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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.

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12/05/2022 — Save Manatees from Extinction Caused in Large Part by Toxic Runoff!

A petition filed last week with the U.S. Fish and Wildlife Service (USFWS) urges increased protections for the West Indian manatee after dramatic declines in its population over recent years. In 2017, USFWS downgraded the classification of the manatee from endangered—a category that broadly protects against “take,” defined as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct”—to threatened, for which an “acceptable” level of “take” is allowed. Following the downlisting of the species, manatee populations have declined dramatically. 

>>Upgrade the Florida manatee to endangered and require protection from chemical pollution! Tell your Congressional Representative to cosponsor H.R. 4946 and your Senators to introduce identical legislation. Tell Florida's Fish and Wildlife Conservation Commission to protect manatees. 

Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years, weigh up to 1,200 lbs., and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants. 

In 2017, U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating that over 1,000 manatees died in just the last year alone, a bipartisan group of Florida Congressional Representatives, Rep. Vern Buchanan (R-FL) and Rep. Darren Soto (D-FL), have introduced legislation (H.R. 4946, Manatee Protection Act) that would reclassify the sea cows as endangered. In addition, a group of concerned environmentalists—the Center for Biological Diversity, Harvard Animal Law and Policy Clinic, Miami Waterkeeper, Save the Manatee Club, and Frank S. González García—have petitioned USFWS to restore the endangered status. 

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive. 

Exposure to contaminants like glyphosate (Roundup) herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other natural causes of mortality—including  red tide, and cold stress in the winter months, as manatees are unable to survive in waters below 68 degrees Fahrenheit. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways from lawns and landscapes, parks, golf courses, and farm fields. Research finds that 55.8% of manatees have glyphosate in their bodies. 

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and highly manicured landscapes. The algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can either directly kill off more aquatic vegetation, or feed algae blooms as it breaks down. According to recent reporting, in just one region, Sarasota Bay, 18% of seagrass was lost between 2018 and 2020. The Florida Governor's plan to target wastewater treatment is an important component of the solution, particularly in light of major incidents like the Piney Point spill, but more must be done to reduce use of toxics and clean up diffuse sources of pollution as well. 

It is critical that lawmakers and the public take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to reduce the need to store tons of fertilizer in precarious lagoons, and spray these and other harmful chemicals broad areas of land throughout the state. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies. 

>>Upgrade the Florida manatee to endangered and require protection from chemical pollution. Tell your Congressional Representative to cosponsor H.R. 4946 and your Senators to introduce identical legislation. Tell Florida's Fish and Wildlife Conservation Commission to protect manatees.

Letter to U.S. Senators: 

Florida manatees are facing severe threats, prompting a group of concerned environmentalists—the Center for Biological Diversity, Harvard Animal Law and Policy Clinic, Miami Waterkeeper, Save the Manatee Club, and Frank S. González García—to petition the U.S. Fish and Wildlife Service (USFWS) to restore the endangered status. Protecting manatees will require a multi-faceted approach, including upgrading their status to endangered and protecting their watery habitat from toxic threats. I am writing to ask you to introduce legislation identical to H.R. 4946, Manatee Protection Act, to re-classify manatees as endangered.

Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years, weigh up to 1,200 lbs., and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants.

In 2017, U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating over 1,000 manatees died in just the last year alone, a bipartisan group of Florida Congressmembers, Rep Vern Buchanan and Rep Darren Soto, have introduced legislation (H.R. 4946) that would re-classify the sea cows as endangered.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other causes of mortality—including red tide and cold stress in the winter months. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and treated landscapes. Algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can both directly kill off more aquatic vegetation and feed algae blooms as it breaks down. More must be done to reduce demand and clean up diffuse sources of pollution as well.

It is critical that lawmakers and the public take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to reduce the need to store tons of fertilizer in precarious lagoons, and spray these and other harmful chemicals broad areas of land throughout the state. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

Please introduce legislation identical to H.R. 4946, Manatee Protection Act of 2021.

Thank you.

Letter to U.S. Representatives:

Florida manatees are facing severe threats, prompting a group of concerned environmentalists—the Center for Biological Diversity, Harvard Animal Law and Policy Clinic, Miami Waterkeeper, Save the Manatee Club, and Frank S. González García—to petition the U.S. Fish and Wildlife Service (USFWS) to restore the endangered status. Protecting manatees will require a multi-faceted approach, including upgrading their status to endangered and protecting their watery habitat from toxic threats. I am writing to ask you to cosponsor H.R. 4946, Manatee Protection Act, to re-classify manatees as endangered.

Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years, weigh up to 1,200 lbs., and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants.

In 2017, U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating over 1,000 manatees died in just the last year alone, a bipartisan group of Florida Congressmembers, Rep Vern Buchanan and Rep Darren Soto, have introduced legislation (H.R. 4946) that would re-classify the sea cows as endangered.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other causes of mortality—including red tide and cold stress in the winter months. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and treated landscapes. Algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can both directly kill off more aquatic vegetation and feed algae blooms as it breaks down. More must be done to reduce demand and clean up diffuse sources of pollution as well.

It is critical that lawmakers and the public take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to reduce the need to store tons of fertilizer in precarious lagoons, and spray these and other harmful chemicals broad areas of land throughout the state. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

Please cosponsor H.R. 4946, Manatee Protection Act of 2021.

Thank you.

Letter to Florida FWC:

I am writing to ask you to take action to protect the Florida manatee by requiring the management of state parks with organic land management practices.

In 2017, U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating over 1,000 manatees died in just the last year alone, it is clear that optimism over the status of the species was premature.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other natural causes of mortality—including red tide, and cold stress in the winter months, as manatees are unable to survive in waters below 68 degrees Fahrenheit. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and treated landscapes. The algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer.

In this context, glyphosate, a phosphorous-based herbicide, can either directly kill off more aquatic vegetation, or feed algae blooms as it breaks down. In just one region, Sarasota Bay, 18% of seagrass was lost between 2018 and 2020. Your plan to target wastewater treatment is an important component of the solution, particularly in light of major incidents like the Piney Point spill, but more must be done to reduce demand and clean up diffuse sources of pollution as well.

It is critical to take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to eliminate threats from harmful chemicals. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

Thank you for acting to protect the Florida manatee.

Thank you to sponsors of H.R. 4946:

Thank you for sponsoring H.R., 4946, Manatee Protection Act of 2021, to restore the manatees’ endangered status under the Endangered Species Act. This action is critical for both the manatees and for Florida’s environment.

11/28/2022 — Tell EPA to Ban Pesticides that Reduce Sperm Counts

Based on new international research adding weight to previous research on falling sperm counts, it is critical that environmental agencies address this and other problems related to endocrine disruption. The study by Levine et al. finds that the drop in sperm count—a drop of 51.6% from 1973 through 2018—is global and that the rate of decline is accelerating.  

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

The documented (average) drop in sperm counts is approaching the level at which the ability to cause a pregnancy begins to plummet dramatically. The reduction in male fertility may have profound psychological and social impacts, including anxiety, low self-esteem, and depression. These psychological problems have health impacts of their own. Equally serious are connections of anxiety and depression with violent behavior and suicide. Compounding the problem is the fact that men are unlikely to seek fertility-related social support.  

The drop in sperm counts is just one example of endocrine disruption largely due to exposure to toxic chemicals. 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.  

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, 26 years later, we have yet to see EPA use endocrine disruption findings in pesticide registration decisions. 

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 diseases, diabetes, 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 no 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.

11/21/2022 — EPA Must Complete Thorough Reviews Before Registering Pesticides

Once again, the Environmental Protection Agency (EPA) has registered a new pesticide without performing a thorough review of its impacts on biodiversity as well as threatened and endangered species. Inpyrfluxam was registered in 2020 and only after being sued by the Center for Biological Diversity for failure to comply with the Endangered Species Act (ESA) did EPA commit to completing draft effects determinations by Fall 2022. Once again, EPA's draft biological evaluation is incomplete and inadequate. EPA is accepting comments on its draft biological evaluation at Regulations.gov. 

>>Tell EPA and Congress that Pesticide Registrations Require Complete Science. The Review of Inpyrfluxam is Incomplete and Inadequate.

The agency's draft effects assessment is flawed and incomplete. We share the details because it shows that EPA is out of step with the science and its regulatory responsibility when it comes a thorough review for ecosystem effects of pesticides.  

The agency used fish early life stage (ELS) tests to estimate chronic fish toxicity. This is inappropriate. The fish ELS is a sub-chronic test of sensitive life stages. Although it is often used as a surrogate or predictor of chronic toxicity, it does not adequately address potential adverse effects on reproduction or transfer of the test chemical to eggs/offspring from parental exposure. Only a complete life-cycle test can satisfy the 40 CFR Part 158 requirements for a valid fish chronic toxicity test. An early life-stage test cannot be appropriately substituted. A full life-cycle test (OSCPP 850.1500) or medaka extended one-generation test (OSCPP 890.2200) is needed to correctly assess reproduction impairment and chronic toxicity from long-term exposures. Such chronic reproductive toxicity testing in fish is further warranted by the observation of reproductive impairment in another vertebrate taxon (bobwhite quail). Additionally, the reduced egg production in a non-monotonic dose response seen in the bobwhite quail reproduction study suggests the potential for an endocrine disrupting modality. The higher toxicity of inpyrfluxam to another bird species (zebra finch) in a sub-acute dietary study warrants a full reproduction test with this passerine species to fully assess serious risks posed to listed avian species. An Endocrine Disruptor Screening Program evaluation of inpyrfluxam has not been completed and is also necessary for an adequate endangered species consultation with the Services. 

The lack of appropriate chronic toxicity and endocrine disruption data is especially worrisome given the recognized environmental persistence of inpyrfluxam. Further, the registration of inpyrfluxam should not have been approved in the first place with such important data missing from the ecological risk assessment. Without these data and with the somewhat marginal benefits of inpyrfluxam use, the agency cannot honestly conclude, as statutorily required, that the use of this fungicide does not pose an unreasonable risk. The agency should immediately suspend the uses of inpyrfluxam until data addressing the chronic reproductive toxicity in fish and birds are available and the Services are consulted on potential jeopardy to these taxa. The agency should be reminded that it should not make any registration decisions until a thorough ecological risk assessment has been completed and as mandated in the Endangered Species Act that the Services have been consulted for any may affect findings noted. 

Beyond Pesticides has previously pointed out deficiencies in EPA's ecological risk assessments for atrazinefludioxonilneonicotinoidscarbaryl and methomylindaziflampyrethroidsparaquatglyphosate, and wood preservatives. In addition, the Center for Biological Diversity and others have successfully sued EPA for numerous failures to perform complete assessments of impacts of pesticides on threatened and endangered species. All this is occurring amid documented threats to biodiversity from the combined impacts of pesticides and climate change.

Please also submit a comment to EPA at this link at Regulations.gov. See suggested language that you can copy into Regulations.gov. Adding a personal comment of concern at the beginning of the comment is helpful but not necessary. 

Suggested language for a comment at Regulations.gov: 

Once again, EPA has registered a new pesticide without performing a thorough review of its impacts on threatened and endangered species. Inpyrfluxam was registered in 2020, and only after being sued by the Center for Biological Diversity for failure to comply with the Endangered Species Act (ESA) did EPA commit to completing draft effects determinations by Fall 2022. Once again, EPA's draft biological evaluation is incomplete and inadequate. EPA is accepting comments on its draft biological evaluation at Regulations.gov. 

The agency's draft effects assessment of inpyrfluxam is flawed and incomplete. The agency used fish early life stage (ELS) tests to estimate chronic fish toxicity. This is inappropriate. The fish ELS is a sub-chronic test of sensitive life stages. Although it is often used as a surrogate or predictor of chronic toxicity, it does not adequately address potential adverse effects on reproduction or transfer of the test chemical to eggs/offspring from parental exposure. Only a complete life-cycle test can satisfy the 40 CFR Part 158 requirements for a valid fish chronic toxicity test. An early life-stage test cannot be appropriately substituted. A full life cycle test (OSCPP 850.1500) or medaka extended one-generation test (OSCPP 890.2200) is needed to correctly assess reproduction impairment and chronic toxicity from long-term exposures. Such chronic reproductive toxicity testing in fish is further warranted by the observation of reproductive impairment in another vertebrate taxon (bobwhite quail). Additionally, the reduced egg production in a non-monotonic dose response seen in the bobwhite quail reproduction study suggests the potential for an endocrine disrupting modality. The higher toxicity of inpyrfluxam to another bird species (zebra finch) in a sub-acute dietary study warrants a full reproduction test with this passerine species to fully assess serious risks posed to listed avian species. An Endocrine Disruptor Screening Program evaluation of inpyrfluxam has not been completed and is also necessary for an adequate endangered species consultation with the Services. 

The lack of appropriate chronic toxicity and endocrine disruption data is especially worrisome given the recognized environmental persistence of inpyrfluxam. Further, the registration of inpyrfluxam should not have been approved in the first place with such important data missing from the ecological risk assessment. Without these data and with the somewhat marginal benefits of inpyrfluxam use, the agency cannot honestly conclude, as statutorily required, that the use of this fungicide does not pose an unreasonable risk. The agency should immediately suspend the uses of inpyrfluxam until data addressing the chronic reproductive toxicity in fish and birds are available and the Services are consulted on potential jeopardy to these taxa. The agency should not make any registration decisions until a thorough ecological risk assessment has been completed and as mandated in the Endangered Species Act that the Services have been consulted for any may affect findings noted. 

Beyond Pesticides has previously pointed out deficiencies in EPA's ecological risk assessments for atrazine, fludioxonil, neonicotinoids, carbaryl and methomyl, indaziflam, pyrethroids, paraquat, glyphosate, and wood preservatives. In addition, the Center for Biological Diversity and others have successfully sued EPA for numerous failures to perform complete assessments of impacts of pesticides on threatened and endangered species. All this is occurring amid documented threats to biodiversity from the combined impacts of pesticides and climate change. 

EPA must cancel the registration of inpyrfluxam and perform complete biological evaluations of all pesticides. 

Thank you. 

>>Tell EPA and Congress that Pesticide Registrations Require Complete Science. The Review of Inpyrfluxam is Incomplete and Inadequate.

Letter to EPA Administrator: 

Once again, EPA has registered a new pesticide without performing a thorough review of its impacts on threatened and endangered species. Inpyrfluxam was registered in 2020, and only after being sued by the Center for Biological Diversity for failure to comply with the Endangered Species Act (ESA) did EPA commit to completing draft effects determinations by Fall 2022. Once again, EPA’s draft biological evaluation is incomplete and inadequate. EPA is accepting comments on its draft biological evaluation at Regulations.gov. 

The agency's draft effects assessment of inpyrfluxam is flawed and incomplete. The agency used fish early life stage (ELS) tests to estimate chronic fish toxicity. This is inappropriate. The fish ELS is a sub-chronic test of sensitive life stages. Although it is often used as a surrogate or predictor of chronic toxicity, it does not adequately address potential adverse effects on reproduction or transfer of the test chemical to eggs/offspring from parental exposure. Only a complete life-cycle test can satisfy the 40 CFR Part 158 requirements for a valid fish chronic toxicity test. An early life-stage test cannot be appropriately substituted. A full life cycle test (OSCPP 850.1500) or medaka extended one-generation test (OSCPP 890.2200) is needed to correctly assess reproduction impairment and chronic toxicity from long term exposures. Such chronic reproductive toxicity testing in fish is further warranted by the observation of reproductive impairment in another vertebrate taxon (bobwhite quail). Additionally, the reduced egg production in a non-monotonic dose response seen in the bobwhite quail reproduction study suggests the potential for an endocrine disrupting modality. The higher toxicity of inpyrfluxam to another bird species (zebra finch) in a sub-acute dietary study warrants a full reproduction test with this passerine species to fully assess serious risks posed to listed avian species. An Endocrine Disruptor Screening Program evaluation of inpyrfluxam has not been completed and is also necessary for an adequate endangered species consultation with the Services. 

The lack of appropriate chronic toxicity and endocrine disruption data is especially worrisome given the recognized environmental persistence of inpyrfluxam. Further, the registration of inpyrfluxam should not have been approved in the first place with such important data missing from the ecological risk assessment. Without these data and with the somewhat marginal benefits of inpyrfluxam use, the agency cannot honestly conclude as statutorily required that the use of this fungicide does not pose an unreasonable risk. The agency should immediately suspend the uses of inpyrfluxam until data addressing the chronic reproductive toxicity in fish and birds are available and the Services are consulted on potential jeopardy to these taxa. The agency should not make any registration decisions until a thorough ecological risk assessment has been completed and as mandated in the Endangered Species Act that the Services have been consulted for any may affect findings noted. 

Beyond Pesticides has previously pointed out deficiencies in EPA’s ecological risk assessments for atrazine, fludioxonil, neonicotinoids, carbaryl and methomyl, indaziflam, pyrethroids, paraquat, glyphosate, and wood preservatives. In addition, the Center for Biological Diversity and others have successfully sued EPA for numerous failures to perform complete assessments of impacts of pesticides on threatened and endangered species. All this is occurring amid documented threats to biodiversity from the combined impacts of pesticides and climate change. 

EPA must cancel the registration of inpyrfluxam and perform complete biological evaluations of all pesticides. 

Thank you. 

Letter to U.S. Representative and Senators: 

Once again, the Environmental Protection Agency (EPA) has registered a new pesticide without performing a thorough review of its impacts on threatened and endangered species. Inpyrfluxam was registered in 2020, and only after being sued by the Center for Biological Diversity for failure to comply with the Endangered Species Act (ESA) did EPA commit to completing draft effects determinations by Fall 2022. Once again, EPA’s draft biological evaluation is incomplete and inadequate. EPA is accepting comments on its draft biological evaluation at Regulations.gov. 

The agency's draft effects assessment of inpyrfluxam is flawed and incomplete. The agency used fish early life stage (ELS) tests to estimate chronic fish toxicity. This is inappropriate. The fish ELS is a sub-chronic test of sensitive life stages. Although it is often used as a surrogate or predictor of chronic toxicity, it does not adequately address potential adverse effects on reproduction or transfer of the test chemical to eggs/offspring from parental exposure. Only a complete life-cycle test can satisfy the 40 CFR Part 158 requirements for a valid fish chronic toxicity test. An early life-stage test cannot be appropriately substituted. A full life cycle test (OSCPP 850.1500) or medaka extended one-generation test (OSCPP 890.2200) is needed to correctly assess reproduction impairment and chronic toxicity from long term exposures. Such chronic reproductive toxicity testing in fish is further warranted by the observation of reproductive impairment in another vertebrate taxon (bobwhite quail). Additionally, the reduced egg production in a non-monotonic dose response seen in the bobwhite quail reproduction study suggests the potential for an endocrine disrupting modality. The higher toxicity of inpyrfluxam to another bird species (zebra finch) in a sub-acute dietary study warrants a full reproduction test with this passerine species to fully assess serious risks posed to listed avian species. An Endocrine Disruptor Screening Program evaluation of inpyrfluxam has not been completed and is also necessary for an adequate endangered species consultation with the Services. 

The lack of appropriate chronic toxicity and endocrine disruption data is especially worrisome given the recognized environmental persistence of inpyrfluxam. Further, the registration of inpyrfluxam should not have been approved in the first place with such important data missing from the ecological risk assessment. Without these data and with the somewhat marginal benefits of inpyrfluxam use, the agency cannot honestly conclude as statutorily required that the use of this fungicide does not pose an unreasonable risk. The agency should immediately suspend the uses of inpyrfluxam until data addressing the chronic reproductive toxicity in fish and birds are available and the Services are consulted on potential jeopardy to these taxa. The agency should be reminded that it should not make any registration decisions until a thorough ecological risk assessment has been completed and as mandated in the Endangered Species Act that the Services have been consulted for any may affect findings noted. 

Beyond Pesticides has previously pointed out deficiencies in EPA’s ecological risk assessments for atrazine, fludioxonil, neonicotinoids, carbaryl and methomyl, indaziflam, pyrethroids, paraquat, glyphosate, and wood preservatives. In addition, the Center for Biological Diversity and others have successfully sued EPA for numerous failures to perform complete assessments of impacts of pesticides on threatened and endangered species. All this is occurring amid documented threats to biodiversity from the combined impacts of pesticides and climate change. 

Please ensure through your oversight that EPA fulfills its responsibilities according to law. EPA must cancel the registration of inpyrfluxam and perform complete biological evaluations of all pesticides. 

Thank you.

11/14/2022 — Tell EPA To Ban Antibiotics in Agriculture, Lawns, and Landscapes

Glyphosate weed killers induce antibiotic resistance in deadly hospital-acquired bacteria, according to a new study published late last month in the journal Scientific Reports. This is the latest finding connecting commonly used herbicides to the rise of antibiotic resistant bacteria. To put this finding in context, antibiotic resistance is rising to dangerously high levels in all parts of the world, according to the World Health Organization. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. writes, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” The authors continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”

>>Tell EPA and Congress that antibiotic pesticides in agriculture, lawns, and landscapes must be eliminated. 

Use of antibiotics in animal agriculture has long been recognized as a contributor to widespread antibiotic resistance. More recently, recognition of the contribution of antibiotics in plant agriculture has led to pressure to eliminate agricultural uses of antibiotics used in medicine. However, two facts lead to the conclusion that even that is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens.

These two facts lead to the conclusion that we must stop broadcasting pesticides in the environment and applying them to food. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides have been disseminated in the environment for decades. At the same time, it is understood that underlying practices and conditions that could be changed in land and agricultural management are the principle reasons for antibiotic use in these areas. As Michael Greger, M.D., Ph.D., author of Bird Flu: A Virus of Our Own Hatching, explains, “When we overcrowd animals by the thousands, in cramped football-field-size sheds, to lie beak to beak or snout to snout, and there's stress crippling their immune systems, and there's ammonia from the decomposing waste burning their lungs, and there's a lack of fresh air and sunlight — put all these factors together and you have a perfect-storm environment for the emergence and spread of disease.” In addition to animal agriculture, the regulation of antibiotics in chemical-intensive crop production is alarmingly weak, allowing residues of antibiotics and antibiotic-resistant bacteria to emerge on agricultural lands, move through the environment, contaminate waterways, and ultimately reach consumers and the general public.

EPA must consider the availability and viability of organic practices, which under USDA organic certification do not allow the use of antibiotics.

EPA must not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and must cancel the registration of those that do.

>>Tell EPA and Congress that antibiotic pesticides in agriculture, lawns, and landscapes must be eliminated.

Letter to Congress

I am writing to ask you to ensure that EPA acts on a serious threat to human health from antibiotic resistance. According to a new study published late last month in the journal Scientific Reports, glyphosate weed killers induce antibiotic resistance in deadly hospital-acquired bacteria. To put this in context, antibiotic resistance is rising to dangerously high levels in all parts of the world, according to the World Health Organization. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” The authors continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”

Use of antibiotics in animal agriculture has long been recognized as a contributor to widespread antibiotic resistance. More recently, recognition of the contribution of antibiotics in plant agriculture has led to pressure to eliminate agricultural uses of antibiotics used in medicine. However, two facts lead to the conclusion that even that is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens.

These two facts lead to the conclusion that we must stop broadcasting pesticides in the environment and applying them to food. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides have been disseminated in the environment for decades.

EPA must not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and must cancel the registration of those that do. EPA must consider the availability and viability of organic practices, which under USDA organic certification do not allow the use of antibiotics.

Thank you for your attention to this serious problem.

Letter to EPA

I am writing to ask EPA to act on a serious threat to human health from antibiotic resistance. According to a new study published late last month in the journal Scientific Reports, glyphosate weed killers induce antibiotic resistance in deadly hospital-acquired bacteria. To put this in context, antibiotic resistance is rising to dangerously high levels in all parts of the world, according to the World Health Organization. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” The authors continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”

Use of antibiotics in animal agriculture has long been recognized as a contributor to widespread antibiotic resistance. More recently, recognition of the contribution of antibiotics in plant agriculture has led to pressure to eliminate agricultural uses of antibiotics used in medicine. However, two facts lead to the conclusion that even that is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens.

These two facts lead to the conclusion that we must stop broadcasting pesticides in the environment and applying them to food. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides have been disseminated in the environment for decades.

EPA must not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and must cancel the registration of those that do. EPA must consider the availability and viability of organic practices, which under USDA organic certification do not allow the use of antibiotics.

Thank you for your attention to this serious problem.

11/07/2022 — Tell Congress to Address Contamination with PFAS and Other Legacy Chemicals

The Maine Congressional delegation — Senators Collins (R) and Angus King (I), and Representatives Chellie Pingree (D) and Jared Golden (D), along with New Hampshire Senator Jeanne Shaheen (D) — have  introduced a bipartisan bill — the Relief for Farmers Hit with PFAS Act — to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. The bills are the identical S. 5070 and H.R. 9186, both titled “Relief for Farmers Hit with PFAS Act.”

>>Tell your U.S. Senators and Representative to cosponsor the Relief for Farmers Hit with PFAS Act. If they are already cosponsors, thank them. Tell EPA to stop the spread of legacy chemicals.

PFAS chemicals, also known as “forever chemicals,” are legacy contaminants or those whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

As indicated by the title of these bills, farmers have often been “hit with” legacy contaminants through no fault of their own, and these bills will authorize $500 million over FY 2023-2027 to the U.S Department of Agriculture to help farmers address the aftermath of the contamination, including: more capacity for PFAS testing of soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. The money comes from taxpayers, not the manufacturers of the chemicals responsible for the contamination.

However, since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while we urge Congress to pass bills offering relief to farmers harmed with PFAS, we must also do all that we can to prevent further contamination.

>>Tell your U.S. Senators and Representative to cosponsor the Relief for Farmers Hit with PFAS Act. If they are already cosponsors, thank them. Tell EPA to stop the spread of legacy chemicals.

Letter to EPA

The Maine Congressional delegation — Senators Collins (R) and Angus King (I), and Representatives Chellie Pingree (D) and Jared Golden (D), along with New Hampshire Senator Jeanne Shaheen (D), have introduced a bipartisan bill — the Relief for Farmers Hit with PFAS Act — to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. The bills are the identical S. 5070 and H.R. 9186, both titled “Relief for Farmers Hit with PFAS Act.”

As you know, PFAS chemicals, also known as “forever chemicals,” are legacy contaminants whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

As indicated by the title of these bills, farmers have often been “hit with” legacy contaminants through no fault of their own, and these bills will provide funding to help farmers address the aftermath of the contamination, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms.

However, since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while we urge Congress to pass bills offering relief to farmers harmed by PFAS, EPA has a duty to do all that it can to prevent further contamination.

I urge you to cancel the registrations of persistent toxic pesticides as well as those not shown to be free of endocrine-disrupting activity.

Thank you.

Letter to Sponsoring U.S. Senators and Members of the House of Representatives

Thank you for cosponsoring the bipartisan bill, the Relief for Farmers Hit with PFAS Act, to help farmers who have been adversely by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill authorize $500 million over FY 2023-2027 to the U.S. Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. I should note that this money, if appropriated, comes from taxpayers, not the manufacturers responsible for the contamination.

However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

I urge you to use your oversight of EPA to ensure that persistent toxic pesticides and other chemicals are no longer allowed to be released into the environment. Ensure that EPA carries out its responsibility to ensure that the pesticides it registers are not endocrine disruptors.

Thank you.

Letter to U.S. Senators

I am writing to urge you to cosponsor S. 5070, the Relief for Farmers Hit with PFAS Act, to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill will authorize $500 million over FY 2023-2027 to the U.S. Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. I should note that this money, if appropriated, comes from taxpayers, not the manufacturers responsible for the contamination.

PFAS chemicals, also known as “forever chemicals,” are legacy contaminants whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

Since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while I urge you to pass this bill offering relief to farmers harmed by PFAS, we must also do all that we can to prevent further contamination.

I urge you to use your oversight of EPA to ensure that persistent toxic pesticides and other chemicals are no longer allowed to be released into the environment. Ensure that EPA carries out its responsibility to ensure that the pesticides it registers are not endocrine disruptors.

Thank you.

Letter to Members of the U.S. House of Representatives

I am writing to urge you to cosponsor H.R. 9186, the Relief for Farmers Hit with PFAS Act, to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill will authorize $500 million over FY 2023-2027 to the U.S. Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. I should note that this money, if appropriated, comes from taxpayers, not the manufacturers responsible for the contamination.

PFAS chemicals, also known as “forever chemicals,” are legacy contaminants whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

Since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while I urge you to pass this bill offering relief to farmers harmed by PFAS, we must also do all that we can to prevent further contamination.

I urge you to use your oversight of EPA to ensure that persistent toxic pesticides and other chemicals are no longer allowed to be released into the environment. Ensure that EPA carries out its responsibility to ensure that the pesticides it registers are not endocrine disruptors.

Thank you.

11/01/2022 — Tell EPA That Clean Air, NOT “Sanitized” Air, Protects Against Disease

Just as the Environmental Protection Agency (EPA) issued a request for information on improving indoor air quality, it approved 32 varieties of a new “air sanitizer” to kill bacteria and viruses in the air. These products contain 14% dipropylene glycol and 86% secret (“other”) ingredients, including fragrances.

Tell EPA that clean air, NOT “sanitized” air, protects against disease.

Through its approval of such sanitizers, EPA promotes the false reasoning that a chemical that kills a pathogen necessarily protects health. Although disinfectants and sanitizers kill viruses, bacteria, and other microbes, they can also negatively affect the immune system, thus reducing resistance to disease. People who have a preexisting condition or are of advanced age, who may have a weakened immune or respiratory system, are more vulnerable to the effects of the virus. Children are at elevated risk from exposure. When managing viral and bacterial infections, chemicals that exacerbate the risk to vulnerable individuals are of serious concern.

EPA opened a 60-day public comment period “to solicit information and recommendations from a broad array of individuals and organizations with knowledge and expertise relating to the built environment and health, indoor air quality, epidemiology, disease transmission, social sciences and other disciplines.” EPA’s request for information says it is “seeking input . . . about actions, strategies, tools and approaches that support ventilation, filtration and air cleaning improvements, and other actions that would promote sustained improvements in indoor air quality in the nation’s building stock to help mitigate disease transmission.” A new, airborne pesticide for indoor use is the opposite of what is needed.

Although dipropylene glycol, the active ingredient in the newly-approved air sanitizers, is considered less toxic than other chemicals, it may cause more problems when inhaled. These products contain 86% secret ingredients, including fragrances. Fragrances are known to trigger adverse respiratory effects.

Efficacy and creating a false sense of security is also of serious concern. The label directions instruct users to spray the chemical for 30 seconds and leave the room empty and closed-up for 12 minutes. Given that airborne viruses are being constantly introduced and reintroduced into public spaces, such as stores, schools, restaurants, and public spaces, the virus may continue to be transmitted through indoor air unless there is adequate ventilation and filtration. So, in this public context, a sanitizer application to an indoor space only protects against the target virus as long as the building is not used by the public.

EPA should focus its efforts on methods of providing increased ventilation without introducing additional chemicals into the indoor atmosphere. Ventilation with clean fresh air has been shown to reduce exposure to airborne viruses.

This action requires you to post a comment to Regulations.gov. Follow this link and type or paste in a comment. A suggested comment can be found below.

Suggested comment to EPA

I am concerned that EPA’s request for information on improving indoor air quality coincides with the approval of 32 varieties of a new pesticide (“air sanitizer”) to kill bacteria and viruses in the air. These products contain 14% dipropylene glycol and 86% secret (“other”) ingredients, including fragrances.

Through its approval of such sanitizers, EPA promotes the false reasoning that a chemical that kills a pathogen necessarily protects health. Although disinfectants and sanitizers kill viruses, bacteria, and other microbes, they can also negatively affect the immune system, thus reducing resistance to disease. People who have a preexisting condition or are of advanced age, who may have a weakened immune or respiratory system, are more vulnerable to the effects of the virus. When managing viral and bacterial infections, chemicals that exacerbate the risk to vulnerable individuals are of serious concern.

EPA seeks “input . . . about actions, strategies, tools and approaches that support ventilation, filtration and air cleaning improvements, and other actions that would promote sustained improvements in indoor air quality in the nation’s building stock to help mitigate disease transmission.” A new, airborne pesticide for indoor use is the opposite of what is needed.

Although dipropylene glycol, the active ingredient in the newly approved air sanitizers, is considered less toxic than other chemicals, it may cause more problems when inhaled. These products contain 86% secret ingredients, including fragrances. Fragrances are known to trigger adverse respiratory effects.

Efficacy and creating a false sense of security is also of serious concern. The label directions instruct users to spray the chemical for 30 seconds and leave the room empty and closed-up for 12 minutes. Given that airborne viruses are being constantly introduced and reintroduced into public spaces, such as stores, schools, restaurants, and public spaces, the virus may continue to be transmitted through indoor air unless there is adequate ventilation and filtration. So, in this public context, a sanitizer application to an indoor space only protects against the target virus as long as the building is not used by the public.

EPA should not approve “air sanitizers” with the false hope of controlling bacteria and viruses in the air. EPA should focus its efforts on methods of providing increased ventilation without introducing additional chemicals into the indoor atmosphere. Ventilation with clean fresh air has been shown to reduce exposure to airborne viruses.

10/21/2022 — Turn Breast Cancer Awareness into Breast Cancer Prevention

We need prevention of the causes of breast cancer, not just awareness. In 1985, Imperial Chemical Industries and the American Cancer Society declared October “Breast Cancer Awareness Month” as part of a campaign to promote mammograms for the early detection of breast cancer. Unfortunately, most of us are all too aware of breast cancer. Detection and treatment of cancers do not solve the problem. 

>>Tell EPA to evaluate and ban endocrine-disrupting pesticides, and make organic food production and land management the standard that legally establishes toxic pesticide use as “unreasonable.”

Next to skin cancer, breast cancer is the most common cancer among women, causing the second most cancer-related deaths in the United States. Genetic factors only play a minor role in breast cancer incidence, while exposure to external environmental factors such as pesticides plays a more notable role. For breast cancer, one in eight women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how environmental exposure to chemicals like pesticides can drive breast cancer development. Several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with breast cancer risk. 

Most types of breast cancers are hormonally responsive and are thus affected by estrogen or progesterone or other chemicals that mimic them, known as endocrine disruptors. Endocrine-disrupting chemicals include pesticides like DDT, organophosphate (OP) insecticides, glyphosate, neonicotinoids, and synthetic pyrethroids, as well as dioxins, PCBs, various solvents, and many other chemicals.

We must mitigate the multigenerational impacts pesticides pose on human and animal health. Adopting regenerative organic practices and using least-toxic pest control can eliminate harmful exposure to pesticides. Solutions like buying, growing, and supporting organic can also help eliminate the extensive use of pesticides in the environment.

In addition to these personal actions, public policy must be changed. 

>>Tell EPA to evaluate and ban endocrine-disrupting pesticides, and make organic food production and land management the standard that legally establishes toxic pesticide use as “unreasonable.”

Letter to Congress

In 1985, Imperial Chemical Industries and the American Cancer Society declared October “Breast Cancer Awareness Month” as part of a campaign to promote mammograms for the early detection of breast cancer. Unfortunately, most of us are all too aware of breast cancer. Detection and treatment of cancers do not solve the problem. We need prevention of the causes of breast cancer, not just awareness.

Next to skin cancer, breast cancer is the most common cancer among women, causing the second most cancer-related deaths in the United States. Genetic factors only play a minor role in breast cancer incidence, while exposure to external environmental factors such as pesticides play a more notable role. For breast cancer, one in eight women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how environmental exposure to chemicals like pesticides can drive breast cancer development. Several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with breast cancer risk.

