Action of the Week Archive

As a new administration is preparing to take office, the nation and world face existential crises that require urgent action. Human actions are contributing to an ongoing Holocene or sixth mass extinction, as well as crises in human disease and climate change. Humans and the biosphere will suffer if President-elect Trump's new Administrator of the Environmental Protection Agency (EPA) follows a course destructive of EPA's mission. Although some have called the environmental record of Mr. Trump's nominee Lee Zeldin “mixed,” citing his past acknowledgment that climate change is real and support for regulating PFAS, he has shown his loyalty by supporting the former president through his first impeachment trial and challenges to the 2020 election results.  

>> Tell your U.S. Senators, under their responsibility to provide “advice and consent” for presidential appointments, to fully vet Lee Zeldin—for the position of EPA Administrator—on his understanding of the current existential environmental crises and the mission of EPA.

According to Mother Jones magazine, “By tapping former New York Rep. Lee Zeldin to head the Environmental Protection Agency, President-elect Donald Trump opted to put his planned radical rollback of climate policy in the hands of a staunch ally who is skilled at projecting an image of a moderate conservationist.” 

Climate change is a real crisis and requires serious action. It is one of multiple crises that are compounding one another. Of course, our continued reliance on petrochemical pesticides and fertilizers is a major contributor to the release of greenhouse gases and the failure to reverse the threat through atmospheric carbon sequestration in healthy soils. While climate change may be most apparent—128 degrees F in Death Valley, heat waves in India, the U.S., and globally, the earliest Category 5 hurricane on record, another wildfire season, etc.—we are also facing crises in human disease and biodiversity collapse. Heat makes the health effects of pesticides more serious. Climate change is intensifying the impacts of habitat destruction and toxic chemicals on biodiversity. The urgency to act is made more apparent every day. 

Both Mr. Trump and Mr. Zeldin have made clear that the mission of the new EPA Administrator is to enact “deregulatory decisions that will be enacted in a way to unleash the power of American businesses.” Of course, businesses and the environment can coexist if industry adapts to the need for practices and products that are compatible with a healthy environment. In contrast, the stated mission of EPA is “to protect human health and the environment.”  

EPA states that its purpose is to ensure that:  

• Americans have clean air, land, and water; 
• National efforts to reduce environmental risks are based on the best available scientific information; 
• Federal laws protecting human health and the environment are administered and enforced fairly, effectively and as Congress intended; 
• Environmental stewardship is integral to U.S. policies concerning natural resources, human health, economic growth, energy, transportation, agriculture, industry, and international trade, and these factors are similarly considered in establishing environmental policy; 
• All parts of society—communities, individuals, businesses, and state, local and tribal governments—have access to accurate information sufficient to effectively participate in managing human health and environmental risks; 
• Contaminated lands and toxic sites are cleaned up by potentially responsible parties and revitalized; and 
• Chemicals in the marketplace are reviewed for safety. 

Unless Mr. Trump is successful in evading the U.S. Senate confirmation hearing process, Senators will have an opportunity to probe the nominee's knowledge of environmental crises and how his deregulatory mission aligns with the mission of protecting human health and the environment. 

Senate confirmation hearings must shine a light on the policies of the new administration and the science (or lack thereof) behind them. How does Mr. Zeldin's support of profligate energy use and petroleum-based industries further EPA's mission to protect public health, in view of their numerous adverse existential impacts on human health, biodiversity, and climate? How does he intend to ensure that Americans have clean air, land, and water, while pursuing a deregulatory agenda? How will he guarantee that EPA acts on the best independent science? How will EPA limit use of chemicals to those that are thoroughly reviewed for possible impacts on human health, biodiversity, and climate? 

>> Tell your U.S. Senators, under their responsibility to provide “advice and consent” for presidential appointments, to fully vet Lee Zeldin—for the position of EPA Administrator—on his understanding of the current existential environmental crises and the mission of EPA. 

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

Thank you for your active participation! The Action is a multi-step process, so please click submit on the form to proceed to step two, where you will be able to personalize comments before final submission. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our text if editing.

Letter to U.S. Senators:

I am writing to ask you to use the confirmation hearing of President-elect Trump’s nominee for Administrator of the Environmental Protection Agency (EPA) to shine a light on the environmental plans of the new administration. It is critical that you exercise your responsibility to provide advice and consent for all presidential appointments, especially those that have a dramatic impact on the health and well-being of the people of our state and nation. Do not permit the circumvention of Senate confirmation hearings, which, as Alexander Hamilton wrote in the Federalist Papers, act as a safeguard against the appointment of “unfit” officials. 

The nation and world face existential crises that require urgent action. Human actions are contributing to an ongoing sixth mass extinction, as well as crises in human disease and climate change. We cannot politicize science that informs public policy intended to protect public health and the environment. Although some have called the environmental record of President-elect Trump’s nominee Lee Zeldin “mixed,” citing his past acknowledgment that climate change is real and support for regulating PFAS (or per- and poly-fluoroalkyl substances known as “forever chemicals”), the EPA Administrator must exercise a first loyalty to the mission of the agency and health of the environment that sustains our lives.  

Both President-elect Trump and Mr. Zeldin have made clear that the mission of the new EPA Administrator is to enact “deregulatory decisions that will be enacted in a way to unleash the power of American businesses.” In contrast, the stated mission of EPA is “to protect human health and the environment.” Both can be achieved as industry adapts to the need for practices and products that are compatible with a healthy environment. EPA’s mission has been clearly nonpartisan and focused on the health of everyone and future generations.  

EPA states that it works to ensure that:  

*Americans have clean air, land, and water; 

*National efforts to reduce environmental risks are based on the best available scientific information; 

*Federal laws protecting human health and the environment are administered and enforced fairly, effectively, and as Congress intended; 

*Environmental stewardship is integral to U.S. policies concerning natural resources, human health, economic growth, energy, transportation, agriculture, industry, and international trade, and these factors are similarly considered in establishing environmental policy; 

*All parts of society--communities, individuals, businesses, and state, local, and tribal governments--have access to accurate information sufficient to effectively participate in managing human health and environmental risks; 

*Contaminated lands and toxic sites are cleaned up by potentially responsible parties and revitalized; and 

*Chemicals in the marketplace are reviewed for safety. 

Senate confirmation hearings must shine a light on the policies of the new administration and the science behind them. How can Mr. Zeldin’s address energy use and petroleum-based industries within the context of EPA’s mission to protect public health, recognizing the existential crises, identified by independent scientific analyses, that threaten human health, biodiversity, and climate stability? How does he intend to ensure that Americans have clean air, land, and water while pursuing a deregulatory agenda? How will he guarantee that EPA acts on the best independent science? How will EPA limit use of chemicals to those that are thoroughly reviewed for possible impacts on human health, biodiversity, and climate? 

Thank you for your consideration. I would appreciate knowing that you intend to fulfill your important advice and consent responsibility on presidential appointments, and help the nation unify on the protection of our health, the health of our nation’s children, and the health of the environment for future generations.   

Due to updates to the website, we are now able to offer a click-and-submit form to the Regulations.gov docket!

For those who wish to also TAKE ACTION to Congress, the browser will redirect after completing your submission.

After over 25 years of delay following the 1996 Congressional mandate to determine whether pesticides disrupt the endocrine system of humans and other organisms, the U.S. Environmental Protection Agency (EPA) in February issued a proposal for modifying its approach to the implementation of the Endocrine Disruptor Screening Program (EDSP). Then, on October 11, EPA published a notice of a proposed partial settlement agreement and consent decree in response to a suit filed by farmworker and health groups challenging the agency's failure to test and regulate endocrine-disrupting pesticides. 

>> Tell EPA that it must consider complete all data concerning endocrine disruption and must not register pesticides without sufficient data to demonstrate no unreasonable adverse endocrine risk. 

The February proposal was an abrogation of EPA's responsibilities under the 1996 Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA) as well as the underlying statute, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the Safe Drinking Water Act (SDWA). Limiting the scope of the EDSP to humans, certain pesticide active ingredients only, and limiting the types of data to assess endocrine disruption (ED) effects runs counter to the Congressional intent and requirements in these statutes. It is also a reversal of the Endocrine Disruptor Screening and Testing Advisory Committee (EDSTAC) advice and the agency's original EDSP implementation policy and science decisions. 

The October 11 proposal sets deadlines by which EPA will implement EDSP requirements and assess some of the endocrine-disrupting effects of pesticides. CFS, which serves as counsel for the plaintiffs, including Alianza Nacional de Campesinas, Pesticide Action Network North America, Rural Coalition, Center for Environmental Health, and Organización en California de Líderes Campesinas, says, “Under the terms of the proposed agreement, over the next five years, EPA will collect data on and assess the effects of endocrine-disrupting pesticides, either as part of the agency's registration review of registered pesticides or as a part of new pesticide approvals. To maximize protection of farmworker and public health, the proposed agreement provides opportunities for farmworker input on prioritizing certain pesticides and requires EPA to provide regular public updates on the status of their ongoing assessment. Per the agreement, EPA will complete endocrine-disrupting assessment for 86 pesticides over the next 10 years.”

While it can be argued that this is the best that can be done under existing federal law, the settlement represents another generation of exposure to endocrine disruptors in air, water, landscapes, and food—chemicals that cause breast cancer, neurological, immunological and reproductive effects, developmental effects, learning disabilities, and a range of effects (many multigenerational) that adversely affect most organ systems. The agreement affirms that the public is not protected and should urgently shift away from a reliance on synthetic pesticides in food production, gardening, and landscape management. For more background, see here, here, here, and here. Also, see the Pesticide-Induced Diseases Database (PIDD) section on endocrine disruptors. 

While the consent decree does commit EPA to test for estrogenic effects in conventional pesticide active ingredients, it falls far short of addressing the full range of endocrine disrupting effects of all pesticide ingredients, as is required to protect human health and the environment. The February 2024 comments of Beyond Pesticides detail these requirements. In addition, the only recourse it gives the plaintiffs is to resume the litigation if EPA fails to deliver on its agreement. 

Under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk. 

