Action of the Week Archive

Thirty-nine years ago, on December 2, 1984, a Union Carbide plant in Bhopal, India, released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic disease range up to 95% of the affected population of 531,881. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. In spite of this history and the many adverse effects of aldicarb, the U.S. Environmental Protection Agency (EPA) is now considering reviving the pesticide's use in citrus production. 

>>Tell EPA not to revive the use of aldicarb. Tell your Congressional Senators and Representative to ensure that EPA decisions are not dictated by the chemical industry.

Less than a year after the Bhopal tragedy, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV. This time, at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA. A tank car ruptured, dumping 19,000 gallons of the soil sterilant metamsodium into the Sacramento River. Several hundred people were hospitalized after inhaling fumes. The chemical causes birth defects and fetal death and is a known mutagen, so the total impact on human health is unknown. However, the chemical sterilized a 41-mile stretch of the river, killing over a million fish and thousands of trees. Such events are not in the distant past, as shown by the derailment of about 50 out of 141 cars on the Norfolk Southern train that exploded in a towering fireball over the town of East Palestine, OH in February 2023. Among the compounds on board those cars were “inert” pesticide ingredients (vinyl chloride, ethylhexyl acrylate, and isobutylene), an antimicrobial compound (ethylene glycol monobutyl ether [EGBE]), benzene (a carcinogenic solvent), and butyl acrylate. In 2022, train accidents resulted in releases of hazardous chemicals 11 times. 

These examples of injuries to humans and the environment show that the harm caused by pesticides goes far beyond the impacts to consumers, farmworkers, other organisms, air, water, and soil caused by the application of those poisons, which are also extensive. We are all potentially affected. In some cases—including aldicarb—the damages caused by use alone have been shown many times to be, in the words of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), “unreasonable adverse effects.”  

In fact, no pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. In short, it is a suspected endocrine disruptor and is linked to neurotoxic and reproductive effects, asthma, and learning behavior problems. It has been detected in groundwater, is a potential leacher, and is toxic to birds and fish/aquatic organisms. In use, it has been implicated in poisoning of workers and their children, poisoning deer and other game consuming contaminated seeds, and notably, poisoning food grown in soil treated with the chemical. The effects don't stop there—aldicarb is also notorious for contaminating groundwater. Aldicarb is a highly toxic, systemic carbamate insecticide banned by over 100 countries under the Rotterdam Convention. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category. 

Aldicarb may persist in groundwater for decades due to its long half-life between 200 to 2,000 days, and ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Furthermore, aldicarb is a systemic pesticide that plant roots and leaves readily uptake, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees. 

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

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

This revival of consideration of aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions. Despite previous cancellations due to unreasonable adverse effects, particularly on children's health through voluntary cancellations, EPA is now considering approving the use of aldicarb for use on Florida oranges and grapefruits. The harms of aldicarb are perhaps the best documented of all pesticides.  

Please see the Daily News from December 14, 2023, for more information about aldicarb.

EPA must not revive the use of aldicarb, which is responsible for so much death and destruction, beginning with its manufacture and continuing through its use. 

>>Tell EPA not to revive the use of aldicarb. Tell your Congressional Senators and Representative to ensure that EPA decisions are not dictated by the chemical industry.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.  

Thank you for your active participation and engagement!

Photo credit: This June 8, 2010 file photo, a worker cleans the dust as he displays a panel of photos of people who died in the 1984 Bhopal gas disaster at the forensic department of Gandhi Medical College in Bhopal, India. India's Supreme Court issued notices Monday, Feb. 28, 2011 to Dow Chemicals and Union Carbide Corp. seeking payment of US$1.7 billion in enhanced compensation for survivors of the world's worst industrial disaster that occurred more than 26 years ago. (AP Photo/Prakash Hatvalne)

Letter to EPA:

Thirty-nine years ago, on December 3, 1984, a Union Carbide plant in Bhopal, India, released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic diseases range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. In spite of this history and the many adverse effects of aldicarb, EPA is now considering reviving the pesticide’s use.  

Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metamsodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert” pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate.   

Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. In fact, no pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. It is a suspected endocrine disruptor, linked to neurotoxic and reproductive effects, asthma, and learning behavior problems. It has been detected in groundwater, is a potential leacher, and is toxic to birds and fish/aquatic organisms. It is a systemic pesticide readily taken up by plant roots and leaves, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees.  

It has been implicated in poisoning of workers and their children, game-consuming contaminated seeds, and notably, food grown in soil treated with the chemical. Aldicarb is also notorious for contaminating groundwater, where it may persist for decades due to its long half-life between 200 to 2,000 days. Ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Aldicarb is a highly toxic, systemic carbamate insecticide banned by over 100 countries under the Rotterdam Convention. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category.  

Evidence demonstrates that past use of aldicarb on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. In 2017 and 2018, the Florida Department of Agriculture denied “Special Local Needs” approval for use on Florida citrus because the registrant was unable to demonstrate that aldicarb is safer than alternatives.  

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

I am appalled that despite previous cancellations due to unreasonable adverse effects, particularly on children's health, EPA is now considering approving the use of aldicarb for use on Florida oranges and grapefruits. This reconsideration of aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.   

EPA must not revive the use of aldicarb, which is responsible for so much death and destruction, beginning with its manufacture and continuing through its use.  

Thank you.

Letter to U.S. Senators and Representative:

Thirty-nine years ago—on December 3, 1984—a Union Carbide plant in Bhopal, India, released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic diseases range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. In spite of this history and the many adverse effects of aldicarb, EPA is now considering reviving the pesticide’s use.  

Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metamsodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert” pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate.   

Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. In fact, no pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. It is a suspected endocrine disruptor, linked to neurotoxic and reproductive effects, asthma, and learning behavior problems. It has been detected in groundwater, is a potential leacher, and is toxic to birds and fish/aquatic organisms. It is a systemic pesticide readily taken up by plant roots and leaves, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees.  

Aldicarb has been implicated in poisoning of workers and their children, game-consuming contaminated seeds, and notably, food grown in soil treated with the chemical. It is also notorious for contaminating groundwater, where it may persist for decades due to its long half-life, between 200 to 2,000 days. Ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Aldicarb is a highly toxic, systemic insecticide banned by over 100 countries under the Rotterdam Convention. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category.  

Evidence demonstrates that past use of aldicarb on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. In 2017 and 2018, the Florida Department of Agriculture denied “Special Local Needs” approval for use on Florida citrus because the registrant was unable to demonstrate that aldicarb is safer than alternatives.  

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

I am appalled that despite previous cancellations due to unreasonable adverse effects, particularly on children's health, EPA is now considering approving the use of aldicarb for use on Florida oranges and grapefruits. This reconsideration of aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.   

Please ensure that EPA does not revive the use of aldicarb, which is responsible for so much death and destruction, beginning with its manufacture and continuing through its use.  

Thank you.

The state of California is often in the lead in regulating pesticides. The state's protective actions often provide a model for the nation. In addition, California supplies the nation with a third of the country's vegetables and nearly three-quarters of the country's fruits and nuts, so people throughout the country have a stake in California's regulation of pesticides.  

The California Department of Pesticide Regulation (DPR) has proposed a new regulation to provide advance notification to all Californians of some of the most hazardous pesticides used in agriculture. This proposed regulation, while progress, does not provide enough transparency. 

>>Tell DPR to require exact field locations for dangerous pesticide applications and commit to improvements based on community input.

We applaud this precedent-setting proposal to provide Californians with the basic right to know about planned use of toxic chemicals in our neighborhoods. However, DPR's proposal will not provide the exact location of planned pesticide applications, instead giving only the 1x1 square mile “section”—even though the exact field location is known to county officials in advance. 
 
This has been shown to be inadequate in four small pilot notification projects last year. In those pilots, DPR received unanimous feedback: Without exact location, these notifications do not provide the information people need to protect themselves.  
 
DPR has also repeatedly promised that the proposed notification program is just a starting point, and the regulation will be revised in future. But the proposed notification does not provide any opportunity for communities to weigh in—just a report by DPR staff after three years with zero commitment to make any changes.  
 
Tell DPR not to waste this historic opportunity! We want the exact location of pesticide applications in California, and a commitment to listen to impacted residents and to make real changes if the regulation is not working.  

>>Tell DPR to require exact field locations for dangerous pesticide applications and commit to improvements based on community input."

The target for this Action is the California Department of Pesticide Regulation. 

Thank you for your active participation and engagement!

Letter to DPR Director Julie Henderson

The state of California is often in the lead in regulating pesticides. The state’s protective actions provide a model for the nation. In addition, California supplies the nation with a third of the country’s vegetables and nearly three-quarters of the country’s fruits and nuts, so people throughout the country have a stake in California’s regulation of pesticides.

The California Department of Pesticide Regulation (DPR) has proposed a new regulation to provide advance notification to all Californians of some of the most hazardous pesticides used in agriculture. This proposed regulation does not go far enough.

I applaud this precedent-setting proposal to provide Californians with the basic right to know about the planned use of toxic chemicals in our neighborhoods. However, DPR’s proposal will not provide the exact location of planned pesticide applications, instead giving only the 1x1 square mile “section”—even though the exact field location is known to county officials in advance.

This has been shown to be inadequate in four small pilot notification projects last year. In those pilots, DPR received unanimous feedback: Without exact location, these notifications do not provide the information people need to protect themselves. 

DPR has also repeatedly promised that the proposed notification program is just a starting point and that the regulation will be revised in the future. But the proposed notification doesn’t provide any opportunity for communities to weigh in—just a report by DPR staff after three years with zero commitment to make any changes. 

Please do not waste this historic opportunity to protect Californians and provide a model for the nation. We want the exact location of pesticide applications in California and a commitment to listen to impacted residents and make real changes if the regulation is not working.

Thank you.

*Update: This Action of the Week is updated to address the organic status of the company cited in the piece, Merchant’s Garden. The company is certified as organic under a different name (Merchant’s Garden Agrotech) than the name used in the USDA press release. As a result, their name did not appear in USDA's Organic Integrity Database (OID) at the time of the original Daily News and Action of the Week posting. USDA updated OID on December 8, 2023, the same day it received a complaint from former National Organic Standard Board chair Jim Riddle. The critical focus of the piece remains the same: It is not disclosed to consumers on food products labeled "organic" when that food or ingredients are grown hydroponically. Beyond Pesticides, as indicated, views hydroponic as a conventional growing practice that does not meet the spirit and intent of the organic system, as defined in the Organic Foods Production Act.

On November 27, Secretary of Agriculture Tom Vilsack announced the release of funds from the USDA Rural Business Development and Value-Added Producer Grant Programs to assist in the financing or expansion of rural businesses. In total, 185 projects worth nearly $196 million are being funded to create new and better market opportunities for agricultural producers. 

One of the projects highlighted in the USDA announcement is very troubling. The announcement states, “Merchant's Garden LLC is a hydroponic and aquaponic farm in Tucson, Arizona. The company will use a $250,000 Value-Added Producer Grant to expand marketing and sales of prepackaged salad mixes to help them become a local supplier of organic leafy greens for southern Arizona.” However, Merchant's Garden's website does not make any organic claims for its produce, so it can only be concluded that USDA is urging this hydroponic/aquaponic producer to seek organic certification.* 

>>Tell Secretary Vilsack and your Congressional representatives to ensure that USDA ceases promotion of hydroponically-grown products as “organic.”

Taxpayer dollars should not used to finance a hydroponic/aquaponic operation that does not comply with the Organic Foods Production Act (OFPA). If products from this operation are to be sold as “organic,” it will cause harm to producers who comply with OFPA. It will also deceive consumers, who purchase organic products believing that such products are produced in healthy, fertile soil, as required by the organic law and regulations. To the extent that hydroponic operations supplant soil-based (real) organic operations, these subsidies negate the climate and biodiversity benefits of organic agriculture.  

The Organic Foods Production Act, at 6513(b), requires that all organic crop production operations submit and follow organic plans that, “shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” The same section of OFPA goes on to state, “An organic plan shall not include any production or handling practices that are inconsistent with this chapter.”  

The Earth needs many more real organic farms that support soil health, help sequester carbon dioxide, and avoid the use of materials like soluble nitrogen fertilizers that contribute many times as much warming potential as carbon dioxide. USDA's financial support should go to new and transitioning organic farms. 

By decisive vote in 2010, the USDA's National Organic Standards Board determined that hydroponic and aquaponic operations are inconsistent with OFPA and do not qualify for organic certification. The National Organic Program (NOP) must determine whether Merchant's Garden LLC complies with section 6513(b) of the Organic Foods Production Act and whether the operation intends to sell their hydroponically-grown products as “organic.” If the operation does not comply, NOP must ensure that it is not certified organic. 

>>Tell Secretary Vilsack and your Congressional representatives to ensure that USDA ceases promotion of hydroponically-grown products as “organic."

The targets for this Action are the U.S. Department of Agriculture and the U.S. Congress.  

Thank you for your active participation and engagement!

Letter to Secretary Vilsack: 

On November 27, you announced the release of funds from the USDA Rural Business Development and Value-Added Producer Grant Programs to assist in the financing or expansion of rural businesses. In total, 185 projects worth nearly $196 million are being funded to create new and better market opportunities for agricultural producers.  

One of the projects highlighted in the USDA announcement is very troubling. The announcement states, “Merchant’s Garden LLC is a hydroponic and aquaponic farm in Tucson, Arizona. The company will use a $250,000 Value-Added Producer Grant to expand marketing and sales of prepackaged salad mixes to help them become a local supplier of organic leafy greens for southern Arizona.” However, Merchant’s Garden’s website does not make any organic claims for its produce, so it can only be concluded that USDA is urging this hydroponic/aquaponic producer to seek organic certification.  

Taxpayer dollars should not used to assist a hydroponic/aquaponic operation that does not comply with the Organic Foods Production Act (OFPA) to sell products as organic. If products from this operation are to be sold as organic, it will cause harm to producers who comply with OFPA. It will also deceive consumers, who purchase organic products believing that such products are produced in healthy, fertile soil, as required by the OFPA and regulations. To the extent that hydroponic operations supplant soil-based (real) organic operations, these subsidies negate the climate and biodiversity benefits of organic agriculture.  

The Organic Foods Production Act, at 6513(b), requires that all organic crop production operations submit and follow organic plans that “shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” The same section of OFPA goes on to state, “An organic plan shall not include any production or handling practices that are inconsistent with this chapter.”   

The Earth needs many more real organic farms that support soil life, help sequester carbon dioxide, and avoid the use of materials like soluble nitrogen fertilizers that contribute many times as much warming potential as carbon dioxide. USDA’s financial support should go to new and transitioning organic farms.  

By decisive vote in 2010, the USDA’s National Organic Standards Board determined that hydroponic and aquaponic operations are inconsistent with OFPA and do not qualify for organic certification. The National Organic Program (NOP) must determine whether Merchant’s Garden LLC complies with section 6513(b) of the Organic Foods Production Act and whether the operation intends to sell its hydroponically-grown products as “organic.” If the operation does not comply, NOP must ensure it is not certified organic.  

Thank you. 

Letter to Representative and Senators: 

On November 27, Secretary of Agriculture Tom Vilsack announced the release of funds from the USDA Rural Business Development and Value-Added Producer Grant Programs to assist in the financing or expansion of rural businesses. In total, 185 projects worth nearly $196 million are being funded to create new and better market opportunities for agricultural producers.  

One of the projects highlighted in the USDA announcement is very troubling. The announcement stated, “Merchant’s Garden LLC is a hydroponic and aquaponic farm in Tucson, Arizona. The company will use a $250,000 Value-Added Producer Grant to expand marketing and sales of prepackaged salad mixes to help them become a local supplier of organic leafy greens for southern Arizona.” However, Merchant’s Garden’s website does not make any organic claims for its produce, so it can only be concluded that USDA is urging this hydroponic/aquaponic producer to seek organic certification.  

Taxpayer dollars should not used to assist a hydroponic/aquaponic operation that does not comply with the Organic Foods Production Act (OFPA) to sell products as organic. If products from this operation are to be sold as organic, it will cause harm to producers who comply with OFPA. It will also deceive consumers, who purchase organic products believing that such products are produced in healthy, fertile soil, as required by the OFPA and regulations. To the extent that hydroponic operations supplant soil-based (real) organic operations, these subsidies negate the climate and biodiversity benefits of organic agriculture.  

The Organic Foods Production Act, at 6513(b), requires that all organic crop production operations submit and follow organic plans that “shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” The same section of OFPA goes on to state, “An organic plan shall not include any production or handling practices that are inconsistent with this chapter.”   

The Earth needs many more real organic farms that support soil life, help sequester carbon dioxide, and avoid the use of materials like soluble nitrogen fertilizers that contribute many times as much warming potential as carbon dioxide. USDA’s financial support should go to new and transitioning organic farms.  

By decisive vote in 2010, the USDA’s National Organic Standards Board determined that hydroponic and aquaponic operations are inconsistent with OFPA and do not qualify for organic certification. The National Organic Program (NOP) must determine whether Merchant’s Garden LLC complies with section 6513(b) of the Organic Foods Production Act and whether the operation intends to sell its hydroponically-grown products as “organic.” If the operation does not comply, NOP must ensure it is not certified organic.  

Please tell Secretary Vilsack to ensure that all certifiers are consistently preventing organic certification of operations that do not comply with section 6513(b) of the Organic Foods Production Act.  

Thank you. 

Final regulations implementing the Pregnant Workers Fairness Act (PWFA) are expected to be issued by the Equal Employment Opportunity Commission (EEOC) in December, 2023. The legislation, which went into effect June 23, 2023, and applies to all workplaces with 15 or more employees, extends protection for pregnant workers for disability (including temporary or short-term disability) associated with childbirth, miscarriages, or related conditions. The legislation was passed as part of the 2023 Omnibus Spending Bill and signed into law by President Biden in December 2022.  

This law should be used to improve protections for farmworkers and other high-risk employees from the elevated adverse impacts on reproductive health associated with pesticides. One of the law's key provisions is an anti-retaliation clause that protects workers asking for “reasonable accommodation.” In addition, accommodations for pregnant workers cannot be imposed by the employer but must be agreeable to the worker as well.  

>>Tell EEOC to require an enforcement plan that ensures pregnant farmworkers will not work in or be exposed to drift from pesticide-treated fields; EPA to update its Worker Protection Standard to ensure that pregnant farmworkers are not exposed to pesticides; and President Biden (through Secretary of State Blinken) to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

Barriers for pregnant farmworkers have been demonstrated in California, where farmworkers—regardless of citizenship status—who are exposed to pesticides can take time off during the pregnancy as a preventive measure if other accommodations are not available, receiving 70 percent of their wages to make up for lost income—to be increased to 90 percent for low-wage workers in 2025. Farmworkers in California who are exposed to pesticides can access this program practically from the time they find out they are pregnant because of the risk pesticide exposure poses. However, farmworkers have historically been shut out of these programs due to language and access barriers, lack of information for workers and their medical care providers, and racism.  

By any measure, farmworkers and agricultural communities are among the least protected and least visible populations in the United States. Despite health risks, most pregnant farmworkers cannot afford to take unpaid time off, often working throughout their pregnancies and returning shortly after giving birth. The annual income for farmworkers is estimated to be just $25,000 to $30,000 a year, and the majority of workers are Latinx. 

Disproportionate Pesticide Harm Is Racial Injustice and Systemic Racism 

Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. As Beyond Pesticides previously reported, 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, highlights the systemic racism of our country's pesticide policies. Our nation depends on farmworkers, 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.

Many farmworkers are migrant workers, and are subject to conditions that would not be permitted for U.S. citizens. The U.S. is not a signatory to the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard to treat migrant workers like workers who are citizens. To learn more about farmworker protection, please visit Beyond Pesticides' Agricultural Justice page. 

EPA must update its Worker Protection Standards and, more fundamentally, must base its pesticide risk assessments on the dangers to the most vulnerable people—pregnant farmworkers and their families. EPA must reverse its policy and require that risk assessments adopt a standard that protects farmworkers. Food production is not sustainable unless the workers who plant and harvest our food are safe in their place of employment. 

Pregnant farmworkers and their families are better protected when we support organic agriculture and purchase organic food. Organic practices eliminate industrial agriculture's reliance on petrochemical pesticides and synthetic fertilizers, protecting health and the environment. 

>>Tell EEOC to require an enforcement plan that ensures pregnant farmworkers will not work in or be exposed to drift from pesticide-treated fields; EPA to update its Worker Protection Standard to ensure that pregnant farmworkers are not exposed to pesticides; and President Biden (through Secretary of State Blinken) to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

The targets for this Action are the U.S. Equal Employment Opportunity Commission, the U.S. Environmental Protection Agency, and the U.S. Secretary of State.  

Thank you for your active participation and engagement!

Letter to U.S. Environmental Protection Agency (EPA): 

Final regulations implementing the Pregnant Workers Fairness Act (PWFA) are expected to be issued by the Equal Employment Opportunity Commission (EEOC) in December, 2023. The legislation, which went into effect June 23, 2023, and applies to all workplaces with 15 or more employees, extends protection for pregnant workers for disability (including temporary or short-term disability) associated with childbirth, miscarriages, or related conditions. The legislation was passed as part of the 2023 Omnibus Spending Bill and signed into law by President Biden in December 2022. 

This law should be used to improve protections for farmworkers and other high-risk employees from the elevated adverse impacts on reproductive health associated with pesticides. EPA’s Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworker communities.  

Farmworkers need enforceable protections. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. 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. 

Many farmworkers are migrant workers and are subject to conditions that would not be permitted for U.S. citizens. The U.S. is not a signatory to the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard to treat migrant workers like workers who are citizens. 

In alignment with the Pregnant Workers Fairness Act (PWFA), please update the agency’s worker protection standard to not permit pregnant farmworkers to work in fields that have been treated with pesticides or work in fields that are subject to pesticide drift. Additionally, please tell President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families. 

Thank you. 

Letter to Equal Opportunity Committee (EEOC): 

Final regulations implementing the Pregnant Workers Fairness Act (PWFA) are expected to be issued by the Equal Employment Opportunity Commission (EEOC) in December 2023. The legislation, which went into effect June 23, 2023 and applies to all workplaces with 15 or more employees, extends protection for pregnant workers for disability (including temporary or short-term disability) associated with childbirth, miscarriages, or related conditions. The legislation was passed as part of the 2023 Omnibus Spending Bill and signed into law by President Biden in December 2022. 

This law should be used to improve protections for farmworkers and other high-risk employees from the elevated adverse impacts on reproductive health associated with pesticides. EPA’s Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworker communities.  

Farmworkers need enforceable protections. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. 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. 

As a means of enforcing the EEOC regulations for the Pregnant Workers Fairness Act (PWFA), please insist that EPA and state agencies responsible for enforcing federal law, under agreements with the federal government, protect pregnant farmworkers by not permitting pregnant farmworkers to work in fields that have been treated with pesticides or work in fields that are subject to pesticide drift. Additionally, please advise President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families. 

Thank you. 

Letter to Secretary of State Antony Blinken: 

I am writing to ask your assistance in protecting migrant farmworkers. 

Final regulations implementing the Pregnant Workers Fairness Act (PWFA) are expected to be issued by the Equal Employment Opportunity Commission (EEOC) in December 2023. The legislation, which went into effect June 23, 2023 and applies to all workplaces with 15 or more employees, extends protection for pregnant workers for disability (including temporary or short-term disability) associated with childbirth, miscarriages, or related conditions. The legislation was passed as part of the 2023 Omnibus Spending Bill and signed into law by President Biden in December 2022. 

This law should be used to improve protections for farmworkers and other high-risk employees from the elevated adverse impacts on reproductive health associated with pesticides. EPA’s Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworker communities.  

Farmworkers need more protection. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. 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. 

Many farmworkers are migrant workers and are subject to conditions that would not be permitted for U.S. citizens. The U.S. is not a signatory to the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard to treat migrant workers like workers who are citizens. 

Please tell President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families. 

Thank you. 

As the pesticide industry and pesticide users look to the Farm Bill as a vehicle for growing their economic interests at the expense of health and the environment, there is the Reducing Regulatory Burdens Act, HR 5089. Introduced in the U.S. House of Representatives by Rep. David Rouzer (R-NC) in July, the legislation would reverse a U.S. Environmental Protection Agency (EPA) requirement to obtain a permit before spraying pesticides on or near waterways. This is a repeat of HR 953, which failed to pass the Senate in 2017. The legislation is actually part of an effort to undermine the purpose of the Clean Water Act—" to restore and maintain the chemical, physical, and biological integrity of the Nation's waters.” This bill follows other attempts to weaken the Clean Water Act, including a court decision limiting the definition of “waters of the U.S.” and subsequent revision of EPA's regulations protecting wetlands. 

>>Tell Congress that protection of the nation's water should be strengthened, not weakened.

HR 5089, if enacted into law, would reverse a 2009 decision issued by the 6th Circuit Court of Appeals, in the case of National Cotton Council et al. v. EPA, which held that pesticides applied to waterways should be considered pollutants under federal law and regulated under the Clean Water Act, through National Pollutant Discharge Elimination System (NPDES) permits. Prior to the decision, the EPA, under the Bush Administration, had allowed the weaker and more generalized standards under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) to be followed. This allowed pesticides to be discharged into U.S. waterways without any federal oversight, as FIFRA does not require tracking such applications and assessing the adverse effects on local ecosystems. 

To be clear, HR 5089 would: 
(1) undermine federal authority to protect U.S. waters under the Clean Water Act,  
(2) allow spraying of toxic chemicals into waterways without local and state oversight, 
(3) contaminate drinking water sources and harm aquatic life, and 
(4) not reduce claimed burdens to farmers, since there are currently no burdens. 

Backers of the bill continually argue that the permit requirements place undue burdens on farmers, but in reality, the majority of pesticide applicators can obtain a permit with little restriction, and agricultural activities are exempt from the requirement. What the bill will actually do is take away Americans' right to know what toxic chemicals are entering their waterways. “This bill takes away the public's right to know about toxic pesticides we may be exposed to,” Mae Wu, senior attorney for the Natural Resources Defense Council's health program, said in a statement about the earlier bill, emailed to ThinkProgress. “It eliminates the current commonsense requirement that communities should have access to basic information about what's being sprayed in waters that can pose risks for public health.” 

If this bill passes, citizens will be forced to take innovative local actions to protect threatened waters. Already, nearly 2,000 waterways are impaired by pesticide contamination, and many more have simply not been tested. A U.S. Geological Survey (USGS) and National Park Service collaborative survey report finds a harmful mixture of pollutants, including pesticides, pharmaceuticals, caffeine, methylparaben, algal toxins, and fecal and parasitic bacteria, in Pipestone Creek at Pipestone National Monument in Minnesota—adding to evidence of widespread pesticide contamination in waterways across the U.S. Pesticide contamination in waterways is historically commonplace. Known pesticide water contaminants, such as atrazine, metolachlor, and simazine, continue to be detected in streams more than 50 percent of the time, with fipronil being the pesticide most frequently found at levels of potential concern for aquatic organisms in urban streams. A 2018 report from the U.S. Geological Survey (USGS) reveals the year-round presence of neonicotinoids (neonics) in the Great Lakes – the world's largest freshwater ecosystem. Neonics, which are highly toxic to aquatic organisms and pollinators, are prevalent in the tributaries of the Great Lakes with concentrations and detections increasing during planting season. In 2015, another USGS report found that neonicotinoid insecticides contaminate over half of urban and agricultural streams across the United States and Puerto Rico.  

The 2021 U.S. Geological Services (USGS) study of pesticide contamination of rivers on the U.S. mainland finds that degradation of those rivers from pesticide pollution continues unabated. USGS scientists looked at data from 2013 to 2017 (inclusive) from rivers across the country and offered these top-level conclusions: “(1) pesticides persist in environments beyond the site of application and expected period of use, and (2) the potential toxicity of pesticides to aquatic life is pervasive in surface waters.” Ultimately, water quality and aquatic organisms and their ecosystems will be fully protected from pesticides only through a wholesale movement to organic land management practices. 

>>Tell Congress that protection of the nation's water should be strengthened, not weakened. 

The target for this Action is the U.S. Congress.

Thank you for your active participation and engagement!

Letter to U.S. Representative and Senators

On July 28, Rep. David Rouzer (R-NC) introduced in U.S. House of Representatives HR 5089, a bill that would reverse an Environmental Protection Agency (EPA) requirement to obtain a permit before spraying pesticides on or near waterways. Titled The Reducing Regulatory Burdens Act, it is actually part of an effort to undermine the purpose of the Clean Water Act—"to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” Please reject this bill either as standalone legislation or as a provision in the 2023 Farm Bill.

Passed in 1972, the Clean Water Act set bold goals for drinkable, swimmable waters in this country. Unfortunately, the “National Pollution Discharge Elimination System” has not made significant steps towards eliminating polluting discharges but has instead reinforced them. Even less progress has been made towards eliminating nonpoint source pollution, such as agricultural runoff.

Already, nearly 2,000 waterways are impaired by pesticide contamination, and many more have simply not been tested. A U.S. Geological Survey (USGS) and National Park Service collaborative survey report finds a harmful mixture of pollutants, including pesticides, pharmaceuticals, caffeine, methylparaben, algal toxins, and fecal and parasitic bacteria, in Pipestone Creek at Pipestone National Monument in Minnesota, U.S.— adding to evidence of widespread pesticide contamination in waterways across the U.S. Pesticide contamination in waterways is historically commonplace. Known pesticide water contaminants continue to be detected in streams more than 50 percent of the time. A 2018 report from the U.S. Geological Survey (USGS) reveals the year-round presence of neonicotinoids (neonics), which are highly toxic to aquatic organisms and pollinators, in the Great Lakes–the world’s largest freshwater ecosystem, with concentrations and detections increasing during planting season. An earlier USGS report found that neonicotinoid insecticides contaminate over half of urban and agricultural streams across the United States and Puerto Rico.

HR 5089, if enacted into law, would reverse a 2009 decision issued by the 6^th Circuit Court of Appeals, in the case of National Cotton Council et al. v. EPA, which held that pesticides applied to waterways should be considered pollutants under federal law and regulated under the Clean Water Act (CWA), through National Pollutant Discharge Elimination System (NPDES) permits. Prior to the decision, the EPA, had allowed the weaker and more generalized standards under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) to be followed. This allowed pesticides to be discharged into U.S. waterways without any federal oversight, as FIFRA does not require tracking such applications and assessing the adverse effects on local ecosystems.

