates of ADHD in children. There is also strong evidence that organophosphate insecticides, still widely used on fruits and vegetables in the U.S., are dropping children's IQs on a national and global scale, costing billions to the economy in the form of lost brain power.

Studies show children's developing organs create “early windows of great vulnerability” during which exposure to pesticides can cause great damage. This is supported by the findings of the American Academy of Pediatrics (AAP), which concludes, “Children encounter pesticides daily and have unique susceptibilities to their potential toxicity.”

Switching from a conventional diet of food produced with chemical-intensive practices to organic diet drastically reduces the levels of pesticides in one's body, with one week on organic food showing a 70% reduction in glyphosate in the body, according to one study. Socio-economic factors play a large role in access to heathy organic foods, and the ability to provide the sort of environment that allows a child's brain to flourish, so it is important that school lunches, which provide nutrition across socioeconomic classes, help to equalize learning potential. Pitting access and cost against the long-term success of a child's development puts many parents in an untenable position. The preponderance of evidence points to organic food providing the nutrition needed to give young minds the start they need in life. But eating organic should not be a choice to make – all food should be grown with high quality standards that reject the use of brain-damaging pesticides and protect the wider environment. 

See the factsheet Children Need Organic Food.

>>Tell your Governor and USDA/Food and Nutrition Service to provide organic school lunches and information for parents.

Letter to Governors and USDA

I am writing out of concern that school lunches nourish, rather than threaten, the brains of our students. Researchers based at the Barcelona Institute for Global Health have added to the growing body of research showing the advantages of organic food for children. Study co-author Jordi Júlvez, PhD, notes, “Healthy diets, including organic diets, are richer than fast food diets in nutrients necessary for the brain, such as fatty acids, vitamins and antioxidants, which together may enhance cognitive function in childhood.” The researchers find that children who eat organic food display higher scores measuring fluid intelligence and working memory.

This adds to previous research showing both the dangers to children of “conventional” food produced by chemical-intensive methods and the advantages of switching to organic foods.

Studies show children’s developing organs create “early windows of great vulnerability” during which exposure to pesticides can cause great damage. This is supported by the findings of the American Academy of Pediatrics (AAP), which concludes, “Children encounter pesticides daily and have unique susceptibilities to their potential toxicity” and recommends that “pediatricians should incorporate this evidence when discussing the health and environmental impact of organic foods and organic farming while continuing to encourage all patients and their families to attain optimal nutrition and dietary variety.”

Studies find that eating a conventional diet produced in a chemical-intensive manner increases the presence of pesticides and their metabolites in an individual’s urine, including higher pesticide body burden from eating foods grown in chemical-intensive systems. Because of their smaller size, children carry higher levels of toxic pesticides in their body. Multiple studies show that many common pesticides result in developmental problems in children, including attention deficit hyperactivity disorder (ADHD), autism, and developmental delays. There is also strong evidence that organophosphate insecticides, still widely used on fruits and vegetables in the United States, are dropping children’s IQs on a national and global scale, costing billions to the economy in the form of lost brain power.

Switching to an organic diet can reduce pesticides and their metabolites in the body, even within a week of the change. Socio-economic factors play a large role in access to heathy organic foods, and the ability to provide an environment that allows a child’s brain to flourish, so it is important that school lunches, which provide nutrition across socioeconomic classes, help to equalize learning potential. Pitting access and cost against the long-term success of a child’s development puts many parents in an untenable position. The preponderance of evidence points to organic food providing the nutrition needed to give young minds the start they need in life. But eating organic should not be a choice to make – all food should be grown with high quality standards that reject the use of brain-damaging pesticides and protect the wider environment.

In addition to ensuring that our schools serve organic lunches, I ask you to help educate parents on the importance of an organic diet to the mental and physical health of children. A factsheet "Children Need Organic Food" from Beyond Pesticides explains the benefits of organic food to children with tips on providing organic food on a budget; it can be found at bp-dc.org/factsheet-children-organic.

07/12/2021 — Tell Your Congressional Reps to Cosponsor Saving America's Pollinator Act

Thank Those Who Already Have Too!

During Pollinator Week 2021 in June, U.S. Representatives Earl Blumenauer (D-OR) and Jim McGovern (D-MA) reintroduced the Saving America's Pollinators Act (SAPA) to reverse ongoing declines in wild and managed pollinators. New data released in June for 2020-21 documents the second highest honey bee losses in 15 years. SAPA uses the latest scientific research and perspectives to ensure that pollinators are protected. The bill suspends the use of neonicotinoid (neonic) insecticides and other pesticides harmful to bees and other pollinators until an independent board of experts determines that they are safe to use, based on a strong scientific assessment.

>>Ask your elected representative in Congress to support pollinators by cosponsoring Saving America's Pollinators Act (SAPA). If they are already a cosponsor, use this occasion to thank them for their leadership on this critical issue.

“Without our world's pollinators, the world would be a very different place. These bees, butterflies, hummingbirds, and other creatures are essential elements of our food system. Losing them means we risk losing the very food we put on our table,” said Rep. Blumenauer. “We must use every tool at our disposal to provide pollinators with much-needed relief from bee-toxic pesticides and monitor their populations to ensure their health and survival.”

Neonicotinoids are systemic pesticides; once applied to a seed or sprayed on a plant they make their way into the pollen, nectar and dew droplets that plants produce and pollinators feed upon. Exposure impairs pollinator navigation, foraging, and learning behavior, and also suppresses their immune system, making them more susceptible to disease and pathogens like the varroa mite.

American beekeepers have lost over 30% of their hives annually over the past decade, while wild pollinators are threatened with extinction. The iconic American Bumblebee has lost 89% of its population over the last 20 years. Populations of eastern monarchs have declined by 80% since the 1990s. This past year, citizens scientists participating in the western monarch count found a scant 2,000 butterflies—down from 1.2 million in the 1990s, 300,000 in 2016, and 30,000 in 2019. Peer-reviewed scientific studies show all of these impacts to be associated with the use of toxic pesticides.

The harmful effects of neonicotinoids and other pollinator-toxic pesticides are not siloed in the environment, however. Declines in pollinator populations work their way up and down food chains and across food webs, from the plants depending upon pollination, to the people who rely on the healthful, nutrient-dense food that pollination provides. Pollination services are valued at $125 billion globally, and pollinators are responsible for one in three bites of food, including nuts, fruits, and vegetables. Past research has found that the loss of pollination services would have a devastating impact on global nutritional health, with women and children most affected. Already in the U.S., many communities lack access to healthy fruits and vegetables –allowing the pollinator crisis to continue unabated is likely to exacerbate these problems by increasing prices on important staples.

The Saving America's Pollinators Act will not only save America's pollinators. SAPA will help people who depend on pollination services for healthy food. SAPA will help underserved communities by eliminating unnecessary exposure to pesticides in public green spaces. SAPA will stop the poisoning of farmworkers who work on the farms that grow the plants that bees and insects pollinate. SAPA will also protect the broader web of life that is being devastated by the use of systemic insecticides. According to the Task Force on Systemic Insecticides, consisting of 242 scientists from across the world, “The balance of evidence strongly suggests that these chemicals [neonicotinoids] are harming beneficial insects and contributing to the current massive loss of global biodiversity.”

Neonicotinoids also harm people directly when used to manage grub problems on turf, despite the availability of alternative methods.  The latest research links neonicotinoids to nervous system toxicity, reproductive damage, and birth defects. In particular, reviews have found links to birth defects of the heart and brain, and the development of finger tremors. Neonicotinoids appear to disproportionately affect the male reproductive system, and animal studies have found cause for concern – from decreased testosterone levels to abnormal and low sperm count (see NRDC for more on the harms of neonics to human health). As reported by the Black Institute, pesticides like glyphosate are disproportionately sprayed in black and brown communities, where public parks are often the only green space available for family picnics and outings.

Beneficial soil dwelling insects, benthic aquatic insects, and grain-eating vertebrates like songbirds are in danger from neonicotinoid use. Neonicotinoid concentrations detected in aquatic environments present hazards to aquatic invertebrates and the ecosystems they support. Neonics adversely affects shrimp and oyster health, decreasing their nutritional value.

There is also evidence of adverse effects harming bird populations. A single corn kernel coated with a neonicotinoid is toxic enough to kill a songbird. Studies conducted in the wild find songbirds that feed on neonicotinoid-contaminated seeds during their migration route display reduced weigh delayed travel, and low rates of survival. The author of ”Common insecticide threatens survival of wild, migrating birds,” ecotoxicologist Chrissy Morrisey, PhD, told Environmental Health News, “Our study shows that this is bigger than the bees — birds can also be harmed by modern neonicotinoid pesticides which should worry us all.” Data from the Netherlands has shown that the most severe bird population declines occurred in those areas where neonicotinoid pollution was highest. These data are alarming in the context of reports finding three billion birds (30% total) lost since 1970 in part due to pesticide use.

SAPA will reorient pesticide regulation towards the protection of pollinators and ecosystem health–an approach that the U.S. Environmental Protection Agency has long failed to adequately consider.

Specifically, the Saving America's Pollinators Act:

  • Establishes a Pollinator Protection Board (PPB), consisting of scientists, beekeepers, farmers, and conservationists that have no direct or indirect ties to pesticide companies, in order to evaluate pesticides for their toxicity to pollinators and pollinator habitat;
  • Cracks down on insecticides that are toxic to pollinators by canceling the registration of neonicotinoid pesticides or pesticides containing imidacloprid, clothianidin, thiamethoxam, dinotefuran, acetamiprid, sulfoxaflor, flupyradifurone, or fipronil until they are properly reviewed by the Pollinator Protection Board; and
  • Implements a state-of-the-art monitoring network for native bees, ensuring that experts and the general public have up-to-date information on the status of native bee populations.

The newest bill language also updates the standard to which the PPB regulates toxic pesticides, making determinations on whether the pesticide presents an unacceptable hazard, based upon the potential to cause harm, including injury, illness, or damage to honey bees, and other pollinators, or pollinator habitat. This language would set pesticide regulation more in line with the precautionary approach taken by the European Union and other international bodies.

Letter to Non-cosponsoring Representatives

In order to reverse the devastating declining in the U.S. pollinator populations, your support of the Saving America’s Pollinators Act of 2021 is urgently needed.

The toxic pesticides addressed by this legislation are acute and chronic poisons for pollinator populations. Studies show these chemicals can be taken up by flowering plants and exuded in the pollen, nectar, and dew droplets honey bees and other pollinators feed on. Exposure then impairs pollinator reproduction, navigation, and foraging, suppresses immune system functioning, and weakens the ability to respond to parasites, pathogens, and other stressors.

There is widespread consensus in the scientific community that systemic insecticides are responsible for pollinator declines and need to be restricted. The European Union and Canada have already taken action to address these pesticides–it is time for the United States to take a stand.

The Save America’s Pollinators Act not only cancels the more dangerous pollinator toxic pesticides; it also puts in place lasting protections for pollinator populations. Pesticides that pose risks to pollinators would undergo another level of review by a board of unbiased pollinator experts. If these experts determine a pesticide is too toxic to pollinators, the pesticide would be removed from market or not permitted for sale in the first place. In the face of an inadequate EPA protocol for protecting pollinators, we need SAPA passed today, before it is too late, and we lose the one in three bites of food that pollinators enable us to produce.

Thank you for your consideration.

Letter to Co-sponsoring Representatives

Thank you for co-sponsoring the Saving America’s Pollinators Act of 2021.

The toxic pesticides addressed by this legislation are acute and chronic poisons for pollinator populations. Studies show these chemicals can be taken up by flowering plants and exuded in the pollen, nectar, and dew droplets honeybees and other pollinators feed on. Exposure then impairs pollinator reproduction, navigation, and foraging, suppresses immune system functioning, and weakens the ability to respond to parasites, pathogens, and other stressors.

There is widespread consensus in the scientific community that systemic insecticides are responsible for pollinator declines and need to be restricted. The European Union and Canada have already taken action to address these pesticides–it is time for the United States to take a stand.

The Save America’s Pollinators Act not only cancels the more dangerous pollinator toxic pesticides; it also puts in place lasting protections for pollinator populations. Pesticides that pose risks to pollinators would undergo another level of review by a board of pollinator experts. If these experts determine a pesticide is too toxic, the pesticide would be removed from market or not permitted for sale in the first place. In the face of an inadequate EPA protocol for protecting pollinators, we need SAPA passed today, before it is too late, and we lose the one in three bites of food that pollinators enable us to produce.

Thank you for hearing this call and acting to protect pollinators.

07/06/2021 — Are Big Dairies Undercutting Organic Milk Producers and Organic Integrity—and What Can We Do About It?

06/28/2021 — Tell EPA to Ban All Triazines

The endocrine disrupting herbicide propazine (in the triazine family of frog-deforming endocrine disruptors) is set for cancellation by the U.S. Environmental Protection Agency (EPA). The move would eliminate use of the hazardous herbicide by the end of 2022. However, all pesticides in the triazine class, including atrazine and simazine, have similar properties and should be eliminated from use.

>>Tell EPA to finish the job by banning all triazines.

In November 2020, Beyond Pesticides and allied environmental groups launched a lawsuit against EPA for its intent to reregister the triazine family of chemicals. The agency's interim approval of the herbicides, conducted under the Trump administration, eliminates important safeguards for children's health and a monitoring programs intended to protect groundwater from contamination. As is typical with EPA, the agency merely proposed minor label changes in attempts to mitigate risks identified in its registration review. According to a release from EPA, it made the decision not out of concerns relating to human health and environmental protection, but in order to provide “regulatory certainty” for farmers and local officials.

In March 2021, the Biden administration requested a stay on the atrazine lawsuit brought by environmental groups, as it indicated it would review the Trump administration's actions on the chemicals. “It is possible that, in response to this review, EPA may undertake actions that could resolve some or all of the issues in this case,” EPA said in its motion to stay, Progressive Farmer reports.

If propazine's cancellation is the extent of the Biden administration's corrective actions after the Trump administration's complete abdication of responsibility to human health and environmental protection, then it is not enough. With greenhouse uses already in the process of cancellation, propazine's remaining use is on sorghum. Although a hefty 200,000 lbs. of propazine are used each year, mainly in Texas, Oklahoma, and Kansas, this amount pales in comparison to the over 70 million lbs. of atrazine used throughout the United States.

Under an Endangered Species Act review, initiated by EPA only after a lawsuit from health and environmental groups, the triazine chemicals were found to adversely affect a range of species. Propazine was found to harm 64 endangered species, while simazine and atrazine were both likely to harm over 50% of all endangered species and 40% of their critical habitats.

EPA has long known about triazine's threats to wildlife, including its ability to chemically castrate male frogs. However, the agency has consistently defended the chemical, and sat by while independent researchers like Tyrone Hayes, PhD, who conducted seminal research on atrazine's endocrine disrupting properties, are pilloried by chemical industry propaganda. In a Critical Perspectives piece published in Environmental Toxicology and Chemistry last month, Jason Rohr, PhD, provides an in-depth investigation of the atrazine controversy.

“I argue that the atrazine controversy must be more than just a true story of cover-ups, bias, and vengeance,” he writes in the piece. “It must be used as an example of how manufacturing uncertainty and bending science can be exploited to delay undesired regulatory decisions and how greed and conflicts of interest—situations where personal or organizational considerations have compromised or biased professional judgment and objectivity—can affect environmental and public health and erode trust in the discipline of toxicology, science in general, and the honorable functioning of societies.”

The triazine class of chemicals also pose significant threats to human health and are particularly concerning in the context of the range of chemicals one may be exposed to in today's world. As Dr. Hayes noted a recent presentation at Beyond Pesticides' National Pesticide Forum, “Children in utero may be exposed to over 300 synthetic chemicals before they leave the womb… I would argue that a human fetus trapped in contaminated amniotic fluid is no different than one of my tadpoles trapped in a contaminated pond.”  

Atrazine has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia (where nasal passages are blocked at birth), and hypospadias (where the opening of a male's urethra is not located at the tip of the penis).

While industry consistently lines up local Congressmembers, former EPA officials, and agrichemical lobbyists to pressure EPA to keep triazines in the market, there is no evidence that the herbicides benefit the farmers these officials claim to represent. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would provide an economic benefit to farmers. “The winners,” the research concludes, “in an atrazine free future would include farm workers, farmers and their families, and others who are exposed to atrazine either directly from field uses or indirectly from contaminated tap water along with natural ecosystem that are currently damaged by atrazine.” 

During the Obama Administration, health and environmental advocates were on the defensive with propazine. After glyphosate-resistant crops predictably invaded genetically engineered cotton fields in Texas, growers requested propazine use on over 3 million acres of farm fields. Although EPA determined Texan farmers met the criteria for an emergency, a decision Beyond Pesticides disagreed with, the agency did find that groundwater risks from the proposed propazine use would be too risky. 

For more information on the dangers of atrazine and its chemical cousins, read Beyond Pesticides comments to EPA, and watch Dr. Tyrone Hayes presentations from past National Pesticide Forum events on Youtube.

>>Tell EPA to finish the job by banning all triazines.

Letter to EPA

I am pleased to hear that EPA has cancelled the registration of propazine herbicides. However, the proposed interim decisions (PIDs) on reregistration of atrazine and simazine demonstrate similar risks. These triazines are highly mobile and persistent in the environment and have been linked to numerous adverse health and environmental effects that have motivated many public interest campaigns to ban their use in the U.S. as well as in Europe. The Draft Ecological Risk Assessments for the Registration Review of Atrazine, Simazine, and Propazine dated October 5, 2016 found high risks that were supported by EPA's assessments.

EPA's Proposed Interim Decisions present data demonstrating unreasonable adverse effects. These hazards are unacceptable, especially in light of the availability of nontoxic alternatives. The hazards include:

* The technical mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH), which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset.

* Despite these endocrine disrupting effects, the PIDs propose reducing the margin of safety and underestimate exposure to children.

* EPA states, “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates in these same locations.”

* In spite of these findings, EPA will increase the level of atrazine allowed in waterways.

Please adhere to the statutory mandate of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and suspend the registration of these pesticides that pose unreasonable adverse health and environmental effects.

Thank you.

06/22/2021 — The Week of June 21 Is Pollinator Week—A Time to Take Personal and Community Action

Pollinator Week reminds us that change is critical to the survival of the planet and that we can take action, both in our households and communities and in the state and federal policy arena. 

Here's how YOU can take action...

1. Create an organic habitat on your own property or a space in the community—such as the library grounds, medians, and rights-of-way. Given that plant starts in many garden centers across the country are grown from seeds coated with bee-toxic neonicotinoid pesticides, or drenched with them, Beyond Pesticides has compiled a comprehensive directory of companies and organizations that sell organic seeds and plants to the general public. Included in this directory are seeds for vegetables, flowers, and herbs, as well as living plants and seedlings. [We are always updating the directory, so send us names of companies that should be added and we will.]

2. Go organic in the management of all your town's public spaces—parks, playing fields, school grounds, and open space. Check out the information on talking with your neighbors, local organizations, and elected officials about advancing our model local policy. Then you can see what other communities are doing across the country. Also, see the cost comparison between organic and chemical-intensive land management.