EPA cannot develop a strategy for evaluating pesticides without understanding the history and status of endocrine disruption research, which are summarized in Beyond Pesticides' comments and the October 29, 2024, Daily News. Evidence that synthetic chemicals can mimic or otherwise interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it soon became apparent that the homeostatic function of the endocrine system—which regulates and balances physiological functions—can be disrupted at many sites and hormone systems.  

Endocrine disruption as a phenomenon affecting humans and other species has been critically reviewed by several authors. A common thread weaving across these reviews is the understanding that chemicals that may disrupt the endocrine systems of humans and wildlife may be pervasive in contaminating their habitats. A pandemic of endocrine-related disorders from attention deficit and hyperactivity disorder (ADHD), autism, diabetes, obesity, childhood and breast cancers, testicular cancer in young men, infertility, male dysgenesis syndrome, hypospadias, low sperm count, loss of semen volume and sperm quality, and increased risk of testicular and prostate cancer can be connected with endocrine-disrupting chemicals (EDCs). All these disorders have been increasing in incidence and can be traced back to prenatal exposure to EDCs. 

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

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

In summary, the agency cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements enumerated in FIFRA, FQPA, and SDWA. EPA should make use of all available scientifically relevant endocrine disruption research findings and also be wary of deviating from established international efforts for screening/testing endocrine disruptors that incorporate human and wildlife-relevant studies. Recognizing that mammalian data inform potential endocrine disruption in other vertebrate taxa (avian, amphibian, fish) and vice versa, the agency should not decouple the mammalian from other vertebrate assays in EDSP screening.  There are more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development (OECD) Conceptual Framework for screening/testing endocrine disrupting effects, and there are additional assays being developed for consideration as well. So, the agency should not limit the range or types of data to be used, but as FQPA prescribes use “appropriate validated test systems and other scientifically relevant information.”  

Even if currently required data—including the limited data required under this proposed partial settlement—meet the needs of human risk assessment, they are inadequate to evaluate endocrine effects on wildlife species. It should also be understood that under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk per the mandate in FIFRA. Further, it is not the agency but pesticide registrants that have the burden to demonstrate with adequate data that their products will not pose unreasonable adverse effects, including the inherently presumed endocrine-disrupting effects.

***
Speaking of endocrine disruption, plan now to attend Beyond Pesticides' 41st National Forum, Imperatives for a Sustainable Future! Thank you to all who attended our launch on October 30—stay tuned for a recording! The second session will continue on Thursday, November 14, 2024, at 1 PM (EST) with Tracey Woodruff, PhD, MPH, the director of the Program on Reproductive Health and the Environment (UCSF). Dr. Woodruff's work focuses on uncovering and addressing environmental determinants of disease and health inequities and has written groundbreaking material on endocrine-disrupting chemicals. Registration is complimentary, with contributions appreciated, and is valid for all sessions of the 2024 National Forum! 

>> Tell EPA that it must consider complete all data concerning endocrine disruption and must not register pesticides without sufficient data to demonstrate no unreasonable adverse endocrine risk. 

The target for this Action is the U.S. Environmental Protection Agency, followed by the U.S. Congress.

Thank you for your active participation! The Action is a multi-step process, so please click submit to proceed to step two, where you will be able to personalize comments before final submission. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing.

Suggested Comments:

The endocrine disruptor strategy (EDSP) proposed under the consent decree abrogates EPA’s responsibilities under the Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and Safe Drinking Water Act (SDWA). While the proposed consent decree commits EPA to test for estrogenic effects in conventional pesticide active ingredients, it falls far short of addressing the full range of endocrine-disrupting effects of all pesticide ingredients, as is required by FIFRA to protect human health and the environment. Limiting the scope of the EDSP to humans, certain pesticide active ingredients only, and limiting the types of data to assess endocrine disruption (ED) effects is contrary to the Congressional intent and requirements in these statutes and reverses Endocrine Disruptor Screening and Testing Advisory Committee advice and EPA’s original EDSP implementation policy and science decisions.  

Evidence that synthetic chemicals can interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it was soon apparent that the homeostatic function of the endocrine system can be disrupted at many sites and hormone systems.   

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

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

Thus, EPA cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements of FIFRA, FQPA, and SDWA. EPA must use all available scientifically relevant endocrine disruption research findings and avoid deviating from established international efforts that incorporate human and wildlife studies. Recognizing that mammalian data inform potential endocrine disruption in other vertebrates (avian, amphibian, fish) and vice versa, the agency must not decouple the mammalian from other vertebrate assays in EDSP screening. With more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development Conceptual Framework for screening/testing endocrine disrupting effects and additional assays in development, EPA must not limit the range or types of data to be used, but as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” Even if currently required data—including the limited data required under this proposed partial settlement—meet the needs of human risk assessment, they are inadequate to evaluate endocrine effects on wildlife species.  

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

Follow up Action to Congress: Tell Congress to Ensure that EPA Follows Through!

>> Tell Congress to ensure that EPA follows through! EPA must not register pesticides without sufficient data demonstrating no endocrine disruption.

Below is our proposed letter to Congress; we welcome you to update the message. As a reminder, the Action is a multi-step process, so please click submit to proceed to step two, where you will be able to personalize comments before final submission. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing to submit successfully.

Letter to Congress:

Plaintiffs and the Environmental Protection Agency have tentatively agreed on a consent decree describing an endocrine disruptor strategy (EDSP) to meet EPA's responsibilities under the Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and Safe Drinking Water Act (SDWA). While the proposed consent decree commits EPA to testing for estrogenic effects in conventional pesticide active ingredients, it falls far short of addressing the full range of endocrine disrupting effects of all pesticide ingredients, as is required by FIFRA to protect human health and the environment. Limiting the scope of the EDSP to humans, certain pesticide active ingredients only, and limiting the types of data to assess endocrine disruption (ED) effects is contrary to the Congressional intent and requirements in these statutes and reverses Endocrine Disruptor Screening and Testing Advisory Committee advice and EPA's original EDSP implementation policy and science decisions. 

Evidence that synthetic chemicals can interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it was soon apparent that the homeostatic function of the endocrine system can be disrupted at many sites and hormone systems.  

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

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

Thus, EPA cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements of FIFRA, FQPA, and SDWA. EPA must use all available scientifically relevant endocrine disruption research findings and avoid deviating from established international efforts that incorporate human and wildlife studies. More than 50 different ecological and mammalian assays are included in the Organization of Economic Cooperation and Development Conceptual Framework for screening/testing endocrine disrupting effects and additional assays in development, so EPA must not limit the range or types of data to be used, but as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” They must be adequate to evaluate endocrine effects on wildlife species as well as humans. 

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

Please ensure that EPA carries out its statutory responsibilities.  

Thank you. 

U.S. Senator Cory Booker (D-NJ) introduced S. 5084, Safe School Meals Act (SSMA) in September, identifying four objectives: 

• Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals. The limits will be based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure. 
• Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement. 
• Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals. 
• Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA's analysis. 

According to Senator Booker, “School meals should be a child's safest source of nourishment, not another source of toxic exposure.” Although S. 5084 does not require organic school meals, the only way for a school to meet these objectives without bearing a large expense for testing is to buy organic food. Unfortunately, as pointed out by Kate Mendenhall, executive director of Organic Farmers Association, “Most organic and small farms have not traditionally had access to school food purchasing programs.” S. 5084 will provide a strong incentive for schools to buy organic food for school lunches and thus, according to Mendenhall, will “open new markets for organic foods and help make organic certification affordable for small farmers.” 

 >> Tell your U.S. Representative and Senators to cosponsor S. 5084, which expands funding for the Organic Certification Cost-Share Program to compensate organic farmers and increases the funding available for schools to purchase safe school meals. 

The Food Quality Protection Act, passed in 1996 as an amendment to both the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Food, Drug, and Cosmetic Act (FDCA) requires regulation of endocrine-disrupting impacts of pesticides. Almost two decades later, EPA has failed to regulate endocrine disrupting pesticides.  

The review process in S. 5084 mandates that at least every five years, the Commissioner of Food and Drugs must "determine potential adjustments to the maximum permissible levels of heavy metals and toxic metalloids.” Similar provisions exist for other toxic materials that this legislation is intended to regulate. Permissible levels of toxic substances—including PFAS, heavy metals, industrial chemicals, and pesticides—are now calculated without consideration given to the cumulative impacts (or toxic burden) across all exposures. In 2020, FDA acknowledged that half of food samples tested by the agency have toxic pesticide residues and one in ten samples have levels that violate legal limits established by EPA, according to the Pesticide Residue Monitoring Report. Consumer Reports recently updated its analysis of pesticide residues in various common grocery store products, finding that 20% of the foods tested pose a “high risk” to the public—12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. 

There are serious long-term health implications for children and youth exposed to the toxic soup of pesticide and chemical residues found in conventionally grown food. Research published in Environmental Pollution in 2022 identified children with higher levels of certain pesticide metabolites are more likely to go through early puberty. The American Academy of Pediatrics identified in a study published this year the proliferation of anti-microbial resistant infections resulting from overreliance on antibiotics in animal agriculture and resulting potentially severe health risks for infants and children. Additionally, a 2024 study published in Environment International finds 60 biomarkers of pollutants and pesticides in hair analyses of children throughout France, which highlights the global crisis resulting from inadequate regulation of toxic chemicals. Despite the known health impacts of pesticide exposure, Congress may end up removing two-hundred-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields depending on how Farm Bill negotiations move forward, according to an analysis by Environmental Working Group.  

There are additional associated benefits for children who consume organic food. Sticking to an organic diet has reduced toxic pesticide residues in the bodies of U.S. children and adults, based on several studies published in 2019 in Environmental Health, and in two 2015 studies published in Environmental Health Perspectives and by the Center for Environmental Research and Children's Health. A particularly noteworthy study published in 2014 in Environmental Research found that organophosphate pesticide metabolites in the urine of adults were reduced after just a week-long organic diet. A 2019 study published in Environmental Health, led by Barcelona Institute for Global Health, found that organic food consumption among children is directly associated with higher test scores, after measuring for fluid intelligence and working memory. Conversely, lower scores on fluid intelligence tests were associated with, among other factors, children's fast-food intake.  