Most types of breast cancers are hormonally responsive and are thus affected by estrogen or progesterone or other chemicals that mimic them, known as endocrine disruptors. Endocrine-disrupting chemicals include pesticides like DDT, organophosphate (OP) insecticides, glyphosate, neonicotinoids, and synthetic pyrethroids, as well as dioxins, PCBs, various solvents, and many other chemicals.

EPA’s examination of the endocrine-disrupting effects of pesticides has stalled. If we are to take action to prevent breast cancer, we must eliminate those pesticides. Organic production and land management need to become the standard against which EPA measures all pesticides.

Please use your oversight responsibility to ensure that EPA takes steps to prevent breast cancer.

Thank you.

Letter to EPA

In 1985, Imperial Chemical Industries and the American Cancer Society declared October “Breast Cancer Awareness Month” as part of a campaign to promote mammograms for the early detection of breast cancer. Unfortunately, most of us are all too aware of breast cancer. Detection and treatment of cancers do not solve the problem. We need prevention of the causes of breast cancer, not just awareness.

Next to skin cancer, breast cancer is the most common cancer among women, causing the second most cancer-related deaths in the United States. Genetic factors only play a minor role in breast cancer incidence, while exposure to external environmental factors such as pesticides plays a more notable role. For breast cancer, one in eight women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how environmental exposure to chemicals like pesticides can drive breast cancer development. Several studies and reports, including U.S. Environmental Protection Agency data, identify hundreds of chemicals as influential factors associated with breast cancer risk.

Most types of breast cancers are hormonally responsive and are thus affected by estrogen or progesterone or other chemicals that mimic them, known as endocrine disruptors. Endocrine-disrupting chemicals include pesticides like DDT, organophosphate (OP) insecticides, glyphosate, neonicotinoids, and synthetic pyrethroids, as well as dioxins, PCBs, various solvents, and many other chemicals.

EPA’s examination of the endocrine-disrupting effects of pesticides has stalled. If we are to take action to prevent breast cancer, we must eliminate those pesticides. Organic production and land management need to become the standard against which EPA measures all pesticides.

Thank you.

10/17/2022 — Eliminate Systemic Racism and Environmental Injustice in Pesticide Policy

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country's pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic to ensure sustenance for the nation and world. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

While we are encouraged to see the formation of EPA's new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty.

>>Tell EPA, Congress, and your Governor (Mayor in DC) to protect farmworkers from pesticides. Choose organic.

The acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. 

EPA's Worker Protection Standards Are Inadequate to Protect Farmworkers
Worker protection standards are set by EPA under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). The original standard was developed after field hearings in the 1970s in which EPA heard from growers, but not farmworkers. After several tries, the WPS still do 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.

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 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.

Congress Should Improve Farmworker Protection in the Law
By leaving farmworker protection entirely under the pesticide law, Congress removed it from the oversight of the Occupational Health and Safety Administration (OSHA). Congress should restore partial jurisdiction over the regulation of pesticide-related occupational hazards to OSHA to ensure better coordination between OSHA and EPA. Simultaneously, Congress should eliminate the small farms exemption from the Occupational Safety and Health Act. Congress should also increase OSHA and EPA appropriations to improve the agencies' capacity to inspect more of the worksites they regulate, particularly given the Biden Administration's clear focus on racial equity and justice.

Protections that are present in other environmental statutes are missing in FIFRA, and Congress should correct this oversight. It should appropriate funds for more monitoring and enforcement.

Don't Forget to Choose Organic Food
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.

>>Tell EPA, Congress, and your Governor (Mayor in DC) to protect farmworkers from pesticides. Choose organic.

Letter to Congress

 

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, for ensuring that we are kept well-fed. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

This acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. By leaving farmworker protection entirely under the pesticide law, Congress removed it from the oversight of the Occupational Health and Safety Administration (OSHA). Congress should restore partial jurisdiction over the regulation of pesticide-related occupational hazards to OSHA to ensure better coordination between OSHA and EPA. Simultaneously, Congress should eliminate the small farms exemption from the OSH Act. Congress should also increase OSHA and EPA appropriations to improve the agencies’ capacity to inspect more of the worksites they regulate, particularly given the Biden Administration’s clear focus on racial equity and justice.

Protections that are present in other environmental statutes are missing in FIFRA, and Congress should correct this oversight. This could include consideration of a private right of action, a greater ability for EPA to address states’ nonattainment of minimum standards, and other measures to strengthen states’ incentives to remain in compliance.

While I am encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty.

Congress should grant EPA greater authority to respond to states failing to meet enforcement goals, including the authority to impose sanctions related to the agriculture industry. Congress can look to other environmental statutes, such as the CAA, where it has given EPA the authority to impose sanctions for noncompliance in the interest of public health.

Congress should appropriate more funds to NIOSH’s SENSOR program to support states in consistently reporting data on acute pesticide-related illness and to expand the number of states in the program.

Thank you for taking action to protect farmworkers.

Letter to EPA

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, to feed us. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by EPA, while study after study documents the disproportionate level of illness among farmworkers.

This acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. While I am encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty. This combination amounts to systemic racism.
EPA’s Worker Protection Standards are inadequate to protect farmworkers. After several tries, the WPS still do 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.

In the past, EPA has admitted that even with maximum feasible personal protective equipment (PPE) and engineering controls, risks to workers still exceed EPA’s levels of concern. A 2008 study analyzing poisonings of pesticide workers 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. 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 report (2012), face even greater health risks compared to adults when exposed to pesticides.

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. Penalties for violations of the WPS should be increased to reflect the grave harm caused to human health and safety. Higher penalties are crucial to create a deterrent effect.

Thank you.

Letter to Governors

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, for ensuring that we are kept well-fed. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

This acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. While I am encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty.

As Governor of our state, please commit to reducing the influence of industry over pesticide regulation. At a minimum, prohibit enforcement officials from being involved in sale, manufacture, or distribution of pesticides, as California has done.

Please implement a neighbor notification system to reduce the incidence of exposure caused by pesticide drift.

Mandatory reporting requirements, both for pesticide use and for incidents of pesticide exposure, would offer protection to both farmworkers and the general public. The state department of health should more authority to conduct inspections and investigations of suspected pesticide exposure incidents, independent of the state’s designated lead agency.

Penalties for violations of the WPS (or state-equivalent regulations) should be increased to reflect the grave harm caused to human health and safety. Higher penalties are crucial to create a deterrent effect.

Thank you.

Letter to DC Mayor

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, for ensuring that we are kept well-fed. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

This acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. While I am encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty.

As Mayor of our city, please commit to reducing the influence of industry over pesticide regulation. At a minimum, prohibit enforcement officials from being involved in sale, manufacture, or distribution of pesticides, as California has done.

Please implement a neighbor notification system to reduce the incidence of exposure caused by pesticide drift.

Mandatory reporting requirements, both for pesticide use and for incidents of pesticide exposure, would offer protection to both farmworkers and the general public. The city department of health should more authority to conduct inspections and investigations of suspected pesticide exposure incidents, independent of the state’s designated lead agency.

Penalties for violations of the WPS (or state-equivalent regulations) should be increased to reflect the grave harm caused to human health and safety. Higher penalties are crucial to create a deterrent effect.

Thank you.

10/11/2022 — Organic Matters: Don’t Let USDA Undermine It

Without continuously improving organic standards and certification, advocates maintain that there is no holistic way to combat the existential crises associated with petroleum-based pesticides and fertilizers—the multiple and growing health threats, biodiversity collapse, and the climate emergency. Have you been confused at the egg case in your grocery store where egg carton labels proclaim “cage-free,” “free-range,” and “pasture raised” organic eggs? The U.S. Department of Agriculture (USDA) is accepting comments on proposed regulations to protect the welfare of livestock and poultry on organic farms. The Organic Livestock and Poultry Standard (OLPS) is a slightly revised version of the Organic Livestock and Poultry Practices (OLPP) rule, which was promulgated after many delays in January 2017, then withdrew the rule before it became effective.

USDA acknowledges that a failure to act on OLPS undermines the organic market, saying “a market failure exists in the organic label,” and the intent of new standard is to “clarify and ensure consistent application of the USDA organic standards.” The inconsistent application of organic standards by certifiers has resulted in a plethora of add-on labels that ensure that organic livestock and poultry production meet the expectations of organic consumers.

However, the proposed OLPS lacks the specificity to meet the stated intention and if implemented, will allow the inconsistencies among certifiers to continue. In order to protect the meaning of the organic label, a few changes are needed. Since these changes are consistent with the stated intentions of USDA, they should not cause delay in implementing the OLPS. Please tell USDA to make the changes listed below.

This action requires a submission at Regulations.gov. Members of the public can copy and paste from Beyond Pesticides’ suggested comment below.

Suggested Public Comment

The proposed OLPS lacks the specificity to meet USDA’s stated intention and if implemented, will the inconsistencies among organic certifiers to continue. In order to protect the meaning of the organic label, a few changes are needed. Since these changes are consistent with the stated intentions of USDA, they should not cause delay in implementing the OLPS. Please make the following changes.

*Do not allow current producers to continue practices inconsistent with the proposed rule for 5-15 years. Three years is adequate for existing operations to provide the outdoor access required in the regulation.

*Define “outdoors” to be soil-based with maximal vegetative cover appropriate for the season, climate, geography, species of livestock, and stage of production.

*Define “access to the outdoors” for poultry to be “having sufficient exit areas that are appropriately distributed to ensure that all birds have ready access to outdoors no more than 10 feet from the house; exit areas for birds to get outside must be designed so that more than one bird at a time can get through the opening and to have a combined length of at least 12 ft per 1,000 ft2 area of the house available to the birds.”

*Do not permit estimates of stocking rates to be based on expected mortality.

*Require that artificial light supplement rather than substitute for natural light. Adopt OLPP provision that required an inspector to be able to read and write with lights turned off on a sunny day. Do not allow any birds to be raised in darkness.

*Remove the provision that allows confinement in inclement weather, including when air temperatures are under 40 degrees F or above 90 degrees F. This loophole could allow confinement for as much as half the year. The provision for confinement in “conditions under which the health, safety, or well-being of the animal could be jeopardized” is sufficient and puts the onus on the producer to demonstrate ill effects of outdoor access, and birds can judge whether they want to go outside in “inclement” weather.

*Monitoring for ammonia levels in poultry houses must be performed frequently—automated continuous monitoring is possible in large houses—and must measure ammonia at the height at which the birds are breathing.

To compromise on the above foundational issues is to undermine public trust in the organic label and the growth of the organic sector. A failure to protect public trust in the USDA organic label for livestock and poultry is to a failure for all of organic and threatens the progress being made in the organic marketplace.

Thank you.

10/03/2022 — Two Actions for Fall: Prime Your Lawns and Landscapes and...

Fall is the best time to start transitioning lawns to organic. The key to a healthy lawn is healthy soil and good mowing, watering, and fertilizing practices. Healthy soil contains high organic content and is teeming with biological life. Healthy soil supports the development of healthy grass that is naturally resistant to weeds and pests. In a healthy, fertile and well-maintained lawn, diseases and pest problems are rare.

>>TAKE ACTION: In addition to priming your own lawns and landscapes, tell your mayor or county executive to transition your public parks and lands to organic management practices!

Lawns that are currently chemically-dependent may require more resources to restore the biological life. But in the long-term, an organic lawn uses fewer materials, such as water and fertilizers, and requires less labor for mowing and maintenance. More importantly, organic lawns will be safe for children, pets, and the local drinking water supply. Our treatment of lawns and landscapes is directly related to the health of our environment! Learn about the importance of maintaining a delicate balance from the Beyond Pesticides' factsheet.

Get Started Now
Mow High Until the Season Ends – Bad mowing practices cause more problems than any other cultural practice. Mowing with a dull blade makes the turf susceptible to disease and mowing too close invites sunlight in for weeds to take hold.

Keep your blades sharp or ask your service provider to sharpen their blades frequently. For the last and first mowing, mow down to 2 inches to prevent fungal problems. For the rest of the year, keep it at 3-3.5 inches to shade out weeds and foster deep, drought-resistant roots.

Aerate – Compaction is an invitation for weeds. If a lawn is hard, compacted, and full of weeds or bare spots, aerate to help air, water, and fertilizer to enter. If you cannot stick a screwdriver easily into the soil, it is too compacted. Getting an aerator on the turf will be especially helpful. Once you have an established, healthy lawn, worms and birds pecking at your soil will aerate it for free!
 
Fertilize, but go easy! – Fertilizing in early fall ensures good growth and root development for your grass. Nitrogen, the most abundant nutrient in lawn fertilizers promotes color and growth. Adding too much nitrogen, or quick release synthetic fertilizers (which are not part of an organic program), will result in quicker growth and the need for more mowing. Too much nitrogen can also weaken the grass, alter the pH, and promote disease, insect, and thatch build-up. If applied too late, nutrients can leach directly into nearby surface waters. Be aware of local phosphorus or nitrogen loading concerns.

Grass clippings contain 58% of the nitrogen added from fertilizers, improve soil conditions, suppress disease, and reduce thatch and crabgrass. So, leave the clippings on the lawn. A mulching mower to leave the leaves on the lawn too – a great alternative to raking.

Compost is an ideal soil amendment, adding the much-needed organic content to the soil and suppressing many turf pathogens. In the fall and spring, preferably after aerating, spread ¼ inch layer of compost over your lawn. Compost tea and worm castings are also great additions. Learn more from Beyond Pesticides' factsheet, Compost is Key to Successful Plant Management

Analyzing soil is highly recommended to determine specific soil needs. Contact the university extension service to find out how to take and send in a soil sample. In addition to nutrients and pH, ask for organic content analysis, and request organic care recommendations. Ideal pH should be between 6.5-7.0, and organic content should be 5% or higher. Soil test results will ensure that only the materials that are needed are applied. Read Maintaining a Delicate Balance: Eliminating phosphorus contamination with organic soil management for in-depth information on the problem of fertilizer contamination, and how to apply fertilizer properly. 

Overseed With the Right Grass Seed – Once again, fall is the best time to seed a lawn. Grass varieties differ enormously in their resistance to certain pests, tolerance to climatic conditions, growth habit and appearance. Endophytic grass seed provides natural protection against some insects and fungal disease – major benefits for managing a lawn organically. The local nursery will know the best seed for the area. Check to see the weed content of the grass seed and that there are no pesticide coatings. 

Develop Your Tolerance – Many plants that are considered weeds in a lawn have beneficial qualities. Learn to read your “weeds” for what they indicate about your soil conditions. Monocrops do not grow in nature and diversity is a good thing. See more information on our Least Toxic Control of Weeds factsheet

For instance, clover (considered a typical weed) is found in soil with low nitrogen levels, compaction issues, and drought stress – conditions that can be alleviated with the above recommendations. However, clover is a beneficial plant that takes free nitrogen from the atmosphere and distributes it to the grass, which helps it grow. Clover roots are extensive and extremely drought resistant, providing significant resources to soil organisms, and staying green long after turf goes naturally dormant. 

There is lots more at Lawns and Landscapes on the Beyond Pesticides' website. For more information about becoming an advocate for organic parks, see Parks for a Sustainable Future and Tools for Change.

>>Send the municipal parks department links to our factsheets on Establishing New Lawns and Landscapes and Maintaining Sustainable Lawns and Landscapes. Or print them out and take them to the parks manager. And take action now to send them the following letter to your mayor or county executives.

Letter to Mayors and County Executives

I’m reminding you with this note that Fall is the time to transition our public parks and lands to organic management practices. The key to a healthy lawn is healthy soil and good mowing, watering, and fertilizing practices. Healthy soil contains high organic content and is teeming with biological life. It supports the development of healthy grass that is naturally resistant to weeds and pests. In a healthy, fertile, and well-maintained lawn, diseases and pest problems are rare.

In the long-term, an organic lawn uses fewer materials, such as water and fertilizers, and requires less labor for mowing and maintenance. More importantly, the lawn will be safe for children, pets, and our local drinking water supply.

These important steps in the Fall will give lawns a good start:

  • Mow high until the season ends. Poor mowing practices cause more problems than any other cultural practice. Mow with sharp blades. For the last and first mowing, mow down to 2 inches to prevent fungal problems. For the rest of the year, keep it at 3-3.5 inches to shade out weeds and foster deep, drought-resistant roots.
  • Aerate to prevent compaction, an invitation for weeds. Aeration helps air, water, and fertilizer to enter.
  • Fertilize, but go easy! Fertilizing in early fall ensures good growth and root development for your grass. Nitrogen, the most abundant nutrient in lawn fertilizers promotes color and growth, but too much nitrogen or synthetic fertilizers will result in quicker growth and the need for more mowing. Too much nitrogen can also weaken the grass, alter the pH, and promote disease, insect, and thatch build-up. If applied too late, nutrients can leach directly into nearby surface waters. Be aware of local phosphorus or nitrogen loading concerns.
  • Grass clippings contain 58% of the nitrogen added from fertilizers, improve soil conditions, suppress disease, and reduce thatch and crabgrass. So, leave the clippings on the lawn. A mulching mower can turn both clippings and leaves into valuable organic matter, while eliminating the need for raking.
  • Compost is an ideal soil amendment, adding the much-needed organic content to your soil and suppressing many turf pathogens. In the fall and spring, preferably after aerating, spread ¼ inch layer of compost over your lawn. Compost tea and worm castings are also great additions.
  • Soil analysis to determine specific soil needs is highly recommended. The Extension Service has information about how to take and send in a soil sample. In addition to nutrients and pH, the analysis should include organic content organic care recommendations. Ideal pH should be between 6.5-7.0, and organic content should be 5% or higher.
  • Overseed with the right grass seed. Fall is the best time for seeding a lawn. Grass varieties differ enormously in their resistance to certain pests, tolerance to climatic conditions, growth habit, and appearance. Endophytic grass seed provides protection against some insects and fungal diseases—major benefits for managing a lawn organically. Check to see the weed content of the grass seed and that there are no pesticide coatings.
  • Develop weed tolerance. Many plants that are considered weeds in a lawn have beneficial qualities. For instance, clover, considered a typical weed, is found in soil with low nitrogen levels, compaction issues, and drought stress—conditions that can be alleviated with the above recommendations. However, clover also takes free nitrogen from the atmosphere and distributes it to the grass, which helps it grow. Clover roots are extensive and extremely drought resistant, providing significant resources to soil organisms, and staying green long after turf goes naturally dormant.

It is time to go organic for community health, sustainable biodiversity, and a livable climate.

09/23/2022 — Last Chance This Fall to Tell the NOSB To Uphold Organic Integrity

09/19/2022 — Kids Must Be Safe from Toxic Pesticides at School!

Our schools have been deeply concerned about providing safety from COVID-19. Let's not forget the toxic pesticides to which students, teachers, and other staff may be exposed as we go back to school this year. 

>>Tell your Governor to ensure that children, teachers, and staff in all schools throughout your state are protected from toxic chemicals. If you are a DC resident, tell Mayor Bowser.

Children face unique hazards from pesticide exposure. In the food they eat and the air they breathe, children take in greater amounts of pesticides (relative to their body weight) than adults, and their developing organ systems are typically more sensitive to toxic exposures. Children also come into closer contact with chemicals than adults, as a result of crawling behavior and hand to mouth contact.

The American Academy of Pediatrics, in a landmark report on children and pesticide use, wrote, “Children encounter pesticides daily and have unique susceptibilities to their potential toxicity. Acute poisoning risks are clear, and understanding of chronic health implications from both acute and chronic exposure is emerging. Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.” Infants and toddlers in childcare are at risk of developmental delays.

The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child's neurological, respiratory, immune, and endocrine system, 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. See the scientific references on why Children and Pesticides Don't Mix.

As the science on the dangers that pesticides pose to public health continue to mount, school administrators, staff, and parents are working to change practices for the better. More and more school buildings and grounds are employing ecological pest management principles that focus on prevention, rather than the regular use of toxic pesticides.

Custodial staff and pest managers can ManageSafe by following simple steps. These include properly identifying pests, setting action or damage thresholds, monitoring and recordkeeping, and the use of structural, mechanical, cultural, and biological controls before using even least-toxic pesticides or organic compatible products. These principles can be applied to both indoor and outdoor environments, with ecological and organic methods.

In the indoor environment, an ecological pest management approach focuses on fostering a culture of pest prevention among both students and staff. It's nothing special – just emphasize building good habits, such as cleaning up after eating, storing food in sealed containers, not leaving food or water out, and other methods that eliminate a pest's access to food, water, or shelter.

In the outdoor environment, the organic principles apply with a focus is fostering healthy soils. School groundskeepers and landscapers play a pivotal role in this process. Rather than reaching for a chemical when a weed appears, the organic approach cultivates healthy soil biology through practices that work with, rather than against nature. We can help improve turfgrass resilience to pest and weed intrusions by caring for building the soil biological life and organic matter. Combine the use of natural soil supplements with cultural practices like mowing high, aeration, and overseeding. All of this leads to long-term cost savings from eliminating pesticides and fertilizers that are replaced by natural cycling of nutrients, and reduced watering because of increased soil tilth and water retention. In sum, these practices will save schools money and prevent children's exposure to toxic pesticides while they focus on learning.

>>Tell your Governor to ensure that children, teachers, and staff in all schools throughout your state are protected from toxic chemicals. If you are a DC resident, tell Mayor Bowser.

Letter to Governors and Mayor Bowser

I am writing to ask you to ensure that our children are safe from toxic pesticides as they go back to school. Our schools have been deeply concerned about providing safety from COVID-19. Let’s not forget the toxic pesticides to which students, teachers, and other staff may be exposed. Please ask the Superintendent of Schools and your Commissioner of Education to eliminate pesticides from our schools.

Children face unique hazards from pesticide exposure. In the food they eat and the air they breathe, children take in greater amounts of pesticides (relative to their body weight) than adults, and their developing organ systems are typically more sensitive to toxic exposures. Children also come into closer contact with chemicals than adults, as a result of crawling behavior and hand to mouth contact.

The American Academy of Pediatrics, in a landmark report on children and pesticide use, wrote, “Children encounter pesticides daily and have unique susceptibilities to their potential toxicity. Acute poisoning risks are clear, and understanding of chronic health implications from both acute and chronic exposure is emerging. Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.”

The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child's neurological, respiratory, immune, and endocrine system, 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.

As the science on the dangers that pesticides pose to public health continue to mount, school administrators, staff, and parents are working to change practices for the better. More and more school buildings and grounds are employing ecological pest management principles that focus on prevention, rather than the regular use of toxic pesticides.

Custodial staff and pest managers can ManageSafe by following simple steps. These include properly identifying pests, setting action or damage thresholds, monitoring and recordkeeping, and the use of structural, mechanical, cultural, and biological controls before using even least-toxic pesticides or organic compatible products. These principles can be applied to both indoor and outdoor environments, with ecological and organic methods.

In the indoor environment, an ecological pest management approach focuses on fostering a culture of pest prevention among both students and staff. It’s nothing special – just emphasize building good habits, such as cleaning up after eating, storing food in sealed containers, not leaving food or water out, and other methods that eliminate a pest’s access to food, water, or shelter.

In the outdoor environment, the organic principles apply with a focus is fostering healthy soils. School groundskeepers and landscapers play a pivotal role in this process. Rather than reaching for a chemical when a weed appears, the organic approach cultivates healthy soil biology through practices that work with, rather than against nature. We can help improve turfgrass resilience to pest and weed intrusions by caring for building the soil biological life and organic matter. Combine the use of natural soil supplements with cultural practices like mowing high, aeration, and overseeding. All of this leads to long-term cost savings from eliminating pesticides and fertilizers that are replaced by natural cycling of nutrients, and reduced watering because of increased soil tilth and water retention. In sum, these practices will save schools money and prevent children’s exposure to toxic pesticides while they focus on learning.

Please tell the state school superintendent to eliminate pesticides. Further information is available at: https://www.beyondpesticides.org/programs/children-and-schools/hazards-of-pesticides.

Thank you.

09/12/2022 — Organic Must Lead the Way!

Take Action: Organic Must Lead the Way! 
Comments are due 11:59 pm EDT September 29

The National Organic Standards Board (NOSB) is receiving written comments from the public through September. This precedes the upcoming public comment webinar on October 18 and 20 and deliberative hearing October 25-27—concerning how organic food is produced. Sign up to speak at the webinar by September 29. Written comments must be submitted through Regulations.gov by 11:59 pm EDT September 29. Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October.

The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health.

The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Fall 2022 issues page. Here are some high priority issues for us:

Organic Agriculture is Climate-Smart Agriculture. The NOSB draft letter to Secretary of Agriculture Vilsack is an excellent primer on how organic agriculture responds to the climate emergency. However, the letter should stress the need for USDA to promote conversion to organic farming. More important to addressing the climate crisis than the questions posed by NOP are questions concerning how USDA programs can assist organic producers and those seeking to convert to organic. The draft letter addresses these as well. It also points out the resiliency of organic agriculture: “Organic is the solution to mitigating climate change and responding to it.” In view of the climate benefits of organic and the incentives inherent in organic marketing, the real question is whether USDA will abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry in favor of whole-hearted support for organic agriculture—because despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should make adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs.

Biodegradable Biobased (Bioplastic) Mulch Film (BBMF) is under consideration for sunset this year. This is part of a larger issue of the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles to which it degrades—on human health and the environment. BBMF should not be relisted. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic production and handling—including packaging.

The NOSB should use the sunset process to eliminate non-organic ingredients in processed organic foods. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that are allowed to be used as ingredients as part of the 5% of organic processed foods that is not required to be organic. Materials should not remain on §205.606 if they can be supplied organically, and anything that can be grown can be grown organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” Two materials on §205.606 are up for sunset this year—pectin and casings. Both are made from agricultural products that can be supplied organically and thus should be sunsetted.

>>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.)

 

09/06/2022 — Take Two Actions this Week!

Beyond Pesticides is holding its National Forum Series—Health, Biodiversity, and Climate: A Path for a Livable Future, beginning on September 15. The National Pesticide Forum has undergone tremendous change in the format, giving participants easier access to timely, bite-sized, and provocative learning experiences and empowering action to fuel change. This year, it focuses on meeting the health, biodiversity, and climate crises with a path for a livable future. We examine both the existential problems associated with current public health and environmental crises and chart a course for a future that solves these urgent problems. The first seminar launches September 15, the second on October 12, and a third will be announced for November. Register for free!
 
The Forum will address both the science that defines the problems associated with the threats and the solutions, some of which are contained in legislation such as the Zero Food Waste Act and the Compost Act. Two ways of helping to reduce agricultural carbon emissions and reduce hunger are addressed in these two bills—by maximizing the amount of food that is eaten and ensuring that food waste is composted to build soil health instead of generating methane in a landfill.

Congresswoman Julia Brownley (D-CA), Congresswoman Ann McLane Kuster (D-NH), and Congresswoman Chellie Pingree (D-ME) introduced two bills, the Zero Food Waste Act (H.R. 4444) and the Cultivating Organic Matter through the Promotion of Sustainable Techniques (COMPOST) Act (H.R. 4443), to reduce the amount of food wasted in the U.S. and to redirect food waste to composting projects. Senator Cory Booker (D-NJ) introduced companion legislation, Zero Food Waste Act (S.2389) and Compost Act (S.2388), in the U.S. Senate. 
 
>>Ask your U.S. Representative and Senators to sponsor the Zero Food Waste and Compost Acts legislation and, if you are represented by a sponsor of the legislation, thank them for their leadership.

About the National Forum Series

Seminar 1 > HEALTH > September 15, 1-2:30 pm
The Problem: We start the Forum Series with a medical doctor who has both treated and studied the effects of toxic chemical exposure, with a focus on pesticides, throughout our daily lives. Claudia Miller, M.D. provides us with a framework for understanding the dire health implications of the current dependency on pesticides and toxic chemicals and the failure of the regulatory system to fully evaluate and control for the range of adverse effects and complexity of their interactions.  

The Solution: The solution is found in a transition to management practices that are no longer dependent on toxic inputs and respect the value of nature and works in partnership with the diversity that it offers. This discussion will be led by an indigenous farmer, Kaipo Kekona, who is working in Hawai'i to regenerate and sustain traditional farming production on former sugarcane land. Learn more.

Seminar 2 > BIODIVERSITY > October 12, 1:00-2:30 pm 
The Problem: Life depends on biodiversity. According to the Global Assessment of Biodiversity and Ecosystem Services, produced by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES),  “Harmful economic incentives and policies associated with unsustainable practices of fisheries, aquaculture, agriculture (including fertilizer and pesticide use), livestock, forestry, mining and energy (including fossil fuels and biofuels) are often associated with land/sea-use change and overexploitation of natural resources, as well as inefficient production and waste management.” In this eye-opening session, you'll hear from Lucas Alejandro Garibaldi, PhD, Professor and Director, Institute for Research in Natural Resources, Agroecology and Rural Development, Universidad Nacional de Rio Negro, Argentina, and member of the Secretariat for IPBES and a contributor to its landmark IPBES report

The Solution: The IPBES report endorses the transition away from pesticide-laden agricultural practices and toward sustainable agriculture to meet the challenges of protecting and enhancing biodiversity. Organic land management systems that eliminate fossil fuel-based toxic pesticides and fertilizers makes a substantial contribution in addressing the dire threat to biodiversity. You'll hear directly from Bob Quinn, PhD, an organic farmer and miller with Montana Flour and Grains in Big Sandy, Montana, who will share his personal insights on the value of organic food production and land management. See the full program.

>>Ask your U.S. Representative and Senators to sponsor the Zero Food Waste and Compost Acts legislation and, if you are represented by a sponsor of the legislation, thank them for their leadership. 

Letter to U.S. House of Representatives

I am writing to ask you to cosponsor H.R. 4443, the Zero Food Waste Act, and H.R. 4444, the Cultivating Organic Matter through the Promotion of Sustainable Techniques (COMPOST) Act.

As Representative Chellie Pingree states, “Food waste has a massive environmental footprint and squanders perfectly good food as millions are going hungry.” Nearly half of all food produced in this country is lost or wasted, so an estimated $408 billion is spent on growing, processing, transporting, storing, and disposing of food that is never consumed. Landfills are now the third-largest source of methane in the U.S., and food is the single largest input by weight in our landfills and incinerators.

The Zero Food Waste Act would create a new Environmental Protection Agency (EPA) administered grant program for state, local, tribal, and territorial governments and for nonprofits, which would offer three types of grants: planning grants, measurement grants, and reduction grants. Planning grants could be used to investigate the kinds of food waste mitigation projects or policies would be most impactful within a given community. Measurement grants could be used to better understand the amount of food waste generated in the state or community.

Reduction grants could be used to fund an assortment of different types of projects—such as food waste prevention projects to stop the generation of food waste, recycling projects to reuse food waste as a feedstock for other uses like composting, rescuing projects that redirect surplus food to places like food shelters, and upcycling projects that make new food from ingredients that would otherwise go to landfills. Additionally, localities could use the grant funding to implement food waste landfill disposal or incineration restrictions designed to stop food waste.

Composting is one of the most environmentally friendly means of disposing of food waste and other organic waste. Not only does composting emit a smaller quantity of greenhouse gases compared to alternative disposal methods, it also yields a valuable soil additive that enhances soil health, which in turn makes the soil a better absorber of carbon, while also making the land more resilient to climate change-fueled disasters like wildfires and floods. While there is growing interest by individuals and businesses across the country to compost food scraps and compostable packaging, there is not enough composting infrastructure in the U.S. to meet this demand.

The Cultivating Organic Matter through the Promotion of Sustainable Techniques (COMPOST) Act would add composting as a conservation practice for U.S. Department of Agriculture (USDA) conservation programs. Both the act of producing compost from organic waste and using compost on a farm would qualify as a conservation practice. It also would create new USDA grant and loan guarantee programs for composting infrastructure projects, including both large-scale composting facilities as well as farm, home, or community-based projects.
Please cosponsor these bills, H.R. 4443 and H.R. 4444.

Thank you.

Letter to Bill Sponsors in House

Thank you for cosponsoring H.R. 4443, the Zero Food Waste Act, and H.R. 4444, the Cultivating Organic Matter through the Promotion of Sustainable Techniques (COMPOST) Act.

As Representative Chellie Pingree states, “Food waste has a massive environmental footprint and squanders perfectly good food as millions are going hungry.” Nearly half of all food produced in this country is lost or wasted, so an estimated $408 billion is spent on growing, processing, transporting, storing, and disposing of food that is never consumed. Landfills are now the third-largest source of methane in the U.S., and food is the single largest input by weight in our landfills and incinerators.

Composting is one of the most environmentally friendly means of disposing of food waste and other organic waste. Not only does composting emit a smaller quantity of greenhouse gases compared to alternative disposal methods, it also yields a valuable soil additive that enhances soil health, which in turn makes the soil a better absorber of carbon, while also making the land more resilient to climate change-fueled disasters like wildfires and floods.

These two bills offer substantial remedies to these pressing problems.

Thank you.

Letter to U.S. Senate

I am writing to ask you to cosponsor S. 2389, the Zero Food Waste Act, and S. 2388, the Cultivating Organic Matter through the Promotion of Sustainable Techniques (COMPOST) Act.

As Representative Chellie Pingree states, “Food waste has a massive environmental footprint and squanders perfectly good food as millions are going hungry.” Nearly half of all food produced in this country is lost or wasted, so an estimated $408 billion is spent on growing, processing, transporting, storing, and disposing of food that is never consumed. Landfills are now the third-largest source of methane in the U.S., and food is the single largest input by weight in our landfills and incinerators.

The Zero Food Waste Act would create a new Environmental Protection Agency (EPA) administered grant program for state, local, tribal, and territorial governments and for nonprofits, which would offer three types of grants: planning grants, measurement grants, and reduction grants. Planning grants could be used to investigate the kinds of food waste mitigation projects or policies would be most impactful within a given community. Measurement grants could be used to better understand the amount of food waste generated in the state or community.

Reduction grants could be used to fund an assortment of different types of projects—such as food waste prevention projects to stop the generation of food waste, recycling projects to reuse food waste as a feedstock for other uses like composting, rescuing projects that redirect surplus food to places like food shelters, and upcycling projects that make new food from ingredients that would otherwise go to landfills. Additionally, localities could use the grant funding to implement food waste landfill disposal or incineration restrictions designed to stop food waste.

Composting is one of the most environmentally friendly means of disposing of food waste and other organic waste. Not only does composting emit a smaller quantity of greenhouse gases compared to alternative disposal methods, it also yields a valuable soil additive that enhances soil health, which in turn makes the soil a better absorber of carbon, while also making the land more resilient to climate change-fueled disasters like wildfires and floods. While there is growing interest by individuals and businesses across the country to compost food scraps and compostable packaging, there is not enough composting infrastructure in the U.S. to meet this demand.

The Cultivating Organic Matter through the Promotion of Sustainable Techniques (COMPOST) Act would add composting as a conservation practice for U.S. Department of Agriculture (USDA) conservation programs. Both the act of producing compost from organic waste and using compost on a farm would qualify as a conservation practice. It also would create new USDA grant and loan guarantee programs for composting infrastructure projects, including both large-scale composting facilities as well as farm, home, or community-based projects.

Please cosponsor these bills, S. 2389 and S. 2388.

Thank you.

Letter to Senate Sponsors

Thank you for cosponsoring S. 2389, the Zero Food Waste Act, and S. 2388, the Cultivating Organic Matter through the Promotion of Sustainable Techniques (COMPOST) Act.

As Representative Chellie Pingree states, “Food waste has a massive environmental footprint and squanders perfectly good food as millions are going hungry.” Nearly half of all food produced in this country is lost or wasted, so an estimated $408 billion is spent on growing, processing, transporting, storing, and disposing of food that is never consumed. Landfills are now the third-largest source of methane in the U.S., and food is the single largest input by weight in our landfills and incinerators.