3. Tell President Biden and your governor to ban all pesticides and treated seeds that harm pollinators—from neonicotinoids, fipronil, synthetic pyrethroids, organophosphate insecticides to the herbicide glyphosate—and assist land managers, from farmers to landscapers, to transition to organic practices that prohibit the use of these deadly chemicals. Tell the Biden administration to reestablish a national strategy to work across agencies to eliminate our reliance on toxic pesticides and assist in the transition to organic land management—in the interest of protecting ecosystems against the ongoing dramatic destruction of biodiversity and the insect apocalypse. Tell your governor to do the same at the state level.

>>Tell President Joe Biden and your governor to get serious about protecting pollinators with a comprehensive strategy.

Letter to President Biden

During this Pollinator Week, it time to act to get serious about protecting pollinators and in so doing eliminate toxic pesticides that are contributing to dramatic declines in biodiversity. As The New York Times wrote in November 2018, “The Insect Apocalypse is Here.” Scientists and researchers have identified three broad contributors to the crisis: pesticide use, habitat destruction, and climate change. With your leadership, we can shift to alternative products and practices, improve biodiversity, and begin to repair the damage done by chemical-intensive land management practices.

To ensure a serious and meaningful effort to address the threat to pollinators, we need to remove from the market pesticides and treated seeds that have been shown, through independent peer-reviewed scientific review, to harm pollinators. This requires comprehensive action against neonicotinoids and related compounds, fipronil, synthetic pyrethroids, organophosphate insecticides and the herbicide glyphosate. At the same time, it is critical that you bring the resources of government to assist land managers, from farmers to landscapers, to transition to organic practices that prohibit the use of these and other deadly chemicals.

We urge you to reestablish a national strategy to work cross-agency to eliminate our reliance on toxic pesticides that harm pollinators and assist in the transition to organic land management in the interest of protecting ecosystems and dramatic destruction of biodiversity, identified by researchers as the insect apocalypse.

In a systematic review of insect declines by researchers Francisco Sánchez-Bayo, PhD and Kris A.G. Wyckhuys, PhD, pesticide use was identified as a critical component in addressing the crisis at large. “A rethinking of current agricultural practices, in particular a serious reduction in pesticide usage and its substitution with more sustainable, ecologically-based practices, is urgently needed to slow or reverse current trends, allow the recovery of declining insect populations and safeguard the vital ecosystem services they provide,” they write.

Without your leadership to elevate the response to the threat to pollinators, our future is threatened. As renowned UK ecologist and coauthor of the study “More than 75 percent decline over 27 years in total flying insect biomass in protected areas,” David Goulson, PhD, has said, “We appear to be making vast tracts of land inhospitable to most forms of life, and are currently on course for ecological Armageddon. If we lose the insects then everything is going to collapse.”

I look forward to learning that you are moving forward with this recommendation to save our future.

Thank you.

Letter to Governors

During this Pollinator Week, it time to get serious about protecting pollinators and in so doing eliminate toxic pesticides that are contributing to dramatic declines in biodiversity. As The New York Times wrote in November 2018, “The Insect Apocalypse is Here.” Scientists and researchers have identified three broad contributors to the crisis: pesticide use, habitat destruction, and climate change. With your leadership, we can shift to alternative products and practices, improve biodiversity, and begin to repair the damage done by chemical-intensive land management practices.

To ensure a serious and meaningful effort to address the threat to pollinators, we need to remove from the market pesticides and treated seeds that have been shown, through independent peer-reviewed scientific review, to harm pollinators. This requires comprehensive action against neonicotinoids and related compounds, fipronil, synthetic pyrethroids, organophosphate insecticides and the herbicide glyphosate. At the same time, it is critical that you bring the resources of government to assist land managers, from farmers to landscapers, to transition to organic practices that prohibit the use of these and other deadly chemicals.

We urge you to establish a state strategy to work across agencies to eliminate our reliance on toxic pesticides that harm pollinators and assist in the transition to organic land management in the interest of protecting ecosystems and dramatic destruction of biodiversity, identified by researchers as the insect apocalypse.

In a systematic review of insect declines by researchers Francisco Sánchez-Bayo, PhD and Kris A.G. Wyckhuys, PhD, pesticide use was identified as a critical component in addressing the crisis at large. “A rethinking of current agricultural practices, in particular a serious reduction in pesticide usage and its substitution with more sustainable, ecologically-based practices, is urgently needed to slow or reverse current trends, allow the recovery of declining insect populations and safeguard the vital ecosystem services they provide,” they write.

Without your leadership to elevate the response to threat to pollinators, our future is threatened. As renowned UK ecologist and coauthor of the study “More than 75 percent decline over 27 years in total flying insect biomass in protected areas,” David Goulson, PhD, has said, “We appear to be making vast tracts of land inhospitable to most forms of life, and are currently on course for ecological Armageddon. If we lose the insects then everything is going to collapse.”

I look forward to learning that you are moving forward with this recommendation to save our future.

Thank you.

06/14/2021 — EPA Must Consider Cutting-Edge Science

Beyond Pesticides reports regularly on new science showing how pesticides harm human health and ecosystems. This science is not factored into EPA decisions.

>>Tell EPA that Cutting Edge Science Must be Considered…See Science and Policy at the National Pesticide Forum.

More than 50 pesticide active ingredients have been identified as endocrine disruptors that mimic the action of a naturally-produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; block hormone receptors in cells, thereby preventing the action of normal hormones; or affect the synthesis, transport, metabolism and excretion of hormones, thus altering the concentrations of natural hormones. Endocrine disruptors have been linked to attention deficit hyperactivity disorder (ADHD), Parkinson's and Alzheimer's diseases, diabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorders, childhood and adult cancers, and other metabolic disorders. Similar effects are found in other species. In spite of legal requirements and the flood of research, EPA issues Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption. EPA continues to register pesticides posing unreasonable health effects.

There is much research on the impacts of pesticides on aquatic and terrestrial invertebrates and plants, including overwhelming evidence of an on-going insect apocalypse and collapse of bird populations. EPA ignores this science and continues to register pesticides that contribute to the problem. 

EPA ignores science on dangers to pollinators, the human gut microbiome, soil organisms, and effects of breakdown products and combinations of ingredients. This cutting edge science is not factored into EPA's static pesticide evaluation program, given its structure. What is needed is a precautionary approach that removes chemicals from the market when science raises reasonable doubts as to their safety. Not to do so is to put economic value to pesticide manufacturers above the health of human beings and the planet.

>>Tell EPA that Cutting Edge Science Must be Considered…See Science and Policy at the National Pesticide Forum.

Letter to EPA

Scientific journals report regularly on new science showing how pesticides harm human health and ecosystems. This science is not factored into EPA decisions.

More than 50 pesticide active ingredients have been identified as endocrine disruptors that mimic the action of a naturally-produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; block hormone receptors in cells, thereby preventing the action of normal hormones; or affect the synthesis, transport, metabolism and excretion of hormones, thus altering the concentrations of natural hormones. Endocrine disruptors have been linked to attention deficit hyperactivity disorder (ADHD), Parkinson’s and Alzheimer’s diseases, diabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorders, childhood and adult cancers, and other metabolic disorders. Similar effects are found in other species. In spite of legal requirements and the flood of research, EPA issues Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption. EPA continues to register pesticides posing unreasonable health effects.

There is much research on the impacts of pesticides on aquatic and terrestrial invertebrates and plants, including overwhelming evidence of an on-going insect apocalypse and collapse of bird populations. EPA ignores this science and continues to register pesticides that contribute to the problem.

EPA ignores science on dangers to pollinators, the human gut microbiome, soil organisms, and effects of breakdown products and combinations of ingredients. This cutting-edge science cannot be factored into EPA’s static pesticide evaluation program. It requires a precautionary approach that removes chemicals from the market when science raises reasonable doubts as to their safety. Not to do so is to put economic value to pesticide manufacturers above the health of human beings and the planet.

Please revise pesticide registration reviews to incorporate precaution.

Thank you.

06/09/2021 — Tell Home Depot and Lowe’s to Promote Herbicide Alternatives

Learn More About Organic Land Care at the National Pesticide Forum

Beyond Pesticides and Friends of the Earth (FOE) collaborated to analyze herbicide products at two of the most popular home and garden retailers, Home Depot and Lowe's. This new Commercial Herbicide Analysis highlights the adverse health and environmental effects of widely available toxic pesticides while encouraging retailers to expand on—and consumers to use—safer, least/nontoxic pesticide approaches.

>>Tell Home Depot and Lowe's to remove toxic herbicides from their shelves and replace them with products that promote least-toxic practices.

According to Akayla Bracey, Beyond Pesticides' science and regulatory manager and lead researcher on the review, “People generally aren't aware that the pesticides widely available in garden retailers like Home Depot and Lowe's are a threat to health and the environment, and that there are safer approaches that are available and used in organic land management.” 

When it comes to weeds, gardeners need good tools that enable them to control them with minimal effort and damage to their plants. Although gardeners differ in their preference for style of garden hoe, all must be sharp to operate efficiently, so files for sharpening should be located near the hoes, and customer service representatives should be prepared to demonstrate their use. 

Weed-free and chemical-free organic mulches—such as straw or wood chips—are garden essentials for both weed control and long-term organic fertility. Speaking of fertility, natural fertility builds healthy soil for growing strong plants that resist insect and disease damage, while synthetic fertilizers kill valuable soil organisms. Stores should stock fertility products approved for use in organic production.

Friends of the Earth composed a comprehensive list of products sold by Home Depot and Lowe's by browsing online and local stores. Furthermore, the organization allowed each retailer to review and edit the list. Beyond Pesticides evaluated active ingredients in all products and performed a toxicity analysis using available epidemiological and laboratory and studies.

The analysis, conducted by Beyond Pesticides, reveals that approximately half of all Home Depot herbicide products (24 of 51) and Lowe's herbicide products (23 of 40) contain ingredients considered Highly Hazardous Pesticides (HPPs). The United Nations Food and Agriculture Organization (FAO) classifies HHPs as “pesticides linked with a high incidence of severe or irreversible adverse effects on human health or the environment.” The following active ingredients pose the most harm to human, animal, and ecosystem health, including cancer, reproductive harm, neurotoxicity, and hormone (endocrine) disruption: glyphosate, 2,4-D, dicamba, mecoprop, and pendimethalin. Of these five chemicals, all but dicamba are classifiable as HHPs. Only 29 percent of Home Depot (15 of 51) and 17 percent of Lowe's (7 of 40) herbicide products qualify as least-toxic or organic.

View the analysis. For more information, see Beyond Pesticides Lawns and Landscapes webpage and Products Compatible with Organic Landscape Management.

>>Tell Home Depot and Lowe's to remove toxic herbicides from their shelves and replace them with products that promote least-toxic practices. Learn more about encouraging organic land care practices in your community by tuning in to Day 3 of the virtual National Pesticide Forum on June 8.

Letter to Home Depot

A recent report by Beyond Pesticides and Friends of the Earth shows that about half (24 of 51) of the herbicide products stocked by your stores contain ingredients considered Highly Hazardous Pesticides (HPPs). The United Nations Food and Agriculture Organization (FOA) classifies HHPs as “pesticides linked with a high incidence of severe or irreversible adverse effects on human health or the environment.” The following active ingredients pose the most harm to human, animal, and ecosystem health, including cancer, reproductive harm, neurotoxicity, and hormone (endocrine) disruption: glyphosate, 2,4-D, dicamba, mecoprop, and pendimethalin. Of these five chemicals, all but dicamba are classifiable as HHPs. Only 29 percent of Home Depot (15 of 51) herbicide products qualify as least-toxic or organic.

Many customers are unaware of what chemicals are in the products they use, let alone their chemical effects. When it comes to weeds, your customers need good tools that enable them to control them with minimal effort and damage to their plants. Although gardeners differ in their preference for style of garden hoe, all must be sharp to operate efficiently, so files for sharpening should be located near the hoes, and customer service representatives should be prepared to demonstrate their use.

Weed-free and chemical-free organic mulches—such as straw or wood chips—are garden essentials for both weed control and long-term organic fertility. Speaking of fertility, natural fertility builds healthy soil for growing strong plants that resist insect and disease damage, while synthetic fertilizers kill valuable soil organisms. Please stock fertility products approved for use in organic production.

Please replace the highly hazardous pesticide products in your stores with products (http://bp-dc.org/WSHS-brochure) to help customers grow organically—high quality tools, organic materials, and least-toxic pesticides (https://bp-dc.org/organic-compatible) approved for use in organic production.

Thank you.

Letter to Lowe's

A recent report by Beyond Pesticides and Friends of the Earth showed that about half (23 of 40) of the herbicide products stocked by your stores contain ingredients considered Highly Hazardous Pesticides (HPPs). The United Nations Food and Agriculture Organization (FOA) classifies HHPs as “pesticides linked with a high incidence of severe or irreversible adverse effects on human health or the environment.” The following active ingredients pose the most harm to human, animal, and ecosystem health, including cancer, reproductive harm, neurotoxicity, and hormone (endocrine) disruption: glyphosate, 2,4-D, dicamba, mecoprop, and pendimethalin. Of these five chemicals, all but dicamba are classifiable as HHPs. Only 17 percent of Lowe’s (7 of 40) herbicide products qualify as least-toxic or organic.

Many customers are unaware of what chemicals are in the products they use, let alone their chemical effects. When it comes to weeds, your customers need good tools that enable them to control them with minimal effort and damage to their plants. Although gardeners differ in their preference for style of garden hoe, all must be sharp to operate efficiently, so files for sharpening should be located near the hoes, and customer service representatives should be prepared to demonstrate their use.

Weed-free and chemical-free organic mulches—such as straw or wood chips—are garden essentials for both weed control and long-term organic fertility. Speaking of fertility, natural fertility builds healthy soil for growing strong plants that resist insect and disease damage, while synthetic fertilizers kill valuable soil organisms. Please stock fertility products approved for use in organic production.

Please replace the highly hazardous pesticide products in your stores with products (http://bp-dc.org/WSHS-brochure) to help customers grow organically—high quality tools, organic materials, and least-toxic pesticides (https://bp-dc.org/organic-compatible) approved for use in organic production.

Thank you.

06/02/2021 — EPA Must Protect Farmworkers

Hear Farmworker Community Members at National Forum on June 1

Farmworkers are at greatest risk from pesticides. EPA's policies toward farmworkers comprise a blatant example of systemic racism. Although everyone suffers from pesticide poisoning, farmworkers and their families shoulder a disproportionate burden of the hazards. Agricultural justice demands that we ensure a workplace with fair wages and benefits, no discrimination or coercion, and protection from hazards, such as harmful chemicals, including pesticides. Acknowledging, respecting, and sustaining the workers who plant, cultivate, and harvest our food is central to the basic values and principles that advance sustainable practices.

>>Tell EPA to protect farmworkers from pesticides.

Worker Protection Standards Are Inadequate to Protect Farmworkers
Worker protection standards are set by the U.S. Environmental Protection Agency (EPA) under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). The original 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 looming in the late 1970s, the Carter Administration funded an effort, conducted by Beyond Pesticides' executive director, to reach out to workers and collect data on their experiences with pesticide exposure and poisoning in the fields.

Through a series of field hearings in collaboration with the nongovernmental organization Rural America, and EPA's Office of Pesticide Programs, federal and state agencies heard directly from farmworkers. Although EPA concluded in 1983 that the regulations were inadequate to protect agricultural workers, it took until 1992 to update the Agricultural Worker Protection Standards (WPS).

Those 1992 updates to the WPS were intended to eliminate or reduce exposure to pesticides, mitigate exposures that occur, and inform employees about the hazards of pesticides. Despite these intentions, the updated WPS still did not adequately protect farmworkers. These standards have been notoriously difficult to enforce and require no record keeping documenting whether the rules have been implemented and only minimal training—all of which can threaten farmworkers and their families.

On September 28, 2015, EPA finally released its new regulation regarding farmworker pesticide safety, revising the WPS, which had not been updated for more than 20 years. These revisions attempt to strengthen the standards through increased training for workers who handle pesticides, improved notification of pesticide applications, and a first-time minimum age requirement for children to work around pesticides. However, the Trump Administration weakened these standards, including reducing protection offered by Application Exclusion Zones (buffer zones).

Systemic Racism is Embodied in EPA's Risk Assessments
Exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. For example, EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—and such exposures that routinely occur to fenceline communities, farmworkers, and factory workers.

In the past, EPA has admitted that even with maximum feasible personal protective equipment (PPE) and engineering controls, including all provisions required by the WPS, risks to workers still exceed EPA's levels of concern. A 2008 study analyzing poisonings of pesticide workers between 1998 and 2005 concluded that in 30% of the cases of high levels of pesticide exposure, all labeling requirements, including those involving re-entry and PPE, had been followed — clearly demonstrating that the WPS and/or labeling requirements are inadequate.

Farm work is demanding and dangerous physical labor. As the scientific literature confirms, farmworkers, their families, and their communities face extraordinary risks from pesticide exposures. Pesticide application and drift result in dermal, inhalation, and oral exposures that are typically underestimated. A 2004 study detected agricultural pesticides in homes near to agricultural fields. According to a 2010 study, workers experience repeated exposures to the same pesticides, evidenced by multiple pesticides routinely detected in their bodies. As a result of cumulative long-term exposures, farmworkers and their children, who often also work on the farms, are at risk of developing serious chronic health problems such as cancer, neurological impairments, and Parkinson's disease. Children, according to an American Academy of Pediatrics (AAP) report (2012), face even greater health risks compared to adults when exposed to pesticides. For more information, read our factsheet, Children and Pesticides Don't Mix.

What We Can Do
Our food choices have a direct effect on those who, around the world, grow and harvest what we eat. This is why food labeled organic is the right choice. In addition to serious health questions linked to actual residues of toxic pesticides on the food we eat, our food buying decisions support or reject hazardous agricultural practices and the protection of farmworkers and farm families. See Beyond Pesticides' guide to Eating with a Conscience to see how your food choices can protect farmworkers. In addition to choosing organic, it is important to consider food labels that create standards for farmworker safety and fairness. See below for more information and resources on how to uphold strong agricultural justice standards.

>>Tell EPA that we need strong Worker Protection Standards, and more fundamentally, EPA must base its pesticide risk assessments on the dangers to the most vulnerable people—farmworkers and their families. EPA must reverse its policy and require that risk assessments adopt a standard that protects farmworkers.

Beyond Pesticides is holding a virtual National Pesticide Forum, in which we address these issues. On Tuesday, June 1, the Forum will include a panel of farmworker community representatives, followed by an interactive discussion with farmworker representatives. Plan now to participate.

Letter to EPA

Farmworkers are at greatest risk from pesticides. EPA’s policies toward farmworkers comprise a blatant example of systemic racism. Although suffer from pesticide poisoning, farmworkers and their families shoulder a disproportionate burden of the hazards.
Agricultural justice must ensure a workplace with fair wages and benefits, no discrimination or coercion, and protection from hazards, such as harmful chemicals, including pesticides. Acknowledging, respecting, and sustaining the workers who plant, cultivate, and harvest our food is central to the basic values and principles that advance sustainable practices.