To be clear, HR 5089 would:
(1) undermine federal authority to protect U.S. waters under the Clean Water Act,
(2) allow spraying of toxic chemicals into waterways without local and state oversight,
(3) contaminate drinking water sources and harm aquatic life, and
(4) not reduce claimed burdens to farmers, since there are currently no burdens.

Backers of the bill argue that the permit requirements place undue burdens on farmers, but the majority of pesticide applicators can obtain a permit with little restriction, and agricultural activities are exempt from the requirement. The bill will actually take away Americans’ right to know what toxic chemicals are entering their waterways, eliminating the current commonsense requirement that communities should have access to basic information about what’s being sprayed in waters that can pose risks for public health.

Please oppose HR 5089 and tell EPA to take stronger steps "to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.”

Thank you.

The Thanksgiving Address (the Ohèn:ton Karihwatéhkwen) of the Haudenosaunee (also known as the Iroquois Confederacy or Six Nations—Mohawk, Oneida, Cayuga, Onondaga, Seneca, and Tuscarora) reflects their relationship to the Earth by giving thanks for life and the world around them. It is a prayer that is appropriate at any time, but especially on a holiday celebrating the abundance of the Earth’s gifts. 

As you read this prayer, please choose actions to protect our relationship with the natural world and her inhabitants. Beyond Pesticides thanks all of you for your support. 

The People  

Today we have gathered and we see that the cycles of life continue. We have been given the duty to live in balance and harmony with each other and all living things. So now, we bring our minds together as one as we give greetings and thanks to each other as people.  

Now our minds are one.  

The Earth Mother  

We are all thankful to our Mother, the Earth, for she gives us all that we need for life. She supports our feet as we walk about upon her. It gives us joy that she continues to care for us as she has from the beginning of time. To our mother, we send greetings and thanks.  

Now our minds are one. 

The Waters  

We give thanks to all the waters of the world for quenching our thirst and providing us with strength. Water is life. We know its power in many forms- waterfalls and rain, mists and streams, rivers and oceans. With one mind, we send greetings and thanks to the spirit of Water.  

Now our minds are one.  

The Fish  

We turn our minds to all the Fish life in the water. They were instructed to cleanse and purify the water. They also give themselves to us as food. We are grateful that we can still find pure water. So, we turn now to the Fish and send our greetings and thanks.  

Now our minds are one.  

The Plants  

Now we turn toward the vast fields of Plant life. As far as the eye can see, the Plants grow, working many wonders. They sustain many life forms. With our minds gathered together, we give thanks and look forward to seeing Plant life for many generations to come.  

Now our minds are one. 

The Food Plants  

With one mind, we turn to honor and thank all the Food Plants we harvest from the garden. Since the beginning of time, the grains, vegetables, beans, and berries have helped the people survive. Many other living things draw strength from them too. We gather all the Plant Foods together as one and send them a greeting of thanks.  

Now our minds are one.  

The Medicine Herbs  

Now we turn to all the Medicine herbs of the world. From the beginning, they were instructed to take away sickness. They are always waiting and ready to heal us. We are happy there are still among us those special few who remember how to use these plants for healing. With one mind, we send greetings and thanks to the Medicines and to the keepers of the Medicines.  

Now our minds are one.  

The Animals  

We gather our minds together to send greetings and thanks to all the Animal life in the world. They have many things to teach us as people. We are honored by them when they give up their lives so we may use their bodies as food for our people. We see them near our homes and in the deep forests. We are glad they are still here and we hope that it will always be so.  

Now our minds are one. 

The Trees  

We now turn our thoughts to the Trees. The Earth has many families of Trees who have their own instructions and uses. Some provide us with shelter and shade, others with fruit, beauty and other useful things. Many people of the world use a Tree as a symbol of peace and strength. With one mind, we greet and thank the Tree life.  

Now our minds are one.  

The Birds  

We put our minds together as one and thank all the Birds who move and fly about over our heads. The Creator gave them beautiful songs. Each day they remind us to enjoy and appreciate life. The Eagle was chosen to be their leader. To all the Birds—from the smallest to the largest—we send our joyful greetings and thanks.  

Now our minds are one.  

The Four Winds  

We are all thankful to the powers we know as the Four Winds. We hear their voices in the moving air as they refresh us and purify the air we breathe. They help us to bring the change of seasons. From the four directions they come, bringing us messages and giving us strength. With one mind, we send our greetings and thanks to the Four Winds.  

Now our minds are one.  

Beyond Pesticides wishes you—our readers, network, and supporters—a healthy Thanksgiving and holiday season. We appreciate you joining us as we strive to elevate our voices for transformational change to protect health and the environment.

>>Click here to read a personal Thanksgiving appeal from Executive Director Jay Feldman and please consider supporting our programming at our secure site—bp-dc.org/give2023

As shown by the recent court decision overturning EPA's attempt to cancel agricultural uses of the highly neurotoxic insecticide chlorpyrifos, the pesticide regulatory process is broken and cannot protect people or the environment from the dangers of their use. The alternative is to promote policies at the state and local level that move toward organic land management in agriculture, communities, and homes.

>>Tell your governor and mayor to adopt policies that support organic land management. 

EPA's action to cancel all agricultural uses of chlorpyrifos was a rare instance when the agency took protective action. Required by a 9th Circuit Court of Appeals decision in April 2021 to take action, EPA issued a final rule in August, 2021—in full effect February 28, 2022—after an earlier 9th Circuit decision, concluding that, “EPA is unable to conclude that the risk from aggregate exposure from the use of chlorpyrifos meets the safety standard of the Federal Food, Drug, and Cosmetic Act (FFDCA). Accordingly, EPA is revoking all tolerances for chlorpyrifos.” On November 3, the 8th Circuit U.S. Court of Appeals decided to vacate EPA's 2021 decision to cancel all food tolerances for chlorpyrifos and sent it back to the agency.

In other cases, EPA has avoided such litigation by taking more limited action. When the industry challenges EPA, the agency almost invariably capitulates through a negotiation process. With the chemical paraquat, EPA allowed an industry umbrella group dubbed the Agricultural Handler Exposure Task Force to correct its data risks posed to workers, resulting in the agency changing its position within months. With the synthetic pyrethroid class of insecticides, EPA allowed an industry group to rework its methodology for addressing pyrethroid risks to children and followed the request of another industry group to allow the pyrethroids to be sprayed with smaller buffer zones during windier conditions. With the chemical glyphosate, despite overwhelming evidence of its carcinogenic properties, the agency has refused to acknowledge this risk, even after a federal court chastised its review process, and instead has acted on the behest of chemical manufacturers to stop glyphosate from being banned in other countries.

The examples of this pattern are numerous, including the recent EPA decision to cancel the deadly chlorinated hydrocarbon wood preservative, pentachlorophenol, with dioxin contaminants, among others (see Pesticide Gateway), after it watched countries around the world one-by-one ban its use under an international treaty—the Stockholm Convention, which was never ratified by the U.S. With a severely diminished market worldwide and difficultly setting up a manufacturing shop in the U.S. after a community and state uproar in South Carolina, the manufacturer withdrew—after 40-plus years of fighting and unthinkable cases of cancer. EPA then announced in March of this year that it was time to cancel the chemical.

And even when EPA suspends the registration of a pesticide, removal from use is very slow because existing stocks are generally allowed to be sold. For example, EPA suspended the registration of the herbicide dimethyl tetrachloroterephthalate (DCPA) (also widely known as Dacthal), effective August 22, 2023, leaving existing stocks (products containing DCPA manufactured before August 22) available on the market.

These examples and more demonstrate that the “whack-a-mole” approach cannot adequately protect against the dangers of pesticides. What is required are policies at every level of government that encourage the adoption of organic agriculture and land management practices. 

Organic management practices build soil health, cycle nutrients naturally, enhance plant resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers. The organic alternative is central to a commitment to both the elimination of practices and products that are petrochemical-based and the ability of organically managed soils to draw down (sequester) atmospheric carbon, which contributes to mitigating global warming and erratic temperatures.

States should adopt a strategy promoting natural and working lands as a critical yet currently underutilized sector in the fight against climate change. These lands can sequester and store carbon emissions, limit future carbon emissions into the atmosphere, protect people and nature from the impacts of climate change, and build resilience to future climate risks. Climate smart management of natural and working lands also improves public health and safety, secures our food and water supplies, and increases equity.

The strategy should define the state's natural and working landscapes; describe how these lands can deliver on climate change goals; highlight priority nature-based climate solutions to address the climate crisis; explore opportunities for regional climate smart land management; identify options to track nature-based climate action and measure progress; and outline opportunities to scale climate smart land management across regions and sectors in the state. States should set a pesticide-free goal for state parks. 

To be effective, the strategy must include ambitious targets focused on reduction of agricultural chemicals and support for organic agriculture. These measures also address other crises, including microbial support for ecosystem health and biodiversity. Industrial farming systems dependent on synthetic fertilizers and other chemical inputs must be replaced with organic systems that do not use chemicals in which animals and feed sources are fully integrated. 

Many communities are already adopting organic land management in parks, playing fields, and other public lands. Beyond Pesticides partners with major organic retailer, Natural Grocers, and organic food company, Stonyfield Organic, and dozens of communities in all regions of the country to see this vision come to life. Natural land care is becoming increasingly popular at the local level, with more and more communities looking to employ practices that protect workers, public health, pets, pollinators, and unique local environments that can be harmed by unnecessary pesticide use. At the same time, community leaders are increasingly challenged with staffing constraints and tight budgets. Beyond Pesticides' Parks for a Sustainable Future program aims to bridge these gaps, allowing communities to pilot the transition to organic land care on two public sites. 

Sign up to be a Parks Advocate today to encourage your community to transition to organic land management!

Program pilot sites provide local land care officials the time needed to dial in new practices and work out any unexpected factors that may impede the move from conventional to organic land care.  They send a message to residents that the community is taking meaningful action to protect their health and environment, at a lower cost to community coffers than a rapid, full-scale transition to organic land care that local pesticide reform policies are increasingly requiring. 

>>Tell your governor and mayor to adopt policies that support organic land management. 

The targets for this Action are U.S. state governors and U.S. municipal mayors, vice-mayors, and mayors pro-tem (*as available in the Every Action database).

*Our database may not include your Mayor through our one-click action. However, you may use our proposed language for sending a letter to your Mayor. Please cut-and-paste the text available below and send in an email to your local Mayor's office.

Thank you for your active participation and engagement!

Letter to Governor:

As shown by the recent court decision overturning EPA’s attempt to cancel agricultural uses of highly neurotoxic insecticide chlorpyrifos, the pesticide regulatory process is broken and cannot protect people or the environment from the dangers of their use. As a result, we need policies at the state and local level that move toward organic land management in agriculture, communities, and homes.

EPA’s action to cancel all agricultural uses of chlorpyrifos was a rare instance when the agency took protective action. Required by a 9th Circuit Court of Appeals decision in April 2021 to take action, EPA issued a final rule in August, 2021—in full effect February 28, 2022—after an earlier 9th Circuit decision, concluding that, “EPA is unable to conclude that the risk from aggregate exposure from the use of chlorpyrifos meets the safety standard of the Federal Food, Drug, and Cosmetic Act (FFDCA). Accordingly, EPA is revoking all tolerances for chlorpyrifos.” On November 3, the 8th Circuit U.S. Court of Appeals decided to vacate EPA’s 2021 decision to cancel all food tolerances for chlorpyrifos and sent it back to the agency.

In other cases, EPA has avoided such litigation by taking more limited action. When the industry challenges EPA, the agency almost invariably capitulates, as in the case of paraquat, when EPA allowed an industry umbrella group dubbed the Agricultural Handler Exposure Task Force to correct its data risks posed to workers, resulting in the agency changing its position within months.

The examples of this pattern are numerous, and even when EPA suspends the registration of a pesticide, removal from use is very slow because existing stocks are generally allowed to be sold. For example, EPA suspended the registration of the herbicide dimethyl tetrachloroterephthalate (DCPA) (also widely known as Dacthal), effective August 22, 2023, leaving existing stocks (products containing DCPA manufactured before August 22) available on the market.

History shows the failure of the “whack-a-mole” approach to pesticide regulation.

States should adopt a strategy promoting natural and working lands as a critical yet currently underutilized sector in the fight against climate change. These lands can sequester and store carbon emissions, limit future carbon emissions into the atmosphere, protect people and nature from the impacts of climate change, and build resilience to future climate risks. Climate smart management of natural and working lands also improves public health and safety, secures our food and water supplies, and increases equity.

The strategy should define the state’s natural and working landscapes; describe how these lands can deliver on climate change goals; highlight priority nature-based climate solutions to address the climate crisis; explore opportunities for regional climate smart land management; identify options to track nature-based climate action and measure progress; and outline opportunities to scale climate smart land management across regions and sectors in the state. States should set a pesticide-free goal for state parks.

To be effective, the strategy must include ambitious targets focused on reduction of agricultural chemicals and support for organic agriculture. These measures also address other crises, including microbial support for ecosystem health and biodiversity. Industrial farming systems dependent on synthetic fertilizers and other chemical inputs must be replaced with organic systems that do not use chemicals in which animals and feed sources are fully integrated.

I urge you to take the lead in creating policies that move our state to organic agriculture and land management.

Thank you.

Letter to Mayor:

As shown by the recent court decision overturning EPA’s attempt to cancel agricultural uses of chlorpyrifos, the pesticide regulatory process is broken and cannot protect people or the environment from the dangers of their use. As a result, we need policies at the state and local level that move towards organic land management in agriculture, communities, and homes.

EPA’s action to cancel all agricultural uses of chlorpyrifos was a rare instance when the agency took protective action. Required by a 9th Circuit Court of Appeals decision in April 2021 to take action, EPA issued a final rule in August, 2021—in full effect February 28, 2022—after an earlier 9th Circuit decision, concluding that, “EPA is unable to conclude that the risk from aggregate exposure from the use of chlorpyrifos meets the safety standard of the Federal Food, Drug, and Cosmetic Act (FFDCA). Accordingly, EPA is revoking all tolerances for chlorpyrifos.” On November 3, the 8th Circuit U.S. Court of Appeals decided to vacate EPA’s 2021 decision to cancel all food tolerances for chlorpyrifos and sent it back to the agency.

In other cases, EPA has avoided such litigation by taking more limited action. When the industry challenges EPA, the agency almost invariably capitulates, as in the case of paraquat, when EPA allowed an industry umbrella group dubbed the Agricultural Handler Exposure Task Force to correct its data risks posed to workers, resulting in the agency changing its position in months.

The examples of this pattern are numerous, and even when EPA suspends the registration of a pesticide, removal from use is very slow because existing stocks are generally allowed to be sold. For example, EPA suspended the registration of the herbicide dimethyl tetrachloroterephthalate (DCPA) (also widely known as Dacthal), effective August 22, 2023, leaving existing stocks (products containing DCPA manufactured before August 22) available on the market.

History shows the failure of the “whack-a-mole” approach to pesticide regulation.

Many communities are already adopting organic land management in parks, playing fields, and other public lands. Beyond Pesticides parners with major retailers like Natural Grocers and Stonyfield Organic, and dozens of communities in all regions of the country to see this vision come to life. Natural land care is becoming increasingly popular at the local level, with more and more communities looking to employ practices that protect workers, public health, pets, pollinators, and unique local environments that can be harmed by unnecessary pesticide use. At the same time, community leaders are increasingly challenged with staffing constraints and tight budgets. Beyond Pesticides’ Parks for a Sustainable Future program aims to bridge these gaps, allowing communities to pilot the transition to organic land care on two public sites.
Program pilot sites provide local land care officials the time needed to dial in new practices and work out any unexpected factors that may impede the move from conventional to organic land care. They send a message to residents that the community is taking meaningful action to protect their health and environment, at a lower cost to community coffers than a rapid, full-scale transition to organic land care that local pesticide reform policies are increasingly requiring.

Please ensure 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 curtail petroleum-based pesticides and fertilizers and sequester atmospheric carbon through effective organic practices.

Thank you.

Following injuries to Kansas City Chiefs tight end Travis Kelce, New York Jets quarterback Aaron Rogers, and others, the National Football League Players Association (NFLPA) is calling to end the use of synthetic (artificial) turf and a return to natural turf. The same safety concerns, in addition to environmental and health hazards, are emerging as communities and school boards discuss the fields used for school and community sports. This debate is taking place as communities are increasingly shifting the management of their playing fields and parks to organic practices, eliminating toxic pesticides and fertilizers, building soil biology to cycle nutrients naturally, increasing the resiliency of turf, and decreasing water use.

>>Tell NFL Commissioner Roger Goodell and your local community leaders* to make the switch to organic grass turf. 

Although manufacturers and advocates of artificial turf (who have created confusion by redefining “turf” to mean synthetic turf) tout its benefits, claiming improved safety and reduced environmental impact, among others, the facts contradict these claims. 

Injuries to high-profile professional football players have prompted the NFLPA to urge the National Football League (NFL) to follow the lead of the FIFA World Cup soccer association, which requires a grass playing field. The players are not the only ones demanding grass fields. Fans of singer-songwriter Taylor Swift came out in full force in favor of the switch after the injury to Ms. Swift's rumored boyfriend Travis Kelce.

Synthetic turf also causes injuries to high school athletes. 

A groundbreaking study, The dark side of artificial greening: Plastic turfs as widespread pollutants of aquatic environments, has unearthed some disturbing revelations on the use of artificial turf. This comprehensive study, prominently featured in the Environmental Pollution (June 2023) journal, has cast a spotlight on the dire consequences of plastic fibers from artificial turf, which are wreaking havoc on marine ecosystems.

River transport and stormwater runoff can carry plastics and microplastics into waterways. Once they make their way into the water, these fibers pose a menacing threat to marine life, leading to a host of health issues and, tragically, even mortality. The fibers also accumulate in sediments, compromising the overall health of aquatic ecosystems. The study authors indicate that plastic fields require enhanced waste management practices to staunch the plastic fibers from entering aquatic habitats. 

Communities discussing synthetic versus natural turf are faced with a number of issues that go to safety, environmental health, and cost. The chemicals used to manage synthetic turf for bacteria, mold, and fungus raise serious health issues and represent a threat that does not exist in organic land management. A builder of sports facilities, American Athletic, states that “beyond surface cleaning, the artificial turf should be sanitized weekly or monthly to protect the players' and coaches' health. This disinfection requires special solvents, cleansers, and anti-microbial products to remove invisible particles and bacterial growth. You should strive to sanitize the field after every game and throughout the school day if it's used for physical education classes.”

Artificial fields can cost over $1 million for field installation, drainage system, and additional costs for water treatment for an approximately ten-year lifespan, not including the game-day and ongoing maintenance costs. Manufacturers also recommend watering the synthetic fields during hot weather because of the heat generated by the artificial material. Studies record maximum surface temperatures on synthetic fields during hot, sunny conditions averaging from 140° F to 170° F, while natural grass is rarely recorded to be above 100° F.

When all the synthetic turf issues are considered, including chemical use, maintenance, heat effects, water contamination and treatment, playability and safety, organic grass turf offers an approach that checks all the critical boxes for protecting health and the environment at a competitive price. Organic management practices build soil health, cycle nutrients naturally, enhance turf resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers. The organic alternative is central to a community's discussion about its residents' commitment to both the elimination of practices and products that are petrochemical-based and the ability of organically managed soils to draw down (sequester) atmospheric carbon, which contributes to mitigating global warming and erratic temperatures.

Sign up to be a Parks Advocate today to encourage your community to transition to organic land management!

>>Tell NFL Commissioner Roger Goodell and your local community leaders* to make the switch to organic grass turf. 

The targets for this Action are the NFL commissioner and U.S. municipal mayors, vice-mayors, and mayors pro-tem (*as available in the Every Action database).

*Our database may not include your Mayor through our one-click action. However, you may use our proposed language for sending a letter to your Mayor. Please cut-and-paste the text provided BELOW and send in an email to your local Mayor's office.

Thank you for your active participation and engagement!

Letter to NFL Commissioner Roger Goodell—Email

I support the request of the National Football League Players Association (NFLPA) for a return to natural turf on playing fields. Besides the issue of safety for players, artificial turf is a source of environmental pollution that is difficult to mitigate.

Although manufacturers of artificial turf tout supposed benefits, claiming improved safety and reduced environmental impact, among others, there are reasons to believe otherwise. Although manufacturers and advocates of artificial turf tout its benefits, claiming improved safety and reduced environmental impact, among others, the facts contradict these claims.

Injuries to high-profile professional football players have prompted the NFLPA to urge the NFL to follow the lead of the FIFA World Cup soccer association, which requires a grass playing field.

A groundbreaking study, The dark side of artificial greening: Plastic turfs as widespread pollutants of aquatic environments, has unearthed some disturbing revelations on the use of artificial turf, which has become a pervasive fixture on sports fields and playgrounds. This comprehensive study, prominently featured in the Environmental Pollution (June 2023) journal, has cast a spotlight on the dire consequences of plastic fibers from artificial turf, which are wreaking havoc on marine ecosystems.

River transport and stormwater runoff can carry plastics and microplastics into waterways. Once they make their way into the water, these fibers pose a menacing threat to marine life, leading to a host of health issues and, tragically, even mortality. The fibers also accumulate in sediments, compromising the overall health of aquatic ecosystems. The authors of the study call for immediate intervention to tackle artificial turf pollution. The study authors indicate that plastic fields require enhanced waste management practices to staunch the plastic fibers from entering aquatic habitats.

Artificial fields can cost over $1 million for field installation, drainage system, and additional costs for water treatment for an approximately ten-year lifespan, not including the game-day and ongoing maintenance costs. Manufacturers also recommend watering the synthetic fields during hot weather because of the heat generated by the artificial material. Studies record maximum surface temperatures on synthetic fields during hot, sunny conditions averaging from 140° F to 170° F, while natural grass is rarely recorded to be above 100° F.

The chemicals used to manage synthetic turf for bacteria, mold, and fungus raise serious health issues and represent a threat that does not exist in organic land management. A builder of sports facilities, American Athletic, states, “Beyond surface cleaning, the artificial turf should be sanitized weekly or monthly to protect the players’ and coaches’ health. This disinfection requires special solvents, cleansers, and anti-microbial products to remove invisible particles and bacterial growth. You should strive to sanitize the field after every game and throughout the school day if it’s used for physical education classes.”

When all the synthetic turf issues are considered, including chemical use, maintenance, heat effects, water contamination and treatment, playability and safety, organic grass turf offers an approach that checks all the critical boxes for protecting health and the environment at a competitive price. Organic management practices build soil health, cycle nutrients naturally, enhance turf resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers. While FIFA guidelines for grass turf do not mandate organic management, they provide a standard for construction and maintenance to which organic practices can be applied.

Therefore, I request that you require NFL playing fields to be grass turf that is transitioned to organic management.

Thank you.

Letter to Mayors—Unites States Conference of Mayors (population 30,000+)

Following injuries to Kansas City Chiefs tight end Travis Kelce, New York Jets quarterback Aaron Rogers, and others, the National Football League Players Association (NFLPA) is calling for a return to natural turf. The same issue arises with regard to playing fields for school and community sports. Besides the issue of safety for players, artificial turf is a source of environmental pollution that is difficult to mitigate.

Although manufacturers of artificial turf tout supposed benefits, claiming improved safety and reduced environmental impact, among others, there are reasons to believe otherwise. Although manufacturers and advocates of artificial turf tout its benefits, claiming improved safety and reduced environmental impact, among others, the facts contradict these claims.

Injuries to high-profile professional football players have prompted the NFLPA to urge the NFL to follow the lead of the FIFA World Cup soccer championship, which requires a grass playing field.
Synthetic turf also causes injuries to young athletes.

A groundbreaking study, The dark side of artificial greening: Plastic turfs as widespread pollutants of aquatic environments, has unearthed some disturbing revelations on the use of artificial turf, which has become a pervasive fixture on sports fields and playgrounds. This comprehensive study, prominently featured in the Environmental Pollution (June 2023) journal, has cast a spotlight on the dire consequences of plastic fibers from artificial turf, which are wreaking havoc on marine ecosystems.

River transport and stormwater runoff can carry plastics and microplastics into waterways. Once they make their way into the water, these fibers pose a menacing threat to marine life, leading to a host of health issues and, tragically, even mortality. The fibers also accumulate in sediments, compromising the overall health of aquatic ecosystems. Immediate intervention is needed to tackle artificial turf pollution, including enhanced waste management practices to staunch the plastic fibers from entering aquatic habitats.

Communities discussing synthetic versus natural turf are faced with issues that go to safety, environmental health, and cost. The chemicals used to manage synthetic turf for bacteria, mold, and fungus raise serious health issues and represent a threat that does not exist in organic land management. A builder of sports facilities, American Athletic, states, “Beyond surface cleaning, the artificial turf should be sanitized weekly or monthly to protect the players’ and coaches’ health. This disinfection requires special solvents, cleansers, and anti-microbial products to remove invisible particles and bacterial growth. You should strive to sanitize the field after every game and throughout the school day if it’s used for physical education classes.”

Artificial fields can cost over $1 million for field installation, drainage system, and additional costs for water treatment for an approximately ten-year lifespan, not including the game-day and ongoing maintenance costs. Manufacturers also recommend watering the synthetic fields during hot weather because of the heat generated by the artificial material. Studies record maximum surface temperatures on synthetic fields during hot, sunny conditions averaging from 140° F to 170° F, while natural grass is rarely recorded to be above 100° F.

When all the synthetic turf issues are considered, including chemical use, maintenance, heat effects, water contamination and treatment, playability and safety, organic grass turf offers an improvement in every way. Organic management practices build soil health, cycle nutrients naturally, enhance turf resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers.

Please ensure that our community’s playing fields are made of natural grass maintained organically.

Thank you.

Please take action by Monday, October 30, 2023 at 11:59 PM Eastern! 

EPA proposes to register a new active ingredient, Ledprona—a genetically engineered pesticide that works by impeding the expression of essential proteins in target pest insects via a cellular mechanism called RNA interference (RNAi). In RNAi, the messenger RNA of the target organism (pest) is adversely affected, and it is left either stunted or dead. EPA is doing so despite lacking essential data that is required by law and despite research warning about ecological impacts of the pesticide. EPA's proposal is especially unconscionable during the current “insect apocalypse” in which almost half of all insect species are rapidly declining, and a third are being threatened with extinction. Clearly, the agency should be promoting alternative management strategies rather than allowing the introduction of new technologies that are not fully evaluated under current law, as weak as it is.

>>Tell EPA not to register Ledprona without complete data supporting its safety.

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires that EPA register a pesticide only if it determines that the pesticide “will perform its intended function without unreasonable adverse effects on the environment.” EPA admits that it is basing its proposed registration decision solely on data the registrant GreenLight submitted to fulfill requirements for its prior application for an experimental use permit (EUP), without any additional data. However, there are far fewer data requirements for approval of an EUP than are required for a full registration.

Ledprona's use of RNAi makes it unique and unlike any other insecticide sprayed on fields. The use of new technology makes it especially imperative to examine all required data for any potential unintended consequences. Since these novel pesticides may be applied by plane, EPA must thoroughly assess the real-world impacts of pesticide drift. This technology, which penetrates plant tissues and leaves traces in the soil, can cause widespread indiscriminate poisoning—as has been seen with bees, butterflies, birds, and the larger catastrophic decline of insect populations. The effects, especially on threatened and endangered species like the American burying beetle, Hungerford's crawling water beetle, the Northeastern beach tiger beetle, and the Puritan tiger beetle, must be evaluated. These species are found near potato production areas close to where the Experimental Trials are being conducted and could be direct casualties of this new biopesticide.

In addition, researchers from the U.S. and Switzerland have published findings, a beginning assessment of how the use of this new category of pesticides—RNAi, delivered in double-stranded RNA (dsRNA) molecules—might impact soils and non-target microorganisms in the soil. The co-authors (Kimberly M. Parker, PhD, et al.) note that “The ecological risk assessment of these emerging pesticides necessitates an understanding of the fate of dsRNA molecules in receiving environments, among which agricultural soils are most important.” Their research has continued, finding that “Due to the ability of DOM (dissolved organic matter) to both bind and suppress the enzymatic degradation of RNA, RNA biodegradation may be slowed in environmental systems with high DOM concentrations, which may increase its persistence.”

>>Tell EPA not to register Ledprona without complete data supporting its safety.

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

Thank you for your active participation and engagement!

Letter to EPA:

I urge EPA not to register the new active ingredient, Ledprona—a genetically engineered pesticide that works by impeding the expression of essential proteins in target pest insects via a cellular mechanism called RNA interference (RNAi). In RNAi, the messenger RNA of the target organism (pest) is adversely affected, and it is left either stunted or dead. EPA is doing so despite lacking essential data that is required by law and despite research warning about ecological impacts of the pesticide. The ecological effects of RNAi gene-manipulating pesticides raise serious questions—they have not been fully studied by EPA and, until they are, the agency should issue a moratorium on their release.

EPA’s proposal is especially unconscionable during the current “insect apocalypse” in which almost half of all insect species are rapidly declining, and a third are being threatened with extinction. Clearly, the agency should be promoting alternative management strategies rather than allowing the introduction of new technologies that are not fully evaluated under current law, as weak as it is.

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires that EPA register a pesticide only if it determines that the pesticide “will perform its intended function without unreasonable adverse effects on the environment.” EPA admits that it is basing its proposed registration decision solely on data the registrant GreenLight submitted to fulfill requirements for its prior application for an experimental use permit (EUP), without any additional data. However, there are far fewer data requirements for approval of an EUP than are required for a full registration.

Ledprona’s use of RNAi makes it unique, and unlike any other insecticide sprayed on fields. The use of a new technology makes it especially imperative to examine all required data for any potential unintended consequences. Since these novel pesticides may be applied by plane, EPA must thoroughly assess the real-world impacts of pesticide drift. This technology, which penetrates plant tissues and leaves traces in the soil, can cause widespread indiscriminate poisoning—as has been seen with bees, butterflies, birds, and the larger catastrophic decline of insect populations. The effects, especially on threatened and endangered species like the American burying beetle, Hungerford’s crawling water beetle, the Northeastern beach tiger beetle, and the Puritan tiger beetle, must be evaluated. These species are found near potato production areas close to where the Experimental Trials are being conducted and could be direct casualties of this new biopesticide.

In addition, researchers from the U.S. and Switzerland have published findings, a beginning assessment of how use of this new category of pesticides—RNAi, delivered in double-stranded RNA (dsRNA) molecules—might impact soils and non-target microorganisms in the soil. The co-authors (Kimberly M. Parker, PhD, et al.) note that “...the ecological risk assessment of these emerging pesticides necessitates an understanding of the fate of dsRNA molecules in receiving environments, among which agricultural soils are most important.” Their research has continued, finding that “... due to the ability of DOM (dissolved organic matter) to both bind and suppress the enzymatic degradation of RNA, RNA biodegradation may be slowed in environmental systems with high DOM concentrations, which may increase its persistence.”