Composting is one of the most environmentally friendly means of disposing of food waste and other organic waste. Not only does composting emit a smaller quantity of greenhouse gases compared to alternative disposal methods, it also yields a valuable soil additive that enhances soil health, which in turn makes the soil a better absorber of carbon, while also making the land more resilient to climate change-fueled disasters like wildfires and floods.

These two bills offer substantial remedies to these pressing problems.

Thank you.

08/29/2022 — Protect Our Community’s Health and Biodiversity, and Fight the Climate Crisis with Organic Parks!

Does your community have a pesticide-free park managed with organic practices? Do you wish it did? If you do have an organic parks policy, do you have updated information on current practices? The time is now to take action to affirm or protect our authority to shift land management in our community to organic practices—just as the pesticide industry is lobbying to take that right away from us. Become a Parks Advocate. And, take the action below.

>>Advance organic land management in your community and ask your Mayor/County Commissioner/Town Manager to affirm or protect your community's right to restrict toxic pesticides.

If your community is one of a growing number across the country that has taken action to protect its citizens and environment by adopting organic policies and practices in its public spaces, please take this opportunity to request an update on how organic land management is going or ask that the community begin transitioning to organic land management. 

At the same time, be aware that the pesticide industry is seeking take away the ability of local communities to restrict toxic pesticides. Ask your Mayor/County Commissioner/Town Manager to contact your U.S. Representative and Senators, on your behalf, and tell them to oppose H.R. 7266 and support the Protect America's Children from Toxic Pesticides Act (PACTPA), which contains a provision affirming local authority to restrict pesticides.

Please share with us pictures of your parks. Tell us why your pesticide-free parks are important to you.

If your community has not yet taken action to protect its residents and environment by adopting organic policies and practices in its public spaces, it's time to do so.

>>Advance organic land management in your community and ask your Mayor/County Commissioner/Town Manager to affirm or protect your community's right to restrict toxic pesticides.

Letter to Mayors/County Commissioners/Town Managers

This letter contains a two-part request—first to address organic management in our community and, second, contact our elected representatives in Congress to protect our community's right to restrict toxic pesticides.

I would like to make sure that all land (parks, playgrounds, playing fields, etc.) in our area is managed with organic practices that eliminate fossil fuel-based toxic pesticides and fertilizers. Where these practices are in place, I would appreciate a report to the community. Where organic practices are not being utilized, I request that a plan be put in place to transition—as part of a community effort to protect health and biodiversity, and to fight the climate crisis. Now is the time that we must all join together to do our part to curtail petroleum-based pesticides and fertilizers and sequester atmospheric carbon in the soil through effective organic practices.

I am also asking you to contact, on behalf of our community, our U.S. Representative and Senators to tell them to oppose H.R. 7266 and support the Protect America’s Children from Toxic Pesticides Act (PACTPA), which contains a provision affirming local authority to restrict pesticides. We need your voice to be heard on behalf of all residents of our community to protect our health and biodiversity, and fight the climate crisis. Transitioning away from fossil fuel-based pesticides and fertilizers through the restriction of toxic pesticides and the adoption of organic practices is critically important to our health now and future sustainability.

Thank you and I look forward to hearing from you.

08/22/2022 — The Inflation Reduction Act Is Just the Beginning

Congratulations! The Inflation Reduction Act (IRA) is, as President Biden claims, “The single most aggressive action the U.S. is taking to tackle the climate crisis and create clean energy solutions in American history.” However, that is a low bar to clear. There is much more required to meet the President's climate goals and much is needed to ensure that the IRA is implemented in a way that helps farmers, fenceline communities, and biodiversity. As stated by Collin O'Mara, president and CEO of the National Wildlife Federation, “President Biden and his administration should take this moment not only to celebrate, but also to recommit and refocus on addressing the environmental injustice and wildlife crises."

>>Tell President Biden that funds in the Inflation Reduction Act must meet the need for a transformative moment to address the existential health (including environmental justice), biodiversity, and climate crises and shift society to organic practices by eliminating fossil fuel-based pesticides and fertilizers; and that further steps are needed to reach critical and urgent goals.

We cannot meet climate goals while maintaining a dependence on fossil fuels. Eliminating that dependence requires more than a shift from gas-powered vehicles to electric vehicles, shifting from oil- and gas-generated electricity to wind and solar generation, or adopting quick fixes like carbon capture. It requires us to think of systems differently. Conserving energy by reducing consumption, eliminating planned obsolescence in products, better urban planning, and improved agricultural systems is as important as producing power differently.

Organic agriculture, with its elimination of chemical fertilizers and reduced dependence on fossil fuels, is an example of an improved system. Organic producers are required to create and act upon an organic system plan that maximizes biological diversity and minimizes adverse environmental impacts. Organic farming increases sequestration of carbon in the soil. Provisions in the IRA that enhance the success of organic farmers and encourage transition to organic farming promote a climate-friendly system.

The organic system should be applied to all land management. Organic farming and land management not only help meet climate goals, but also reduce the impacts of hazardous chemicals and resource extraction on fenceline communities and ecosystems, making it responsive to environmental justice threats.

As monies are expended under this legislation, the government must prioritize programs that attack the existential crises associated with pesticide threats, including health, biodiversity, and climate. This mandate must come from the White House and ensure that all funds first and foremost effect a transformative change necessary to meet the current looming crises. To this end, 100% of funds dedicated to conservation (Conservation Stewardship Program and all other affected agricultural programs), environmental quality incentives program (EQIP), environmental justice, and other related programs, must go to organic transition that eliminates toxic pesticides and fossil fuel-based chemicals and fertilizers.

We are experiencing a climate emergency, a health emergency, and an ecological emergency. The President should heed calls to declare a climate emergency and initiate creative, systemic solutions to existential threats to human life and life on Earth.

>>Tell President Biden that funds in the Inflation Reduction Act must meet the need for a transformative moment to address the existential health (including environmental justice), biodiversity, and climate crises and shift society to organic practices by eliminating fossil fuel-based pesticides and fertilizers; and that further steps are needed to reach critical and urgent goals.

Letter to President Biden

Congratulations! The Inflation Reduction Act (IRA) passed, “the single most aggressive action the U.S. is taking to tackle the climate crisis and create clean energy solutions in American history.” However, that is a low bar to clear. There is much more required to meet your climate goals, and much is needed to ensure that the IRA is implemented in a way that helps farmers, fenceline communities, and biodiversity. As stated by Collin O’Mara, president and CEO of the National Wildlife Federation, “[You] should take this moment not only to celebrate, but also to recommit and refocus on addressing the environmental injustice and wildlife crises.”

We cannot meet climate goals while maintaining a dependence on fossil fuels. Eliminating that dependence requires more than a shift from gas-powered vehicles to electric vehicles, shifting from oil- and gas-generated electricity to wind and solar generation, or adopting quick fixes like carbon capture. It requires us to think of systems differently. Conserving energy by reducing consumption, eliminating planned obsolescence in products, better urban planning, and improved agricultural systems is as important as producing power differently to meet the existential crises of the day.

Organic agriculture, with its elimination of chemical fertilizers and reduced dependence on fossil fuels, is an example of an improved system. Organic producers are required to create and act upon an organic system plan that maximizes biological diversity and minimizes adverse environmental impacts. Organic farming increases sequestration of carbon in the soil. Provisions in the IRA that enhance the success of organic farmers and encourage transition to organic farming promote a climate-friendly system.

The organic system should be applied to all land management. Organic farming and land management not only help meet climate goals, but also reduce impacts of hazardous chemicals and resource extraction on fenceline communities and ecosystems.

As monies are expended under this legislation, the government must prioritize programs that attack the existential crises associated with pesticide threats, including health, biodiversity, and climate. This mandate must come from the White House and ensure that all funds, first and foremost, effect a transformative change necessary to meet the looming crises. To this end, 100% of funds dedicated to conservation (Conservation Stewardship Program and all other affected agricultural programs), environmental quality incentives program (EQIP), environmental justice, and other related program, must go to organic transition that eliminates toxic pesticides and fossil fuel-based chemicals and fertilizers.

We are experiencing a climate emergency, a health emergency, and an ecological emergency. I call upon you to heed calls to declare a climate emergency and initiate creative, systemic solutions to existential threats to human life and life on Earth.

Thank you.

Letter to Congress

Congratulations! The Inflation Reduction Act (IRA) passed, “the single most aggressive action the U.S. is taking to tackle the climate crisis and create clean energy solutions in American history.” However, that is a low bar to clear. There is much more required to meet our climate goals, and much is needed to ensure that the IRA is implemented in a way that helps farmers, fenceline communities, and biodiversity. As stated by Collin O’Mara, president and CEO of the National Wildlife Federation, “President Biden and his administration should take this moment not only to celebrate, but also to recommit and refocus on addressing the environmental injustice and wildlife crises.”

We cannot meet climate goals while maintaining a dependence on fossil fuels. Eliminating that dependence requires more than a shift from gas-powered vehicles to electric vehicles, shifting from oil- and gas-generated electricity to wind and solar generation, or adopting quick fixes like carbon capture. It requires us to think of systems differently. Conserving energy by reducing consumption, eliminating planned obsolescence in products, better urban planning, and improved agricultural systems is as important as producing power differently to meet the existential crises of the day.

Organic agriculture, with its elimination of chemical fertilizers and reduced dependence on fossil fuels, is an example of an improved system. Organic producers are required to create and act upon an organic system plan that maximizes biological diversity and minimizes adverse environmental impacts. Organic farming increases sequestration of carbon in the soil. Provisions in the IRA that enhance the success of organic farmers and encourage transition to organic farming promote a climate-friendly system.

The organic system should be applied to all land management. Organic farming and land management not only help meet climate goals, but also reduce impacts of hazardous chemicals and resource extraction on fenceline communities and ecosystems.

As monies are authorized and appropriated under this and much needed future legislation, Congress must prioritize programs that attack the existential crises associated with pesticide threats, including health, biodiversity, and climate. Congress must mandate the expenditure of funds, first and foremost, to effect a transformative change necessary to meet the looming crises. To this end, 100% of funds dedicated to conservation (Conservation Stewardship Program and all other affected agricultural programs), environmental quality incentives program (EQIP), environmental justice, and other related program, must go to organic transition that eliminates toxic pesticides and fossil fuel-based chemicals and fertilizers.

We are experiencing a climate emergency, a health emergency, and an ecological emergency. I call upon you to heed calls to declare a climate emergency and initiate creative, systemic solutions to existential threats to human life and life on Earth.

In addition, please support H.R. 794, which requires President Biden to declare a climate emergency and prioritize investments and actions enabling a racially and socially just transition to a clean energy economy.

Thank you.

08/16/2022 — Eliminate Pesticides in National Wildlife Refuges

Senator Cory Booker (D-NJ) and seven other members of the United States Senate are calling on the U.S. Fish and Wildlife Service (FWS) to phase out the use of toxic pesticides in National Wildlife Refuges in order to protect declining wildlife species and the country's unique natural resources. The senators sent a letter to FWS Director Martha Williams urging FWS to “expeditiously begin a rulemaking process to phase out the use of agricultural pesticides on National Wildlife Refuges.” The move comes at a time when native wildlife and the ecosystems humans rely upon are under greater threats than ever before from climate change, habitat destruction, and the indiscriminate use of toxic pesticides.

>>Tell the USFWS to phase out the use of agricultural pesticides on National Wildlife Refuges. Tell Congress to support this phase out. 

“The Refuge System was established to provide sanctuary for listed threatened and endangered species, migratory birds, and other wildlife,” wrote the senators in their letter. “The Refuges' migratory sanctuary and breeding grounds are especially critical for North American birds, as they have faced precipitous population declines; there are 3 billion fewer breeding birds in North America than there were in 1970. Unfortunately these birds and other threatened species are being put at risk by pesticide use in the Refuges that were designed to protect them.” 

Responding to court challenges in 2014, the former Chief of the National Wildlife Refuge System officially phased out the use of genetically engineered crops and neonicotinoids insecticides on all US wildlife refuges. The decision, as outlined in a memorandum by former Chief James Kurth, was based on the fact that neonicotinoid use, and the harms associated with it, “is not consistent with Service policy…[]based on a precautionary approach to our wildlife management practices and not on agricultural practices.”

Despite these important restrictions, other toxic agricultural pesticides continued to be sprayed in these sensitive and protected sites. A report by the Center for Biological Diversity (CBD) found that in 2016 alone over 270,000 acres were sprayed with more than 490,000 pounds of hazardous pesticides. Despite these concerning statistics, the Trump administration's USFWS released a memorandum reversing the 2014 restrictions on neonicotinoid pesticides, allowing use on a “case-by-case basis,” thus unnecessarily exposing a broad range of threatened and endangered wildlife to chemicals that do not belong in protected natural areas. As the senators write, these chemicals “leach into the surrounding groundwater and soil and are picked up by native flowering plants and pollinators.” This threatens not only non-target organisms, but also the 53 million annual human visitors to U.S. Wildlife Refuges.

An update to CBD's report, finds pesticide use expanded 34% from 2016, to more than 363,000 acres of wild lands. Use of the most dangerous pesticides increased by more than 70% within this time frame. To remedy the situation, the senators are calling for the Refuge System to work to eliminate all toxic pesticide use in favor products compatible with organic land care. The letter to FWS also asks for provisions that permit pesticide use on non-native species only on a limited basis if compatible with a Refuge's Comprehensive Conservation Plan. Furthermore, they ask that the 2014 memorandum issued by the United States Fish and Wildlife Service Chief James Kurth be reinstated, phasing out neonicotinoids.

In addition to Senator Booker, Senators Ed Markey (D-MA), Bernie Sanders (I-VT), Kirsten Gillibrand (D-NY), Elizabeth Warren (D-MA), Alex Padilla (D-CA), Dianne Feinstein (D-CA), and Martin Heinrich (D-NM) signed on to the letter.

Help support the efforts of these Senate champions by joining calls to urge FWS to reinstate Refuge System protections. Further support Senator Booker's steadfast efforts to protect American children and the wider environment from toxic pesticides by urging your own senators to join in cosponsoring the Protect America's Children from Toxic Pesticides Act.

>>Tell the USFWS to phase out the use of agricultural pesticides on National Wildlife Refuges. Tell Congress to support this phase out.

Letter to U.S. Fish and Wildlife Services

I am writing to support the request by Senator Cory Booker and seven other U.S. Senators that USFWS phase out the use of toxic pesticides in National Wildlife Refuges in order to protect declining wildlife species and the country’s unique natural resources. Native wildlife and the ecosystems upon which humans rely are under greater threats than ever before from climate change, habitat destruction, and the indiscriminate use of toxic pesticides.

As stated by the senators, “The Refuge System was established to provide sanctuary for listed threatened and endangered species, migratory birds, and other wildlife. The Refuges’ migratory sanctuary and breeding grounds are especially critical for North American birds, as they have faced precipitous population declines; there are 3 billion fewer breeding birds in North America than there were in 1970. Unfortunately, these birds and other threatened species are being put at risk by pesticide use in the Refuges that were designed to protect them.”

Along with the senators, I ask that you expeditiously begin a rulemaking process to phase out the use of agricultural pesticides on National Wildlife Refuges. Specifically, I ask that:
1. All chemical or biological pesticides registered under Section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act be subject to phase out on National Wildlife Refuge land, automatically exempting minimum risk pesticides such as those used in organic production.
2. The use of any pesticides for the control of invasive or non-native species be authorized only on a limited basis when necessary so long as it is compatible with each Refuge’s Comprehensive Conservation Plan and strictly in conformity with an Integrated Pest Management plan.
3. As a short-term fix, I ask that the 2014 memorandum issued by the United States Fish and Wildlife Service Chief James Kurth be reinstated, phasing out neonicotinoids.

Thank you for your consideration of this request.

Letter to Congress

I am asking you to support the request by Senator Cory Booker and seven other senators that U.S Fish and Wildlife Service (FWS) phase out the use of toxic pesticides in National Wildlife Refuges in order to protect declining wildlife species and the country’s unique natural resources. Native wildlife and the ecosystems upon which humans rely are under greater threats than ever before from climate change, habitat destruction, and the indiscriminate use of toxic pesticides.

As stated by the senators in a letter to FWS, “The Refuge System was established to provide sanctuary for listed threatened and endangered species, migratory birds, and other wildlife. The Refuges’ migratory sanctuary and breeding grounds are especially critical for North American birds, as they have faced precipitous population declines; there are 3 billion fewer breeding birds in North America than there were in 1970. Unfortunately these birds and other threatened species are being put at risk by pesticide use in the Refuges that were designed to protect them.”

Along with the senators, I ask that you ask FWS to expeditiously begin a rulemaking process to phase out the use of agricultural pesticides on National Wildlife Refuges. Specifically, I ask that:

1. All chemical or biological pesticides registered under Section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act be subject to phase out on National Wildlife Refuge land, automatically exempting minimum risk pesticides such as those used in organic production.
2. The use of any pesticides for the control of invasive or non-native species be authorized only on a limited basis when necessary so long as it is compatible with each Refuge’s Comprehensive Conservation Plan and strictly in conformity with an Integrated Pest Management plan.
3. As a short-term fix, I ask that the 2014 memorandum issued by the United States Fish and Wildlife Service Chief James Kurth be reinstated, phasing out neonicotinoids.

Thank you for your consideration of this request.

08/08/2022 — Preserve Local Democracy and the Right for Communities to Restrict Pesticide Use

The pesticide industry has selected August as Anti-Democracy Month, as it launches a month-long campaign to undermine local control over pesticides. The National Pest Management Association is encouraging members to lobby members of Congress in August to support H.R. 7266, to “prohibit local regulations relating to the sale, distribution, labeling, application, or use of any pesticide or device” subject to state or federal regulation under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

Beyond Pesticides urges you to make August Preserve Local Democracy Month by participating in actions in support of allowing communities to protect themselves from chemical exposure when state and federal regulation is inadequate.

>>Tell your U.S. Representative and Senators to support communities by opposing H.R. 7266 and supporting the Protect America's Children from Toxic Pesticides Act (PACTPA), which contains a provision affirming local authority to restrict pesticides. >>TAKE ACTION NOW.

The fight to defend the authority of local governments to protect people and the environment has been ongoing for decades, reaching the U.S. Supreme Court in 1991. The Court specifically upheld the authority of local governments to restrict pesticides throughout their jurisdictions under federal pesticide law. In Wisconsin Public Intervenor v. Mortier, the Court ruled that federal pesticide law does not prohibit, or preempt, local jurisdictions from restricting the use of pesticides more stringently than the federal government throughout their jurisdiction. According to Mortier, however, states do retain authority to take away local control. In response to the Supreme Court decision, the pesticide lobby immediately formed a coalition, called the Coalition for Sensible Pesticide Policy, and developed boilerplate legislative language that restricts local municipalities from passing ordinances on the use of pesticides on private property. The Coalition's lobbyists descended on states across the country, seeking and passing, in most cases, preemption legislation that was often identical to the Coalition's wording.

Since the passage of those state laws, there have been numerous efforts to prohibit localities from developing policies reflecting the unique needs and values of the people living there. In states that do not prohibit local action on pesticides, an ever-increasing number of communities are stepping up to protect their residents and unique local environment from pesticide poisoning and contamination. Having failed to curtail local action and with a growing number of communities deciding to act, the chemical industry is flexing its muscle with an attack in Congress.

Legislation introduced in April by U.S. Representative Rodney Davis (R-IL), who just lost his primary race, would roll back, preempt, and prohibit local jurisdictions from enacting policies that protect resident health and a community's unique local environments from hazardous pesticides. The bill is a direct attack on the scores of local communities that have enacted common sense safeguards from toxic pesticides, and represents the pesticide industry's response to the growing momentum of the pesticide reform movement. Health and environmental advocates are expecting Rep. Davis and his partners in the agrichemical industry to attempt to work the provisions of the legislation into the upcoming 2023 farm bill. The industry had previously failed to work prohibitions against local restrictions into the 2018 farm bill, after massive pushback from health advocates, local officials, and Congressional allies.

Rep. Davis's press release for the bill, in which he was joined with quotes from a range of agrichemical industry leaders, is titled “Davis Introduces Legislation to Prevent Liberal Local Governments from Banning or Restricting Pesticide Use,” striking a partisan tone. Caring about public and environmental health is typically not viewed as a liberal or conservative, Democratic or Republican issue. Those monitoring local governments that enact pesticide restrictions do not see partisan motivations; these laws are borne out of concern for children's health, pregnant women, workers at disproportionate risk, and the immunocompromised, many of whom come to local government meetings to share their stories of pesticide poisoning. Conversations in local communities focus on the potential contamination of drinking water, local recreational swimming areas in waterways, the parks in which residents walk their beloved pets, and stories of locals witnessing a steep decline in pollinators.

The decision to enact a local pesticide policy is one that comes from local community discussion. Yet, Rep. Davis's bill could stop communities from exercising basic local governance to protect people and the environment. 

The bill would amend federal pesticide law by adding the following provision:
“(d) LOCAL REGULATION PROHIBITED – A political subdivision of a State shall not impose, or continue in effect, any requirement relating to the sale, distribution, labeling, application, or use of any pesticide or device subject to regulation by a State pursuant to this section or by the Administrator under this Act.”

This language is considerably more restrictive than the amendment Rep. Davis and the industry proposed under the 2018 farm bill. Under this new language, by prohibiting a community to “continue in effect” any requirement relating to pesticide use, the bill would overturn any existing restrictions already passed in local communities. With uncertainty over how broadly this bill would be interpreted, all local jurisdictions with pesticide reform policies, including those only applying to public properties, could be reversed with this legislation.  

While traditionally anathema to the ideology of Rep. Davis and his colleagues, this bill represents a massive federal “big government” overreach into local communities.

The impacts for public health and ecological stability would be devastating. Only state agencies and the federal government would be able to regulate pesticide use. With the vast majority of state agencies effectively acting as rubber stamps for pesticide approvals by the U.S. Environmental Protection Agency (EPA), local jurisdictions would be forced to follow the rulemaking of an agency that has been documented to be captured by industry interests.

Time and time again, EPA has shown itself to be willing to override its mission to protect health and the environment at the behest of agrichemical industry interests. As dozens of local communities act to protect declining pollinator populations by limiting the use of bee toxic neonicotinoid insecticides, EPA is set to reregister them for another 15 years. While local communities across the country are eliminating the use of glyphosate due cancer concerns and legal liability over its health impacts, EPA has denied the chemical's cancer links and worked hand in glove with agrichemical industry groups to defend its use and stop other countries from enacting bans or restrictions.

With new evidence continuing to emerge on the depths of agrichemical industry corruption within EPA's Office of Pesticide Programs, it is little wonder that a large and growing swath of communities are enacting laws that eliminate nearly all synthetic pesticides registered by EPA in favor of organic and minimum risk practices and products.

Scientific research backs up the assertion that laws limiting local protections harm public welfare. The study, “Anti-Community State Pesticide Preemption Laws Prevent Local Governments From Protecting People From Harm,” published in the International Journal of Agricultural Sustainability and supported by the USDA's National Institute of Food and Agriculture, finds that state laws prohibiting local protective ordinances “compromise public health and economic well-being” by preventing localities from enacting pesticide use restrictions that are more restrictive than their state's regulations. In the words of the authors, “By eliminating the ability of local governments to enact ordinances to safeguard inhabitants from health risks posed by pesticides, state preemption laws denigrate public health protections.”

The most frequent justification stated by anti-democracy proponents is the desire for “economies of scale” to prevent a “patchwork” of legislation, which would centralize control and create a “predictable regulatory environment.” Rep. Davis's press release is littered with similar statements. Based on evidence of industry influence over state policies, however, study authors hold the position that these justifications are a ploy for more perverse economic motivations—to sell their toxic products, increase their stock, and reward their highly paid executives.

According to OpenSecrets, the agricultural services/products industry represented one of the top five industries donating to Rep. Davis between 2019-2020, totaling $160,625 for that period.

>>Tell your U.S. Representative and Senators to support communities by opposing H.R. 7266, and supporting the Protect America's Children from Toxic Pesticides Act (PACTPA), which contains a provision affirming local authority to restrict pesticides.

Letter to Congress

I am writing to urge you to oppose H.R. 7266, which seeks to deny local communities the power to protect themselves from chemical exposure when state and federal regulation is inadequate. The bill would amend federal pesticide law to prohibit local governments from restricting pesticide use on private property within their jurisdictions. However, the rights of local governmental jurisdictions under existing pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), have been left to the states since the law’s adoption. In fact, local laws protecting the environment and public health have historically emerged out of local governments, with laws related to recycling, smoking, pet waste, building codes, and zoning.

The rights of local governments to protect people and the environment were upheld by the U.S. Supreme Court in 1991. The Court specifically upheld the authority of local governments to restrict pesticides throughout their jurisdictions under federal pesticide law. In Wisconsin Public Intervenor v. Mortier, the Court ruled that FIFRA does not prohibit, or preempt, local jurisdictions from restricting the use of pesticides more stringently than the federal government. According to Mortier, however, states may restrict local control as a matter of state authority.

Please support the Protect America’s Children from Toxic Pesticides Act (PACTPA), which contains a provision affirming local authority to restrict pesticides. PACTPA will provide some desperately needed improvements to FIFRA to better protect people and the environment, including banning some of the most damaging pesticides, restoring balance to protect ordinary citizens by removing dangerous pesticides from the market, and protecting frontline communities that bear the burden of pesticide exposure.

Please let me know your position on these bills.

Thank you.

08/01/2022 — Tell USDA to Support Organic, Not Undermine It

The U.S. Department of Agriculture (USDA) has just renewed the charter of the National Organic Standards Board (NOSB), with changes that threaten the balance on the board created by law. Organic production is successful, with sales topping $63 billion, and still growing. Organic production not only brings healthful food to it consumers, but also reduces the amount of toxic chemicals released to the air, soil, and water. And it helps to reduce climate change by sequestering carbon in the soil. To ensure rigorous oversight of USDA and robust advice and management of the National List of Allowed and Prohibited Substances, the NOSB was created to ensure balanced representation from organic stakeholders, including consumers, conservationists, farmers, a scientist, retailer, and certifier. The growth of the organic brand is attributable in great part to public trust in the standards and processes that govern oversight over the USDA organic label.

>>Tell USDA to classify all NOSB members as “Representatives” to protect the integrity of organic production. Tell Congress to ensure that USDA follows the letter and spirit of the organic law.

The success of organic derives from consumer trust in the organic label, and that trust depends on a system in which the USDA national organic program (NOP) receives direction from a board composed of a balanced group of stakeholders—producers, processors, retailers, certifiers, scientists, environmentalists, and consumers—the NOSB. The composition of the NOSB is laid out in the Organic Foods Production Act. While many organic consumers do not know about the NOSB, they would certainly know about controversies if not resolved within the board's debates—such as the decision to prohibit antibiotic use on apples and pears for fire blight.

USDA's new NOSB charter changes the classification of two categories of members—environmentalists and the scientist—from “representatives” to “special government employees” (SGEs). As stated by USDA, “The most important point to emphasize is that SGEs ARE Government employees.” As government employees, not only do SGEs have greater disclosure requirements, but there are additional restrictions on the number of days they can work in a year (even though an NOSB position is a volunteer position) and their actions both during their service and afterwards. In addition, as government employees, such NOSB members may not feel free to criticize USDA when appropriate.

Classifying some NOSB members as “Representatives” and some as SGEs creates an imbalance in the NOSB, whose composition was carefully selected to provide a balance of interests. If some NOSB members are SGEs, who are restricted to working no more than 130 days per year, the imbalance is accentuated.

The balance on the NOSB needs to be restored, in order to maintain public trust in the USDA organic label.

>>Tell USDA to classify all NOSB members as “Representatives” to protect the integrity of organic production. Tell Congress to ensure that USDA follows the letter and spirit of the organic law.

Letter to USDA

I am writing to express my concern about the revised charter for the National Organic Standards Board, which undermines the balance created by the Organic Foods Production Act (OFPA). The growth of the organic brand is attributable in great part to public trust in the standards and processes that govern oversight over the USDA organic label. This change undermines that trust.

The new charter reclassifies environmental and scientist members of the NOSB as special government employees (SGEs) instead of ”Representatives.”

First of all, in case you are not aware of the work done by this volunteer board, NOSB members work far more than the maximum 130 days per year allowed by SGEs.

Organic production is successful, with sales topping $63 billion, and still growing. Organic production not only brings healthful food to it consumers, but also reduces the amount of toxic chemicals released to the air, soil, and water. And it helps to reduce climate change by sequestering carbon in the soil.

The success of organic derives from consumer trust in the organic label, and that trust depends on a system in which the USDA national organic program (NOP) receives direction from a board composed of a balanced group of stakeholders—producers, processors, retailers, certifiers, scientists, environmentalist, and consumers—the NOSB. The composition of the NOSB is laid out in the Organic Foods Production Act. While many organic consumers do not know about the NOSB, they would certainly know about controversies if not resolved within the board’s debates.

In the report accompanying OFPA, the Congressional authors of the bill said, “The membership of this Board was carefully selected to provide a balance of interests.… As a result the Committee restructured the Board so that the farmers and handlers involved in organic production receive six representatives, equal to the consumer and environmental organizations, which together also receive six representatives.” This language makes it clear that members of the NOSB are representatives of their various classes, and that the balance of interests that they represent is essential.

SGEs are treated differently under the law from representatives. As stated by the USDA, “The most important point to emphasize is that SGEs ARE Government employees.” As government employees, not only do SGEs have greater disclosure requirements, but there are additional restrictions on their actions both during their service and afterwards. In addition, as government employees, such NOSB members may not feel free to criticize USDA when appropriate.

Classifying some NOSB members as “Representatives” and some as SGEs creates an imbalance in the NOSB, whose composition was carefully selected to provide a balance of interests. If some NOSB members are restricted to working no more than 130 days per year, the imbalance is accentuated.

Finally, the Federal Advisory Committee Act requires the FACA committee to file the charter and renewals, not USDA, which raises the issue of the validity of the new charter.

Please ensure that the charter reverts to the former classification of NOSB members.

Thank you.

Letter to Congress

I am writing to express my concern about the revised charter for the National Organic Standards Board, which undermines the balance created by the Organic Foods Production Act (OFPA). The growth of the organic brand is attributable in great part to public trust in the standards and processes that govern oversight over the USDA organic label. This change undermines that trust.

The new charter reclassifies environmental and scientist members of the NOSB as special government employees (SGEs) instead of ”Representatives.”

First of all, in case you are not aware of the work done by this volunteer board, NOSB members work far more than the maximum 130 days per year allowed by SGEs.

Organic production is successful, with sales topping $63 billion, and still growing. Organic production not only brings healthful food to it consumers, but also reduces the amount of toxic chemicals released to the air, soil, and water. And it helps to reduce climate change by sequestering carbon in the soil.

The success of organic derives from consumer trust in the organic label, and that trust depends on a system in which the USDA national organic program (NOP) receives direction from a board composed of a balanced group of stakeholders—producers, processors, retailers, certifiers, scientists, environmentalist, and consumers—the NOSB. The composition of the NOSB is laid out in the Organic Foods Production Act. While many organic consumers do not know about the NOSB, they would certainly know about controversies if not resolved within the board’s debates.

In the report accompanying OFPA, the Congressional authors of the bill said, “The membership of this Board was carefully selected to provide a balance of interests. … As a result the Committee restructured the Board so that the farmers and handlers involved in organic production receive six representatives, equal to the consumer and environmental organizations, which together also receive six representatives.” This language makes it clear that members of the NOSB are representatives of their various classes, and that the balance of interests that they represent is essential.

SGEs are treated differently under the law from representatives. As stated by the USDA, “The most important point to emphasize is that SGEs ARE Government employees.” As government employees, not only do SGEs have greater disclosure requirements, but there are additional restrictions on their actions both during their service and afterwards. In addition, as government employees, such NOSB members may not feel free to criticize USDA when appropriate.

Classifying some NOSB members as “Representatives” and some as SGEs creates an imbalance in the NOSB, whose composition was carefully selected to provide a balance of interests. If some NOSB members are restricted to working no more than 130 days per year, the imbalance is accentuated.

Finally, the Federal Advisory Committee Act requires the FACA committee to file the charter and renewals, not USDA, which raises the issue of the validity of the new charter.

Please ensure through your oversight that the charter reverts to the former classification of NOSB members.

Thank you.

07/25/2022 — Protect Our Oceans and Our Lives

We have seen pesticide use, habitat destruction, and climate change result in dramatic losses of insect biodiversity and biomass—an “insect apocalypse” that is resulting in cascading impacts on other species that depend on them. A preliminary report on two years of water sampling from sites in the Atlantic Ocean near the United Kingdom (UK), by a team from the Global Oceanic Environmental Survey Foundation (GOES), suggests that plankton populations may have plummeted by 90% since baseline 1940 levels. They conclude, “An environmental catastrophe is unfolding. We believe humanity could adapt to global warming and extreme weather changes. It is our view that humanity will not survive the extinction of most marine plants and animals.”

>>Tell EPA to protect our oceans and our lives. Tell Congress to ensure that EPA does its job.

Action is needed now to stop the ongoing plankton apocalypse. Just as insects are crucial as the basis of terrestrial ecosystems, plankton are the base of aquatic and marine food chains. "Researchers blame chemical pollution from pesticides, farm fertilizers, and oil spills in the water. The U.S. Environmental Protection Agency (EPA) has responsibilities under the Federal Insecticide, Fungicide, and Rodenticide Act and the Clean Water Act to protect human health and the environment from these threats.

The same chemicals that contribute to the insect apocalypse on land are contributing to the loss of keystone aquatic and marine organisms. For example, neonicotinoid insecticides, which have been detected in rivers, streams, and lakes in 29 states, present detrimental impacts on keystone aquatic organisms and result in a complex cascading impact on ecosystems. In its 2017 risk assessment for the most widely used neonicotinoid, imidacloprid, EPA found, “[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates.” The agency evaluated an expanded universe of adverse effects data and finds that acute (short-term) and chronic (long-term) toxicity endpoints are lower (adverse effects beginning at 0.65 μg/L (micrograms per liter)-acute and 0.01 μg/L-chronic effects) than previously established aquatic life benchmarks (adverse effects from 34.5 μg/L-acute and 1.05μg/L-chronic effects). In its 2017 risk assessment, EPA finds risks from imidacloprid exposure to ecologically important organisms not previously evaluated as part of its regulatory review. Despite its acknowledgement that current benchmarks are not adequately protective, EPA describes its review process as requiring studies of the most sensitive organisms and a range of publicly available environmental laboratory and field studies. 

The same industrial agriculture that is supported by EPA's registration of toxic pesticides and results in emissions of climate-changing nitrogen oxides and loss of soil health is also a major contributing factor to nitrate run-off and the need for petroleum-based chemicals whose production results in oil spills. It is not an exaggeration to say that it is within the power and authority of EPA to reverse the threats to biodiversity and human existence.

>>Tell EPA to protect our oceans and our lives. Tell Congress to ensure that EPA does its job.

Letter to EPA

We have seen pesticide use, habitat destruction, and climate change result in dramatic losses of insect biodiversity and biomass—an “insect apocalypse” that is resulting in cascading impacts on other species that depend on them. Now researchers, in a preliminary report, are finding a similar phenomenon in the oceans, with a 90% reduction in plankton. They conclude, “An environmental catastrophe is unfolding. We believe humanity could adapt to global warming and extreme weather changes. It is our view that humanity will not survive the extinction of most marine plants and animals.”

Action is needed now to stop the ongoing plankton apocalypse. Researchers blame chemical pollution from pesticides, farm fertilizers, and oil spills in the water. The U.S. Environmental Protection Agency (EPA) has responsibilities under the Federal Insecticide, Fungicide, and Rodenticide Act and the Clean Water Act to protect human health and the environment from these threats.