Worker protection standards (WPS) are set by the U.S. Environmental Protection Agency (EPA) under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). The various iterations of the WPS have failed to adequately protect farmworkers. These standards have been notoriously difficult to enforce, and require no record keeping documenting whether the rules have been implemented and only minimal training—all of which can threaten farmworkers and their families. On September 28, 2015, EPA finally released its new regulation regarding farmworker pesticide safety, revising the WPS. These revisions attempt to strengthen the standards through increased training for workers who handle pesticides, improved notification of pesticide applications, and a first-time minimum age requirement for children to work around pesticides. However, the Trump Administration weakened these standards, including reducing protection offered by Application Exclusion Zones (buffer zones).

Systemic racism is embodied in EPA’s risk assessments. Exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. For example, EPA routinely calculates worker exposure separately from other exposures. EPA has admitted that even with maximum feasible personal protective equipment (PPE) and engineering controls, including all provisions required by the WPS, risks to workers still exceed EPA’s levels of concern. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—and such exposures routinely occur to fenceline communities, farmworkers, and factory workers.

Please implement strong Worker Protection Standards and reverse the weakening changes of the Trump administration. More fundamentally, EPA must base its pesticide risk assessments on the dangers to the most vulnerable people—farmworkers and their families. EPA must reverse its policy and require that risk assessments adopt a standard that protects farmworkers.

Thank you.

05/25/2021 — Regenerative Agriculture Can Fight Climate Change—But Only if We Define It Correctly

Agriculture is a major contributor to climate change. In a recent article in Science, Clark et al. show that even if fossil fuel emissions were eliminated immediately, emissions from the global food system alone would make it impossible to limit warming to 1.5°C and difficult even to realize the 2°C target. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced GHG emissions. The contribution of animal agriculture has been estimated at 14.5% to 87% or more of total GHG emissions. These estimates include emissions of carbon dioxide, methane, nitrous oxide, and ammonia. The carbon dioxide contribution largely comes from converting land from natural forest to pasture or cropland.

>>Tell EPA and USDA that “regenerative” agriculture must be organic.

“Regenerative” agriculture is widely considered to be a solution for reducing or even reversing these impacts. Unfortunately, a movement by promoters of chemical-intensive agriculture has fooled some environmentalists into supporting toxic “regenerative” agriculture. The so-called “regenerative agriculture” promoted by these groups ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients as well as for the heat and energy driving chemical reactions. It is important to see through this deception.

Regenerative agriculture must be organic.

Organic agriculture practices reduce greenhouse gas (GHG) emissions. 

Reducing Emissions of Nitrogen Oxides. Excessive use of nitrogen fertilizers in chemical-intensive agriculture is driving global nitrous oxide (N2O) emissions higher than any projected scenario, putting the world at greater risk of a climate catastrophe. According to research published by an international team of scientists in the journal Nature, failure to adequately address nitrous oxide emissions has the potential to impede the ability for the world to keep warming below the 2°C target established under the Paris Climate Agreement, necessitating further cuts in other greenhouse gasses.
 
A 2018 study from the University of Virginia and The Organic Center found that “reactive” nitrogen, in the form readily available to be taken up by plants, is conserved in organic systems. Jessica Shade, PhD of The Organic Center, noted that the research was “significant and timely because its findings show that many common organic farming practices—like composting and the use of manure fertilization in place of synthetic fertilizers—can recycle reactive nitrogen that is already in the global system, rather than introducing new reactive nitrogen into the environment, and thus have a much smaller environmental impact.”

Organic practices sequester carbon. Organic systems sequester significant amounts of carbon from the atmosphere into on-farm soil carbon. A report from the Rodale Institute expounds on these benefits. It reads, “Simply put, recent data from farming systems and pasture trials around the globe show that we could sequester more than 100% of current annual CO2 emissions with a switch to widely available and inexpensive organic management practices, which we term 'regenerative organic agriculture.' These practices work to maximize carbon fixation while minimizing the loss of that carbon once returned to the soil, reversing the greenhouse effect.”

Organic practices preserve natural lands and biodiversity. Natural forests are more effective than tree plantations in sequestering carbon. Preserving natural land increases biodiversity, which also reduces dependence on petroleum-based pesticides. Organic farms are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife, as required by § 205.200 of the regulations and per the § 205.2 definition of Natural resources of the operation.”

It is crucial, as we move forward with a plan to harness agriculture in the fight against climate change, that we not be misled into promoting the same practices that have created the problem. As aptly stated by Jeff Moyer of the Rodale Institute, "We believe that in order to be regenerative, you have to start by being organic. It's a little disingenuous to say you can regenerate soil health and sequester carbon and still use nitrogen fertilizers and synthetic pesticides. What you're really saying is equivalent to saying 'I want to be healthy as a person, but I still want to smoke cigarettes."

>>Tell EPA and USDA that “regenerative” agriculture must be organic.

Letter to EPA and USDA

I am concerned that “regenerative” agriculture, which is widely considered to be a solution for reducing or even reversing climate change, will have negative impacts if not properly defined. Unfortunately, a movement by promoters of chemical-intensive agriculture has fooled some environmentalists into supporting toxic “regenerative” agriculture. The so-called “regenerative agriculture” promoted by these groups ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients as well as for the heat and energy driving chemical reactions. It is important to see through this deception.

The climate crisis and the devastating decline in biodiversity are escalating as a result of uncontrolled and unnecessary reliance on toxic chemicals. These threats to life require a meaningful holistic strategy to end our fossil fuel dependence and use of materials that release harmful levels of noxious gases (including greenhouse gases). The current carbon market proposals fall short.

The lack of a holistic approach allows continued disproportionate hazards to people of color and communities living near toxic sites. Alongside proposals to replace the combustion engine with electric vehicles, agriculture must—across the board and on an expedited five-year schedule—shift to organic practices. Organic practices both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. Importantly, the data show that organic agriculture now operates without sacrificing productivity or profitability. While the vested economic interests in the petroleum and chemical industry cling to the status quo, there are good jobs and money to be made in a green economy.

We need a national plan to shift to 100% organic farming. Organic land management is more effective at reducing emissions and sequesters carbon in the soil. There is already a national program for certifying farms that meet organic standards. Organic operations must “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.”

Undefined “regenerative” agriculture falls short by ignoring the direct climate impacts of nitrogen fertilizers, the damage to soil health and ecosystem services caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients and for the heat and energy-driving chemical reactions.

We need a national land management plan. Preserving natural land increases biodiversity, reducing dependence on petroleum-based pesticides, and is more effective in sequestering carbon. Biodiversity buffers against damage from climate change—for example, by protecting shorelines from storm damage.

Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change. I urge you to incorporate into a holistic approach, at the very least, the provisions included in the following:

* Climate Stewardship Act of 2019.
* The Agriculture Resilience Act of 2020.
* A pledge to conserve at least 30% of U.S. land and ocean by 2030 and 50% by 2050.
* The Resolution on a National Biodiversity Strategy.
* A $30 billion fund dedicated solely to fund the transition to organic agriculture, with a goal of achieving 100% organic farms by 2026.

Thank you.

05/17/2021 — Tell EPA to Ban Chlorpyrifos and Other Neurotoxic Pesticides

The U.S. Environmental Protection Agency (EPA) has less than two months to decide whether to cancel or modify its registration of the brain-damaging organophosphate insecticide chlorpyrifos, following a decision from a federal appeals court. The ruling comes after more than a decade of delay from the federal agency tasked with protecting public health and the environment from the hazards of chemicals like chlorpyrifos. The decision now falls to the Biden Administration's EPA Administrator Michael Regan, after the previous administration reversed a proposal to ban agricultural uses of chlorpyrifos in 2017. Most residential uses of the chemical were banned in 2000. 

>>Tell EPA to ban chlorpyrifos and other neurotoxic pesticides.

The target of action by which chlorpyrifos and many other pesticides kill is the nervous system. It is not surprising, then, that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides relative to their body weight than adults, and whose developing organ systems are typically more sensitive to toxic exposures.

The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child's neurological, respiratory, immune, and endocrine systems, even at low exposure levels. Several pesticide families, such as synthetic pyrethroids, organophosphates, and carbamates, are also known to cause or exacerbate respiratory symptoms like asthma. The American Academy of Pediatrics wrote, “Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.”

In deciding whether to ban chlorpyrifos, a dangerous, proven neurotoxicant that has dire impacts on children, EPA's action to allow its continued use would be a failure of both its protective mission and ethics. Further, it would be an environmental justice failure, given that risks of exposure fall disproportionately on low-income African American and Latino families, including farmworker families, who are at the greatest risk of harm. The ban on chlorpyrifos will be an important first step in eliminating neurotoxic pesticides.

Chlorpyrifos is a poster child for the problems with federal pesticide regulation, but chlorpyrifos is just one of numerous organophosphate class chemicals remaining on the market. These WW2-era nerve agents are relics of the past that have no place in 21st century agriculture and should have already been eliminated from use. And beyond the organophosphates lie a number of other insecticides that the chemical-intensive farming will utilize as toxic substitutes. This toxic treadmill, with the increased use of bee-toxic neonicotinoid and highly hazardous synthetic pyrethroids, becomes a Faustian bargain for farmers who rely on toxic chemicals that are harmful to health and the environment.

The court set a hard deadline on the agency, which the judges appeared to indicate was particularly lenient given the circumstances. EPA now has 60 days to either modify the food tolerances (allowed levels of the chemical on food) of chlorpyrifos and publish a finding that the new tolerances are safe for infants and children, or revoke all tolerances. The agency must also determine whether to modify or cancel registration of the chemical for food use under federal pesticide law.

For these reasons it is critical that the need to eliminate this particular chemical be seen as an indictment of chemical-intensive farming as a whole. It is not acceptable to repeatedly weigh the evils of one hazardous chemical or another when other systems exist that do not rely on these products. Organic farming eliminates highly toxic synthetic pesticides in favor of practices that enhance biodiversity, soil health, and climate resilience. Like the move away from fossil fuel dependent energy and toward renewable systems, organic practices will be the future of farming in the 21st century.

>>Tell EPA to ban chlorpyrifos and other neurotoxic pesticides.

Letter to EPA Administrator

The federal appeals court has given EPA less than two months to decide whether to cancel or modify its registration of the brain-damaging organophosphate insecticide chlorpyrifos. The ruling comes after more than a decade of delay from the federal agency—yours—tasked with protecting public health and the environment from the hazards of pesticides. The decision now falls to you, as the Biden Administration’s EPA Administrator, after the previous administration reversed a proposal to ban agricultural uses of chlorpyrifos in 2017. Most residential uses of the chemical were banned in 2000.

Chlorpyrifos and many other pesticides kill by targeting the nervous system. It is not surprising, then, that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides relative to their body weight than adults, and whose developing organ systems are typically more sensitive to toxic exposures.

The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child's neurological, respiratory, immune, and endocrine systems, even at low exposure levels. Several pesticide families, such as synthetic pyrethroids, organophosphates, and carbamates, are also known to cause or exacerbate respiratory symptoms like asthma. The American Academy of Pediatrics wrote, “Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.”

In the upcoming decision, EPA’s action to allow its continued use of chlorpyrifos—a dangerous, proven neurotoxicant that has dire impacts on children—would be a failure of both its protective mission and ethics. Further, it would be an environmental justice failure, since risks of exposure fall disproportionately on low-income African American and Latino families, including farmworker families, who are at the greatest risk of harm. The ban on chlorpyrifos will be an important first step in eliminating neurotoxic pesticides.

Chlorpyrifos is a poster child for the problems with federal pesticide regulation, but chlorpyrifos is just one of numerous organophosphate chemicals remaining on the market. These WW2-era nerve agents have no place in 21st century agriculture and should have already been eliminated from use. Beyond the organophosphates lie a number of other insecticides that the chemical-intensive farming will utilize as toxic substitutes. This toxic treadmill, with the increased use of bee-toxic neonicotinoid and highly hazardous synthetic pyrethroids, becomes a Faustian bargain for farmers who rely on toxic chemicals that are harmful to health and the environment.

The court set a hard deadline for the agency, which the judges appeared to indicate was particularly lenient given the circumstances. EPA now has 60 days to either modify the food tolerances (allowed levels of the chemical on food) of chlorpyrifos and publish a finding that the new tolerances are safe for infants and children, or revoke all tolerances. The agency must also determine whether to modify or cancel registration of the chemical for food use under federal pesticide law.

For these reasons it is critical that the chlorpyrifos story be regarded by EPA as an indication of the failure of chemical-intensive farming as a whole. It is not acceptable to repeatedly weigh the evils of one hazardous chemical or another when other systems exist that do not rely on these products. Organic farming eliminates highly toxic synthetic pesticides in favor of practices that enhance biodiversity, soil health, and climate resilience. Like the move away from fossil fuel dependent energy and toward renewable systems, organic practices will be the future of farming in the 21st century. Please ensure that EPA reviews all pesticides in light of these larger considerations.

Thank you.

05/10/2021 — USDA Must Complete Rulemaking Initiated by the National Organic Standards Board

USDA is dragging its heels in completing rulemaking recommended by the National Organic Standards Board (NOSB)—including recommendations passed as early as 2001 and including those concerning both materials and organic practices. This threatens organic integrity and public trust in the process governing the USDA organic label. When the Organic Foods Production Act (OFPA) was passed in 1990, supporters had grave mistrust of the commitment of the U.S. Department of Agriculture (USDA)—a department that had embraced chemical-intensive agriculture and promoted the dependence on pesticides and chemical fertilizers. Therefore, Congress built into the law protections by assigning a major role for the NOSB—an advisory board comprised of representatives of all the stakeholders including producers, processors, retailers, certifiers, consumers, scientists, and environmentalists. Not only must the NOSB vote on allowed synthetic materials used in organic production, but USDA must also consult with the NOSB on all aspects of the National Organic Program (NOP). 

>>Tell USDA that NOSB recommendations must be proposed as regulations.

Crucial to organic practices, and written into OFPA, is the concept of continuous improvement. The importance of this concept is most apparent in materials review, which includes a sunset provision that requires all synthetic materials used in crop and livestock production and non-organic ingredients used in processing to be re-considered every five years. If organic producers no longer need those materials or new issues of concern have been identified, they should no longer be allowed. However, continuous improvement extends to all aspects of the organic program, including regulations governing organic practices. 

USDA has had difficulty with the concept of continuous improvement because it requires flexibility that is unusual in regulatory programs across government. The biggest obstacle, according to USDA, is the Office of Management and the Budget (OMB). Ever since the Reagan administration, regulatory review by the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and the Budget (OMB) has prevented agencies from promulgating new regulations based on new science and technologies that are more protective of health and the environment—the argument being that it causes economic dislocation for the regulated industry. OIRA acts as a gatekeeper to new regulations and has generally resisted changes to the status quo—even in regulations designed to adapt to new science and technology.

Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with the goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order reverses the historical trend of status-quo regulatory reviews required by the White House Office of Management and Budget (OMB) that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers). Instead, the President's EO, Modernizing Regulatory Review, sets the stage for the adoption of agency policy across government to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism). It allows—even promotes—the policy of continuous improvement.

NOP's list of NOSB recommendations includes those on which USDA has refused to take action as well as those which have lingered for years. USDA has refused to prohibit the use of sodium nitrate, carrageenan, inulin-oligofructose enriched, Turkish bay leaves, and whey protein concentrate as recommended by the NOSB. It has failed to act on recommendations to examine individual non-disclosed “inert” ingredients. It has closed consideration of several practice standards and let others languish. If the EO has any meaning, then USDA must act to bring these recommendations to the regulatory arena, where the public may provide comments and they can be evaluated against the new criteria of the EO, as well as the old criterion of continuous improvement.

>>Tell USDA that NOSB recommendations must be proposed as regulations.

Letter to USDA Secretary Vilsack

Congress built into the Organic Foods Production Act a major role for the National Organic Standards Board (NOSB)—an advisory board comprised of representatives of organic stakeholders, including producers, processors, retailers, certifiers, consumers, scientists, and environmentalists. Not only must the NOSB vote on the allowance of synthetic materials used in organic production, but USDA must also consult with the NOSB on all aspects of the National Organic Program (NOP).

Unfortunately, USDA still fails to complete rulemaking recommended by the NOSB—including recommendations passed as early as 2001 and including those concerning both materials and organic practices.

Crucial to organic practices is the concept of continuous improvement. The importance of this concept is most apparent in materials review, which includes a sunset provision that requires all synthetic materials used in crop and livestock production and non-organic ingredients used in processing to be re-considered every five years. If organic producers no longer need those materials or new issues of concern have been identified, they should no longer be allowed. However, continuous improvement extends to all aspects of the organic program.

USDA has had a difficulty with the concept of continuous improvement because it requires flexibility that is unusual in regulatory programs. The biggest obstacle, according to USDA, is the Office of Management and the Budget (OMB). Ever since the Reagan administration, regulatory review by the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and the Budget (OMB) has prevented agencies from promulgating new regulations. OIRA acts as a gatekeeper to new regulations and has generally resisted changes to the status quo—even in regulations designed to adapt to new science and technology.

Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order reverses the historical trend of status-quo regulatory reviews required by OMB that typically support vested economic interests. Instead, the President’s EO, Modernizing Regulatory Review, sets the stage for the adoption of agency policy across government to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism). It allows—even promotes—the policy of continuous improvement.

NOP’s list of NOSB recommendations includes those on which USDA has refused to take action as well as those which have lingered for years. USDA has refused to prohibit the use of sodium nitrate, carrageenan, inulin-oligofructose enriched, Turkish bay leaves, and whey protein concentrate as recommended by the NOSB. It has failed to act on recommendations to examine individual non-disclosed “inert” ingredients. It has closed consideration of several practice standards and let others languish. If the EO has any meaning, then USDA must act to bring these recommendations to the regulatory arena, where they can be judged by the public against the new criteria of the EO, as well as the old criterion of continuous improvement.

Thank you for your attention to this important issue.

05/03/2021 — Tell EPA to Remove Risky Disinfectants from Its Recommended List

Hazardous disinfectants are not necessary for protection against COVID-19, and the Centers for Disease Control and Prevention (CDC) is agreeing. The U.S. Environmental Protection Agency (EPA) seems to now agree, but has not changed it recommendations and listing for the public. Since last March, EPA has recommended disinfectants on List N for protecting against exposure to surfaces that would spread the virus causing COVID-19. Beyond Pesticides has evaluated the disinfectants, categorizing them as materials to seek out or to avoid. More recently, we evaluated the available evidence and recommended that schools and other institutions concentrate on providing adequate ventilation and protection from airborne virus.

>>Tell EPA to remove risky disinfectants from its recommended list.

EPA's List N contains products containing toxic chemicals such as chlorine bleach, peroxyacetic acid, alkyl dimethyl benzyl ammonium chlorides, didecyl dimethyl ammonium chloride, and other “quats,” sodium dichloro-s-triazinetrione, and hydrochloric acid. In addition to their outright toxicity, some of these can also trigger asthma attacks. Now, EPA has recognized this evidence and offered revised recommendations, stressing the need to avoid airborne transmission and stating in an infographic that the risk of contracting disease by touching contaminated surfaces is low and that disinfectants can trigger an asthma attack. However, List N remains as a resource for avoiding COVID-19. This confusion and misrepresentation of safety must stop.