EPA’s human and ecological risk assessments are deficient, and EPA must not allow Ledprona to be used until they are complete.

Thank you for your consideration of these comments.

The Environmental Protection Agency is receiving written comments from the public, which must be submitted by October 22, 2023 at Regulations.gov.

The U.S. Environmental Protection Agency's (EPA) plan to “protect” endangered species, its Draft Herbicide Strategy Framework, continues a legacy of failed risk assessment and mitigation measures that do not meet the moment of looming biodiversity collapse. This is a critical time for the agency to embrace real fundamental change in how it regulates pesticides, recognizing that land management strategies, including in agriculture, exist that are no longer reliant on pesticides. This is not a time to tinker with strategies that EPA admits fall short. 

Recognizing that its Pesticide Program has failed to meet its obligation to protect endangered species from registered pesticides, EPA has come up with a strategy to redefine its responsibilities to protect endangered species in its pesticide registration and registration review program. According to EPA, “The proposed Strategy is structured to provide flexibility to growers to choose mitigations that work best for their situation. Additionally, the draft Strategy may require more or less mitigation for growers/pesticide applicators depending on their location.”

Understandably, EPA has taken this approach, finding it virtually impossible to meet the statutory obligations of the Endangered Species Act (ESA)—given the fact that the agency itself admits, “EPA's Pesticide Program has been unable to keep pace with its ESA workload, resulting not only in inadequate protections for listed species but also successful litigation against the Agency.” And, “Even if EPA completed this work for all of the pesticides that are currently subject to court decisions and/or ongoing litigation, that work would take until the 2040s, and even then, would represent only 5% of EPA's ESA obligations.”

EPA recognizes that it needs to fundamentally change. But to EPA, the “fundamental change” means risk mitigation measures that have failed miserably over its history –drift mitigation being one of many key failures. In fact, the fundamental change that is needed is change of agricultural practices that have kept farmers dependent on chemical-intensive practices. Fundamental change would require EPA in every pesticide registration and registration review to ask whether there are practices that can eliminate the harm, not reduce risk with high degrees of uncertainty. 

The planet faces an existential biodiversity crisis, with a rising number of species on the brink of extinction. The goal of ESA is to address the broader issue of biodiversity loss by protecting habitats of species most at risk, or, as stated in ESA, to “Provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions set forth. . .” in the law. On the contrary, EPA’s language about its proposed changes includes phrases like “draft Strategy may require more or less mitigation for growers/pesticide applicators depending on their location.” That is not a plan to avoid biodiversity collapse.

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

***
This action requires use of Regulations.gov. Click on this link. Then please submit comments by copy and pasting the text from the yellow box below. Comments are due October 22.

>>Submit Comments Now. 

>>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 language from the 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.) 

The holiday that for many years celebrated the invasion of Western hemisphere by Europeans—Columbus Day—has increasingly become a day to remember the people of nations indigenous to our country. Our commemoration must go beyond a holiday. Indigenous cultures—because they arose as part of the land—have a history of gaining food, clothing, medicines, and other necessities without destroying the land that provides them. As Kaipo Kekona shared with Beyond Pesticides at the 39th National Forum Series last year, it is critical for us to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings. 

>>Tell EPA to begin meaningful dialogue with tribes in order to learn how pesticide use can be avoided by adopting indigenous practices. Tell EPA that when needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment."

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai'i are not necessarily the same as those in the Great Plains, Eastern North America or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the indigenous authors of the White/Wiphala Paper on Indigenous Peoples' Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world's biodiversity is in our lands and territories. We didn't know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our wellbeing and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.” 

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.  

In a recent report, EPA's Office of Inspector General (OIG) told the agency that although it “adhered to applicable tribal consultation policies when it conducted consultations for the three RUP [restricted use pesticide] actions that we reviewed, the EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The investigation was specifically directed toward RUP actions, but the OIG's advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate.  

>>Tell EPA to begin meaningful dialogue with tribes in order to learn how pesticide use can be avoided by adopting indigenous practices. Tell EPA that when needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment."

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.  

Thank you for your active participation and engagement!

Letter to EPA:

Indigenous agriculture and landcare provide a model for a truly sustainable relationship with the land. By ignoring this fact in registering pesticides, EPA promotes the opposite, increasing problems with health, biodiversity, and climate--not to mention the possibility of humans living sustainably on Earth.

Indigenous cultures—because they arose as part of the land—have a history of gaining food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for us to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those Great Plains or Eastern North America or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today, scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our wellbeing and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency that although it “adhered to applicable tribal consultation policies when it conducted consultations for the three RUP [restricted use pesticide] actions that we reviewed, the EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The investigation was specifically directed toward RUP actions, but the OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate.

I urge you to begin meaningful dialogue with tribes in order to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment” and should result in the cancellation of the pesticide use.

Thank you.

Letter to U.S. Senators and Representative:

Indigenous agriculture and landcare provide a model for a truly sustainable relationship with the land. By ignoring this fact in registering pesticides, EPA promotes the opposite, increasing problems with health, biodiversity, and climate--not to mention the possibility of humans living sustainably on Earth.

Indigenous cultures—because they arose as part of the land—have a history of gaining food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for us to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those Great Plains or Eastern North America or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our wellbeing and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency that although it “adhered to applicable tribal consultation policies when it conducted consultations for the three RUP [restricted use pesticide] actions that we reviewed, the EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The investigation was specifically directed toward RUP actions, but the OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate.

Please urge EPA to begin meaningful dialogue with tribes in order to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment” and should result in the cancellation of the pesticide use.

Thank you.

As the United States commemorates the 50th anniversary of the Endangered Species Act (ESA), there is a growing recognition that the planet faces an existential biodiversity crisis, with a rising number of species on the brink of extinction. In a collective effort to address threats to global biodiversity—the diversity of all life—a coalition of environmental organizations, including Beyond Pesticides, calls for bold and comprehensive action to preserve our planet's natural heritage for future generations in an urgent letter to President Joe Biden.

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

>>As part of this “whole of government” approach, EPA must redirect its pesticide program to protecting all species and their habitats.

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

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

Studies upon studies upon studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA's registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments.

Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. Agricultural intensification, in particular pesticide and fertilizer use, is the leading factor driving declines in bird populations.

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between this industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity.

In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. If EPA is to really protect endangered species, it must eliminate the use of toxic pesticides and encourage organic production.

The letter to President Biden emphasizes the need for a whole-of-government approach to address this crisis and underscores the importance of consulting with Tribal governments and honoring federal trust obligations to Indigenous communities. Recognizing and incorporating indigenous knowledge and practices in conservation efforts is deemed crucial to safeguarding biodiversity, protecting the rights of indigenous peoples, and ensuring social equity and justice.

The letter calls on President Biden to take the following actions:

1. Implement Whole of Government Approaches to Saving Biodiversity and Endangered Species: A national biodiversity strategy is proposed to serve as a blueprint for a coordinated response to biodiversity loss, addressing primary threats such as habitat degradation, climate change, wildlife exploitation, invasive species, and pollution.

2. Boost Recovery of Endangered Species Through Robust Funding and Engaging Agencies Across Government: Adequate funding for the ESA and the prioritization of conservation and recovery efforts by all federal agencies, in consultation with Tribal and Indigenous communities, are essential to reversing species decline.

3. Adopt an Ambitious Ecosystem-based Framework to Recover Endangered Species and Rebuild America's Wildlife Populations: The letter calls for a holistic approach to recovery that considers a species' role in ecosystems and protects key areas to increase resiliency and preserve biodiversity hotspots.

>>As part of this “whole of government” approach, EPA must redirect its pesticide program to protecting all species and their habitats.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.  

Thank you for your active participation and engagement!

Letter to EPA Administrator: 

On the 50th anniversary of the passing of the Endangered Species Act (ESA), the U.S. Environmental Protection Agency (EPA) must take bold, visionary steps to protect all species and their habitats.  

Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and vulnerability of species to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first to the ways it has created the crisis in the first place. Dwindling biodiversity is an existential crisis that requires removing serious threats posed by pesticides. 

Many studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments. 

Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. And yet, EPA continues to ignore its responsibility to eliminate risks from endocrine disrupting pesticides. Agricultural intensification, in particular pesticide and fertilizer use, is also the leading factor driving declines in bird populations. 

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between this industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity. 

In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. Certainly, these threats to biodiversity qualify as “unreasonable adverse effects on the environment” which, according to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), should disqualify toxic pesticides from being used. If EPA is to really protect endangered species, it must eliminate the use of toxic pesticides and consider organic production in applying the FIFRA “unreasonable adverse effects” standard in the pesticide registration review.  

Thank you. 

Letter to U.S. Senators and Representative: 

On the 50th anniversary of the passing of the Endangered Species Act (ESA), the U.S. Environmental Protection Agency (EPA) must take bold, visionary steps to protect all species and their habitats.  

Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and vulnerability of species to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first to the ways it has created the crisis in the first place. Dwindling biodiversity is an existential crisis that requires removing serious threats posed by pesticides. 

Many studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments. 

Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. And yet, EPA continues to ignore its responsibility to eliminate risks from endocrine disrupting pesticides. Agricultural intensification, in particular pesticide and fertilizer use, is also the leading factor driving declines in bird populations. 

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between this industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity. 

In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. Certainly, these threats to biodiversity qualify as “unreasonable adverse effects on the environment” which, according to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), should disqualify toxic pesticides from being used. If EPA is to really protect endangered species, it must eliminate the use of toxic pesticides and encourage organic production.  

The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by September 28, 2023.

This precedes the upcoming public comment webinar on October 17 and 19 and the deliberative hearing October 24-26—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 28. 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 (substances) 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 Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and the Fall 2023 issues page.

>>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 language from the 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! 

The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by September 28, 2023.

This deadline precedes the upcoming public comment webinar on October 17 and 19 and deliberative hearings on October 24-26—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 28. 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 (substances) 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 Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and the Fall 2023 issues page. see Keeping Organic Strong and the Fall 2023 issues page. USDA’s National Organic Program (NOP) and the NOSB have relied on allowable lists of “inert” ingredients that are no longer maintained by the U.S. Environmental Protection (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA. Beyond Pesticides has advocated that the NOSB break down the hundred or so “inerts” of potential concern into groups of chemical families and common toxicological mechanisms to conduct its review over several years. For example, the ethoxylated compounds could be evaluated together. In fact, they are not permitted in EPA’s Safer Choice labeling program. (For a more in-depth discussion of the “inerts” in organics, please see “Inert” Ingredients Used in Organic Production.) 

This is not a new issue for the NOSB and NOP, but one that needs resolution now.  

Some crucial facts must be acknowledged by USDA:

• “Inert” ingredients are not necessarily biologically or chemically inert. The Beyond Pesticides report  ”Inert” Ingredients in Organic Production compares the toxicity of active substances and “inert” substances used in organic production. In almost every category, there are more harmful “inerts” than active substances. 
  
  
• OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application” based on a recommendation by the NOSB, following procedures in OFPA. 
  
  
• The NOSB has repeatedly passed recommendations telling the NOP to evaluate individual “inerts.” 
  

We urge you to submit comments to the docket on the NOSB/NOP “Inerts Pre-Discussion Document” (under consideration at the upcoming NOSB meeting in October), incorporating the following points (feel free to cut-and-paste these comments you submit in the docket): 

>>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 comments above into Regulations.gov and add or adjust the text to personalize it. Please see this instructional video for guidance. (Regulations.gov has changed its look since this video was made.) 

Time after time, citizens have had to sue the U.S. Fish and Wildlife Service (USFWS) for failing to protect the animals and their habitat as required by law, in areas that the nation has recognized as critical to preserve as habitat and for public recreation. Now USFWS is willing to allow, for private profit, the industrialization of refuge lands for shellfish operations. 

>>Tell the U.S. Fish and Wildlife Service and U.S. Secretary of Interior Deb Haaland that the Dungeness National Wildlife Refuge lease for industrial aquaculture must be rescinded.

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," USFWS 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. 

In the words written of an October 2022 USFWS internal memorandum, “Forgoing a compatibility determination in order to facilitate incompatible commercial activities by any entity would be a subversion of the fundamental requirements in the [USFWS] Improvement Act.” 

We are targeting the most recent case of the USFWS's permissiveness in one of the country's most pristine nature lands, the Dungeness National Wildlife Refuge in the small rural town of Sequim Washington, just below the Olympic National Park. In this case, the shellfish corporation raises shellfish on other sites. They do not need to operate in a national refuge and deny wildlife their feeding and breeding grounds. 

The Dungeness National 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 with the use of pesticides. Shellfish aquaculture also involves large-scale use of plastics—PVC tubes and plastic netting—that are hazardous to marine organisms and can trap and entangle wildlife. Commercial shellfish aquaculture is a major industry in Washington state that 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). 

Among 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 National Wildlife Refuge are NOT minimal. Decisionmakers should not place financial benefits to the corporation above the long-term and cumulative impacts to the refuge. Half of the world's 10,000-odd bird species are in decline. One in eight faces the threat of extinction. 2.9 billion breeding adult birds have been lost from the United States and Canada in only 50 years. 

Let's raise our national voice and try and stop this refuge destruction with public persuasion. This is a public space we pay to protect. For more information, check out the Daily News post from last August, "Groups Sue U.S. Interior Department to Protect the Dungeness National Wildlife Refuge from Industrial Aquaculture." 

This action follows a lawsuit filed by three environmental organizations against the U.S. Department of Interior for failing to protect the Dungeness National Wildlife Refuge from industrial aquaculture. The groups, including Protect the Peninsula's Future, Coalition to Protect Puget Sound Habitat, and Beyond Pesticides, filed their complaint in the U.S. Western District Court of Washington State. The complaint states that the U.S. Fish and Wildlife Service (USFWS), U.S. Department of Interior, must “take action that is required by the Refuge Improvement Act and conduct a compatibility determination and require a special use permit for a proposed industrial aquaculture use” that will abut and impact the Refuge. The plaintiffs are represented by the Seattle, WA law firm of Bricklin and Newman LLP. 

>>Tell the U.S. Fish and Wildlife Service and U.S. Secretary of Interior Deb Haaland that the Dungeness National Wildlife Refuge lease for industrial aquaculture must be rescinded.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Secretary of State.  

Thank you for your active participation and engagement!

Letter to Hugh Morrison, Regional Director for the Pacific Region USFWS, and U.S. Secretary of Interior Deb Haaland: 

As a citizen and taxpayer of the United States, I strongly oppose your support for allowing a for-profit shellfish operation in the Dungeness National Wildlife Refuge. It is upsetting to learn that USFWS would have operations known to be destructive of the wildlife refuge and refuse to abide by its own compatibility determination regulations. 

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," UFWS 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 National 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 with the use of pesticides. Shellfish aquaculture also involves large-scale use of plastics—PVC tubes and plastic netting—that are hazardous to marine organisms and can trap and entangle wildlife. Commercial shellfish aquaculture is a major industry in Washington state that 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). 

Among 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 National Wildlife Refuge are NOT minimal. Decisionmakers should not place financial benefits to the corporation above the long-term and cumulative impacts to the refuge. 

Please let me know that you will write an honest compatibility determination. 

Thank you. 

Labor Day not only marks the end of summer vacation, but also honors workers and celebrates actions taken to protect them. Unfortunately, some of the workers with whom we have the closest connection—those who grow and harvest our food—have not enjoyed those protections. 

>> Tell EPA to protect farmworkers. Please tell President Biden (through Secretary of State Blinken) to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

EPA's Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworker communities.

Farmworkers need more protections, not industry-friendly compromises. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. 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 U.S. Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

Among the dangers to which farmworkers are exposed are fumigants. 1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health's PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.

These and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable production shows that these toxic pesticides do not meet the standard in the pesticide law (FIFRA) that requires that registered pesticides not cause unreasonable adverse effects. Farmworkers would not suffer these effects under organic agriculture.

Many farmworkers are migrant workers and are subject to conditions that would not be permitted for typical U.S. citizens. The U.S. is not a signatory to the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard to treat migrant workers like workers who are citizens. 

>>Tell EPA to protect farmworkers. Please tell President Biden (through Secretary of State Blinken) to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Secretary of State.  

Thank you for your active participation and engagement!

Letter to EPA:

EPA’s Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworker communities.

Farmworkers need more protections, not industry-friendly compromises. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. 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.

Among the dangers to which farmworkers are exposed are fumigants. These and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable production shows that these toxic pesticides do not meet the standard in the pesticide law (FIFRA, the Federal Insecticide, Fungicide, and Rodenticide Act) that requires that registered pesticides not cause unreasonable adverse effects. Farmworkers would not suffer these effects under organic agriculture.

This Labor Day, please protect farmworkers by directing EPA to follow the science and eliminate the use of toxic fumigants. This is a labor and environmental justice issue.

Thank you.

Letter to Secretary of State Blinken:

I am writing to ask for your assistance in protecting migrant farmworkers.

After the Trump Environmental Protection Agency (EPA) was blocked from weakening the application exclusion zone (AEZ) provisions for protecting farmworkers, the rules reverted to the Obama era rules. Now EPA proposes to reaffirm part of that rule, while accepting some of the weakening amendments from the Trump administration.

EPA’s Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworker communities. Under the WPS, AEZs are buffer zones where people are not allowed to enter during the course of a pesticide application. Like all buffer zones, they are designed to allow application of toxic pesticides while providing a nominal degree of protection.

Under the proposed regulations, the AEZ would remain the same, while—as proposed by the Trump administration—allowing farm families to remain inside structures within the AEZ and allowing applications to resume after halting because someone was in the AEZ. These proposed rules, while not as egregious as the Trump EPA rule, are a step backwards from the current rule.

Farmworkers need more protections, not industry-friendly compromises. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. 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 EPA, while study after study documents the disproportionate level of illness among farmworkers.

Many farmworkers are migrant workers and are subject to conditions that would not be permitted for typical U.S. citizens. The U.S. is not a signatory to the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard to treat migrant workers like workers who are citizens.

This Labor Day, please urge President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families and work for Senate ratification.

Thank you.

We have an important opportunity to tell the U.S. Environmental Protection Agency (EPA) to evaluate fertilizers for compatibility with natural systems, protection of soil organisms, waterways, human health, and helping to mitigate the climate and biodiversity crises—by labeling safer fertilizers as Safer Choice. We previously initiated an action on EPA’s Safer Choice program to request it be more holistic and in sync with natural systems, not just a product substitution program. Now, we are taking action on a specific request to the agency that it labels certain fertilizers as Safer Choice for meeting standards that support the sustainability of life in agriculture, landscaping, and gardening as opposed to introducing (i) petrochemical fertilizers that contribute to the climate emergency, biodiversity collapse, and the destruction of biological systems, or (ii) biosolids that disperse hazardous contaminants. Written comments are due by September 11, 2023 (instructions below). 

The U.S. Environmental Protection Agency (EPA) is considering expanding its Safer Choice program (not to be confused with Beyond Pesticides’ pre-existing Safer Choice program). EPA’s Safer Choice is a non-regulatory program that identifies alternative chemicals for a number of uses that meet expanded safety criteria. (For pesticidal uses, the program is called Design for the Environment (DfE), which has so far been limited to disinfectants.)  

>>Tell EPA to add fertilizer products to Safer Choice. Comment text is at the bottom of the page.

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. 

However, sometimes the choice of material drives the choice of system—as is the case for fertilizers. Chemical fertilizers—those granular, powdered, or liquid products identified by NPK (the percentages of nitrogen, phosphorus, and potassium)—consist of highly-soluble chemical salts that feed plants directly, but poison soil microorganisms. The choice of such fertilizers rules out an organic system in which fertility inputs feed organisms in the soil, which release substances that feed plants. Chemical fertilizers also contribute to climate change because they are produced with fossil fuels and limit the ability of soil to draw down (sequester) atmospheric carbon, thus undermining efforts to mitigate the climate emergency and the horrific fire and flooding events that destroy life. Chemical fertilizers, in addition, produce weak growth that invites insects to feed on the plants. Aphids, for example, have long been known to increase on plants fertilized with soluble nitrogen fertilizer. 

EPA encourages the land application of biosolids (sewage sludge), noting benefits to soil fertility and structure and other “economic and waste management benefits (e.g., conservation of landfill space; reduced demand on nonrenewable resources like phosphorus; and a reduced demand for synthetic fertilizers).” However, as summarized by the Guardian, “Now the practice is behind a growing number of public health problems. Spreading pollutant-filled biosolids on farmland is making people sick, contaminating drinking water and filling crops, livestock, and humans with everything from pharmaceuticals to PFAS.” Biosolids used as fertilizer also contribute plastic to the soil. Unfortunately, many products derived from biosolids are sold as “organic” fertilizers. 

The wise gardener or farmer chooses soil amendments that are not toxic to the soil, environment, or consumers. One way to ensure freedom from chemical fertilizers or biosolids is to look for the OMRI (Organic Materials Review Institute) seal. Organic standards specifically prohibit the use of sewage sludge (aka biosolids), but the home gardener may not always be able to discern the materials from which “organic” fertilizers are made. In addition, “organic” fertilizers sourced from composted manure generally come from nonorganic confined animal feeding operations (CAFOs) and may also contain undesirable contaminants, such as antibiotics, antibiotic resistance genes, pesticide degradants, or heavy metals. Since these contaminants are not regulated, Safer Choice could offer an additional indicator of safety for gardeners and farmers. 

Dates:

•  Virtual Listening Session: August 29, 2023, 2:00–3:00 p.m. EST. To receive the webcast meeting link and audio teleconference information before the meeting, you must register by 5 p.m. EST on August 28, 2023. 
  
  
• Special Accommodations: To allow EPA time to process your request for special accommodations, please submit the request on or before August 22, 2023. 
  
  
• Written Comments: Comments must be received on or before September 11, 2023. 

>>Tell EPA to add fertilizer products to Safer Choice.

This action uses Regulation.gov to submit comments to EPA’s docket. Comments must be submitted by September 11, 2023. Please consider copying and pasting the following into your comment here!

Comment to EPA: 

As EPA considers expanding the Safer Choice program, I request that it add the category of fertilizers or soil amendments.  

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. 

However, sometimes the choice of material drives the choice of system—as is the case for soil amendments. Chemical fertilizers—those granular, powdered, or liquid products identified by NPK (the percentages of nitrogen, phosphorus, and potassium)—consist of highly-soluble chemical salts that feed plants directly, but poison soil microorganisms. The choice of such fertilizers rules out an organic system in which fertility inputs feed organisms in the soil, which release substances that feed plants. Chemical fertilizers also contribute to climate change because they are produced with fossil fuels and limit the ability of soil to draw down (sequester) atmospheric carbon, thus undermining efforts to mitigate the climate emergency and the horrific fire and flooding events that destroy life. Chemical fertilizers, in addition, produce weak growth that invites insects to feed on the plants. Aphids, for example, have long been known to increase on plants fertilized with soluble nitrogen fertilizer. 

EPA encourages the land application of biosolids (sewage sludge), noting benefits to soil fertility and structure and other “economic and waste management benefits (e.g., conservation of landfill space; reduced demand on nonrenewable resources like phosphorus; and a reduced demand for synthetic fertilizers).” However, as summarized by the Guardian, “Now the practice is behind a growing number of public health problems. Spreading pollutant-filled biosolids on farmland is making people sick, contaminating drinking water and filling crops, livestock, and humans with everything from pharmaceuticals to PFAS.” Biosolids used as fertilizer also contribute plastic to the soil. Unfortunately, many products derived from biosolids are sold as “organic” fertilizers. 

The wise gardener or farmer chooses soil amendments that are not toxic to the soil, environment, or consumers. One way to ensure freedom from chemical fertilizers or biosolids is to look for the OMRI (Organic Materials Review Institute) seal. Organic standards specifically prohibit the use of sewage sludge (aka biosolids), but the home gardener may not always be able to discern the materials from which “organic” fertilizers are made. In addition, “organic” fertilizers sourced from composted manure generally come from nonorganic confined animal feeding operations (CAFOs) and may also contain undesirable contaminants such as antibiotics, antibiotic resistance genes, pesticide degradants, or heavy metals. Since these contaminants are not regulated, Safer Choice could offer an additional indicator of safety for gardeners and farmers. 

Please add the category of fertilizers or soil amendments to Safer Choice. 

Thank you. 

The U.S. Environmental Protection Agency (EPA) is considering expanding its Safer Choice program (not to be confused with Beyond Pesticides' pre-existing Safer Choice program). EPA's Safer Choice is a non-regulatory program that identifies alternative chemicals for a number of uses that meet expanded safety criteria. [For pesticidal uses, the program is called Design for the Environment (DfE), which has so far been limited to disinfectants.]

>>Tell EPA and Congress that substituting chemicals alone is not the Safer Choice. Use Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

For problems requiring a chemical solution—for example, laundry detergents—EPA's Safer Choice is a valuable resource. Consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, which must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA's Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. 

Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA), is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives—produced in a way that benefits health, ecology, and biodiversity—NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural (nonsynthetic) or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food.

The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by available organic methods. 

Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.” There are two ways that the Safer Choice program could improve CWA implementation. First, the chemical and toxicological analyses required by Safer Choice could identify priorities for elimination. Second, the Safer Choice alternatives analyses could identify alternative processes that could eliminate those substances and create a list of substances for which NPDES permits might be allowed for specified uses—analogous to the National List in NOP. 

In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program. 

These applications are consistent with policies of EPA and the Biden administration. EPA characterizes Safer Choice as being part of the agency's Pollution Prevention (P2) program, which EPA defines as “any practice that reduces, eliminates, or prevents pollution at its source prior to recycling, treatment, or disposal.” EPA says, “Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer, and industrial sectors. Prevention practices are essential for preserving wetlands, groundwater sources, and other critical ecosystems areas in which we especially want to stop pollution before it begins.” P2, in concert with President Biden's Executive Order 14057 on catalyzing American clean energy industries and jobs through Federal sustainability and accompanying Federal Sustainability Plan, establishes a framework for applying Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy. 

Note: We will have more on Safer Choice in a future action, but we believe it is important to first put this program into the context of what is needed to meet the challenges of severe health threats, biodiversity collapse, and the climate emergency—systemic change in the way synthetic chemicals are regulated. 

This action uses Regulation.gov to submit comments to EPA's docket. Please consider copying and pasting the following into your comment here: 

For problems requiring a chemical solution—for example, laundry detergents—EPA's Safer Choice is a valuable resource. Consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, which must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA's Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to organic methods. 

Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA) is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural (nonsynthetic) or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food. 

The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by organic methods. 

Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.” There are two ways that the Safer Choice program could improve CWA implementation. First, the chemical and toxicological analyses required by Safer Choice could identify priorities for elimination. Second, the Safer Choice alternatives analyses could identify alternative processes that could eliminate those substances and create a list of substances for which NPDES permits might be allowed for specified uses—analogous to the National List in NOP. 

In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program. 

These applications are consistent with policies of EPA and the Biden administration. EPA characterizes Safer Choice as being part of the agency's pollution prevention (P2) program, which EPA defines as “any practice that reduces, eliminates, or prevents pollution at its source prior to recycling, treatment, or disposal.” EPA says, “Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer, and industrial sectors. Prevention practices are essential for preserving wetlands, groundwater sources, and other critical ecosystems – areas in which we especially want to stop pollution before it begins.” P2, in concert with President Biden's Executive Order 14057 on catalyzing American clean energy industries and jobs through Federal sustainability and accompanying Federal Sustainability Plan, establishes a framework for applying Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy. 

Please expand Safer Choice and use it to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy. 

***

>>Tell EPA and Congress that substituting chemicals alone is not the Safer Choice. Use Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.  

Thank you for your active participation and engagement!

Letter to U.S. Representative and Senators: 

EPA is considering expanding its Safer Choice program—a non-regulatory program that identifies alternative chemicals that meet expanded safety criteria for specified uses. Substituting chemicals alone is not the safer choice. Safer Choice should be expanded and used to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy. 

For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, which must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. 

Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA) is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food. 

The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by organic methods. 

Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.” The Safer Choice program could improve CWA implementation by identifying priorities for elimination and identifying alternative processes that could eliminate those substances. Analogous to the National List in NOP, a list of allowable discharges could be created. 

In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program. 

These applications are consistent with current policies. EPA characterizes Safer Choice as being part of the agency’s pollution prevention (P2) program. EPA says, “Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer, and industrial sectors.”  

Please encourage EPA to use P2, in concert with President Biden's Executive Order 14057 and Federal Sustainability Plan, to apply Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy. 

Thank you. 

All harms resulting from pesticides are unreasonable if no benefits ensue from their use. So, why is the U.S. Environmental Protection Agency (EPA) allowing the use of pesticides under the “unreasonable adverse effects” to health or the environment standard of the federal pesticide law, Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), if the pesticides over short periods of time lose their efficacy on the target organism because of the well-known biological mechanism of chemical resistance? This is particularly problematic when the goal is to manage insects that are a disease vector and we are ignoring nonchemical management strategies that are efficacious and sustainable. 

>>Tell EPA, Governors, and Congress that given the certainty of pesticide resistance, ecologically-based mosquito management must replace a reliance on pesticides.

Insect resistance to insecticides has been an issue since the introduction of DDT in the 1940s. Although most countries currently ban DDT use, several currently used insecticides pose the same threat. In fact, resistance is predicted by elementary population genetics, and the speed of its evolution is directly related to the toxicity—that is, strength of selection pressure—and inversely related to the generation length of the organism. When that target organism of the pesticide is a disease vector, like West Nile Virus, the consequences of EPA's failed regulatory review process to calculate target organism (e.g., mosquito) resistance are not merely economic—they pose a threat to public health. The threat is effectively caused by the reliance on chemical-intensive management strategies by virtue of the registration of the toxic chemicals instead of focusing public attention on sustainable nonchemical management practices that focus of preventing breeding and underlying conditions that contributes to the unwanted organism(s).

Areawide, indiscriminate spraying of insecticides causes resistance to develop among many organisms. Mosquitoes have become increasingly resistant to synthetic pyrethroids, in addition to other classes of insecticides, such as carbamates and organophosphates. For example, a study published in Pest Management Science finds resistance to insecticides like pyrethroids is jeopardizing attempts to control the mosquito Aedes aegypti, the primary vector of dengue fever. Prevention of disease outbreaks is threatened by reliance on chemical biocides—whether to antibiotics, antimicrobials, or pesticides—to which pathogens and their vectors develop resistance.