The same chemicals that contribute to the insect apocalypse on land are contributing to the loss of keystone aquatic and marine organisms. For example, neonicotinoid insecticides, which have been detected in rivers, streams, and lakes in 29 states, present detrimental impacts on keystone aquatic organisms and result in a complex cascading impact on ecosystems. In its 2017 risk assessment for the most widely used neonicotinoid, imidacloprid, EPA found, “[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates.” The agency evaluated an expanded universe of adverse effects data and finds that acute (short-term) and chronic (long-term) toxicity endpoints are lower (adverse effects beginning at 0.65 μg/L (micrograms per liter)-acute and 0.01 μg/L-chronic effects) than previously established aquatic life benchmarks (adverse effects from 34.5 μg/L-acute and 1.05μg/L-chronic effects). In its 2017 risk assessment, EPA finds risks from imidacloprid exposure to ecologically important organisms not previously evaluated as part of its regulatory review. Despite its acknowledgement that current benchmarks are not adequately protective, EPA describes its review process as requiring studies of the most sensitive organisms and a range of publicly available environmental laboratory and field studies.

The same industrial agriculture that is supported by EPA’s registration of toxic pesticides and results in emissions of climate-changing nitrogen oxides and loss of soil health is also a major contributing factor to nitrate run-off and the need for petroleum-based chemicals whose production results in oil spills. It is not an exaggeration to say that it is within the power and authority of EPA to reverse the threats to biodiversity and human existence.

EPA must re-evaluate its risk-benefit analysis to recognize the existential threats posed by toxic pesticides and the industrial agriculture they support. EPA must, instead, promote organic agriculture that does not create such threats.

Thank you.

Letter to Congress

We have seen pesticide use, habitat destruction, and climate change result in dramatic losses of insect biodiversity and biomass—an “insect apocalypse” that is resulting in cascading impacts on other species that depend on them. Now researchers, in a preliminary report, are finding a similar phenomenon in the oceans, with a 90% reduction in plankton. They conclude, “An environmental catastrophe is unfolding. We believe humanity could adapt to global warming and extreme weather changes. It is our view that humanity will not survive the extinction of most marine plants and animals.”

Action is needed now to stop the ongoing plankton apocalypse. Researchers blame chemical pollution from pesticides, farm fertilizers, and oil spills in the water. The U.S. Environmental Protection Agency (EPA) has responsibilities under the Federal Insecticide, Fungicide, and Rodenticide Act and the Clean Water Act to protect human health and the environment from these threats.

The same chemicals that contribute to the insect apocalypse on land are contributing to the loss of keystone aquatic and marine organisms. For example, neonicotinoid insecticides, which have been detected in rivers, streams, and lakes in 29 states, present detrimental impacts on keystone aquatic organisms and result in a complex cascading impact on ecosystems. In its 2017 risk assessment for the most widely used neonicotinoid, imidacloprid, EPA found, “[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates.” The agency evaluated an expanded universe of adverse effects data and finds that acute (short-term) and chronic (long-term) toxicity endpoints are lower (adverse effects beginning at 0.65 μg/L (micrograms per liter)-acute and 0.01 μg/L-chronic effects) than previously established aquatic life benchmarks (adverse effects from 34.5 μg/L-acute and 1.05μg/L-chronic effects). In its 2017 risk assessment, EPA finds risks from imidacloprid exposure to ecologically important organisms not previously evaluated as part of its regulatory review. Despite its acknowledgement that current benchmarks are not adequately protective, EPA describes its review process as requiring studies of the most sensitive organisms and a range of publicly available environmental laboratory and field studies.

The same industrial agriculture that is supported by EPA’s registration of toxic pesticides and results in emissions of climate-changing nitrogen oxides and loss of soil health is also a major contributing factor to nitrate run-off and the need for petroleum-based chemicals whose production results in oil spills. It is not an exaggeration to say that it is within the power and authority of EPA to reverse the threats to biodiversity and human existence.

EPA must re-evaluate its risk-benefit analysis to recognize the existential threats posed by toxic pesticides and the industrial agriculture they support. Please use your oversight to ensure that EPA instead promotes organic agriculture that does not create such threats.

Thank you.

07/21/2022 — EPA Must Ban Endocrine-Disrupting Pesticides

The failure of the U.S. Environmental Protection Agency (EPA) to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine disrupting chemicals must end. A study published in Toxicology and Applied Pharmacology adds urgency to the need to eliminate endocrine-disrupting pesticides. The authors find that prepubescent exposure to endocrine-disrupting chemicals (EDCs), including pesticides, impairs male reproduction through the interruption of testicular homeostasis and development of reproductive Leydig cells, and can have multigenerational effects. This adds to the long list of scientific articles showing EPA neglect of the devastating effects of widely used pesticides.

>>Tell EPA that pesticide use cannot continue without findings of no endocrine disruption. Tell Congress to ensure that EPA does its job.

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.

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.”

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.

Under the Food Quality Protection Act (FQPA), EPA 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.

>>Tell EPA that pesticide use cannot continue without findings of no endocrine disruption. Tell Congress to ensure that EPA does its job.

Letter to EPA

 

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

A study published in Toxicology and Applied Pharmacology adds urgency to the need to eliminate endocrine-disrupting pesticides. The authors find that prepubescent exposure to endocrine-disrupting chemicals (EDCs), including pesticides, impairs male reproduction through the interruption of testicular homeostasis and development of reproductive Leydig cells, and can have multigenerational effects. This adds to the long list of scientific articles showing EPA neglect of the devastating effects of widely used pesticides.

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.”

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.

A study published in Toxicology and Applied Pharmacology adds urgency to the need to eliminate endocrine-disrupting pesticides. The authors find that prepubescent exposure to endocrine-disrupting chemicals (EDCs), including pesticides, impairs male reproduction through the interruption of testicular homeostasis and development of reproductive Leydig cells, and can have multigenerational effects. This adds to the long list of scientific articles showing EPA neglect of the devastating effects of widely used pesticides.

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.”

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.

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.

07/11/2022 — Think Globally, Act Locally for a Livable Future

If there is one thing that recent Supreme Court decisions, including West Virginia et al. v. Environmental Protection Agency et al. (June 30, 2022, No. 20-1530), have shown us, it is that we cannot rely on regulators, courts, and corporations to protect health and the environment and ensure a livable future. Fortunately, at least with respect to our climate and environmental crises, solutions are up and running in many communities, and have been embraced by many institutions and companies. These efforts need our support, and there is much we can do in our communities now, as we advocate for federal and international policies that take the existential environmental crises seriously and with urgency.

>>Ask your mayor or county executive to convert to organic land management in your local parks, playing fields, and other public places.

We learned in the 1970s that energy crises cannot be solved entirely at the supply end, but require changes in the way we do things—by conserving energy. Similarly, our environmental crises today cannot be solved totally by regulation alone, especially given the current political climate. We must advance new and creative approaches.

Organic food production and land management are examples of solutions that are up and running. A regulation like the one adopted by the European Union—banning all pesticides in “public parks or gardens, playgrounds, recreation or sports grounds, public paths, as well as ecologically sensitive areas” and adopting strategies for achieving the pesticide use- and risk-reduction goals in agriculture—may seem out of reach in the U.S. for now. However, we have a foundation to build on, with organic production now a more than $60 billion enterprise in this country at the same time that local communities across the nation are adopting organic land management practices and policies. 

With our future in peril, we need to chart a future that embodies a respect for life that is missing in federal regulation. Organic practices not only avoid industrial agriculture's reliance on fertilizers and pesticides made from fossil fuels, but also help to sequester carbon in the soil. With rising costs of fossil fuels, the economic advantage of organic management increasing.

>>Ask your mayor or county executive to convert to organic land management in your local parks and playing fields, and other public places.

Letter to Mayors and County Executives

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.

In the spirit of Earth Day and daily concern for the environment, 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.

Beyond Pesticides provides in-depth training to assist community land managers in transitioning two public green spaces to organic landscape management through its Parks for a Sustainable Future program (bp-dc.org/sustainable-parks). Please contact Beyond Pesticides at [email protected] to find out how our town can transition to organic.

Thank you.

07/05/2022 — Get Plastic Out of Organic!

>>Tell the National Organic Standards Board it must lead in phasing out plastic at all stages of production and handling.

Plastics are a huge environmental problem, yet organic production and handling continue to exacerbate the problem instead of solving it.

Plastic production and use aggravate the climate emergency via the production and use of plastics. Researchers have found, “The U.S. plastics industry is responsible for at least 232 million tons of CO2 gas emissions per year. This amount is equivalent to the average emissions from 116 average-sized (500-megawatt) coal-fired power plants.”

Plastic is intentionally added to organic farms in the form of mulch, netting, tree guards, plant containers, irrigation tubing, feed bags, and many other items. The largest use, and the one that has received attention by the National Organic Standards Board (NOSB) is plastic sheet mulch. 

The Organic Foods Production Act (OFPA), in recognition of current practices by organic farmers, allows non-PVC plastic mulch if it is removed at the end of the growing or harvest season. The fact that huge quantities of plastic are carted off to landfills every year from organic farms created a demand for plastic mulch that will degrade on site. As of 2014, organic growers are allowed to use “biodegradable biobased mulch film” (BBMF) which does not need to be removed. However, there are still no available products that meet the regulatory definition of biodegradable. Furthermore, while BBMF may be “biodegradable” in name, it is now apparent that it does not totally degrade, but leaves microplastic particles in the soil.

Microplastics cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals. 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 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, including reduction in growth and reproduction of soil microfauna. Microplastics serve as hotspots of gene exchange between different microorganisms, potentially increasing the spread of antibiotic resistant pathogens in water and sediments.

BBMFs are not removed from the field by the grower but are tilled into the soil, purposefully creating microplastics to be degraded by soil organisms. However, growers report that fragments persist in the soil, and research on the eventual fate of biodegradable mulch films is ongoing. Still, some research indicates 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 toxicants.

The use of natural organic materials in compost and mulch is foundational to organic production, which is intended to mimic natural ecosystems. In natural systems, plants are fed by the action of soil organisms breaking down plant residues and excreting substances that are plant nutrients. Natural mulches are the organic alternative—providing a steady diet of organic matter for soil organisms. 

The NOSB has not examined organic food packaging and placed on hold consideration of “Packaging materials including BPA.” BPA (bisphenol A) is the molecular building block for polycarbonate plastics and epoxy resins. The epoxy resins are also used as a coating for metal cans and other containers. BPA was listed as a reproductive toxicant by the state of California in 2015. The Technical Review (TR) commissioned by the National Organic Program provides further documentation of human exposure, citing studies showing that BPA leaches from the plastic linings of metal cans. BPA leaching from the linings of cans violates the prohibitions in law against the “use or reuse of any bag or container that has been in contact with any substance in such a manner as to compromise the organic integrity of any organically produced product or ingredient placed in those containers.”

Plastic packaging is a major source of environmental contamination. The National Academies of Sciences find, “Plastic containers and packaging comprise the largest fraction of the plastic waste stream (41%) and enter the waste stream most quickly after production in the year they are produced.” 

In addition to plastic used in crop production and packaging, plastics enter into every aspect of organic food production. Plastic containers, tubing, and implements may be used in processing. All these uses pose potential hazards as chemicals migrate from plastic to food. 

Eliminating plastic will not be easy, but in view of the numerous threats that are now recognized, it is important for organic production and handling to lead the way in making the transition. The NOSB should add the development of a strategy for eliminating plastic to the NOSB work agenda.

>>Tell the NOSB to get plastic out of organic.

Please note: This is a Regulations.gov action, which requires you to go to Regulations.gov and insert a comment into a form. Please copy and paste some or all of the above text, as a comment to the NOSB. The above link takes you directly to Docket # AMS-NOP-22-0042, where you can comment.

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.

 

(Photo credit: itman__47 from Getty Images)

06/27/2022 — Tell EPA to Ban the Carcinogen Glyphosate

It is now—more than ever—up to the Environmental Protection Agency (EPA) to recognize glyphosate (Roundup and other products) as a carcinogen and remove it from the market. As the Ninth Circuit Court of Appeals voided EPA's “interim registration review” decision approving continued use of glyphosate, issued in early 2020 saying, “EPA did not adequately consider whether glyphosate causes cancer and shirked its duties under the Endangered Species Act (ESA),” and the Supreme Court refused to consider (deny certiorari) a Bayer petition to save the company from being held accountable to those diagnosed with cancer after using glyphosate herbicides, EPA's failure to act speaks to the capture of the agency by the industry it is supposed to regulate.

>>Tell the EPA to ban glyphosate immediately. Tell Congress to ensure that EPA performs its job as required by law.

The Ninth Circuit court held that EPA unlawfully concluded that glyphosate does not pose a cancer risk. Despite overwhelming evidence and high profile lawsuits against Bayer—with jury verdicts against the company in the tens of millions of dollars—EPA came to “no conclusion” on glyphosate's connection to non-Hodgkin lymphoma (NHL). Notably, the agency did not assess how much glyphosate gets into a user's bloodstream after skin contact with the herbicide, a major route of exposure for the chemical. The court criticized EPA for its “disregard of tumor results;” its use of “bare assertions” that “fail[] to account coherently for the evidence;” making conclusions that do not “withstand[] scrutiny under the agency's own framework,” and “fail[ing] to abide by” its cancer guidelines. In sum the court noted EPA's “inconsistent reasoning” made its decision on cancer “arbitrary,” and struck it down. 

Meanwhile, courts have been granting large settlements to people who contracted cancer as a result of using glyphosate. In June 2020, facing approximately 125,000 suits for Roundup's role in cancer outcomes, Bayer announced a $10 billion settlement to resolve roughly 75% of current and potential future litigation; claimants who signed on to the settlement were to receive compensation and were not to pursue any additional legal action. However, roughly 30,000 complainants did not sign on to the settlement, leaving the queue of potential lawsuits potentially enormous. Seeing the writing on the wall, Bayer tried for a second settlement (of roughly $2 billion) to handle any future claims, but in 2021, a U.S. District Court judge (for the Northern District of California) rejected Bayer's settlement proposal, saying that it was inadequate for future victims diagnosed with cancer after using the herbicide.

Other evidence is mounting against glyphosate, with research showing disruption of bumblebee reproduction, negative impacts on the gut microbiome, increased greenhouse gas emissions, oxidative stress and DNA damage, body burdens, threats to endangered species, and more. If EPA is to convince citizens that it is worthy of the job entrusted to it and not captured by the pesticide industry—in particular, Bayer/Monsanto—it must do a thorough review of all the evidence that finds glyphosate to be carcinogenic.

That evidence shows that glyphosate must be banned immediately.

>>Tell the EPA to ban glyphosate immediately. Tell Congress to ensure that EPA performs its job as required by law.

Letter to EPA

It is now—more than ever—up to EPA to recognize glyphosate (Roundup and other products) as a carcinogen and remove it from the market. As the Ninth Circuit Court of Appeals voided EPA’s “interim registration review” decision approving continued use of glyphosate, issued in early 2020 saying, “EPA did not adequately consider whether glyphosate causes cancer and shirked its duties under the Endangered Species Act (ESA),” and the Supreme Court refused to consider (deny certiorari) a Bayer petition to save the company from being held accountable to those diagnosed with cancer after using glyphosate herbicides, EPA’s failure to act speaks to the capture of the agency by the industry it is supposed to regulate.

The Ninth Circuit court held that EPA unlawfully concluded that glyphosate does not pose a cancer risk. Despite overwhelming evidence and high profile lawsuits against Bayer—with jury verdicts against the company in the tens of millions of dollars—EPA came to “no conclusion” on glyphosate’s connection to non-Hodgkin lymphoma (NHL). Notably, the agency did not assess how much glyphosate gets into a user’s bloodstream after skin contact with the herbicide, a major route of exposure for the chemical. The court criticized EPA for its “disregard of tumor results;” its use of “bare assertions” that “fail[] to account coherently for the evidence;” making conclusions that do not “withstand[] scrutiny under the agency’s own framework,” and “fail[ing] to abide by” its cancer guidelines. In sum the court noted EPA’s “inconsistent reasoning” made its decision on cancer “arbitrary,” and struck it down.

Meanwhile, courts have been granting large settlements to people who contracted cancer as a result of using glyphosate. In June 2020, facing approximately 125,000 suits for Roundup’s role in cancer outcomes, Bayer announced a $10 billion settlement to resolve roughly 75% of current and potential future litigation; claimants who signed on to the settlement were to receive compensation and were not to pursue any additional legal action. However, roughly 30,000 complainants did not sign on to the settlement, leaving the queue of potential lawsuits potentially enormous. Seeing the writing on the wall, Bayer tried for a second settlement (of roughly $2 billion) to handle any future claims, but in 2021, a U.S. District Court judge (for the Northern District of California) rejected Bayer’s settlement proposal, saying that it was inadequate for future victims diagnosed with cancer after using the herbicide.

Other evidence is mounting against glyphosate, with research showing disruption of bumblebee reproduction, negative impacts on the gut microbiome, increased greenhouse gas emissions, oxidative stress and DNA damage, body burdens, threats to endangered species, and more. If EPA is to convince citizens that it is worthy of the job entrusted to it and not captured by the pesticide industry—in particular, Bayer/Monsanto—it must do a thorough review of all the evidence that finds glyphosate to be carcinogenic.

Please ban glyphosate immediately.

Thank you.

Letter to Congress

Please ensure that the Environmental Protection Agency (EPA) performs its job as required by law.

It is now—more than ever—up to EPA to recognize glyphosate (Roundup and other products) as a carcinogen and remove it from the market. As the Ninth Circuit Court of Appeals voided EPA’s “interim registration review” decision approving continued use of glyphosate, issued in early 2020 saying, “EPA did not adequately consider whether glyphosate causes cancer and shirked its duties under the Endangered Species Act (ESA),” and the Supreme Court refused to consider (deny certiorari) a Bayer petition to save the company from being held accountable to those diagnosed with cancer after using glyphosate herbicides, EPA’s failure to act speaks to the capture of the agency by the industry it is supposed to regulate.

The Ninth Circuit court held that EPA unlawfully concluded that glyphosate does not pose a cancer risk. Despite overwhelming evidence and high profile lawsuits against Bayer—with jury verdicts against the company in the tens of millions of dollars—EPA came to “no conclusion” on glyphosate’s connection to non-Hodgkin lymphoma (NHL). Notably, the agency did not assess how much glyphosate gets into a user’s bloodstream after skin contact with the herbicide, a major route of exposure for the chemical. The court criticized EPA for its “disregard of tumor results;” its use of “bare assertions” that “fail[] to account coherently for the evidence;” making conclusions that do not “withstand[] scrutiny under the agency’s own framework,” and “fail[ing] to abide by” its cancer guidelines. In sum the court noted EPA’s “inconsistent reasoning” made its decision on cancer “arbitrary,” and struck it down.

Meanwhile, courts have been granting large settlements to people who contracted cancer as a result of using glyphosate. In June 2020, facing approximately 125,000 suits for Roundup’s role in cancer outcomes, Bayer announced a $10 billion settlement to resolve roughly 75% of current and potential future litigation; claimants who signed on to the settlement were to receive compensation and were not to pursue any additional legal action. However, roughly 30,000 complainants did not sign on to the settlement, leaving the queue of potential lawsuits potentially enormous. Seeing the writing on the wall, Bayer tried for a second settlement (of roughly $2 billion) to handle any future claims, but in 2021, a U.S. District Court judge (for the Northern District of California) rejected Bayer’s settlement proposal, saying that it was inadequate for future victims diagnosed with cancer after using the herbicide.

Other evidence is mounting against glyphosate, with research showing disruption of bumblebee reproduction, negative impacts on the gut microbiome, increased greenhouse gas emissions, oxidative stress and DNA damage, body burdens, threats to endangered species, and more. If EPA is to convince citizens that it is worthy of the job entrusted to it and not captured by the pesticide industry—in particular, Bayer/Monsanto—it must do a thorough review of all the evidence that finds glyphosate to be carcinogenic.

Please ensure that EPA bans glyphosate immediately.

Thank you.

06/20/2022 — Protect Pollinators, Biodiversity, and Our Food Supply During Pollinator Week

June 20-24 is Pollinator Week, during which we recognize—and take action to protect—this important ecosystem link. Pollinators––bees, butterflies, birds, bats, and other organisms––make a critical contribution to plant health, crop productivity, and the preservation of natural resources, but their existence is threatened by their pesticide-contaminated habitat. Pesticides have consistently been implicated as a key contributor to dramatic pollinator declines. Of the 100 crop varieties that provide 90% of the world's food, 71 are pollinated by bees. Honey bees alone pollinate 95 kinds of fruits, nuts and vegetables, such as apples, avocados, almonds, and cranberries.

>>Take action to protect pollinators.

Providing protection for pollinators also protects the ecosystem in which they live. That protection requires eliminating harm as well as providing safe habitats where they can live and reproduce. 

Provide organic habitat on your own property and encourage your town to go organic. Since 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. In partnership with major retailers like Natural Grocers and Stonyfield Organic, the Beyond Pesticides' Parks for a Sustainable Future program provides in-depth training and demonstration sites to assist community land managers in transitioning public green spaces to organic landscape management, while aiming to provide the knowledge and skills necessary to eventually transition all public areas in a locality to these sustainable and safe practices. Through this program, Beyond Pesticides is now assisting local leaders and municipal landscapers to convert parks and recreational areas across the country to exclusively organic practices, which eliminate the use of synthetic pesticides and fertilizers.

Tell your U.S. Representative and Senators to support the Saving America's Pollinators Act. By introducing this critical piece of legislation, U.S. Representative Earl Blumenauer (D-OR) continues the fight against to protect pollinators in the face of the vested economic interests of chemical companies, chemical service industry, and an unresponsive U.S. Environmental Protection Agency (EPA). And as a result of pollinator heroes like yourself, they've already enlisted 73 cosponsors to join the effort. The bill has not yet been introduced in the Senate, so Senate sponsors are needed.

Saving America's Pollinators Act (H.R.4079) will not only cancel specific bee-toxic pesticides, it will reshape the EPA process for permitting pesticides to be used in our communities and homes in the first place. Current law is filled with language that allows chemical lobbyists to unduly influence EPA decisions and loopholes that favor pesticide dependency instead of incentivizing alternatives like organic practices and products. 

Under SAPA, pesticides that pose risks to pollinators will undergo a higher level of review by a board of unbiased pollinator experts. If these experts, who will not have conflicts of interest with the chemical industry, determine a pesticide is too toxic, then it will be removed or never allowed on the market in the first place. 

SAPA creates a sustainable model for pollinator protection, including an annual, ongoing review on the health of pollinator populations. In the face of an EPA captured by chemical company corruption, SAPA will become an important tool to prevent ongoing chemical crimes against pollinators and the environment.

Tell Kroger to adopt a pollinator protection policy that adequately addresses toxic pesticide use. Kroger's competitors are taking action on pollinator health. Walmart announced an industry-leading policy to protect pollinators from pesticides. In 2020, Giant Eagle announced a commitment to eliminate pollinator-toxic neonicotinoid pesticides from its produce supply chain. Kroger should take similar steps to protect pollinators.

Independent laboratory testing of items that children and families typically eat, including cereal, apples, applesauce, spinach, and pinto beans, finds that Kroger's private-label foods contain toxic pesticides—glyphosate, organophosphates, and neonicotinoids. These pesticides are linked to adverse human health impacts ranging from increased risk of cancer and infertility to harm to children's developing brains and endocrine disruption. They are also associated with harm to bees and other pollinators.

Tell the Environmental Protection Agency (EPA) and President Biden 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.

>>Take action to protect pollinators.

Letter to President Biden and EPA

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.

I 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 is 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 U.S. House of Representatives

In order to reverse the devastating declining in the U.S. pollinator populations, your support of H.R.4079, Saving America’s Pollinators Act (SAPA) is urgently needed.

While EPA updated its guidelines for pollinator risk assessments in 2014, the agency continues to either fail to conduct full assessments or dismiss concerning data it receives. EPA appears to discount threats like the insect apocalypse, evidenced by a 75% decline in insect abundance, which threatens not only global ecosystems, but also food production that depends on animal pollination. As pesticides move through the food web, bird numbers are down 29% since Rachel Carson wrote Silent Spring in 1962.

The problem is highlighted by EPA’s recent Interim Decision on fenbuconazole, in which the agency notes that, “For larval bees, RQs (risk quotients) exceed the LOC (level of concern) for all pollinator attractive uses including when assessed at the lowest application rate of 0.0938 lb a.i./Acre (RQ = 1.1).” Yet in the same document, the agency declares that “…the benefits of fenbuconazole (e.g., efficacy in management of fungal pathogens) outweigh any remaining risk and that continuing to register fenbuconazole provides significant benefits, including its ability to increase crop yields and help with resistance management.” While the agency added additional restrictive language on spray drift, it implemented no new precautionary measures for pollinators. With the only indications that this chemical is dangerous to pollinators deep in EPA’s dense review documents the public rarely if ever reads, the agency continues to fail pollinators, farmers, and the public.

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.

SAPA 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, the pesticide would be removed from market or not permitted for sale in the first place. In the face of ongoing EPA inaction, 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.

Please support pollinators by cosponsoring H.R.4079, Saving America’s Pollinators Act.

Thank you.

Letter to Bill Sponsor/Co-Sponsors

Thank you for being a pollinator hero and co-sponsoring H.R.4079, Saving America’s Pollinators Act (SAPA).

While EPA updated its guidelines for pollinator risk assessments in 2014, the agency continues to either fail to conduct full assessments or dismiss concerning data it receives. EPA appears to discount threats like the insect apocalypse, evidenced by a 75% decline in insect abundance, which threatens not only global ecosystems, but also food production that depends on animal pollination. As pesticides move through the food web, bird numbers are down 29% since Rachel Carson wrote Silent Spring in 1962.

The problem is highlighted by EPA’s recent Interim Decision on fenbuconazole, in which the agency notes that, “For larval bees, RQs (risk quotients) exceed the LOC (level of concern) for all pollinator attractive uses including when assessed at the lowest application rate of 0.0938 lb a.i./Acre (RQ = 1.1).” Yet in the same document, the agency declares that “…the benefits of fenbuconazole (e.g., efficacy in management of fungal pathogens) outweigh any remaining risk and that continuing to register fenbuconazole provides significant benefits, including its ability to increase crop yields and help with resistance management.” While the agency added additional restrictive language on spray drift, it implemented no new precautionary measures for pollinators. With the only indications that this chemical is dangerous to pollinators deep in EPA’s dense review documents the public rarely if ever reads, the agency continues to fail pollinators, farmers, and the public.

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.

SAPA 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 ongoing EPA inaction, 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.

Letter to U.S. Senate

In order to reverse the devastating declining in the U.S. pollinator populations, your support of H.R.4079, Saving America’s Pollinators Act (SAPA) is urgently needed. Although SAPA has 74 cosponsors in the House of Representatives, it has not yet been introduced in the Senate. Please be the supporter that pollinators need by introducing SAPA in the Senate.

While EPA updated its guidelines for pollinator risk assessments in 2014, the agency continues to either fail to conduct full assessments or dismiss concerning data it receives. EPA appears to discount threats like the insect apocalypse, evidenced by a 75% decline in insect abundance, which threatens not only global ecosystems, but also food production that depends on animal pollination. As pesticides move through the food web, bird numbers are down 29% since Rachel Carson wrote Silent Spring in 1962.

The problem is highlighted by EPA’s recent Interim Decision on fenbuconazole, in which the agency notes that, “For larval bees, RQs (risk quotients) exceed the LOC (level of concern) for all pollinator attractive uses including when assessed at the lowest application rate of 0.0938 lb a.i./Acre (RQ = 1.1).” Yet in the same document, the agency declares that “…the benefits of fenbuconazole (e.g., efficacy in management of fungal pathogens) outweigh any remaining risk and that continuing to register fenbuconazole provides significant benefits, including its ability to increase crop yields and help with resistance management.” While the agency added additional restrictive language on spray drift, it implemented no new precautionary measures for pollinators. With the only indications that this chemical is dangerous to pollinators deep in EPA’s dense review documents the public rarely if ever reads, the agency continues to fail pollinators, farmers, and the public.

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.

SAPA 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, the pesticide would be removed from market or not permitted for sale in the first place. In the face of ongoing EPA inaction, 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.

Please be the supporter that pollinators need by introducing SAPA in the Senate.

Thank you.

Letter to Kroger CEO

Planet Earth is suffering mortal attacks. Scientists warn we are facing an ‘insect apocalypse’ largely driven by toxic pesticides as 40% of invertebrate pollinators face extinction, posing serious material risks for the grocery industry. Declines in pollinator populations have already resulted in decreased production of key crops like apples, cherries and tomatoes while food costs are predicted to rise. Studies show that organic farming can help reverse pollinator declines while making the food system more resilient.

Friends of the Earth’s 2021 Bee-Friendly Retailer Scorecard, which analyzes 25 of the largest U.S. grocery stores, gave Kroger a dismal D- rating, noting that Kroger has failed to take any meaningful action since it created an initial pollinator health policy in 2019. Unlike competitors such as Walmart and Giant Eagle, Kroger’s policy does not include any measurable targets to reduce pesticides or to expand ecological farming methods in its supply chain to protect pollinators.

Please eliminate products foods and beverages produced with toxic pesticides this year and replace them with organic products.

Thank you.

06/13/2022 — Give Migrating Birds a Hand

Birds are beautiful. They fill our world with color, song, and acrobatics. Most songbirds eat insects during the nesting season, thus contributing to management of insects in crops and gardens. It is no wonder that Rachel Carson chose their absence as an indicator of ecosystem collapse in Silent Spring.

>>Tell your U.S. Senators to cosponsor S. 4187, the Neotropical Migratory Bird Conservation Enhancements Act. Tell your U.S. Senators and Representative to ensure that EPA does not allow pesticides that threaten birds or their insect food supply.

It's not always easy to be a bird. About half of the world's bird species migrate up to tens of thousands of miles each year. Whether at home or on the way to warmer climates for the winter, birds face harsh weather conditions, barriers like windows and radio towers, and the problem of storing enough energy for the flight in a tiny body. About 72 million birds are killed by pesticides and other toxic chemicals every year. In addition, pesticide use has contributed to the collapse of insect populations—the source of protein and fat that birds need to raise their young.

Congress has passed laws to help prevent a “silent spring”—including the Migratory Bird Treaty Act and the Endangered Species Act. In spite of these laws, birds continue to be at risk. U.S. Senators Ben Cardin (D-MD) and Rob Portman (R-OH) have just introduced S. 4187 to enhance the Neotropical Migratory Bird Conservation Act (NMBCA). The NMBCA is an innovative and cost-effective approach to the conservation of the more than 350 neotropical bird species in the U.S. that travel to Central and South America, the Caribbean, and Canada every year, such as the Scarlet Tanager, Purple Martin, and Baltimore Oriole. It supports the conservation of bird habitat as well as research, monitoring, outreach, and education.  

As a matching grant program, it catalyzes funding from a range of sources beyond the U.S. government and will triple the investment NMBCA can make in on-the-ground habitat protection, restoration, education, and research, ensuring that those funds are leveraged by other governments and partners. It will also provide greater capacity to implement the grant program by raising the amount the Fish and Wildlife Service can allocate toward managing it. 

>>Tell your U.S. Senators to cosponsor S. 4187, the Neotropical Migratory Bird Conservation Enhancements Act. Tell your U.S. Senators and Representative to ensure that EPA does not allow pesticides that threaten birds or their insect food supply.

Letter to U.S. Senate

 

Birds are beautiful. They fill our world with color, song, and acrobatics. Most songbirds eat insects during the nesting season, thus contributing to management of insects in crops and gardens. It is no wonder that Rachel Carson chose their absence as an indicator of ecosystem collapse in Silent Spring.

It’s not always easy to be a bird. About half of the world’s bird species migrate up to tens of thousands of miles each year. Whether at home or on the way to warmer climates for the winter, birds face harsh weather conditions, barriers like windows and radio towers, and the problem of storing enough energy for the flight in a tiny body. About 72 million birds are killed by pesticides and other toxic chemicals every year. In addition, pesticide use has contributed to the collapse of insect populations—the source of protein and fat that birds need to raise their young.

Congress has passed laws to help prevent a “silent spring”—including the Migratory Bird Treaty Act and the Endangered Species Act. In spite of these laws, birds continue to be at risk. Senators Ben Cardin (D-MD) and Rob Portman (R-OH) have just introduced S. 4187 to enhance the Neotropical Migratory Bird Conservation Act (NMBCA). The NMBCA is an innovative and cost-effective approach to the conservation of the more than 350 neotropical bird species in the U.S. that travel to Central and South America, the Caribbean, and Canada every year, such as the Scarlet Tanager, Purple Martin, and Baltimore Oriole. It supports the conservation of bird habitat as well as research, monitoring, outreach, and education.

As a matching grant program, it catalyzes funding from a range of sources beyond the U.S. government and will triple the investment NMBCA can make in on-the-ground habitat protection, restoration, education, and research, ensuring that those funds are leveraged by other governments and partners. It will also provide greater capacity to implement the grant program by raising the amount the Fish and Wildlife Service can allocate toward managing it.

Please cosponsor S. 4187 and ensure by your oversight that EPA does not allow pesticides that threaten birds or their insect food supply.

Thank you.

Letter to Bill Sponsors

Thank you for cosponsoring S. 4187, the Neotropical Migratory Bird Conservation Enhancements Act.

Birds are beautiful. They fill our world with color, song, and acrobatics. Most songbirds eat insects during the nesting season, thus contributing to management of insects in crops and gardens. It is no wonder that Rachel Carson chose their absence as an indicator of ecosystem collapse in Silent Spring.

It’s not always easy to be a bird. About half of the world’s bird species migrate up to tens of thousands of miles each year. Whether at home or on the way to warmer climates for the winter, birds face harsh weather conditions, barriers like windows and radio towers, and the problem of storing enough energy for the flight in a tiny body. About 72 million birds are killed by pesticides and other toxic chemicals every year. In addition, pesticide use has contributed to the collapse of insect populations—the source of protein and fat that birds need to raise their young.

Congress has passed laws to help prevent a “silent spring”—including the Migratory Bird Treaty Act and the Endangered Species Act. In spite of these laws, birds continue to be at risk. The Neotropical Migratory Bird Conservation Act (NMBCA). The NMBCA is an innovative and cost-effective approach to the conservation of the more than 350 neotropical bird species in the U.S. that travel to Central and South America, the Caribbean, and Canada every year, such as the Scarlet Tanager, Purple Martin, and Baltimore Oriole. It supports the conservation of bird habitat as well as research, monitoring, outreach, and education.

As a matching grant program, it catalyzes funding from a range of sources beyond the U.S. government and will triple the investment NMBCA can make in on-the-ground habitat protection, restoration, education, and research, ensuring that those funds are leveraged by other governments and partners. It will also provide greater capacity to implement the grant program by raising the amount the Fish and Wildlife Service can allocate toward managing it.

Thank you for championing S. 4187.

Letter to U.S. House of Representatives

 

Birds are beautiful. They fill our world with color, song, and acrobatics. Most songbirds eat insects during the nesting season, thus contributing to management of insects in crops and gardens. It is no wonder that Rachel Carson chose their absence as an indicator of ecosystem collapse in Silent Spring.

It’s not always easy to be a bird. About half of the world’s bird species migrate up to tens of thousands of miles each year. Whether at home or on the way to warmer climates for the winter, birds face harsh weather conditions, barriers like windows and radio towers, and the problem of storing enough energy for the flight in a tiny body. About 72 million birds are killed by pesticides and other toxic chemicals every year. In addition, pesticide use has contributed to the collapse of insect populations—the source of protein and fat that birds need to raise their young.