As stated by the Centers for Disease Control and Prevention (CDC) on April 5,

People can be infected with SARS-CoV-2 through contact with surfaces. However, based on available epidemiological data and studies of environmental transmission factors, surface transmission is not the main route by which SARS-CoV-2 spreads, and the risk is considered to be low. The principal mode by which people are infected with SARS-CoV-2 is through exposure to respiratory droplets carrying infectious virus. In most situations, cleaning surfaces using soap or detergent, and not disinfecting, is enough to reduce risk. Disinfection is recommended in indoor community settings where there has been a suspected or confirmed case of COVID-19 within the last 24 hours. The risk of fomite transmission can be reduced by wearing masks consistently and correctly, practicing hand hygiene, cleaning, and taking other measures to maintain healthy facilities.

>>Tell EPA to remove risky disinfectants from its recommended list.

Letter to EPA

I am writing to ask you to revise your advice on disinfectants based on the revised assessment by the Centers for Disease Control and Prevention of the risk of COVID-19 from surface contamination (fomites) compared to respiratory exposure. I applaud EPA’s new infographic, which de-emphasizes the use of disinfectants, identifying hazards of disinfectants and the efficacy of cleaning with soap and water.

However, List N, which lists 529 products, many of which present respiratory hazards without distinguishing them from less hazardous products, is still the list to which websites and agencies refer. In view of the statements in the infographic—"In most situations, cleaning is enough to reduce risk,” and “Disinfectants can trigger an asthma attack”—EPA must evaluate substances on List N and remove the hazardous products or identify their hazards for those who consult the list.

Thank you for your immediate attention to this.

04/26/2021 — Tell Your U.S. Representative and Senators to Support the Agricultural Resilience Act

Representative Chellie Pingree (D-Maine), Senator Martin Heinrich (D-N.M), and 17 House cosponsors have reintroduced the Agriculture Resilience Act (ARA), which establishes a roadmap for achieving net-zero emissions from agriculture by 2040, while empowering farmers with the tools and resources needed to improve soil health, sequester carbon, reduce emissions, enhance their resilience, and tap into new market opportunities. Pingree first introduced the legislation in the 116th Congress, where it served as a model for recognizing agriculture as a part of the climate solution.

>>Ask your U.S. Representatives and Senators to Cosponsor the Agricultural Resilience Act and thank those who already have.

The ARA offers farmer-driven climate solutions to reach net-zero greenhouse gas emissions in U.S. agriculture by 2040:

  • Research 
    • Increases funding for USDA's Regional Climate Hubs
    • Invests in public breed and cultivar research
  • Soil Health 
    • Authorizes USDA to offer performance-based crop insurance discounts for practices that can be demonstrated to reduce risk
    • Creates new USDA grants to state and tribal governments to improve soil health
    • Directs USDA to establish a Soil Health and Greenhouse Gas Advisory Committee
  • Farmland Preservation and Farm Viability
    • Creates a new Local Agriculture Marketing Program (LAMP) subprogram to help 
    • Farmers develop and expand markets for farm products that improve soil health
    • Increases funding for the Agriculture Conservation Easement Program
  • Pasture-based Livestock 
    • Creates a new grant program to support small-scale meat and poultry processing infrastructure 
    • Establishes a new Grasslands 30 Pilot Program through which grasslands at risk of conversion to cropping or development can receive annual payments
  • On-farm Renewable Energy 
    • Increases funding for USDA's Rural Energy for America Program 
    • Directs USDA to research dual-use energy systems that integrate renewable energy production with crop or animal production
  • Food Loss and Waste 
    • Standardizes food date labeling to reduce consumer confusion
    • Creates a new USDA program to reduce food waste in schools

The ARA has received widespread support from businesses, climate change experts, farmers, and environmentalists for addressing climate threats to and from agriculture.

>>Ask your U.S. Representatives and Senators to Cosponsor the Agricultural Resilience Act. Thank those who already have.

Letter to Congress

I am writing to ask you to cosponsor the Agriculture Resilience Act (ARA), which establishes a roadmap for achieving net-zero emissions from agriculture by 2040, while empowering farmers with the tools and resources needed to improve soil health, sequester carbon, reduce emissions, enhance their resilience, and tap into new market opportunities. Rep. Chellie Pingree (D-Maine), Sen, Martin Heinrich (D-N.M), and 16 House cosponsors reintroduced the ARA that was first introduced in the 116th Congress, where it served as a model for recognizing agriculture as a part of the climate solution. The ARA has received widespread support from businesses, climate change experts, farmers, and environmentalists for addressing climate threats to and from agriculture.

Although farming has always been a risky business, extreme weather events and trade wars today create challenges that threaten food production and jeopardize farmers’ livelihoods. We must work to keep farmers on the land and in business. Climate change impacts agriculture, jeopardizing agricultural productivity, altering the nutrient content of crops, increasing the price of food, and creating other challenges.

Agriculture also impacts climate change, contributing 9.6% of total US greenhouse gas emissions in 2019. We can reduce that number and sequester more carbon in the soil by providing farmers with more diverse, voluntary, incentive-based conservation options. Farmers are already environmental stewards and have a clear interest in adopting conservation practices and renewable energy systems, based on adoption rate increases in the last USDA Census of Agriculture.

The ARA offers farmer-driven climate solutions to reach net-zero greenhouse gas emissions in U.S. agriculture by 2040, in these areas: research, soil health, farmland preservation and farm viability, pasture-based livestock, on-farm renewable energy, and food loss and waste.

Please cosponsor the Agricultural Resilience Act.

Thank you.

Letter to Cosponsors

I am writing to thank you for cosponsoring the Agriculture Resilience Act (ARA), which establishes a roadmap for achieving net-zero emissions from agriculture by 2040, while empowering farmers with the tools and resources needed to improve soil health, sequester carbon, reduce emissions, enhance their resilience, and tap into new market opportunities. Rep. Chellie Pingree (D-Maine), Sen, Martin Heinrich (D-N.M), and 16 House cosponsors reintroduced the ARA that was first introduced in the 116th Congress, where it served as a model for recognizing agriculture as a part of the climate solution.

Although farming has always been a risky business, extreme weather events and trade wars today create challenges that threaten food production and jeopardize farmers’ livelihoods. We must work to keep farmers on the land and in business. Climate change impacts agriculture, jeopardizing agricultural productivity, altering the nutrient content of crops, increasing the price of food, and creating other challenges.

Agriculture also impacts climate change, contributing 9.6% of total US greenhouse gas emissions in 2019. We can reduce that number and sequester more carbon in the soil by providing farmers with more diverse, voluntary, incentive-based conservation options. Farmers are already environmental stewards and have a clear interest in adopting conservation practices and renewable energy systems, based on adoption rate increases in the last USDA Census of Agriculture.

The ARA offers farmer-driven climate solutions to reach net-zero greenhouse gas emissions in U.S. agriculture by 2040, in these areas: research, soil health, farmland preservation and farm viability, pasture-based livestock, on-farm renewable energy, and food loss and waste.

Thank you for your support of the Agricultural Resilience Act.

04/19/2021 — Take the Ladybug Pledge, Support Beyond Pesticides & Bring Organic Landcare to Your City

In celebration of Earth Day and its fourth annual Ladybug Love campaign throughout the month of April, Natural Grocers is supporting Beyond Pesticides. The campaign celebrates insects that play a crucial role in food supply stability, and regenerative farming practices that use ladybugs and other beneficial insects instead of harmful synthetic pesticides to manage pests. Natural Grocers will donate $1 to Beyond Pesticides for each person who pledges (including renewals) “not use chemicals that harm ladybugs and other beneficial insects on their lawn or garden, and to support 100% organic produce.” 

>>1. Sign the Ladybug Pledge and support Beyond Pesticides. 

You do not have to be a Natural Grocers shopper to sign this nationwide pledge. For shoppers at any of Natural Grocers' 161 stores—all in 20 states west of the Mississippi—you can donate to Beyond Pesticides at checkout. Thank you! Ladybug Love also features in-store promotions.

>>2. Advertise your commitment with a Beyond Pesticides “Pesticide Free Zone” sign.

Natural Grocers' fundraising efforts have supported Beyond Pesticides and local leaders in converting the following parks and recreational areas to convert exclusively to organic practices and to eliminate the use of synthetic pesticides and fertilizers: Roosevelt Park in Longmont, CO, Chief Garry Park in Spokane, WA, Reid Park and Silverlake Fields in Tucson, AZ, Tempe Sports Complex in Tempe, AZ, Irwin Park in Eugene, OR, and Island Park in Springfield, OR. Beyond Pesticides has assisted other cities in such a transformation and invites people and local governments to contact us about the program at [email protected]

>>3. Sign the letter to ask your mayor to convert to organic landcare in city parks and other public places.

Letter to Mayors

A growing body of evidence in scientific literature shows that pesticide exposure can adversely affect neurological, respiratory, immune, and endocrine systems in humans, even at low levels. Children are especially sensitive to pesticide exposure because they (1) take up more pesticides (relative to their body weight) than do adults, and (2) have developing organ systems that are more vulnerable to pesticide impacts and less able to detoxify harmful chemicals. Fortunately, there are proven safe, effective, and affordable ways to maintain attractive lawns and playing fields without the use of toxic pesticides.

On this Earth Day, please commit to converting care of public lands in our city to organic practices. Organic practices have been proven to be successful and cost-effective. Avoiding use of toxic pesticides is good for public health, particularly in these times when respiratory assaults can increase the threat of COVID-19. Organic practices are also climate-friendly and support biodiversity.

Thank you.

04/12/2021 — Plan Now to Attend the National Pesticide Forum

Are you a regular National Pesticide Forum attendee? Have you always wanted to attend, but couldn’t afford the time and money? Are you new to the pesticide issue and want the best introduction, from Pesticides 101 to deep science? Do you want to meet with others who are taking their communities to natural organic land management? Do you want to meet with people doing amazing work across the country who are fighting the climate crisis, biodiversity collapse, and environmental injustice. This is your chance!

This year’s Forum is taking place virtually and will be held over four weeks, one day a week, May 25, June 1, 8, and 15. Plus, there’s a special pre-conference session Pesticide Literacy 101: Truth & Advertising on May 24. What’s more, we have registration options for all budgets.

Take Action: Sign-Up for the Forum and join with others across the country and around the world for a toxic-free future – confronting health threats, climate disasters, and biodiversity collapse. See you there!

What’s it all about? Scientific understanding. Collective action. Systemic change. A toxic-free future. Organic transition. The serious and existential environmental and health challenges that we face bring an urgency to the focus of this Forum and the work that is going on in communities around the U.S. and the world. Central to the solution is the elimination of petroleum-based pesticides and fertilizers in exchange for regenerative organic land management and nontoxic materials that stop the harm from toxic chemical production, use, and disposal. We recognize that this is the only way to protect our children and families, those in workplaces, pets, pollinators, and the rich diversity of organisms essential to life.

Who attends? The Forum brings together scientists, policymakers, practitioners, advocates, and activists to elevate with greater clarity the threats associated with environmental decline and collapse and the urgency with which we need to adopt solutions that are within our grasp. We hope you will participate! 

While we are celebrating Beyond Pesticides’ 40th anniversary this year, we still have much work to do and you are critical to the successful transition to organic solutions. That’s why we hope you will join us for this important conference! Please take a look at the Forum website, including the stellar list of confirmed speakers (more being added), for more details.

Thanks for being part of the network and for your continued support. We hope to “see” you in May. 

Take Action: Sign-Up for the Forum and join with others across the country and around the world for a toxic-free future – confronting health threats, climate disasters, and biodiversity collapse. See you there!

SPONSORSHIP OPPORTUNITIES! Showcase what you’re doing (as a nonprofit, volunteer, or business organization) through our “poster” or “exhibitor” opportunities. Take a look at our sponsorship packages, there’s a cost-effective option for all budgets. If you’d like to discuss a sponsorship, please call 202-543-5450 or send us an email

04/06/2021 — Ban Endocrine Disrupting Pesticides Now to Protect People and Wildlife

The failure of EPA to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine disrupting chemicals must end. Over recent decades, evidence has mounted showing that many pesticides interfere with hormones—and are therefore endocrine-disrupting chemicals (EDCs). In 1996, the promise of screening pesticides for endocrine disruption generated support from environmentalists and public health advocates for the Food Quality Protection Act (FQPA), which traded the absolute prohibition of carcinogens in food of the Delaney Clause for a risk assessment standard that is subject to manipulation and an underestimation of real-life hazards. And now, 25 years later, we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.

>>Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.

The endocrine system consists of a set of glands (thyroid, gonads, adrenal and pituitary) and the hormones they produce (thyroxine, estrogen, testosterone and adrenaline), which help guide the development, growth, reproduction, and behavior of animals, including humans. Hormones are signaling molecules, which travel through the bloodstream and elicit responses in other parts of the body. 

More than 50 pesticide active ingredients have been identified as endocrine disruptors by the European Union and the late endocrine disruptor expert Theo Colborn, PhD. Endocrine disruption is the mechanism for several health effect endpoints. Endocrine disruptors function by: (i) Mimicking the action of a naturally produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; (ii) Blocking hormone receptors in cells, thereby preventing the action of normal hormones; or (iii) Affecting the synthesis, transport, metabolism, and excretion of hormones, thus altering the concentrations of natural hormones. Endocrine disruptors have been linked to attention deficit hyperactivity disorder (ADHD)Parkinson's and Alzheimer's diseasesdiabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorderschildhood and adult cancers, and other metabolic disorders. 

It is not only humans who are affected. Hermaphroditic frogs, polar bears with penis-like stumps, panthers with atrophied testicles and intersex fish with immature eggs in their testicles have all been linked to endocrine disruption. The popular herbicide atrazine chemically castrates and feminizes exposed male tadpoles. The mosquito-killing S-methoprene larvicide alters early frog embryo development. Distorted sex organ development and function in alligators is linked to the organochlorine insecticide dicofol. The ubiquitous antibacterial chemical triclosan alters thyroid function in frogs, while its chemical cousin triclocarban enhances sex hormones in rats and in human cells. In her book, Our Stolen Future, Dr. Colborn states that the decline of animal species can no longer be simply explained by habitat destruction and human disturbance, but also by reproductive failures within populations brought on by the influence of endocrine disrupting chemicals.

According to FQPA, the agency must screen all pesticide chemicals for potential endocrine activity. To ensure timely follow-through, EPA was given a timeline by Congress to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. It started a screening program (Tier 1) and reported results in 2009. Since, according to EPA, Tier 1 Screening (which looks at high exposure chemicals) is not sufficient to implicate a chemical as an endocrine disrupting chemical, but acts as a tool for defining which chemicals must undergo Tier 2 testing, the only stage that can influence regulatory decision-making. Indeed, it is unclear when or how EPA will move forward with Tier 2 testing, and how, if at all, any Tier 2 findings will be used to inform actual regulation.

EPA now issues Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption.

>>Demand that EPA test for and act on endocrine disruptors as required by law.

Letter to EPA Administator

I am writing to ask you to act now to meeting a statutory mandated to protect people and wildlife from dire health consequences.

In 1998, following a mandate in the Food Quality Protection Act (FQPA) of 1996, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 23 years, the Endocrine Disruptor Screening Program (EDSP), established to carry out the act, has made little progress in reviewing and regulating endocrine-disrupting pesticides.

To ensure timely follow-through, EPA was given a timeline by Congress to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. EPA has issued Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption. In the absence of such findings, EPA must cancel and suspend the registration of each pesticide lacking data or findings.

Please ensure that your agency meets its responsibility to protect the health of people and wildlife.

Thank you.

Letter to Congress

I am writing to ask you elevate a critical public and environmental health issue –the regulation of endocrine disrupting pesticides. The failure of EPA to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine disrupting chemicals must end. For over a decade, EPA ignored the vast wealth of information on endocrine disruption from independent academic researchers funded by the U.S. and other governments in Europe and Asia. And, EPA has simply not carried out its statutory mandate to regulate endocrine disrupting pesticides.

Endocrine disruptors are linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as to attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. This is a public health tragedy that cannot be ignored.

Since EPA announced it was ready to begin testing both active and “inert” (usually the majority of the undisclosed product ingredients that make the solution, dust, or granule) pesticide ingredients for potential endocrine disrupting effects in 2009, the protocols EPA proposed to use have become significantly outdated, having been first recommended in 1998. In the interim, science has progressed such that it offered more sophisticated assumptions than those that informed the EPA test designs. Further, as Beyond Pesticides noted in 2009, “Each of EPA’s tests and assays was designed under the surveillance of corporate lawyers who had bottom lines to protect, and assorted toxicologists who were not trained in endocrinology and developmental biology. For over a decade, EPA ignored the vast wealth of information on endocrine disruption from independent academic researchers funded by the U.S. and other governments in Europe and Asia.”

In 1998, following a mandate in the Food Quality Protection Act (FQPA) of 1996, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 21 years, the Endocrine Disruptor Screening Program (EDSP), established to carry out the act, has made little progress in reviewing and regulating endocrine-disrupting pesticides. As of 2019, the program has stalled entirely.

To ensure timely follow-through, EPA was given a timeline by Congress to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. That has real costs. Please use the power of your office to push EPA to meet its statutory responsibility to protect the health of people and wildlife.

Thank you.

03/29/2021 — Tell EPA and Congress to Save the Hummingbirds

...by Suspending Use of Neonicotinoid Insecticides and Supporting the Transition to Organic Practices

New data on the hazards of neonicotinoid insecticides calls for urgent regulatory action. The same pesticides that are linked to the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Widely known for their nectar-fueled hovering flight powered by wings beating up to 80 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal.

>>Tell EPA and Congress to save the hummingbirds. 

While hovering, a hummingbird consumes calories faster than any other bird or mammal. That's why the finding that exposure to the neonicotinoid insecticide imidacloprid slows metabolism up to 25% is so disturbing. Systemic pesticides like imidacloprid and other neonics are transported throughout the plant, including nectar. 

Findings on the danger neonicotinoids pose to hummingbirds decades after the chemicals were first permitted to be used in the environment, and by independent scientists, not regulatory agencies, is indicative of a regulatory approach that fails to embrace precaution from the outset. Overwhelming data has already been established on the threat neonicotinoids pose to the health of ecosystems worldwide. The list of animals found to be adversely affected by neonicotinoids is extensive, ranging from humans and other mammals, to insect pollinators, songbirds, amphibians, and other aquatic species.

Of the 338 species of hummingbirds—all found in the Western hemisphere—34 are already endangered. We need to remove this threat to these amazing little birds by replacing chemical-intensive agriculture and horticulture with organic practices.

To help hummingbirds:

>>Tell EPA and Congress to save the hummingbirds by suspending use of neonicotinoid insecticides and supporting the transition to organic practices.