Resistance is an entirely normal, widely known, and expected phenomenon. Organisms evolve under the strong selection pressure of constant pesticide use, exploiting beneficial genetic mutations that give them a survival advantage. Another component of resistance is learned behavior, which allows mosquitoes to escape pesticides. As resistance grows in all areas in which biocides are used, including agriculture and medicine, it often leads to an increase in pesticide use, with implications for human health—including cancer, endocrine (hormone) disruption, reproductive dysfunction, neurotoxicity, and kidney/liver damage—and the ecosystem. 

Thus, resistance demonstrates the need for sustainable and effective strategies to combat the growing disease burdens. These strategies must start with an understanding of the ecological and social conditions leading to the spread of the diseases and their vectors. They must abandon the doomed pesticidal approach, which take resources from successful ecological approaches, poison humans, and disrupt healthy ecosystems that keep mosquito populations in balance with predators. 

In view of the impacts of relying on pesticides for managing insect transmission of disease vectors, their use constitutes unreasonable adverse effects on humans and the environment, which should result in the cancellation of their registrations. 

>>Tell EPA, Governors, and Congress that given the certainty of pesticide resistance, ecologically-based mosquito management must replace a reliance on pesticides.

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. State Governors, and the U.S. Congress. 

Letter to EPA:

All harms resulting from pesticides are unreasonable if no benefits ensue from their use. So, why is the U.S. Environmental Protection Agency (EPA) allowing the use of pesticides under the “unreasonable adverse effects” to health or the environment standard of the federal pesticide law, Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), if the pesticides over short periods of time lose their efficacy on the target organism because of the well-known biological mechanism of chemical resistance? This is particularly problematic when the goal is to manage insects that are a disease vector and we are ignoring nonchemical management strategies that are efficacious and sustainable.

Insect resistance to insecticides has been an issue since the introduction of DDT in the 1940s. Although most countries currently ban DDT use, several currently used insecticides pose the same threat. In fact, resistance is predicted by elementary population genetics, and the speed of its evolution is directly related to the toxicity—that is, strength of selection pressure—and inversely related to the generation length of the organism. When that target organism of the pesticide is a disease vector, like West Nile Virus, the consequences of EPA’s failed regulatory review process to calculate target organism (e.g., mosquito) resistance are not merely economic—they pose a threat to public health. The threat is effectively caused by the reliance on chemical-intensive management strategies by virtue of the registration of the toxic chemicals instead of focusing public attention on sustainable nonchemical management practices that focus of preventing breeding and underlying conditions that contributes to the unwanted organism(s).

Areawide, indiscriminate spraying of insecticides causes resistance to develop among many organisms. Mosquitoes have become increasingly resistant to synthetic pyrethroids, in addition to other classes of insecticides, such as carbamates and organophosphates. For example, a study published in Pest Management Science finds resistance to insecticides like pyrethroids is jeopardizing attempts to control the mosquito Aedes aegypti, the primary vector of dengue fever. Prevention of disease outbreaks is threatened by reliance on chemical biocides—whether to antibiotics, antimicrobials, or pesticides—to which pathogens and their vectors develop resistance.

Resistance is an entirely normal, widely known, and expected phenomenon. Organisms evolve under the strong selection pressure of constant pesticide use, exploiting beneficial genetic mutations that give them a survival advantage. Another component of resistance is learned behavior, which allows mosquitoes to escape pesticides. As resistance grows in all areas in which biocides are used, including agriculture and medicine, it often leads to an increase in pesticide use, with implications for human health—including cancer, endocrine (hormone) disruption, reproductive dysfunction, neurotoxicity, and kidney/liver damage—and the ecosystem.

Thus, resistance demonstrates the need for sustainable and effective strategies to combat the growing disease burdens. These strategies must start with an understanding of the ecological and social conditions leading to the spread of the diseases and their vectors. They must abandon the doomed pesticidal approach, which take resources from successful ecological approaches, poison humans, and disrupt healthy ecosystems that keep mosquito populations in balance with predators.

In view of the impacts of relying on pesticides for vector control, their use constitutes unreasonable adverse effects on humans and the environment, which should result in the cancellation of their registrations.

Thank you.

Letter to Governor:

All harms resulting from pesticides are unreasonable if no benefits ensue from their use. So, why are we allowing the spraying of toxic pesticides if over short periods of time they lose their efficacy on the target organism because of the well-known biological mechanism of chemical resistance? This is particularly problematic when the goal is to manage insects that are a disease vector and we are ignoring nonchemical management strategies that are efficacious and sustainable.

Insect resistance to insecticides has been an issue since the introduction of DDT in the 1940s. Although most countries currently ban DDT use, several currently used insecticides pose the same threat. In fact, resistance is predicted by elementary population genetics, and the speed of its evolution is directly related to the toxicity—that is, strength of selection pressure—and inversely related to the generation length of the organism. When that target organism of the pesticide is a disease vector, like West Nile Virus, the consequences of EPA’s failed regulatory review process to calculate target organism (e.g., mosquito) resistance are not merely economic—they pose a threat to public health. The threat is effectively caused by the reliance on chemical-intensive management strategies by virtue of the registration of the toxic chemicals instead of focusing public attention on sustainable nonchemical management practices that focus of preventing breeding and underlying conditions that contributes to the unwanted organism(s).

Areawide, indiscriminate spraying of insecticides causes resistance to develop among many pests. Mosquitoes have become increasingly resistant to synthetic pyrethroids, in addition to other classes of insecticides, such as carbamates and organophosphates. For example, a study published in Pest Management Science finds resistance to insecticides like pyrethroids is jeopardizing attempts to control the mosquito Aedes aegypti, the primary vector of dengue fever. Prevention of disease outbreaks is threatened by reliance on chemical biocides—whether to antibiotics, antimicrobials, or pesticides—to which pathogens and their vectors develop resistance.

Resistance is an entirely normal, expected phenomenon. Organisms evolve under the strong selection pressure of constant pesticide use, exploiting beneficial genetic mutations that give them a survival advantage. Another component of resistance is learned behavior, which allows mosquitoes to escape pesticides. As resistance grows in all areas in which biocides are used, including agriculture and medicine, it often leads to an increase in pesticide use, with implications for human health—including cancer, endocrine (hormone) disruption, reproductive dysfunction, neurotoxicity, and kidney/liver damage—and the ecosystem.

Thus, resistance demonstrates the need for sustainable and effective strategies to combat the growing disease burdens. These strategies must start with an understanding of the ecological and social conditions leading to the spread of the diseases and their vectors. They must abandon the doomed pesticidal approach, which take resources from successful ecological approaches, poison humans, and disrupt healthy ecosystems that keep mosquito populations in balance with predators.

In view of the impacts of relying on pesticides for vector control, our state should move towards sound ecologically-based mosquito management. Information about this approach is available from websites of Beyond Pesticides and the city of Boulder, CO.

Thank you.

Letter to U.S. Representative and Senators:

All harms resulting from pesticides are unreasonable if no benefits ensue from their use. So, why is the U.S. Environmental Protection Agency (EPA) allowing the use of pesticides under the “unreasonable adverse effects” to health or the environment standard of the federal pesticide law, Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), if the pesticides over short periods of time lose their efficacy on the target organism because of the well-known biological mechanism of chemical resistance? This is particularly problematic when the goal is to manage insects that are a disease vector and we are ignoring nonchemical management strategies that are efficacious and sustainable.

Insect resistance to insecticides has been an issue since the introduction of DDT in the 1940s. In fact, resistance is predicted by elementary population genetics, and the speed of its evolution is directly related to the toxicity—that is, strength of selection pressure—and inversely related to the generation length of the organism. When that target organism of the pesticide is a disease vector, like West Nile Virus, EPA’s failure to calculate target organism (e.g., mosquito) resistance is not merely economic—it poses a threat to public health. The threat is effectively caused by the reliance on chemical-intensive management strategies by virtue of the registration of the toxic chemicals instead of focusing public attention on sustainable nonchemical management practices that focus of preventing breeding and underlying conditions that contributes to the unwanted organism(s).

Areawide, indiscriminate spraying of insecticides causes resistance to develop among many organisms. Mosquitoes have become increasingly resistant to synthetic pyrethroids, in addition to other classes of insecticides, such as carbamates and organophosphates. For example, a study published in Pest Management Science finds resistance to insecticides like pyrethroids is jeopardizing attempts to control the mosquito Aedes aegypti the primary vector of dengue fever. Prevention of disease outbreaks is threatened by reliance on chemical biocides—whether to antibiotics, antimicrobials, or pesticides—to which pathogens and their vectors develop resistance.

Resistance is an entirely normal, expected phenomenon. Organisms evolve under the strong selection pressure of constant pesticide use, exploiting beneficial genetic mutations that give them a survival advantage. Another component of resistance is learned behavior, which allows mosquitoes to escape pesticides. As resistance grows in all areas in which biocides are used, including agriculture and medicine, it often leads to an increase in pesticide use, with implications for human health—including cancer, endocrine (hormone) disruption, reproductive dysfunction, neurotoxicity, and kidney/liver damage—and the ecosystem.

Thus, resistance demonstrates the need for sustainable and effective strategies to combat the growing disease burdens. These strategies must start with an understanding of the ecological and social conditions leading to the spread of the diseases and their vectors. They must abandon the doomed pesticidal approach, which take resources from successful ecological approaches, poison humans, and disrupt healthy ecosystems that keep mosquito populations in balance with predators. In view of the impacts of relying on pesticides for vector control, our nation should move towards sound ecologically-based mosquito management. Information about this approach is available from websites of Beyond Pesticides (https://ow.ly/q9cE50Pt4nb) and the city of Boulder, CO.

In view of the impacts of relying on pesticides for vector control, their use constitutes unreasonable adverse effects on humans and the environment, which should result in the cancellation of their registrations. Please ensure that EPA does not continue to approve these pesticides that threaten human and ecological health.

Thank you.

Despite the political furor surrounding medical abortions, the U.S. Environmental Protection Agency (EPA) continues to allow pesticides that cause involuntary spontaneous abortions (miscarriages) and other reproductive effects in exposed women.

>>Tell EPA to ban pesticides that cause involuntary spontaneous abortions (miscarriages) and other reproductive effects. Tell Congress to ensure that EPA does not permit the use of pesticides affecting reproduction.

Most spontaneous abortions occur during the first trimester. The most common cause of miscarriage during the first trimester is chromosomal abnormality. Pesticide-induced chromosomal abnormalities may be seen in a damaged egg or sperm cell. Female farmworkers are particularly at risk, though exposure of the father to pesticides also increases the risk of spontaneous abortion. 

Pesticides are ubiquitous in the environment, with 90 percent of Americans having at least one pesticide compound in their body. Numerous studies indicate chemical exposure mainly stems from dietary exposure, like food and drinking water. Although many countries ban most organochlorine compounds, these chemicals remain in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. These compounds have a global distribution, with evaporation and precipitation facilitating long-range atmospheric transport, deposition, and bioaccumulation of hazardous chemicals in the environment. Thus, exposure to these toxicants can cause many adverse environmental and biological health effects, including spontaneous abortions. The scientific literature demonstrates pesticides' long history of severe adverse effects on human health (i.e., endocrine disruption, cancer, reproductive/birth problems, neurotoxicity, etc.) and wildlife, and biodiversity. With the increasing ubiquity of pesticides, current measures safeguarding against pesticide use and exposure must be improved. 

The presence of pesticides in the body has implications for human health, especially during vulnerable life stages like childhood, puberty, pregnancy, and old age. Pesticide exposure during pregnancy is of specific concern both because of the risk of spontaneous abortion and the health effects of those who survive, as well as to future generations. Just as nutrients are transferable between mother and fetus, so are chemical contaminants. Studies find pesticide compounds in a mother's blood can transfer to the fetus via the umbilical cord. A 2021 study finds pregnant women already have over 100 chemicals in blood and umbilical cord samples, including banned persistent organic pollutants.  

Despite the evidence, EPA continues to allow the use of pesticides causing spontaneous abortion and other reproductive effects. It is time to ban these pesticides. 

>>Tell EPA to ban pesticides that cause involuntary spontaneous abortions (miscarriages) and other reproductive effects. Tell Congress to ensure that EPA does not permit the use of pesticides affecting reproduction.

The targets for this Action are the U.S. Congress and the U.S. Environmental Protection Agency Administrator. 

Thank you for your active participation and engagement!

Letter to EPA:

Despite the public attention to medical abortions, EPA continues to allow pesticides that cause involuntary spontaneous abortions (miscarriages) and other reproductive effects in exposed women.

Most spontaneous abortions occur during the first trimester. The most common cause of miscarriage during the first trimester is chromosomal abnormality. Pesticide-induced chromosomal abnormalities may be seen in a damaged egg or sperm cell. Female farmworkers are particularly at risk, though exposure of the father to pesticides also increases the risk of spontaneous abortion.

Pesticides are ubiquitous in the environment, with 90 percent of Americans having at least one pesticide compound in their body. Numerous studies indicate chemical exposure mainly stems from dietary exposure, like food and drinking water. Although many countries ban most organochlorine compounds, these chemicals remain in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. These compounds have a global distribution, with evaporation and precipitation facilitating long-range atmospheric transport, deposition, and bioaccumulation of hazardous chemicals in the environment. Thus, exposure to these toxicants can cause many adverse environmental and biological health effects, including spontaneous abortions. The scientific literature demonstrates pesticides’ long history of severe adverse effects on human health (i.e., endocrine disruption, cancer, reproductive/birth problems, neurotoxicity, etc.) and wildlife, and biodiversity. With the increasing ubiquity of pesticides, current measures safeguarding against pesticide use and exposure must be improved.

The presence of pesticides in the body has implications for human health, especially during vulnerable life stages like childhood, puberty, pregnancy, and old age. Pesticide exposure during pregnancy is of specific concern both because of the risk of spontaneous abortion and the health effects of those who survive, as well as to future generations. Just as nutrients are transferable between mother and fetus, so are chemical contaminants. Studies find pesticide compounds in a mother’s blood can transfer to the fetus via the umbilical cord. A 2021 study finds pregnant women already have over 100 chemicals in blood and umbilical cord samples, including banned persistent organic pollutants.

In spite of the evidence, EPA continues to allow the use of pesticides causing involuntary spontaneous abortion and other reproductive effects. It is time to ban these pesticides.

Thank you.

Letter to U.S. Representative and Senators:

Despite the public attention to medical abortions, EPA continues to allow pesticides that cause involuntary spontaneous abortions (miscarriages) and other reproductive effects in exposed women.

Most spontaneous abortions occur during the first trimester. The most common cause of miscarriage during the first trimester is chromosomal abnormality. Pesticide-induced chromosomal abnormalities may be seen in a damaged egg or sperm cell. Female farmworkers are particularly at risk, though exposure of the father to pesticides also increases the risk of spontaneous abortion.

Pesticides are ubiquitous in the environment, with 90 percent of Americans having at least one pesticide compound in their body. Numerous studies indicate chemical exposure mainly stems from dietary exposure, like food and drinking water. Although many countries ban most organochlorine compounds, these chemicals remain in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. These compounds have a global distribution, with evaporation and precipitation facilitating long-range atmospheric transport, deposition, and bioaccumulation of hazardous chemicals in the environment. Thus, exposure to these toxicants can cause many adverse environmental and biological health effects, including spontaneous abortions. The scientific literature demonstrates pesticides’ long history of severe adverse effects on human health (i.e., endocrine disruption, cancer, reproductive/birth problems, neurotoxicity, etc.) and wildlife, and biodiversity. With the increasing ubiquity of pesticides, current measures safeguarding against pesticide use and exposure must be improved.

The presence of pesticides in the body has implications for human health, especially during vulnerable life stages like childhood, puberty, pregnancy, and old age. Pesticide exposure during pregnancy is of specific concern both because of the risk of spontaneous abortion and the health effects of those who survive, as well as to future generations. Just as nutrients are transferable between mother and fetus, so are chemical contaminants. Studies find pesticide compounds in a mother’s blood can transfer to the fetus via the umbilical cord. A 2021 study finds pregnant women already have over 100 chemicals in blood and umbilical cord samples, including banned persistent organic pollutants.

In spite of the evidence, EPA continues to allow the use of pesticides causing involuntary spontaneous abortion and other reproductive effects. I request that you, in your oversight capacity, tell EPA that it is time to ban these pesticides.

Thank you.

Sewage sludge, also known as biosolids, is a byproduct of sewage treatment and is used as a source of organic matter for amending soil in nonorganic agriculture and landscaping. EPA has published a list of 726 chemicals found in biosolids in the National Sewage Sludge Surveys. This list does not include the per- and polyfluoroalkyl substances (PFAS), which are emerging contaminants of biosolids.  

>>Tell your Governor and local officials to ban the use of biosolids in farms and parks, until there is adequate testing of toxic residues—which does not currently exist.

In addition to PFAS (also referred to as “forever chemicals”), persistent toxic pollutants found in biosolids include: inorganic chemicals such as metals and trace elements; organic chemicals such as polychlorinated biphenyls or PCBs, dioxins, pharmaceuticals, and surfactants; and pathogens including bacteria, viruses, and parasites. Regulation of biosolids by the U.S. Environmental Protection Agency (EPA) has been found by the EPA Office of Inspector General (OIG) to be inadequate. Lacking sufficient oversight at the federal level, states and local jurisdictions must act to eliminate the hazards created by these contaminants. 

Land application of biosolids to farms and landscapes is considered the standard means of “disposal.” Chemicals such as PFAS have been found to migrate into food when grown in farms using contaminated biosolids. Over 60% of biosolids are used in crops, and the contaminants in them make their way to our food and water. But if biosolids are used in landscaping, the contaminants pose a hazard to landscapers and those using athletic fields. In view of EPA's failure to provide comprehensive identification, regulation, and elimination of potential contaminants, the biosolids themselves must be tested to ensure safety. Biosolids should be tested to ensure that they do not cause acute toxicity, cancer, genetic mutations, birth defects, reproductive or developmental effects, neurotoxicity, endocrine disruption, or immune system effects. Otherwise, they should not be used on farms or landscapes.

>>Tell your Governor and local officials to ban the use of biosolids in farms and parks, until there is adequate testing of toxic residues—which does not currently exist.

The targets for this Action are U.S. State Governors and local elected officials. As a note, if the mayor or local elected official is not shown in the messages (#2) section, then their information is currently not available in the system. For more information and to contact your mayor or township elected official, we recommend using the "Find and contact elected officials" tool on USA.gov. 

Thank you for your active participation and engagement!

Letter to Governors and local elected officials: 

Sewage sludge, also known as biosolids, is a byproduct of sewage treatment and is used as a source of organic matter for amending soil in nonorganic agriculture and landscaping. EPA has published a list of 726 chemicals found in biosolids in the National Sewage Sludge Surveys. This list does not include the per- and polyfluoroalkyl substances (PFAS), which are emerging contaminants of biosolids. 

In addition to PFAS (also referred to as “forever chemicals”), persistent toxic pollutants found in biosolids include inorganic chemicals such as metals and trace elements; organic chemicals such as polychlorinated biphenyls or PCBs, dioxins, pharmaceuticals, and surfactants; and pathogens including bacteria, viruses, and parasites. Regulation of biosolids by the Environmental Protection Agency (EPA) has been found by the EPA Office of Inspector General (OIG) to be inadequate. Lacking sufficient oversight at the federal level, states and local jurisdictions must act to eliminate the hazards created by these contaminants. 

Land application of biosolids to farms and landscapes is considered the standard means of “disposal.” Chemicals such as PFAS have been found to migrate into food when grown in farms using contaminated biosolids. Over 60% of biosolids are used in crops, and the contaminants in them make their way to our food and water. But if biosolids are used in landscaping, the contaminants pose a hazard to landscapers and those using athletic fields. In view of EPA’s failure to provide comprehensive identification, regulation, and elimination of potential contaminants, the biosolids themselves must be tested to ensure safety. Biosolids must be tested to ensure that they do not cause acute toxicity, cancer, genetic mutations, birth defects, reproductive or developmental effects, neurotoxicity, endocrine disruption, or immune system effects. Otherwise, they should not be used on farms or landscapes. 

Thank you for your attention to this urgent issue.

There is an urgent need to enact a transformation to organic agriculture in order to address existential threats to human health, climate, and biodiversity. The Farm Bill covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—offering many opportunities for strengthening organic production. 

>>Tell Congress to use the Farm Bill to strengthen organic agriculture and our democratic process.

As Congress drafts the 2023 Farm Bill, there is an opportunity for many topics—good and bad—to be introduced. Dating back to Franklin D. Roosevelt's New Deal of the 1930s, which addressed threats posed by the Great Depression and drought, the Farm Bill is an omnibus bill passed every five years. It is designed to secure a sufficient food supply, establish fair food prices for both farmers and consumers, provide supplemental food assistance, and protect the soil and other natural resources on which farmers depend, but includes much more. Several proposals relevant to organic agriculture are currently under consideration, and Congress needs to hear that there is strong public support for those that will strengthen organic agriculture. In addition, bills that threaten democratic processes are also being considered. Our voices are also needed to oppose attacks on democracy and support an open, democratic process in writing the Farm Bill. 

The Farm Bill is created through a process of negotiation that largely excludes the public at large. It consists of many sections, championed by a number of different constituencies and vest interests. The Agriculture Committees negotiate the contents of the Farm Bill, but it reaches Congress as one bill to be considered as a whole. As the Farm Bill is currently being put together, we are aware of several potential “marker bills” relevant to organic agriculture and the adoption of organic land care that may be incorporated. 

Positive goals may be supported by these marker bills:

• Increase number of organic farms.
  • Opportunities in Organic Act (S. 1582, H.R. 3650)
• Support beginning and BIPOC farmers. 
  • Justice for Black Farmers Act (S. 96, H.R. 1167) 
• Promote soil health and climate resilience through conservation policy.
  • Agriculture Resilience Act (S. 1016, H.R. 1840) 
• Sustain research that supports organic.
  • Strengthening Organic Agriculture Research Act (SOAR) (H.R. 2720) 
• Provide infrastructure that supports organic. 
  • Seeds and Breeds for the Future Act (S. 2023) 
• Support for organic dairy is urgently needed, but so far no marker bill has been introduced that covers these areas: 
  • More detailed organic milk data to reflect the depth of information provided for non-organic milk production.
  • An organic dairy safety net program based on organic-specific milk and input cost data.
  • Immediate support to address dramatically increased organic input costs for organic dairy farms.
  • Investment in organic milk processing infrastructure that serves areas within the US that have large numbers of organic dairies.
  • Fund feasibility studies on Regional Organic Milkshed Market Access.
    • Expand and improve access for organic dairy farmers to current funding.
    • Create Regional positions for Organic Dairy Market Specialists.
    • Support increased regionally headquartered processing capacity.
• Invest in local and regional food systems. 
  • Local Food and Farms Act (S. 1205, H.R. 2723) 
  • Strengthening Local Processing Act (S. 354, H.R. 945) 
• Address consolidation in food and agriculture. 
  • Farm System Reform Act (S. 271, H.R. 797) 
  • Industrial Agriculture Accountability Act (S. 272, H.R. 805) 
  • Protecting America's Meatpacking Workers Act (S. 270, H.R. 798) 
• The following measures to strengthen organic integrity should be supported, but currently no bill incorporates them: 
  • Set a timeframe for the NOP to do rulemaking after receiving a National Organic Standards Board (NOSB) recommendation when the recommendation is supported by 2/3 of the board.  
  • Require the NOP to clearly state how their rulemaking relates to NOSB recommendations.  
  • Authorize funding for the NOP to keep pace with organic industry growth and direct specific resources towards standards development.  
  • Allow USDA to expand the definition of reimbursable expenses for farmer members of the NOSB to cover substitute labor on their operations during their Board service. Restore the NOSB procedure for “sunset review” of National List materials, to require a 2/3 vote to re-list a material (as opposed to the current process of a 2/3 vote needed to de-list.)  
  • Require the NOP to accredit third-party material review organizations that review agricultural inputs for compliance with the organic standards.  
  • Grant the NOP the authority to take enforcement actions against false organic claims on agricultural non-food products.  

In addition, the following bills threaten the adoption of pesticide restrictions and organic land care by communities and should be strenuously opposed: 

• Agricultural Labeling Uniformity Act (H.R. 4288).
  • Threatens to undermine local and state authority to protect the health of their residents from pesticides—effectively overturning decades of Supreme Court precedent. 
• Ending Agricultural Trade Suppression Act (EATS Act, S. 2019), not to be confused with the Enhance Access to Snap Act (also abbreviated EATS Act).
  • The EATS Act is virtually identical to the notorious “King amendment,” which former Rep. Steve King (R-IA) tried unsuccessfully to attach to the 2014 and 2018 Farm Bills, generating overwhelming bipartisan opposition. With the bill's purpose “To prevent States and local jurisdictions from interfering with the production and distribution of agricultural products....” local and state health and environmental concerns are preempted. An analysis of the King amendment by the Harvard Law School Animal Law & Policy Program produced a long, but not exhaustive, list of laws in every state that could be repealed by the EATS Act. 

Note: We will update this action as more information becomes available to Beyond Pesticides. 

>>Tell Congress to use the Farm Bill to strengthen organic agriculture and our democratic process.

The target for this Action is the U.S. Congress. 

Thank you for your active participation and engagement!

Letter to U.S. Representative and Senators: 

I am writing to urge you to support an open democratic process in creating the 2023 Farm Bill and to use the Farm Bill to address the existential threats to health, climate, and biodiversity, as well as threats to democratic process.

As Congress drafts the 2023 Farm Bill, there is an opportunity for many topics to be introduced. The Farm Bill is created through a process of negotiation that largely excludes the public at large. It consists of many sections, championed by a number of different constituencies. The Agriculture Committees negotiate the contents of the Farm Bill, but it reaches Congress as one bill to be considered as a whole. I urge you to support a more open process.

I also urge you to support the following goals, as embodied in these marker bills:

*Increase number of organic farms: Opportunities in Organic Act H.R. 3650 and S. 1582.

*Support beginning and BIPOC farmers: Justice for Black Farmers Act (S. 96, H.R. 1167)

*Promote soil health and climate resilience through conservation policy: Agriculture Resilience Act (S. 1016, H.R. 1840)

*Sustain research that supports organic: Strengthening Organic Agriculture Research Act
(SOAR) (H.R. 2720)

*Provide infrastructure that supports organic: Seeds and Breeds for the Future Act (S. 2023)

*Support for organic dairy is urgently needed, but so far no marker bill has been introduced that covers these areas:

- More detailed organic milk data to reflect the depth of information provided for non-organic milk production.
- An organic dairy safety net program based on organic-specific milk and input cost data.
- Immediate support to address dramatically increased organic input costs for organic dairy farms.
- Investment in organic milk processing infrastructure that serves areas within the US that have large numbers of organic dairies.
- Fund feasibility studies on Regional Organic Milkshed Market Access.
     - Expand and improve access for organic dairy farmers to current funding.
     - Create Regional positions for Organic Dairy Market Specialists.
     - Support increased regionally headquartered processing capacity.

-FSA/Organic Certification Cost Share Program (OCSSP).

*Invest in local and regional food systems: Local Food and Farms Act (S. 1205, H.R. 2723); Strengthening Local Processing Act (S. 354, H.R. 945)

*Address consolidation in food and agriculture: Farm System Reform Act (S. 271, H.R. 797); Industrial Agriculture Accountability Act (S. 272, H.R. 805); Protecting America’s Meatpacking Workers Act (S. 270, H.R. 798).

*In addition, measures to strengthen organic integrity should be supported, but currently no bill incorporates them, and they deserve public debate.

It is also vitally important to protect democracy and local authority by opposing these proposals:

*Agricultural Labeling Uniformity Act (H.R. 4288), which threatens to undermine local and state authority to protect the health of their residents from pesticides—effectively overturning decades of Supreme Court precedent.

*Ending Agricultural Trade Suppression Act (EATS Act, S. 2019), not to be confused with the Enhance Access to Snap Act (also abbreviated EATS Act). S. 2019 is virtually identical to the notorious “King amendment,” which former Rep. Steve King (R-IA) tried unsuccessfully to attach to the 2014 and 2018 Farm Bills, generating overwhelming bipartisan opposition. An analysis of the King amendment by the Harvard Law School Animal Law & Policy Program produced a long, but not exhaustive, list of laws in every state that could be repealed by the EATS Act.

Thank you.

Mosquito season is upon us, and to many that means spraying pesticides to kill them. But not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds. 

>>Tell EPA to eliminate pesticides that threaten birds or their insect food supply. Tell the U.S. Fish and Wildlife Service and Department of Interior to protect birds by eliminating the use of pesticides that threaten them. Tell Congress that EPA and other agencies need to do their job to protect birds and other mosquito predators.

While the appetite of purple martins for mosquitoes is well known, most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year. 

Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, grackles, chickadees, sparrows, nighthawks, and even the much-maligned starlings. Attract these birds to keep mosquitoes from feasting on you.

On the other hand, insectivorous birds are threatened directly by pesticide use and indirectly by the loss of their prey. In 1962, Rachel Carson drew attention to the poisoning of songbirds in her book Silent Spring. Despite restrictions on the organochlorines used in 1962, over three billion birds, or 29% of 1970s numbers, have been lost in North America over the last 50 years. Research shows that 57% of bird species are in decline, and mosquito-eating birds lead the list. Ninety percent of all declines were within 12 bird families that include sparrows, warblers, blackbirds, larks, sparrows, swallows, nightjars, swifts, finches, flycatchers, starlings, and thrushes. Only waterfowl and wetland bird species show any increase.

Meanwhile, the world is experiencing an insect apocalypse. Recent research has found dramatic drops in overall insect abundance, with leading entomologists identifying steep declines in insect populations. Various studies have found reductions of up to a factor 60 over the past 40 years—there were 60 times as many insects in some locations in the 1970s. Insect abundance has declined more than 75% over the last 29 years, according to research published by European scientists. 

Insectivorous birds are an essential part of global food webs that bring balance to ecological communities, but birds are not the only insectivores to feed on mosquitoes. Animals who contribute to maintaining ecological balance by consuming mosquito larvae and adults include insects, spiders, fish, amphibians, and bats. All are threatened by pesticides.

On a personal level, you can nurture a safe haven for birds and other mosquito predators. Urge your community to adopt safer mosquito management practices. And, remember there are safer personal repellents. See How To Repel Mosquitoes Safely.

Spread the word to your neighbors on safer mosquito management with Beyond Pesticides' doorknob hanger, Manage Mosquitoes This Season without Toxic Chemicals. 