Congress has passed laws to help prevent a “silent spring”—including the Migratory Bird Treaty Act and the Endangered Species Act. In spite of these laws, birds continue to be at risk. Senators Ben Cardin (D-MD) and Rob Portman (R-OH) have just introduced S. 4187 to enhance the Neotropical Migratory Bird Conservation Act (NMBCA). The NMBCA is an innovative and cost-effective approach to the conservation of the more than 350 neotropical bird species in the U.S. that travel to Central and South America, the Caribbean, and Canada every year, such as the Scarlet Tanager, Purple Martin, and Baltimore Oriole. It supports the conservation of bird habitat as well as research, monitoring, outreach, and education.

As a matching grant program, it catalyzes funding from a range of sources beyond the U.S. government and will triple the investment NMBCA can make in on-the-ground habitat protection, restoration, education, and research, ensuring that those funds are leveraged by other governments and partners. It will also provide greater capacity to implement the grant program by raising the amount the Fish and Wildlife Service can allocate toward managing it.

Please ensure by your oversight that EPA does not allow pesticides that threaten birds or their insect food supply. Support S. 4187 when it reaches the House of Representatives.

Thank you.

06/06/2022 — Protect the Dungeness National Wildlife Refuge from Becoming a Commercial Shellfish Aquaculture Operation

In spite of the known harm to migratory and residential birds, salmon, forage fish, other wildlife and their primary feeding areas, and a recommendation by the National Marine Fisheries Service that “an alternative site be identified in a location that results in less potential impacts to wildlife that is more appropriate for aquaculture and meets the goals of the tribe," permitting agencies approved permits and a lease for a 50-acre industrial oyster farm for private financial gain inside the Dungeness National Wildlife Refuge. This decision, which is in violation of the Clean Water Act and the Migratory Bird Treaty Act, must be reversed.

Agencies are well aware of the potential damage to the lands it is their mission to protect.

>>Tell the Washington State Department of Natural Resources and the U.S. Fish and Wildlife Service that the Dungeness National Wildlife lease must be rescinded.

The Dungeness Bay Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” The Refuge provides habitat, a preserve and breeding grounds for more than 250 species of birds and 41 species of land animals. 

The front page of the Refuge website states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture. 

These detrimental effects to the Dungeness National Wildlife Refuge are NOT minimal. Among the negative impacts of this project are: 50% reduction in bird primary feeding grounds;  20,000 – 80,000 toxic plastic oyster bags that exclude the probing shorebird flocks from feeding deeply into the substrate, entrapment of fish and birds, add macro- and micro-plastic bits to the sediment throughout the refuge, and shift the benthic community composition; diminishment of the ecological benefits provided by eelgrass to threatened fish and birds, such as nourishment and cover from predators and, with warming waters, increased toxic algal blooms that will leave a graveyard of dead oysters. Additionally, commercial shellfish operations attract pathogens and non-native species that threaten the area ecosystem and the shellfish. Decision makers should not place financial benefits to the corporation above the long term and cumulative impacts to the refuge.

>>Tell the Washington State Department of Natural Resources and the U.S. Fish and Wildlife Service that the Dungeness National Wildlife lease must be rescinded.

Letter to Washington State

I am writing to ask that your agency rescind the lease from the Jamestown S’Klallam Tribe to reestablish oyster farming in the Dungeness National Wildlife Refuge. They have four other sites, one of which has space to expand.

In spite of the U.S. Corps of Engineers predicted harm to the Refuge birds, salmon, forage fish, and other wildlife, and a recommendation by the National Marine Fisheries Service that “an alternative site be identified in a location that results in less potential impacts to wildlife that is more appropriate for aquaculture and meets the goals of the tribe," permitting agencies approved an industrial oyster farm inside the Dungeness National Wildlife Refuge. This decision, which is in violation of the Clean Water Act and the Migratory Bird Treaty Act, must be reversed.

The Dungeness Bay Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” The front page of the Refuge website states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture.

Industrial shellfish aquaculture is known to reduce or eliminate eelgrass. Shifts in the sediment from the thousands of bottom bags containing the oysters will damage the eelgrass beds. This shellfish operation involves large-scale use of plastics that are hazardous to marine organisms and can trap and entangle wildlife. Commercial shellfish aquaculture, already a major industry in Washington State, has significant impacts on the nearshore marine environments, which provide essential habitat for many species, including invertebrates, fish (including herring and salmon), and birds (migratory and shorebirds).

The U.S. Army Corps of Engineers predicts the negative impacts of this project are: 50% reduction in bird primary feeding grounds; plastic oyster bags that exclude the probing shorebird flocks from feeding deeply into the substrate, entrap fish and birds, add macro- and micro-plastic bits to the sediment throughout the refuge, and shift the benthic community composition; diminishing of the ecological benefits provided by eelgrass to threatened fish and birds, such as nourishment and cover from predators; and increased algal blooms that will leave a graveyard of dead oysters. These detrimental effects to the Dungeness Bay National Refuge are NOT minimal. Decision makers should not place financial benefits to the corporation above the long term and cumulative impacts to the refuge.

Please revoke the lease and prevent damage to the wildlife refuge and the harm that would come to the wildlife that depend on it.

Thank you.

Letter to U.S. Fish and Wildlife Service

I am writing to ask that your agency reinstate your opposition to establish oyster farming in Dungeness Bay.

In spite of demonstrated harm to birds, salmon, forage fish, and shellfish, and a recommendation by the National Marine Fisheries Service that “an alternative site be identified in a location that results in less potential impacts to wildlife that is more appropriate for aquaculture and meets the goals of the tribe," permitting agencies approved a lease for an industrial oyster farm inside the Dungeness National Wildlife Refuge. This decision, which is in violation of the Clean Water Act and the Migratory Bird Treaty Act, must be reversed.

The Dungeness Bay Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” The front page of the Refuge website states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture.

Among the negative impacts of this project, as predicted by the U.S. Army Corps of Engineers are: 50% reduction in bird primary feeding grounds; toxic plastic oyster bags that exclude the probing shorebird flocks from feeding deeply into the substrate, entrap fish and birds, add macro- and micro-plastic bits to the sediment throughout the refuge, and shift the benthic community composition; diminish the ecological benefits provided by eelgrass to threatened fish and birds, such as nourishment and cover from predators; and increased algal blooms that will leave a graveyard of dead oysters. These detrimental effects to the Dungeness Bay National Refuge are NOT minimal. Decision makers should not place financial benefits to the corporation above the long term and cumulative impacts to the refuge.

Your mission is to protect refuges. Please reinstate USFWS opposition to the lease and prevent damage to the wildlife refuge and the harm that would come to the wildlife that depend on it.

Thank you.

05/30/2022 — Show Your Support for Veterans Harmed by Toxic Chemical Exposure

This Memorial Day, ask the U.S. government to show respect for veterans by recognizing Gulf War Illness (GWI) and honoring our commitment to those who have served the country. New research is providing strong causal evidence that Gulf War Illness (GWI) is the result of exposure to sarin gas, an organophosphate nerve agent, when Iraqi chemical weapons storage and production facilities were bombed during the Gulf War. The findings, published earlier this month in Environmental Health Perspectives, have important implications for the hundreds of thousands of American service members suffering from a constellation of chronic symptoms without a true understanding of how they became sick. “Quite simply, our findings prove that Gulf War Illness was caused by sarin, which was released when we bombed Iraqi chemical weapons storage and production facilities,” said Robert Haley, MD, lead author of the study and epidemiologist at University of Texas Southwestern. “There are still more than 100,000 Gulf War veterans who are not getting help for this illness and our hope is that these findings will accelerate the search for better treatment.”

>>Tell the Secretary of Veterans Affairs and the U.S. Senate to provide disability benefits to those veterans suffering from Gulf War Illness.

Veterans of the Gulf War are still fighting for care. A 2017 Government Accountability Office report found that 80% of Gulf War veteran disability claims are denied by U.S. Veteran's Affairs. GWI claims are approved at a rate roughly three times lower than all other potential claimed disabilities. With strong data now on the cause, VA must move rapidly to ensure American veterans get the treatment they deserve.

Veterans dealing with Gulf War Illness have described a range of ongoing symptoms, from fever to fatigue, headaches, night sweats and insomnia, difficulty finding words, issues with concentration and retaining information, sexual dysfunction, respiratory problems, dizziness, skin rashes, joint and body pain and diarrhea and indigestion. The U.S. Department of Veterans Affairs refers to the illness as a “chronic multisymptom illness.”

A bill in the U.S. House of Representatives, H.R. 3967, Honoring Our Promise to Address Comprehensive Toxics Act of 2021 (with 100 cosponsors—97 Democrats, 3 Republicans), which passed the House in March, 2022, and was sent to the Senate, would provide broad coverage for toxic exposure during military service, combining 15 previous bills. The Senate has not taken up this legislation. S. 1039, improving compensation for disabilities occurring in Persian Gulf War veterans, was introduced by Senator Robert Menendez (D-NJ).

>>Tell the Secretary of Veterans Affairs and the U.S. Senate to provide disability benefits to those veterans suffering from Gulf War Illness.

Letter to VA Secretary

This Memorial Day, please ensure that the U.S. government shows respect for veterans by recognizing Gulf War Illness (GWI) and honoring our commitment to those who have served the country. New research is providing strong causal evidence that Gulf War Illness (GWI) is the result of exposure to sarin gas, an organophosphate nerve agent, when Iraqi chemical weapons storage and production facilities were bombed during the Gulf War.
The findings, published earlier this month in Environmental Health Perspectives, have important implications for the hundreds of thousands of American service members suffering from a constellation of chronic symptoms without a true understanding of how they became sick. “Quite simply, our findings prove that Gulf War illness was caused by sarin, which was released when we bombed Iraqi chemical weapons storage and production facilities,” said Robert Haley, MD, lead author of the study and epidemiologist at University of Texas Southwestern. “There are still more than 100,000 Gulf War veterans who are not getting help for this illness and our hope is that these findings will accelerate the search for better treatment.”

Veterans of the Gulf War are still fighting for care. A 2017 Government Accountability Office report found that 80% of Gulf War veteran disability claims are denied by U.S. Veteran’s Affairs. GWI claims are approved at a rate roughly three times lower than all other potential claimed disabilities. With strong data now on the cause, VA must move rapidly to ensure American veterans get the treatment they deserve.

Veterans dealing with Gulf War Illness have described a range of ongoing symptoms, from fever to fatigue, headaches, night sweats and insomnia, difficulty finding words, issues with concentration and retaining information, sexual dysfunction, respiratory problems, dizziness, skin rashes, joint and body pain and diarrhea and indigestion. The U.S. Department of Veterans Affairs refers to the illness as a “chronic multisymptom illness.”

Please take action immediately to fully serve with health care and disability benefits the veterans who have served our country.

Thank you.

Letter to U.S. Senate

This Memorial Day, please ensure that the U.S. government shows respect for veterans by recognizing Gulf War Illness (GWI) and honoring our commitment to those who have served the country. New research is providing strong causal evidence that Gulf War Illness (GWI) is the result of exposure to sarin gas, an organophosphate nerve agent, when Iraqi chemical weapons storage and production facilities were bombed during the Gulf War. The findings, published earlier this month in Environmental Health Perspectives, have important implications for the hundreds of thousands of American service members suffering from a constellation of chronic symptoms without a true understanding of how they became sick. “Quite simply, our findings prove that Gulf War illness was caused by sarin, which was released when we bombed Iraqi chemical weapons storage and production facilities,” said Robert Haley, MD, lead author of the study and epidemiologist at University of Texas Southwestern. “There are still more than 100,000 Gulf War veterans who are not getting help for this illness and our hope is that these findings will accelerate the search for better treatment.”

Veterans of the Gulf War are still fighting for care. A 2017 Government Accountability Office report found that 80% of Gulf War veteran disability claims are denied by U.S. Veteran’s Affairs. GWI claims are approved at a rate roughly three times lower than all other potential claimed disabilities. With strong data now on the cause, VA must move rapidly to ensure American veterans get the treatment they deserve.

Veterans dealing with Gulf War Illness have described a range of ongoing symptoms, from fever to fatigue, headaches, night sweats and insomnia, difficulty finding words, issues with concentration and retaining information, sexual dysfunction, respiratory problems, dizziness, skin rashes, joint and body pain and diarrhea and indigestion. The U.S. Department of Veterans Affairs refers to the illness as a “chronic multisymptom illness.”

Please take action immediately to fully serve the veterans who have served the country by taking up H.R. 3967, Honoring Our Promise to Address Comprehensive Toxics Act of 2021, which passed the House in March, 2022 and was sent to the Senate for consideration. Also, please cosponsor S. 1039, improving compensation for disabilities occurring in Persian Gulf War veterans, which was introduced by Senator Robert Menendez (D-NJ).

Please show your support of veterans with action by supporting desperately needed health care and disability benefits for illnesses contracted during their service to our country.

Thank you.

 

05/23/2022 — “Invasive” Plants Must be Managed Under an Organic System

Chemical Control is Dangerous and Doesn't Work

The climate change-induced increase in wildfire frequency and intensity has lent new urgency to efforts to manage so-called “invasive” plants. Unfortunately, the herbicide-based approach favored by many is both counterproductive and hazardous. It must be replaced by an organic system, incorporating biological control agents like goats and establishing a more resilient ecology.

>>Tell your county/city officials to replace herbicides with integrated, ecologically based management. Tell EPA and Congress that herbicides must be evaluated in the context of the availability of alternative rangeland and wildland management systems.

Use of the herbicide indaziflam is an example of the ineffectiveness of management based on herbicides. While indaziflam is considered a “selective” herbicide, it actually kills and prevents germination of a wide range of broad-leaved plants and grasses and comes close to being a soil sterilant. The action on seedlings is long-lasting, thus inhibiting the growth and establishment of a resilient plant community that is resistant to invasion. Given its persistence and nonselective action and the extent of the damage it causes to native soil seed banks and plant biodiversity, indaziflam could contribute to the eventual ecological collapse of ecosystems where it's applied, similar to the cascading impacts of the systemic insecticides, fipronil and the neonicotinoids on animals. The impacts of indaziflam could be even greater than insecticides since plants are the foundation of all living systems.  Building resilience and resistance into a plant community requires working with succession, which requires the growth of some annuals, in preparation for the longer term community of mostly perennials—contrary to the approach of killing all “weeds.”

As one might expect from an herbicide with such wide-ranging effects, indaziflam—which was promoted and used for 10 years with an incomplete (“conditional”) registration—has serious and pervasive ecological impacts. Plants are the foundation of both terrestrial and aquatic food chains, and thus impacts of this long-lasting herbicide reverberate through the ecosystem. In spite of these risks, EPA considers registration of indaziflam to be “in the public interest.” EPA's conclusion is based on considerations that do not include alternative management systems— or, indeed, the inadequacies of the management systems in which it is used. No determination weighing risks and benefits can be adequate if it does not consider the conditions under which the user decides to use it.

In addition to the substantial negative ecological impacts, indaziflam's health effects are also significant. The nervous system is the major target for toxicity in mammals. Evidence of neurotoxicity (e.g., decreased motor activity, clinical signs, and neuropathology) was observed in rats and dogs, in acute, subchronic, and chronic toxicity studies. Organs affected by indaziflam in mice and rats include the kidney, liver, thyroid, stomach, seminal vesicles, and ovaries. Adverse effects on the thyroid indicating potential endocrine disruption include increased thyroid stimulating hormone (TSH) and thyroid histopathology. Chronic exposures also led to atrophied small seminal vesicles (which produce semen) in male rats and glandular erosion/necrosis in the stomach and blood-filled ovarian cysts/follicles in female mice. Developmental toxicity is evidenced by decreased fetal weight with decreased maternal body weight gain and food consumption. Decreased pup weight and delays in sexual maturation were observed in offspring in the rat two-generation reproductive toxicity study, along with clinical signs of toxicity, at a dose causing parental toxicity.

Herbicide treatments should be replaced by organic management. Organic vegetation management occurs within a system of defined parameters, which determine which materials may be used. In the case of vegetation control for fire management, many have found that no synthetic chemicals are needed—that goats can provide both vegetation removal and soil preparation. Although overgrazing with cattle can contribute to “invasive” plant problems by creating bare spots for them to colonize, well-managed cattle grazing can reduce exotic annual grasses that pose a fire hazard.

>>Tell your county/city officials to replace herbicides with integrated, ecologically based management. Tell EPA and Congress that herbicides must be evaluated in the context of the availability of alternative rangeland and wildland management systems.

Letter to Congress

The climate change-induced increase in wildfire frequency and intensity has lent new urgency to efforts to manage so-called “invasive” plants. Unfortunately, the herbicide-based approach favored by many is both counterproductive and hazardous. It must be replaced by an organic system, incorporating biological control agents like goats and establishing a more resilient ecology.

Use of the herbicide indaziflam is an example of the ineffectiveness of management based on herbicides. While indaziflam is considered a “selective” herbicide, it actually kills and prevents germination of a wide range of broad-leaved plants and grasses and comes close to being a soil sterilant. The action on seedlings is long-lasting, thus inhibiting the growth and establishment of a resilient plant community that is resistant to invasion. Given its persistence and nonselective action and the extent of the damage it causes to native soil seed banks and plant biodiversity, indaziflam could contribute to the eventual ecological collapse of ecosystems where it’s applied, similar to the cascading impacts of the systemic insecticides, fipronil and the neonicotinoids on animals. The impacts of indaziflam could be even greater than insecticides since plants are the foundation of all living systems. Building resilience and resistance into a plant community requires working with succession, which requires the growth of some annuals, in preparation for the longer term community of mostly perennials—contrary to the approach of killing all “weeds.”

As one might expect from an herbicide with such wide-ranging effects, indaziflam—which was promoted and used for 10 years with an incomplete (“conditional”) registration—has serious and pervasive ecological impacts. Plants are the foundation of both terrestrial and aquatic food chains, and thus impacts of this long-lasting herbicide reverberate through the ecosystem. In spite of these risks, EPA considers registration of indaziflam to be “in the public interest.” EPA’s conclusion is based on considerations that do not include alternative management systems— or, indeed, the inadequacies of the management systems in which it is used. No determination weighing risks and benefits can be adequate if it does not consider the conditions under which the user decides to use it.

Herbicide treatments should be replaced by organic management. Organic vegetation management occurs within a system of defined parameters, which determine which materials may be used. In the case of vegetation control for fire management, many have found that no synthetic chemicals are needed—that goats can provide both vegetation removal and soil preparation. Although overgrazing with cattle can contribute to “invasive” plant problems by creating bare spots for them to colonize, well-managed cattle grazing can reduce exotic annual grasses that pose a fire hazard.

I request that you prevent EPA from abusing the conditional registration of pesticides, which allows companies to market products before they are fully evaluated.

Thank you.

Letter to County/City Executives

The climate change-induced increase in wildfire frequency and intensity has lent new urgency to efforts to manage so-called “invasive” plants. Unfortunately, the herbicide-based approach favored by many is both counterproductive and hazardous. It must be replaced by an organic system, incorporating biological control agents like goats and establishing a more resilient ecology.

Use of the herbicide indaziflam is an example of the ineffectiveness of management based on herbicides. While indaziflam is considered a “selective” herbicide, it actually kills and prevents germination of a wide range of broad-leaved plants and grasses and comes close to being a soil sterilant. The action on seedlings is long-lasting, thus inhibiting the growth and establishment of a resilient plant community that is resistant to invasion. Given its persistence and nonselective action and the extent of the damage it causes to native soil seed banks and plant biodiversity, indaziflam could contribute to the eventual ecological collapse of ecosystems where it’s applied, similar to the cascading impacts of the systemic insecticides, fipronil and the neonicotinoids on animals. The impacts of indaziflam could be even greater than insecticides since plants are the foundation of all living systems. Building resilience and resistance into a plant community requires working with succession, which requires the growth of some annuals, in preparation for the longer term community of mostly perennials—contrary to the approach of killing all “weeds.”

As one might expect from an herbicide with such wide-ranging effects, indaziflam—which was promoted and used for 10 years with an incomplete (“conditional”) registration—has serious and pervasive ecological impacts. Plants are the foundation of both terrestrial and aquatic food chains, and thus impacts of this long-lasting herbicide reverberate through the ecosystem. In spite of these risks, EPA considers registration of indaziflam to be “in the public interest.” EPA’s conclusion is based on considerations that do not include alternative management systems— or, indeed, the inadequacies of the management systems in which it is used. No determination weighing risks and benefits can be adequate if it does not consider the conditions under which the user decides to use it.

Herbicide treatments should be replaced by organic management. Organic vegetation management occurs within a system of defined parameters, which determine which materials may be used. In the case of vegetation control for fire management, many have found that no synthetic chemicals are needed—that goats can provide both vegetation removal and soil preparation. Although overgrazing with cattle can contribute to “invasive” plant problems by creating bare spots for them to colonize, well-managed cattle grazing can reduce exotic annual grasses that pose a fire hazard.

I request that you replace the use of herbicides with organic alternatives.

Thank you.

Letter to EPA

The climate change-induced increase in wildfire frequency and intensity has lent new urgency to efforts to manage so-called “invasive” plants. Unfortunately, the herbicide-based approach favored by many is both counterproductive and hazardous. It must be replaced by an organic system, incorporating biological control agents like goats and establishing a more resilient ecology.

Use of the herbicide indaziflam is an example of the ineffectiveness of management based on herbicides. While indaziflam is considered a “selective” herbicide, it actually kills and prevents germination of a wide range of broad-leaved plants and grasses and comes close to being a soil sterilant. The action on seedlings is long-lasting, thus inhibiting the growth and establishment of a resilient plant community that is resistant to invasion. Given its persistence and nonselective action and the extent of the damage it causes to native soil seed banks and plant biodiversity, indaziflam could contribute to the eventual ecological collapse of ecosystems where it’s applied, similar to the cascading impacts of the systemic insecticides, fipronil and the neonicotinoids on animals. The impacts of indaziflam could be even greater than insecticides since plants are the foundation of all living systems. Building resilience and resistance into a plant community requires working with succession, which requires the growth of some annuals, in preparation for the longer term community of mostly perennials—contrary to the approach of killing all “weeds.”

As one might expect from an herbicide with such wide-ranging effects, indaziflam—which was promoted and used for 10 years with an incomplete (“conditional”) registration—has serious and pervasive ecological impacts. Plants are the foundation of both terrestrial and aquatic food chains, and thus impacts of this long-lasting herbicide reverberate through the ecosystem. In spite of these risks, EPA considers registration of indaziflam to be “in the public interest.” EPA’s conclusion is based on considerations that do not include alternative management systems— or, indeed, the inadequacies of the management systems in which it is used. No determination weighing risks and benefits can be adequate if it does not consider the conditions under which the user decides to use it.

Herbicide treatments should be replaced by organic management. Organic vegetation management occurs within a system of defined parameters, which determine which materials may be used. In the case of vegetation control for fire management, many have found that no synthetic chemicals are needed—that goats can provide both vegetation removal and soil preparation. Although overgrazing with cattle can contribute to “invasive” plant problems by creating bare spots for them to colonize, well-managed cattle grazing can reduce exotic annual grasses that pose a fire hazard.

I request that you reconsider the registration of indaziflam and other herbicides for which organic alternatives are readily available.

Thank you.

05/16/2022 — Tell Congress to Increase Funding for Environmental Law Enforcement

Despite the fact that many more people die from living and working in unhealthy environments than from homicides or traffic crashes, resources put into preventing those deaths have been lacking—even decreasing in recent years.

>>Tell Congress to double budgets for environmental law enforcement.

Toxic pesticide residues readily contaminate soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) set standards. Scientific literature demonstrates pesticides' long history of adverse effects on the environment, including wildlife, biodiversity, and human health. Pesticides can present acute and long-term health impacts worldwide, especially to farmers, 44 percent of whom experience pesticide poisoning every year. Furthermore, a 2020 study attributes approximately 385 million cases of non-fatal unintentional poisonings and 11,000 deaths annually to pesticides. 

The risks to human and environmental health must be met with strong environmental law enforcement. In the case of pesticides, this involves not only enforcement of label restrictions in the field, but also closer attention to ensuring that pesticides are not registered for uses in which risks outweigh benefits—as required by law. The commitment to stronger environmental law enforcement should begin with a doubling of the budget for these activities. President Biden's 2023 budget proposal, which aims to create more than 1,900 new full-time positions, barely covers the 1,500 jobs the EPA eliminated during the first year and a half of the Trump administration. Instead, a doubling of the staff level will help EPA to reduce the growing divergence between work load and staff.

In addition to EPA, other environmental agencies are in dire need. More investigators at the U.S. Fish and Wildlife Service (FWS), Bureau of Land Management (BLM), Forest Service, and other agencies are needed to protect wildlife and endangered species at danger from poachers, chemical contamination, development, and climate change. The Fish and Wildlife Service has only about 250 special agents investigating wildlife crimes, while the BLM devotes just 70 people to criminal investigations.

>>Tell Congress to double budgets for environmental law enforcement.

Letter to Congress

As you consider President Biden’s budget requests, I ask that you address the need for environmental law enforcement. Despite the fact that many more people die from living and working in unhealthy environments than from homicides or traffic crashes, resources put into preventing those deaths have been lacking—even decreasing in recent years.

Toxic pesticide residues readily contaminate soils, water, and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) set standards. Scientific literature demonstrates pesticides’ long history of adverse effects on the environment, including wildlife, biodiversity, and human health. Pesticides can present acute and long-term health impacts worldwide, especially to farmers, 44 percent of whom experience pesticide poisoning every year. Furthermore, a 2020 study attributes approximately 385 million cases of non-fatal unintentional poisonings and 11,000 deaths annually to pesticides.

The risks to human and environmental health must be met with strong environmental law enforcement. In the case of pesticides, this involves not only enforcement of label restrictions in the field, but also closer attention to ensuring that pesticides are not registered for uses in which risks outweigh benefits—as required by law. The commitment to stronger environmental law enforcement should begin with a doubling of the budget for these activities. President Biden’s 2023 budget proposal, which aims to create more than 1,900 new full-time positions, barely covers the 1,500 jobs the EPA eliminated during the first year and a half of the Trump administration. Instead, a doubling of the staff level will help EPA to reduce the growing divergence between work load and staff.

In addition to EPA, other environmental agencies are in dire need. More investigators at the U.S. Fish and Wildlife Service (FWS), Bureau of Land Management (BLM), Forest Service, and other agencies are needed to protect wildlife and endangered species at danger from poachers, chemical contamination, development, and climate change. The Fish and Wildlife Service has only about 250 special agents investigating wildlife crimes, while the BLM devotes just 70 people to criminal investigations.

Thank you for your attention to this urgent issue.

 

05/09/2022 — Tell EPA To Protect Pollinators. Tell Congress To Insist that EPA Does Its Job.

While the U.S. Environmental Protection Agency (EPA) updated its guidelines for pollinator risk assessments in 2014, the agency continues to either fail to conduct full assessments, or dismiss concerning data it receives. EPA appears to discount threats like the insect apocalypse, evidenced by a 75% decline in insect abundance, which threatens not only global ecosystems, but also food production that depends on animal pollination. As pesticides move through the food web, birds are also at risk. Bird numbers are down 29% since Rachel Carson wrote Silent Spring in 1962.

 

Tell EPA To Protect Against Other Threats to Pollinators. Tell Congress To Insist that EPA Does Its Job.

The problem is highlighted by EPA's recent Interim Decision on fenbuconazole, in which the agency notes that, “For larval bees, RQs (risk quotients) exceed the LOC (level of concern) for all pollinator attractive uses including when assessed at the lowest application rate of 0.0938 lb a.i./Acre (RQ = 1.1).” Yet in the same document, the agency declares that “…the benefits of fenbuconazole (e.g., efficacy in management of fungal pathogens) outweigh any remaining risk and that continuing to register fenbuconazole provides significant benefits, including its ability to increase crop yields and help with resistance management.” While the agency added additional restrictive language on spray drift, it implemented no new precautionary measures for pollinators. With the only indications that this chemical is dangerous to pollinators deep in EPA's dense review documents the public rarely if ever reads, the agency continues to fail pollinators, farmers, and the public.  

Exposure to this commonly used fungicide considered to be 'slightly toxic or nontoxic' to pollinators makes male mason bees less likely to find a mate, jeopardizing future generations of critically important pollinators. This determination comes from research recently published in the Journal of Applied Ecology by scientists at Germany's University of Würzburg. The timing of these findings comes after the EPA reapproved uses of fenbuconazole late last year without completing all required studies on pollinator health effects.

EPA's action on fenbuconazole follows other actions by the agency that threaten pollinators, such as neonicotinoid (neonic) insecticides. Despite EPA's own findings of evidence of serious threats posed by neonics to pollinators, aquatic invertebrates, and other wildlife, it issued interim decisions on them in January 2020 that disregard the science on the pesticides' impacts and it appears that the agency is prepared to finalize these registrations late in 2022. This would, barring further action, extend the use of these harmful compounds for 15 years.

EPA's history of unenforceable and impractical pesticide label restrictions resulting in findings of ludicrously small or no risk continues with its announcement that allows the continued use of the deadly organophosphate insecticide malathion—another example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases. Malathion poses a threat to 97 percent of species listed under the Endangered Species Act, including Kirtland's Warbler and Black-capped Vireo. Bats, who are valuable pollinators, insectivores, and seed dispersers, are at high risk from pesticide exposure.

After registering over 300 products containing synthetic pyrethroid pesticides within the last six years, EPA has done nothing to safeguard endangered species from exposure to these toxic chemicals, despite a legal requirement to do so. Synthetic pyrethroid insecticides are synthesized derivatives of pyrethrins, which compared to their natural counterpart take significantly longer to degrade in the environment and thus pose longer term risks to humans and wildlife. The chemicals interfere with the proper function of the body's sodium channels, resulting in harm to the central nervous system. Symptoms of poisoning include headache, nausea, incoordination, tremors, and facial swelling, with severe incidents causing diarrhea, convulsions, paralysis, and death. “The EPA admits pyrethroids' wide-ranging harm to wildlife but still rubberstamps hundreds of pesticide products containing them without assessing their risks to endangered species,” said Lori Ann Burd, environmental health director at the Center for Biological Diversity.

To help avert ecosystem collapse, EPA must complete pollinator assessments and ban pesticides, including fungicides, insecticides, and herbicides, shown to imperil populations of insects and other pollinators.

Tell EPA To Protect Against Other Threats to Pollinators. Tell Congress To Insist that EPA Does Its Job.

05/09/2022 — Support Organic Habitat: No Mow May

Lawns occupy 40 million acres, or 2% of the land in the U.S. Their maintenance typically involves pesticides and fertilizers that kill pollinators and soil life and wash into streams, where they do more damage. Lawn maintenance also involves a lot of mowing. While mowing is an effective way to encourage grasses over most broadleaved plants, it also has broader ecological impacts.

The 3,600 species of bees in the U.S. and Canada range from large bumblebees to tiny sweat bees. There are many things you can do in your yard and community to protect these bees—starting with managing lawns and landscapes organically and planting flowers favored by bees and other pollinators. This one—No Mow May—requires less work. 

No Mow May began with research by Plantlife in the UK and was taken up by property owners in Appleton, WI, who demonstrated that “homes that participated in No Mow May had more diverse and abundant flora than regularly mowed green spaces throughout the city.”

May is the month when many bees emerge from hibernation throughout the U.S. and seek sources of pollen and nectar. By allowing your lawn to grow during May, more flowering plants will bloom, feeding the bees and other pollinators. The longer grass also provides a more diversified habitat for ground beetles and some butterflies. Mowing may still be advisable if ticks are a problem (mow paths!) or ground-nesting bees are present.

One obstacle that many people face in taking a break from mowing is that some communities have weed ordinances that prohibit tall vegetation. After years of fines for allowing his grass on his Prairie Street lot to grow, Michael Almon of Lawrence, KS collaborated with the Lawrence Sustainability Advisory Board in drafting a new natural landscaping ordinance to replace the old weed ordinance. See Beyond Pesticides' Tools for Change for help in changing your city's outdated ordinance.

>>Participate in No Mow May. Manage your landscape organically. Plant flowers for pollinators. Send a message to your mayor.

04/23/2022 — Take the Ladybug Pledge, Support Beyond Pesticides, and Bring Organic Landcare to Your City

In celebration of Earth Day and its fifth annual Ladybug LoveSM 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 control pests. Natural Grocers will donate $1 to Beyond Pesticides for each person who pledges (including renewals) to “not use chemicals that harm ladybugs and other beneficial insects on their lawn or garden, and to support 100% organic produce.” You do not need to shop at Natural Grocers to sign, but you will support the environment, public health, and Beyond Pesticides' hands-on program to assist communities with the transition to organic parks and playing fields.

Please take three actions:

1. Sign the Ladybug Pledge this year (even if you have previously) and support Beyond Pesticides. April shoppers at Natural Grocers' 162 stores—all in 20 states west of the Mississippi—are also invited to donate to Beyond Pesticides at checkout. Ladybug Love also features in-store promotions.

2. Advertise your commitment with a Beyond Pesticides “Pesticide Free Zone” yard sign. In partnership with major retailers like Natural Grocers and Stonyfield Organic, the Beyond Pesticides' Parks for a Sustainable Future program provides in-depth training and demonstration sites to assist community land managers in transitioning public green spaces to organic landscape management, while aiming to provide the knowledge and skills necessary to eventually transition all public areas in a locality to these sustainable and safe practices. Through this program, Beyond Pesticides is now assisting local leaders and municipal landscapers to convert parks and recreational areas across the country to exclusively organic practices, which eliminate the use of synthetic pesticides and fertilizers. For more information on the importance of transitioning to organic land management practices, see the latest issues of Beyond Pesticides' journal, Pesticides and You, Retrospective2021—A Call to Urgent Action.

3. 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.

In the spirit of Earth Day and daily concern for the environment, 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.

Beyond Pesticides provides in-depth training to assist community land managers in transitioning two public green spaces to organic landscape management through its Parks for a Sustainable Future program (bp-dc.org/sustainable-parks). Please contact Beyond Pesticides at [email protected] to find out how our town can transition to organic.

Thank you.

04/18/2022 — Tell USDA To Protect Wild Birds and Prevent Avian Flu Pandemics

Industrial poultry operations—generally indoors and with crowded conditions—provide the perfect incubator for pandemic influenza. According to the United Nations Food and Agriculture Organization (FAO), “These involve the congregation of large numbers of genetically identical animals of the same age (young) and sex, with rapid turnover and 'all-in, all-out' systems.” The U.S. Department of Agriculture (USDA) is delaying the adoption of organic rules that would require meaningful outdoor access and prevent indoor crowding. 

Influenza pandemics have killed millions of people—between 20 and 40 million people died in the 1918 pandemic, one million in 1957, and one to three million in 1968. According to the World Health Organization (WHO), “Influenza type A viruses are of most significance to public health due to their potential to cause an influenza pandemic.” There are several subtypes of type A influenza, which originates in birds. According to the Centers for Disease Control (CDC), there were 700 human cases of the H5N1 subtype since 2003, and only 40% survived.

>>Tell USDA to promulgate a strong Organic Livestock and Poultry Standard. Tell USDA to protect against flu pandemics by applying the same rules to all poultry.

Because avian flu poses a risk to domestic poultry as well as humans, the Animal and Plant Health Inspection Service (APHIS) of USDA conducts ongoing surveillance of wild birds, who can carry the virus without becoming sick. 

Wild birds provide valuable services to farmers, and pastured poultry is valued for integration with organic farming systems as well as the superior quality of eggs and meat. Yet conventional advice from USDA discourages outdoor access for poultry as well as allowing wildlife on the farm. 

The virus thrives on intensive confinement, and the lack of genetic diversity is a contributing factor. If the virus gets into a barn, it will wreak havoc. Hence, USDA and the commercial poultry industry point endlessly to biosecurity, which is integral to conventional industrial production systems, but not as effective as removing the underlying unhealthy conditions that cause the problem. According to the American Pastured Poultry Producers Association

The virus causes the most damage to intensely confined flocks commonly found in the commercial poultry industry. A relatively small number of backyard birds have also been affected. But backyard is not synonymous with pastured and the commercial flocks, as USDA is reporting them, do not include any pastured flocks. 