The transition to organic food in school cafeterias is not a new policy concern. In a 2004 article published in Pesticides and You, School Lunches Go Organic: Science supports growing movement, numerous examples across the nation demonstrate a pathway forward for broader adoption of organic mandates. “Stonyfield Farm has sponsored organic programs at schools in Rhode Island, California, Massachusetts, New York, New Hampshire, and Connecticut,” according to the article. Additionally, the authors wrote, “An organic salad bar started at Lincoln Elementary School in Olympia, Washington has proven so popular and economically feasible, all grade schools in Olympia now have one. California school districts in Berkeley, Santa Monica, and Palo Alto also have organic food programs. In 2004, the Seattle school district adopted H61.01, Breakfast and Lunch Program Procedure, a policy banning junk food and encouraging organic food in school cafeterias.” More recently, Beyond Pesticides called for requiring organic school lunches in order to eliminate obesogenic pesticide residues. 

S. 5084 also establishes a pathway forward for acknowledging organic food production as a public good and service by expanding funding for the Organic Certification Cost-Share Program to fully compensate farmers for certification costs, a long-term policy goal for organic advocates nationwide. It increases the funding available for schools to purchase safe school meals. Supporters of the bill include a broad spectrum of educational, health, environmental, and organic advocates, who welcome the continued leadership of Senator Booker in pushing forward legislation that eliminates a number of toxic residues from the National School Lunch Program and the elevation of organic food production on the national stage.  

>> Tell your U.S. Representative and Senators to cosponsor S. 5084, which increases the funding available for schools to purchase safe school meals and expands funding for the Organic Certification Cost-Share Program to compensate organic farmers.

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 ask you to cosponsor S. 5084, Safe School Meals Act, introduced by Senator Cory Booker in September, which has four objectives: 

*Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals, based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure. 

*Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement. 

*Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals. 

*Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA’s analysis. 

School meals should be a child’s safest source of nourishment, not another source of toxic exposure. Although S. 5084 does not require organic school meals, buying organic food is a cost-effective way for schools to meet the bill’s requirements. EPA has still failed to advance the protections for children mandated by the Food Quality Protection Act, passed in 1996. In 2020, FDA acknowledged that half of food samples tested by the agency have toxic pesticide residues and one in ten samples have levels that violate legal limits established by EPA. Consumer Reports recently updated its analysis of pesticide residues in various common grocery store products, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. 

There are serious long-term health implications for children and youth exposed to pesticide and chemical residues found in food grown in chemical-intensive agriculture. Research published in Environmental Pollution in 2022 identified children with higher levels of certain pesticide metabolites are more likely to go through early puberty. The American Academy of Pediatrics identified the proliferation of anti-microbial resistant infections resulting from overreliance on antibiotics in animal agriculture and resulting in potentially severe health risks for infants and children. A 2024 study published in Environment International finds 60 biomarkers of pollutants and pesticides in hair analyses of children throughout France.  

Children benefit from organic food. An organic diet reduces toxic pesticide residues in the bodies of U.S. children and adults, based on several studies published in 2019 in Environmental Health, and in two 2015 studies published in Environmental Health Perspectives, and by the Center for Environmental Research and Children’s Health. A study published in 2014 in Environmental Research found that organophosphate pesticide metabolites in the urine of adults declined after just a week-long organic diet. A 2019 study published in Environmental Health, led by Barcelona Institute for Global Health, found that organic food consumption among children is directly associated with higher test scores. Conversely, lower scores on fluid intelligence tests were associated with, among other factors, children’s fast-food intake. 

S. 5084 also expands funding for the Organic Certification Cost-Share Program to fully compensate farmers for certification costs, a long-term policy goal for organic advocates across the nation and increases the funding available for schools to purchase safe school meals. Supporters of the bill include a broad spectrum of educational, health, environmental, and organic advocates. 

Please cosponsor S. 5084. 

Thank you. 

To solve the existential crises of climate change, biodiversity loss, and human disease, it is critical that organic agriculture grow—eventually becoming the standard for agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic.

The OCCSP will disappear in 2025 unless Congress passes a five-year Farm Bill with funding or includes sufficient funding in a stopgap bill this fall.

Chemical-intensive agriculture, with its dependence on petrochemical pesticides and fertilizers, is a major contributor to the existential health and environmental crises and contamination of air, land, and water. Organic agriculture, certified and labeled in compliance with the Organic Foods Production Act (OFPA) provides:

• A definition of organic agriculture that defines health-biodiversity-climate friendly practices;
• A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests;
• A rigorous process for an allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
• A third-party certification and enforcement system;
• A process for public participation to ensure a feedback loop for continuous improvement; and,
• Funding to ensure elements are carried out in a robust way.

>> Tell Congress to ensure that organic programs, and their funding, do not lapse this fall.

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:

Now that the Farm Bill and its extension have expired on September 30, I am reaching out because I am concerned about gaps in funding for programs that are essential for organic farms and businesses. 

To solve the existential crises of climate change, biodiversity loss, and human disease, it is critical that organic agriculture grow—eventually becoming the standard for agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic. 

Organic agriculture also promotes economic growth by creating market opportunities for farmers, while supporting rural development through practices that protect natural resources and boost community resilience. I am writing to urge you to pass a five-year Farm Bill before the end of this year. I support the Farm Bill framework put forward by Senate Agriculture Committee Chairwoman Stabenow, which provides funding for essential organic programs and provides a foundation so organic agriculture can thrive. However, as this proposal moves forward, do not accept any legislative language that limit pesticide restrictions and the right to sue chemical manufacturers and allied users of pesticides when harmed. 

If Congress does not renew the five-year Farm Bill, it is imperative that the Farm Bill extension include funding for the Organic Certification Cost Share Program (OCCSP). This essential program provides a partial reimbursement to defray the cost of organic certification.  

The cost of certification is one of the biggest challenges faced by organic farmers. Without Congressional action, this program will expire, leaving thousands of organic farmers with a huge net increase in their annual certification costs. A lapse or reduction in funding, will have a big impact on farmers’ ability to stay certified, and would come at a time when most operations are seeing significant increases in certification costs to keep up with inflation and new requirements to strengthen enforcement of organic rules. 

Level funding of $8 million, as was provided last year, is no longer enough funding and would result in cuts to this essential program! The cost of the program has risen due to increasing certification costs and as more operations are getting certified. Congress needs to provide at least $11 million for the OCCSP in the Farm Bill extension (or through an ad hoc emergency assistance package). 

In addition to the Organic Certification Cost Share Program, please include provisions to reauthorize the Organic Agriculture Research and Extension Program (OREI), and fund the Organic Data Initiative and the Organic Certification Trade and Tracking Program (OCTT), which is necessary for organic fraud prevention activities. Like the OCCSP, the Organic Data Initiative and the Organic Certification Trade and Tracking Program are ‘orphan’ programs. Essential funding for these programs will lapse with devastating consequences unless there is Congressional action. 

Please make sure organic programs do not lapse this fall. 

Thank you. 

The holiday that for many years celebrated the invasion of the Western hemisphere by Europeans—Columbus Day—has increasingly become a day to remember the people of those 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 generating food, clothing, medicines, and other necessities without destroying the land that provides them. As Kaipo Kekona shared with the Beyond Pesticides 39th Pesticide Forum, it is critical for us to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings. 

Last year, President Biden reissued from 2021 his Proclamation on Indigenous Peoples' Day, on October 9, 2023, stating: “[T]hroughout our Nation's history, Indigenous peoples have faced violence and devastation that has tested their limits. . . Today, Indigenous peoples are a beacon of resilience, strength, and perseverance as well as a source of incredible contributions... They challenge all of us to celebrate the good, confront the bad, and tell the whole truth of our history.  And as innovators, educators, engineers, scientists, artists, and leaders in every sector of society, Indigenous peoples contribute to our shared prosperity.  Their diverse cultures and communities today are a testament to the unshakable and unbreakable commitment of many generations to preserve their cultures, identities, and rights to self-governance.  That is why, despite centuries of devastation and turmoil, Tribal Nations continue to thrive and lead in countless ways.”  

>> Tell EPA to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. Tell Congress 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 well-being and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.” 

According to A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “There are stark differences between agricultural systems in indigenous communities and agricultural systems in contemporary communities. The first being the idea of collective resources. In an Indigenous community, there are some things that just cannot be commodified – land, water, air, animals, even the health of the people, all of which are considered collective resources. Collective resources require collective and community management. Contemporary agriculture doesn't have the same base. In contemporary agriculture, there are individualized, commodified resources like land, you can buy water, at one point in our history you could even buy somebody's body and health.” 

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 to learn how pesticide use can be avoided by adopting indigenous practices. Tell Congress 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: 

On Indigenous Peoples' Day, I urge the U.S. Environmental Protection Agency (EPA) to recognize that Indigenous agriculture and landcare provide a model for a truly sustainable relationship with the land. These practices must be integrated into the agency’s decision making that now allows unreasonable levels of harm to health and the environment despite the availability of alternative practices and products. By ignoring this fact in registering pesticides, EPA promotes unsustainable practices, increasing crises with health, biodiversity, and climate—and undermines the opportunity for humans to live sustainably on Earth.  

Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for EPA 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 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 well-being 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, “EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” 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. A starting place is the understanding that, in the words of A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “In an Indigenous community, there are some things that just cannot be commodified—land, water, air, animals, even the health of the people, all of which are considered collective resources.”  

I urge you to begin meaningful dialogue with tribes 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”—the statutory standard for regulating pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act—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, the U.S. Environmental Protection Agency (EPA) promotes the opposite, increasing problems with health, biodiversity, and climate--not to mention the possibility of humans living sustainably on Earth. 

On Indigenous Peoples' Day, I urge you to require EPA to engage in constructive dialogue with Native American Tribes to incorporate Indigenous agriculture and landcare practices in its assessment of pesticide registrations that allow unreasonable harm to people and the environment, despite the viability of truly sustainable Indigenous methods. These Indigenous practices must be integrated into the agency’s decision making. By ignoring these practices in registering pesticides, EPA promotes unsustainable practices, increasing crises with health, biodiversity, and climate—and undermines the opportunity for humans to live sustainably on Earth. 

Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for EPA 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 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, “EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” 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. A starting place is the understanding that, in the words of A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “In an Indigenous community, there are some things that just cannot be commodified – land, water, air, animals, even the health of the people, all of which are considered collective resources.”