 

Letter to EPA Administrator

New data on the hazards of neonicotinoid insecticides calls for urgent regulatory action. The same pesticides that are linked to the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Widely known for their nectar-fueled hovering flight powered by wings beating up to 80 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal.

While hovering, a hummingbird consumes calories faster than any other bird or mammal. That’s why the finding that exposure to the neonicotinoid insecticide imidacloprid slows metabolism up to 25% is so disturbing. Systemic pesticides like imidacloprid and other neonics are transported throughout the plant, including nectar.

The failure of EPA to act on Independent scientific findings on the danger that neonicotinoids pose to hummingbirds is indicative of clearly inadequate protection of ecosystems critical to our future. Overwhelming data has already been established on the threat neonicotinoids pose to the health of ecosystems worldwide. The list of animals found to be adversely affected by neonicotinoids is extensive, ranging from humans and other mammals, to insect pollinators, songbirds, amphibians, and other aquatic species.

Of the 338 species of hummingbirds—all found in the Western hemisphere—34 are already endangered. We need to remove this threat to these amazing little birds by supporting and incentivizing the transition from chemical-intensive agriculture and horticulture to organic practices.

Please address these threats to hummingbirds by suspending neonicotinoid insecticides. Eliminate pesticides that endanger pollinators and their habitat.

Thank you.

Letter to Congress

New data on neonicotinoid insecticides calls for urgent regulatory action. The same pesticides that are linked to the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Widely known for their nectar-fueled hovering flight powered by wings beating up to 80 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal.

While hovering, a hummingbird consumes calories faster than any other bird or mammal. That’s why the finding that exposure to the neonicotinoid insecticide imidacloprid slows metabolism up to 25% is so disturbing. Systemic pesticides like imidacloprid and other neonics are transported throughout the plant, including nectar.

The failure of EPA to act on Independent scientific findings on the danger that neonicotinoids pose to hummingbirds is indicative of clearly inadequate protection of ecosystems critical to our future. Overwhelming data has already been established on the threat neonicotinoids pose to the health of ecosystems worldwide. The list of animals found to be adversely affected by neonicotinoids is extensive, ranging from humans and other mammals, to insect pollinators, songbirds, amphibians, and other aquatic species.

Of the 338 species of hummingbirds—all found in the Western hemisphere—34 are already endangered. We need to remove this threat to these amazing little birds by supporting and incentivizing the transition from chemical-intensive agriculture and horticulture to organic practices.

Please ask EPA to address these threats to hummingbirds by suspending neonicotinoid insecticides. Eliminate pesticides that endanger pollinators and their habitat.

Thank you.

03/22/2021 — Tell the NOSB to Keep Antibiotics Out of Organic!

The National Organic Standards Board (NOSB) is receiving written comments from the public through April 5. This precedes the upcoming public hearing on April 20 and 22—concerning how organic food is produced. Also, by April 5, sign up to speak (3 minutes) at the virtual NOSB hearing. Written comments must be submitted through Regulations.gov.

As always, there are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2021 issues page.

Comment 1: The National Organic Standards Board (NOSB) is considering a petition to allow the antibiotic kasugamycin to be used in organic apple and pear production. Earlier NOSB members struggled long and hard to erase the stigma of antibiotic use in organic fruit production—something that was left over from the transition of so many chemical-intensive fruit orchards after the Alar “scare” in which apple and apple products were contaminated with the cancer-causing plant growth regulator daminozide. Do we now want to step on that treadmill again? The reasons for rejecting the kasugamycin petition are the same as the reasons for eliminating the antibiotics streptomycin and tetracycline in crop production.

Now that we have learned what a pandemic looks and feels like, with the astounding levels of infection, hospitalization, and death from COVID-19, we must take serious steps to prevent another pandemic on the horizon—this one tied to bacterial resistance to antibiotics. An important article in The Lancet points to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”

When streptomycin and tetracycline were presented for their final votes by the Crops Subcommittee, the committee was unanimous that the antibiotics needed to go—the question was how fast. How fast could growers of these crops get over their dependence on these antibiotics that pose threats to human health and the environment and are unpopular with organic consumers? Streptomycin and tetracycline are gone, and we do not need another antibiotic.

Tell the NOSB to keep organic strong and keep antibiotics out of organic.

As always, the NOSB is considering many issues that affect the integrity of organic products. Other important issues are the use of ion exchange technology in processing organic food and the use of so-called “biodegradable biobased mulch film.”

Comment 2: Biodegradable Biobased Mulch Film (BBMF) was approved by the NOSB for use in organic production in October 2012, and the listing was finalized September 30, 2014 as “Biodegradable biobased mulch film as defined in §205.2. Must be produced without organisms or feedstock derived from excluded methods.” The definition required that BBMF meet specific requirements for compostability, biodegradation, and biobased content. Subsequently, the Organic Material Research Institute (OMRI) found that there are no products meeting all of the requirements set by the board. The NOSB is now considering a proposal to change the definition to allow BBMF that is not 100% biobased. BBMF is not removed from the field by the grower, but is tilled into the soil. The tillage process purposefully creates microplastics, with the intention that the action of soil organisms will degrade these small particles. However, as reported in OMRI’s 2016 Supplemental Technical Review, many growers report that fragments persist in the soil. OMRI reports research showing that the BBMFs do not completely degrade and may degrade more slowly when tilled under the surface, that they contain components that may be hazardous, and particles may adsorb persistent toxins. Microplastics may be incorporated into plant and animal tissues. Organic mulches have always been a central aspect of organic production, and reliance on synthetic mulches for functions that can be performed by organic mulch is not compatible with organic production. The NOSB should not redefine BBMF in a way that encourages microplastic contamination of the soil.

Comment 3: Ion exchange is a reaction in which an element from the treated substance is removed and replaced by a different element. Although the most familiar example of ion exchange is water softening, in which the “hard” minerals calcium and magnesium are replaced with sodium, the technology is widely used in food processing. Food processors run liquids, such as sugar cane juice, through a column of plastic beads charged with a substance that replaces an undesirable substance in the liquid with a different chemical. Ion exchange produces a chemical change in the food, which can subsequently only be regarded as synthetic under organic rules—and, therefore, be limited to less than 5% in food labeled “organic.” Products treated with ion exchange must be treated as synthetic substances. Resins and recharge chemicals must be on the product label.

Submit comments now.

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the three comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)

Thank you for keeping organic strong!

03/16/2021 — Tell FDA and USDA to Get Heavy Metals Out of Baby Food

staff report produced for the Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform of the U.S. House of Representatives has documented substantial levels of the heavy metals arsenic, lead, cadmium, and mercury in infant foods. The researchers examined organic as well as nonorganic brands, finding contamination of both. They found that heavy metals were present in both crop-based ingredients and additives. However, many unknowns remain regarding the precise origin of the metals.

Two U.S. Senators (Amy Klobuchar, D-MN and Tammy Duckworth, D-IL) and two U.S. Representatives (Raja Krishnamoorthi, D-IL and Tony Cardenas, D-CA) have drafted legislation to strengthen regulations for infant food safety, but meanwhile want the Food and Drug Administration (FDA) to use existing authority to take immediate action. The National Organic Program should also take action to ensure that parents can depend on organic baby food to be the best possible.

>>TAKE ACTION: Tell FDA and USDA to get heavy metals out of baby food!

Heavy metals can have serious health impacts, especially on young children. As stated in the report: 

  • Children's exposure to toxic heavy metals causes permanent decreases in IQ, diminished future economic productivity, and increased risk of future criminal and antisocial behavior.​​​​​

  • Babies' developing brains are “exceptionally sensitive to injury caused by toxic chemicals, and several developmental processes have been shown to be highly vulnerable to chemical toxicity.” The fact that babies are small, have other developing organ systems, and absorb more of the heavy metals than adults, exacerbates their risk from exposure to heavy metals. 

  • Exposure to heavy metals at this developmental stage can lead to “untreatable and frequently permanent” brain damage, which may result in “reduced intelligence, as expressed in terms of lost IQ points, or disruption in behavior.” For example, a recent study estimates that exposure to environmental chemicals, including lead, are associated with 40,131,518 total IQ points loss in 25.5 million children (or roughly 1.57 lost IQ points per child)—more than thetotal IQ losses associated with preterm birth (34,031,025), brain tumors (37,288), and traumatic brain injury (5,827,300) combined. For every single IQ point lost, it is estimated that a child's lifetime earning capacity will be decreased by $18,000.

Because heavy metal contamination occurs in organic as well as nonorganic baby foods and in food ingredients as well as additives such as vitamin mixtures, it is important to discover the sources from which heavy metals enter the food. Some sources are known—it is known that some vitamin mixes are contaminated. It is known that rice—especially brown rice—contains arsenic as a result of historical use of arsenic pesticides and the fact that rice concentrates arsenic. Other sources are more speculative, but there are three main possible sources—pesticide residues in agricultural products, food contact with processing machinery and containers, and food additives. Growing food organically eliminates additions to the heavy metal burden of soils but does not eliminate existing residues in the soil and environment generally. Organic processing standards must be strengthened to address problems associated with food contact contaminants and contaminated additives. While background levels and action levels set by FDA standards are one measure, under the Organic Foods Production Act, the National Organic Standards Board must set its own standards for contaminants of added substances in organic food production and processing, taking into account background levels in the environment.

After decades of polluting practices in agricultural production under risk assessment standards that allowed contamination at “acceptable levels,” we have a legacy problem with background contamination of farmland. As a result, manufacturers of processed food may not be able to source ingredients without these unacceptable contaminants. Therefore, we need to first define the scope of the problem and then consider remediation measures that may be needed on the agricultural land used to grow crops that are ingredients in baby food and the food supply generally. 

With the problem fully defined, we can launch a national clean-up program—from farmers to processors and packagers—to eliminate the contamination from the food supply. As a part of this national program, FDA must set strict regulations on heavy metal concentrations in finished products. As a goal, Consumer Reports (CR) has suggested that FDA:

Establish aggressive targets: Set a goal of having no measurable amounts of cadmium, inorganic arsenic, or lead in baby and children's food.

Create and enforce benchmarks: To reach its goals in baby and children's food, FDA should set incremental targets for industry to meet along the way.

Finalize existing proposed guidelines: FDA should limit inorganic arsenic in apple juice to 10 ppb and revise existing guidance for lead in fruit juice to reduce the limit from 50 to 5 ppb.

>>TAKE ACTION: Tell FDA and USDA to get heavy metals out of baby food!

Letter to FDA

A staff report produced for the Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform of the U.S. House of Representatives has documented substantial levels of the heavy metals arsenic, lead, cadmium, and mercury in infant foods. The researchers examined organic as well as nonorganic brands, finding contamination of both. They found that heavy metals were present in both crop-based ingredients and additives. However, many unknowns remain regarding the precise origin of the metals.

Heavy metals can have serious health impacts, especially on young children. As stated in the report,

- Children’s exposure to toxic heavy metals causes permanent decreases in IQ, diminished future economic productivity, and increased risk of future criminal and antisocial behavior.

- Babies’ developing brains are “exceptionally sensitive to injury caused by toxic chemicals, and several developmental processes have been shown to be highly vulnerable to chemical toxicity.” The fact that babies are small, have other developing organ systems, and absorb more of the heavy metals than adults, exacerbates their risk from exposure to heavy metals.

- Exposure to heavy metals at this developmental stage can lead to “untreatable and frequently permanent” brain damage, which may result in “reduced intelligence, as expressed in terms of lost IQ points, or disruption in behavior.” For example, a recent study estimates that exposure to environmental chemicals, including lead, are associated with 40,131,518 total IQ points loss in 25.5 million children (or roughly 1.57 lost IQ points per child)—more than the total IQ losses associated with preterm birth (34,031,025), brain tumors (37,288), and traumatic brain injury (5,827,300) combined. For every one IQ point lost, it is estimated that a child’s lifetime earning capacity will be decreased by $18,000.

Because heavy metal contamination occurs in organic as well as nonorganic baby foods and in food ingredients as well as additives such as vitamin mixtures, it is important to discover the sources from which heavy metals enter the food. Some sources are known—it is known that some vitamin mixes are contaminated. It is known that rice—especially brown rice—contains arsenic as a result of historical use of arsenic pesticides and the fact that rice concentrates arsenic. Other sources are more speculative, but there are three main possible sources—pesticide residues in agricultural products, food contact with processing machinery and containers, and food additives. Growing food organically eliminates additions to the heavy metal burden of soils but does not eliminate existing residues. Organic processing standards have not yet caught up with the problems of food contact contaminants and contaminated additives and rely to some extent on FDA standards.

It is important to motivate those involved in baby food manufacture—from farmers to processors and packagers—to eliminate known sources of contamination. This can be accomplished with strict FDA regulations on heavy metal concentrations in finished products. I urge you to take these steps to protect children from hazardous heavy metals:

1) Establish aggressive targets: Set a goal of having no measurable amounts of cadmium, inorganic arsenic, or lead in baby and children’s food.
2) Create and enforce benchmarks: To reach its goals in baby and children’s food, FDA should insist that manufacturers follow recognized best practices and set incremental targets for industry to meet along the way.
3) Finalize existing proposed guidelines: FDA should limit inorganic arsenic in apple juice to 10 ppb and revise existing guidance for lead in fruit juice to reduce the limit from 50 to 5 ppb.

Thank you for your consideration.

Letter to USDA

I am writing because I am concerned about the report produced for the Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform of the U.S. House of Representatives that documented substantial levels of the heavy metals arsenic, lead, cadmium, and mercury in infant foods, including organic products. Heavy metals can have serious health impacts, especially on young children. As stated in the report,

- Children’s exposure to toxic heavy metals causes permanent decreases in IQ, diminished future economic productivity, and increased risk of future criminal and antisocial behavior.

- Babies’ developing brains are “exceptionally sensitive to injury caused by toxic chemicals, and several developmental processes have been shown to be highly vulnerable to chemical toxicity.” The fact that babies are small, have other developing organ systems, and absorb more of the heavy metals than adults, exacerbates their risk from exposure to heavy metals.

- Exposure to heavy metals at this developmental stage can lead to “untreatable and frequently permanent” brain damage, which may result in “reduced intelligence, as expressed in terms of lost IQ points, or disruption in behavior.” For example, a recent study estimates that exposure to environmental chemicals, including lead, are associated with 40,131,518 total IQ points loss in 25.5 million children (or roughly 1.57 lost IQ points per child)—more than the total IQ losses associated with preterm birth (34,031,025), brain tumors (37,288), and traumatic brain injury (5,827,300) combined. For every one IQ point lost, it is estimated that a child’s lifetime earning capacity will be decreased by $18,000.

The heavy metal contamination occurs regardless of organic production and processing methods. Organic standards are based on practices rather than purity, but consumers do expect that organic foods will be free of hazardous contaminants. Therefore, regardless of actions that may be taken by Congress or the Food and Drug Administration (FDA) affecting foods in general or baby foods in general, the National Organic Program (NOP) should, to the extent possible, ensure that organic food, especially infant food, is free from heavy metal contamination.

To this end, NOP must work with the National Organic Standards Board to eliminate, as much as possible heavy metal contamination arising from:

1. Organic crop and livestock production practices and the land;
2. National List ingredients;
3. Processing and handling processes; and
4. Packaging materials.

Thank you for your consideration.

03/05/2021 — Tell EPA to Stop the Sale of Deadly Seresto Flea Collars

In the face of 1,700 pet deaths linked to Seresto's flea and tick collar—as reported March 2, 2021, by USA Today, based on EPA records—EPA has taken no action. This unconscionable inaction is defended by an EPA spokesperson who told the media that, despite these incidents, the agency has deemed Seresto collars “'eligible for continued registration' based on best available science, including incident data....No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Seresto is developed by Bayer and sold by Elanco.

>>Tell EPA and Members of Congress to take responsible and immediate action to stop the death of dogs and cats by stopping the sale of Seresto flea collars. 

Beyond Pesticides is calling on EPA to recognize, finally, that the label on flea collars is not adequately protective, as evidenced by the number of deaths and 75,000 incidents. “EPA has the authority to act now, and it should use its powers to protect the health and lives of pets,” said Jay Feldman, executive director of Beyond Pesticides. “EPA should act on the deaths immediately, not wait for further study, just as it did with the herbicide Imprelis when trees were killed after the product's use.” said Mr. Feldman. In 2011, EPA issued an order to E.I. DuPont de Nemours (DuPont) directing the company to immediately cease the distribution, sale, use or removal of Imprelis Herbicide products under its ownership, control, or custody. The agency found that, “The directions for use and/or warning or caution statements on DuPont's Imprelis labeling are inadequate.”

USA Today reports, “A 2012 Bayer study found [flumethrin and imidacloprid] have a 'synergistic effect,' meaning they are more toxic together on fleas....“ However, a 2016 EPA bulletin concluded, “The risk of the combination of the two active ingredients, flumethrin and imidacloprid, was not assessed because the two chemicals act in completely different ways.” This failure to evaluate synergistic effects of pesticides is standard practice of EPA. As Beyond Pesticides has pointed out repeatedly, EPA does not do an adequate job of evaluating the risks and harms of exposures to multiple pesticide compounds, as well as those of so-called  “inert” or “other” pesticide ingredients.

The Seresto flea collar is meant to stay on dogs or cats for months at a time to kill fleas and ticks. Apart from deaths, pets suffer from rashes, seizures, motor dysfunction, fatigue, diarrhea, vomiting, and excessive drooling. The product label on the collar specifically states that it is for external use only; but that direction does not account for the fact that dogs and cats clean themselves (by licking their fur) frequently, and can ingest the collar's pesticides because it is designed to release and disperse them onto fur and skin steadily over the course of months.

The same concern is true for children's exposure to the chemical residues on their pets and their direct contact with the flea collar. EPA's 2016 bulletin includes the label warning: “DO NOT LET CHILDREN PLAY WITH THIS COLLAR OR REFLECTORS; KEEP OUT OF REACH OF CHILDREN.” The bulletin further states, “Flumethrin exposures to people placing collars on pets, and to adults and children interacting with pets (including incidental ingestion because of children's hand-to-mouth activities), are below levels of concern. The assessment of imidacloprid identified no risks to humans placing the collars on pets or interacting with pets wearing the collars.” And it reiterates, “As stated in the precautions on the label, do not allow children to play with the collars. In addition, try to keep the pet away from young children for a day after putting on the collar to minimize exposure.” EPA's use of ALL CAPS and repeated warnings about children suggests a high level of agency concern.

EPA has logged these “Seresto” incidents in its database for years but has not seen fit to warn the public. Karen McCormack, a retired EPA scientist and communications officer, notes that these collars have garnered the greatest number of incident reports of any pesticide product in her long experience. She says, “EPA appears to be turning a blind eye to this problem, and after seven years of an increasing number of incidents, they are telling the public that they are continuing to monitor the situation. But I think this is a significant problem that needs to be addressed sooner rather than later.”

>>Tell EPA and Members of Congress to take responsible and immediate action to stop the death of dogs and cats by stopping the sale of Seresto flea collars.