In the 2014-2015 outbreak the affected sites looked like this:
• 211 commercial poultry farms killing 50 million chickens and turkeys.
• 21 backyard flocks killing 10,000 birds. Approximately 5,000 of those backyard birds were on a gamebird farm. 

The outbreak in 2022 is showing similar trends. When you look at the data, there's a clear risk, and it's not pastured poultry farms. 

Furthermore, organic poultry is required to have access to the outdoors. However, the National Organic Program lacks regulations to ensure meaningful outdoor access for organic chickens and other animal welfare requirements. After a decade of work by organic stakeholders and the National Organic Standards Board, USDA promulgated the 2017 Organic Livestock and Poultry Practices (OLPP) final rule in the waning days of the Obama administration, then withdrew it in 2018 during the Trump administration. The OLPP contained provisions to ensure outdoor access and prevent indoor crowding, thus reducing the likelihood that organic poultry operations will be incubators for influenza. A remake of the rule (OLPS) is pending.

>>Tell USDA to promulgate a strong Organic Livestock and Poultry Standard. Tell USDA to protect against flu pandemics by applying the same rules to all poultry.

Letter to USDA

Industrial poultry operations—generally indoors and with crowded conditions—provide the perfect incubator for pandemic influenza. According to the United Nations Food and Agriculture Organization (FAO), “These involve the congregation of large numbers of genetically identical animals of the same age (young) and sex, with rapid turnover and ‘all-in, all-out’ systems.”

Influenza pandemics have killed millions of people—between 20 and 40 million people died in the 1918 pandemic, one million in 1957, and one to three million in 1968. According to the World Health Organization (WHO), “Influenza type A viruses are of most significance to public health due to their potential to cause an influenza pandemic.” There are several subtypes of type A influenza, which originates in birds. According to the CDC, there were 700 human cases of the H5N1 subtype since 2003, and only 40% survived.

Because avian flu poses a risk to domestic poultry as well as humans, USDA’s Animal and Plant Health Inspection Service (APHIS) conducts surveillance of wild birds, who can carry the virus without becoming sick.

Wild birds provide valuable services to farmers, and pastured poultry is valued for integration with the organic farm as well as the superior quality of eggs and meat. Yet, conventional advice from USDA discourages outdoor access for poultry as well as allowing wildlife on the farm.

The virus thrives on intensive confinement, and the lack of genetic diversity is a contributing factor. If the virus gets into a barn, it will wreak havoc. Hence USDA and the commercial poultry industry drone on and on about biosecurity, which is their only defense, and not as effective as removing the unhealthy conditions. According to the American Pastured Poultry Producers Association,

The virus causes the most damage to intensely confined flocks commonly found in the commercial poultry industry. A relatively small number of backyard birds have also been affected. But backyard is not synonymous with pastured and the commercial flocks, as USDA is reporting them, do not include any pastured flocks.

In the 2014-2015 outbreak the affected sites looked like this:

  • 211 commercial poultry farms killing 50 million chickens and turkeys.
  • 21 backyard flocks killing 10,000 birds. Approximately 5,000 of those backyard birds were on a gamebird farm.

The outbreak in 2022 is showing similar trends. When you look at the data, there's a clear risk, and it's not pastured poultry farms.

Furthermore, organic poultry is required to have access to the outdoors. However, the National Organic Program lacks regulations to ensure meaningful outdoor access for organic chickens and other animal welfare requirements. After a decade of work by organic stakeholders and the National Organic Standards Board, USDA promulgated the 2017 Organic Livestock and Poultry Practices (OLPP) final rule in the waning days of the Obama administration, then withdrew it in 2018 during the Trump administration. The OLPP contained provisions to ensure outdoor access and prevent indoor crowding, thus reducing the likelihood that organic poultry operations will be incubators for influenza. A remake of the rule (OLPS) is pending.

We need not only a strong OLPS for the sake of organic integrity, but also similar requirements for non-organic farms to protect against future pandemics. Please ensure that USDA takes steps to require healthy living conditions for all poultry that will not promote the development of the next flu pandemic. We can prevent it if we take the necessary steps to require meaningful outdoor access and eliminate overcrowding in the management of poultry.

Thank you.

Letter to Congress

Industrial poultry operations—generally indoors and with crowded conditions—provide the perfect incubator for pandemic influenza. According to the United Nations Food and Agriculture Organization (FAO), “These involve the congregation of large numbers of genetically identical animals of the same age (young) and sex, with rapid turnover and ‘all-in, all-out’ systems.” The U.S. Department of Agriculture (USDA) is delaying the adoption of organic rules that would require meaningful outdoor access and prevent indoor crowding.

Influenza pandemics have killed millions of people—between 20 and 40 million people died in the 1918 pandemic, one million in 1957, and one to three million in 1968. According to the World Health Organization (WHO), “Influenza type A viruses are of most significance to public health due to their potential to cause an influenza pandemic.” There are several subtypes of type A influenza, which originates in birds. According to the CDC, there were 700 human cases of the H5N1 subtype since 2003, and only 40% survived.

Because avian flu poses a risk to domestic poultry as well as humans, USDA’s Animal and Plant Health Inspection Service (APHIS) conducts surveillance of wild birds, who can carry the virus without becoming sick.

Wild birds provide valuable services to farmers, and pastured poultry is valued for integration with the organic farm as well as the superior quality of eggs and meat. Yet, conventional advice from USDA discourages outdoor access for poultry as well as allowing wildlife on the farm.

The virus thrives on intensive confinement, and the lack of genetic diversity is a contributing factor. If the virus gets into a barn, it will wreak havoc. Hence USDA and the commercial poultry industry drone on and on about biosecurity, which is their only defense, and not as effective as removing the unhealthy conditions. According to the American Pastured Poultry Producers Association,

The virus causes the most damage to intensely confined flocks commonly found in the commercial poultry industry. A relatively small number of backyard birds have also been affected. But backyard is not synonymous with pastured and the commercial flocks, as USDA is reporting them, do not include any pastured flocks.

In the 2014-2015 outbreak the affected sites looked like this:

  • 211 commercial poultry farms killing 50 million chickens and turkeys.
  • 21 backyard flocks killing 10,000 birds. Approximately 5,000 of those backyard birds were on a gamebird farm.

The outbreak in 2022 is showing similar trends. When you look at the data, there's a clear risk, and it's not pastured poultry farms.

Furthermore, organic poultry is required to have access to the outdoors. However, the National Organic Program lacks regulations to ensure meaningful outdoor access for organic chickens and other animal welfare requirements. After a decade of work by organic stakeholders and the National Organic Standards Board, USDA promulgated the 2017 Organic Livestock and Poultry Practices (OLPP) final rule in the waning days of the Obama administration, then withdrew it in 2018 during the Trump administration. The OLPP contained provisions to ensure outdoor access and prevent indoor crowding, thus reducing the likelihood that organic poultry operations will be incubators for influenza. A remake of the rule (OLPS) is pending.

We need not only a strong OLPS for the sake of organic integrity, but also similar requirements for non-organic farms to protect against future pandemics. Please ask USDA to take steps to require healthy living conditions for all poultry that will not promote the development of the next flu pandemic. We can prevent it if we take the necessary steps to require meaningful outdoor access and eliminate overcrowding in the management of poultry.

Thank you.

04/11/2022 — Aid Programs Must Support Traditional and Organic, Not Chemical-Intensive, Agriculture

As the U.S. encourages the spread of chemical-intensive, industrialized agriculture, local farmers are increasingly pressured into giving up traditional agricultural practices in favor of monocultures to increase the demand  for agrichemical pesticides and fertilizers worldwide. This policy is promoted by the industry with vested economic interests as good for the U.S. economy, but it is not good for either planetary health or global food security. Instead, U.S. foreign aid agencies, through the U.S. Agency for International Development (USAID) and other agencies, should be supporting traditional practices and organic agriculture.

>>Tell Congress and U.S. AID to support aid that promotes traditional and organic agriculture.

Industrial agriculture depends on monoculture—growing single crops that can be easily planted, fertilized, treated with pesticides, and harvested—especially on large-scale, mechanized farms. In spite of the perceived advantages of monoculture, however, it is a significant contributor to biodiversity loss and pollinator decline. Loss of biodiversity feeds the pesticide treadmill by removing predators and parasites who keep crop-feeding insects below damaging levels. The vast majority of crop plants depend on pollinators.

Traditional agriculture, like organic agriculture, depends on interacting species. Most organic agriculture resembles monoculture piecewise, but integrates cover crops, hedgerows and other natural areas, and crop diversity. Traditional agriculture frequently involves plant polycultures—such as the corn-beans-squash polyculture of Native Americans—but also integrates animals. A traditional rice paddy that incorporates fish or other aquatic animals is an example of the latter. Research shows that such systems not only protect global ecosystems, but can also yield more food.

Traditional and organic agriculture do not depend on the petroleum-based pesticides that keep industrial agriculture running. Nor do they depend on synthetic nitrogen fertilizers, a source of nitrous oxide, or NOx — another potent greenhouse gas that also pollutes the air and feeds the development of ozone. NOx is roughly 300 times as potent in trapping heat as CO2. They do not depend on synthetic pesticides that poison our soil, air, water, and ecosystems, as well as people.

The U.S. government's international aid must aggressively and urgently support traditional agricultural systems that meet organic standards. Instead, USAID has used an “Invitation for Applications” in its Feed the Future program (Bangladesh Rice and Diversified Crops Activity) that describes “farm production challenges” for rice production that may allow for the introduction of practices and materials (pesticides and fertilizers) that undermine traditional and organic practices. The USAID states the following:

Farm Production Challenges
Farmers have limited availability of quality commercial rice inputs such as short duration and high yielding varieties, climate resilient varieties, pest and disease resistance varieties seeds, fertilizers (macro & micro), crop protection products (especially for insect, disease & weed control).

Inadequate information and knowledge for farmers on the benefits of quality seeds, new varieties, modern cultivation practices (appropriate age of seedling, judicious use of fertilizer & pesticides) and post-harvest practices, and rice-based cropping system.

Farmers lack of linkages with product buyers (small to large) and processing plants (small engleberg friction, semi-auto, and auto rice millers). 

Embracing a sustainable future requires an honoring of traditional agricultural methods and organic practices that work in sync with nature and advances food security worldwide. 

>>Tell Congress and U.S. AID to support aid that promotes traditional and organic agriculture.

Letter to USAID

As the U.S. encourages the spread of chemical-intensive, industrialized agriculture, local farmers are increasingly pressured into giving up traditional agricultural practices in favor of monocultures to that increase agrichemical use worldwide. This policy is promoted by the industry with vested economic interests as good for the U.S. economy, but it is not good for either planetary health or global food security. Instead, U.S. foreign aid agencies should be supporting traditional practices. It is time for the U.S. Agency for International Development (USAID) and other agencies to aggressively and urgently support traditional agricultural systems that meet organic standards.

Meanwhile, studies are showing that local economies in developing countries are best served by traditional agricultural practices. Research shows that such systems not only protect global ecosystems, but can also yield more food. An article, “Using aquatic animals as partners in increase yield and maintain soil nitrogen in the paddy ecosystems,” published eLife, shows a yield increase in rice production with co-cultures.

Industrial agriculture depends on monoculture—growing single crops that can be easily planted, fertilized, treated with pesticides, and harvested—especially on large-scale, mechanized farms. In spite of the perceived advantages of monoculture, however, it is a significant contributor to biodiversity loss and pollinator decline. Loss of biodiversity feeds the pesticide treadmill by removing predators and parasites who keep crop-feeding insects below damaging levels. The vast majority of crop plants depend on pollinators.

Traditional agriculture and organic agriculture, depend on interacting species. Most organic agriculture resembles monoculture piecewise, but integrates cover crops, hedgerows and other natural areas, and crop diversity. Traditional agriculture frequently involves plant polycultures—such as the corn-beans-squash polyculture of Native Americans—but also integrates animals. A traditional rice paddy that incorporates fish or other aquatic animals is an example of the latter.

Traditional and organic agriculture do not depend on the petroleum-based pesticides that keep industrial agriculture running. Nor do they depend on synthetic nitrogen fertilizers, a source of nitrous oxide, or NOx — another potent greenhouse gas that also pollutes the air and feeds the development of ozone. NOx is roughly 300 times as potent in trapping heat as CO2. They do not depend on synthetic pesticides that poison our soil, air, water, and ecosystems, as well as people.

Please urge USAID to promote traditional and organic agriculture in its funding and support programs. Embracing a sustainable future requires an honoring of traditional agricultural methods and organic practices that work in sync with nature and advance food security worldwide.

Thank you.

Letter to Congress

As the U.S. encourages the spread of chemical-intensive, industrialized agriculture, local farmers are increasingly pressured into giving up traditional agricultural practices in favor of monocultures to that increase agrichemical use worldwide. This policy is promoted by the industry with vested economic interests as good for the U.S. economy, but it is not good for either planetary health or global food security. Instead, U.S. foreign aid agencies should be supporting traditional practices. It is time for the U.S. Agency for International Development (USAID) and other agencies to aggressively and urgently support traditional agricultural systems that meet organic standards.

Meanwhile, studies are showing that local economies in developing countries are best served by traditional agricultural practices. Research shows that such systems not only protect global ecosystems, but can also yield more food. An article, “Using aquatic animals as partners in increase yield and maintain soil nitrogen in the paddy ecosystems,” published eLife, shows a yield increase in rice production with co-cultures.

Industrial agriculture depends on monoculture—growing single crops that can be easily planted, fertilized, treated with pesticides, and harvested—especially on large-scale, mechanized farms. In spite of the perceived advantages of monoculture, however, it is a significant contributor to biodiversity loss and pollinator decline. Loss of biodiversity feeds the pesticide treadmill by removing predators and parasites who keep crop-feeding insects below damaging levels. The vast majority of crop plants depend on pollinators.

Traditional agriculture and organic agriculture, depend on interacting species. Most organic agriculture resembles monoculture piecewise, but integrates cover crops, hedgerows and other natural areas, and crop diversity. Traditional agriculture frequently involves plant polycultures—such as the corn-beans-squash polyculture of Native Americans—but also integrates animals. A traditional rice paddy that incorporates fish or other aquatic animals is an example of the latter.

Traditional and organic agriculture do not depend on the petroleum-based pesticides that keep industrial agriculture running. Nor do they depend on synthetic nitrogen fertilizers, a source of nitrous oxide, or NOx — another potent greenhouse gas that also pollutes the air and feeds the development of ozone. NOx is roughly 300 times as potent in trapping heat as CO2. They do not depend on synthetic pesticides that poison our soil, air, water, and ecosystems, as well as people.

Please urge USAID to promote traditional and organic agriculture in its funding and support programs. Embracing a sustainable future requires an honoring of traditional agricultural methods and organic practices that work in sync with nature and advance food security worldwide.

Thank you.

04/04/2022 — EPA Must Protect Birds, Bees, and Other Pollinators; Ban Neonic Insecticides

Recent actions by the U.S. Environmental Protection Agency (EPA) highlight the urgent need to prevent pesticides from further endangering crucial pollinators, including birds, bees, and bats

>>Tell EPA to ban neonics and protect against other threats to pollinators. Tell Congress to insist that EPA does its job.

Despite EPA's own findings of evidence of serious threats posed by neonicotinoid (neonic) pesticides to pollinators, aquatic invertebrates, and other wildlife, it issued interim decisions on these neonics in January 2020 that disregard the science on the pesticides' impacts, and it appears that the agency is prepared to finalize these registrations late in 2022. This would, barring further action, extend the use of these harmful compounds for 15 years. Now is the time to let EPA know that continued use of neonicotinoids is unacceptable.

Furthermore, building on a history of unenforceable and impractical pesticide label restrictions resulting in EPA findings of ludicrously small or no risk, the agency spun its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” As the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases, EPA actions continue to protect pesticide manufacturers instead of fulfilling its mission “to protect human health and the environment,” and to ensure that “national efforts to reduce environmental risks are based on the best available scientific information.”

EPA appears to discount threats like the insect apocalypse, evidenced by a 75% decline in insect abundance, which threatens not only global ecosystems, but also food production that depends on animal pollination. As pesticides move through the food web, birds are also at risk. Bird numbers are down 29% since Rachel Carson wrote Silent Spring in 1962. Malathion poses a threat to 97% of species listed under the Endangered Species Act, including Kirtland's Warbler and Black-capped Vireo. Bats, who are valuable pollinators, insectivores, and seed dispersers, are at high risk from pesticide exposure.

To help avert ecosystem collapse, EPA must ban pesticides, including neonicotinoids and organophosphates, shown to imperil populations of insects and other pollinators.

>>Tell EPA to ban neonics and protect against other threats to pollinators. Tell Congress to insist that EPA does its job.

Letter to EPA

Recent actions by EPA highlight the agency’s failure to prevent pesticides from imperiling crucial pollinators, including birds, bees, and bats.

Despite EPA’s own findings of evidence of serious threats posed by neonicotinoid (neonic) pesticides to pollinators, aquatic invertebrates, and other wildlife, it issued interim decisions on these neonics in January 2020 that disregard the science on the pesticides’ impacts and it appears that the agency is prepared to finalize these registrations late in 2022. This would, barring further action, extend the use of these harmful compounds for 15 years. This is a crucial time to take action to stop neonicotinoid use.

Furthermore, building on a history of unenforceable and impractical pesticide label restrictions resulting in EPA findings of ludicrously small or no risk, the agency spun its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” As the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases, EPA actions continue to protect pesticide manufacturers instead of fulfilling its mission “to protect human health and the environment,” and to ensure that “national efforts to reduce environmental risks are based on the best available scientific information.”

EPA appears to discount threats like the insect apocalypse, evidenced by a 75% decline in insect abundance, which threatens not only global ecosystems, but also food production that depends on insect pollination. As pesticides move through the food web, birds are also at risk. Bird numbers are down 29% since Rachel Carson wrote Silent Spring in 1962. Malathion poses a threat to 97 percent of species listed under the Endangered Species Act, including Kirtland's Warbler and Black-capped Vireo. Bats, who are valuable pollinators, insectivores, and seed dispersers, are at high risk from pesticide exposure.

To help avert ecosystem collapse, I urge you to ban, this year, neonicotinoids shown to imperil populations of insects and other pollinators.

Thank you.

Letter to Congress

Recent actions by the Environmental Protection Agency (EPA) highlight the urgent need to prevent pesticides from further endangering crucial pollinators, including birds, bees, and bats. I am writing to urge you to exert pressure on EPA to act in accordance with its mission to protect the environment and public health.

Despite EPA’s own findings of evidence of serious threats posed by neonicotinoid (neonic) pesticides to pollinators, aquatic invertebrates, and other wildlife, it issued interim decisions on these neonics in January 2020 that disregard the science on the pesticides’ impacts and it appears that the agency is prepared to finalize these registrations late in 2022. This would, barring further action, extend the use of these harmful compounds for 15 years. Now is the time to let EPA know that continued use of neonicotinoids is unacceptable.

Furthermore, building on a history of unenforceable and impractical pesticide label restrictions resulting in EPA findings of ludicrously small or no risk, the agency spun its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” As the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases, EPA actions continue to protect pesticide manufacturers instead of fulfilling its mission “to protect human health and the environment,” and to ensure that “national efforts to reduce environmental risks are based on the best available scientific information.”

EPA appears to discount threats like the insect apocalypse, evidenced by a 75% decline in insect abundance, which threatens not only global ecosystems, but also food production that depends on animal pollination. As pesticides move through the food web, birds are also at risk. Bird numbers are down 29% since Rachel Carson wrote Silent Spring in 1962. Malathion poses a threat to 97 percent of species listed under the Endangered Species Act, including Kirtland's Warbler and Black-capped Vireo. Bats, who are valuable pollinators, insectivores, and seed dispersers, are at high risk from pesticide exposure.

To help avert ecosystem collapse, please let EPA know that it must, this year, ban neonicotinoids shown to imperil populations of insects and other pollinators.

Thank you.

03/29/2022 — Last Chance This Spring to Tell the NOSB to Uphold Organic Integrity

03/21/2022 — Tell EPA to Take Meaningful Action to Protect Endangered Species

With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that spins its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” This just the latest example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.

>>Tell EPA To protect endangered species. Tell Congress to make sure the Biden administration protects endangered species.

The announcement follows the release of a final biological opinion by U.S. Fish and Wildlife Service (FWS), which, according to the Center for Biological Diversity (CBD), “relies on scientifically unfounded assessment methods imposed during the Trump administration [and] stands in sharp contrast to the agency's 2017 conclusion that 1,284 species would likely be jeopardized by malathion.” Meanwhile, the National Marine Fisheries Service, a sister agency to the U.S. Fish and Wildlife Service, released an updated biological opinion that determined malathion and two other toxic organophosphate pesticides are causing jeopardy to virtually every endangered U.S. salmon, sturgeon, and steelhead species, as well as to Puget Sound orcas.

The current decision by EPA is a result of corporate and political intervention following the 2017 biological opinion by FWS. Dow AgroSciences—now called Corteva—asked the Administration to suspend the assessments. Then-acting Department of Interior Secretary David Bernhardt complied after becoming aware of the fact that the Service's analysis had determined that malathion jeopardized the continued existence of 1,284 protected species.

Agency decisions like this call into question the Biden administration's commitment to protecting the environment and human health. As stated by CBD's Lori Ann Burd, “The Biden administration has squandered a historic opportunity to rein in the dangerous use of one of the world's worst neurotoxic pesticides. By ignoring the best available science and choosing to rely on unenforceable promises of good behavior by the pesticide makers rather than real, on-the- ground conservation measures, the Biden administration is condemning wildlife to extinction with a wink and a nod. This decision to cave to powerful special interest groups will do far-
reaching harm to our most endangered wildlife.”

The insistence that labeling restrictions can prevent harm to endangered species flies in the face of past experience, which has produced an insect apocalypse and extinction crisis. EPA must protect endangered species by banning the use of hazardous pesticides like malathion and other organophosphates.

>>Tell EPA To protect endangered species. Tell Congress to make sure the Biden administration protects endangered species.

Letter to EPA

 

With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that spins its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” This just the latest example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.

The recent final biological opinion on malathion by U.S. Fish and Wildlife Service (FWS) relies on scientifically unfounded assessment methods imposed during the Trump administration and stands in sharp contrast to the agency’s 2017 conclusion that 1,284 species would likely be jeopardized by malathion. Meanwhile, the National Marine Fisheries Service has released an updated biological opinion that determined malathion and two other toxic organophosphate pesticides are causing jeopardy to virtually every endangered U.S. salmon, sturgeon, and steelhead species, as well as to Puget Sound orcas.

The current decision by EPA is a result of corporate and political intervention following the 2017 biological opinion by FWS. Dow AgroSciences—now called Corteva—asked the administration to suspend the assessments. Then-acting Department of Interior Secretary David Bernhardt complied after becoming aware of the fact that the Service’s analysis had determined that malathion jeopardized the continued existence of 1,284 protected species.

Agency decisions like this call into question the Biden administration’s commitment to
protecting the environment and human health. As stated by Lori Ann Burd of the Center for
Biological Diversity, “The Biden administration has squandered a historic opportunity to rein in the dangerous use of one of the world’s worst neurotoxic pesticides. By ignoring the best available science and choosing to rely on unenforceable promises of good behavior by the pesticide makers rather than real, on-the-ground conservation measures, the Biden administration is condemning wildlife to extinction with a wink and a nod. This decision to cave to powerful special interest groups will do far-reaching harm to our most endangered wildlife.”

The insistence that labeling restrictions can prevent harm to endangered species flies in the face of past experience, which has produced an insect apocalypse and extinction crisis. EPA must protect endangered species by banning the use of hazardous pesticides like malathion and other organophosphates.

Thank you.

Letter to Congress

Please ensure that the Biden administration protects endangered species.

With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that spins its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” This just the latest example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.

The recent final biological opinion on malathion by U.S. Fish and Wildlife Service (FWS) relies on scientifically unfounded assessment methods imposed during the Trump administration and stands in sharp contrast to the agency’s 2017 conclusion that 1,284 species would likely be jeopardized by malathion. Meanwhile, the National Marine Fisheries Service has released an updated biological opinion that determined malathion and two other toxic organophosphate pesticides are causing jeopardy to virtually every endangered U.S. salmon, sturgeon, and steelhead species, as well as to Puget Sound orcas.

The current decision by EPA is a result of corporate and political intervention following the 2017 biological opinion by FWS. Dow AgroSciences—now called Corteva—asked the administration to suspend the assessments. Then-acting Department of Interior Secretary David Bernhardt complied after becoming aware of the fact that the Service’s analysis had determined that malathion jeopardized the continued existence of 1,284 protected species.

Agency decisions like this call into question the Biden administration’s commitment to
protecting the environment and human health. As stated by Lori Ann Burd of the Center for
Biological Diversity, “The Biden administration has squandered a historic opportunity to rein in the dangerous use of one of the world’s worst neurotoxic pesticides. By ignoring the best available science and choosing to rely on unenforceable promises of good behavior by the pesticide makers rather than real, on-the-ground conservation measures, the Biden administration is condemning wildlife to extinction with a wink and a nod. This decision to cave to powerful special interest groups will do far-reaching harm to our most endangered wildlife.”

The insistence that labeling restrictions can prevent harm to endangered species flies in the face of past experience, which has produced an insect apocalypse and extinction crisis. EPA must protect endangered species by banning the use of hazardous pesticides like malathion and other organophosphates.

Thank you.

03/14/2022 — Don't Let Proposals Undermine Organic Integrity! Keep Organic Strong!

The National Organic Standards Board (NOSB) is receiving written comments from the public through April 1. This precedes the upcoming public hearing on April 19 and 21—concerning how organic food is produced. Written comments must be submitted through Regulations.gov. For details on the all the issues of importance to organic integrity, please see Beyond Pesticides’ Keeping Organic Strong webpage.

The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health

The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2022 issues page. Here are some high priority issues for us:

Cetylpyridinium chloride (CPC) is a quaternary ammonium compound (quat or QAC) that is being petitioned for use on raw organic poultry. The class of QACs includes several toxic sanitizers and disinfectants as well as the highly toxic herbicides paraquat and diquat. CPC is highly toxic, and poses a particular hazard to workers. CPC residues have been discovered on treated surfaces and poultry skin, exposing consumers to unlabeled pesticide residues. It is unnecessary in organic production, and the petition should be denied.

The NOSB is considering a proposal limiting the use of highly soluble nitrogen fertilizers in organic production. This follows on recommendations by the NOSB in Fall 2021, prohibiting the use of stripped ammonia and concentrated ammonia as fertilizers in organic crop production. In recognition of the fact that their high solubility makes them inconsistent with organic

production, which “feeds the soil, not the plant,” the Crops Subcommittee proposes to generalize the prohibition unless use is restricted to no more than 20 percent of the crop’s total nitrogen requirement. USDA has stated that it will not implement the prohibition of stripped ammonia and concentrated ammonia unless this proposal passes. The NOSB should pass this proposal to protect organic integrity.

Biodegradable Biobased (Bioplastic) Mulch Film (BBMF) is under consideration for sunset this year. Although the NOSB will not vote on BBMF until the Fall 2022 meeting, this is part of a larger issue of the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles to which it degrades—on human health and the environment. BBMF should not be relisted. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic production and handling—including packaging.

Please feel free to use the text above to highlight for the NOSB the concerns of these key issues.

>>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!

03/07/2022 — Insist That USDA Uphold Organic Integrity and the Law; Keep Synthetic Hormones Out of Milk Production.

Contrary to the demands of consumers for hormone-free organic dairy products and the requirements of the Organic Foods Production Act (OFPA), the U.S. Department of Agriculture (USDA) will allow continued use of the synthetic hormone oxytocin in organic dairy production. The National Organic Standards Board (NOSB) voted unanimously in 2017 to reject the use of the synthetic hormone oxytocin in livestock production. Since administration of oxytocin has been linked to a range of serious health problems and early onset puberty, autism, and psychiatric disorders, it is important to avoid residues in food that may cause a hormone imbalance in food consumers.

>>Tell USDA Secretary Vilsack to reverse the decision to allow oxytocin in organic dairy. Tell Congress that greater oversight is needed to ensure that USDA upholds the Organic Foods Production Act.

Substances on the National List are reconsidered every five years to determine whether they still meet criteria in OFPA—that is, that their use is (1) not harmful to human health or the environment, (2) necessary for organic production, and (3) consistent with organic practices. In the case of oxytocin, a hormone involved in the milk “let-down” reflex, there is longstanding concern that misuse of the hormone to increase milk production may be at the expense of the health of the cows. Increased milk production may also be at the expense of the organic dairy industry. USDA, with its mentality of increasing production, ignores the greater importance of organic principles to organic consumers.

In 2017, the NOSB unanimously recommended the sunsetting (removal) of oxytocin from the National List of Allowed and Prohibited Substances (National List). Oxytocin had been allowed to be used for “use in postparturition therapeutic applications” since 2000. In deciding not to relist oxytocin, the NOSB said, “[M]ethods and materials have been developed that make oxytocin less essential for maintaining animal health and welfare. The expectations and awareness of dairy production tools by consumers has changed over time. They now expect organic milk be produced without the use of synthetic hormones. The Livestock Subcommittee realizes that some producers may need to learn new methods to address post parturition issues, but we believe the knowledge and materials are present, so that there will be no interruption in commerce, economic hardship, or lessening of animal welfare if this material is removed from the National List of approved synthetics.”

Thus, the NOSB decided that oxytocin meets neither the essentiality nor the compatibility criterion. USDA ignored the NOSB decision and, contrary to OFPA, which prohibits USDA from adding any synthetic to the National List that has not been recommended by the NOSB, issued a final rule—which goes into effect March 30, 2022—relisting oxytocin.

>>Tell USDA Secretary Vilsack to reverse the decision to allow oxytocin in organic dairy. Tell Congress that greater oversight is needed to ensure that USDA upholds the Organic Foods Production Act.

Letter to USDA

USDA’s decision to relist oxytocin on the National List of synthetic materials allowed in organic production is contrary to the expectations of organic consumers and to the letter of the Organic Foods Production Act (OFPA).

Organic consumers expect that organic milk is produced without added hormones. Milk, because it is an important food for children, is especially critical for organic integrity.

Furthermore, taking an action to relist a synthetic material on the National List in spite of a recommendation to the contrary by the National Organic Standards Board is expressly prohibited by OFPA’s “no additions” clause (§6517(d)(2)).

I am extremely disturbed by actions taken by USDA that threaten organic integrity and the role of the NOSB in representing the organic community. The final rule is due to take effect on March 30. I request that you revoke the rule before that date.

Thank you.

Letter to Congress

Organic consumers expect that organic milk is produced without added hormones. Milk, because it is an important food for children, is especially critical for organic integrity. And yet, USDA, contrary to the recommendation of the National Organic Standards Board (NOSB), has relisted oxytocin, a synthetic hormone, for use in organic dairy.

Furthermore, taking an action to relist a synthetic material on the National List in spite of a recommendation to the contrary by the NOSB is expressly prohibited by OFPA’s “no additions” clause (§6517(d)(2)).

I am extremely disturbed by actions taken by USDA that threaten organic integrity and the role of the NOSB in representing the organic community. The final rule is due to take effect on March 30. Please ask USDA to revoke the rule before that date.

Thank you.

02/28/2022 — EPA Must Stop Pesticide Use Patterns Leading to Deadly Antifungal and Antibiotic Resistance

When bacteria and fungi become resistant to pesticides, it is a signal that the toxic chemical approach to controlling pathogens does not work. But resistance also poses a direct threat to human health when the pesticide (or a related chemical) is used in human medicine.

>>Tell EPA to cancel all uses of a pesticide when resistance is discovered or predicted to occur. Tell Congress to ensure that EPA protects public health from deadly antifungal and antibiotic resistance.

The threat of resistance in bacterial human pathogens has long been widely recognized. Although research sponsored by the Environmental Protection Agency (EPA) recognizes the spread of resistance to antibiotics important in human medicine through horizontal gene transfer in the environment, EPA inaction both on antibiotic and antifungal resistance has become a growing crisis. 

EPA does recognize the existence of resistance to fungicides. It uses codes produced by the Fungicide Resistance Action Committee in decisions regarding fungicide registration. Although EPA says resistance “may be considered in the risk-benefit decision-making process,” there is no evidence that the agency actually considers the failure of EPA-registered pesticides to control the target organisms in registering pesticides. That failure has a serious impact on human and environmental health as users of the chemical increase use and as medical uses of antibiotics and fungicides become ineffective.

The threat of resistance is evident with a number of fungicides, as well as bactericides and viricides. For example, Candida auris is an emerging fungal pathogen that threatens those with compromised or immature immune systems, such as infants, the elderly, people taking steroids for autoimmune disorders, diabetics, those undergoing chemotherapy, and even smokers. Nearly half of those who contract a C. auris infection die within 90 days. One of the factors making this fungus so deadly is that it has developed resistance to existing antifungal medicines, with 90% of infections resistant to one drug, and 30% to two or more. As is true for resistant bacteria, culprits in C. auris's development of resistance include the use of antifungal medications in health care and reliance on fungicides in agriculture.

A recent study conducted by scientists at the University of Georgia finds fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens. Of 700 Aspergillus fumigatus samples collected, nearly 20% (123) displayed some level of resistance to the commonly used azole fungicide tebuconazole. Twelve of the 123 were highly resistant at clinically relevant levels for human health care. No samples taken from organic sites contained  resistant fungi.

Azole-resistant strains also displayed resistance  to methyl benzimidazole carbamate (MBC) fungicides like carbendazim, and quinone outside inhibitors (Qol) like azoxystrobin.A review of genome sequences shows that genetically those with broad resistance to azole fungicides show a close match between those discovered on farms and those found in human  clinical settings. Of 25 pan-azole resistant samples analyzed, eight farm samples and 12 human  clinical samples also display resistance to non-azole fungicides.

These results indicate a need for a shift toward eliminating reliance on toxic fungicides. Unfortunately, regulators and politicians are neither heeding the science, nor listening to scientists. EPA's recent response to the rise of drug-resistant Candida auris is a case in point. The agency failed to assess the efficacy of any pesticides that are not used for public health purposes; EPA only evaluated the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related—thus ignoring the impact of other antimicrobial pesticides on resistance in human pathogens.

At the international level, a Freedom of Information Act request revealed officials at the U.S. Department of Agriculture working to downplay the role of synthetic fungicide use in chemical agriculture as a factor in the rise of drug-resistant fungal infections worldwide by denying the truth on the ground and attempting to halt protective actions, as EPA did with pentachlorophenol (recently cancelled with a 5-year phaseout after the manufacturer pulled out of the market). Prior research on resistance in agriculture has shown that the only true way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century. Rising resistance, and the need to retain life-saving medications for protecting people's health is another reason why investing in organic is the right choice for the future.

>>Tell EPA to cancel all uses of a pesticide when resistance is discovered or predicted to occur. Tell Congress to ensure that EPA protects public health from deadly antifungal and antibiotic resistance.

Letter to EPA

When bacteria and fungi become resistant to pesticides, it signals that the toxic chemical approach to controlling pathogens does not work. But resistance also poses a direct threat to human health when the pesticide (or a related chemical) is used in human medicine. EPA must cancel all uses of a pesticide found to cause resistance.

The threat of resistance in bacterial human pathogens has long been widely recognized. Although research sponsored by the Environmental Protection Agency (EPA) shows the spread of resistance to antibiotics important in human medicine through horizontal gene transfer in the environment, EPA inaction both on antibiotic and antifungal resistance has become a growing crisis..