Please urge EPA to begin meaningful dialogue with tribes 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”—the statutory standard for regulating pesticides under FIFRA—and should result in the cancellation of the pesticide's use.  

Thank you. 

While the Environmental Protection Agency (EPA) received accolades for its August 7, 2024, decision to ban the herbicide Dacthal (or DCPA—dimethyl tetrachloroterephthalate), it also leaves many people asking, “Why Dacthal and not other very hazardous pesticides?” Paraquat, for example, poses similar elevated hazards to people and the environment, has no antidote, and has viable alternatives. Therefore, we need to challenge EPA to apply the same standard that removed Dacthal from the market to the long list of pesticides that are contributing to a health crisis, biodiversity collapse, and the climate emergency. 

In the case of Dacthal, EPA used the “imminent hazard” clause of the federal pesticide law to immediately suspend the chemical's use. At the same time, the agency is exercising its authority to prohibit the continued use of Dacthal's existing stocks, a power that EPA rarely uses. Additionally, the agency, in coordination with the U.S. Department of Agriculture, found that there were alternatives to Dacthal. 

Based on the reasoning in the Dacthal decision, EPA should ban paraquat. More background on the Dacthal decision and history of pesticide law that supports the immediate cancellation of paraquat is provided toward the end of this Action.

>> EPA must apply the standard of the Dacthal decision to paraquat and issue an emergency suspension and prohibit use of existing stocks.

1. Paraquat poses immediate serious harms to people and the environment. [First factor used in Dacthal decision]

Citing serious health issues associated with its use, including Parkinson's disease, and inaction by EPA, a number of legislative efforts have been undertaken to ban paraquat. A bill in California, originally introduced as a ban bill (AB 1963), was amended to require state review and passed in August. According to the California Legislative Information website, the legislation “[r]equires, on or before January 1, 2029, the Department of Pesticide Regulation (DPR) to complete a reevaluation of paraquat dichloride (paraquat), and make the determination to retain, cancel, or suspend its registration, or to place new appropriate restrictions on the use of paraquat.” The passage of this bill follows a long history of scientific documentation of the pesticide's hazards, fits and starts in the regulatory process, and previous efforts to ban the herbicide through legislative action. In 2018, U.S. Representative Nydia Velasquez (D-NY) introduced legislation (Protect Against Paraquat Act) to ban paraquat. Paraquat was banned in the European Union in 2007, following its prohibition years earlier in 13 countries, including Sweden, Denmark, and Austria. Now, over 60 countries have banned the use, production, and sale of paraquat, including China, where the pesticide was first developed. 

The 6th edition of Recognition and Management of Pesticide Poisonings by James R. Roberts, M.D., MPH, and J. Routt Reigart, M.D., says, “When a toxic dose is ingested (see below), paraquat has life-threatening effects on the gastrointestinal tract, kidney, liver, heart and other organs. The LD50 in humans is approximately 3-5 mg/kg, which translates into as little as 10-15 mL of a 20% solution... Although pulmonary toxicity occurs later in paraquat poisoning than other manifestations, it is the most severe and, therefore, mentioned first. Pulmonary effects represent the most lethal and least treatable manifestation of toxicity from this agent. The primary mechanism is through the generation of free radicals with oxidative damage to lung tissue. While acute pulmonary edema and early lung damage may occur within a few hours of severe acute exposures, the delayed toxic damage of pulmonary fibrosis, the usual cause of death, most commonly occurs 7-14 days after the ingestion. In those patients who ingest a very large amount of concentrated solution (20%), some have died more rapidly from circulatory failure (within 48 hours) prior to the onset of pulmonary fibrosis.” 

A 2005 study in Toxicological Sciences was able to “reproduce features of Parkinson's disease (PD) in experimental animals.” Studies continued to replicate findings associating paraquat with Parkinson's disease, as EPA continued to reject the need for action.  

In the U.S., paraquat is currently a restricted-use pesticide (meaning it can only be applied by certified applicators or those working under their on- or off-site supervision) and banned on golf courses. There is established and mounting evidence of links between minimal exposure and various adverse health impacts for humans and wildlife.  

Beyond Pesticides continues to track the latest scientific literature on adverse health impacts of paraquat. Within all the single-pollutant models employed in a 2022 study published in Journal of Clinical Endocrinology and Metabolism, researchers found a linkage between paraquat dichloride and thyroid cancer. A different study published that same year in Independent determined the toxic impacts of paraquat on bird embryos, including the Japanese quail, mallards, bobwhite quail, and ring-necked pheasant.  

EPA's ecological risk assessment in support of its ID did not consider risks to endangered/threatened species and potential jeopardy to their continued existence. As stated in the assessment: “Given that the agencies are continuing to develop and work toward implementation of the Interim Approaches to assess the potential risks of pesticides to listed species and their designated critical habitat, this ecological risk assessment for paraquat does not contain a complete ESA analysis that includes effects determinations for specific listed species or designated critical habitat.” Considering that the calculated risk quotients (RQs) exceed established levels of concern (LOCs) for most unlisted species, it can be inferred that listed plant and animal species in areas of paraquat use could indisputably be at risk of jeopardy. 

Paraquat has also not been fully assessed by EPA for potential endocrine disruption. Both the human health and ecological assessments deferred an assessment and provided canned language that endocrine disrupting potential will be further considered under the Endocrine Disruptor Screening Program (EDSP). However, there is evidence available that paraquat has endocrine disrupting effects. Use of paraquat is significantly associated with hypothyroidism. Paraquat has been reported to decrease testosterone, follicle-stimulating hormone, luteinizing hormone and prolactin in male rats. In the frog Rana esculenta, paraquat was found to inhibit the production of testosterone in the testis and 17-beta-estradiol in the ovary. More importantly, the endocrine disruption activity of paraquat that causes excessive reactive oxygen species production also links paraquat to Parkinson's Disease. Though somewhat limited, these data do indicate a potential for unreasonable adverse endocrine disruption in humans and wildlife and should be further investigated as mandated in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Food Quality Protection Act (FQPA). 

>> EPA must apply the standard of the Dacthal decision to paraquat and issue an emergency suspension and prohibit use of existing stocks.

2. Mitigation measures have not eliminated the harm. [Second factor used in Dacthal decision]

In 2018, EPA downplayed the connection between exposure to paraquat and the development of Parkinson's disease in registration review documents released by the agency. But California Assemblymember Friedman, the prime sponsor of AB1963 (cited above), in a press release on the day the California legislation was introduced, said, “We cannot afford to ignore decades of mounting evidence linking paraquat exposure to Parkinson's disease, non-Hodgkin lymphoma, and childhood leukemia.” She continued: “In 2021, the latest year for which data are publicly available, just over 430,000 pounds were applied in California, primarily in Kern, Kings, Fresno, Merced, and Tulare counties. The herbicide is extremely toxic to humans, with low doses causing death, and it has been linked to increased risk of Parkinson's Disease.” 

EPA's actions, or inaction as some would argue, on the scientific literature on paraquat exposure and Parkinson's disease represent a failure of EPA to take a proactive approach in ending the continued exposure and health impacts of the toxic herbicide to chemically sensitive populations. According to the EPA's Office of Pesticide Programs' guidelines on paraquat and diquat, these ammonium herbicides are life-threatening in toxic doses and hold the potential to “impact GI tract, kidney, lungs liver, heart, and other organs.” Specifically regarding paraquat, “pulmonary fibrosis is the usual cause of death in paraquat poisoning.” 

In 2019, EPA released, “Systematic Review of the Literature to Evaluate the Relationship between Paraquat Dichloride Exposure and Parkinson's Disease.” Following this ruling, EPA was lambasted for its dismissal of the linkage between Paraquat exposure and Parkinson's Disease, despite a growing body of literature between 2009 and 2019 and, given that “[a]n EPA environmental review conducted as part of the reregistration process found evidence of significant reproductive harm to small mammals, and determined that songbirds may be exposed to levels well beyond lethal concentrations known to cause death. Threats to mammals and songbirds are particularly concerning considering significant declines in these animal groups.” 

In 2019, Beyond Pesticides submitted comments and concluded: “Since the agency risk assessments are intended to support Agency risk management review, risk management recommendations are not provided in its draft risk assessments. The many risk concerns and uncertainties (lack of data) identified in both the human health and ecological risk assessments makes it unconscionable to allow continued use of such a dangerous pesticide as paraquat. A restricted use label will do little to allay the ecological risk concerns enumerated or adequately protect persons in vicinity of treatments or in harvest and post-harvest activities. Taken together with the clear inability of the agency to preclude potential for Parkinson's disease, it is recommended that the use of paraquat should be immediately suspended if not outright cancelled as it is in the EU and several other countries.” 

In late January 2024, EPA released a report, “Preliminary Supplemental Consideration of Certain Issues in Support of its Interim Registration Review Decision for Paraquat.” According to the interim report, “The Agency prepared several documents to support its 2021 interim registration review decision for paraquat and attempted 'to connect the dots' of the risk-benefit information contained in its support documents in the Paraquat ID.” The results of this interim report, specifically regarding linkage to Parkinson's Disease and other health risks associated with chronic exposure to paraquat, highlight the flaws in EPA's approach to risk assessment and opportunities to incorporate additional sources of sound science in the final report in January 2025. For example, “EPA intends to consider [additional studies] as part of the next steps in this process. First, EPA recognizes that the Michael J. Fox Foundation and Earthjustice submitted letters to EPA on August 4, 2023, along with information that they believe is relevant to EPA's consideration of paraquat's health risks. This information consisted of approximately 90 submissions including scientific studies, as well as testimony filed in an ongoing state lawsuit concerning paraquat. EPA has included these documents in the docket for paraquat at EPA-HQ-OPP-2011-0855-0317 and EPA-HQ-OPP2011-0855-0313. While the Agency has started reviewing that material, it was unable to complete that review prior to the issuance of this document. [As a result, this document does not reflect the Agency's review of any of those materials.] Second, new information on paraquat vapor pressure was submitted on January 18, 2024, which may impact the Agency's volatilization analysis. Due to the late submission of that data, EPA has not incorporated that information into this document. Therefore, EPA intends to address that material along with any other significant information it receives during the public comment period and incorporate its consideration of those materials into any final document(s) issued by January 17, 2025.” Advocates found it surprising that the EPA was not able to review studies submitted by the Michael J. Fox Foundation and Earthjustice even though the agency had more than several months for review. Beyond Pesticides will continue to track updates to this upcoming public comment period to insert new studies and data points for EPA to include in their final report.   

