(Beyond Pesticides, November 3, 2015) The U.S. Environmental Protection Agency (EPA) is proposing to revoke all food tolerances for the organophosphate insecticide chlorpyrifos (also known as Dursban), a neurotoxic pesticide produced by Dow AgroSciences that poses particular risks to children and farmworkers. If EPA’s rule is finalized, chlorpyrifos would be effectively eliminated from use in agriculture 15 years after consumer uses were discontinued. However, other non-food uses, including golf courses, turf, green house and mosquito control are not affected by this decision and will remain.
EPA’s proposed rule came on the day of a court-ordered deadline from the U.S. Court of Appeals Judge for the Ninth Circuit, M. Margaret McKeown. In August of this year, Judge McKeown ordered EPA to respond to a petition filed by Pesticide Action Network North America and the Natural Resources Defense Council nearly nine years ago. The lawsuit called on the agency to ban all uses of the insecticide in light of scientific evidence and public comments ignored by the agency after its cumulative risk assessment for organophosphate insecticides.
In 2012, EPA imposed “no-spray” buffer zones around public spaces, including recreational areas, schools, and homes to reduce bystander exposure risks. Earlier this year, the agency updated its 2011 preliminary human health risk assessment for chlorpyrifos, a report that was widely criticized by health and environmental groups. The update identified significant risks to children, farmworkers, and drinking water as a result of the chemical’s use.
Chlorpyrifos is highly neurotoxic. It is a cholinesterase inhibitor, which means that it can bind irreversibly to acetylcholine esterase (AchE), an essential enzyme for normal nerve impulse transmission, inactivating the enzyme. Studies have documented that exposure to even low levels of organophosphates like chlorpyrifos during pregnancy can impair learning, change brain function, and alter thyroid levels of offspring into adulthood. The evidence of the neurotoxic dangers associated with chlorpyrifos’ exposure is extensive and consistent. See the Pesticide Induced-Disease Database (PIDD) for more information.
While EPA had requested the Judge give the agency until April 15, 2016 to revoke food tolerances for chlorpyrifos, the court rejected this timeline, ordering EPA to deny the petition or issue a revocation rule by October 31, 2015. EPA indicates it is proposing the rule rather than issuing a final rule in order to provide for public comment, and the agency indicates it will release its final rule in December 2016.
EPA’s decision to revoke food tolerances for chlorpyrifos was based upon aggregate risk calculated under the Federal Food, Drug, and Cosmetic Act (FFDCA). The law requires the agency to consider all sources of exposure to a certain chemical. Though EPA asserted that food exposure was not of concern, when aggregated with potential exposure through drinking water, safety standards were exceeded in certain watersheds where chlorpyrifos is heavily used.
This outcome is similar to the decision handed down on another neurotoxic pesticide produced by Dow AgroScience, sulfuryl fluoride. In 2006, Beyond Pesticides, Environmental Working Group, and Fluoride Action Network petitioned EPA to cancel food tolerances for the pesticide. The agency found that when residues on food products are combined with fluoridated drinking water and toothpaste, aggregate exposure levels were too high. In 2011, EPA announced plans to phase-out the use of sulfuryl fluoride with the intent of eliminating its use by 2014. However, in 2015, a backdoor amendment to the Agriculture Act of 2014 (Farm Bill) made behind closed doors at the last minute barred EPA from considering the risks of fluoride exposure in drinking water. This action effectively allowed sulfuryl fluoride to remain on the market despite the tangible risks the chemical still poses to children’s health. Thus, while celebrating this victory, health and environmental advocates must remain vigilant of Dow’s ability to lobby Congress to protect its profits over health.
Chlorpyrifos leads a list of numerous toxic chemicals that are central to chemical-intensive agricultural practices that threaten human health and the environment. Although eliminating its use in agriculture is important, the delay in removing the remaining uses of this well-researched and highly toxic chemical reflects the dysfunction of the pesticide regulatory process. Ultimately the widespread adoption of organic management is necessary to protect consumers and the environment in the long-term. Beyond Pesticides has long sought a broad-scale marketplace transition to organic practices that disallows the use of toxic synthetic pesticides by law and encourages a systems-based approach that is protective of health and the environment. This approach never allows the use of highly toxic synthetic pesticides, let alone organophosphates such as chlorpyrifos, and advances a viable, scalable path forward for growing food.
EPA will open and accept public comments for 60 days at regulations.gov (docket number EPA-HQ-OPP-2015-0653).
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
Source: Environmental Protection Agency