EPA recognizes the existence of resistance to fungicides by using codes produced by the Fungicide Resistance Action Committee in registration decisions. Although EPA says resistance “may be considered in the risk-benefit decision-making process,” there is no evidence that the agency actually considers the failure of EPA-registered pesticides to control the target organisms in registration—a failure that affects human and environmental health because those who depend on the pesticide use ever-higher amounts, as medical uses of antibiotics and fungicides become ineffective.

The resistance threat to human health is evident with a number of fungicides, bactericides, and viricides. For example, Candida auris is an emerging fungal pathogen that threatens those with compromised or immature immune systems, such as infants, the elderly, people taking steroids for autoimmune disorders, diabetics, those undergoing chemotherapy, and even smokers. Nearly half of those who contract a C. auris infection die within 90 days. One of the factors making this fungus so deadly is that it has developed resistance to existing antifungal medicines, with 90% of infections resistant to one drug, and 30% to two or more. Culprits in C. auris’s development of resistance include the use of antifungal medications in health care and reliance on fungicides in agriculture.

A recent study conducted by scientists at the University of Georgia finds fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens. Of 700 Aspergillus fumigatus samples collected, nearly 20% (123) displayed some level of resistance to the commonly used azole fungicide tebuconazole. Twelve of the 123 were highly resistant at clinically relevant levels for human health care. No samples taken from organic sites contained resistant fungi.

Azole-resistant strains also display resistance to methyl benzimidazole carbamate fungicides like carbendazim, and quinone outside inhibitors like azoxystrobin. A review of genome sequences shows that genetically, those with broad resistance to azole fungicides show a close match between those discovered on farms and those found in human clinical settings.

These results indicate a need for a shift toward eliminating reliance on toxic fungicides. EPA’s recent response to the rise of drug-resistant C. auris demonstrates EPA’s failure to use the science. The agency failed to assess the efficacy of pesticides not used for public health purposes, only evaluating the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related—thus ignoring the impact of other antimicrobial pesticides on resistance in human pathogens.

Research shows that the only way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century.

Rising resistance, and the need to retain life-saving medications for protecting people’s health require that EPA cancel all uses of a pesticide found to cause resistance.

Letter to Congress

When bacteria and fungi become resistant to pesticides, it signals that the toxic chemical approach to controlling pathogens does not work. But resistance also poses a direct threat to human health when the pesticide (or a related chemical) is used in human medicine. EPA must cancel all uses of a pesticide found to cause resistance.

The threat of resistance in bacterial human pathogens has long been widely recognized. Although research sponsored by the Environmental Protection Agency (EPA) shows the spread of resistance to antibiotics important in human medicine through horizontal gene transfer in the environment, EPA inaction both on antibiotic and antifungal resistance has become a growing crisis..

EPA recognizes the existence of resistance to fungicides by using codes produced by the Fungicide Resistance Action Committee in registration decisions. Although EPA says resistance “may be considered in the risk-benefit decision-making process,” there is no evidence that the agency actually considers the failure of EPA-registered pesticides to control the target organisms in registration—a failure that affects human and environmental health because those who depend on the pesticide use ever-higher amounts, as medical uses of antibiotics and fungicides become ineffective.

The resistance threat to human health is evident with a number of fungicides, bactericides, and viricides. For example, Candida auris is an emerging fungal pathogen that threatens those with compromised or immature immune systems, such as infants, the elderly, people taking steroids for autoimmune disorders, diabetics, those undergoing chemotherapy, and even smokers. Nearly half of those who contract a C. auris infection die within 90 days. One of the factors making this fungus so deadly is that it has developed resistance to existing antifungal medicines, with 90% of infections resistant to one drug, and 30% to two or more. Culprits in C. auris’s development of resistance include the use of antifungal medications in health care and reliance on fungicides in agriculture.

A recent study conducted by scientists at the University of Georgia finds fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens. Of 700 Aspergillus fumigatus samples collected, nearly 20% (123) displayed some level of resistance to the commonly used azole fungicide tebuconazole. Twelve of the 123 were highly resistant at clinically relevant levels for human health care. No samples taken from organic sites contained resistant fungi.

Azole-resistant strains also display resistance to methyl benzimidazole carbamate fungicides like carbendazim, and quinone outside inhibitors like azoxystrobin. A review of genome sequences shows that genetically, those with broad resistance to azole fungicides show a close match between those discovered on farms and those found in human clinical settings.

These results indicate a need for a shift toward eliminating reliance on toxic fungicides. EPA’s recent response to the rise of drug-resistant C. auris demonstrates EPA’s failure to use the science. The agency failed to assess the efficacy of pesticides not used for public health purposes, only evaluating the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related—thus ignoring the impact of other antimicrobial pesticides on resistance in human pathogens.

Research shows that the only way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century.

Please ensure that in view of rising resistance, and the need to retain life-saving medications for protecting people’s health, that EPA cancels all uses of a pesticide found to cause resistance.

02/22/2022 — EPA’s Action to Stop Penta Must Happen Now, Not Over Five Years

Regulation of toxic chemicals must recognize the reality that, “The cocktail of chemical pollution that pervades the planet now threatens the stability of global ecosystems upon which humanity depends,” as stated by The Guardian. When the Environmental Protection Agency (EPA) recognizes the dangers of a toxic chemical—especially one persistent in the environment—it must take immediate action to prevent further contamination. So, allowing the phase-out of chemicals with long residual life can extend the poisoning and contamination for generations.

>>Tell EPA to immediately ban all uses of pentachlorophenol and other toxic wood preservatives. Tell Congress to ensure that EPA does its job.

There is an ongoing crisis, widely reported, posed by the nearly ubiquitous presence of “forever chemicals”—poly- and perfluoroalkyl substances (PFAS) and their relatives. A report by the Centers for Disease Control and Prevention (CDC) finds that 97% of Americans have PFAS in their blood. The Safer States Network finds that more than 210 bills will be considered in at least 32 states in 2022 to try to address the problem. Even the U.S. Environmental Protection Agency has confirmed that 'forever chemicals' are contaminating containers that store pesticide products, and subsequently the products themselves.

PFAS are only the most recent persistent toxic chemicals to achieve notoriety. Ever since its inception, Beyond Pesticides has shown the need to ban highly toxic wood preservatives. According to Koppers Recovery, “43% of all new poles are treated with penta; 42% are treated with CCA; and 13% are treated with creosote.”

EPA has long known about the dangers pentachlorophenol (penta) poses to health, particularly the health of workers in penta production or wood treatment plants and opposed worldwide action to ban the chemical. In 2008, the agency determined that these occupational handlers have a 1 in 1,000 risk of developing cancer. Rather than cancel the chemical at that time to protect worker health, the agency opted to attempt additional mitigation measures, requiring further personal protective equipment, engineering controls, and changes to treatment procedures. With no real-world evidence that this would make a difference, the agency expected these changes to drop the cancer risk to workers. However, in its most recent draft risk assessment, EPA found that this drastically high cancer risk remained the same. The agency's current action to phase-out penta over five years came only when the manufacturer in North America stopped production after being shut down in Mexico.

Similarly, EPA has known about the dangers of creosote and arsenical wood preservatives. Despite a high-profile tour of communities affected by toxic chemicals by EPA Administrator Michael Regan, the agency still fails to make connections that could help protect against the poisoning of workers, fenceline communities, and others. As Mr. Regan, in November, visited Houston, Texas, where thousands of residents are suing Union Pacific Railroad Company for contaminating their properties with highly hazardous creosote wood preservatives, EPA is in the process of reauthorizing creosote use for another 15 years with the knowledge that it is virtually impossible to produce and use without causing contamination and poisoning. When EPA proposed interim decision for creosote, it wrote, “Creosote-treated wood offers unique benefits in the preservation of railroad crossties, wooden utility poles, and round timber foundation piles for land, freshwater, and marine use.” In light of these “unique benefits,” the agency did not even consider the viability of alternatives, such as steel, composites, and fiberglass that could replace the hazardous wood preservative process with non or less toxic materials.

All of the wood preservatives are broadly highly toxic and persistent. There is no safe way to dispose of treated wood. As was seen firsthand by EPA Administrator Regan, it is evident from both history and the present day that chemical corporations target low income, BIPOC neighborhoods to site hazardous industrial processes, creating fence line communities with higher rates of disease incidence and other health problems. EPA must not only clean up contamination caused by past injustices, but also stop future injustice directed toward black and brown communities by suspending the registration of hazardous wood preservatives like creosote.

Unfortunately, when EPA takes action, it is delayed. Although after nearly a century of use, EPA is officially cancelling the highly toxic wood preservative pentachlorophenol (penta), it has done so with a 5-year phase-out period. But the first step to removing these “forever chemicals” from our environment is to quit adding them.

>>Tell EPA to immediately ban all uses of pentachlorophenol and other toxic wood preservatives. Tell Congress to ensure that EPA does its job.

Letter to EPA

 

Regulation of toxic chemicals must recognize the reality that “The cocktail of chemical pollution that pervades the planet now threatens the stability of global ecosystems upon which humanity depends,” according to The Guardian. When EPA recognizes the dangers of a toxic chemical—especially one persistent in the environment—it must take immediate action to prevent further contamination.

There is a widely reported ongoing crisis posed by the nearly ubiquitous presence of “forever chemicals”—poly- and perfluoroalkyl substances (PFAS) and their relatives. 97% of Americans have PFAS in their blood, resulting in more than 210 bills that will be considered in at least 32 states in 2022 to try to address the problem.

But PFAS are only the most recent persistent toxic chemicals to achieve notoriety. Highly toxic wood preservatives pose a similar danger.

EPA has long known about the dangers pentachlorophenol (penta) poses to health, particularly the health of workers in penta production or wood treatment plants. In 2008, the agency determined that these occupational handlers have a 1 in 1,000 risk of developing cancer. Rather than cancel the chemical at that time to protect worker health, the agency opted to attempt additional mitigation measures, requiring further personal protective equipment, engineering controls, and changes to treatment procedures. With no real-world evidence that this would make a difference, the agency expected these changes to drop the cancer risk to workers. However, in its most recent draft risk assessment, EPA found that this drastically high cancer risk remained the same.

Similarly, EPA has known about the dangers of creosote and arsenical wood preservatives. Despite a high-profile tour of communities affected by toxic chemicals by EPA Administrator Michael Regan, EPA still fails to make connections that could help protect against poisoning of workers, fenceline communities, and others. As Mr. Regan, in November, visited Houston, Texas, where thousands of residents are suing Union Pacific Railroad Company for contaminating their properties with highly hazardous creosote wood preservatives, EPA is in the process of reauthorizing creosote use for another 15 years with the knowledge that it is virtually impossible to produce and use without causing contamination and poisoning. In its proposed interim decision for creosote, EPA wrote, “Creosote-treated wood offers unique benefits in the preservation of railroad crossties, wooden utility poles, and round timber foundation piles for land, freshwater, and marine use.” In light of these “unique benefits,” the agency did not even consider the viability of alternatives, such as steel, composites, and fiberglass that could replace the hazardous wood preservative process with non or less toxic materials.

All the wood preservatives are broadly highly toxic and persistent. As was seen firsthand by EPA Administrator Regan, it is evident from both history and the present day that chemical corporations target low income, BIPOC neighborhoods to site hazardous industrial processes, creating fence line communities with higher rates of disease incidence and other health problems. EPA must not only clean up contamination that caused past injustices, but also stop future injustice directed toward black and brown communities by eliminating the use of penta, creosote, and arsenical wood preservatives.

Unfortunately, when EPA takes action, it is delayed. Although after nearly a century of use, EPA is officially cancelling the highly toxic wood preservative pentachlorophenol (penta), it has done so with a 5-year phase-out period. But the first step to removing these “forever chemicals” from our environment is to quit adding them.

Please take action to eliminate use of these persistent toxic chemicals immediately.

Thank you.

Letter to Congress

I am writing out of an urgent concern for our future, in view of increasing contamination with toxic “forever chemicals.”

Regulation of toxic chemicals must recognize the reality that, “The cocktail of chemical pollution that pervades the planet now threatens the stability of global ecosystems upon which humanity depends,” according to the Guardian. When EPA recognizes the dangers of a toxic chemical—especially one persistent in the environment—it must take immediate action to prevent further contamination.

Anyone who reads the news is aware of the crisis posed by the nearly ubiquitous presence of “forever chemicals”—poly- and perfluoroalkyl substances (PFAS) and their relatives. 97% of Americans have PFAS in their blood, resulting in more than 210 bills that will be considered in at least 32 states in 2022 to try to address the problem.

But PFAS are only the most recent persistent toxic chemicals to achieve notoriety. Highly toxic wood preservatives pose a similar danger.

EPA has long known about the dangers pentachlorophenol (penta) poses to health, particularly the health of workers in penta production or wood treatment plants. In 2008, the agency determined that these occupational handlers have a 1 in 1,000 risk of developing cancer. Rather than cancel the chemical at that time to protect worker health, the agency opted to attempt additional mitigation measures, requiring further personal protective equipment, engineering controls, and changes to treatment procedures. The agency expected these changes to drop the cancer risk to workers. However, in its most recent draft risk assessment, EPA found that this drastically high cancer risk remained the same.

Similarly, EPA has known about the dangers of creosote and arsenical wood preservatives. Despite a high-profile tour of communities affected by toxic chemicals by EPA Administrator Michael Regan, EPA still fails to make connections that could help protect against poisoning of workers, fenceline communities, and others. As Mr. Regan visited Houston, Texas, where thousands of residents are suing Union Pacific Railroad Company for contaminating their properties with highly hazardous creosote wood preservatives, EPA is in the process of reauthorizing creosote use for another 15 years with the knowledge that it is virtually impossible to produce and use without causing contamination and poisoning. In its proposed interim decision for creosote, EPA wrote, “Creosote-treated wood offers unique benefits in the preservation of railroad crossties, wooden utility poles, and round timber foundation piles for land, freshwater, and marine use.” In light of these “unique benefits,” the agency did not even consider the viability of alternatives, such as steel, composites, and fiberglass that could replace the hazardous wood preservative process with non or less toxic materials.

All wood preservatives are broadly highly toxic and persistent. As was seen firsthand by EPA Administrator Regan, chemical companies target low income, BIPOC neighborhoods to site hazardous industrial processes, creating fence line communities with higher rates of disease incidence and other health problems. EPA must not only clean up contamination that caused past injustices, but also stop future injustice directed toward black and brown communities by eliminating the use of penta, creosote, and arsenical wood preservatives.

Unfortunately, when EPA takes action, it is delayed. Although after nearly a century of use, EPA is officially cancelling the highly toxic wood preservative pentachlorophenol (penta), it has done so with a 5-year phase-out period. But the first step to removing these “forever chemicals” from our environment is to quit adding them.

Please ensure that EPA takes action to eliminate use of these persistent toxic chemicals immediately.

Thank you.

 

02/14/2022 — Fight Climate Change with Compost

When your food scraps are sent to the landfill, their anaerobic decomposition releases methane, a greenhouse gas with 84 times the global warming potential of carbon dioxide over its first 20 years in the atmosphere. By composting those scraps instead, you not only reduce methane emissions, but also support organic practices that eliminate other greenhouse gases, like nitrogen fertilizer.

California's SB 1383, signed into law in 2016, now requires individuals and businesses to separate food waste from trash. While individuals and businesses can compost their own food waste, local agencies also facilitate the process by providing separate bins for organic materials, including food waste, lawn and garden trimmings, and paper. The law also provides a means for collecting and distributing surplus edible food.

>>Tell your Governor and state legislators to follow the lead of California in fighting climate change with composting. If you live in California, thank your legislators and Governor for passing SB 1383.

Methane comprises 16% of greenhouse gas (GHG) emissions, but due to its greater warming potential, it affects climate change at least as much as carbon dioxide (CO2). Agriculture, energy production, and landfills are among the greatest sources of methane emissions. Directing food waste from landfills to compost can reduce two of these sources. In addition, the use of synthetic fertilizers is a particular and noxious contributor to the rising planetary temperature, largely through these products' emissions of nitrous oxide, or NOx — another potent greenhouse gas that also pollutes the air and feeds the development of ozone. NOx is roughly 300 times as potent in trapping heat as CO2. Nitrous oxide levels have increased, compared to pre-industrial levels, by 20% from all sources. 

Directing food waste to compost can support organic gardening, farming, and land management, thus reducing dependence on synthetic nitrogen fertilizer. As states follow the lead of California in mandating separation of compostable waste, they should also mandate the use of organic land management by public agencies on parks, playing fields, and other public lands. 

You don't need to wait for a law. Start composting now.

>>Tell your Governor and state legislators to follow the lead of California in fighting climate change with composting. If you live in California, thank your legislators and Governor for passing SB 1383.

Letter to Governors and State Legislators (except CA)

When our food scraps are sent to the landfill, their anaerobic decomposition releases methane, a greenhouse gas with 84 times the global warming potential of carbon dioxide over its first 20 years in the atmosphere. By composting those scraps instead, we not only reduce methane emissions, but also support organic practices that eliminate other greenhouse gases, like nitrogen fertilizer.

California’s SB 1383, signed into law in 2016, now requires individuals and businesses to separate food waste from trash. While individuals and businesses can compost their own food waste, local agencies also facilitate the process by providing separate bins for organic materials, including food waste, lawn and garden trimmings, and paper. The law also provides a means for collecting and distributing surplus edible food.

Methane comprises 16% of greenhouse gas (GHG) emissions, but due to its greater warming potential, it affects climate change at least as much as carbon dioxide (CO2). Agriculture, energy production, and landfills are among the greatest sources of methane emissions. Directing food waste from landfills to compost can reduce two of these sources. In addition, the use of synthetic fertilizers is a particular and noxious contributor to the rising planetary temperature, largely through these products’ emissions of nitrous oxide, or NOx — another potent greenhouse gas that also pollutes the air and feeds the development of ozone. NOx is roughly 300 times as potent in trapping heat as CO2. Nitrous oxide levels have increased, compared to pre-industrial levels, by 20% from all sources.

Directing food waste to compost can support organic gardening, farming, and land management, thus reducing dependence on synthetic nitrogen fertilizer. Please draft and pass legislation following the lead of California in mandating separation of compostable waste and also mandate the use of organic land management by public agencies on parks, playing fields, and other public lands.

Please increase the impact of this legislation by using your leadership to require the management of our state parks with organic land management practices. Organic practices not only counter climate change, but they also protect us from the hazards of pesticides.

Thank you.

Letter to CA Governor and Legislators

When our food scraps are sent to the landfill, their anaerobic decomposition releases methane, a greenhouse gas with 84 times the global warming potential of carbon dioxide over its first 20 years in the atmosphere. By composting those scraps instead, we not only reduce methane emissions, but also support organic practices that eliminate other greenhouse gases, like nitrogen fertilizer.

California’s SB 1383, signed into law in 2016, now requires individuals and businesses to separate food waste from trash. While individuals and businesses can compost their own food waste, local agencies also facilitate the process by providing separate bins for organic materials, including food waste, lawn and garden trimmings, and paper. The law also provides a means for collecting and distributing surplus edible food.

Methane comprises 16% of greenhouse gas (GHG) emissions, but due to its greater warming potential, it affects climate change at least as much as carbon dioxide (CO2). Agriculture, energy production, and landfills are among the greatest sources of methane emissions. Directing food waste from landfills to compost can reduce two of these sources. In addition, the use of synthetic fertilizers is a particular and noxious contributor to the rising planetary temperature, largely through these products’ emissions of nitrous oxide, or NOx — another potent greenhouse gas that also pollutes the air and feeds the development of ozone. NOx is roughly 300 times as potent in trapping heat as CO2. Nitrous oxide levels have increased, compared to pre-industrial levels, by 20% from all sources.

Directing food waste to compost can support organic gardening, farming, and land management, thus reducing dependence on synthetic nitrogen fertilizer. Please draft and pass legislation following the lead of California in mandating separation of compostable waste and also mandate the use of organic land management by public agencies on parks, playing fields, and other public lands.

Please increase the impact of this legislation by using your leadership to require the management of our state parks with organic land management practices. Organic practices not only counter climate change, but they also protect us from the hazards of pesticides.

Thank you.

 

02/07/2022 — EPA Must Remove Toxic Ingredients in Disinfectants

Recent research on quaternary ammonium compounds (QACs) shows the critical need for a reassessment of U.S. Environmental Protection Agency (EPA) criteria for determining appropriate disinfectant products where coronavirus (SARS-CoV-2, the virus causing COVID-19), is a concern. EPA maintains a list of disinfectants—List N—that it expects to kill all strains and variants of SARS-CoV-2. However, in creating List N, EPA fails to consider dangers posed by some of the chemicals. QACs, in particular, can cause serious acute and chronic health problems.

>>Tell EPA to reassess its criteria for List N and delist quaternary ammonia compounds. Tell Congress to make sure EPA does its job.

Early in the pandemic, emphasis was placed on disinfecting surfaces, under the mistaken assumption that transmission of the virus was primarily through contact with contaminated surfaces, or fomites. According to the Centers for Disease Control and Prevention (CDC), it is now known that, “The principal mode by which people are infected with SARS-CoV-2 (the virus that causes COVID-19) is through exposure to respiratory droplets carrying infectious virus. It is possible for people to be infected through contact with contaminated surfaces or objects (fomites), but the risk is generally considered to be low.”

A study published in Environmental Science and Technology finds that concentrations of QACs in the human body have increased during the COVID-19 pandemic, raising health and safety concerns. QACs include a variety of chemicals in personal care, pharmaceutical, and medical products used as disinfectants, sanitizers, antimicrobials. However, over the past 70 years, large-scale production and use of these compounds led to accumulation in the environment, including surface water, sediment, and soil. Previously, researchers thought most QACs lack the potential to bioaccumulate, but emerging evidence demonstrates that specific QACs bioaccumulate in blood and other body tissues and can cause a range of toxic effects. Therefore, studies like this highlight the significance of monitoring chemical exposure for adverse health effects. The researchers note, “Further efforts are needed to explore the relationship between the use of QAC-containing products and the levels of QACs in human blood or of their metabolites in urine. Considering the increased use of some QACs as a result of the Covid-19 pandemic, our findings warrant further exposure and epidemiological research focused on QACs.” The results show 15 out of the 18 QACs are detectable in blood samples, with QAC concentrations significantly higher during the pandemic than prior to it. The main routes of exposure include diet, inhalation, ingestion, or the skin.

While EPA has certified several disinfectants as effective against COVID-19 (List N), many of these chemicals are hazardous. Quaternary ammonium compounds are among some of the most harmful disinfectants, as their “long-lasting” properties have adverse impacts on human health, which has extensive documentation in the scientific literature. Effects include mutations, lower fertility, and increased antibiotic resistance. QAC disinfectants' overuse in U.S. Immigration and Custom Enforcement (ICE) detainment centers caused nose bleeds and other adverse health effects. Furthermore, teachers are seeking less harmful disinfectants to use in the classroom, especially as many are experiencing adverse impacts of disinfectant use (e.g., chemical skin burns, respiratory issues). Since EPA has listed so many disinfectant products containing QACs, they remain ubiquitous in the environment as use continues.

EPA is currently promoting false reasoning that a chemical that kills a pathogen necessarily protects health. Although disinfectants like QACs, kill viruses, bacteria, and other microbes via cell wall and protein destruction, they can also negatively affect the immune system, thus reducing resistance to disease. People who have a preexisting condition or are of advanced age, who may have a weakened immune or respiratory system, are more vulnerable to the effects of the virus. When managing viral and bacterial infections, chemicals that exacerbate the risk to vulnerable individuals are of serious concern. 

While Beyond Pesticides identifies “Disinfectants to Avoid,” including those with QACs, many safer disinfectants are, at the same time, listed by EPA as effective against the virus, including citric acid, ethanol, isopropanol, L-lactic acid, hydrogen peroxide, sodium bisulfate, dodecylbenzene sulfonic acid, and thymol. Products containing these chemicals are present on Beyond Pesticides' list of “Disinfectants to Look for.” Avoid pressure to use toxic disinfectants, despite the availability of safer products. In fact, while [CDC] is recommending 70% alcohol for surface disinfection, [EPA's] Office of Pesticide Programs promotes the use of unnecessarily toxic substances.

QACs are harmful to the respiratory system and have a long list of adverse effects from cancer and genetic mutations to lower fertility and increase antibiotic resistance. Most recently, the QAC antimicrobial cetylpyridinium chloride (CPC) has raised concerns. The compound is present in mouthwashes, lozenges, toothpaste, and nasal sprays and is thus commonly encountered orally. A recent study finds CPC has associations with adverse respiratory effects (e.g., lung inflammation). Moreover, acute oral inhalation can be fatal. Since COVID-19 is a systemic (general) disease that overwhelmingly impacts the respiratory system, exposure to CPC presents a heightened risk of co-occurring symptoms. Damage to the respiratory system can also trigger the development of extra-respiratory systemic manifestations like rheumatoid arthritis, and cardiovascular disease

Check out our downloadable infographic The Dirty Side of Disinfectants & Sanitizers.

EPA must assess all risks associated with pesticide use, including the mode of action. EPA's failure to respond to current science is a significant shortcoming of its risk assessment process, especially regarding disease implications. In contrast to EPA, Beyond Pesticides tracks the most recent health studies related to pesticide exposure through the Pesticide-Induced Diseases Database (PIDD). This database supports the clear need for strategic action to shift away from pesticide dependency. For more information on harms associated with pesticide exposure, see PIDD pages on asthma/respiratory effects and other diseases.

>>Tell EPA to reassess its criteria for List N and delist quaternary ammonia compounds. Tell Congress to make sure EPA does its job.

Letter to EPA

Recent research on quaternary ammonium compounds (QACs) shows the need for a reassessment of EPA’s criteria for determining appropriate disinfectants where the SARS-CoV-2 virus is a concern. In creating List N of disinfectants to kill SARS-CoV-2, EPA fails to consider dangers posed by some of the chemicals. QACs, for example, can cause serious acute and chronic health problems.

Early in the pandemic, emphasis was placed on disinfecting surfaces, under the mistaken assumption that transmission of the virus was primarily through contact with contaminated surfaces, or fomites. According to the Centers for Disease Control and Prevention (CDC), it is now known that, “The principal mode by which people are infected with SARS-CoV-2 (the virus that causes COVID-19) is through exposure to respiratory droplets carrying infectious virus. It is possible for people to be infected through contact with contaminated surfaces or objects (fomites), but the risk is generally considered to be low.” This means that elimination of fomites can no longer be used as the basis for allowing high risks of disinfectant chemicals.

A study published in Environmental Science and Technology finds increased concentrations of QACs in the human body during the COVID-19 pandemic, raising health and safety concerns. QACs include a variety of chemicals in personal care, pharmaceutical, and medical products used as disinfectants, sanitizers, antimicrobials. Production and use of these compounds have led to their accumulation in the environment. Emerging evidence demonstrates that specific QACs bioaccumulate in blood and other body tissues, causing a range of toxic effects. The researchers note, “Considering the increased use of some QACs as a result of the Covid-19 pandemic, our findings warrant further exposure and epidemiological research focused on QACs.” Results show 15 out of the 18 QACs are detectable in blood samples, with QAC concentrations significantly higher during the pandemic than prior to it. Routes of exposure include diet, inhalation, ingestion, and the skin.

Many disinfectants on List N are hazardous. QACs are among the most harmful, with effects including mutations, lower fertility, increased antibiotic resistance, and harm to the respiratory system. The antimicrobial QAC cetylpyridinium chloride (CPC), present in mouthwashes, lozenges, toothpaste, and nasal sprays, has been associated with adverse respiratory effects (e.g., lung inflammation). Acute oral inhalation can be fatal. Since COVID-19 is a systemic disease that overwhelmingly impacts the respiratory system, exposure to CPC presents a heightened risk of co-occurring symptoms. Damage to the respiratory system can also trigger the development of systemic disease, including rheumatoid arthritis and cardiovascular disease.

Outside of the lab, QAC overuse in U.S. Immigration and Custom Enforcement (ICE) detainment centers caused nose bleeds and other adverse health effects. Teachers experiencing adverse impacts of disinfectant use (e.g., chemical skin burns, respiratory issues) are seeking less harmful disinfectants to use in the classroom. EPA’s listing of so many disinfectant products containing QACs contributes to their ubiquitous presence in the environment.

Although disinfectants like QACs kill pathogens, they can also negatively affect the immune system, thus reducing resistance to disease. People who have a preexisting condition or are of advanced age, who may have a weakened immune or respiratory system, are more vulnerable to the effects of the virus. When managing viral and bacterial infections, chemicals that exacerbate the risk to vulnerable individuals are of serious concern.

EPA must assess all risks associated with disinfectant use and must reevaluate its assessment of their benefits. QACs do not belong on List N. EPA’s failure to respond to current science is a significant shortcoming of its risk assessment process, especially regarding disease implications.

Letter to Congress

 

Recent research on quaternary ammonium compounds (QACs) shows the need for a reassessment of EPA’s criteria for determining appropriate disinfectants where SARS-CoV-2 is a concern. In creating List N of disinfectants to kill SARS-CoV-2, EPA fails to consider dangers posed by some of the chemicals. QACs, for example, can cause serious acute and chronic health problems.

Early in the pandemic, emphasis was placed on disinfecting surfaces, under the mistaken assumption that transmission of the virus was primarily through contact with contaminated surfaces, or fomites. According to the Centers for Disease Control and Prevention (CDC), it is now known that “The principal mode by which people are infected with SARS-CoV-2 (the virus that causes COVID-19) is through exposure to respiratory droplets carrying infectious virus. It is possible for people to be infected through contact with contaminated surfaces or objects (fomites), but the risk is generally considered to be low.” This means that elimination of fomites can no longer be used as as the basis for allowing high risks of disinfectant chemicals.

A study published in Environmental Science and Technology finds increased concentrations of QACs in the human body during the COVID-19 pandemic, raising health and safety concerns. QACs include a variety of chemicals in personal care, pharmaceutical, and medical products used as disinfectants, sanitizers, antimicrobials. Production and use of these compounds have led to their accumulation in the environment. Emerging evidence demonstrates that specific QACs bioaccumulate in blood and other body tissues, causing a range of toxic effects. The researchers note, “Considering the increased use of some QACs as a result of the Covid-19 pandemic, our findings warrant further exposure and epidemiological research focused on QACs.” Results show 15 out of the 18 QACs are detectable in blood samples, with QAC concentrations significantly higher during the pandemic than prior to it. Routes of exposure include diet, inhalation, ingestion, and the skin.

Many disinfectants on List N are hazardous. QACs are among the most harmful, with effects including mutations, lower fertility, increased antibiotic resistance, and harm to the respiratory system. The antimicrobial QAC cetylpyridinium chloride (CPC), present in mouthwashes, lozenges, toothpaste, and nasal sprays, has been associated with adverse respiratory effects (e.g., lung inflammation). Acute oral inhalation can be fatal. Since COVID-19 is a systemic disease that overwhelmingly impacts the respiratory system, exposure to CPC presents a heightened risk of co-occurring symptoms. Damage to the respiratory system can also trigger the development of systemic disease, including rheumatoid arthritis and cardiovascular disease.

Outside of the lab, QAC overuse in U.S. Immigration and Custom Enforcement (ICE) detainment centers caused nose bleeds and other adverse health effects. Teachers experiencing adverse impacts of disinfectant use (e.g., chemical skin burns, respiratory issues) are seeking less harmful disinfectants to use in the classroom. EPA’s listing of so many disinfectant products containing QACs contributes to their ubiquitous presence in the environment.

Although disinfectants like QACs kill pathogens, they can also negatively affect the immune system, thus reducing resistance to disease. People who have a preexisting condition or are of advanced age, who may have a weakened immune or respiratory system, are more vulnerable to the effects of the virus. When managing viral and bacterial infections, chemicals that exacerbate the risk to vulnerable individuals are of serious concern.

Please ensure that EPA assesses all risks associated with disinfectant use and must reevaluate its assessment of their benefits. QACs do not belong on List N. EPA’s failure to respond to current science is a significant shortcoming of its risk assessment process, especially regarding disease implications.

01/31/2022 — Save the Manatees from Extinction Caused in Large Part by Toxic Runoff

Public concern is now heightened as Florida manatees are facing extremely severe threats—so severe that wildlife officials have resorted to feeding them cabbage and lettuce in an attempt to keep their rapidly dwindling populations alive. Protecting manatees will require a multi-faceted approach, including upgrading their status to endangered and protecting their watery habitat from toxic threats.

>>Tell the U.S. Fish and Wildlife Service to upgrade the Florida manatee to endangered and require protection from chemical pollution. Tell your Congressional Representative and Senators to support H.R. 4946. Tell the Florida Fish and Wildlife Conservation Commission to protect manatees.

Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years old, weigh up to 1,200 lbs, and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants.

In 2017, the U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating that over 1,000 manatees died in just the last year alone, a bipartisan group of Florida Congressional Representatives, Rep Vern Buchanan and Rep Darren Soto, have introduced legislation. (H.R. 4946) that would reclassify the sea cows as endangered.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate (Roundup) herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other natural causes of mortality—including  red tide, and cold stress in the winter months, as manatees are unable to survive in waters below 68 degrees Fahrenheit. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways from lawns and landscapes, parks, golf courses, and farm fields. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and highly manicured landscapes. The algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can either directly kill off more aquatic vegetation, or feed algae blooms as it breaks down. According to recent reporting, in just one region, Sarasota Bay, 18% of seagrass was lost between 2018 and 2020. The Florida Governor's plan to target wastewater treatment is an important component of the solution, particularly in light of major incidents like the Piney Point spill, but more must be done to reduce use of toxics and clean up diffuse sources of pollution as well.

It is critical that lawmakers and the public take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to reduce the need to store tons of fertilizer in precarious lagoons, and spray these and other harmful chemicals broad areas of land throughout the state. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

>>Tell the U.S. Fish and Wildlife Service to upgrade the Florida manatee to endangered and require protection from chemical pollution. Tell your Congressional Representative and Senators to support H.R. 4946. Tell the Florida Fish and Wildlife Conservation Commission to protect manatees.

Letter to U.S. Fish and Wildlife Service

In 2017, the U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating over 1,000 manatees died in just the last year alone, it is clear that optimism over the status of the species was premature.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate (Roundup) herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other natural causes of mortality—including red tide, and cold stress in the winter months, as manatees are unable to survive in waters below 68 degrees Fahrenheit. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and treated landscapes. The algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can either directly kill off more aquatic vegetation, or feed algae blooms as it breaks down. In just one region, Sarasota Bay, 18% of seagrass was lost between 2018 and 2020. The Florida Governor’s plan to target wastewater treatment is an important component of the solution, particularly in light of major incidents like the Piney Point spill, but more must be done to reduce demand and clean up diffuse sources of pollution as well.

It is critical to take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to eliminate threats from harmful chemicals. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

Thank you for considering this request.

Letter to H.R. 4946 Sponsors

I am writing to thank you for introducing H.R. 4946 to re-classify manatees as endangered. Florida manatees are facing severe threats—so severe that wildlife officials have resorted to feeding them cabbage and lettuce in attempts to keep their rapidly dwindling populations alive. Protecting manatees will require a multi-faceted approach, including upgrading their status to endangered and protecting their watery habitat from toxic threats.

Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years old, weigh up to 1,200 lbs, and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants.
In 2017, the U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating over 1,000 manatees died in just the last year alone, it is clear that optimism over the status of the species was premature.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other causes of mortality—including red tide and cold stress in the winter months. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and treated landscapes. Algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can both directly kill off more aquatic vegetation and feed algae blooms as it breaks down. In just one region, Sarasota Bay, 18% of seagrass was lost between 2018 and 2020. The Florida Governor’s plan to target wastewater treatment is an important component of the solution, particularly in light of major incidents like the Piney Point spill, but more must be done to reduce demand and clean up diffuse sources of pollution as well.