In April 2024, Beyond Pesticides' comments on the Paraquat Interim Registration Review stated, “EPA failed to assess a common mechanism of toxicity for PQ [paraquat] and any other substance in its review for the ID [interim decision], erroneously concluding that PQ does not have a common mechanism of toxicity or combined toxic action with other substances that may interact and potentiate its action.” The comments address the mandates under FIFRA and FQPA, stating that the agency failed to meet its mandate to obtain proof that paraquat “unequivocally does not cause or contribute to Parkinson's disease” and to assess paraquat endocrinological risk through FQPA's EDSP, respectively. Additionally, the comments cite EPA's failure to adequately review and incorporate the breadth of studies pointing to a relationship between Parkinson's Disease and paraquat exposure; failure within its ecological risk assessment to consider risks to endangered wildlife and subsequent ecosystem balance concerns; and failure in its risk-benefit analysis to fully consider the risks of paraquat exposure. 

3. The public does not benefit from continued registration of paraquat. [Third factor used in Dacthal decision]

Although EPA asserts that there are no direct alternatives to paraquat, several alternatives, chemical and nonchemical, are widely available. Given the availability of alternative pest management practices that incorporate alternative cultural practices and/or less toxic products, including other registered pesticides, the agency has a statutory duty to revoke all registrations of the paraquat under its unreasonable adverse effects standard in FIFRA. The risks and uncertainties identified by the agency in its assessments and the independent scientific literature are not reasonable in light of the availability of less toxic alternatives and cultural practices. To refute a rebuttable presumption against paraquat registration, the many data gaps listed before would need to be fulfilled and reveal opposing evidence to existing adverse effect data. 

EPA has sufficient information to cancel paraquat. 

EPA has the information above, which is in the open literature and/or provided in regulatory comments by Beyond Pesticides and others. The failed regulation, and subsequent harm, caused by paraquat is but one representation of a failed regulatory system that can and should do more to eliminate the use of toxic petrochemical-based pesticides. The convergence of crosscutting crises of health threats, biodiversity collapse, and the climate emergency stems from continued reliance on fossil fuels and petrochemical pesticides and fertilizers, which perpetuate the harms of greenhouse gas emissions. These crises are causing ecosystem fragmentation and failure, and public health crises that undermine the nutritional integrity of the food supply and the scientific integrity the public relies on for safety and well-being. After decades of working with farmworkers and farmers who face the brunt of toxic pesticide exposure, Beyond Pesticides echoes the call for advocates across the nation to expand and strengthen organic land management principles to move beyond the existing product substitution framework that leads to the continuous use of toxic pesticides.  

>> EPA must apply the standard of the Dacthal decision to paraquat and issue an emergency suspension and prohibit use of existing stocks.

Additional Background Information—What is the Dacthal Standard?

EPA describes its regulatory process leading to Dacthal ban as follows: 

In 2013, the agency issued a Data Call-In (DCI) to AMVAC Chemical Corporation, the sole manufacturer of DCPA, [Dacthal] requiring it to submit more than 20 studies to support the existing registrations of DCPA. The required data included a comprehensive study of the effects of DCPA on thyroid development and function in adults and in developing young before and after birth, which was due by January 2016. Several of the studies that AMVAC submitted from 2013-2021 were considered insufficient to address the DCI, while the thyroid study and other studies were not submitted at all. 

In April 2022, EPA issued a very rarely used Notice of Intent to Suspend the DCPA technical-grade product (used to manufacture end-use products) based on AMVAC's failure to submit the complete set of required data for almost 10 years, including the thyroid study. While AMVAC submitted the required thyroid study in August 2022, EPA suspended the registration based solely on AMVAC's continued failure to submit other outstanding data on Aug. 22, 2023, following an administrative hearing.  In November 2023, the data submission suspension was lifted after AMVAC submitted sufficient data. Most DCPA use on turf was voluntarily canceled by AMVAC in December 2023, but unacceptable risks from other uses remained. 

As society and the global community struggle with petrochemical pesticides and their contribution to health threats, biodiversity collapse, and the climate emergency, and EPA must acknowledge that Dacthal is one active ingredient among over 1,000 in 56,000 pesticide products whose uses can be eliminated with the use of organic systems that have now been shown to be effective.  

The last time EPA issued an emergency action like this was in 1979 when the agency acknowledged miscarriages associated with the forestry use of the herbicide 2,4,5-T—one-half of the chemical weed killer Agent Orange, sprayed over people to defoliate the landscape of Vietnam in the war there—with the most potent form of dioxin, TCDD (2,3,7,8-Tetrachlorodibenzo-p-dioxin). The chemical manufacturer of Dacthal, AMVAC Chemical Corporation, can challenge the agency's findings under the law and seek court review, but EPA's action takes effect immediately while any appeal is considered. Meanwhile, EPA has stopped use under 7 U.S.C. 136 et seq., pursuant to section 6(c)(3) (7 U.S.C. 136d(c)(3)). (See Unit IV.) The prohibition on the use of existing stocks is mandated under Section 6(a)(1). 

The timeline for review and action on individual pesticides has taken decades since the 1972 overhaul of the nation's pesticide law, FIFRA. The law's risk-benefit standard allows for high levels of harm, especially to farmworkers and those handling pesticides, as well as public exposure through residues in food, water, and air. EPA's decisions are based on agency risk assessments that use flawed assumptions and ignore vulnerable populations like children and those with preexisting health conditions—like cancer, endocrine system disruption, neurological illness (including Parkinson's disease), and other health effects that are exacerbated by exposure. Amendments to FIFRA in 1996, in FQPA, have done little to reduce the ongoing reliance on toxic chemicals in food production and land management, despite the growth of the $70 billion organic industry—still not considered by EPA as a legitimate alternative to be evaluated when determining the “reasonableness” or “acceptability” of risk under pesticide law. Instead, EPA calculates acceptability of risk in the context of available alternative chemicals. In its press release on the Dacthal decision, EPA said, “In deciding whether to issue today's Emergency Order, EPA consulted with the U.S. Department of Agriculture to understand how growers use DCPA and alternatives to this pesticide.” The agency's consultation with USDA evaluated alternative chemicals, not alternative organic management systems and organic-compatible substances. 

The current mechanism that EPA uses to restrict pesticides—negotiated settlements instead of regulatory action—compromises the health of people and the environment, often disproportionately for people of color and workers, who are the first to be exposed as applicators or agricultural workers. Could the Dacthal decision be a watershed moment to change a regulatory process that allows daily pesticide exposure, poisoning, and contamination at rates that EPA deems acceptable—despite the overwhelming science linking real-world pesticide use (homes, to parks and playing fields, schools, and farms) to dreaded illnesses, biodiversity collapse, and the climate crisis? (See the Pesticide-Induced Diseases Database and the Pesticide Gateway.)

In making its decision to ban Dacthal, EPA states that it considered: 

• The seriousness of the threatened harm; 
• The immediacy of the threatened harm; 
• The probability that the threatened harm will occur; 
• The benefits to the public of the continued use of the pesticide; and 
• The nature and extent of the information before the Agency at the time it makes a decision. 

These criteria could be met for most of the pesticides for which EPA has negotiated settlements with pesticide manufacturers, resulting in partial withdrawals of pesticides from the market and compromises that threaten health and the environment. 

By 2032, all petrochemical pesticides must be phased out and replaced by organic systems and substances compatible with the protection of health and the environment and a livable future. 

>> EPA must apply the standard of the Dacthal decision to paraquat and issue an emergency suspension and prohibit use of existing stocks.

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:

I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. Now, I respectfully request that EPA apply the same criteria to paraquat and stop its use. 

In deciding to ban Dacthal, EPA says it considered the seriousness, immediacy, and likelihood of the threatened harm; benefits to the public of continued use; and nature and extent of the information before EPA. 

Please apply the three following criteria to paraquat, the three factors used to ban Dacthal. 

1. Paraquat poses immediate serious harms to people and the environment. 

The 6th edition of Recognition and Management of Pesticide Poisonings by James R. Roberts, M.D., M.P.H, and J. Routt Reigart, M.D., says, “[P]araquat has life-threatening effects on the gastrointestinal tract, kidney, liver, heart and other organs. The LD50 in humans is approximately 3-5 mg/kg, which translates into as little as 10-15 mL of a 20% solution. . . Although pulmonary toxicity occurs later in paraquat poisoning than other manifestations, it is the most severe and, . . .[p]ulmonary effects represent the most lethal and least treatable manifestation of toxicity from this agent. The primary mechanism is through the generation of free radicals with oxidative damage to lung tissue. While acute pulmonary edema and early lung damage may occur within a few hours of severe acute exposures, the delayed toxic damage of pulmonary fibrosis, the usual cause of death, most commonly occurs 7-14 days after the ingestion. In those patients who ingest a very large amount of concentrated solution (20%), some have died more rapidly from circulatory failure (within 48 hours) prior to the onset of pulmonary fibrosis.” 

Paraquat poses risks to endangered/threatened species and potential jeopardy to their continued existence. It is an endocrine disruptor. Use of paraquat is significantly associated with hypothyroidism. It has been reported to decrease testosterone, follicle-stimulating hormone, luteinizing hormone, and prolactin in male rats. In the frog Rana esculenta, paraquat was found to inhibit the production of testosterone in the testis and 17-beta-estradiol in the ovary. Moreover, the endocrine disruption activity of paraquat that causes excessive reactive oxygen species production also links it to Parkinson’s Disease. 

2. Mitigation measures have not eliminated harm. 

EPA has downplayed the connection between exposure to paraquat and the development of Parkinson’s disease in registration review documents released by the agency, leading numerous legislators to call for the banning of paraquat. 

3. The public does not benefit from continued use. 

Alternative pest management practices that incorporate cultural practices and/or less toxic products are available. Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.”  