>>Tell EPA to eliminate pesticides that threaten birds or their insect food supply. Tell the U.S. Fish and Wildlife Service and Department of Interior to protect birds by eliminating the use of pesticides that threaten them. Tell Congress that EPA and other agencies need to do their job to protect birds and other mosquito predators.

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. Fish and Wildlife Services, the U.S. Department of the Interior, and the U.S. Congress. 

Thank you for your active participation and engagement!

Letter to EPA:

Mosquito season is upon us, and to many that means spraying pesticides to kill them. But not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds. Most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year.

Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, grackles, chickadees, sparrows, nighthawks, and even the much-maligned starlings.

On the other hand, insectivorous birds are threatened directly by pesticide use and indirectly by the loss of their prey. In 1962, Rachel Carson drew attention to the poisoning of songbirds in her book Silent Spring. Despite restrictions on the organochlorines used in 1962, over three billion birds, or 29% of 1970s numbers, have been lost in North America over the last 50 years. Research shows that 57% of bird species are in decline, and mosquito-eating birds lead the list. Ninety percent of all declines were within 12 bird families that include sparrows, warblers, blackbirds, larks, sparrows, swallows, nightjars, swifts, finches, flycatchers, starlings, and thrushes. Please note the overlap with mosquito-eating birds. Only waterfowl and wetland bird species show any increase.

Meanwhile, the world is experiencing an insect apocalypse. Recent research has found dramatic drops in overall insect abundance, with leading entomologists identifying steep declines in insect populations. Various studies have found reductions of up to a factor 60 over the past 40 years—there were 60 times as many insects in some locations in the 1970s. Insect abundance has declined more than 75% over the last 29 years, according to research published by European scientists.

Insectivorous birds are an essential part of global food webs that bring balance to ecological communities, but birds are not the only insectivores to feed on mosquitoes. Animals who contribute to maintaining ecological balance by consuming mosquito larvae and adults include insects, spiders, fish, amphibians, and bats. All are threatened by pesticides.

The use of pesticides that threaten birds and others who consume mosquitoes is an unreasonable adverse effect on the environment that should lead to the elimination of these pesticides.

Please eliminate the use of pesticides that imperil birds, other mosquito predators, and their insect food supply. At the same time, teach people how to choose safer personal repellents.

Thank you.

Letter to USFWS and DOI:

Mosquito season is upon us, and to many that means spraying pesticides to kill them. But not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds. Most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year.

Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, grackles, chickadees, sparrows, nighthawks, and even the much-maligned starlings.

On the other hand, insectivorous birds are threatened directly by pesticide use and indirectly by the loss of their prey. In 1962, Rachel Carson drew attention to the poisoning of songbirds in her book Silent Spring. Despite restrictions on the organochlorines used in 1962, over three billion birds, or 29% of 1970s numbers, have been lost in North America over the last 50 years. Research shows that 57% of bird species are in decline, and mosquito-eating birds lead the list. Ninety percent of all declines were within 12 bird families that include sparrows, warblers, blackbirds, larks, sparrows, swallows, nightjars, swifts, finches, flycatchers, starlings, and thrushes. Please note the overlap with mosquito-eating birds. Only waterfowl and wetland bird species show any increase.

Meanwhile, the world is experiencing an insect apocalypse. Recent research has found dramatic drops in overall insect abundance, with leading entomologists identifying steep declines in insect populations. Various studies have found reductions of up to a factor 60 over the past 40 years—there were 60 times as many insects in some locations in the 1970s. Insect abundance has declined more than 75% over the last 29 years, according to research published by European scientists.

Insectivorous birds are an essential part of global food webs that bring balance to ecological communities, but birds are not the only insectivores to feed on mosquitoes. Animals who contribute to maintaining ecological balance by consuming mosquito larvae and adults include insects, spiders, fish, amphibians, and bats. All are threatened by pesticides.

The use of pesticides that threaten birds and others who consume mosquitoes is not consistent with management of public lands to support wildlife.

Please eliminate the use of pesticides that imperil birds, other mosquito predators, and their insect food supply. At the same time, teach people how to choose safer personal repellents.

Thank you.

Letter to U.S. Representative and Senators:

Mosquito season is upon us, and to many that means spraying pesticides to kill them. But not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds. Most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year.

Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, grackles, chickadees, sparrows, nighthawks, and even the much-maligned starlings.

On the other hand, insectivorous birds are threatened directly by pesticide use and indirectly by the loss of their prey. In 1962, Rachel Carson drew attention to the poisoning of songbirds in her book Silent Spring. Despite restrictions on the organochlorines used in 1962, over three billion birds, or 29% of 1970s numbers, have been lost in North America over the last 50 years. Research shows that 57% of bird species are in decline, and mosquito-eating birds lead the list. Ninety percent of all declines were within 12 bird families that include sparrows, warblers, blackbirds, larks, sparrows, swallows, nightjars, swifts, finches, flycatchers, starlings, and thrushes. Please note the overlap with mosquito-eating birds. Only waterfowl and wetland bird species show any increase.

Meanwhile, the world is experiencing an insect apocalypse. Recent research has found dramatic drops in overall insect abundance, with leading entomologists identifying steep declines in insect populations. Various studies have found reductions of up to a factor 60 over the past 40 years—there were 60 times as many insects in some locations in the 1970s. Insect abundance has declined more than 75% over the last 29 years, according to research published by European scientists.

Insectivorous birds are an essential part of global food webs that bring balance to ecological communities, but birds are not the only insectivores to feed on mosquitoes. Animals who contribute to maintaining ecological balance by consuming mosquito larvae and adults include insects, spiders, fish, amphibians, and bats. All are threatened by pesticides.

The use of pesticides that threaten birds and others who consume mosquitoes is an unreasonable adverse effect on the environment that should lead to the elimination of these pesticides.

Please ensure by your oversight that EPA, DOI, and other agencies eliminate the use of pesticides that imperil birds, other mosquito predators, and their insect food supply. At the same time, urge EPA to teach people how to choose safer personal repellents.

Thank you.

In view of EPA's failure to protect pollinators from pesticides, the lives of those essential insects, birds, and mammals are increasingly dependent on state and local laws that are under threat of U.S. Congressional action in the upcoming Farm Bill. 

>>Tell Congress: Don't allow the Farm Bill to pre-empt state and local laws.

The Farm Bill covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—and one provision that the pesticide industry would like to include is preemption of local authority to restrict pesticide use. This attack on local governance would undercut the local democratic process to protect public health and safety, especially important in the absence of adequate federal protection of the ecosystems that sustain life.    

As Congress drafts the 2023 Farm Bill, there is an opportunity for many topics—good and bad—to be introduced. Dating back to Franklin D. Roosevelt's New Deal of the 1930s, which addressed threats posed by the Great Depression and drought, the Farm Bill is an omnibus bill passed every five years. It is designed to secure a sufficient food supply, establish fair food prices for both farmers and consumers, and protect the soil and other natural resources on which farmers depend, but includes much more. Both the House of Representatives and the Senate have previously considered and rejected legislation to prohibit local governments from adopting pesticide or food production laws that are more protective than federal rules. If such language were to be incorporated into the 2023 Farm Bill as industrial agriculture, the chemical sector, and the pest control agency plan to do, it would overturn decades of precedent as well as prevent local governments from protecting their residents from hazardous chemicals in their environment. Even if a state is currently preempting local jurisdictions from restricting pesticides throughout their communities, a federal law codifying a prohibition of local rights to restrict pesticides will make it virtually impossible to restore the basic local authority to protect public health and the environment, which has historically been vested in local governments. Remember that the U.S. Supreme Court in 1983 upheld the right of local communities to restrict pesticides under current pesticide law, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). 

The most recent of these potential preempting pieces of the Farm Bill is the Exposing Agricultural Trade Suppression Act (EATS Act), introduced as S. 2619/H.R. 4999 in the 117th Congress by Sen. Roger Marshall (R-KS) and Rep. Ashley Hinson (R-IA), who are expected to reintroduce it soon. The EATS Act is virtually identical to the notorious “King amendment,” which former Rep. Steve King (R-IA) tried unsuccessfully to attach to the 2014 and 2018 Farm Bills, generating overwhelming bipartisan opposition. An analysis of the King amendment by the Harvard Law School Animal Law & Policy Program produced a long, but not exhaustive, list of laws in every state that could be repealed by the EATS Act. 

A diverse set of more than 170 groups strongly opposed the King amendment, including the National Governors Association, National Conference of State Legislatures, National Association of Counties, National League of Cities, FreedomWorks, Fraternal Order of Police, National Farmers Union, National Dairy Producers Organization, National Sustainable Agriculture Coalition, Consumer Federation of America, Consumer Reports, Natural Resources Defense Council, Sierra Club, Humane Society of the United States, ASPCA, United Farm Workers, International Brotherhood of Teamsters, and National Fire Protection Association, plus hundreds of federal and state legislators (bipartisan), individual farmers, veterinary professionals, faith leaders, legal experts, and newspaper editorials including USA Today

When it comes to pesticides applied in communities on lawns and landscapes, the language contained in a 2022 bill, H.R. 7266 “to prohibit the local regulation of pesticide use” is under consideration in the Farm Bill debate. Incorporation of such preemption language is a direct assault on nearly 200 communities across the country that have passed their own policies to restrict the use of toxic pesticides.

The fight to defend the authority of local governments to protect people and the environment has been ongoing for decades. In response to the Supreme Court's 1983 decision in Wisconsin Pub. Intervenor v. Mortier, which found in favor of localities' authority, the pesticide lobby immediately formed the “Coalition for Sensible Pesticide Policy,” and developed boilerplate legislative language to restrict 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 in most cases obtaining, preemption legislation whose text was often identical to the coalition's. Since the passage of those state laws, there have been numerous efforts to preempt local authority in states that do not prohibit local action on pesticides. The American Legislative Exchange Council (ALEC), an industry-backed group, appeared to be behind a failed effort during the last two years to preempt local authority in the Maine state legislature. 

As National Pollinator Week draws to a close, it is vital that communities maintain their right to restrict pesticides linked to pollinator decline and ecosystem collapse, cancer and a host of health effects, and water contamination in order to protect their resident's health and unique local ecosystems. 

>>Tell Congress: Don't allow the Farm Bill to pre-empt state and local laws.

In addition to contacting your members of Congress below, reach out to your local officials and ask them to sign on to a letter opposing preemption language in the Farm Bill. Click here for a sample letter that you can use to contact your local officials. Only local officials may sign on to this letter!

The targets for this Action are the U.S. Congress and U.S. local officials.

Thank you for your active participation and engagement!

Letter to U.S. Representative and Senators:

As we observe Pollinator Week, we must recognize that in view of EPA’s failure to protect pollinators from pesticides, the lives of these vital insects, birds, and mammals are increasingly dependent on state and local laws.

The Farm Bill covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—and one provision that the pesticide industry would like to include is preemption of state and local authorities—which would undercut the local democratic process to protect public health and safety.

As Congress drafts the 2023 Farm Bill, there is an opportunity for many topics—good and bad—to be introduced. Dating back to Franklin D. Roosevelt’s New Deal, which addressed threats posed by the Great Depression and drought, the Farm Bill is an omnibus bill passed every five years. It is designed to secure a sufficient food supply, establish fair food prices for farmers and consumers, and protect the soil and other natural resources on which farmers depend, but includes much more. Both the House of Representatives and the Senate have previously introduced legislation to prohibit local governments from adopting pesticide or food production laws that are more protective than federal rules. If such language were to be incorporated into the 2023 Farm Bill, it would overturn decades of precedent as well as prevent local governments from protecting their residents from hazardous chemicals in their environment.

The most recent of Farm Bill's potential preempting pieces is the Exposing Agricultural Trade Suppression Act (EATS Act), introduced as S. 2619/H.R. 4999 in the 177th Congress by Sen. Roger Marshall (R-KS) and Rep. Ashley Hinson (R-IA), who are expected to reintroduce it soon. The EATS Act is virtually identical to the notorious “King amendment,” which former Rep. Steve King (R-IA) tried unsuccessfully to attach to the 2014 and 2018 Farm Bills, generating overwhelming bipartisan opposition. An analysis of the King amendment by the Harvard Law School Animal Law & Policy Program produced a long, but not exhaustive, list of laws in every state that could be repealed by the EATS Act.

A diverse set of more than 170 groups strongly opposed the King amendment, including the National Governors Association, National Conference of State Legislatures, National Association of Counties, National League of Cities, FreedomWorks, Fraternal Order of Police, National Farmers Union, National Dairy Producers Organization, National Sustainable Agriculture Coalition, Consumer Federation of America, Consumer Reports, Natural Resources Defense Council, Sierra Club, Humane Society of the United States, ASPCA, United Farm Workers, International Brotherhood of Teamsters, and National Fire Protection Association, plus hundreds of federal and state legislators (bipartisan), individual farmers, veterinary professionals, faith leaders, legal experts, and newspaper editorials including USA Today.

Both the U.S. House of Representatives and the Senate have considered and rejected legislation to prohibit local governments from adopting pesticide or food production laws that are more protective than federal rules. If such language were to be incorporated into the 2023 Farm Bill as industrial agriculture, the chemical sector, and the pest control industry have advocated, it would overturn decades of precedent as well as prevent local governments from protecting their residents from hazardous chemicals in their environment. This would be an attack on the nearly 200 communities that have passed or plan to pass their own policies to restrict the use of toxic pesticides. Communities must maintain the right to restrict pesticides linked to pollinator decline and ecosystem collapse, cancer and a host of health effects, and water contamination in order to protect their resident’s health and unique local ecosystems.

Please oppose any attempts to introduce into the Farm Bill any language that preempts state and local authorities.

Organic milk is the top-selling organic food, but organic dairy farmers live on the edge and do not receive prices that meet expenses.   

>>Tell Secretary of Agriculture Vilsack to help organic dairies stay in business.

After years of milk prices that do not cover the cost of organic production, organic dairy farmers in the US are in crisis, and their farms need improvements. Increased consolidation in milk processing and inconsistent enforcement of regulations by the National Organic Program have led to oversupply and a low pay price. More recently, energy costs have increased rapidly as essential feed components have doubled and tripled in price due to unstable international market forces. This threatens the viability of small and mid-sized farms. 

Since 2016, dairy states have been losing family organic dairy farms at an alarming rate. In Vermont, over 35% of organic dairy family farms have folded or left organic. Immediate support to address dramatically increased organic input costs for organic dairy farms is urgently needed. Organic dairy farmers appreciate the recently announced U.S. Department of Agriculture (USDA) Organic Dairy Marketing Assistance Program (ODMAP) funding, but say more aid will be needed to keep organic dairies in business.  

Given the recent estimate that under 50% of the $104 million awarded to the program will be used in the first round, the remaining 25% of estimated marketing costs should be immediately distributed through an automatic process, bringing payments up to $1.10/cwt without requiring producers to re-apply. In addition, USDA should initiate an immediate subsequent round of the program to reflect the difference in costs between marketing of organic and conventional milk—which include greater hauling costs to avoid commingling with nonorganic milk, smaller herds, and a limited number of processing facilities, as well as more expensive organic feed. USDA has acknowledged that there is a significant lack of available data on the production and utilization of organic milk.  

Support is needed for regional programs to collect and publish cost of production data for organic milk, including all costs, not just organic feed. USDA should make full use of the $104 million allocated to the ODMAP program to reflect the higher cost of marketing organic milk as opposed to nonorganic. The National Organic Program must consistently enforce the law for organic dairies, including access to pasture and origin of livestock, to level the playing field for small and mid-sized farms.

There are reasons that organic milk is the top-selling organic food. Milk is important in the diet of children. Research finds that organic milk has a higher nutritional content than non-organic milk, including healthier omega-3 fatty acids and more disease-fighting antioxidants. Organic cows are raised in humane conditions and eat healthy diets, so organic milk can be free of antibiotics, synthetic growth hormones or toxic pesticides. Thus, many parents choose to give their kids a healthy start by feeding them organic dairy. 

>>Tell Secretary of Agriculture Vilsack to help organic dairies stay in business.

The target for this Action is the U.S. Department of Agriculture. 

Thank you for your active participation and engagement!

Letter to Secretary Vilsack: 

Organic milk is the top-selling organic food, but organic dairy farmers live on the edge and do not receive prices that meet expenses.

After years of milk prices that do not cover the cost of organic production, organic dairy farmers in the US are in crisis, and their farms need improvements. Increased consolidation in milk processing and inconsistent enforcement of regulations by the National Organic Program have led to oversupply and a low pay price. More recently, energy costs have increased rapidly as essential feed components have doubled and tripled in price due to unstable international market forces. This threatens the viability of small and mid-sized farms.

Since 2016, dairy states have been losing family organic dairy farms at an alarming rate. In Vermont, over 35% of organic dairy family farms have folded or left organic. Immediate support to address dramatically increased organic input costs for organic dairy farms is urgently needed. Organic dairy farmers appreciate the recently announced USDA Organic Dairy Marketing Assistance Program (ODMAP) funding, but more aid will be needed to keep organic dairies in business.

Given the recent estimate that under 50% of the $104 million awarded to the program will be used in the first round, please ensure that the remaining 25% of estimated marketing costs be immediately distributed through an automatic process, bringing payments up to $1.10/cwt without requiring producers to re-apply. In addition, USDA should initiate an immediate subsequent round of the program to reflect the difference in costs between marketing of organic and conventional milk—which include greater hauling costs to avoid commingling with nonorganic milk, smaller herds, and a limited number of processing facilities, as well as more expensive organic feed. USDA has acknowledged that there is a significant lack of available data on the production and utilization of organic milk. 

Support is needed for regional programs to collect and publish cost of production data for organic milk, including all costs, not just organic feed. USDA should make full use of the $104 million allocated to the ODMAP program to reflect the higher cost of marketing organic milk as opposed to nonorganic. The National Organic Program must consistently enforce the law for organic dairies, including access to pasture and origin of livestock, to level the playing field for small and mid-sized farms.

There are reasons that organic milk is the top-selling organic food. Milk is important in the diet of children. Research finds that organic milk has a higher nutritional content than non-organic milk, including healthier omega-3 fatty acids and more disease-fighting antioxidants. Organic cows are raised in humane conditions and eat healthy diets, so organic milk can be free of antibiotics, synthetic growth hormones or toxic pesticides. Thus, many parents choose to give their kids a healthy start by feeding them organic dairy.

Please support organic dairies through funding and consistent enforcement. Let parents give kids a healthy start.

Thank you.

In view of the urgent need to enact a transformation to organic agriculture in order to address existential threats to human health, climate, and biodiversity, U.S. Senator Peter Welch (VT) and U.S. Representatives Jimmy Panetta (CA-19) and Alma Adams (NC-12) have introduced Senate and House versions of the Opportunities in Organic Act to reduce cost-barriers, expand access to new markets and resources, and provide support and training.

>>Tell your U.S. Representative and U.S. Senators to cosponsor H.R. 3650 and S. 1582, the Opportunities in Organic Act. Thank those who are current cosponsors.

Although some existing programs support organic agriculture, transition, and research, they do not level the playing field for organic producers and do not adequately or holistically meet their needs. Organic certification costs and processes remain a barrier for many, and most producers have limited access to organic-specific technical assistance or mentorship – especially in regions with smaller organic sectors. The Opportunities in Organic Act will expand the existing National Organic Certification Cost-Share Program to reduce these barriers and better serve organic producers.

The Opportunities in Organic Act has three major components:

• Organic Certification Cost-Share. The Opportunities in Organic Act will modernize reimbursements for organic certification, to ensure cost does not deter producers. Cost-share payments will cover up to $1,500 in certification costs. USDA will have discretion to exceed that cap to ensure that certification costs are not a barrier to certification for underserved producers and regions.
  
  
• Transition and Resilience Funds. The bill will provide support for nongovernmental organizations (NGOs) to build capacity to support organic transition, particularly for smaller scale and socially disadvantaged producers and underserved regions. The program will also pass-through funding from NGOs to producers to offset costs and reduce barriers associated with organic transition.
  
  
• Technical Assistance.  The bill will provide resources for organic capacity and partnerships at public institutions and NGOs, including support for education, outreach, and market expansion so producers in any part of the country will have access to professional assistance with building healthy soil, natural pest management, and protecting ecosystems and natural resources.

A wide range of environmental, organic agriculture, and organic research organizations support the Opportunities in Organic Act. Our thanks to the sponsors and cosponsors:

• S. 1582: Sen. Baldwin, Tammy [D-WI], Sen. Booker, Cory A. [D-NJ], Sen. Casey, Robert P., Jr. [D-PA], Sen. Fetterman, John [D-PA], Sen. Gillibrand, Kirsten E. [D-NY], Sen. Heinrich, Martin [D-NM], Sen. King, Angus S., Jr. [I-ME], Sen. Lujan, Ben Ray [D-NM], Sen. Markey, Edward J. [D-MA], Sen. Merkley, Jeff [D-OR], Sen. Murphy, Christopher [D-CT], Sen. Padilla, Alex [D-CA], Sen. Sanders, Bernard [I-VT], and Sen. Smith, Tina [D-MN].
  
  
• H.R. 3650: Rep. Adams, Alma S. [D-NC-12], Rep. Bonamici, Suzanne [D-OR-1], Rep. Lofgren, Zoe [D-CA-18], Rep. McGovern, James P. [D-MA-2], Rep. Panetta, Jimmy [D-CA-19], Rep. Payne, Donald M., Jr. [D-NJ-10], Rep. Pingree, Chellie [D-ME-1], Rep. Salinas, Andrea [D-OR-6], and Rep. Tokuda, Jill N. [D-HI-2].

>>Tell your U.S. Representative and U.S. Senators to cosponsor H.R. 3650 and S. 1582, the Opportunities in Organic Act. Thank those who are current cosponsors.

Letter to U.S. Senators who are not currently co-sponsors of S. 1582:

There is an urgent need to enact a transformation to organic agriculture in order to address existential threats to human health, climate, and biodiversity. U.S. Senator Peter Welch (VT) has introduced S. 1582, the Opportunities in Organic Act to reduce cost-barriers, expand access to new markets and resources, and provide support and training.

Although some existing programs support organic agriculture, transition, and research, they do not level the playing field for organic producers and do not adequately or holistically meet their needs. Organic certification costs and processes remain a barrier for many, and most producers have limited access to organic-specific technical assistance or mentorship – especially in regions with smaller organic sectors.  The Opportunities in Organic Act will expand the existing National Organic Certification Cost-Share Program to reduce these barriers and better serve organic producers.

The Opportunities in Organic Act has three major components:

Organic Certification Cost-Share. The Opportunities in Organic Act will modernize reimbursements for organic certification, to ensure cost does not deter producers. Cost-share payments will cover up to $1,500 in certification costs. USDA will have discretion to exceed that cap to ensure that certification costs are not a barrier to certification for underserved producers and regions.

Transition and Resilience Funds. The bill will provide support for nongovernmental organizations (NGOs) to build capacity to support organic transition, particularly for smaller scale and socially disadvantaged producers and underserved regions. The program will also pass-through funding from NGOs to producers to offset costs and reduce barriers associated with organic transition.

Technical Assistance.  The bill will provide resources for organic capacity and partnerships at public institutions and NGOs, including support for education, outreach, and market expansion so producers in any part of the country will have access to professional assistance with building healthy soil, natural pest management, and protecting ecosystems and natural resources.

A wide range of environmental, organic agriculture, and organic research organizations support the Opportunities in Organic Act.

Will you please cosponsor the Opportunities in Organic Act?

Thank you.

Letter to Senators who are currently co-sponsors of S. 1582:

Thank you for sponsoring S. 1582, the Opportunities in Organic Act. There is an urgent need to enact a transformation to organic agriculture in order to address existential threats to human health, climate, and biodiversity.

Although some existing programs support organic agriculture, transition, and research, they do not level the playing field for organic producers and do not adequately or holistically meet their needs. Organic certification costs and processes remain a barrier for many, and most producers have limited access to organic-specific technical assistance or mentorship – especially in regions with smaller organic sectors. The Opportunities in Organic Act will expand the existing National Organic Certification Cost-Share Program to reduce these barriers and better serve organic producers.

Thank you.

Letter to U.S. Representatives not currently cosponsors of H.R. 3650:

There is an urgent need to enact a transformation to organic agriculture in order to address existential threats to human health, climate, and biodiversity. U.S. Representatives Jimmy Panetta (CA-19) and Alma Adams (NC-12) have introduced H.R. 3650, the Opportunities in Organic Act to reduce cost-barriers, expand access to new markets and resources, and provide support and training., the Opportunities in Organic Act to reduce cost-barriers, expand access to new markets and resources, and provide support and training.

Although some existing programs support organic agriculture, transition, and research, they do not level the playing field for organic producers and do not adequately or holistically meet their needs. Organic certification costs and processes remain a barrier for many, and most producers have limited access to organic-specific technical assistance or mentorship – especially in regions with smaller organic sectors. The Opportunities in Organic Act will expand the existing National Organic Certification Cost-Share Program to reduce these barriers and better serve organic producers.

The Opportunities in Organic Act has three major components:

Organic Certification Cost-Share. The Opportunities in Organic Act will modernize reimbursements for organic certification, to ensure cost does not deter producers. Cost-share payments will cover up to $1,500 in certification costs. USDA will have discretion to exceed that cap to ensure that certification costs are not a barrier to certification for underserved producers and regions.

 Transition and Resilience Funds. The bill will provide support for nongovernmental organizations (NGOs) to build capacity to support organic transition, particularly for smaller scale and socially disadvantaged producers and underserved regions. The program will also pass-through funding from NGOs to producers to offset costs and reduce barriers associated with organic transition.

Technical Assistance. The bill will provide resources for organic capacity and partnerships at public institutions and NGOs, including support for education, outreach, and market expansion so producers in any part of the country will have access to professional assistance with building healthy soil, natural pest management, and protecting ecosystems and natural resources.

A wide range of environmental, organic agriculture, and organic research organizations support the Opportunities in Organic Act.

Will you please cosponsor the Opportunities in Organic Act?

Thank you.

Letter to U.S. Representatives who are currently cosponsors of H.R. 3650:

Thank you for sponsoring H.R. 3650, the Opportunities in Organic Act. There is an urgent need to enact a transformation to organic agriculture in order to address existential threats to human health, climate, and biodiversity.

Although some existing programs support organic agriculture, transition, and research, they do not level the playing field for organic producers and do not adequately or holistically meet their needs. Organic certification costs and processes remain a barrier for many, and most producers have limited access to organic-specific technical assistance or mentorship – especially in regions with smaller organic sectors. The Opportunities in Organic Act will expand the existing National Organic Certification Cost-Share Program to reduce these barriers and better serve organic producers.

Thank you.

Butterflies—the most attractive of our insect fauna—are disappearing at an appalling rate, largely due to pesticide use. Recent studies have documented declines of almost 50% from 1990 to 2011 in Europe (with trends continuing), of 58 percent between 2000 and 2009 in the U.K., and of 33% from 1996–2016 in the state of Ohio in the U.S. Even steeper declines have been documented for Monarch butterflies, with an 80 percent decline of Eastern monarchs and 99 percent decline of Western monarchs. 

>>Tell EPA to eliminate pesticides that threaten butterflies. Tell the U.S. Fish and Wildlife Service and Department of Interior to help bring back butterflies by eliminating the use of pesticides that threaten them. Tell Congress that EPA and other agencies need to do their job and protect our most charismatic insects.

Last year, EPA admitted that three neonicotinoid pesticides are “likely to adversely affect from two-thirds to over three-fourths of America's endangered species—1,225 to 1,445 species in all,” including many butterfly species. On May 5 of this year, EPA released new analyses of these neonics' effects on endangered species. EPA's analyses focus on the species most at risk of extinction, and the results represent a “five-alarm fire,” according to the Center for Biological Diversity's environmental health director, Lori Ann Bird. EPA identifies 25 insect species and upwards of 160 plants dependent on insect pollination whose existence is most perilous.  

Studies upon studies upon studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. The problem is not just insecticides, however. Since butterflies depend on plants—sometimes specific plants, as monarchs depend on milkweeds—the widespread use of herbicides is also a major factor in the loss of butterflies.  

At a more foundational level, pesticides that support industrial agriculture eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity.  

>>Tell EPA to eliminate pesticides that threaten butterflies. Tell the U.S. Fish and Wildlife Service and Department of Interior to help bring back butterflies by eliminating the use of pesticides that threaten them. Tell Congress that EPA and other agencies need to do their job and protect our most charismatic insects.

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. Fish and Wildlife Service, the U.S. Department of the Interior, and the U.S. Congress. 

Thank you for your active participation and engagement!

Letter to EPA:

Butterflies—the most charismatic of our insect fauna—are disappearing at an appalling rate, largely due to pesticide use. Recent studies have documented declines of almost 50% from 1990 to 2011 in Europe (with trends continuing), of 58 percent between 2000 and 2009 in the U.K., and of 33% over 1996–2016 in the state of Ohio in the U.S. Even steeper declines have been documented for Monarch butterflies, with an 80 percent decline of Eastern monarchs and 99 percent decline of Western monarchs.

Last year the EPA admitted that three neonicotinoid pesticides are “likely to adversely affect from two-thirds to over three-fourths of America’s endangered species—1,225 to 1,445 species in all,” including many butterfly species. On May 5 of this year, EPA released new analyses of these neonics’ effects on endangered species. EPA’s analyses focus on the species most at risk of extinction, and the results represent a “five-alarm fire,” according to the Center for Biological Diversity’s environmental health director, Lori Ann Bird. EPA identifies 25 insect species and upwards of 160 plants dependent on insect pollination whose existence is most perilous.

Many studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. The problem is not just insecticides, however. Since butterflies depend on plants—sometimes specific plants, as monarchs depend on milkweeds—the widespread use of herbicides is also a major factor in the loss of butterflies.

At a more foundational level, pesticides that support industrial agriculture eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity.

Please eliminate pesticides that threaten butterflies.

Thank you.

Letter to USFWS and DOI:

Butterflies—the most charismatic of our insect fauna—are disappearing at an appalling rate, largely due to pesticide use. Recent studies have documented declines of almost 50% from 1990 to 2011 in Europe (with trends continuing), of 58 percent between 2000 and 2009 in the U.K., and of 33% over 1996–2016 in the state of Ohio in the U.S. Even steeper declines have been documented for Monarch butterflies, with an 80 percent decline of Eastern monarchs and 99 percent decline of Western monarchs.