It is critical that lawmakers and the public take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to reduce the need to store tons of fertilizer in precarious lagoons, and spray these and other harmful chemicals broad areas of land throughout the state. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

Thank you for your support of the Florida manatee.

Letter to U.S. Representatives and Senators

Florida manatees are facing severe threats—so severe that wildlife officials have resorted to feeding them cabbage and lettuce in attempts to keep their rapidly dwindling populations alive. Protecting manatees will require a multi-faceted approach, including upgrading their status to endangered and protecting their watery habitat from toxic threats. I am writing to ask you to support HR 4946 to re-classify manatees as endangered.

Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years old, weigh up to 1,200 lbs, and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants.

In 2017, the U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating over 1,000 manatees died in just the last year alone, a bipartisan group of Florida Congressmembers, Rep Vern Buchanan and Rep Darren Soto, have introduced legislation (H.R. 4946) that would re-classify the sea cows as endangered.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other causes of mortality—including red tide and cold stress in the winter months. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and treated landscapes. Algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can both directly kill off more aquatic vegetation and feed algae blooms as it breaks down. In just one region, Sarasota Bay, 18% of seagrass was lost between 2018 and 2020. The Florida Governor’s plan to target wastewater treatment is an important component of the solution, particularly in light of major incidents like the Piney Point spill, but more must be done to reduce demand and clean up diffuse sources of pollution as well.

It is critical that lawmakers and the public take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to reduce the need to store tons of fertilizer in precarious lagoons, and spray these and other harmful chemicals broad areas of land throughout the state. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

Please support H.R. 4946.

Thank you.

Letter to Florida Fish and Wildlife Conservation Commission

I am writing to ask you to take action to protect the Florida manatee by using your leadership to help transition the management of state parks to organic land management practices.

In 2017, the U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating over 1,000 manatees died in just the last year alone, it is clear that optimism over the status of the species was premature.

Massive red tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees depend. Starvation resulting from the loss of seagrass beds has been a major cause of death of more than 1,000 manatees last year, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep them alive.

Exposure to contaminants like glyphosate herbicides, which persistently pollute Florida waterways, can increase manatee susceptibility to other natural causes of mortality—including red tide, and cold stress in the winter months, as manatees are unable to survive in waters below 68 degrees Fahrenheit. Because manatees are the only marine mammals that drink freshwater, they are more likely to drink from highly contaminated runoff flowing directly into local waterways. Research finds that 55.8% of manatees have glyphosate in their bodies.

Ongoing use of glyphosate and other herbicides on farms, turfgrass, and directly in waterways is particularly concerning in the context of the current crisis. Incidents of red tide and other harmful algae blooms are exacerbated by nitrogen and phosphorus runoff from industrial farms and treated landscapes. The algae blooms cause a cascade of impacts. Floating on the surface, algae block sunlight to seagrasses and other submerged aquatic vegetation. As seagrass is lost, manatees and other animals that rely on it for food and habitat also suffer. In this context, glyphosate, a phosphorous-based herbicide, can either directly kill off more aquatic vegetation, or feed algae blooms as it breaks down. In just one region, Sarasota Bay, 18% of seagrass was lost between 2018 and 2020. Florida's plan to target wastewater treatment is an important component of the solution, particularly in light of major incidents like the Piney Point spill, but more must be done to reduce demand and clean up diffuse sources of pollution as well.

It is critical to take a holistic look at the problems facing manatees and other marine wildlife and take meaningful action to eliminate threats from harmful chemicals. Organic land management and organic agriculture are critical to the solution. By eliminating toxic pesticide and fertilizer use, and focusing on maintaining or improving soil health, organic practices can stop nonpoint source runoff from making its way into local water bodies.

Thank you for acting to protect the Florida manatee.

01/24/2022 — Toxic Pesticides that Increase Vulnerability to COVID Must Be Eliminated

The advisory board of health experts who counseled President Biden during his transition have now called for an entirely new domestic pandemic strategy geared to the “new normal” of living with the virus indefinitely. While this new strategy addresses important issues like "reimagining public health" and disparities in vulnerability to COVID, it misses out on an important one—reducing vulnerability to disease by eliminating exposure to toxic chemicals, especially those that threaten the immune, nervous, and respiratory systems.

>>Tell the President, EPA, and Congress to address the ongoing threat of Covid-19 by eliminating toxic pesticide use that elevates overall, and disproportionately for people of color, the public's vulnerability to the virus.

The strategic initiative is organized by Ezekiel J. Emanuel, MD, PhD, an oncologist, medical ethicist, and University of Pennsylvania professor who advised former President Barack Obama. The group published a collection of opinion articles in the Journal of the American Medical Association (JAMA). In those articles, the group advises President Biden to give up on an eradication goal, accept that COVID-19 is here to stay—that is, that it is becoming endemic—and adopt a goal of living with it. These articles explore what that means.

The introductory article by Dr. Emanuel et al. says, “As the US moves from crisis to control, this national strategy needs to be updated. Policy makers need to specify the goals and strategies for the 'new normal' of life with COVID-19 and communicate them clearly to the public.” There are many unknowns concerning a future with COV-19, the authors say, including “[t]he precise duration of immunity to SARS-CoV-2 from vaccination or prior infection; . . . whether SARS-CoV-2 will become a seasonal infection; whether antiviral therapies will prevent long COVID; or whether even more transmissible, immune-evading, or virulent variants will arise after Omicron.”

In spite of the uncertainties, the authors believe, “The goal for the 'new normal' with COVID-19 does not include eradication or elimination, e.g., the 'zero COVID' strategy. Neither COVID-19 vaccination nor infection appear to confer lifelong immunity. Current vaccines do not offer sterilizing immunity against SARS-CoV-2 infection. Infectious diseases cannot be eradicated when there is limited long-term immunity following infection or vaccination or nonhuman reservoirs of infection. The majority of SARS-CoV-2 infections are asymptomatic or mildly symptomatic, and the SARS-CoV-2 incubation period is short, preventing the use of targeted strategies like 'ring vaccination.' Even 'fully' vaccinated individuals are at risk for breakthrough SARS-CoV-2 infection. Consequently, a 'new normal with COVID' in January 2022 is not living without COVID-19.”

The authors address the problems of developing a pandemic preparedness program encompassing a comprehensive approach to all respiratory viruses; a comprehensive, digital, real-time, integrated data infrastructure for public health; and advances in vaccines and therapeutics. It must also address “stark racial and ethnic disparities” and differences in vulnerability. 

However, these medical professionals need to look beyond the world of medicine to the world where disparities and differences in vulnerabilities are created. We know that exposure to toxic chemicals like pesticides creates greater vulnerability to disease. The manufacture, use, and disposal of pesticides disproportionately affects farmworker and fenceline communities, where those “stark racial and ethnic disparities” must be addressed. According to the Centers for Disease Control and Prevention: “The COVID-19 pandemic has brought social and racial injustice and inequity to the forefront of public health. It has highlighted that health equity is still not a reality as COVID-19 has unequally affected many racial and ethnic minority groups, putting them more at risk of getting sick and dying from COVID-19.” The use of toxic pesticides is not necessary. Beyond health professionals, agencies like the Environmental Protection Agency (EPA) must be included in a pandemic preparedness program to eliminate exposure to toxic pesticides that increases vulnerability to disease.

>>Tell the President, EPA, and Congress to address the ongoing threat of Covid-19 by eliminating toxic pesticide use that elevates overall, and disproportionately for people of color, the public's vulnerability to the virus.

Letter to President Biden

The advisory board of health experts who counseled you during your transition have now called for an entirely new domestic pandemic strategy geared to the “new normal” of living with the virus indefinitely. While this new strategy addresses important issues like “reimagining public health” and disparities in vulnerability to COVID, it misses out on an important one—reducing vulnerability to disease by eliminating exposure to toxic chemicals, especially those that threaten the immune, nervous, and respiratory systems. We must address the ongoing threat of Covid-19 by eliminating toxic pesticide use that elevates overall, and disproportionately for people of color, vulnerability to the virus.

The strategic initiative is organized by Ezekiel J. Emanuel, MD, PhD, an oncologist, medical ethicist, and University of Pennsylvania professor who advised former President Barack Obama. In a collection of articles in the Journal of the American Medical Association, they advise you to give up on an eradication goal, accept that COVID-19 is here to stay—that is, that it is becoming endemic—and adopt a goal of living with it.

Dr. Emanuel et al. says, “As the US moves from crisis to control, this national strategy needs to be updated. Policy makers need to specify the goals and strategies for the ‘new normal’ of life with COVID-19 and communicate them clearly to the public.” There are many unknowns concerning a future with COV-19, but the authors believe, “The goal for the ‘new normal’ with COVID-19 does not include eradication or elimination, e.g., the ‘zero COVID’ strategy. Neither COVID-19 vaccination nor infection appear to confer lifelong immunity. Current vaccines do not offer sterilizing immunity against SARS-CoV-2 infection. Infectious diseases cannot be eradicated when there is limited long-term immunity following infection or vaccination or nonhuman reservoirs of infection. The majority of SARS-CoV-2 infections are asymptomatic or mildly symptomatic, and the SARS-CoV-2 incubation period is short, preventing the use of targeted strategies like ‘ring vaccination.’ Even ‘fully’ vaccinated individuals are at risk for breakthrough SARS-CoV-2 infection. Consequently, a ‘new normal with COVID’ in January 2022 is not living without COVID-19.”

The authors address the problems of developing a pandemic preparedness program encompassing a comprehensive approach to all respiratory viruses; a comprehensive, digital, real-time, integrated data infrastructure for public health; and advances in vaccines and therapeutics. It must also address “stark racial and ethnic disparities” and differences in vulnerability.

However, there is more to disease prevention than medical advances. Exposure to toxic chemicals like pesticides creates greater vulnerability to disease. The manufacture, use, and disposal of pesticides disproportionately affects farmworker and fenceline communities, where those “stark racial and ethnic disparities” must be addressed. According to the Centers for Disease Control and Prevention: “The COVID-19 pandemic has brought social and racial injustice and inequity to the forefront of public health. It has highlighted that health equity is still not a reality as COVID-19 has unequally affected many racial and ethnic minority groups, putting them more at risk of getting sick and dying from COVID-19.” The use of toxic pesticides is not necessary. Agencies like the Environmental Protection Agency (EPA) must be included in a pandemic preparedness program to eliminate exposure to toxic pesticides that increases vulnerability to disease.

Please instruct EPA to cancel unnecessary pesticide registrations as part of a plan to limit the ongoing threat of Covid-19 to people generally and to people of color who disproportionately have higher rates of the virus.

Letter to U.S. Senators and Representative:

The advisory board of health experts who counseled President Biden during his transition have now called for an entirely new domestic pandemic strategy geared to the “new normal” of living with the virus indefinitely. While this new strategy addresses important issues like "reimagining public health" and disparities in vulnerability to COVID, it misses out on an important one—reducing vulnerability to disease by eliminating exposure to toxic chemicals, especially those that threaten the immune, nervous, and respiratory systems. We must address the ongoing threat of Covid-19 by eliminating toxic pesticide use that elevates overall, and disproportionately for people of color, the public’s vulnerability to the virus.

The strategic initiative is organized by Ezekiel J. Emanuel, MD, PhD, an oncologist, medical ethicist, and University of Pennsylvania professor who advised former President Barack Obama. In a collection of opinion articles in the Journal of the American Medical Association (JAMA), they advise giving up on an eradication goal, accepting that COVID-19 is here to stay—that is, that it is becoming endemic—and adopting a goal of living with it.

Dr. Emanuel et al. says, “As the US moves from crisis to control, this national strategy needs to be updated. Policy makers need to specify the goals and strategies for the ‘new normal’ of life with COVID-19 and communicate them clearly to the public.” There are many unknowns concerning a future with COV-19, but authors believe, “The goal for the ‘new normal’ with COVID-19 does not include eradication or elimination, e.g., the ‘zero COVID’ strategy. Neither COVID-19 vaccination nor infection appear to confer lifelong immunity. Current vaccines do not offer sterilizing immunity against SARS-CoV-2 infection. Infectious diseases cannot be eradicated when there is limited long-term immunity following infection or vaccination or nonhuman reservoirs of infection. The majority of SARS-CoV-2 infections are asymptomatic or mildly symptomatic, and the SARS-CoV-2 incubation period is short, preventing the use of targeted strategies like ‘ring vaccination.’ Even ‘fully’ vaccinated individuals are at risk for breakthrough SARS-CoV-2 infection. Consequently, a ‘new normal with COVID’ in January 2022 is not living without COVID-19.”

The authors address the problems of developing a pandemic preparedness program encompassing a comprehensive approach to all respiratory viruses; a comprehensive, digital, real-time, integrated data infrastructure for public health; and advances in vaccines and therapeutics. It must also address “stark racial and ethnic disparities” and differences in vulnerability.

However, there is more to disease prevention than medical advances. Exposure to toxic chemicals like pesticides creates greater vulnerability to disease. The manufacture, use, and disposal of pesticides disproportionately affects farmworker and fenceline communities, where those “stark racial and ethnic disparities” must be addressed. According to the Centers for Disease Control and Prevention: “The COVID-19 pandemic has brought social and racial injustice and inequity to the forefront of public health. It has highlighted that health equity is still not a reality as COVID-19 has unequally affected many racial and ethnic minority groups, putting them more at risk of getting sick and dying from COVID-19.” The use of toxic pesticides is not necessary. Agencies like EPA must be included in a pandemic preparedness program to eliminate exposure to toxic pesticides that increases vulnerability to disease.

Your oversight is required to ensure that toxic pesticides do not intensify future pandemics.

Letter to EPA Administrator and Office of Pesticide Programs

The advisory board of health experts who counseled President Biden during his transition have now called for an entirely new domestic pandemic strategy geared to the “new normal” of living with the virus indefinitely. While this new strategy addresses important issues like "reimagining public health" and disparities in vulnerability to COVID, it misses out on an important one—reducing vulnerability to disease by eliminating exposure to toxic chemicals, especially those that threaten the immune, nervous, and respiratory systems. We must address the ongoing threat of Covid-19 by eliminating toxic pesticide use that elevates overall, and disproportionately for people of color, the public’s vulnerability to the virus.

The strategic initiative is organized by Ezekiel J. Emanuel, MD, PhD, an oncologist, medical ethicist, and University of Pennsylvania professor who advised former President Barack Obama. In a collection of opinion articles in the Journal of the American Medical Association (JAMA), they advise giving up on an eradication goal, accepting that COVID-19 is here to stay—that is, that it is becoming endemic—and adopting a goal of living with it.

Dr. Emanuel et al. says, “As the US moves from crisis to control, this national strategy needs to be updated. Policy makers need to specify the goals and strategies for the ‘new normal’ of life with COVID-19 and communicate them clearly to the public.” There are many unknowns concerning a future with COV-19, but the authors believe, “The goal for the ‘new normal’ with COVID-19 does not include eradication or elimination, e.g., the ‘zero COVID’ strategy. Neither COVID-19 vaccination nor infection appear to confer lifelong immunity. Current vaccines do not offer sterilizing immunity against SARS-CoV-2 infection. Infectious diseases cannot be eradicated when there is limited long-term immunity following infection or vaccination or nonhuman reservoirs of infection. The majority of SARS-CoV-2 infections are asymptomatic or mildly symptomatic, and the SARS-CoV-2 incubation period is short, preventing the use of targeted strategies like ‘ring vaccination.’ Even ‘fully’ vaccinated individuals are at risk for breakthrough SARS-CoV-2 infection. Consequently, a ‘new normal with COVID’ in January 2022 is not living without COVID-19.”

The authors address the problems of developing a pandemic preparedness program encompassing a comprehensive approach to all respiratory viruses; a comprehensive, digital, real-time, integrated data infrastructure for public health; and advances in vaccines and therapeutics. It must also address “stark racial and ethnic disparities” and differences in vulnerability.

However, there is more to disease prevention than medical advances. Exposure to toxic chemicals like pesticides creates greater vulnerability to disease. The manufacture, use, and disposal of pesticides disproportionately affects farmworker and fenceline communities, where those “stark racial and ethnic disparities” must be addressed. According to the Centers for Disease Control and Prevention: “The COVID-19 pandemic has brought social and racial injustice and inequity to the forefront of public health. It has highlighted that health equity is still not a reality as COVID-19 has unequally affected many racial and ethnic minority groups, putting them more at risk of getting sick and dying from COVID-19.” The use of toxic pesticides is not necessary. Agencies like EPA must be included in a pandemic preparedness program to eliminate exposure to toxic pesticides that increases vulnerability to disease.

Please eliminate the use of toxic pesticides as part of a plan to limit the ongoing threat of Covid-19 to people generally and to people of color who disproportionately have higher rates of the virus.

 

 

01/14/2022 — Tell the Senate to Pass Voting Rights Legislation Now!

As environmental and public health advocates, the democratic process is key to the urgent progress needed to address key health threats, biodiversity collapse, and the climate crisis. The democratic process is key to advancing solutions that Beyond Pesticides works on by growing organic solutions and standards that provide for a livable and sustainable future. 

We will not meet the existential environmental and health challenges of our time without a strong democratic process, where all people can protect their families and communities through the electoral process.

Our democracy and the right to vote has been under attack for quite some time but escalated with the deadly attack on the U.S. Capitol one year ago. In fact, 19 states have already passed laws that are clearly designed to suppress votes, especially those of Americans of color who are forced to stand in long lines and often miss work, instead of being provided easy access to the ballot. 

>>Tell your Senators to fix procedural roadblocks in the Senate and pass legislation to ensure that everyone can easily exercise their right to vote.

Why are we talking about voting rights? Voter suppression targets the same marginalized communities impacted by environmental racism. Environmental justice issues arise at every stage of the cradle-to-grave life cycle of toxic chemicals, from production, transportation, handling, and use, to disposal... 

  • Petroleum refineries are likely to be sited near poor communities composed of people of color. 
  • Mines contaminate tribal lands and poor rural communities. 
  • Manufacturing facilities are also located near low-income neighborhoods, employing their inhabitants in hazardous jobs. 
  • Pesticides are applied by farmworkers whose housing is surrounded by poisoned fields.
  • Landscapers who handle dangerous pesticides are disproportionately people of color in many communities. 
  • Lower-income individuals living in older, larger multi-dwellings suffer adverse health from pesticides that are heavily used in those buildings.
  • Toxic pesticides are applied more often in parks, playgrounds, and public spaces in lower-income neighborhoods. 
  • And, coming full circle, hazardous waste “disposal” sites are surrounded by low-income communities.

Our future is on the line. The voices of those from marginalized communities and environmentalists must be heard and their right to vote protected. For people and the planet to survive, we must adopt the changes necessary to reverse public health threats, biodiversity collapse, and the climate crisis. That's exactly why we must pass voting rights legislation, including the Freedom to Vote Act and John Lewis Voting Rights Advancement Act. 

>>Tell your Senators to fix procedural roadblocks in the Senate and pass legislation to ensure that everyone can easily exercise their right to vote.

Letter to Senate

As environmental and public health advocates, the democratic process is key to the urgent progress needed to address key health threats, biodiversity collapse, and the climate crisis. The democratic process is key to advancing solutions that Beyond Pesticides works on by growing organic solutions and standards that provide for a livable and sustainable future.

We will not meet the existential environmental and health challenges of our time without a strong democratic process, where all people can protect their families and communities through the electoral process.

Our democracy and the right to vote has been under attack for quite some time but escalated with the deadly attack on the U.S. Capitol one year ago. In fact, 19 states have already passed laws that are clearly designed to suppress votes, especially those of Americans of color who are forced to stand in long lines and often miss work, instead of being provided easy access to the ballot.

Why are we talking about voting rights? Voter suppression targets the same marginalized communities impacted by environmental racism.

Environmental justice issues arise at every stage of the cradle-to-grave life cycle of toxic chemicals, from production, transportation, handling, and use, to disposal...
• Petroleum refineries are likely to be sited near poor communities composed of people of color.
• Mines contaminate tribal lands and poor rural communities.
• Manufacturing facilities are also located near low-income neighborhoods, employing their inhabitants in hazardous jobs.
• Pesticides are applied by farmworkers whose housing is surrounded by poisoned fields.
• Landscapers who handle dangerous pesticides are disproportionately people of color in many communities.
• Lower-income individuals living in older, larger multi-dwellings suffer adverse health from pesticides that are heavily used in those buildings.
• Toxic pesticides are applied more often in parks, playgrounds, and public spaces in lower-income neighborhoods.
• And, coming full circle, hazardous waste “disposal” sites are surrounded by low-income communities.

Our future is on the line. The voices of those from marginalized communities and environmentalists must be heard and their right to vote protected. For people and the planet to survive, we must adopt the changes necessary to reverse public health threats, biodiversity collapse, and the climate crisis. That’s exactly why we must pass voting rights legislation, including the Freedom to Vote Act and John Lewis Voting Rights Advancement Act.

Please fix the procedural roadblocks in the Senate and pass legislation to ensure that everyone can easily exercise their right to vote.

Thank you.

01/10/2022 — Ask Congress to Push for Oversight of USDA’s Dishonest Disclosure of GE Food Ingredients

The U.S. Department of Agriculture (USDA) is now undermining full public disclosure of genetically engineered ingredients in our food, both through misrepresentation in labeling and through a definition that allows a large percentage of ingredients to go undisclosed. The National Bioengineered Food Disclosure Act, dubbed the Deny Americans the Right to Know (DARK) Act by food safety advocates, establishes a national GMO (genetically modified organisms or genetically engineered GE) food labeling requirement that has led to deceptive messaging, preempts states from adopting stronger label language and standards, and excludes a large portion of the population without special cell phone technology (because information is accessed the QR codes on products). However, USDA regulations go further—creating loopholes and barriers to transparency that prohibit the use of the widely-known terms "GMO" and "GE" and prohibit retailers from providing more information to consumers.

>>Tell USDA Secretary Tom Vilsack to require USDA agencies to honestly disclose genetically engineered ingredients and carry out the goals of the Executive Memorandum, Modernizing Regulatory Review. Urge your U.S. Senators and Representative to ask Agriculture Committees to hold oversight hearings to ensure that USDA holds to those goals. 

USDA is huge—encompassing 29 agencies and offices, with almost 100,000 employees—with duties ranging from research to marketing to distributing money to regulation. These agencies have a variety of missions, sometimes conflicting. The conflict was evident in the creation of regulations to implement the Dark Act. USDA has also been described as a captured agency that largely serves the interests of chemical-intensive agriculture and agribusiness. This was recognized when President Nixon shifted pesticide regulation out of USDA to the newly created Environmental Protection Agency (EPA) in 1970. It was also recognized when Congress passed the Organic Foods Production Act (OFPA) and created an independent panel of stakeholders, the National Organic Standards Board (NOSB), to provide oversight and direct USDA in implementing the law.

USDA encourages the use of genetically engineered crops, which, in turn, increases pesticide use and pesticide dependency. This conflict between promoting GE and chemical-intensive agriculture and protecting the public through the use of transparent labeling is one way that USDA's practices are in conflict with the direction of President Biden's inauguration day action, the Executive Memorandum and directive Modernizing Regulatory Review. This presidential action instructs 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. Oversight is necessary to hold federal agencies—especially captured agencies like USDA— accountable to full transparency and public safety.  

>>Tell USDA Secretary Tom Vilsack to require USDA agencies to honestly disclose genetically engineered ingredients in food and carry out the goals of the Executive Memorandum, Modernizing Regulatory Review. Urge your U.S. Senators and Representative to ask Agriculture Committees to hold oversight hearings to ensure that USDA holds to those goals.

Letter to Congress

The U.S. Department of Agriculture (USDA) is huge—encompassing 29 agencies and offices, with almost 100,000 employees—with duties ranging from research to marketing to distributing money to regulation. Many have referred to USDA as a captured agency that largely serves the interests of chemical-intensive agriculture and agribusiness. This was recognized when President Nixon shifted pesticide regulation out of USDA to the newly created Environmental Protection Agency (EPA) in 1970. It was also recognized when Congress passed the Organic Foods Production Act (OFPA) and created an independent panel of stakeholders, the National Organic Standards Board (NOSB), to provide oversight and direct USDA in implementing the law.

USDA’s agencies have a variety of missions, sometimes conflicting. The conflict was evident in the creation of regulations to implement the National Bioengineered Food Disclosure Act. The statute itself, dubbed the Deny Americans the Right to Know (DARK) Act by food safety advocates, establishes a national GMO (genetically modified organisms or genetically engineered GE) food labeling requirement that has led to deceptive messaging, preempts states from adopting stronger label language and standards, and excludes a large portion of the population without special cell phone technology (because information is accessed the OR codes on products). However, USDA regulations go further—creating loopholes and barriers to transparency that prohibit the use of the widely-known terms "GMO" and "GE" and prohibit retailers from providing more information to consumers.

USDA encourages the use of genetically engineered crops, which, in turn, increases pesticide use and pesticide dependency. This conflict between promoting GE and chemical-intensive agriculture and protecting the public through the use of transparent labeling is one way that USDA’s practices are in conflict with the direction of President Biden’s inauguration day action, 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.

Oversight is necessary to hold USDA accountable to the goals of this administration as expressed in the Executive Memorandum.

Please ask the Agriculture Committee to hold oversight hearings to ensure that USDA honestly discloses genetically engineered ingredients in food and carries out the goals of the Executive Memorandum, Modernizing Regulatory Review.

Thank you.

Letter to USDA

The U.S. Department of Agriculture (USDA) is huge—encompassing 29 agencies and offices, with almost 100,000 employees—with duties ranging from research to marketing to distributing money to regulation. Its agencies also have a variety of missions, sometimes conflicting. The conflict of programs supporting chemical-intensive agriculture with those promoting the interests of health, environment, and organic farmers was recognized when President Nixon shifted pesticide regulation from USDA to the newly created Environmental Protection Agency (EPA) in 1970. It was also recognized when Congress passed the Organic Foods Production Act (OFPA) and created an independent panel of stakeholders, the National Organic Standards Board (NOSB), to provide oversight and direct USDA in implementing the law.

The conflict was also evident in the creation of regulations to implement the National Bioengineered Food Disclosure Act. The statute itself, dubbed the Deny Americans the Right to Know (DARK) Act by food safety advocates, establishes a national GMO (genetically modified organisms or genetically engineered GE) food labeling requirement that has led to deceptive messaging, preempts states from adopting stronger label language and standards, and excludes a large portion of the population without special cell phone technology (because information is accessed the QR codes on products). However, USDA regulations go further—creating loopholes and barriers to transparency that prohibit the use of the widely-known terms "GMO" and "GE" and prohibit retailers from providing more information to consumers.

USDA generally encourages the use of genetically engineered crops, which, in turn, increases pesticide use and pesticide dependency. This conflict between promoting GE and chemical-intensive agriculture and protecting the public through the use of transparent labeling is one way that USDA’s practices are in conflict with the direction of President Biden’s inauguration day action, 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.

I urge you to hold USDA agencies accountable to the goals of this administration as expressed in the Executive Memorandum.

Thank you.

01/03/2022 — Tell the Senate: The Pesticide Law Needs Real Reform

Environmentalists and public health advocates are calling for an aggressive program of policy change in 2022—change they say is critical to addressing existential crises of public health threats, biodiversity collapse, and severe climate disruption that is not being taken seriously by policy makers.

On November 23, 2021, Senator Cory Booker introduced legislation to eliminate many of the current problems with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which regulates the registration and use of pesticides in the U.S. It corrects some of the worst mistakes in registering pesticides and removes some of the worst loopholes in the law. However, in order to prevent future pesticide problems, we need reform that goes deeper. 

>>Urge your Senators to co-sponsor PACTPA and reforms to the toxic core of FIFRA.  

Specifically, the bill, the Protect America's Children from Toxic Pesticides Act of 2021 (PACTPA), would provide some desperately needed improvements to FIFRA to better protect people and the environment, including:

1. Bans some of the most damaging pesticides scientifically known to cause significant harm to people and the environment:

  • Organophosphate insecticides, which are designed to target the neurological system and have been linked to neurodevelopmental damage in children;
  • Neonicotinoid insecticides, which have contributed to pollinator collapse around the world (the European Union and Canada have significantly restricted or banned their use to protect pollinators and other wildlife) and have recently been shown to cause developmental defects, heart deformations, and muscle tremors in unborn children;
  • Paraquat, which is one of the most acutely toxic herbicides in the world—according to the EPA, just “one sip can kill.” Science has shown that chronic exposure to paraquat increases the risk of developing Parkinson's disease by 200% to 600%. It is already banned in 32 countries, including the European Union.

2. Restores balance to protect ordinary citizens by removing dangerous pesticides from the market by:

  • Creating a petition process to enable individual citizens to petition the EPA to identify dangerous pesticides so that the EPA would no longer be able to indefinitely allow dangerous pesticides to remain on the market;
  • Closing dangerous loopholes that have allowed the EPA to issue emergency exemptions and conditional registrations to use pesticides before they have gone through full health and safety review by the agency;
  • Enabling local communities to enact protective legislation and other policies without being vetoed or preempted by state law;
  • Suspending the use of pesticides deemed unsafe by the E.U. or Canada until they are thoroughly reviewed by the EPA.

3. Provides protections for frontline communities that bear the burden of pesticide exposure by:

  • Requiring employers of farmworkers to report all pesticide-caused injuries to the EPA, with strong penalties for failure to report injuries or retaliating against workers;
  • Directing the EPA to review pesticide injury reports and work with the pesticide manufacturers to develop better labeling to prevent future injury;
  • Requiring that all pesticide label instructions be written in Spanish and in any language spoken by more than 500 pesticide applicators.

Despite this impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, Congress must:

1. Prohibit the registration and use of pesticides that do not meet these criteria:

  • Necessary to prevent harm to humans and the environment based on an analysis of all alternatives;
  • Cause no harm to humans and the environment; and
  • Protect against the existential crises of biodiversity collapse, runaway climate change, and chronic and acute health threats.

2. Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration).

3. Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects.

4. Deny and cancel registrations of all pesticides posing a threat to life in the soil—and hence threatening the climate.

5. Deny and cancel registrations of all pesticides posing a threat to any endangered species.

>>Urge your Senators to co-sponsor PACTPA and reforms to the toxic core of FIFRA.  

Letter to Sponsors: Senators Booker, Gillibrand, Padilla, Sanders and Warren

Thank you for your sponsorship of the Protect America’s Children from Toxic Pesticides Act of 2021 (PACTPA). PACTPA would provide some improvements to the pesticide law (FIFRA) to better protect people and the environment, including:

1. Bans some of the most damaging pesticides scientifically known to cause significant harm to people and the environment:

- Organophosphate insecticides, which are designed to target the neurological system and have been linked to neurodevelopmental damage in children;
- Neonicotinoid insecticides, which have contributed to pollinator collapse around the world (the European Union and Canada have significantly restricted or banned their use to protect pollinators and other wildlife) and have recently been shown to cause developmental defects, heart deformations, and muscle tremors in unborn children;
- Paraquat, which is one of the most acutely toxic herbicides in the world —according to the EPA, just “one sip can kill.” Science has shown that chronic exposure to paraquat increases the risk of developing Parkinson’s disease by 200% to 600%. It is already banned in 32 countries, including the European Union.

2. Removes dangerous pesticides from the market by:
- Creating a petition process to enable individual citizens to petition the EPA to identify dangerous pesticides so that the EPA would no longer be able to indefinitely allow dangerous pesticides to remain on the market;
- Closing dangerous loopholes that have allowed the EPA to issue emergency exemptions and conditional registrations to use pesticides before they have gone through full health and safety review by the agency;
- Enabling local communities to enact protective legislation and other policies without being vetoed or preempted by state law;
- Suspending the use of pesticides deemed unsafe by the E.U. or Canada until they are thoroughly reviewed by the EPA.

3. Provides protections for frontline communities that bear the burden of pesticide exposure by:
- Requiring employers of farmworkers to report all pesticide-caused injuries to the EPA, with strong penalties for failure to report injuries or retaliating against workers;
- Directing the EPA to review pesticide injury reports and work with the pesticide manufacturers to develop better labeling to prevent future injury;
- Requiring that all pesticide label instructions be written in Spanish and in any language spoken by more than 500 pesticide applicators.

Despite this impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, please introduce legislation to:

1. Prohibit the registration and use of pesticides that do not meet these criteria:
- Necessary to prevent harm to humans and the environment based on an analysis of all alternatives;
- Cause no harm to humans and the environment; and
- Protect against the existential crises of biodiversity collapse, runaway climate change, and chronic and acute health threats.

2. Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration).

3. Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects.

4. Deny and cancel registrations of all pesticides posing a threat to life in the soil—and hence threatening the climate.

5. Deny and cancel registrations of all pesticides posing a threat to any endangered species.

We look forward to working with you to advance legislation that is truly protective of health and the environment as fossil fuel-based pesticides and fertilizers are contributing public health threats, biodiversity collapse, and the climate crisis. We do not need toxic pesticides to maintain agricultural productivity or quality of life and look forward to the adoption of legislation that reflects this.

Thank you for your leadership.

Letter to Other Senators

I am writing to urge you to cosponsor the Protect America’s Children from Toxic Pesticides Act of 2021 (PACTPA). PACTPA would provide some desperately-needed improvements to the pesticide law (FIFRA) to better protect people and the environment, including:

1. Bans some of the most damaging pesticides scientifically known to cause significant harm to people and the environment:
- Organophosphate insecticides, which are designed to target the neurological system and have been linked to neurodevelopmental damage in children;
- Neonicotinoid insecticides, which have contributed to pollinator collapse around the world (the European Union and Canada have significantly restricted or banned their use to protect pollinators and other wildlife) and have recently been shown to cause developmental defects, heart deformations, and muscle tremors in unborn children;
- Paraquat, which is one of the most acutely toxic herbicides in the world —according to the EPA, just “one sip can kill.” Science has shown that chronic exposure to paraquat increases the risk of developing Parkinson’s disease by 200% to 600%. It is already banned in 32 countries, including the European Union.

2. Removes dangerous pesticides from the market by:
- Creating a petition process to enable individual citizens to petition the EPA to identify dangerous pesticides so that the EPA would no longer be able to indefinitely allow dangerous pesticides to remain on the market;
- Closing dangerous loopholes that have allowed the EPA to issue emergency exemptions and conditional registrations to use pesticides before they have gone through full health and safety review by the agency;
- Enabling local communities to enact protective legislation and other policies without being vetoed or preempted by state law;
- Suspending the use of pesticides deemed unsafe by the E.U. or Canada until they are thoroughly reviewed by the EPA.

3. Provides protections for frontline communities that bear the burden of pesticide exposure by:
- Requiring employers of farmworkers to report all pesticide-caused injuries to the EPA, with strong penalties for failure to report injuries or retaliating against workers;
- Directing the EPA to review pesticide injury reports and work with the pesticide manufacturers to develop better labeling to prevent future injury;
- Requiring that all pesticide label instructions be written in Spanish and in any language spoken by more than 500 pesticide applicators.

Despite this impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, please support legislation to:

1. Prohibit the registration and use of pesticides that do not meet these criteria:
- Necessary to prevent harm to humans and the environment based on an analysis of all alternatives;
- Cause no harm to humans and the environment; and
- Protect against the existential crises of biodiversity collapse, runaway climate change, and chronic and acute health threats.

2. Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration).

3. Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects.

4. Deny and cancel registrations of all pesticides posing a threat to life in the soil—and hence threatening the climate.

5. Deny and cancel registrations of all pesticides posing a threat to any endangered species.

We look forward to working with you to advance legislation that is truly protective of health and the environment as fossil fuel-based pesticides and fertilizers are contributing public health threats, biodiversity collapse, and the climate crisis. We do not need toxic pesticides to maintain agricultural productivity or quality of life and look forward to the adoption of legislation that reflects this.

Thank you.