EPA has sufficient information to ban paraquat. EPA has the information above, which is in the open literature and/or provided in regulatory comments, demonstrating that the agency has a statutory duty to revoke all registrations of the paraquat under its unreasonable adverse effects standard in FIFRA.  

Please apply the standard of the Dacthal decision to paraquat. Issue an emergency suspension and prohibit use of existing stocks. 

Thank you. 

Letter to U.S. Representative and Senators: 

I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. However, paraquat fits the criteria used to ban Dacthal. All of this is known to EPA. 

In deciding to ban Dacthal, EPA says it considered the seriousness, immediacy, and likelihood of the threatened harm; benefits to the public of continued use; and nature and extent of the information before EPA. 

1. Paraquat poses immediate serious harms to people and the environment. 

The 6th edition of Recognition and Management of Pesticide Poisonings by James R. Roberts, M.D., M.P.H, and J. Routt Reigart, M.D., says, “[P]araquat has life-threatening effects on the gastrointestinal tract, kidney, liver, heart and other organs. The LD50 in humans is approximately 3-5 mg/kg, which translates into as little as 10-15 mL of a 20% solution. . . Although pulmonary toxicity occurs later in paraquat poisoning than other manifestations, it is the most severe and, . . .[p]ulmonary effects represent the most lethal and least treatable manifestation of toxicity from this agent. The primary mechanism is through the generation of free radicals with oxidative damage to lung tissue. While acute pulmonary edema and early lung damage may occur within a few hours of severe acute exposures, the delayed toxic damage of pulmonary fibrosis, the usual cause of death, most commonly occurs 7-14 days after the ingestion. In those patients who ingest a very large amount of concentrated solution (20%), some have died more rapidly from circulatory failure (within 48 hours) prior to the onset of pulmonary fibrosis.” 

Paraquat poses risks to endangered/threatened species and potential jeopardy to their continued existence. It is an endocrine disruptor. Use of paraquat is significantly associated with hypothyroidism. It has been reported to decrease testosterone, follicle-stimulating hormone, luteinizing hormone and prolactin in male rats. In the frog Rana esculenta, paraquat was found to inhibit the production of testosterone in the testis and 17-beta-estradiol in the ovary. Moreover, the endocrine disruption activity of paraquat that causes excessive reactive oxygen species production also links it to Parkinson’s Disease. 

2. Mitigation measures have not eliminated harm. 

EPA has downplayed the connection between exposure to paraquat and the development of Parkinson’s disease in registration review documents released by the agency, leading California Assemblymember Laura Friedman (D-Burbank), chair of the bicameral Environmental Caucus, to introduce legislation to phase out and ban the use of paraquat across all uses, including agriculture, by the end of 2025. 

3. The public does not benefit from continued use of paraquat. 

Alternative pest management practices that incorporate cultural practices and/or less toxic products are available. Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.”  

EPA has sufficient information to ban paraquat. EPA has the information above, which is in the open literature and/or provided in regulatory comments, demonstrating that the agency has a statutory duty to revoke all registrations of the paraquat under its unreasonable adverse effects standard in FIFRA.  

Tell EPA to apply the standard of the Dacthal decision consistently—to ban paraquat. 

Thank you. 

Comments are due by 11:59 PM EDT on September 30, 2024. 

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

The National Organic Standards Board (NOSB) is receiving written comments from the public on key issues, which must be submitted by 11:59 PM EDT on September 30, 2024. Written comments can be submitted via our form below. 

This precedes the upcoming public comment webinar on October 15 and 17 and the deliberative hearing from October 22-24—concerning how organic food is produced and processed. Sign up for a 3-minute comment at the webinar by 11:59 PM EDT on September 30 to let U.S. Department of Agriculture (USDA) know how important organic is! Oral comment sign-ups fill up fast! Links to the virtual comment webinars will be provided on this webpage in early October, approximately one week before the meeting.  

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 public involvement in the current public comment period. This is required to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But we will only keep organic strong and growing stronger if we participate in voicing our position on key issues to the stakeholder advisory board, the National Organic Standards Board (NOSB). We have identified key issues for the meeting below. 

>> Click here to submit your comments to the NOSB by 11:59 PM EDT on Sept 30, 2024.

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 Fall. ➡️ For a complete discussion, please see the Keeping Organic Strong page and review the UPDATED Fall 2024 issues! 

Some of our high priority issues for the upcoming NOSB meeting (see others here):

1. Make elimination of plastic in organic a research priority. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well documented. We need research into ways to replace all forms of plastic in organic production and handling. 

Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.  

Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products. 

The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale, 90% of which are not identifiable, but the number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. When they exposed cod eggs, embryos and larvae to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans. 

Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta. 

2. Eliminate nonorganic ingredients in processed organic foods as a part of NOSB's sunset review. 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) only 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?” Materials on §205.606 up for sunset review this year made from agricultural products that can be supplied organically should be taken off the National List of allowed materials. 

The majority of the Handling Subcommittee voted to remove dried orange pulp from §205.606 because organic dried orange pulp is now available. This should be supported. 

Cultured celery powder is a way of adding "natural" nitrites. The quotation marks are appropriate since it is not possible to achieve the high levels of nitrate desired through organic celery production. Rather, the celery must be grown in chemical-intensive production where it takes up nitrates from synthetic fertilizers. Given the known health effects of nitrates, we do not believe there is a good reason for keeping celery powder on the National List. The Agency for Toxic Disease Registry (ATSDR)/Centers for Disease Control and Prevention (CDC) lists, for example, methemoglobinemia, hypotension, risk of pregnancy complications, a number of reproductive effects, and cancer, among others.  

In addition, there are 62 pesticides with allowed residues (tolerances) for celery, 27 are acutely toxic and create a hazardous environment for farmworkers, 57 are linked to chronic health problems (such as cancer), 15 contaminate streams or groundwater, and 56 are poisonous to wildlife. Celery powder should be removed from the National List. 

3. All segments of organic production and regulation should cooperate in ensuring that organic products are produced using organic seed and starts. Processors should not require organic growers to produce varieties if the seeds or starts for those varieties are not available organically. Processors who sell products with the organic seal benefit from certification and should share the responsibility for continuous improvement.  

Organic cotton growers find it very difficult to source organic seed due to the small size of the industry. Most growers must use conventional, untreated, non-GMO seed. Given current seed regulations, the delinting process used on conventional seeds (sulfuric acid) is allowed since the seeds themselves are untreated and non-GMO. Also, due to the consolidation of seed companies, organic growers have an increasingly hard time finding their desired varieties that have been available in the past. The push for genetically modified cotton varieties has also made seed sourcing for organic growers even more difficult. The NOSB and NOP should make the availability of organic seed a priority. 

>> Click here to submit your comments to the NOSB by 11:59 PM EDT on Sept 30, 2024.

We urge you to submit comments to the docket on the above issues and to add a sentence or two at the beginning of the comments explaining why organic is important to you! For those who prefer to copy and paste comments directly to Regulations.gov, please see our comments included on our Fall issues page.

The target for this Action is the U.S. National Organic Standards Board, a federal advisory board of dedicated public volunteers from across the organic community under the U.S. Department of Agriculture's Agricultural Marketing Service.

Thank you for your active participation and engagement in keeping organic strong! The Action is a multi-step process, so please click submit below to proceed to step two, where you will be able to personalize comments before final submission.

Comments to the NOSB:

Please consider the following key issues to uphold organic integrity: 

1. Eliminate plastic in organic production. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well-documented. We need research into ways to replace all forms of plastic in organic production and handling. Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic).

Microplastics are of increasing concern because they can cause harmful effects to humans and other organisms, act as carriers of toxic chemicals, and increase the spread of antibiotic resistance genes in water and sediments. Microplastic particles been found in human carotid artery plaque, lungs, blood, feces, breast milk, and placenta. Cod eggs, embryos, and larvae exposed to water containing microplastics, exhibited toxic effects reminiscent of scoliosis in humans. 

Highly hazardous PFAS (per- and polyfluoroalkyl substances) leach out of plastic containers and contaminate food products. The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics. A study analyzing 50 items in common use finds many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases.  

2. Eliminate nonorganic ingredients in processed organic foods as a part of NOSB’s sunset review. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. Nonorganic materials should not be allowed if they can be supplied organically, and we can now grow virtually anything organically. The NOSB needs to ask potential suppliers, “Could you supply the need if the organic form is required?” Materials on §205.606 up for sunset review made from agricultural products that can be supplied organically should be taken off the National List of allowed materials.

I support the vote of the Handling Subcommittee to remove dried orange pulp from §205.606 because organic dried orange pulp is now available.  

Cultured celery powder is a way of adding "natural" nitrates. The quotation marks are appropriate since celery takes up the high level of nitrates desired from synthetic fertilizers in chemical-intensive production.  Nitrates have known health effects of nitrates, including methemoglobinemia, hypotension, risk of pregnancy complications, a number of reproductive effects, and cancer. In addition, of 62 pesticides with allowed residues (tolerances) for celery, 27 are acutely toxic and create a hazardous environment for farmworkers, 57 are linked to chronic health problems (such as cancer), 15 contaminate streams or groundwater, and 56 are poisonous to wildlife. Celery powder should be removed from the National List. 

3. All segments of organic production and regulation should cooperate in ensuring that organic products are produced using organic seed and starts. Processors should not require organic growers to produce varieties if the seeds or starts for those varieties are not available organically. Processors who sell products with the organic seal benefit from certification and should share the responsibility for continuous improvement. 

Organic cotton growers find it very difficult to source organic seed. Most must use conventional, untreated, non-GMO seed. Also, due to the consolidation of seed companies, organic growers have an increasingly hard time finding their desired varieties that have been available in the past. The NOSB and NOP should make the availability of organic seed a priority. 

Thank you for considering these comments.

Stop Cycle of Increasing Pesticide Use with Ecosystem and Bat Decline, Resulting in Higher Infant Mortality 

Shocking new research connects declines in bat populations with increased human infant mortality. The connection is increased pesticide use. The study by Eyal Frank, PhD, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes with a finding that “declines in insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.” 