Last year the EPA admitted that three neonicotinoid pesticides are “likely to adversely affect from two-thirds to over three-fourths of America’s endangered species—1,225 to 1,445 species in all,” including many butterfly species. On May 5 of this year, EPA released new analyses of these neonics’ effects on endangered species. EPA’s analyses focus on the species most at risk of extinction, and the results represent a “five-alarm fire,” according to the Center for Biological Diversity’s environmental health director, Lori Ann Bird. EPA identifies 25 insect species and upwards of 160 plants dependent on insect pollination whose existence is most perilous.

Many studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. The problem is not just insecticides, however. Since butterflies depend on plants—sometimes specific plants, as monarchs depend on milkweeds—the widespread use of herbicides is also a major factor in the loss of butterflies.

At a more foundational level, pesticides that support industrial agriculture eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity.

Please help bring back butterflies by eliminating the use of pesticides that threaten them on public lands.

Thank you.

Letter to U.S. Senators and Representative:

Butterflies—the most charismatic of our insect fauna—are disappearing at an appalling rate, largely due to pesticide use. Recent studies have documented declines of almost 50% from 1990 to 2011 in Europe (with trends continuing), of 58 percent between 2000 and 2009 in the U.K., and of 33% over 1996–2016 in the state of Ohio in the U.S. Even steeper declines have been documented for Monarch butterflies, with an 80 percent decline of Eastern monarchs and 99 percent decline of Western monarchs.

Last year the EPA admitted that three neonicotinoid pesticides are “likely to adversely affect from two-thirds to over three-fourths of America’s endangered species—1,225 to 1,445 species in all,” including many butterfly species. On May 5 of this year, EPA released new analyses of these neonics’ effects on endangered species. EPA’s analyses focus on the species most at risk of extinction, and the results represent a “five-alarm fire,” according to the Center for Biological Diversity’s environmental health director, Lori Ann Bird. EPA identifies 25 insect species and upwards of 160 plants dependent on insect pollination whose existence is most perilous.

Many studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. The problem is not just insecticides, however. Since butterflies depend on plants—sometimes specific plants, as monarchs depend on milkweeds—the widespread use of herbicides is also a major factor in the loss of butterflies.

At a more foundational level, pesticides that support industrial agriculture eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity.

Please ensure that EPA and other agencies need to do their job and protect our most charismatic insects.

Thank you.

On Endangered Species Day, the U.S. Environmental Protection Agency (EPA) revealed an unfortunate degree of hypocrisy in its claims to protect endangered species from pesticides. 

>>Tell EPA and Congress that dwindling biodiversity is an existential crisis that requires removing serious threats posed by pesticides.

EPA announced that it “is publishing a group of StoryMaps to raise public awareness about protecting endangered species from pesticides.” It continues, “Through its Vulnerable Species Pilot, EPA has been identifying endangered species that are vulnerable to pesticides, developing mitigations to protect them from pesticide exposure, and will apply the mitigations to many types of pesticides.” 

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

Studies upon studies upon studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA's registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments. 

Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. Agricultural intensification, in particular pesticide and fertilizer use, is the leading factor driving declines in bird populations. 

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between this industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity. 

In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. If EPA is to really protect endangered species, it must eliminate the use of toxic pesticides and encourage organic production. The agency must evaluate the allowance of toxic pesticides in a holistic context and recognize that under law EPA has a responsibility to protect living systems that are harmed by the introduction of toxic pesticides—whose uses are unreasonable, given the availability and economic viability of management systems not reliant on toxic inputs.

>>Tell EPA and Congress that dwindling biodiversity is an existential crisis that requires removing serious threats posed by pesticides.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.

Letter to EPA: 

On Endangered Species Day, the U.S. Environmental Protection Agency (EPA) revealed its latest plan to protect endangered species from pesticides. 

EPA announced that it is “publishing a group of StoryMaps to raise public awareness about protecting endangered species from pesticides.” It continues, “Through its Vulnerable Species Pilot, EPA has been identifying endangered species that are vulnerable to pesticides, developing mitigations to protect them from pesticide exposure, and will apply the mitigations to many types of pesticides.” 

However, pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and vulnerability of species to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first to the ways it has created the crisis in the first place. Dwindling biodiversity is an existential crisis that requires removing serious threats posed by pesticides. 

Many studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments. 

Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. And yet, EPA continues to ignore its responsibility to eliminate risks from endocrine disrupting pesticides. Agricultural intensification, in particular pesticide and fertilizer use, is also the leading factor driving declines in bird populations. 

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between this industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity. 

In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. Certainly, these threats to biodiversity qualify as “unreasonable adverse effects on the environment” which, according to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), should disqualify toxic pesticides from being used. If EPA is to really protect endangered species, it must eliminate the use of toxic pesticides and encourage organic production.  

EPA must evaluate the allowance of toxic pesticides in a holistic context and recognize that under law EPA has a responsibility to protect living systems that are harmed by the introduction of toxic pesticides—whose uses are unreasonable, given the availability and economic viability of management systems not reliant on toxic inputs. 

Thank you. 

Letter to U.S. Senators and Representatives: 

On Endangered Species Day, the U.S. Environmental Protection Agency (EPA) revealed its latest plan to protect endangered species from pesticides. 

EPA announced that it is “publishing a group of StoryMaps to raise public awareness about protecting endangered species from pesticides.” It continues, “Through its Vulnerable Species Pilot, EPA has been identifying endangered species that are vulnerable to pesticides, developing mitigations to protect them from pesticide exposure, and will apply the mitigations to many types of pesticides.” 

However, pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and vulnerability of species to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first to the ways it has created the crisis in the first place. Dwindling biodiversity is an existential crisis that requires removing serious threats posed by pesticides. 

Many studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and a part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments. 

Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. And yet, EPA continues to ignore its responsibility to eliminate risks from endocrine disrupting pesticides. Agricultural intensification, in particular pesticide and fertilizer use, is also the leading factor driving declines in bird populations. 

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between this industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity. 

In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. Certainly, these threats to biodiversity qualify as “unreasonable adverse effects on the environment” which, according to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), should disqualify toxic pesticides from being used.  

Please tell EPA to protect endangered species by eliminating the registrations of toxic pesticides and encouraging organic production. 

Thank you. 

Since most of the domestically produced fresh produce we eat comes from California, what happens in the state is of concern to most consumers. The California Department of Pesticide Regulation (DPR) has made minor adjustments to its proposal to remove existing limits on the use of 1,3-dichloropropene (1,3-D or Telone), allowing Californians to breathe much more 1,3-D than state toxicologists at the California Office of Environmental Health Hazard Assessment—charged with establishing safe limits of exposure and enforcing Prop 65—say is safe, highlights the dangers to which farmworkers are routinely exposed. It is outrageous that the U.S. Environmental Protection Agency (EPA) would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices. You may have commented on this early in the year, and now we need to follow up with a strong message to protect those who harvest the nation's food. 

>>Tell EPA, Congress and CDPR to cancel the registration of all toxic soil fumigants and encourage organic alternatives.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health's PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.

These and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment and should be banned. 

>>Tell EPA, Congress, and CDPR to cancel the registration of all toxic soil fumigants and encourage organic alternatives.

For more information, please see Beyond Pesticides' comments to CDPR on proposed regulation #22-005 for 1,3 dichloropropene soil fumigation AND CDPR's notice of proposed changes in the regulations with notice of public hearing.

The targets for this Action are the California Department of Pesticide Regulation, the U.S. Congress and the U.S. Environmental Protection Agency. 

Thank you for your active participation and engagement!

Letter to EPA:

The California Department of Pesticide Regulation (DPR) proposal to remove existing limits on the use of 1,3-dichloropropene (1,3-D), allowing Californians to breathe much more 1,3-D than other state toxicologists say is safe, highlights the dangers to which farmworkers are routinely exposed. It is outrageous that the U.S. Environmental Protection Agency would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices. The minor changes to amend the state’s earlier proposal are woefully inadequate.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health’s PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.

These and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment. Their registrations should be cancelled

Thank you for your attention to this urgent issue.

Letter to U.S. Representatives and Senators

The California Department of Pesticide Regulation (DPR) proposal to remove existing limits on the use of 1,3-dichloropropene (1,3-D), allowing Californians to breathe much more 1,3-D than other state toxicologists say is safe, highlights the dangers to which farmworkers are routinely exposed. It is outrageous that the U.S. Environmental Protection Agency (EPA) would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices. The minor changes to amend the state’s earlier proposal are woefully inadequate.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health’s PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.

These and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment.

Please tell EPA that their registrations should be cancelled.

Thank you for your attention to this urgent issue.

Letter to CDPR:

The California Department of Pesticide Regulation (DPR) proposal to remove existing limits on the use of 1,3-dichloropropene (1,3-D), allowing Californians to breathe much more 1,3-D than other state toxicologists say is safe, highlights the dangers to which farmworkers are routinely exposed. It is outrageous that the DPR would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices. The minor changes to amend the state’s earlier proposal are woefully inadequate.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health’s PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.

These and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment. Their registrations should be cancelled.

Thank you for your attention to this urgent issue.

Say "legacy contaminant" or "forever chemical" and most people today think “PFAS” (perfluoroalkyl substances), but PFAS are just the latest persistent toxic chemicals recognized as presenting an alarmingly difficult cleanup problem. Fortunately, steps are being taken by governments and businesses to eliminate use of PFAS. (Organic farmers concerned about the integrity of their products have been leaders in these efforts.) Although we should be devoting energy to cleaning them up, unless we stop manufacturing them and releasing them into the environment, cleanup efforts will be futile. The U.S. is a signatory to the 2001 Stockholm Convention, which provides an international framework for moving persistent organic pollutants out of commerce, but the U.S. Senate never ratified it.  

>>Ask your Senators to ratify the Stockholm convention. Tell EPA that persistent toxic pesticides must be considered to pose an “unreasonable risk to the environment under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),” which must result in cancellation of their registrations.

PFAS contamination is just the latest chapter of a very old story. Legacy contamination of our bodies and the environment is partly a result of a slow piecemeal approach to eliminating these toxic chemicals. PFAS contamination is found in pesticides—and chlorinated dibenzo-p-dioxins ("dioxins") and chlorodibenzofurans ("dibenzofurans" or "furans") are also found in pesticides like 2,4-D and pentachlorophenol. 

Lead and arsenic are legacy contaminants arising from historical use of lead arsenate as a pesticide, but most legacy pesticide contamination comes from persistent organic (meaning containing carbon) pollutants or POPs. These include organochlorine pesticides like pentachlorophenol, DDT, dieldrin, aldrin, chlordane, mirex, endrin, heptachlor, hexachlorobenzene, and toxaphene. Although use of many persistent organic pesticides is not allowed in the U.S., use of others--notably pentachlorophenol and lindane--is still permitted. (Lindane's use is allowed by FDA as a pediculicide.) Some of those not used in the U.S. are used elsewhere and move in the environment. 

POPs are hazardous chemicals that threaten human health and the planet's ecosystems. POPs take a long time to degrade, are widely distributed throughout the environment, bioaccumulate and biomagnify through the food chain, and are toxic to humans and wildlife. POPs are linked to adverse immune system effects, reproductive disorders, and population declines in birds, fish, and other species. They are associated with reproductive, developmental, behavioral, neurological, endocrine, and immunological health effects in humans.

The persistence and mobility of these toxic chemicals requires a global approach to their removal. The Stockholm Convention on POPs requires signatories to adopt a range of control measures to reduce and, where feasible, eliminate the release of POPs but the U.S. has not ratified the treaty.

>>Ask your Senators to ratify the Stockholm convention. Tell EPA that persistent toxic pesticides must be considered to pose an “unreasonable risk to the environment under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),” which must result in cancellation of their registrations.

The targets for this Action are the U.S. Congress and the U.S. Environmental Protection Agency Administrator. 

Thank you for your active participation and engagement!

Letter to U.S. Senators: 

Say "legacy contaminant" or "forever chemical" and most people today think “PFAS” (perfluoroalkyl substances), but PFAS are just the latest persistent toxic chemicals recognized as presenting an alarmingly difficult cleanup problem. Fortunately, steps are being taken by governments and businesses to eliminate the use of PFAS. Although we should be devoting energy to cleaning them up, unless we stop manufacturing them and releasing them into the environment, cleanup efforts will be futile. 

PFAS contamination is just the latest chapter of a very old story. Legacy contamination of our bodies and the environment is partly a result of a slow piecemeal approach to eliminating these toxic chemicals. One source of PFAS contamination is pesticides—and chlorinated dibenzo-p-dioxins ("dioxins") and chlorodibenzofurans ("dibenzofurans" or "furans") are also found in pesticides like 2,4-D and pentachlorophenol.

Lead and arsenic are legacy contaminants arising from historical use of lead arsenate as a pesticide, but most legacy pesticide contamination comes from persistent organic (carbon-containing) pollutants or POPs. These include organochlorine pesticides like pentachlorophenol, DDT, dieldrin, aldrin, chlordane, mirex, endrin, heptachlor, hexachlorobenzene, and toxaphene. Although use of many persistent organic pesticides is not allowed in the U.S., use of others--notably pentachlorophenol and lindane--is still permitted. (Lindane's use is allowed by FDA as a pediculicide.) Some of those not used in the U.S. are used elsewhere and move in the food system and the environment. 

POPs are hazardous chemicals that threaten human health and the planet’s ecosystems. POPs take a long time to degrade, are widely distributed throughout the environment, bioaccumulate and biomagnify through the food chain, and are toxic to humans and wildlife. POPs are linked to adverse immune system effects, reproductive disorders, and population declines in birds, fish, and other species. They are associated with reproductive, developmental, behavioral, neurological, endocrine, and immunological health effects in humans. 

The persistence and mobility of these toxic chemicals requires a global approach to their removal. One global mechanism is the Stockholm Convention on POPs, which requires signatories to adopt a range of control measures to reduce and, where feasible, eliminate the release of POPs. Although the U.S. has signed the Stockholm convention, it still requires Senate ratification. 

I ask you to advocate for a vote to ratify the Stockholm convention. 

Thank you. 

Letter to EPA: 

Say "legacy contaminant" or "forever chemical," and most people today think “PFAS” (perfluoroalkyl substances), but PFAS are just the latest persistent toxic chemicals recognized as presenting an alarmingly difficult cleanup problem. Fortunately, steps are being taken by governments and businesses to eliminate use of PFAS. Although we should be devoting energy to cleaning them up, unless we stop manufacturing them and releasing them into the environment, cleanup efforts will be futile. 

PFAS contamination is just the latest chapter of a very old story. Legacy contamination of our bodies and the environment is partly a result of a slow piecemeal approach to eliminating these toxic chemicals. One source of PFAS contamination is pesticides—and other persistent toxic substances like chlorinated dibenzo-p-dioxins ("dioxins") and chlorodibenzofurans ("dibenzofurans" or "furans") are also found in pesticides like 2,4-D and pentachlorophenol.

Lead and arsenic are legacy contaminants arising from historical use of lead arsenate as a pesticide, but most legacy pesticide contamination comes from persistent organic (carbon-containing) pollutants or POPs. These include organochlorine pesticides like pentachlorophenol, DDT, dieldrin, aldrin, chlordane, mirex, endrin, heptachlor, hexachlorobenzene, and toxaphene. Although use of many persistent organic pesticides is not allowed in the U.S., use of others--notably pentachlorophenol and lindane--is still permitted. (Lindane's use is allowed by FDA as a pediculicide.) Some of those not used in the U.S. are used elsewhere and move in the food system and the environment. 

POPs are hazardous chemicals that threaten human health and the planet’s ecosystems. POPs take a long time to degrade, are widely distributed throughout the environment, bioaccumulate and biomagnify through the food chain, and are toxic to humans and wildlife. POPs are linked to adverse immune system effects, reproductive disorders, and population declines in birds, fish, and other species. They are associated with reproductive, developmental, behavioral, neurological, endocrine, and immunological health effects in humans. 

The persistence and mobility of these toxic chemicals requires a global approach to their removal. One global mechanism is the Stockholm Convention on POPs, which requires signatories to adopt a range of control measures to reduce and, where feasible, eliminate the release of POPs. Although the U.S. has not ratified the Stockholm convention, EPA can—and should—adopt its policy in pesticide registration decisions. 

Persistent toxic pesticides must be considered to pose an “unreasonable risk to the environment,” which must result in cancellation of their registrations. 

Thank you. 

The Farm Bill in Congress covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—and the pesticide industry would like to insert a provision that takes away (preempts) local authority to restrict pesticide use—which would undercut the local democratic process to protect public health and safety. Even if communities are not now regulating toxic pesticides, we do not want to close the door on future action, as communities take on petrochemical pesticide and fertilizer use that is contributing to health threats, biodiversity collapse, and the climate emergency. 

>>Part 1: Tell your local officials to sign onto a letter opposing the preemption language | Part 2: Tell your U.S. Representative and Senators to support communities by opposing anti-democratic preemption language in the 2023 Farm Bill.

As Congress drafts the 2023 Farm Bill, there is an opportunity for many topics—good and bad—to be introduced. Dating back to Franklin D. Roosevelt's New Deal of the 1930s, which addressed threats posed by the Great Depression and drought, the Farm Bill is an omnibus bill passed every five years. It is designed to secure a sufficient food supply, establish fair food prices for both farmers and consumers, and protect the soil and other natural resources on which farmers depend, but includes much more. In the 117th Congress, H.R. 7266 was introduced to prohibit local governments from adopting pesticide laws that are more protective than federal rules. If such language were to be incorporated into the 2023 Farm Bill as the pesticide industry plans to do, it would overturn decades of precedent as well as prevent local governments from protecting their residents from hazardous chemicals in their environment.  

This is a direct assault on nearly 200 communities across the country that have passed their own policies to restrict the use of toxic pesticides. Communities must maintain the right to restrict pesticides linked to cancer, water-contamination, and the decline of pollinators to protect their residents' health and unique local ecosystems. 

The provision hinges on the concept of preemption: a legal theory that allows larger jurisdictions (federal and state) to limit the authority of a jurisdiction within it to regulate a specific issue. In 1991, the Supreme 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 may 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.  

If the pesticide industry is successful, the impacts for public health and ecological stability would be devastating. Only states and the federal government would be able to regulate pesticide use. With most state agencies allowing all uses on labels approved 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. 

Preemption would quash a growing national grassroots movement encouraging alternatives to toxic pesticides where people live, work, and play. Federal preemption would prevent local governments from instituting pesticide regulations that are stricter than federal regulations, taking away communities' basic right to secure their own safety and interrupting a burgeoning movement of local pesticide restrictions. Such preemption provisions will likely prevent states from giving localities the right to regulate pesticides.  

Many pesticides targeted by local city residents, including neonicotinoids, glyphosate, and atrazine, have been banned or restricted in other countries due to health or environmental concerns. However, in the U.S. the Environmental Protection Agency has not taken similar action on these pesticides. Given federal inaction and the previous administration's failure to follow sound science, it is imperative that local governments retain the ability to tailor laws so localities can respond to federal actions that permit the use of toxic chemicals that residents do not want in their community.  

Having failed to curtail prohibitions against local restrictions into the 2018 Farm Bill after massive pushback from health advocates, local officials, and Congressional allies, the chemical industry is renewing its attack. The industry continues to flex its muscle in Congress through attempts to add preemption language in the 2023 Farm Bill as a growing number of communities are deciding to act.

>>Part 1: Tell your local officials to sign onto a letter opposing the preemption language | Part 2: Tell your U.S. Representative and Senators to support communities by opposing anti-democratic preemption language in the 2023 Farm Bill.

The targets for this Action are the U.S. Congress and local elected officials across the United States. 

Thank you for your active participation and engagement!

Part I: Ask your local officials to sign on this letter opposing the preemption language 

Mayors, city council members, and county commissioners should make their voices heard in opposition to preemption, which prohibits local governments from adopting pesticide laws that are more protective than federal and state rules and overturns decades of precedent and Supreme Court rulings. It could prevent local governments from tailoring laws to the specific needs of their communities.

Please send your mayor and other local officials a short note (see below) asking them to sign this letter! [Note: Only sign-ons of local officials can be accepted]

To find contact information for local elected officials, check out this tool from usa.gov: https://www.usa.gov/elected-officials 

• Letter Link: bp-dc.org/official-local-letter-pesticide-preemption
• Link for a local elected official to sign: https://secure.everyaction.com/aMcVHaaV7ES6Qw6RhBOCbw2

Sample email to local elected officials (please cut-and-paste, as needed):

As a local elected official, please make your voice heard in opposition to federal preemption of local authority, which prohibits local governments from adopting pesticide laws that are more protective than federal and state rules and overturns decades of precedent and Supreme Court rulings. It could prevent local governments from tailoring laws to the specific needs of our community. Please see the letter and a link to sign onto the letter below:

Letter: bp-dc.org/official-local-letter-pesticide-preemption

Link to sign on to the letter: https://secure.everyaction.com/aMcVHaaV7ES6Qw6RhBOCbw2

While having differing views on pesticides, local leaders take very seriously a duty to protect constituents. Federal pesticide preemption is a direct attack on this authority. This provision prohibits local governments from adopting pesticide laws that are more protective than federal rules. It overturns decades of precedent and Supreme Court rulings and could prevent local governments from tailoring laws to the specific needs of their communities. 

As of 2023, nearly 200 communities across the country have passed policies to restrict the use of pesticides in response to emerging evidence about potential human and environmental impacts. The exact concerns differ by pesticide, but include links to cancer, developmental challenges, lower IQ, and delayed motor development. Many of these laws work to protect the most vulnerable among us, such as children, who take in more pesticides relative to their body weight than adults and have developing organ systems. Others focus on safeguarding precious water resources, or the protection of wildlife like declining pollinator species critical to our environment and food supply.   

While not every city has taken these actions, it is important to support the right to do so and you should oppose forfeiting this right for the indefinite future. In fact, federal pesticide preemption undermines the key role that local governments play across the country. 

Please sign this letter in opposition to including preemption in the Farm Bill. 

Thank you. 

Part II: Tell Congress to support communities by opposing anti-democratic preemption language in the 2023 Farm Bill

Letter to U.S Representative and Senators with local elected official signatories:

I am writing to urge you to oppose adding language in the 2023 Farm Bill that seeks to deny local communities the power to protect themselves from chemical exposure when state and federal regulation is inadequate. If incorporated into the upcoming 2023 Farm bill, it would amend federal pesticide law to prohibit local governments from restricting pesticide use 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. Our state is represented in a letter to the Agriculture Committees of Congress, requesting that they uphold the right of communities to protect the health and safety of their residents and their environment. The letter can be found at bp-dc.org/official-local-letter-pesticide-preemption. 

This is a direct assault on nearly 200 communities across the country that have passed their own policies to restrict the use of toxic pesticides. Communities must maintain the right to restrict pesticides linked to cancer, water contamination, and the decline of pollinators to protect their resident’s health and unique local ecosystems. 

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 retain authority to take away local control. 

This legislation would quash a growing national grassroots movement encouraging alternatives to toxic pesticides where people live, work, and play. It would prevent local governments from instituting pesticide regulations that are stricter than federal regulations, confiscating communities’ basic right to secure their own safety and interrupting a burgeoning movement of local pesticide restrictions. Many pesticides targeted by local city residents, including neonicotinoids, glyphosate, and atrazine, have been banned or restricted in other countries due to health or environmental concerns. However, in the U.S. the Environmental Protection Agency has not taken similar action on these pesticides. Given federal inaction and the previous administration’s failure to follow sound science, it is imperative that local governments retain the ability to tailor laws so localities can respond to federal actions that permit the use of toxic chemicals that residents do not want in their community.    

Please let me know your position on these preemption provisions. 

Thank you. 

Letter to U.S Representative and Senators without local elected official signatories:

I am writing to urge you to oppose adding language in the 2023 Farm Bill that seeks to deny local communities the power to protect themselves from chemical exposure when state and federal regulation is inadequate. If incorporated into the upcoming 2023 Farm bill, it would amend federal pesticide law to prohibit local governments from restricting pesticide use 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 

This is a direct assault on nearly 200 communities across the country that have passed their own policies to restrict the use of toxic pesticides. Communities must maintain the right to restrict pesticides linked to cancer, water contamination, and the decline of pollinators to protect their resident’s health and unique local ecosystems. 

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 retain authority to take away local control. 

This legislation would quash a growing national grassroots movement encouraging alternatives to toxic pesticides where people live, work, and play. It would prevent local governments from instituting pesticide regulations that are stricter than federal regulations, confiscating communities’ basic right to secure their own safety and interrupting a burgeoning movement of local pesticide restrictions. Many pesticides targeted by local city residents, including neonicotinoids, glyphosate, and atrazine, have been banned or restricted in other countries due to health or environmental concerns. However, in the U.S. the Environmental Protection Agency has not taken similar action on these pesticides. Given federal inaction and the previous administration’s failure to follow sound science, it is imperative that local governments retain the ability to tailor laws so localities can respond to federal actions that permit the use of toxic chemicals that residents do not want in their community.    

Please let me know your position on these preemption provisions. 

Thank you. 

The sheer number of different chemicals in the nation's waterways and thus potential for toxic mixtures presents significant risks to health and the environment. However, the range of pesticides and the widespread contamination across the country would not be as fully uncovered without the work of the U.S. Geological Survey (USGS). Research conducted by USGS and the U.S. Environmental Protection Agency (EPA) on urban runoff across the country in 2019 found 215 of 438 sampled toxic compounds present in the water.  

The toxic soup in many U.S. waterways is unsustainable and threatens the foundation of many food chains. Imbalances in aquatic environments can ripple throughout the food web, creating trophic cascades that further exacerbate health and environmental damage. The data on water contamination has become one of the compelling reasons to abandon reliance on toxic chemicals in favor of organic land management can eliminate these threats.  

>>Tell your U.S. Representative and Senators to help keep the USGS’ Pesticide National Synthesis Project. Tell Secretary of Interior Deb Haaland and EPA Administrator that USGS mapping of pesticide use and monitoring of waterways is critical to good decision making and pesticides shown to contaminate rivers and streams must be banned.

The USGS Water Resources Mission Area (WMA) researches pesticide use, trends in pesticide occurrence in streams, concentrations of pesticides in water of potential human health concern, pesticide toxicity to aquatic organisms, pesticides and stream ecology, and pesticides and lake sediment. While agricultural practices appear to correlate with peaking pesticide contamination during the growing season, urban runoff represents a larger overall proportion of the contamination flowing into waterways. With little to no natural soil to filter contamination, and impervious surfaces creating massive outflows of polluted water, this finding is unsurprising. 

A recent USGS study shows that waterways that flow into the Great Lakes are experiencing year-round pesticide contamination that exceeds benchmarks meant to protect aquatic life. This is only one of many studies based on USGS monitoring of 110 stream and river sites, combined with mapping of annual agricultural chemical use. Other recent studies by USGS have found that dozens of pesticides are consistently found in midwestern streams; 88 percent of water samples in U.S. rivers and streams contain at least five or more different pesticides; 41% of public water supply wells are contaminated with pesticides or their degradates; and degradation of rivers from pesticide pollution continues unabated. 

The studies relating pesticide use and contamination of waterways should be used by the EPA in pesticide registration decisions. “What you use makes it into the water,” Sam Oliver, PhD, coauthor of the most recent study, told the Milwaukee Journal Sentinel. As important as the existing monitoring network is, a joint study by USGS and EPA shows that it underestimates the problem—more frequent sampling detects twice as many pesticides, at higher concentrations. 

>>Tell Secretary of Interior Deb Haaland to expand USGS mapping of pesticide use and monitoring of waterways. Tell EPA Administrator Michael Regan that pesticides shown to contaminate rivers and streams must be banned.

The targets for this Action are the U.S. Congress, the U.S. Secretary of the Interior, and the U.S. Environmental Protection Agency Administrator. 

Thank you for your active participation and engagement!

Letter to U.S. Secretary of Interior Deb Haaland 

A recent study by the U.S. Geological Survey (USGS) shows that waterways that flow into the Great Lakes are experiencing year-round pesticide contamination that exceeds benchmarks meant to protect aquatic life. This is only one of many studies based on USGS monitoring of 110 stream and river sites, combined with mapping of annual agricultural chemical use. Other recent studies by USGS have found that dozens of pesticides are consistently found in midwestern streams; 88 percent of water samples in U.S. rivers and streams contain at least five or more different pesticides; 41% of public water supply wells are contaminated with pesticides or their degradates; and degradation of rivers from pesticide pollution continues unabated. 

The studies relating pesticide use and contamination of waterways should be used by the Environmental Protection Agency (EPA) in pesticide registration decisions. “What you use makes it into the water,” Sam Oliver, PhD, coauthor of the most recent study, told the Milwaukee Journal Sentinel. As important as the existing monitoring network is, a joint study by USGS and EPA shows that it underestimates the problem—more frequent sampling detects twice as many pesticides, at higher concentrations. 

The USGS Water Resources Mission Area (WMA) researches pesticide use, trends in pesticide occurrence in streams, concentrations of pesticides in water of potential human health concern, pesticide toxicity to aquatic organisms, pesticides and stream ecology, and pesticides and lake sediment. While agricultural practices appear to correlate with peaking pesticide contamination during the growing season, urban runoff represents a larger overall proportion of the contamination flowing into waterways. With little to no natural soil to filter contamination, and impervious surfaces creating massive outflows of polluted water, this finding is unsurprising. Research conducted by USGS and EPA on urban runoff across the country in 2019 found 215 of 438 sampled toxic compounds present in the water. The sheer number of different chemicals and thus potential for even more toxic mixtures presents significant risks to health and the environment.   

The toxic soup in many U.S. waterways is unsustainable and threatens the foundation of many food chains. Imbalances in aquatic environments can ripple throughout the food web, creating trophic cascades that further exacerbate health and environmental damage. The data on water contamination has become one of the compelling reasons to abandon reliance on toxic chemicals in favor of organic land management can eliminate these threats.  

Scientific research by USGS is essential to evaluate the impacts of pesticides and must be included in EPA’s pesticide registration decisions. I urge you to increase USGS research into pesticide use and impacts. 

Thank you. 

Letter to U.S. EPA Administrator Michael Regan 

A recent study by the U.S. Geological Survey (USGS) shows that waterways that flow into the Great Lakes are experiencing year-round pesticide contamination that exceeds benchmarks meant to protect aquatic life. This is only one of many studies based on USGS monitoring of 110 stream and river sites, combined with mapping of annual agricultural chemical use. Other recent studies by USGS have found that dozens of pesticides are consistently found in midwestern streams; 88 percent of water samples in U.S. rivers and streams contain at least five or more different pesticides; 41% of public water supply wells are contaminated with pesticides or their degradates; and degradation of rivers from pesticide pollution continues unabated. 