Letter to EPA and Congress

In the face of 1,700 pet deaths linked to Seresto’s flea and tick collar—as reported March 2, 2021 by USA Today, based on EPA records—EPA has taken no action. This unconscionable inaction is defended by an EPA spokesperson who told the media that, despite these incidents, the agency has deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data. . . . No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Seresto is developed by Bayer and sold by Elanco.

I am calling on EPA to recognize, finally, that the label on flea collars is not adequately protective, as evidenced by the number of deaths and 75,000 incidents. EPA has the authority to act now, and it should use its powers to protect the health and lives of pets by stopping the sale of Seresto flea collars. EPA should act on the deaths immediately, not wait for further study—just as it did with the herbicide Imprelis (2011) by issuing an order to E.I. DuPont de Nemours (DuPont) directing the company to immediately cease the distribution, sale, use or removal. In that case, EPA said, “The directions for use and/or warning or caution statements on DuPont's Imprelis labeling are inadequate [to prevent the death of trees]”.

USA Today reports, “A 2012 Bayer study found [flumethrin and imidacloprid] have a ‘synergistic effect,’ meaning they are more toxic together on fleas. . . “ However, a 2016 EPA bulletin concluded, “The risk of the combination of the two active ingredients, flumethrin and imidacloprid, was not assessed because the two chemicals act in completely different ways.” This failure to evaluate synergistic effects of pesticides is standard practice of EPA. The agency does an inadequate job of evaluating the risks and harms of exposures to multiple pesticide compounds, as well as those of so-called “inert” or “other” pesticide ingredients.

The Seresto flea collar is meant to kill fleas and ticks, while on dogs or cats for months at a time. Apart from deaths, pets suffer rashes, seizures, motor dysfunction, fatigue, diarrhea, vomiting, and excessive drooling. Although the product label on the collar specifically states that it is for external use only, it fails to account for grooming behavior of dogs and cats through which the pet can ingest the pesticides that the collar releases and disperses onto fur and skin steadily over the course of months.

The same concern is true for children’s exposure to the chemical residues on their pets and their direct contact with the flea collar. The collar’s label warns: “DO NOT LET CHILDREN PLAY WITH THIS COLLAR OR REFLECTORS; KEEP OUT OF REACH OF CHILDREN.” Although EPA acknowledges synergistic effects on fleas and ticks, the agency finds separate risks of flumethrin and imidacloprid to be below levels of concern and did not assess their combined risk.

EPA has logged “Seresto” incidents in its database for years, but has not seen fit to warn the public. Karen McCormack, a retired EPA scientist and communications officer, notes that these collars have garnered the greatest number of incident reports of any pesticide product in her long experience. She says, “EPA appears to be turning a blind eye to this problem, and after seven years of an increasing number of incidents, they are telling the public that they are continuing to monitor the situation. But I think this is a significant problem that needs to be addressed sooner rather than later.”

Thank you for your urgent consideration.

03/01/2021 — Support National Reckoning to Bridge Racial Divides with Meaningful Actions

The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” Black, Indigenous, and other people of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership. With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. This discussion has taken on greater general public understanding since the killing of George Floyd, as there is more national awareness of systemic racial injustice and the deep adverse impact that it has on all aspects of life. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership. 

>>Tell your U.S. Senators and U.S. Representative to support increased equity for Black, Indigenous, and other people of color in farming.

Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. The three pieces of legislation in this action relate to disenfranchisement of African Americans and other people of color as the struggle continues for Native American and tribal rights to land taken from them by the U.S. government. There are several bills in Congress, which are not included in this action, to put certain lands into trust or transfer land for the benefit of various Native American tribes.

The undermining of land ownership in the Black community has not been widely recognized by the general public. In 1910, one in seven farmers were African Americans, who held titles to approximately 16 to 19 million acres of farmland. Over the next century, 98% of Black farmers were dispossessed through discriminatory practices at the U.S. Department of Agriculture (USDA) and various federal programs.

The current existential threats arise from continued policies of colonization, including “resource extraction,” “economic development,” and agriculture. But large-scale logging, mining, petroleum extraction, and dispersal of poisons is opposed by efforts to restore lands and waters to Indigenous guardianship and/or Indigenous stewardship—to begin the process of reparations, healing, and recovery. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land." Land-care practices based on specific land-based cultural practices are as diverse as the more than 500 tribal nations of Turtle Island.

Two bills have been introduced in the Senate (but do not have numbers as of this writing) aimed at boosting the growing push for equity and diversity within food and agriculture policy and politics. Sen. Cory Booker (D-N.J.) reintroduced the Justice for Black Farmers Act to address a history of USDA discrimination and injustice to Black farmers. Sen. Raphael Warnock (D-Ga.) introduced the Emergency Relief for Farmers of Color Act that would provide $5 billion to farmers of color. Sen. Warnock said he is urging that the bill be included in the $1.9 trillion pandemic relief package moving through Congress.

The Justice for Black Farmers Act will fund agriculture programs at historically Black colleges and universities and create new training programs for new farmers of color. It will also create a civil rights oversight board at USDA to investigate reports of discrimination both within the department and its Farm Service Agency county committees. Most notably, the bill includes a provision that would provide up to 160 acres to existing and aspiring Black farmers and provides debt forgiveness for those who filed claims under the landmark 1999 Pigford v. Glickman class action discrimination suit that Black farmers filed against USDA.

Sen. Warnock's bill provides $5 billion to Black, Indigenous, Hispanic and other farmers of color, including $4 billion in direct relief payments to help farmers of color pay outstanding USDA farm loan debts and related taxes, and help them respond to the economic impacts of the pandemic; and $1 billion to support activities at USDA to "root out systemic racism, provide technical and legal assistance to agricultural communities of color and fund under-resourced programs that will shape the future for farmers and communities of color." 

Missing from this package is a provision to return land to Indigenous nations. The authors of these bills should include provisions that return ownership of public and trust lands to the tribes from whom they were taken. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

And, on the issue of reparations, H.R.40, Commission to Study 5 and Develop Reparation Proposals for African Americans Act, was introduced by Rep. Sheila Jackson Lee (D-TX) and 116 co-sponsors. The legislation, which the ACLU has called “restorative justice,” had been introduced by Rep. John Conyers (D-MI) for three decades. According to Rep. Jackson Lee, “Though many thought it a lost cause, he believed that a day would come when our nation would need to account for the brutal mistreatment of African Americans during chattel slavery, Jim Crow segregation, and the enduring structural racism endemic to our society.” The bill is H.R. 40 for a reason: “The designation of this legislation as H.R. 40 is intended to memorialize the promise made by Gen. William T. Sherman, in his 1865 Special Field Order No. 15, to redistribute 400,000 acres of formerly Confederate-owned coastal land in South Carolina and Florida, subdivided into 40-acre plots.” With broad support in Congress and the private sector, Rep. Jackson Lee said, “By passing H.R. 40, Congress can start a movement toward the national reckoning we need to bridge racial divides. Reparations are ultimately about respect and reconciliation — and the hope that one day, all Americans can walk together toward a more just future. The bill establishes a Commission to Study and Develop Reparation Proposals for African Americans to research the issues involved and make reparation recommendations.

>>Tell your U.S. Senators and U.S. Representative to support for increased equity for Black, Indigenous, and other people of color in farming.

Letter to U.S. Representatives

I am writing to ask your support for increased equity for Black, Indigenous, and other people of color in farming. The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” Black, Indigenous, and other people of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership. With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership.

H.R.40, Commission to Study 5 and Develop Reparation Proposals for African Americans Act, was introduced by Rep. Sheila Jackson Lee (D-TX) and 116 co-sponsors. The legislation, which the ACLU has called “restorative justice,” had been introduced by Rep. John Conyers (D-MI) for three decades. According to Rep. Jackson Lee, “Though many thought it a lost cause, he believed that a day would come when our nation would need to account for the brutal mistreatment of African Americans during chattel slavery, Jim Crow segregation, and the enduring structural racism endemic to our society.” The bill is H.R. 40 for a reason: “The designation of this legislation as H.R. 40 is intended to memorialize the promise made by Gen. William T. Sherman, in his 1865 Special Field Order No. 15, to redistribute 400,000 acres of formerly Confederate-owned coastal land in South Carolina and Florida, subdivided into 40-acre plots.” With broad support in Congress and the private sector, Rep. Jackson Lee said, “By passing H.R. 40, Congress can start a movement toward the national reckoning we need to bridge racial divides. Reparations are ultimately about respect and reconciliation — and the hope that one day, all Americans can walk together toward a more just future. The bill establishes a Commission to Study and Develop Reparation Proposals for African Americans to research the issues involved and make reparation recommendations.

Missing from this bill is a provision to return land to Indigenous nations. We also need provisions that return ownership of public and trust lands to the tribes from whom they were taken. Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

Thank you for your support.

Letter to U.S. Senators

I am writing to ask your support for increased equity for Black, Indigenous, and other people of color in farming. To that end, I ask you to co-sponsor two bills (which have been introduced but do not have numbers as of this writing) in the Senate aimed at boosting the growing push for equity and diversity within food and agriculture policy and politics. Sen. Cory Booker (D-N.J.) reintroduced the Justice for Black Farmers Act to address a history of USDA discrimination and injustice to Black farmers. Sen. Raphael Warnock (D-Ga.) introduced the Emergency Relief for Farmers of Color Act that would provide $5 billion to farmers of color. Sen. Warnock said he is urging that the bill be included in the $1.9 trillion pandemic relief package moving through Congress.

The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” Black, Indigenous and other people of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership.
With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership.

Two pieces of legislation relate to disenfranchisement of African Americans as the struggle continues for Native American and tribal rights to land taken from them by the U.S. government. There are several additional bills in Congress to put certain lands into trust or transfer land for the benefit of various Native American tribes.

The undermining of land ownership in the Black community has not be widely recognized by the general public. In 1910, one in seven farmers were African Americans, and African Americans held titles to approximately 16 to 19 million acres of farmland. Over the next century, 98% of Black farmers were dispossessed through discriminatory practices at the U.S. Department of Agriculture (USDA) and various federal programs.

Missing from this package is a provision to return land to Indigenous nations. The authors of these bills should include provisions that return ownership of public and trust lands to the tribes from whom they were taken. Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

Thank you for your support.

Thank You Letters to Senators Booker and Warnock

I am writing to thank you for your support for increased equity for Black, Indigenous, and other people of color in farming. To that end, I support your leadership on two bills aimed at boosting the growing push for equity and diversity within food and agriculture policy and politics—Black Farmers Act to address a history of USDA discrimination and injustice to Black farmers, and the Emergency Relief for Farmers of Color Act that would provide $5 billion to farmers of color.

The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” People of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership. With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership.

I appreciate that these two pieces of legislation relate to disenfranchisement of African Americans as the struggle continues for Native American and tribal rights to land taken from them by the U.S. government. There are several additional bills in Congress to put certain lands into trust or transfer land for the benefit of various Native American tribes.

The undermining of land ownership in the Black community has been subtle and hidden from the general public. In 1910, one in seven farmers were African Americans, and African Americans held titles to approximately 16 to 19 million acres of farmland. Over the next century, 98% of Black farmers were dispossessed through discriminatory practices at the U.S. Department of Agriculture (USDA) and various federal programs.

Missing from this package is a provision to return land to Indigenous nations. I urge that these bills include provisions that return ownership of public and trust lands to the tribes from whom they were taken. Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

Thank you for your leadership.

02/22/2021 — Help Get Congress to Support National Biodiversity Strategy Legislation

Congressional Rep. Joe Neguse, Rep. Alan Lowenthal and Chair of the Natural Resources Subcommittee on Water, Oceans and Wildlife Rep. Jared Huffman have reintroduced their resolution (H.Res. 69: Expressing the need for the federal government to establish a national biodiversity strategy for protecting biodiversity for current and future) to create a national biodiversity strategy. Everywhere we turn, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. Never was a holistic strategy on biodiversity more urgent. 

>>Tell your U.S. Representative to cosponsor Rep. Neguse's National Biodiversity Strategy Resolution, H.Res. 69.

The resolution calls for a national commitment to addressing the biodiversity crisis by establishing a strategy to be developed through an interagency process announced by the president in an Executive Order. The strategy process will encourage agencies to identify and pursue a full range of actions within existing laws and policies and encourage consideration of new ones. It would also promote accountability and progress in addressing the biodiversity crisis through a new quadrennial assessment.

“The decline of biodiversity presents a direct threat to the security, health and well-being of our communities and our planet. Human-caused activity has led to the damage of ecosystems, the exploitation of wildlife, increased pollution and the acceleration of climate change,” said Representative Joe Neguse. “It is our hope that the Biden Administration would use our resolution as a roadmap for establishing a robust, whole-of-government approach to protect our ecosystems, our wildlife and tackle the biodiversity crisis. The United States ought to be playing a global leadership role on these issues.”

The resolution lays out a holistic national biodiversity strategy, including: 

  • Setting a national goal of protecting at least 30% of United States lands and water to conserve biodiversity and address climate change by 2030; 
  • Affirming the need to protect threatened, endangered, and at-risk species from further extinction; 
  • Developing climate adaptation and mitigation strategies for biodiversity; 
  • Joining and leading international agreements to combat climate change, such as the Paris Agreement
  • Establishing climate corridors for conservation of species affected by climate change; 
  • Rapidly building renewable energy; 
  • Reviewing existing laws and programs that are relevant to addressing threats of biodiversity; 
  • Advancing conservation in coordination with State and Tribal governments; 
  • Incorporating indigenous knowledge; 
  • Providing means to ensure equitable access to nature; and 

Establishing regular monitoring, reporting, research and development and adequate funding for conservation efforts. 

>>Tell your U.S. Representative to cosponsor Rep. Neguse's National Biodiversity Strategy Resolution, H.Res. 69.

Letter to Congress

I am writing to urge your support for H.Res. 69: Expressing the need for the federal government to establish a national biodiversity strategy for protecting biodiversity for current and future, reintroduced by Rep. Joe Neguse, Rep. Alan Lowenthal and Chair of the Natural Resources Subcommittee on Water, Oceans and Wildlife Jared Huffman. Everywhere we turn, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. Never was a holistic strategy on biodiversity more urgent.

The resolution calls for a national commitment to addressing the biodiversity crisis by establishing a strategy to be developed through an interagency process announced by the president in an Executive Order. The strategy process will encourage agencies to identify and pursue a full range of actions within existing laws and policies and encourage consideration of new ones. It would also promote accountability and progress in addressing the biodiversity crisis through a new quadrennial assessment.

“The decline of biodiversity presents a direct threat to the security, health and well-being of our communities and our planet. Human-caused activity has led to the damage of ecosystems, the exploitation of wildlife, increased pollution and the acceleration of climate change,” said Congressman Joe Neguse. “It is our hope that the Biden Administration would use our resolution as a roadmap for establishing a robust, whole-of-government approach to protect our ecosystems, our wildlife and tackle the biodiversity crisis. The United States ought to be playing a global leadership role on these issues.”

The resolution lays out a holistic national biodiversity strategy, including:

- Setting a national goal of protecting at least 30% of United States lands and water to conserve biodiversity and address climate change by 2030;
- Affirming the need to protect threatened, endangered, and at-risk species from further extinction;
- Developing climate adaptation and mitigation strategies for biodiversity;
-Joining and leading international agreements to combat climate change, such as the Paris Agreement;
- Establishing climate corridors for conservation of species affected by climate change;
- Rapidly building renewable energy capacity;
- Reviewing existing laws and programs that are relevant to addressing threats of biodiversity;
- Advancing conservation in coordination with State and Tribal governments;
- Incorporating indigenous knowledge;
- Providing means to ensure equitable access to nature; and
- Establishing regular monitoring, reporting, research and development and adequate funding for conservation efforts.

Please cosponsor H.Res. 69, Rep. Neguse’s national biodiversity strategy resolution.

Thank you.

02/16/2021 — Shift to Organic Farming, Not Carbon Trading, Is Critical to Thwart the Climate Crisis and Biodiversity Collapse

The climate crisis, with unprecedented temperature shifts, storms, and wildfires, and the devastating decline in biodiversity are escalating as a result of uncontrolled and unnecessary reliance on toxic chemicals. These existential crises that threaten life, to be successfully thwarted, require a meaningful holistic strategy that commits our nation to ending our fossil fuel-based economy and use of petroleum-based materials that release harmful levels of carbon and noxious gases (including greenhouse gases/GHG) into the environment. The proposals now in Congress and the administration require close attention and scrutiny if we are to meet the urgency of the moment.

The carbon market approach embodied in the Growing Climate Solutions Act and President Biden's Climate 21 Project does not adequately and comprehensively respond to the current and looming interconnected threats to public health and the environment. The focus on carbon to the exclusion of a holistic approach that addresses complex life-supporting biological communities allows the continuation of disproportionate hazards to people of color and communities living adjacent to toxic sites. The mechanisms of carbon trading or the purchasing of carbon offsets under consideration do not establish an end date for admittedly unacceptable materials and practices, nor do they ensure a transition to life-sustaining practices. Just as there are proposals to end production of the combustion engine and move to electric vehicles, we must demand that agriculture—across the board and on an expedited five-year schedule—shift to organic practices, whose standards are already codified in federal law. Organic production and handling practices have a proven, commercially viable, track record and both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. And, importantly, the data shows that this sector of agriculture is now operating without sacrificing productivity or profitability. The only problem: the vested economic interests in the petroleum and chemical industry are holding on to the status-quo. The good news: there are good jobs and money to be made in a green economy.

>>Tell your Congressional Representatives and Senators to support a holistic approach to the existential threats of the climate crisis and biodiversity collapse.

Carbon trading schemes won't work because:

In addition,

Why we need a national plan to shift to 100% organic farming. Organic land management is more effective at reducing emissions and increasing carbon sequestration. Organic farming practices have been shown to sequester carbon in the soil. There is in place a national program for certifying farms that meet organic standards. In addition, organic operations are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.” 

Why undefined “regenerative” agriculture falls short. The so-called “regenerative agriculture” promoted by proposals like the Growing Climate Solutions Act and President Biden's Climate 21 Project ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health and ecosystem services caused by pesticides and chemical fertilizers, the adverse impact of chemical no-till practices that rely on glyphosate (Roundup) and other equally hazardous herbicides, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients and also for the heat and energy-driving chemical reactions. It is important to see through this deception. As aptly stated by Jeff Moyer of the Rodale Institute, "We believe that in order to be regenerative, you have to start by being organic. It's a little disingenuous to say you can regenerate soil health and sequester carbon and still use nitrogen fertilizers and synthetic pesticides. What you're really saying is equivalent to saying, 'I want to be healthy as a person, but I still want to smoke cigarettes.'"