>> Tell your Governor and Mayor to stop the cycle of increasing pesticide dependency tied to an imbalance in ecosystems degraded by pesticide use and other factors—resulting in a loss of natural insect management by bats and other wildlife that leads to rising pesticide use and increasing infant mortality and public health threats.

Many farmers rely on bats as alternatives to insecticides to protect their crops from insects, but the invasive fungus Pseudogymnoascus destructans, White-Nose Syndrome (WNS) has caused a serious decline in bat populations since 2006. Bats are also important in keeping mosquitoes under control. According to bat experts, 52% of bat species in North America are at risk of severe declines over the next 15 years. While there are numerous causes of fungal diseases, pesticide use can increase vulnerability by depressing the immune system. With the collapse of many bat populations from WNS found in caves that affect bats during hibernation, farmers turn to toxic chemicals to replace the ecosystem services bats usually provide. These chemicals, however, lead to ripples through the ecosystem and endanger human health.  

To determine the impacts on human health from these population declines, Dr. Frank collected data from WNS-affected counties on insecticide use and infant mortality from 2006-2017. In comparing these numbers, “after the onset of bat die-offs, farmers in the county increase their insecticide use by 31.1%, on average,” he states. “Infant mortality rates due to internal causes of death (i.e., not due to accidents or homicides) increased by 7.9%, on average, in the affected counties. This result highlights that real-world use levels of insecticides have a detrimental impact on health, even when used within regulatory limits.” These rates correspond to an additional 1,334 infant deaths—for every 1% increase in pesticides, a 0.25% increase in the infant mortality rate is documented. CDC (Centers for Disease Control and Prevention) says, “The infant mortality rate is an important marker of the overall health of a society.” Although infant mortality in the U.S. has been decreasing, 43 countries have infant death rates lower than the United States.  

But, not only does decreasing bat populations lead to more pesticide use, leading to more infant deaths, but pesticide use also leads to decreasing bat populations. An extensive article by William Quarles, PhD, published in the IPM Practitioner in 2013, lays out much of the research that has been done on bats, pesticides, and WNS. Dr. Quarles finds that the immune system of bats in the U.S. is unable to prevent infection with WNS. He reviews studies showing that pesticides including DDT, organophosphates, and carbamates result in death or reproductive toxicity in bats. More recently, Pierre Mineau, PhD, and Carolyn Callaghan, PhD, find, “[T]here is evidence to support the claim that bats are being negatively affected by neonicotinoid insecticides in several different ways, indirectly through reduction in insect abundance and directly through impairment.” J.M. Oliviera et al. review research on pesticide impacts on bats, finding, “Pesticides toxicity leads to immunosuppression and makes the individual more susceptible to infections by pathogenic organisms.” 

The cycle of pesticide use causing decreasing bat populations causing more pesticide use is an engine leading to ongoing and increasing infant deaths. We can break the cycle of increasing pesticide dependency with organic practices that are in sync with nature and intended to protect and enhance biodiversity.  

Multiple crises impacting biodiversity, human health, and climate change threaten ecological balance. Bats are one of many species providing important ecosystem services, such as mosquito management and pollination, who are underappreciated until their services are no longer available.  

>> Tell your Governor and Mayor to stop the cycle of increasing pesticide dependency tied to an imbalance in ecosystems degraded by pesticide use and other factors—resulting in a loss of natural insect management by bats and other wildlife that leads to rising pesticide use and increasing infant mortality and public health threats.

The targets for this Action are the U.S. state governors and U.S. mayors, as available dependent on residency.

Letter to the Governor:

Shocking new research connects declines in bat populations to increased human infant mortality. The connection is increased pesticide use. The study by Eyal Frank, PhD, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes, “[D]eclines in insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.” 

Bats help protect crops from insects and control mosquitoes, but the White-Nose Syndrome (WNS), has reduced bat populations. According to bat experts, 52% of bat species in North America are at risk of severe declines over the next 15 years. While there are many causes of fungal diseases, pesticide use can increase vulnerability by depressing the immune system. With the collapse of many bat populations from WNS, farmers turn to toxic chemicals to replace the ecosystem services bats usually provide—chemicals that ripple through the ecosystem and endanger human health.  

To determine impacts on human health from bat population declines, Dr. Frank collected data from counties with WNS regarding insecticide use and infant mortality from 2006-2017. In comparing these numbers, “[A]fter the onset of bat die-offs, farmers in the county increase their insecticide use by 31.1%, on average,” he states. “Infant mortality rates due to internal causes of death (i.e., not due to accidents or homicides) increased by 7.9%, on average, in the affected counties. This result highlights that real-world use levels of insecticides have a detrimental impact on health, even when used within regulatory limits.” These rates correspond to an additional 1,334 infant deaths—for every 1% increase in pesticides, a 0.25% increase in the infant mortality rate results.  

Not only do decreasing bat populations lead to more pesticide use, leading to more infant deaths, but pesticide use also leads to decreasing bat populations. William Quarles, Ph.D., in The IPM Practitioner, summarizes research done on bats, pesticides, and WNS. He finds that the immune system of bats in the U.S. is unable to prevent infection with WNS and reviews studies showing that pesticides including DDT, organophosphates, and carbamates, result in death or reproductive toxicity in bats. More recently, Pierre Mineau, PhD, and Carolyn Callaghan, PhD, find, “[T]here is evidence to support the claim that bats are being negatively affected by neonicotinoid insecticides in several different ways, indirectly through reduction in insect abundance and directly through impairment.” J.M. Oliviera et al. review research on pesticide impacts on bats, finding, “Pesticides toxicity leads to immunosuppression and makes the individual more susceptible to infections by pathogenic organisms.” 

The cycle of pesticide use causing decreasing bat populations causing more pesticide use is an engine leading to ongoing and increasing infant deaths. We can break the cycle of increasing pesticide dependency with organic practices that are in sync with nature and protect and enhance biodiversity. 

Please eliminate the use of pesticides in our city that imperil bats by adopting biodiversity conservation goals including: (1) ecological mosquito management with measures that recognize the benefit of preventive strategies, establish source reduction programs to manage breeding sites on public lands, educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonicotinoids; and (3) land management on public lands—including hospitals, higher education institutions, schools, and parks—using regenerative organic principles and organic certified practices and products, to transition to a viable system that prioritizes long-term health of the public, ecology, and economy. 

Thank you. 

Letter to the Mayor: 

Shocking new research connects declines in bat populations to increased human infant mortality. The connection is increased pesticide use. The study by Eyal Frank, PhD, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes, “[D]eclines in insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.”   

Bats help protect crops from insects and control mosquitoes, but the invasive fungus Pseudogymnoascus destructans, White-Nose Syndrome (WNS), has reduced bat populations since 2006. According to bat experts, 52% of bat species in North America are also at risk of severe declines over the next 15 years. While there are numerous causes of fungal diseases, pesticide use can increase vulnerability by depressing the immune system. With the collapse of many bat populations from WNS, farmers turn to toxic chemicals to replace the ecosystem services bats usually provide—chemicals that ripple through the ecosystem and endanger human health.    

To determine impacts on human health from bat population declines, Dr. Frank collected data from counties with WNS regarding insecticide use and infant mortality from 2006-2017. In comparing these numbers, “[A]fter the onset of bat die-offs, farmers in the county increase their insecticide use by 31.1%, on average,” he states. “Infant mortality rates due to internal causes of death (i.e., not due to accidents or homicides) increased by 7.9%, on average, in the affected counties. This result highlights that real-world use levels of insecticides have a detrimental impact on health, even when used within regulatory limits.” These rates correspond to an additional 1,334 infant deaths—for every 1% increase in pesticides, a 0.25% increase in the infant mortality rate results.    

But, not only does decreasing bat populations lead to more pesticide use, leading to more infant deaths, but pesticide use also leads to decreasing bat populations. William Quarles, PhD, summarizes research done on bats, pesticides, and WNS; he finds that the immune system of bats in the U.S. is unable to prevent infection with WNS. He reviews studies showing that pesticides including DDT, and more recently organophosphates, and carbamates, result in death or reproductive toxicity in bats. More recently, Pierre Mineau, PhD, and Carolyn Callaghan, PhD, find, “[T]here is evidence to support the claim that bats are being negatively affected by neonicotinoid insecticides in several different ways, indirectly through reduction in insect abundance and directly through impairment.” J.M. Oliviera et al. review research on pesticide impacts on bats, finding, “Pesticides' toxicity leads to immunosuppression and makes the individual more susceptible to infections by pathogenic organisms.”   

The cycle of pesticide use causing decreasing bat populations causing more pesticide use is an engine leading to ongoing and increasing infant deaths. We can break the cycle of increasing pesticide dependency with organic practices in sync with nature and intended to protect and enhance biodiversity.   

Please eliminate the use of pesticides that imperil bats by adopting biodiversity conservation goals including: (1) ecological mosquito management with measures that recognize the benefit of preventive strategies, establish source reduction programs to manage breeding sites on public lands, educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonics; and (3) land management on public lands—including hospitals, universities, schools, and parks—using regenerative organic principles and organic certified practices and products, to transition to a viable system that prioritizes long-term health of the public, ecology, and economy. 

Thank you. 

BREAKING ACTION: Do Not Let the Council Reverse Its Groundbreaking Ordinance to Protect Maui from Toxic Pesticides and Fertilizers 

***This Action is limited to residents of the county of Maui, Hawai'i.

A proposal is coming before the County Council on September 13, 2024, to repeal Maui's ordinance that prevents the use of toxic pesticides and fertilizers in the management of playing fields and golf courses. In order to protect public health, mitigate the climate crisis, and curtail biodiversity collapse, now is not the time to backtrack and reverse course on the County law to eliminate petrochemical pesticides and fertilizers on Maui. 

>> Urge your councilmember to protect Maui's residents and safeguard the groundbreaking ordinance preventing petrochemical pesticide and fertilizer use! Tell the Council to oppose Bill 131 and to send any legislation on this matter to the Water Authority, Social Services, and Parks Committee for consideration. 

When Maui County adopted an ordinance to transition away from toxic pesticide and fertilizer use in 2021, allowing only those materials permitted under federal organic law, it provided important leadership on a critical public health issue.