The studies relating pesticide use and contamination of waterways should be used by the Environmental Protection Agency (EPA) in pesticide registration decisions. “What you use makes it into the water,” Sam Oliver, PhD, coauthor of the most recent study, told the Milwaukee Journal Sentinel. As important as the existing monitoring network is, a joint study by USGS and EPA shows that it underestimates the problem—more frequent sampling detects twice as many pesticides, at higher concentrations. 

The USGS Water Resources Mission Area (WMA) researches pesticide use, trends in pesticide occurrence in streams, concentrations of pesticides in water of potential human health concern, pesticide toxicity to aquatic organisms, pesticides and stream ecology, and pesticides and lake sediment. While agricultural practices appear to correlate with peaking pesticide contamination during the growing season, urban runoff represents a larger overall proportion of the contamination flowing into waterways. With little to no natural soil to filter contamination, and impervious surfaces creating massive outflows of polluted water, this finding is unsurprising. Research conducted by USGS and EPA on urban runoff across the country in 2019 found 215 of 438 sampled toxic compounds present in the water. The sheer number of different chemicals and thus potential for even more toxic mixtures presents significant risks to health and the environment.   

The toxic soup in many U.S. waterways is unsustainable and threatens the foundation of many food chains. Imbalances in aquatic environments can ripple throughout the food web, creating trophic cascades that further exacerbate health and environmental damage. The data on water contamination has become one of the compelling reasons to abandon reliance on toxic chemicals in favor of organic land management can eliminate these threats. 

Scientific research by USGS is essential to evaluate the impacts of pesticides and must be included in EPA’s pesticide registration decisions. EPA must not register toxic chemicals that pollute waterways and groundwater. No contamination is reasonable under federal pesticide law, given the availability of cost-effective alternative practices and products certified by the U.S. Department of Agriculture’s National Organic Program. 

Thank you. 

Letter to U.S. Representative and U.S. Senators 

I am writing to ask you to advocate for the retention of the Pesticide National Synthesis Project at the U.S. Geological Survey (USGS). This important program for data collection is slated to be phased out.

A recent study by the USGS shows that waterways that flow into the Great Lakes are experiencing year-round pesticide contamination that exceeds benchmarks meant to protect aquatic life. This is only one of many studies based on USGS monitoring of 110 stream and river sites, combined with mapping of annual agricultural chemical use. Other recent studies by USGS have found that dozens of pesticides are consistently found in midwestern streams; 88 percent of water samples in U.S. rivers and streams contain at least five or more different pesticides; 41% of public water supply wells are contaminated with pesticides or their degradates; and degradation of rivers from pesticide pollution continues unabated.

The studies relating pesticide use and contamination of waterways can and should be used by the Environmental Protection Agency (EPA) in pesticide registration decisions. “What you use makes it into the water,” Sam Oliver, PhD, coauthor of the most recent study, told the Milwaukee Journal Sentinel. As important as the existing monitoring network is, a joint study by USGS and EPA shows that it underestimates the problem—more frequent sampling detects twice as many pesticides, at higher concentrations.

The USGS Water Resources Mission Area (WMA) researches pesticide use, trends in pesticide occurrence in streams, concentrations of pesticides in water of potential human health concern, pesticide toxicity to aquatic organisms, pesticides and stream ecology, and pesticides and lake sediment. While agricultural practices appear to correlate with peaking pesticide contamination during the growing season, urban runoff represents a larger overall proportion of the contamination flowing into waterways. With little to no natural soil to filter contamination, and impervious surfaces creating massive outflows of polluted water, this finding is unsurprising. Research conducted by USGS and EPA on urban runoff across the country in 2019 found 215 of 438 sampled toxic compounds present in the water. The sheer number of different chemicals and thus potential for even more toxic mixtures presents significant risks to health and the environment.  

The toxic soup in many U.S. waterways is unsustainable and threatens the foundation of many food chains. Imbalances in aquatic environments can ripple throughout the food web, creating trophic cascades that further exacerbate health and environmental damage. The data on water contamination has become one of the compelling reasons to abandon reliance on toxic chemicals in favor of organic land management can eliminate these threats.

Scientific research by USGS is essential to evaluating the impacts of pesticides and must be included in EPA’s pesticide registration decisions. USGS needs your continued support to elevate, not eliminate or reduce, its role in uncovering and documenting the contamination caused by registered pesticide use. In addition, please urge EPA to cancel pesticides that pollute waterways and groundwater. No contamination is reasonable under federal pesticide law, given the availability of cost-effective alternative practices and products certified by the U.S. Department of Agriculture’s National Organic Program.

Thank you.

It is well-known that trees and other plants help fight climate change by sequestering carbon in their wood and roots—especially when they are allowed to grow continuously. However, plants help in other ways as well. 

Plants—especially trees—also moderate the climate through their participation in the water cycle. And when the weather is hot and dry, they hold the soil, preventing dust bowl conditions. In the 1930's, the U.S. Forest Service, Civilian Conservation Corps, and the Works Progress Administration, together with local farmers, planted more than 220 million trees, developing 18,000 miles of windbreaks on the Great Plains. Unfortunately, those windbreaks are now endangered by the same economic impetus that helped create the Dust Bowl—making more room for economically valuable crops. 

Organic farming helps resist climate change in several ways. Regenerative organic farming sequesters carbon in the soil. Organic farming does not rely on synthetic fertilizers that release nitrous oxide, which is 300 times more potent than carbon dioxide as a greenhouse gas. Finally, organic producers are required to conserve biodiversity, which involves preserving elements of natural ecosystems. Unfortunately, however, the U.S. Department of Agriculture (USDA) has yet to implement the recommendation of the National Organic Standards Board (NOSB) to remove incentives to convert native ecosystems to organic farms. 

Dating back to Franklin D. Roosevelt's New Deal of the 1930s, which addressed threats posed by the Great Depression and drought, the Farm Bill is an omnibus bill passed every five years. It is designed to secure a sufficient food supply, establish fair food prices for both farmers and consumers, and protect the soil and other natural resources on which farmers depend. Although the Farm Bill now covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—over its history, conservation has been a major concern addressed in the bill. This year, incorporating climate-friendly provisions is more urgent than ever. 

Moving forward: 

• Congress must incorporate into the Farm Bill support for a national transition to organic farming, incentives to build soil health and eliminate dependence on petrochemical inputs, disincentives for removing trees and native vegetation, and incentives to plant hedgerows and shelterbelts. 
• USDA must implement the NOSB recommendation to remove incentives to convert native ecosystems to organic farms. Currently, organic farmers transitioning from nonorganic practices must wait three years before selling products as organic, while farmers who bulldoze forests can sell organic products immediately. 

U.S. Representatives and Senators are developing bills for incorporation in the Farm Bill. So far, the Agriculture Resilience Act (ARA) includes the provisions and investments to ensure the long-term viability of our farms and food system, and the Protect the West Act calls for a $60 billion investment in the region's forests, grasslands, and watersheds, with the aim of preventing another Dust Bowl. These bills are not perfect—the ARA avoids mentioning organic agriculture, and the Protect the West Act advances “restoration and resilience,” but contains unqualified support for control of invasive species without mandating restrictions on petrochemical pesticides and fertilizers.

Needless to say, without these critical restrictions, we will see ongoing and increasing dependency on toxic chemicals that contribute to health threats, biodiversity collapse, and the climate emergency. We must advocate with those ready to consider a Farm Bill that addresses climate change clear stipulations to eliminate use of fossil fuel-based pesticides and fertilizers. 

>>Tell your U.S. Representative and Senators to address climate change in the Farm Bill by incorporating a large-scale, national transition to certified organic agriculture and restoration and resilience strategies that prohibit the use of petrochemical pesticides and fertilizers. Tell Secretary of Agriculture Vilsack to implement the NOSB recommendation to remove incentives to convert native ecosystems to organic farms.

The targets for this Action are the U.S. Congress and the Secretary of the U.S. Department of Agriculture. 

Thank you for your active participation and engagement!

Letter to U.S. Representative and Senators: 

Agriculture both contributes to climate change and suffers from its impacts. As the 2023 Farm Bill is developed, it is important that it contain provisions to mitigate climate change and adopt restoration and resilience strategies prohibiting the use of petrochemicals—with dramatically increased support for conversion to organic land management and strict protection of native ecosystems. 

Although trees and other plants help fight climate change by sequestering carbon in their tissues, they help in other ways as well. 

Plants—especially trees—also moderate the climate through their participation in the water cycle. And when the weather is hot and dry, they hold the soil, preventing dust bowl conditions. In the 1930’s, 18,000 miles of windbreaks were planted on the Great Plains. Unfortunately, those windbreaks are now endangered by the same economic impetus that helped create the Dust Bowl—making more room for economically valuable crops. 

Organic farming helps resist climate change by sequestering carbon in the soil; eliminating reliance on synthetic fertilizers that release nitrous oxide (300 times more potent than carbon dioxide as a greenhouse gas); and conserving biodiversity and natural ecosystems. Unfortunately, however, the U.S. Department of Agriculture (USDA) has yet to implement the recommendation of the National Organic Standards Board (NOSB) to remove incentives to convert native ecosystems to organic farms. Currently, organic farmers transitioning from nonorganic practices must wait three years before selling products as organic, while farmers who bulldoze forests can sell organic products immediately. 

Dating back to the New Deal of the 1930s, which addressed threats posed by the Great Depression and drought, the Farm Bill is an omnibus bill passed every five years. It now covers many areas—ranging from the supplemental nutritional assistance program (SNAP) to trade—but conservation has always been of major importance in the bill. This year, incorporating climate-friendly provisions is more urgent than ever. 

Congress must incorporate into the Farm Bill support for a national transition to organic farming, incentives to build soil health and reduce farm use of petrochemical inputs, disincentives for removing trees and native vegetation, and incentives to plant hedgerows and shelterbelts. 

Some bills developed for incorporation in the Farm Bill address issues affecting climate. The Agriculture Resilience Act (ARA) includes provisions and investments to ensure the long-term viability of our farms and food system; the Protect the West Act calls for a $60 billion investment in the region’s forests, grasslands, and watersheds, with the aim of preventing another Dust Bowl. These bills are not perfect—the ARA avoids mentioning organic agriculture, and the Protect the West Act advances “restoration and resilience,” but contains unqualified support for control of invasive species without mandating restrictions on petrochemical pesticides and fertilizers that are critical to reduce dependency on toxic chemicals that contribute to health threats, biodiversity collapse, and the climate emergency.  

As you consider a Farm Bill that addresses climate change, please establish clear requirements to eliminate use of fossil fuel-based pesticides and fertilizers in any provisions advancing important restoration and resilience practices. 

Please advocate for a Farm Bill that promotes a large-scale, national transition to certified organic farming (which contains incentives to build soil health and eliminates dependence on petrochemical inputs) and includes disincentives for removing trees and native vegetation and incentives to plant hedgerows and shelterbelts. 

Please tell USDA to implement the NOSB recommendation to remove incentives to convert native ecosystems to organic farms.  

Thank you. 

Letter to Secretary Vilsack: 

In 2018, the National Organic Standards Board (NOSB) voted nearly unanimously to protect native ecosystems. It sought to change the current perverse regulation that incentivizes the immediate destruction of native ecosystems and conversion to organic production as a cheaper and faster option than transitioning existing conventional farmland over a three-year period. It is now time for the National Organic Program (NOP) to take action to protect the integrity of the seal and help reverse the biodiversity crisis and reduce global warming. 

Protecting native ecosystems slows climate change, something the Biden Administration and organic consumers care deeply about, but NOP regulations will continue to contribute to the problem until the NOP makes this regulatory change. Native ecosystems store carbon in woody plants, in the soil’s duff layer and its deeper horizons. Native grassland and forest soils contain 20 to 50 tons of organic carbon per acre in about the top three feet of soil. When land is converted from a natural ecosystem to cropland, 30 to 50 percent of soil carbon is lost to the atmosphere over a 50-year period. Conversion of forests causes larger losses of carbon from woody biomass, especially if the land is burned before being cropped—up to 75 percent of organic carbon is lost in 25 years when a tropical forest is cleared. It also causes disruption of the water cycle that exacerbates climate change. 

Destroying native ecosystems is more than a national issue; it is international. We are in the middle of a 6th mass extinction. In the last 50 years, animal populations worldwide have declined by almost 70%. With this proposed regulation, the NOP can address biodiversity loss and climate change, while maximizing co-benefits. Ecosystems help regulate floods, enhance water quality, reduce soil erosion, and ensure pollination and pest control. Overexploitation of natural resources has led to changes in climate and the biodiversity crisis, and the NOP needs to now be part of the solution.  

The NOSB recommended that the National Organic Program (NOP) add the following definition to §205.200:  

Native Ecosystems: Native ecosystems can be recognized in the field as retaining both dominant and characteristic plant species as described by established classifications of natural vegetation. These will tend to be on lands that have not been previously cultivated, cleared, drained or otherwise irrevocably altered. However, they could include areas that have recovered expected plant species and structure.  

It also recommended that the NOP add the following language to §205.200 General: 

(a) A site supporting a native ecosystem cannot be certified for organic production as provided for under this regulation for a period of 10 years from the date of conversion. 

The recommended regulations allow native ecosystems to be used in organic production, including low-impact grazing, mushrooms, maple syrup production, and other kinds of wild crop harvesting. 

Organic consumers are distressed to learn that the NOP rules incentivize native ecosystem destruction. Organic farmers do not think it is fair that this loophole allows immediate certification, when many have complied with a three-year requirement to transition conventional land.  

The Organic Farming Production Act (OFPA) states that the NOP must ensure standards are consistent throughout. NOP claims that it “conserve(s) biodiversity” and “ecological balance” over 300 different times on its website, while it incentivizes the conversion of native ecosystems to organic production. The NOP is charged with making sure the organic market stays strong, but it is undermining consumer confidence with its inaction.  

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

Thank you. 

In celebration of Earth Day and its sixth 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, so do it again even if you pledged last year) “not use chemicals that harm ladybugs and other beneficial insects on their lawn or garden, and to support 100% organic produce.” 

Even if you've signed the pledge in previous years, please take moment to sign! You do not need to shop at Natural Grocers to sign, but it's a great store to shop at if there's one in your area! 

>>Sign the Ladybug Pledge and support Beyond Pesticides.

April shoppers at Natural Grocers' 166 stores—all in 21 states west of the Mississippi—are also invited to donate to Beyond Pesticides at checkout. Ladybug Love also features in-store promotions.

>>Advertise Your Commitment with a Beyond Pesticides “Pesticide Free Zone” 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 to assist community land managers in transitioning two 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 safer practices. Through this program, Beyond Pesticides has assisted local leaders in converting dozens of parks and recreational areas to organic practices and to eliminate the use of synthetic pesticides and fertilizers. [Contact Beyond Pesticides about converting two parks, as demonstration sites, to organic in your town.] 

Regarding the program, Natural Grocers says,” We have an exciting, long-term partnership with Beyond Pesticides. Part of that partnership includes fundraising campaigns throughout the year, specifically for Earth Day in April and Organic Month in September. Natural Grocers is a longtime leader of the organic movement through its national advocacy efforts. We are proud to partner with Beyond Pesticides to further the critical mission of converting local parks and playing fields to pesticide-free management practices to make them safer for kids and pets to play in.” 

>>Ask your mayor to convert to organic landcare in city parks and other public places.

The targets for this Action are local executives and mayors across U.S cities and townships.

Thank you for your active participation and engagement!

Congress has entrusted the Environmental Protection Agency (EPA) with the responsibility to protect the health and environment of the United States. As yet another report of EPA's Office of Inspector General (OIG)—this one relating to risk assessment for a PFAS chemical—finds that EPA has failed to abide by its own scientific integrity policy, thereby leaving “the public vulnerable to potential negative impacts on human health,” it becomes urgently necessary to insist on accountability for scientific integrity failures at the agency. 

>>Tell Congress and the President to hold accountable political appointees at EPA who fail to uphold scientific integrity.

OIG is an independent branch of EPA that can receive complaints of mismanagement, misconduct, abuse of authority, or censorship, including those related to scientific or research misconduct, without fear of improper influence. Through its statutory mandate, OIG investigates these allegations. It makes recommendations based on findings, which it reports to Congress, but it cannot ensure the personal accountability of those responsible for misconduct. In this case, OIG made recommendations relating to strengthening policies and procedures for dealing with scientific data, disagreements, and integrity, and one recommendation “to strengthen the EPA's culture of scientific integrity, transparency, and accountability of political leadership actions.” EPA disagreed with all five recommendations. If left unresolved, it will be included in OIG's semiannual report to Congress.  

Corruption and lack of scientific integrity are not new issues for EPA. (Other OIG reports also deal with failures of scientific integrity.) Regarding the pesticide program, Public Employees for Environmental Responsibility (PEER) Senior Counsel Peter Jenkins stated, “EPA's Office of Pesticide Programs has bent so far over backwards to accommodate industry desires that it is now beyond chiropractic help – major surgery is required,” noting that while problems within OPP worsened under Trump, they preexisted his term and continue today. “Inside OPP, marginalization of science remains cause for celebration and the result has been repeated ecological and public health disasters,” Mr. Jenkins said.

As indicated in the most recent OIG report, problems often arise when scientific professionals are overruled by political appointees. Political appointees—starting with the EPA Administrator—should be held accountable for actions that disregard scientific findings, putting at risk people and the environment. EPA's failures to take actions recommended by OIG should create a presumption of misconduct of the Administrator and program directors, which should result in initiation of dismissal actions. Congress receives OIG's annual report, which documents such failures and should trigger oversight hearings if those responsible are not held accountable.

The targets for this Action are the U.S. Congress and the Office of the President of the United States. 

Thank you for your active participation and engagement!

>>Tell Congress and the President to hold accountable political appointees at EPA who fail to uphold scientific integrity.

To send a letter to the White House for President Biden, please see the instructions at the bottom of the page to cut/paste into the online White House Contact Us form. We advise taking this step first before clicking submit to move forward with a message to your elected representatives; right-clicking the link will allow for the page to open in a new tab or window.

Letter to U.S. Representative and Senators:

Congress has entrusted the Environmental Protection Agency (EPA) with the responsibility to protect the health and environment of the United States. As yet another report of EPA’s Office of Inspector General (OIG)—this one relating to risk assessment for a PFAS chemical—finds that EPA has failed to abide by its own scientific integrity policy, thereby leaving “the public vulnerable to potential negative impacts on human health,” it becomes urgently necessary to insist on accountability for scientific integrity failures at the agency.

OIG is an independent branch of EPA that can receive complaints of mismanagement, misconduct, abuse of authority, or censorship, including those related to scientific or research misconduct, without fear of improper influence. Through its statutory mandate, OIG investigates these allegations. It makes recommendations based on findings, which it reports to Congress, but it cannot ensure the personal accountability of those responsible for misconduct. In this case, OIG made recommendations relating to strengthening policies and procedures for dealing with scientific data, disagreements, and integrity, and one recommendation “to strengthen the EPA’s culture of scientific integrity, transparency, and accountability of political leadership actions.” EPA disagreed with all five recommendations. If left unresolved, it will be included in OIG’s semiannual report to Congress.

Corruption and lack of scientific integrity are not new issues for EPA. (Other OIG reports also deal with failures of scientific integrity.) Regarding the pesticide program, Public Employees for Environmental Responsibility (PEER) Senior Counsel Peter Jenkins stated, “EPA’s Office of Pesticide Programs has bent so far over backwards to accommodate industry desires that it is now beyond chiropractic help – major surgery is required,” noting that while problems within OPP worsened under Trump, they preexisted his term and continue today. “Inside OPP, marginalization of science remains cause for celebration and the result has been repeated ecological and public health disasters,” Mr. Jenkins said.

As indicated in the most recent OIG report, problems often arise when scientific professionals are overruled by political appointees. Political appointees—starting with the EPA Administrator—should be held accountable for actions that disregard scientific findings, putting at risk people and the environment. EPA’s failures to take actions recommended by OIG should create a presumption of misconduct of the Administrator and program directors, which should result in initiation of dismissal actions. Congress receives OIG’s annual report, which documents such failures and should trigger oversight hearings if those responsible are not held accountable.

Thank you.

***

To send a letter to the White House for President Biden, please cut/paste the following message into the online White House Contact Us form. 

The form will ask for your name (pronouns optional), email, phone number, address information (street, city, state, zip code) and country/state/region. If you would prefer to not receive updates from the White House, please remember to uncheck the blue box at the end of the form before hitting the blue submit button.

Message type: Contact the President

Congress entrusted EPA with the responsibility to protect the health and environment of the United States. As yet another report of EPA's Office of Inspector General (OIG)—this one relating to risk assessment for a PFAS chemical—finds that EPA has failed to abide by its own scientific integrity policy, thereby leaving “the public vulnerable to potential negative impacts on human health,” it is necessary to insist on accountability for scientific integrity failures at the agency.

OIG, an independent branch of EPA, can receive complaints of mismanagement, misconduct, abuse of authority, or censorship, including those related to scientific or research misconduct. Through its statutory mandate, OIG investigates these allegations. It makes recommendations based on findings, which it reports to Congress, but it cannot ensure the personal accountability of those responsible for misconduct. In this case, OIG made recommendations relating to strengthening policies and procedures for dealing with scientific data, disagreements, and integrity, and one recommendation “to strengthen the EPA's culture of scientific integrity, transparency, and accountability of political leadership actions.” EPA disagreed with all five recommendations. If left unresolved, it will be included in OIG's semiannual report to Congress.

Corruption and lack of scientific integrity are not new issues for EPA. Other OIG reports also deal with failures of scientific integrity.

As indicated in the most recent OIG report, problems often arise when scientific professionals are overruled by political appointees. Political appointees—starting with the EPA Administrator—should be held accountable for actions that disregard scientific findings, putting at risk people and the environment. EPA's failures to take actions recommended by OIG should create a presumption of misconduct of the Administrator and program directors, which should result in initiation of dismissal actions.

Thank you.

Contribute your voice to a strong organic! Comments are due 11:59 pm EDT April 5

The National Organic Standards Board (NOSB) is receiving written comments from the public through April 5. April 5 is also the deadline for registering for the upcoming public comment webinar on April 18 and 20, which precedes the online meeting April 25-27—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov. 

As always, there are many important issues on the NOSB agenda this Spring. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong (KOS) and the Spring 2023 issues webpage, where you can find Beyond Pesticides’ comments on all issues facing the NOSB at this meeting.

In the spirit of “continuous improvement,” we urge you to submit comments that contribute to an increasingly improved organic production system. If you have already submitted comments on the key issues we have suggested below, please take a look at our KOS page and pick an issue to comment on.

(You’re welcome to cut-and-paste from the Beyond Pesticides’ comments to the NOSB!)

Here are some high priority issues for us:

Prohibit the Routine Allowance of Ingredients Processed with Ion Exchange. Because the ion exchange process is a chemical process, all organic ingredients processed in this manner must be subject to review by the NOSB. Ion exchange creates synthetic ingredients through chemical change—removing some components and substituting other chemicals—that are used in processed food. It is not simply filtration. Chemicals in the ion exchange resins may leak into the food product. Yet, the Handling Subcommittee of the NOSB is proposing to allow any and all resins without review. To maintain the integrity of the organic label, resins must be subject to full National List (National List of Allowed and Prohibited Substances) review to determine whether these ingredients meet organic standards, rather than establishing a blanket allowance of ion exchange in organic processing. 

Organic Agriculture is Climate-Smart Agriculture. In a draft letter to Secretary of Agriculture Tom Vilsack, the NOSB has written an excellent primer on how organic agriculture responds to the climate emergency. However, the letter needs to stress the need for USDA to dramatically increase support for converting chemical-intensive agriculture to organic. It is critical that the National Organic Program ask, “What more should USDA be doing to advance organic?” As the Board states, the resiliency of organic is established: “Organic is the solution to mitigating climate change and responding to it.” However, despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should require the adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs and abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry. 

Plastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging. 

The NOSB should use the review (or sunset) process to eliminate nonorganic ingredients in processed organic foods. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials. 

Please submit comments here (Regulations.gov)

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

In a move labeled “risk mitigation”—that is, mitigation of the risk to its shareholders—Bayer-Monsanto announced in 2021 that it would phase out Roundup™ products containing glyphosate for the residential lawn and garden market as of January 2023. In taking this action, Bayer-Monsanto is making no admissions, and glyphosate products will still be available to farmers. However, Lowe's and Home Depot are still selling the glyphosate-based lawn and garden products.

>>Tell Lowe's and Home Depot to eliminate Roundup™ and other toxic pesticides, promote organic practices, and sell organic compatible products.

In fact, since this is a voluntary reformulation, and Bayer-Monsanto has decided its own timing, the company cannot be held accountable to anything. The company could change its mind, and stores can continue to sell the glyphosate-based products as long as they want. And keep in mind that replacement versions of Roundup™ products are also toxic. Roundup® Dual Action, for example, contains the following active ingredients: triethylamine salt of triclopyr, fluazipop-P-butyl, diquat dibromide, and ammonium salt of imazapic.

Thus, Bayer/Monsanto announces that it is changing the formulation of Roundup and moving away from glyphosate, while continuing to sell Roundup™ products formulated both with and without glyphosate—leaving consumers unaware of their risks. The U.S. Environmental Protection Agency (EPA) has not taken any meaningful action to restrict glyphosate, and so we continue to see the threats to people and ecosystems associated with the chemical's use. Of course, some of those who have been harmed by Roundup have secured large jury verdicts against Bayer-Monsanto for the harm inflicted and the Supreme Court, in failing to take an appeal from Bayer-Monsanto has upheld those jury verdicts. But glyphosate is the tip of the iceberg in a sea of toxic pesticides that have no place in our society. We know, for instance, that neonicotinoid insecticides have indiscriminately harmed pollinators, birds, and living organisms (terrestrial and aquatic) that are crucial to ecosystems that support life.

So, the alternative is to fiercely advance organic practices and hold responsible corporations to do the same. To do otherwise is to ignore the existential threat that petrochemical pesticides pose to health, biodiversity, and climate.

>>Tell Lowe's and Home Depot to eliminate Roundup™ and other toxic pesticides, promote organic practices, and sell organic compatible products.

Contribute Your Voice to a Strong Organic; Comments are due 1:59 pm EDT April 5

As a means of taking on the challenges of health threats, biodiversity collapse, and the climate emergency, the review and updating of organic standards requires the public involvement in the current public comment period to keep organic strong and continually improving. 

The National Organic Standards Board (NOSB) is receiving written comments from the public through April 5, 2023. This precedes the upcoming public comment webinar on April 18 and 20 and deliberative hearing April 25-27—concerning how organic food is produced. Sign up for a 3-minute comment to let U.S. Department of Agriculture (USDA) know how important organic is at the webinar by April 5. Written comments must be submitted through Regulations.gov by 11:59 pm EDT April 5. Links to the virtual comment webinars will be provided approximately one week prior to the sessions.

The NOSB is responsible for guiding 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 consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2023 Beyond Pesticides’ issues webpage.

Here are some of our high priority issues for the upcoming meeting: 

Prohibit the Routine Allowance of Ingredients Processed with Ion Exchange. Because the ion exchange process is a chemical process, all organic ingredients processed in this manner must be subject to review by the NOSB. Ion exchange creates synthetic ingredients through chemical change—removing some components and substituting other chemicals—that are used in processed food. It is not simply filtration. Chemicals in the ion exchange resins may leak into the food product. Yet, the Handling Subcommittee of the NOSB is proposing to allow any and all resins without review. To maintain the integrity of the organic label, resins must be subject to full National List (National List of Allowed and Prohibited Substances) review to determine whether these ingredients meet organic standards, rather than establishing a blanket allowance of ion exchange in organic processing. 

Organic Agriculture is Climate-Smart Agriculture. In a draft letter to Secretary of Agriculture Tom Vilsack, the NOSB has written an excellent primer on how organic agriculture responds to the climate emergency. However, the letter needs to stress the need for USDA to dramatically increase support for converting chemical-intensive agriculture to organic. It is critical that the National Organic Program ask, “What more should USDA be doing to advance organic?” As the Board states, the resiliency of organic is established: “Organic is the solution to mitigating climate change and responding to it.” However, despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should require the adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs and abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry. 

Plastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging. 

The NOSB should use the review (or sunset) process to eliminate nonorganic ingredients in processed organic foods. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials. 

Please submit comments here (Regulations.gov)

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

The U.S. House of Representatives voted on March 9 to overturn a Biden administration rule expanding the definition of and protections for the “waters of the United States.” The rule, Revised Definition of Waters of the United States, clarifies that thousands of wetlands, smaller streams, and other kinds of waterways are included under the Clean Water Act's protection provisions set to go into effect on March 20. Now, the overturning resolution goes to the Senate and is expected to be taken up very soon; President Biden has said he will exercise his veto power if it reaches his desk. Were his veto overridden, this rollback would put at greater risk the nation's waterways, from all sorts of pollution, including more than 90% of the nation's rivers and streams that are contaminated with five or more pesticides, according to Beyond Pesticides 2020 coverage. (See this Fact Sheet on the rule.) 

The Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers, through the final rule, repeals the previous Trump administration rule scaling back water protections that had been in place during Obama's presidency. Beyond Pesticides wrote in early 2020: “President Obama's WOTUS, aka Clean Water Rule, has provided protections from pesticide runoff and other pollutants to millions of acres of wetlands and thousands of miles of streams... The WOTUS rule was created to provide greater protections from pollution, and to 'bring clarity to decades of political and legal debate over which waters should qualify.' The rule included many smaller waterways and wetlands that function as recharge areas or tributaries to larger water bodies.” 

At the time, Republicans and industry/trade/business groups clamored loudly against the Obama administration's more protective definition of WOTUS. Today, the same is happening with the Biden rule where the same general crew of opponents claim it constitutes regulatory overreach that is “burdensome” to private enterprise, property rights, and — essentially — what they consider their “right” to pollute.  

(Please see the March 17, 2023 Daily News for more information) 

>>Let your U.S. Senators know that you want clean water and that they should uphold the new water rule by voting against legislation to repeal it.

The United Nations has just announced on March 4, 2023, an agreement on a new high seas treaty. The treaty, which must be adopted by member states and then ratified by at least 60 countries to take effect could be a critical development for meeting the UN's COP15 “30 by 30” goal of protecting 30% of the world's land and sea by 2030 to slow and arrest global biodiversity losses.