Beyond farming, we need a land management plan as a part of a national plan. Preserving natural land increases biodiversity, which also reduces dependence on petroleum-based pesticides. Natural forests are more effective than tree plantations in sequestering carbon. Biodiversity in forest ecosystems adds to their effectiveness in sequestering carbon. In addition, biodiversity buffers against damage from climate change—for example, by protecting shorelines from storm damage. Protecting forests, mangroves, peatlands, and other natural habitats helps to store more carbon in soil and vegetation.
Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change. Instead of promoting carbon trading, Congress and the Biden Administration must incorporate into a holistic approach, at the very least, the provisions included in the following:

  • Climate Stewardship Act of 2019, introduced in the House by then-Representative Haaland and in the Senate by Senator Booker.
  • The Agriculture Resilience Act, introduced in 2020 by Representative Pingree.
  • Former Senator Udall's pledge to conserve at least 30% of U.S. land and ocean by 2030 and 50% by 2050.
  • Representative Neguse's Resolution on a National Biodiversity Strategy.
  • A $30 billion fund dedicated solely to fund the transition to organic agriculture, with a goal of achieving 100% organic farms by 2026.

>>Tell your Congressional Representatives and Senators to support a holistic approach to the existential threats of the climate crisis and biodiversity collapse.

Letter to Congress

I am concerned that the carbon market approach embodied in the Growing Climate Solutions Act and President Biden’s Climate 21 Project does not adequately and comprehensively respond to interconnected threats to public health and the environment. The climate crisis and the devastating decline in biodiversity are escalating as a result of uncontrolled and unnecessary reliance on toxic chemicals. These threats to life require a meaningful holistic strategy to end our fossil fuel dependence and use of materials that release harmful levels of noxious gases (including greenhouse gases/GHG). The current carbon market proposals fall short.

The focus on carbon outside of a holistic approach allows continued disproportionate hazards to people of color and communities living near toxic sites. Carbon trading/offsets under consideration do not establish an end date for admittedly unacceptable practices or ensure a transition to life-sustaining practices. Alongside proposals to replace the combustion engine with electric vehicles, agriculture must—across the board and on an expedited five-year schedule—shift to organic practices. Organic practices both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. Importantly, the data show that organic agriculture now operates without sacrificing productivity or profitability. While the vested economic interests in the petroleum and chemical industry cling to the status quo, there are good jobs and money to be made in a green economy.

Carbon trading schemes are flawed because they:

*Ignore the impact of more potent GHGs, including the 300 times as potent nitrous oxide emitted by chemical fertilizer.

*Allow big polluters to continue business as usual by purchasing carbon credits.

*Can incentivize practices, like chemical no-till, that rely on inputs based on petroleum, poison soil, and release more potent GHGs.

*Do not protect natural land, which is even more effective in sequestering carbon.

*Has negative impacts on communities on the frontlines of fossil fuel destruction, including indigenous communities and other people of color on the fencelines of the fossil fuel industry.

We need a national plan to shift to 100% organic farming. Organic land management is more effective at reducing emissions and sequesters carbon in the soil. There is already a national program for certifying farms that meet organic standards. Organic operations must “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.”

Undefined “regenerative” agriculture falls short by ignoring the direct climate impacts of nitrogen fertilizers, the damage to soil health and ecosystem services caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels. It is important to see through this deception.

We need a national land management plan.  Preserving natural land increases biodiversity, reducing dependence on petroleum-based pesticides, and is more effective in sequestering carbon. Biodiversity buffers against damage from climate change—for example, by protecting shorelines from storm damage.

Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change. Instead of promoting carbon trading, Congress and the Administration must incorporate into a holistic approach, at the very least, the provisions included in the:

*Climate Stewardship Act of 2019.

*The Agriculture Resilience Act of 2020.

*A pledge to conserve at least 30% of U.S. land and ocean by 2030 and 50% by 2050.

*The Resolution on a National Biodiversity Strategy.

*A $30 billion fund dedicated solely to fund the transition to organic agriculture, with a goal of achieving 100% organic farms by 2026.

Thank you.

02/08/2021 — Tell Agencies New Executive Order Requires Bold Regulatory Action

Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order, if effective, will  reverse the historical trend of status quo regulatory reviews that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers), required by the White House Office of Management and Budget (OMB). Instead, the President's EO, Modernizing Regulatory Review, sets the stage for the adoption of agency policy across government to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism). 

Key agencies that can have a systemic effect in meeting these existential challenges are the Environmental Protection Agency (EPA), Department of Interior (DOI), Department of Agriculture (USDA), and Department of Labor/Occupational Safety and Health Administration (DOL/OSHA). But, the EO will remain words on a page unless we all across the country exercise our voice and advocate for the changes necessary to end our reliance on hazardous chemicals and immediately embrace the viability of nonpolluting alternatives, like organic agriculture and land management.  No one expects the polluting corporations to shrink in the face of a shift to a green economy—which makes our voice and oversight all that more important.

>>Tell the heads of EPA, DOI, USDA, and DOL/OSHA to review decisions allowing toxic chemical use based on available alternatives—technologies, practices, and products—that reduce or eliminate hazards.

Ever since the Reagan administration, regulatory review by the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and the Budget (OMB) has prevented agencies from promulgating new regulations based on new science and technologies that are more protective of health and the environment. OIRA acts as a gatekeeper to new regulations and has generally resisted changes to the status quo—even in regulations designed to adapt to new science and technology. An example of such regulations is the sunset process created in the Organic Foods Production Act (OFPA), which was is designed to review synthetic materials allowed in organic production every five years and remove them if they no longer meet OFPA criteria.

There are many examples of such regulations, and OIRA no longer needs to explicitly deny changes in regulations because agencies restrict their own actions based on the fear of OIRA review. President Biden's Executive Order offers an opportunity for OIRA/OMB and federal agencies to place new criteria on changes in regulations. Instead of protecting the status quo, the review should be based on the President's priorities as stated in the Modernizing Regulatory Review EO.

To be meaningful, regulatory reviews, in accordance with the EO, must analyze existing regulatory decisions on registration, allowance, and/or use of toxic pesticides and synthetic fertilizers in the context of available alternatives—technologies, practices and products—that reduce or eliminate hazards. We urge that all agencies immediately conduct an alternatives assessment that evaluates available organic practices in accordance with 7 CFR 205.600, the National List of Allowed and Prohibited Substances under the National Organic Program. This is especially important in the context of protecting health and the environment and ensuring racial equity in the application of regulations that currently allow for disproportionate and elevated risk for farmworkers and landscapers, as well as fenceline communities and people of color. These communities currently suffer disproportionate risk due to toxic chemical exposure, comorbidities, and elevated vulnerabilities to diseases and COVID-19 that are ignored under current regulatory reviews.

The tools are available now to end the use of toxic chemicals in current land management practices nationwide, including the management of agricultural land and landscapes, yet regulations allow disproportionate harm to black, brown, and indigenous people that is associated with a chain of poisoning and contamination from production to transportation, application, and disposal. The EO, if it is to be implemented in the spirit that is intended, requires that each agency conduct a full assessment of actions that it can take immediately to eliminate or reduce the current harms being inflicted that are unnecessary, given the availability of organic (as defined in federal law) alternatives.

>>Tell the heads of EPA, DOI, USDA, and DOL/OSHA to review decisions allowing toxic chemical use based on available alternatives—technologies, practices, and products—that reduce or eliminate hazards.

Letter to the (new) heads of EPA, DOI, USDA, and DOL/OSHA

Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order, Modernizing Regulatory Review, sets the stage for the adoption of agency policy to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism).

I ask your agency to conduct a review, in accordance with the Modernizing Regulatory Review EO, to analyze existing regulatory decisions on registration, allowance, and/or use of toxic pesticides and synthetic fertilizers in the context of available alternatives—technologies, practices and products— that reduce or eliminate hazards. I urge you to immediately conduct an alternatives assessment—associated with all your regulatory and administrative decisions— that evaluates available organic practices in accordance with 7 CFR 205.600, the National List of Allowed and Prohibited Substances under the National Organic Program. This is especially important in the context of protecting health and the environment and ensuring racial equity in the application of regulations that currently allow for disproportionate and elevated risk for farmworkers and landscapers, as well as fenceline and people of color communities. These communities currently suffer disproportionate risk due to toxic chemical exposure, comorbidities, and elevated vulnerabilities to diseases and COVID-19 that are ignored under your current regulatory reviews.

The tools are now available to end the use of toxic chemicals in current land management practices, including the management of agricultural land and landscapes, yet the regulations of your agency allow disproportionate harm to black, brown, and indigenous people that is associated with a chain of poisoning and contamination from production to transportation, application, and disposal. The EO, if it is to be implemented in the spirit that is intended, requires that your agency conduct a full assessment of actions that it can take immediately to eliminate or reduce the current harms being inflicted that are unnecessary, given the availability of organic (as defined in federal law) alternatives.

Please know that there is a wealth of information on the efficacy, economic viability, and profitability of organic management practices that replace your agency’s current assumption about the need for, or reasonableness of, toxic chemical dependency. We urge that this information be utilized in all your regulatory and administrative decision-making in order to eliminate the current unnecessary reliance on toxic materials.

I look forward to your agency’s alternative organic analysis full implementation of the Modernizing Regulatory Review EO.

Thank you.

02/01/2021 — Save Monarch Butterflies from Extinction

The yearly winter monarch count along the California coast, overseen each year by the conservation group Xerces Society, was the lowest ever. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate that many on the planet today are, within their lifetimes, likely to experience a world where western monarchs are extinct.

>>Tell the U.S. Fish and Wildlife Service to list monarch butterflies on the list of threatened and endangered species. Tell the Environmental Protection Agency to eliminate pollinator poisons.

Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count. In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, that number fell to 1.2 million. Five years ago, counts were at roughly 300,000. By 2019, numbers crashed below 30,000.

This year's count saw no monarchs at well-known overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park, saw only a few hundred. “These sites normally host thousands of butterflies, and their absence this year was heartbreaking for volunteers and visitors flocking to these locales hoping to catch a glimpse of the awe-inspiring clusters of monarch butterflies,” said Sarina Jepsen, director of endangered species at the Xerces Society.

Decline is driven by human activity. Climate change, habitat destruction, and the use of toxic pesticides are causing “death by a thousand cuts,” says Xerces Society executive director Scott Black.

A changing climate impacts environmental cues that trigger breeding, migration, and hibernation in monarchs. Climate-induced extreme weather events such as wildfires, severe storms, and droughts further stress populations. Habitat destruction has occurred through the displacement of natural land with industrial development, and logging and other damage to monarch overwintering sites. Milkweed plants that monarchs require as larval food have been found to contain pesticides at levels that can kill them—one study found toxic pesticides in every milkweed plant tested. Herbicides, like glyphosate (Roundup), that do not kill monarchs directly are killing milkweed, exacerbating concerns around habitat destruction. Each of these stressors are harmful on its own, but stress is compounded by their combination.

A study published in the journal Biological Conservation in 2017 (while numbers were still ~300,000) determined that western monarchs faced a 72% chance of extinction in 20 years and an 86% chance of extinction within the next 50 years. “This study doesn't just show that there are fewer monarchs now than 35 years ago,” said study coauthor Cheryl Schultz, PhD, at Washington State University. “It also tells us that, if things stay the same, western monarchs probably won't be around as we know them in another 35 years.”

Eastern monarchs are also suffering. This population migrates from the U.S. East and Midwest to overwintering grounds in Mexico each year. A 2018 study published by a research team at University of Florida found that this population has declined by 80% since 2005. Two years after that study was published, the 2019/2020 eastern monarch count conducted by citizen scientists found another 53% reduction. Eastern monarchs are counted by the number of acres they occupy. In 2019/20, this number was 7 acres, down from 15 acres the prior year. Scientists have determined that 15 acres is the minimum threshold necessary to prevent total migratory collapse. A report from the World Wildlife Fund estimates that at the current rate of decline, the eastern monarch migration could collapse within 20 years.

Wildlife and conservation groups urged the U.S. Fish and Wildlife Service to list monarchs under the Endangered Species Act. Late last December, the Trump Administration announced it was a candidate for listing, but that listing is “precluded by work on higher-priority listing actions.” The Biden administration must follow through with listing and protective actions.

Monarchs may be the most charismatic pollinator to fall in the age of the insect apocalypse. But unless meaningful changes are made, it will not be the last. Recent research published in Biological Conservation show that 41% of insect species are declining and 30% are endangered, with an overall rate of insect decline at 2.5% each year.

>>Tell the U.S. Fish and Wildlife Service to list monarch butterflies on the list of threatened and endangered species. Tell the Environmental Protection Agency to eliminate pollinator poisons.

 

Letter to Martha Williams, Principal Deputy Director, U.S. Fish and Wildlife Service

The yearly winter monarch count along the California coast was the lowest ever. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate the imminent extinction of western monarchs. Urgent action is required to implement a plan to protect monarchs as an endangered species!

Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count.  In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, the number fell to 1.2 million. Five years ago, counts were at roughly 300,000. By 2019, numbers had crashed below 30,000.

This year’s count saw no monarchs at well-known overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park, saw only a few hundred.

Decline is driven by human activity. Climate change, habitat destruction, and the use of toxic pesticides are combining to threaten the species. The way to initiate action to protect monarchs is to include them on the list of threatened and endangered species.

A changing climate alters environmental cues that trigger monarchs to breed, migrate, and hibernate. Climate-induced extreme weather events such as wildfires, severe storms, and droughts further stress populations. Habitat destruction includes logging, the displacement of natural land by industrial development, and other damage to monarch breeding and overwintering sites. Milkweed plants that monarchs require as larval food have been found to contain pesticides at levels that can kill them– one study found toxic pesticides in every milkweed plant tested. Herbicides, like glyphosate (Roundup), that do not kill monarchs directly kill milkweed, exacerbating habitat destruction. Each of these stressors is harmful on its own, but their combination compounds the damage.

A study published in the journal Biological Conservation in 2017 (while numbers were still ~300,000) determined that western monarchs faced a 72% chance of extinction in 20 years and an 86% chance of extinction within the next 50 years.

Eastern monarchs are also suffering. This population migrates from the US East and Midwest to overwintering grounds in Mexico each year. A 2018 study by researchers at University of Florida found that this population has declined by 80% since 2005. Two years later, the 2019/2020 eastern monarch count conducted by citizen scientists found another 53% reduction. Eastern monarchs are counted by the number of acres they occupy. In 2019/20, this number was 7 acres, down from 15 acres the prior year. Scientists have determined that 15 acres is the minimum threshold necessary to prevent total migratory collapse. A report from the World Wildlife Fund estimates that at the current rate of decline, the eastern monarch migration could collapse within 20 years.

Wildlife and conservation groups urged the U.S. Fish and Wildlife Service to list the monarch under the Endangered Species Act (ESA). Late last December, the Trump Administration announced it was a candidate for listing, but that listing is “precluded by work on higher-priority listing actions.” The presence of other high-priority issues is further evidence of the existence of severe threats to biodiversity, not a reason to avoid action. Protecting biodiversity is the purpose of the ESA. The Biden administration must follow through with listing and protective actions.

Monarchs may be the most charismatic pollinator to fall in the age of the insect apocalypse. But unless meaningful changes are made, it will not be the last. Recent research published in Biological Conservation show that 41% of insect species are declining and 30% are endangered, with an overall rate of insect decline at 2.5% each year.

Please put monarch butterflies on the threatened and endangered species list and require protective actions by other agencies.

Thank you.

 

Letter to Jane Nishida, Acting Administrator, EPA

The yearly winter monarch count along the California coast was the lowest ever. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate the imminent extinction of western monarchs. Urgent action is required to protect monarchs as an endangered species!

Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count.  In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, the number fell to 1.2 million. Five years ago, counts were at roughly 300,000. By 2019, numbers had crashed below 30,000. This year’s count saw no monarchs at well-known overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park, saw only a few hundred.

Decline is driven by human activity. Climate change, habitat destruction, and the use of toxic pesticides are combining to threaten the species.

A changing climate alters environmental cues that trigger monarchs to breed, migrate, and hibernate. Climate-induced extreme weather events such as wildfires, severe storms, and droughts further stress populations. Habitat destruction includes logging, the displacement of natural land by industrial development, and other damage to monarch breeding and overwintering sites.

Milkweed plants that monarchs require as larval food have been found to contain pesticides at levels that can kill them– one study found toxic pesticides in every milkweed plant tested. Herbicides, like glyphosate (Roundup), that do not kill monarchs directly kill milkweed, exacerbating habitat destruction. Each of these stressors is harmful on its own, but their combination compounds the damage.

A study published in the journal Biological Conservation in 2017 (while numbers were still ~300,000) determined that western monarchs faced a 72% chance of extinction in 20 years and an 86% chance of extinction within the next 50 years.

Eastern monarchs are also suffering. This population migrates from the U.S. East and Midwest to overwintering grounds in Mexico each year. A 2018 study by researchers at University of Florida found that this population has declined by 80% since 2005. Two years later, the 2019/2020 eastern monarch count conducted by citizen scientists found another 53% reduction. Eastern monarchs are counted by the number of acres they occupy. In 2019/20, this number was 7 acres, down from 15 acres the prior year. Scientists have determined that 15 acres is the minimum threshold necessary to prevent total migratory collapse. A report from the World Wildlife Fund estimates that at the current rate of decline, the eastern monarch migration could collapse within 20 years.

Wildlife and conservation groups urged the U.S. Fish and Wildlife Service to list the monarch under the Endangered Species Act (ESA). Late last December, the Trump Administration announced it was a candidate for listing, but that listing is “precluded by work on higher-priority listing actions.” The presence of so many high-priority issues is further evidence of the existence of severe threats to biodiversity, not a reason to avoid action. It is time for EPA to protect biodiversity from toxic chemical threats.

Monarchs may be the most charismatic pollinator to fall in the age of the insect apocalypse. But unless meaningful changes are made, it will not be the last. Recent research published in Biological Conservation show that 41% of insect species are declining and 30% are endangered, with an overall rate of insect decline at 2.5% each year.

Please include these threats to insect biodiversity in EPA’s pesticide registration decisions. Eliminate pesticides that endanger pollinators and their habitat.

Thank you.

01/25/2021 — Tell EPA to Reverse Approval of Highly Toxic Insecticide Aldicarb on Oranges

First registered in 1970 and voluntarily cancelled in 2010, aldicarb (Temik™) was being manufactured in Bhopal, India in 1984 when a leak of a precursor—methyl isocyanate (MIC)—spread over the city, ultimately killing more than 25,000 people and leaving more than 120,000 people who still suffer from severe health problems as a result of their exposure. In 1989, Union Carbide Corporation—the manufacturer of aldicarb at the time—paid $470 million (equivalent to $860 million in 2019) to settle litigation stemming from the disaster. Aldicarb, now made by Bayer, has been allowed by the outgoing Trump EPA for use on oranges.

>>Tell EPA to Reverse Approval of Highly Toxic Insecticide Aldicarb!

No pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. The disaster in Bhopal was followed by others, including a leak in Institute, WV in 1985 that injured at least 135 people and a 2008 explosion in Institute, WV that killed two and injured at least eight. In use, it has been implicated in poisoning of workers and their children, poisoning deer and other game consuming contaminated seeds, and notably, poisoning food grown in soil treated with the chemical. The effects don't stop there—aldicarb is also notorious for contaminating groundwater.

EPA has approved aldicarb (an insecticide) in combination with streptomycin (an antibiotic used to fight human disease) to control citrus greening, a disease transmitted by the Asian citrus psyllid. As Nathan Donley, PhD of the Center for Biological Diversity says, “Only the Trump EPA would approve use of a medically important antibiotic and a pesticide banned in over 100 countries on citrus crops.”