The treaty represents a step toward implementation of President Biden's “America the Beautiful Initiative” set in 2021, proclaiming “the first-ever national conservation goal” established by a President –a goal of conserving at least 30 percent of U.S. lands and waters by 2030.” However, the U.S. has a poor track record on approval of UN environmental treaties; approval requires a two-thirds majority affirmative vote in the Senate, and failure on that would block a Presidential signature and ratification.

Meanwhile, a report just reissued by an international coalition of scientists led by Boston College's Global Public Health Program and Global Observatory on Planetary Health and the Centre Scientifique de Monaco documents the widespread and growing pollution of the ocean. The full report, “Human Health and Ocean Pollution,” is published in the Annals of Global Health (DOI: 10.5334/aogh.2831). 

>>Tell President Biden to sign the UN high seas treaty. Tell EPA and Congress to protect the ocean from toxic pollution.

Professor Philip Landrigan, M.D., the director of Boston College's Global Public Health Program and the Global Observatory on Planetary Health summarize the importance of actions to protect the oceans, “Simply put: Ocean pollution is a major global problem, it is growing, and it directly affects human health.” The UN treaty recognizes the need to address “biodiversity loss and degradation of ecosystems of the ocean, due to, in particular, climate change impacts on marine ecosystems, such as warming and ocean deoxygenation, as well as ocean acidification, pollution, including plastic pollution, and unsustainable use.” 

The UN treaty will promote the implementation of the United Nations Convention on the Law of the Sea, adopted in 1982, by establishing protected areas on the high seas—that is, the vast portion of the ocean that is outside of national boundaries—and providing for an overhaul of environmental impact assessments for actions affecting the ocean.  

But signing and ratifying the treaty are only the first steps. In order to comply with the treaty, nations must take concrete steps to promote the objectives of the treaty when making decisions under other laws, ensuring “that the activity can be conducted in a manner consistent with the prevention of significant adverse impacts on the marine environment.” As shown by the Global Observatory's report, whose findings are drawn from 584 scientific reports, these impacts include: 

• Pollution of the oceans by plastics, toxic metals, manufactured chemicals, pesticides, sewage, and agricultural runoff that is killing and contaminating the fish that feed 3 billion people. 
• Coastal pollution spreading life-threatening infections.  
• Oil spills and chemical wastes that threaten the microorganisms in the seas that provide much of the world's oxygen supply. 

Action is needed now to stop the ongoing collapse of marine ecosystems. Researchers blame chemical pollution from pesticides, farm fertilizers, and oil spills in the water. 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. The U.S. Environmental Protection Agency's (EPA) 2017 risk assessment for the most widely used neonicotinoid, imidacloprid, found, “[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates.” These surface waters eventually drain into the ocean. 

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. 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. 

Industrial agriculture, supported by EPA's registration of toxic pesticides, results in emissions of climate-changing nitrogen oxides and loss of soil health. It 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 within the power and authority of EPA to reverse the threats to biodiversity and human existence. 

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. Congress, the U.S. Department of State, and the U.S. Mission to the United Nations.

Thank you for your active participation and engagement!

>>Tell President Biden to sign the UN high seas treaty. Tell EPA and Congress to protect the ocean from toxic pollution.

After the Trump EPA was blocked from weakening the application exclusion zone (AEZ) provisions for protecting farmworkers, the rules reverted to the Obama era rules. Now EPA proposes to reaffirm part of that rule, while accepting some of the weakening amendments from the Trump administration. 

>>Tell EPA to strengthen pesticide rules to protect farmworkers. Tell President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

EPA's Worker Protection Standards (WPS) are rules that govern labor safety standards within federal pesticide law (the Federal Insecticide Fungicide and Rodenticide Act, or FIFRA). Farmworkers are not covered for toxic chemical exposure by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), and WPS have long been criticized by farmworker, labor, and health advocates for providing insufficient protections for farmworkers, their children and communities. Under the WPS, AEZs are buffer zones where people are not allowed to enter during the course of a pesticide application. Like all buffer zones, they are designed to allow application of toxic pesticides while providing a nominal degree of protection. Pesticides drift long distances when being applied and they volatilize off of treated areas and then move through air currents. 

Under the proposed regulations, the AEZ would remain the same, while—as proposed by the Trump administration—allowing farm families to remain inside structures within the AEZ and allowing applications to resume after halting because someone was in the AEZ. These proposed rules, while not as egregious as the Trump EPA rule, are a step backwards from the current rule. 

Farmworkers need more protections, not industry-friendly compromises. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. 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. 

Many farmworkers are migrant workers, and are subject to conditions that would not be permitted for U.S. citizens. The U.S. is not a signatory to the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard to treat migrant workers like workers who are citizens.   

The target for this Action are the U.S. Environmental Protection Agency, the U.S. Department of State, and the U.S. Mission to the United Nations. 

Thank you for your active participation and engagement!

>>Tell EPA to strengthen pesticide rules to protect farmworkers. Tell President Biden to sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

California's Department of Pesticide Regulation (DPR) is asking for comments on its “Sustainable Pest Management (SPM) Roadmap” by 5 pm (PST) March 13, 2023. While recognizing problems inherent in traditional integrated pest management (IPM), DPR's roadmap is directing us to a destination that includes another generation of exposure to the worst of the worst pesticides—while failing to embrace the elimination of farm inputs harmful to ecosystems and the capacity of soil biology to cycle nutrients and draw down the maximum amount of atmospheric carbon. The Roadmap's off-handed rejection of organic practices, rather than building on organic systems, creates a lost opportunity for adopting a holistic and serious solution to the current crises of health threats from pesticides, biodiversity collapse, and the climate emergency. 

>>Tell DPR to revise its destination to immediately eliminate the worst pesticides and implement wide scale transition to organic practices.

DPR's Roadmap states these goals: 

• By 2050, eliminate the use of Priority Pesticides by transitioning to SPM. 
• By 2050, SPM will be adopted as the de facto pest management system in California. 

DPR says “The criteria for classifying pesticides as “Priority Pesticides” include, but are not limited to, hazard and risk classifications, availability of effective alternative products or practices, and special consideration of pest management situations that potentially cause severe or widespread adverse impacts. . .. Priority Pesticides are a subset of high-risk pesticides. We define 'high risk' pesticides as active ingredients that are highly hazardous and/or formulations or uses that pose a likelihood of, or are known to cause, significant or widespread human and/or ecological impacts from their use.”

To set as a goal elimination of these pesticides—by definition the worst of the worst—by 2050 is to accept another generation of their use. This is another generation of using “groundwater contaminants, toxic air contaminants, and restricted products as well as carcinogens, endocrine disruptors, reproductive and developmental toxicants, and environmental toxicants, such as those toxic to pollinators, mammals, birds, and fish.” A roadmap to this destination is clearly inadequate because the destination does not fully address the existential threats we are facing, in significant part created by petrochemical pesticide and fertilizer use. 

The second goal is the adoption of SPM as the de facto pest management system in California. Integrated Pest Management (IPM) is a 60-year-old approach to agricultural practice that, when first conceived and implemented, had among its goals a significant reduction of synthetic pesticide use, and the health, environmental, and ecosystemic benefits that would flow from that. However, as a study published in 2021 concluded, IPM has overall been unsuccessful in achieving those goals. DPR recognizes shortcomings of IPM, but its substitute, SPM, does not address the crucial deficiencies of IPM. 

DPR describes SPM as “a holistic, whole-system approach applicable in agricultural and other managed ecosystems and urban and rural communities that builds on the concept of integrated pest management (IPM) to include the wider context of the three sustainability pillars: human health and social equity, environmental protection, and economic vitality.” This “evolution of the IPM concept,” however, does not address the key deficiency of IPM—defining the conditions under which pesticide use is “necessary” or warranted.  

In addition, SPM shows no signs of being rooted in the health of soil and people. Organic agriculture, on the other hand, is a systems approach to building healthy soils, plants, and animals, in which “pests” become minor factors. The result is healthy people and a healthy ecosystem. Similarly, strong IPM in urban systems focuses on building healthy systems that prevent pest problems. Both organic agriculture and strong, defined IPM seek to eliminate all toxic chemicals, while working with and respecting nature. 

The Organic Trade Association reports that organic sales now exceed $63 billion per year, and the U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $11.2 billion worth of organic food on 4.9 million acres in 2021. California has long been a leader in organic production. DPR must immediately undertake a comprehensive effort to transition California agriculture to organic. Similarly, the explosive growth in organic parks and least-toxic building management shows that a slow, piecemeal transition will unnecessarily expose a whole generation of Californians to highly toxic chemicals. 

The target for this Action is the California Department of Pesticide Regulation.

Thank you for your active participation and engagement!

>>Tell DPR to revise its destination to immediately eliminate the worst pesticides and implement wide scale transition to organic practices.

The recent train derailment in East Palestine, Ohio, should be a reminder to all of us that problems with our reliance on toxic chemicals go beyond broadcasting them on fields. In order to get pesticides to their point of use, toxic precursors and active ingredients must be transported. Toxic waste products are also delivered to a location where they may be burned or deposited in a landfill. In weighing the hazards of toxic pesticides, these ancillary hazards should also be considered.

>>Tell EPA and Congress that all impacts of toxic chemicals—from cradle to grave—must be considered before allowing their use.

The freight train that derailed February 3, 2023, in East Palestine was carrying a number of toxic chemicals. EPA notified the railroad, “EPA has spent, or is considering spending, public funds to investigate and control releases of hazardous substances or potential releases of hazardous substances at the Site. Based on information presently available to EPA, EPA has determined that Norfolk Southern Railway Company (Norfolk Southern or “you”) may be responsible under CERCLA [Comprehensive Environmental Response, Compensation, and Liability Act–Superfund] for cleanup of the Site or costs EPA has incurred in cleaning up the Site.” 

But what are the toxic chemicals, and why were they being transported?

As of February 10, EPA says, “[V]inyl chloride, butyl acrylate, ethylhexyl acrylate, and ethylene glycol monobutyl ether are known to have been and continue to be released to the air, surface soils, and surface waters.”

The toxic chemicals on the train included vinyl chloride, ethylhexyl acrylate, butyl acrylate, isobutylene, and ethylene glycol monobutyl ether (EGBE). The first four are all precursors in plastic manufacture. All except butyl acrylate are pesticide “inert” ingredients, and EGBE is an antimicrobial active ingredient as well. So, the manufacture of pesticides and plastics requires that toxic chemicals be transported.

Looking a little deeper, vinyl chloride has justly received prominence in news reports. Vinyl chloride is a highly flammable chlorinated hydrocarbon that may emit toxic fumes of carbon dioxide, carbon monoxide, hydrogen chloride and phosgene when heated to decomposition. Although it is a gas under normal conditions, it is shipped under pressure as a liquid. Exposure affects the nervous system and causes liver damage. Prolonged exposure can result in joint and muscle pain and skin damage. Vinyl chloride is a known human carcinogen that is associated with liver cancer, brain and lung cancer, and cancers of the lymphatic and hematopoietic system. Phosgene itself is a major industrial chemical used to make plastics and pesticides. It can damage the skin, eyes, nose, throat, and lungs and has been used as a chemical warfare agent. Exposure to hydrogen chloride can cause serious respiratory damage (depending on the amount of exposure), as well as irritation or burns to eyes or skin.

Ethylhexyl acrylate is highly irritating to the eyes, skin, and respiratory tract. It can cause corneal lesions, and breathing high concentrations of the vapors can lead to pulmonary edema. IARC classifies it in Group 2B, possibly carcinogenic to humans. Butyl acrylate is irritating to the eyes, skin, and respiratory tract. Inhalation can result in toxic pneumonitis. The International Agency for Research on Cancer (IARC) puts it in Group 3, not classifiable for carcinogenicity to humans. Isobutylene is a neurotoxin and asphyxiant. EGBE is neurotoxic. It causes damage to the liver and kidneys. Exposure can result in hemolytic anemia and damage to the reproductive system. IARC puts it in Group 3, not classifiable for carcinogenicity to humans.

All these toxic chemicals are being transported over roads and rails that run through the most densely populated parts of the country. According to the Federal Rail Administration, at least one train derails every day in the United States, and reports have warned of risks of similar accidents across the country. Although trains are considered the safest way to transport hazardous materials, train accidents resulted in releases of hazardous chemicals 11 times in 2022, down from 20 times in 2018 and 2020. Although hazardous materials account for only 7-8% of the 30 million shipments delivered by rail every year, at least a couple cars of hazardous materials can be found on most trains. The train that derailed in East Palestine, for example, also carried medical cotton balls, automobiles, and frozen vegetables.

• The worst railroad disaster in recent history occurred in 2013 when the brakes failed on an unattended train carrying 72 tankers of petroleum crude oil, which ended its 65-mph descent into the Canadian town of Lac-Mégantic by derailing and erupting in flames. Most of the town's downtown core, including dozens of homes, was destroyed. Forty-seven people died, and 26,000 gallons of oil seeped into nearby Chaudière River. Soil and structures took years to clean up.
   
• In 2013, just outside the town of Casselton, ND, a crude oil train collided with several cars from a grain train that had derailed, sending fireballs into the air. Residents were saved by the fact that the collision occurred outside of town.
   
• In 2005, nine people died and more than 250 were injured in Graniteville, SC, when a train carrying chlorine gas ran into a sidelined train due to a misplaced switch.
   
• In 1991, California's worst hazardous chemical spill resulted from a train derailment just outside of Dunsmuir as the train was crossing the Sacramento River near Mt. Shasta. About 19,000 gallons of metam sodium, a highly toxic pesticide still used as a fungicide and herbicide, flowed into the river. Residents of the town of Dunsmuir were evacuated. The chemical killed fish, other aquatic organisms, and plants in the river and seeped into the soil, contaminating the shallow ground water aquifers. Wildlife was affected by the contamination of their water supply and by the gases in the air.

The examples above are a small sample of transportation accidents that released toxic chemicals, killing people and contaminating the environment. In assessing blame, attention is typically focused on those running the trains (or ships or trucks). But why are those toxic chemicals being transported through cities, towns, and sensitive environments? They are on their way to be turned into products. 

When those products are pesticides—also toxic chemicals that will be transported to the sites where they will be used—EPA, as the agency responsible for allowing pesticides to be used, must, but does not, take into account the potential for death and destruction from transportation accidents. In applying the legal standard of the Federal Insecticide, Fungicide, and Rodenticide Act—of no unreasonable adverse effects—EPA must look at those adverse effects from manufacture to disposal, from cradle to grave, and weigh them against measured “benefits” of using the pesticides, given the availability of safer alternative practices and products.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.

Thank you for your active participation and engagement!

Tell EPA and Congress that all impacts of toxic chemicals—from cradle to grave—must be considered before allowing their use.

U.S. Senator Cory Booker (D-N.J.) reintroduced legislation February 2 to increase protections against exposure to toxic pesticides. The Protect America's Children from Toxic Pesticides Act of 2023 (PACTPA), S.269, addresses many of the controversial issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S. This major reform legislation tackles some of the documented deficiencies in the regulation of pesticides and removes a number of loopholes in the law. The legislation, introduced with Senators Kirsten Gillibrand (D-NY), Bernie Sanders (D-VT), Elizabeth Warren (D-MA) and Brian Schatz (D-HI), also includes a ban on all organophosphate and neonicotinoid insecticides, as well as the weed killer paraquat, which is known to cause Parkinson's disease and lung fibrosis.  

Despite these reform provisions, the legislation does not touch the core of FIFRA's pesticide registration process and chart a path for the systemic, transformative change that Beyond Pesticides says is essential to meet the existential challenges of current times—devastating health threats, biodiversity collapse, and the climate crisis.  

>>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 (PACTPA), S.269, would provide some desperately needed improvements to FIFRA to better protect people and the environment, including: 

• 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. 
• 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. 
• 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. 

At a time of increasing public health threats, biodiversity collapse, and climate crisis, it is critical to advance legislation that is truly protective of health and the environment. As the widespread success of natural, organic land care practices has shown, toxic pesticides are not needed to maintain agricultural productivity, beautiful landscapes, or quality of life. 

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: 

• 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. 
• Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration). 
   
• Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects. 
   
• Deny and cancel registrations of all pesticides posing a threat to life in the soil—and hence threatening the climate. 
   
• Deny and cancel registrations of all pesticides posing a threat to any endangered species. 

The targets for this Action are co-sponsors of Protect America's Children from Toxic Pesticides Act (PACTPA), S.269, and members of the U.S. Senate.

Thank you for your active participation and engagement!

>>Urge your Senators to co-sponsor PACTPA and reforms to the toxic core of FIFRA.

During Black History Month, it is of note that on January 10, the Biden-Harris Environmental Protection Agency (EPA) announced funding of approximately $100 million for “projects that advance environmental justice in underserved and overburdened communities across the country” through its Environmental Justice Government-to-Government (EJG2G) program. While viewed as assistance for those communities “disproportionately impacted by pollution and climate change,” it is important to recognize that the same communities are also disproportionately impacted by activities that produce pollution and climate change.  

>>Tell EPA, Governors (Mayor in DC), and Congress to support environmental justice by eliminating activities leading to pollution and climate change.

EPA must reverse its 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. 

On the community level addressed by this funding project, EPA could assist communities to transition to organic land management. The EJG2G program must assist communities to manage local parks, playing fields, and greenways without unnecessary toxic pesticides.  

But EPA's assistance must go beyond funding. EPA's pesticide registration decisions promote contamination of communities where pesticides are manufactured, stored, used, and disposed of. By ignoring impacts of pesticides on soil health, EPA's pesticide registration decisions promote the climate crisis. EPA's pesticide program must incorporate in all of its registration decisions an analysis of impact on the climate crisis, with particular attention to the protection of soil health. 

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 EPA, while study after study documents the disproportionate level of illness among farmworkers. EPA must eliminate systemic racism in its pesticide program. 

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. State Governors, the Mayor of D.C., and the U.S. Congress.

Thank you for your active participation and engagement!

>>Tell EPA, Governors (Mayor in DC), and Congress to support environmental justice by eliminating activities leading to pollution and climate change.

Because antibiotics and fungicides are widely used in agriculture (except organic), they contribute significantly to the increasing efficacy problems with antimicrobial (antibiotic and antifungal medicines) use in health care, contributing to a growing crisis. According to Tedros Adhanom Ghebreyesus, PhD, World Health Organization Director-General, “Antimicrobial resistance undermines modern medicine and puts millions of lives at risk.”  Microorganisms—including bacteria, fungi, and viruses—are notoriously quick to evolve resistance to antimicrobial medicines. We know that selection for resistance is directly related to the frequency and intensity of antimicrobial use, so medical practitioners try to avoid using those medicines unless they are necessary.  

>>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.

Unfortunately, the medical profession lacks complete control over the use of antimicrobials. Many of the same chemicals used in human medicine are also used in agriculture. These may show up in or on treated food, but can also spread antimicrobial resistance through horizontal gene transfer. So, in addition to ingesting antibiotics in our food, the movement of resistance bacteria and fungi in the environment contribute to this escalating crisis. 

Oral arguments began last week in a lawsuit challenging the U.S. Environmental Protection Agency's (EPA) approval of the antibiotic streptomycin as a pesticide on citrus crops. Brought forth by a coalition of farmworker, health, and environmental groups, the lawsuit aims to stop the use of a critical medical treatment for agricultural purposes. Beyond Pesticides executive director Jay Feldman commented on the filing of the lawsuit: “It is past time to take urgent action to transition away from practices in agriculture that are dependent on antibiotics, advance organic farm management, and avoid new deadly pandemics. This lawsuit is an important action to reverse the previous administration's decision to ignore the science and allow expanded use of an antibiotic in agriculture.” 

Not all antimicrobial pesticides are registered for their antimicrobial action. For example, the herbicides glyphosate, 2,4-D, and dicamba are able to create resistance in Salmonella and E. coli. From another health perspective, antimicrobial pesticides may negatively affect the gut microbiome, which is essential for human nutrition and immune system function. EPA must cease registration of pesticides with antimicrobial effects (or potential antimicrobial effects) in human pathogens or beneficial human microbiota. 

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.

Thank you for your active participation and engagement!

>>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.

There is no doubt that the climate crisis is upon us. And the consequences are undeniably grave. So, we must incorporate our understanding of the grave health and environmental effects into the deliberations on all policy decisions regarding petrochemical pesticide registrations and synthetic fertilizer use in agriculture and nonagricultural land management. Of critical importance, in this context, is the effect of policy decisions on soil health—in particular, soil organic carbon, which sequesters atmospheric carbon and reduces its damaging atmospheric effects. 

>>Tell USDA, EPA, and Congress to incorporate in ALL its policy decisions an analysis of impact on the climate crisis, with particular attention to the protection of soil health.

Although the soil is commonly recognized as a sink for atmospheric carbon, there is a false narrative that says carbon can be sequestered in the soil through chemical-intensive no-till agriculture. Now the Rodale Institute's 40-Year Report on their “Farming Systems Trial” should end the myth of the toxic, petrochemical-based, GMO-herbicide, no-till systems. Rodale's scientific trials clearly show that these degenerative no-till systems are inferior to Regenerative Organic Agriculture on every key criterion.  

The highest yields of corn in the tilled organic manure system and the best increases in soil organic carbon were produced with an organic manure system and limited tillage (tilled every other year). Of importance to climate resilience, organic corn yields have been 31 percent higher than conventional/industrial farming systems in drought years. 

The trials show that herbicide no-till systems do not produce higher levels of soil organic carbon (SOC) than tillage systems. This result is consistent with reviews of 194 studies comparing no-till and tilled fields.  

According to Andre Leu, international director at Regeneration International, “The main reason for the loss of soil carbon in farming systems is not tillage; it is synthetic nitrogen fertilizers. Research shows that there is a direct link between the application of synthetic nitrogenous fertilizers and a decline in soil carbon.” In addition, those same nitrogenous fertilizers act as potent greenhouse gases when volatilized to the atmosphere. 

Thus, chemical-intensive agriculture and nonagricultural land management contribute to climate change in multiple ways. If we are to be serious about combating climate change and mitigating its impacts, all agencies must consider climate impacts when making decisions. This means that the U.S. Environmental Protection Agency (EPA) must not approve registrations of pesticides that harm the soil or facilitate agricultural practices that interfere with carbon sequestration. It means that the U.S. Department of Agriculture (USDA), in a much more aggressive way, must lead the transition to organic agriculture as a replacement for chemical-intensive practices and should cease all support for chemical-intensive agriculture immediately. It means that the Department of Interior (DOI) must manage all public lands with organic practices that ensure soil health and all that means for a livable future. 

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. Department of Agriculture, and the U.S. Congress.

***According to our partners at EveryAction, the contact information for members of Congress is in the process of being updated as the new members had not been formally seated prior to the confirmation of the House Speaker. Unfortunately, the delayed transition may impact targets for this Action and we appreciate your continued activism.  

Thank you for your active participation and engagement!

>>Tell USDA, EPA, and Congress to incorporate in ALL its policy decisions an analysis of impact on the climate crisis, with particular attention to the protection of soil health.

One of the world's most successful conservation laws—the U.S. Endangered Species Act (ESA)—was enacted in 1973. Since then, it has saved countless imperiled species from extinction, put hundreds more on the road to recovery, and has enabled the preservation of habitats that support all of us. Thanks to the Endangered Species Act, the humpback whale, bald eagle, and snail darter are still with us. The ESA is our most powerful tool to combat the extinction crisis and stem the loss of biodiversity currently facing our country and the global community. However, decades of underfunding have kept it from realizing its full potential.

>>Tell the Biden Administration and Congress to provide adequate funding for the Endangered Species Act.

The Biden Administration must significantly increase its budget request for endangered species in FY24. A budget of $841 million for the U.S. Fish and Wildlife Service (FWS) is needed to fully implement the Endangered Species Act. Currently, FWS only receives around 50% of the funding required to properly implement the Act. The money is needed to support the following activities. 

Listing: FWS needs at least $66.3 million, or an increase of at least $11.3 million per year for at least the next four years, to process the backlog of nearly 200 species awaiting review. Underfunding for the listing program has resulted in many animals and plants waiting over a decade to receive safeguards, with devastating consequences. Nearly 50 unlisted species have been declared extinct while waiting for protections because of these funding shortfalls. This is unacceptable. 

Recovery: The FWS recovery program needs $467.9 million to support recovery planning, implementation, and recovery progress tracking. FWS desperately needs additional funding to help stabilize and save the most critically endangered species and ensure that all listed species receive a minimum amount of funding for their recovery. 

Planning and Consultation: $179.3 million is required for planning and consultation to be maximally effective and efficient. This includes funding for standard consultations, pesticide consultations; “ECOSphere” development; voluntary conservation; and basic compliance monitoring that does not currently exist. 

Conservation and Restoration: $10.15 million is needed to help conserve species—such as the Monarch butterfly—by improving their habitat and removing threats before they need to be listed.  

Cooperative Endangered Species Conservation: $117.7 million is required to close the gap from previous funding shortfalls and match the current need for state and private lands conservation. 

The targets for this action are the Biden administration, the U.S. Department of the Interior, the U.S. Fish and Wildlife Service, and the U.S. Congress.

***According to our partners at EveryAction, the contact information for members of Congress is in the process of being updated as the new members had not been formally seated prior to the confirmation of the House Speaker. Unfortunately, the delayed transition may impact targets for this Action and we appreciate your continued activism under the circumstances.  

Thank you for your active participation and engagement!

>>Tell the Biden Administration and Congress to provide adequate funding for the Endangered Species Act.

The Biden EPA still needs a new vision in order to meet the existential crises in public health, climate change, and biodiversity. The Trump Environmental Protection Agency (EPA) reversed in four years much of the progress made by the EPA in decades. Despite a broad new perspective embodied in President Biden's Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office, the Biden EPA has not adopted a new direction for regulating pesticides.  

>>Tell the Biden administration, EPA, and Congress to adopt a new direction for pesticide regulation. 

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

In order for EPA to live up to the vision embodied in the EM, the agency must make systemic changes that incorporate the new direction into every decision. Those systemic changes include:

Challenge so-called “benefits” of pesticides. 
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. Claimed “benefits” for toxic pesticides need to be judged in comparison to organic production, which is able to produce all types of food and feed. The Organic Trade Association reports that organic sales now exceed $63 billion per year, and the U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $11.2 billion worth of organic food on 4.9 million acres in 2021. EPA assumes benefits, rather than measuring them, and does not take into account the development of resistance in target insects or plants. 

Protect pollinators. 
Agriculture relies on insect pollinators to facilitate fertilization and maintain annual crop yield. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet, many agricultural pesticides are killing pollinators outright, making them more susceptible to parasites and disease, and destroying their habitat. Pollinator protection should be a priority of EPA.

Protect workers. 
Farmworkers are at greatest risk from pesticide exposure. A blatant example of systemic racism is imbedded in risk assessments in environmental regulation. In deciding on “acceptable” risks, 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 in fenceline communities, farmworkers, and factory workers. 

Protect biodiversity. 
Roughly a quarter of the global insect population has been wiped out since 1990, according to research published in the journal Science. Monarchs are near extinction and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies, the foundation of so many food chains, and fireflies, the foundation of so many childhood summer memories, for reasons that can be prevented with leadership in regulating pesticides. It is likely that the declines we are seeing in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, has been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. Amphibians are also particularly at risk. 

As if the loss of biodiversity was not bad enough in itself, it combines with the other existential threats to amplify the impacts. A study in the journal Nature finds that, “The interaction between indices of historical climate warming and intensive agricultural land use is associated with reductions of almost 50% in the abundance and 27% in the number of species within insect assemblages relative to those in less-disturbed habitats with lower rates of historical climate warming.” And a study in Environmental Health Perspectives finds that resulting from the loss of pollinators, “3%–5% of fruit, vegetable, and nut production is lost due to inadequate pollination, leading to an estimated 427,000 (95% uncertainty interval: 86,000-691,000) excess deaths annually from lost healthy food consumption and associated diseases.” That study also finds the economic value of crops to be “12%–31% lower than if pollinators were abundant.” EPA does not factor these impacts into its cost-benefit analysis. 

Get rid of endocrine-disrupting pesticides. 
Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson's, Alzheimer's, and childhood and adult cancers. In 1998, 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) has made little progress in reviewing and regulating endocrine-disrupting pesticides.  Now the program has stalled entirely. 

To ensure appropriate follow-through, Congress gave EPA a timeline 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. According to EPA, Tier 1 Screening (which looks at high exposure chemicals) is not sufficient to implicate a chemical as an endocrine disrupting chemical. It is instead a step to define which chemicals must undergo Tier 2 testing – the only stage that can influence regulatory decision making. 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. Only those registrations supported by testing showing a lack of endocrine-disrupting effects should be approved or allowed to continue. 

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

The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child's neurological, respiratory, immune, and endocrine 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. The American Academy of Pediatrics wrote, “Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.” 

Action taken by this administration to ban food uses of the extremely neurotoxic insecticide chlorpyrifos is an important first step in eliminating neurotoxic pesticides, but a small one. Even the uses of chlorpyrifos that remain allow continued exposure to workers and children. In addition, many other neurotoxic pesticides continue to be used and threaten public health. 

The targets for this action are the Biden administration (including the Council on Environmental Quality), the U.S. Environmental Protection Agency, and the U.S. Congress.

***According to our partners at EveryAction, the contact information for members of Congress is in the process of being updated as the new members had not been formally seated prior to the confirmation of the House Speaker. Unfortunately, the delayed transition may impact targets for this Action and we appreciate your continued activism under the circumstances.  

Thank you for your active participation and engagement; it continues to make an incredible difference in the work that we do!

>>Tell the Biden administration, EPA, and Congress to adopt a new direction for pesticide regulation. 

The California Department of Pesticide Regulation (DPR) announced new rules that remove existing limits on the use of 1,3-dichloropropene (1,3-D or Telone), allowing Californians to breathe much more 1,3-D than some state toxicologists say is safe and highlighting the dangers to which farmworkers are routinely exposed. It is outrageous that the Environmental Protection Agency (EPA) would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices. While the state of California describes its action as increasing protection, advocates point to continued use, unacceptable harm, and the availability of alternative organic agricultural production methods that eliminate the use of 1,3-D. Since over a third of the country's vegetables and three-quarters of the country's fruits and nuts are grown in California, most people who buy their food in a grocery store have a stake in how food is grown in the state and the impact that it has on those who live and work there. 

>>Tell EPA, Congress, and the state of California to cancel the registration of all toxic soil fumigants and encourage organic alternatives. 

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health's PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.  

These and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment and should be banned. 

Consider the effects that food grown in chemical-intensive agriculture have on workers, communities, and the environment by checking out Eating with a Conscience. 

>>Tell EPA, Congress, and the state of California to cancel the registration of all toxic soil fumigants and encourage organic alternatives.