Aldicarb is a highly toxic, systemic carbamate insecticide that is a fast-acting cholinesterase inhibitor that permanently binds to the active site of an essential enzyme for normal nerve impulse transmission, acetylcholinesterase (AChE), deactivating the enzyme. In doing this, the chemical causes damage to the central and peripheral nervous systems, interrupting neurological activity. Aldicarb is subject to regulation under the Rotterdam Convention, an international treaty established to reduce the trade of the most globally hazardous chemicals, with over 100 countries—excluding the U.S.—banning its use. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category. However, the U.S. is one of only a few countries around the world that does not regulate aldicarb via the treaty, but merely strictly restricts its uses.

Aldicarb may persist in groundwater for decades due to its long half-life between 200 to 2000 days and ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Furthermore, aldicarb is a systemic pesticide that plant roots and leaves readily uptake, leading to toxic chemical residues in pollen and sap-like droplets (guttation) easily accessible to vulnerable pollinators, like bees.

In 2010, Bayer CropScience agreed with EPA to voluntarily cancel the production of Temik 15G, the sole aldicarb pesticide on the market, ending distribution by 2017. The chemical poses an unnecessary dietary risk to infants and children, causing neurological harm at very low doses. However, less than a decade after its discontinuation, a new aldicarb product by AgLogic—AgLogic 15G—surfaced, with limited use on a small subset of U.S. crops.

Presently, AgLogic is the only manufacturer of aldicarb pesticide products, and approving it for use on citrus fruit highlights faults within the pesticide regulatory system. Evidence demonstrates that past use of Temik 15G on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. Furthermore, the Florida Department of Agriculture denied AgLogic's request to gain “Special Local Needs” approval under Section 24(c) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) for use on Florida citrus in 2017 and 2018. AgLogic was unable to demonstrate that aldicarb is safer at controlling pests than other alternatives. This new AgLogic registration does not “require the submission of comparative efficacy studies,” which accelerated regular Section 3 registration on citrus.

Organic growers know that soil biology and soil health is important to protection from diseases like citrus greening. The use of aldicarb and streptomycin, on the other hand, destroy healthy soil biota.

The approval of AgLogic15G for use on citrus crops (e.g., grapefruit, lemon, orange, lime trees) allows an additional 400,000 acres of crop treatments in areas where pesticides already pose a threat to human, animal, and environmental health. Karen McCormack, a retired employee of the EPA's pesticide office, states her concern over aldicarb approval: “It's deeply disappointing to watch the current EPA renege on its agreement to ban this highly toxic and persistent pesticide. After receiving numerous complaints of aldicarb leaching into groundwater and contaminating drinking water supplies in Florida and elsewhere, my colleagues worked tirelessly to reach a voluntary agreement with the aldicarb manufacturer to stop producing this hazardous pesticide. Now it appears all this work may have been in vain.”

The approval of the aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.

It is essential that when EPA weighs the risks and benefits of extending pesticide uses, the agency acknowledges previous harms associated with those chemicals. Harms ultimately associated with contaminant exposure should end through policy reform and the adoption of practices that eliminate toxic pesticide use. With far too many diseases in the U.S. associated with pesticide exposure, prohibiting the use of pesticides with known toxic effects is crucial for safeguarding public health.

>>Tell EPA to reverse approval of highly toxic insecticide aldicarb.

Letter to EPA

It is crucial that the Biden administration add to its list of urgent actions the reversal of EPA’s approval of the highly toxic insecticide aldicarb for use on citrus.

First registered in 1970 and voluntarily cancelled in 2010, aldicarb (Temik™) was being manufactured in Bhopal, India in 1984 when a leak of a precursor—methyl isocyanate (MIC)—spread over the city, ultimately killing more than 25,000 people and leaving more than 120,000 people who still suffer from severe health problems as a result of their exposure. In 1989, Union Carbide Corporation—the manufacturer of aldicarb at the time—paid $470 million (equivalent to $860 million in 2019) to settle litigation stemming from the disaster. Aldicarb, now made by Bayer, has been allowed by the outgoing Trump EPA for use on oranges.

No pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. The disaster in Bhopal was followed by others, including a leak in Institute, WV in 1985 that injured at least 135 people and a 2008 explosion in Institute, WV that killed two and injured at least eight. In use, it has been implicated in poisoning of workers and their children, poisoning deer and other game consuming contaminated seeds, and notably, poisoning food grown in soil treated with the chemical. The effects don’t stop there—aldicarb is also notorious for contaminating groundwater.

EPA has approved aldicarb (an insecticide) in combination with streptomycin (an antibiotic used to fight tuberculosis) to control citrus greening, a disease transmitted by the Asian citrus psyllid. As Nathan Donley, PhD of the Center for Biological Diversity says, “Only the Trump EPA would approve use of a medically important antibiotic and a pesticide banned in over 100 countries on citrus crops.”

Aldicarb is a highly toxic, systemic carbamate insecticide banned by over 100 countries under the Rotterdam Convention. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category.

Aldicarb may persist in groundwater for decades due to its long half-life between 200 to 2000 days, and ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Furthermore, aldicarb is a systemic pesticide that plant roots and leaves readily uptake, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees.

In 2010, Bayer CropScience agreed with EPA to voluntarily cancel the production of Temik 15G, the sole aldicarb pesticide on the market, ending distribution by 2017. However, less than a decade after its discontinuation, a new aldicarb product by AgLogic—AgLogic 15G—surfaced, with limited use on a small subset of U.S. crops.

Evidence demonstrates that past use of Temik 15G on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. Furthermore, the Florida Department of Agriculture denied AgLogic’s request to gain “Special Local Needs” approval under Section 24(c) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) for use on Florida citrus in 2017 and 2018 because AgLogic was unable to demonstrate that aldicarb is safer at controlling pests than other alternatives.

Organic growers know that soil biology and soil health is important to protection from diseases like citrus greening. The use of aldicarb and streptomycin, on the other hand, destroy healthy soil biota.

The approval of the aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.

Please reverse EPA’s approval of the highly toxic insecticide aldicarb for use on citrus.

01/21/2021 — Tell the Biden USDA and Congress to Protect COVID relief for Black, Indigenous, People of Color, and Military Veteran Farmers!

(Beyond Pesticides, January 19, 2021) Inadequate funding proposed by the U.S. Department of Agriculture (USDA) for the Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers Program (also known as the “Section 2501” program) fails to address historic discrimination and inadequate assistance for farmers of color and military veteran farmers. Funding for the Section 2501 program, which for three decades, has been the only farm bill program specifically addressing needs of these underserved populations in agriculture is smaller this year, placing undue stress on already stretched-thin community organizations working to respond to farmers during this unprecedented period of prolonged economic hardship.

Tell the Biden USDA to ensure that the full Section 2501 funding reaches farmers of color and military veteran farmers.

Since 1990, the goal of the Section 2501 program has been to increase historically underserved farmers’ awareness of and access to USDA resources—addressing the historic inequities that farmers of color, or socially disadvantaged farmers, faced in accessing USDA programs, including Farm Service Agency (FSA) loans. Congress added military veterans to the program in 2014 as an additional underserved audience. Section 2501 grants provide funding to community-based organizations and minority-serving academic institutions to conduct critical outreach and technical assistance to communities of color and veterans. 

Unfortunately, USDA has redirected $2 million of this funding, along with $2 million redirected from Natural Resources Conservation Service (NRCS) conservation technical assistance funds to a separate, administratively created initiative. USDA’s a new Centers for Community Prosperity initiative seeks to address economic development in persistent poverty communities, with a focus on faith-based initiatives. This new program is less focused on socially disadvantaged farmers and much more prescriptive in project design than the Section 2501 program. In total, USDA diverted $4.2 million into this new initiative. 

Congress recently provided an additional $40 million for the Section 2501 grant program in its latest COVID relief bill passed in December 2020. Please urge USDA to ensure this funding goes directly to Section 2501 grantees and reaches socially disadvantaged farmers, and not be used for any other initiative—such as the Centers for Community Prosperity.

Tell the Biden USDA to ensure that the full Section 2501 funding reaches farmers of color and military veteran farmers.

Letter to Congress

As the COVID-19 pandemic drags on, farmers across the country are struggling to keep their farms afloat and plan for the uncertainty that the coming year holds. While farmers have suffered from several years of depressed prices, uncertainty in trade markets, and the increasingly severe impacts of climate change, the already tenuous livelihoods of our nation’s most chronically underserved farmers—particularly Black, Indigenous, and people of color farmers–were made worse this year as a result of the pandemic. I am increasingly concerned about the sustainability of our nation’s most underserved farmers who often not only have the fewest resources to draw on but also are most in need of emergency relief and long-term support in these challenging times—as well as the nation’s food security that depends on them.

As you know, Congress recently passed its fourth round of emergency relief to help farmers, small businesses, health care professionals, households and communities across the country combat the worsening impacts of the coronavirus pandemic. As directed in the farm bill, the $80 million in additional  USDA funding is to be divided equally between USDA’s Beginning Farmer and Rancher Development Program and the Outreach and Technical Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers Program, also known as the Section 2501 Program.

I urge you to make sure that USDA moves expeditiously to grant these additional Section 2501 funds to eligible entities with the skills and experience to reach socially disadvantaged and veteran farmers and ranchers, including those most impacted by the ongoing coronavirus pandemic. It is my expectation, as is shared by Congress, that the additional $40 million in funding to be directed to the Section 2501 grant program will support projects as authorized under the farm bill and will not be diverted to any other administrative initiative or purpose, such as the Centers for Community Prosperity.

In the fact of the future uncertainty of the ultimate impacts of the pandemic on our food system and communities of color, please pressure USDA to distribute the additional Section 2501 grants in a way that ensures organizations have resources over the coming years to respond to their community’s needs. USDA should also use the additional funding to increase the total grant award amount to its statutory level of $250,000 per year. Finally, I share the expectation of Congress that USDA will ensure that any project funded with these additional funds complies with the statutory requirements laid out in the farm bill—that it:

  • Has demonstrated experience in providing agricultural education or other agriculturally related services to socially disadvantaged farmers and ranchers and veteran farmers and ranchers;
  • Provides documentary evidence of work with, and on behalf of, socially disadvantaged farmers or ranchers and veteran farmers and ranchers during the 3-year period preceding the submission of their 2501 application;
  • Will use any 2501 funding to provide outreach and technical assistance exclusively to socially disadvantaged and veteran farmers in order to improve their participation in USDA agricultural program; and
  • Will represent a regional balance of projects that are geographically diverse and serve farmers in all states and regions

Thank you for supporting this critical program—especially during a time of such critical need for Black, Indigenous and people of color communities across the country.

Letter to Biden Transition Team on Agriculture

As the COVID-19 pandemic drags on, farmers across the country are struggling to keep their farms afloat and plan for the uncertainty that the coming year holds. While farmers have suffered from several years of depressed prices, uncertainty in trade markets, and the increasingly severe impacts of climate change, the already tenuous livelihoods of our nation’s most chronically underserved farmers—particularly Black, Indigenous, and people of color farmers—were made worse this year as a result of the pandemic. I am increasingly concerned about the sustainability of our nation’s most underserved farmers who often not only have the fewest resources to draw on but also are most in need of emergency relief and long-term support in these challenging times—as well as the nation’s food security that depends on them.

Congress recently passed its fourth round of emergency relief to help farmers, small businesses, health care professionals, households and communities across the country combat the worsening impacts of the coronavirus pandemic. As directed in the farm bill, the $80 million in additional  USDA funding is to be divided equally between USDA’s Beginning Farmer and Rancher Development Program and the Outreach and Technical Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers Program, also known as the Section 2501 Program.

I urge the Department to move expeditiously to grant these additional Section 2501 funds to eligible entities with the skills and experience to reach socially disadvantaged and veteran farmers and ranchers, including those most impacted by the ongoing coronavirus pandemic. It is my expectation, as is shared by Congress, that the additional $40 million in funding to be directed to the Section 2501 grant program will support projects as authorized under the farm bill and will not be diverted to any other administrative initiative or purpose, such as the Centers for Community Prosperity.

In the face of the future uncertainty of the ultimate impacts of the pandemic on our food system and communities of color, I ask USDA to distribute the additional Section 2501 grants in a way that ensures organizations have resources over the coming years to respond to their community’s needs. USDA should also use the additional funding to increase the total grant award amount to its statutory level of $250,000 per year. Finally, I share the expectation of Congress that USDA will ensure that any project funded with these additional funds complies with the statutory requirements laid out in the farm bill—that it:

  • Has demonstrated experience in providing agricultural education or other agriculturally related services to socially disadvantaged farmers and ranchers and veteran farmers and ranchers;
  • Provides documentary evidence of work with, and on behalf of, socially disadvantaged farmers or ranchers and veteran farmers and ranchers during the 3-year period preceding the submission of their 2501 application;
  • Will use any 2501 funding to provide outreach and technical assistance exclusively to socially disadvantaged and veteran farmers in order to improve their participation in USDA agricultural program; and
  • Will represent a regional balance of projects that are geographically diverse and serve farmers in all states and regions

Thank you for considering these recommendations and for supporting this critical program—especially during a time of such critical need for Black, Indigenous and people of color communities across the country.

01/11/2021 — Tell President-Elect Biden and Congress to Clean Up at EPA—End the Era of Corporate Deception

Tell President-Elect Biden and Congress to Clean Up at EPA—End the Era of Corporate Deception

01/04/2021 — Secure Your Food and the Future of Local Organic Farmers

As we begin the new year, one of the most pervasive problems that our country faces, which has been particularly painful especially during the holiday season, is food insecurity—now affecting 54 million people. Food insecurity in the U.S. is real. As we continue through the dark winter months with the threat of even greater surges in COVID-19, it is important to strengthen those connections that support food security and those who produce our food.

>>Ask your U.S. Senators and Representatives to make permanent support for small and medium sized local farmers, building on the Emergency Coronavirus Relief Package.

Worldwide, the threats of impending famine have been met by extraordinary responses from countries and private donors. These events are evidence that food shortages are caused by inequities in distribution rather than underproduction, consistent with continuing population growth and contrary to claims by the pesticide industry. Peasant activists Jeongyeol Kim and Pramesh Pokharel argue that the solution to food insecurity is food sovereignty—that a food system depending on big agribusiness and corporations does not support local food production. That food system contributes to food insecurity for both the countries depending on food imports that may not be present is a pandemic and for countries exporting food—whose food supplies may be exported and whose farmers are dependent on income from exports.

“The COVID-19 pandemic has had a profound impact on our nation's food supply,” said Senator Corey Booker, who sponsored the Local FARM Act. “Food banks are grappling with greater demand while subsequently facing steep reductions in donations. Farmers have been forced to dump products due to supply-chain disruptions and a resulting lack of access to traditional markets. And corporate agribusiness is proving incapable of maintaining operations in a way that is safe for both workers and our food supply.”

“In response, this legislation strengthens local and regional food systems in order to avoid the harmful supply-chain disruptions stemming from a consolidated market and provides greater choice to those purchasing food to feed their families during this difficult time,” said Senator Booker. “Billions of dollars in farm aid have been made available in response to the current health crisis, but current programs fail to not only fairly compensate farmers from across the economic spectrum, they fail to invest in resilient food systems that could protect the nation's food supply both now and in a future pandemic. It's time for that to change.”

"The ongoing coronavirus pandemic has left many small, beginning, and historically underserved producers, including Black, Indigenous, and farmers of color; in a precarious financial situation - especially farmers who have traditionally relied on selling into local and regional markets such schools, institutions, restaurants and farmers markets,” said Wes King, Senior Policy Specialist of the National Sustainable Agriculture Coalition (NSAC).

We need to make permanent support for small and medium sized local farmers, building on the Emergency Coronavirus Relief Package. Elements of Local Food Assistance and Resilient Markets Act (the Local FARM Act) must become permanent:

(i) Create specialty crop block grants; (ii) Expand online supplemental nutrition assistance program; (iii) Expand the Local Agriculture Market Program (LAMP); and (iv) Expand farm microloans.

According to Eric Deeble, NSAC policy director, “[The Emergency Coronavirus Relief Package] does not do enough to target aid to those producers and families who have been most impacted, and sunsets too soon: all but ensuring advocates will have to return to fight for families again in January.”  Mr. Deeble continued, “Even still, it is an important starting point as the new Administration and Congress begin to look beyond emergency response to the longer term work of rebuilding our food and farm system to be more sustainable, must, and equitable for every family.” 

In addition to the need for policy reform and in accordance with “Think globally and act locally,” we can help ourselves, our local farmers, and the resilience of the global food system by buying locally-grown organic food directly from the farmer—or with as few intervening steps as possible. Below are some resources that can help.

LocalHarvest provides a connection to community supported agriculture (subscription services), farms, farmers markets, and other local food sources. Eatwild provides a clearinghouse for information about pasture-based farming, with a directory of local farmers in the U.S. and Canada who sell their pastured farm and ranch products directly to consumers. The U.S. Department of Agriculture (USDA) maintains a database of local farmers markets. Another step away, there is a listing of cooperative grocery stores at the Cooperative Grocers Network. Winter may not be a good time to grow vegetables in most states, but sprouts and microgreens can be grown anywhere. 

>>Ask your U.S. Senators and Representatives to make permanent support small and medium sized local farmers, building on the Emergency Coronavirus Relief Package.

Letter to Congress

As we begin the new year, one of the most pervasive problems that our country faces, which has been particularly painful especially during the holiday season, is food insecurity—now affecting 54 million people. Food insecurity in the U.S. is real. As we continue through the dark winter months with the threat of even greater surges in COVID-19, it is important to strengthen those connections that support food security and those who produce our food.

I am writing to ask you to make permanent support for small and medium sized local farmers, building on the Coronavirus Relief Package. Elements of Local Food Assistance and Resilient Markets Act (the Local FARM Act) must become permanent:

(i) Create specialty crop block grants;
(ii) Expand online supplemental nutrition assistance program;
(iii) Expand the Local Agriculture Market Program (LAMP); and
(iv) Expand farm microloans.

Worldwide, the threats of impending famine have been met by extraordinary responses from countries and private donors. These events are evidence that food shortages are caused by inequities in distribution rather than underproduction, consistent with continuing population growth and contrary to claims by the pesticide industry. Peasant activists Jeongyeol Kim and Pramesh Pokharel argue that the solution to food insecurity is food sovereignty—that a food system depending on big agribusiness and corporations does not support local food production. That food system contributes to food insecurity for both the countries depending on food imports that may not be present is a pandemic and for countries exporting food—whose food supplies may be exported and whose farmers are dependent on income from exports.

"The ongoing coronavirus pandemic has left many small, beginning, and historically underserved producers, including Black, Indigenous, and farmers of color; in a precarious financial situation - especially farmers who have traditionally relied on selling into local and regional markets such schools, institutions, restaurants and farmers markets,” said Wes King, Senior Policy Specialist of the National Sustainable Agriculture Coalition.

Please help our local farmers to ensure the availability of food in our communities.

Thank you.