The ordinance codifies the values and principles of the elected officials on behalf of the people of Maui with the clarity of its commitment: 

The purpose of this ordinance is to prohibit the County's purchase or use of certain pesticides and fertilizers to safeguard the health and welfare of County of Maui employees, residents, and visitors; and to conserve and protect the County's waterways and natural resources.  The Council's intent is for the County to be a responsible steward and curtail the use of pesticides for turf, landscape, and outdoor pest management on County property, while maintaining safety for those who use or maintain County-owned public spaces, roadways, and parks. 

[The legislation sets out the stipulations of the federal National Organic Program (NOP), asserting that no synthetic pesticides and fertilizers may be used unless they are compatible with organic systems as permitted under NOP, with some specific exemptions. The sections of the federal code cited in the legislation, which detail such compatible materials, are found under the Title 7 Code of Federal Regulations: 205.601, 205.603, 205.605, and 205.606.] 

Scientific evidence in support of Maui's ordinance is overwhelming—the hearing record reflects this with cited scientific and regulatory documents—from the adverse effects of toxic pesticides and fertilizers on public health and the local ecosystem, the island's resilience in response to the climate crisis, and biodiversity decline. Pesticides are not safe just because they are registered by the U.S. Environmental Protection Agency (EPA); for example, the state of Hawai'i recognized phasing out the insecticide chlorpyrifos—a chemical allowed by EPA—because of the indisputable science on its brain-damaging effects to children.

Land management practices are effective without toxic pesticides and fertilizers. The Maui law advances a land management system, pest prevention, and proper fertilization by nurturing biodiversity and natural cycling of nutrients, recognizing that we can manage playing fields, park lands, and golf courses on Maui via a whole systems ecological approach.

The Parks Department was provided with a plan and the staff was provided with training for the management of several pilot sites (War Memorial Little League Field, Luana Gardens, Makana Park) by Beyond Pesticides. This information should have facilitated compliance with the 2021 Maui ordinance. A major tenet of success in implementing organic land management is the concept of replacing chemical-intensive management practices with the nurturing of healthy soils with a soil food web that provides nutrients through the breakdown of organic matter. 

As the report and training provided to the Parks Department says: 

The goal of a natural organic turf management program is to create turf that meets aesthetic site objectives while eliminating toxic and synthetic chemical inputs that may have adverse impacts on health, the environment, and soil biology. Additionally, the products and programs are designed to utilize materials and adopt cultural practices that will avoid problems associated with runoff or leaching of nutrients and pest control products into water bodies and groundwater. 

>> Urge your councilmember to protect Maui's residents and safeguard the groundbreaking ordinance preventing petrochemical pesticide and fertilizer use! Tell the Council to oppose Bill 131 and to send any legislation on this matter to the Water Authority, Social Services, and Parks Committee for consideration.

Image credit: Forest & Kim Starr, CC BY 3.0, via Wikimedia Commons. "Myoporum sandwicense (planting near path view baseball field). Location: Maui, Eddie Tam Makawao

The targets for this Action are Maui County Councilmembers and County Clerk. 

Thank you for your active participation and engagement!

***For nonresidents of Maui, please copy/paste the following and send an email to the Maui County Clerk at [email protected].

Letter to the Councilmembers and County Clerk:
I am writing to urge you to stop a proposal before the County Council on Friday, September 13, 2024 that will repeal Maui's ordinance to prevent the use of toxic pesticides and fertilizers in the management of playing fields and golf courses. In order to protect public health, mitigate the climate crisis, and curtail biodiversity collapse, now is not the time to backtrack and reverse course on the County law to eliminate petrochemical pesticides and fertilizers on Maui. 

Please send any legislation amending the pesticide ordinance relating to pesticide and fertilizer use to the Water Authority, Social Services, and Parks Committee for consideration.

When Maui County adopted the ordinance to transition away from toxic pesticide and fertilizer use in 2021, allowing only those materials permitted under federal organic law, it provided important leadership on a critical public health issue.

The ordinance codifies the values and principles of the elected officials on behalf of the people of Maui with the clarity of its commitment: 

The purpose of this ordinance is to prohibit the County's purchase or use of certain pesticides and fertilizers to safeguard the health and welfare of County of Maui employees, residents, and visitors; and to conserve and protect the County's waterways and natural resources.  

Scientific evidence in support of Maui's ordinance is overwhelming—the hearing record reflects this with cited scientific and regulatory documents—from the adverse effects of toxic pesticides and fertilizers.

Land management practices are effective without toxic pesticides and fertilizers. The Maui law advances a land management system, pest prevention, and proper fertilization by nurturing biodiversity and natural cycling of nutrients, recognizing that we can manage playing fields, park lands, and golf courses on Maui via a whole systems ecological approach.

The Parks Department was provided with a plan and the staff was provided with training for the management of several pilot sites (War Memorial Little League Field, Luana Gardens, Makana Park) by Beyond Pesticides. This information should have facilitated compliance with the 2021 Maui ordinance. A major tenet of success in implementing organic land management is the concept of replacing chemical-intensive management practices with the nurturing of healthy soils with a soil food web that provides nutrients through the breakdown of organic matter. 

As the report and training provided to the Parks Department says: 

The goal of a natural organic turf management program is to create turf that meets aesthetic site objectives while eliminating toxic and synthetic chemical inputs that may have adverse impacts on health, the environment, and soil biology. Additionally, the products and programs are designed to utilize materials and adopt cultural practices that will avoid problems associated with runoff or leaching of nutrients and pest control products into water bodies and groundwater. 

We can and must end our unnecessary reliance on petrochemical pesticides and fertilizers.

Thank you for your attention to this important matter.

The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by 11:59 PM EDT on September 30, 2024. This precedes the upcoming public comment webinar on October 15 and 17 and a deliberative board hearing on October 22-24—concerning how organic food is produced.

• • Sign up to speak at the webinar by 11:59 pm EDT on September 30. (Speaking slots are generally filled early.)
  • Written comments can be submitted via our form or directly through Regulations.gov.
  • Links to the virtual comment webinars and public meeting will be posted on this page 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. 

>> Click here to submit your comments to the National Organic Standard Board by September 30.

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 stay tuned for updates to our Fall 2024 issues page! 

Some priority issues for Beyond Pesticides at this meeting are: 

“Inert” ingredients used in organic production. USDA's National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection Agency (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.  

The Materials Subcommittee has proposed two options for addressing this problem.  

• • The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling. 
     
  • The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food and not adverse effects to the environment and workers, falling short of the holistic assessment required by the organic law. 

Compost regulations. The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. Beyond Pesticides supports the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a 'de minimis' doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.” 

Meloxicam in organic livestock. The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes to list the drug without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.”  

Beyond Pesticides opposes the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.  

We urge you to submit comments to the docket on the above issues and to add a sentence or two at the beginning of the comments explaining why organic is important to you! For those who prefer to copy and paste comments directly to Regulations.gov, please see a copy of our comments included below.

>> Click here to submit your comments to the National Organic Standard Board by September 30.

The target for this Action is the U.S. National Organic Standards Board, a federal advisory board of dedicated public volunteers from across the organic community under the U.S. Department of Agriculture's Agricultural Marketing Service.

Comments to the NOSB: Add a sentence introducing yourself and share why organic is important to you!

To the members of the NOSB, 

Please consider the following: 

“Inert” ingredients used in organic production. USDA’s National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is 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.   

The Materials Subcommittee has proposed two options for addressing this problem.   

*The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling.  

*The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food and not adverse effects to the environment and workers, falling short of the holistic assessment required by the organic law.  

Compost regulations. The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. I support the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a ‘de minimis‘ doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.”  

Meloxicam in organic livestock. The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes to list the drug without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.”   

I oppose the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.   

Thank you for your consideration of my comments. 

On Labor Day, we remind decision makers in our community of the importance of worker health as one foundational reason for stopping the use of toxic pesticides. This is a day of reflection and commitment to taking meaningful action for workers who serve our communities and are expected to handle toxic pesticides in the process. We can be a part of changing that expectation by stopping the use of toxic pesticides through the adoption of organic land management. In the process, we protect landscapers who are daily applying toxic pesticides and, in the process, protect children, pets, and biodiversity. We also protect those who produce, handle, transport, and dispose of the toxic pesticides used in chemical-intensive land management. 

Part of this Labor Day reminder includes the question: What can I do about the problem of pesticides in a regulatory and policy making climate that is unresponsive to the need for restrictions of toxic chemicals? Is it enough to advocate for the adoption of large-scale reforms—agreed by most health and environmental advocates to be necessary for worker and general health as well as environmental protection—when we know that achieving the necessary policy reforms may not be attainable in the near term? There is more we can do now.   

>> Tell your governor and mayor to exercise their leadership in recognizing and acting on the importance of worker health to eliminate pesticide use in your community and state.

For instance, we know that the only ethical policy for the regulation of toxic pesticides is a precautionary policy that restricts or eliminates uses based on the preponderance of scientific information. So, we call for policy change and action by regulators, the U.S. Congress, and state policy makers to keep these issues in front of them and to define the limitations of current policy to protect workers, the general public, and the environment. At the same time, in the absence of federal and state action, these actions help to frame what can and should be done locally by local governments, which are integral to decisions by individuals and households.  

For example, we can define the hazards of the weedkillers glyphosate (Roundup, see here and here) and atrazine, as well as neonicotinoid insecticides, and urge action at the federal and state level. But action can be taken now, in our communities, to: 

1. Stop parks departments, school districts, and households from using these toxic pesticides now. In the process, we are not waiting for the possibility of action by regulators to protect the workers who apply these chemicals and the communities and environment that are exposed. When a community or school district acts to stop toxic pesticide use and adopt organic land management practices, the first in line of exposure—those workers who handle the toxic materials—are protected; and 

2. Stop the purchasing by school cafeterias, religious institutions, civic clubs, and others of food grown with toxic pesticides now. In purchasing organic food, we are protecting those who grow and harvest our food, farmworkers. 

As we say on Labor Day, our communities must annually renew the commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color who suffer elevated levels of harm. We can do this through the adoption of local, state, and national policies that eliminate toxic pesticide use, which disproportionately affects workers. This is a moment for building coalitions in our communities to advance policies that ensure all aspects of a healthful life and environment, supported by our social structures. In doing this, we recognize that we must join together to build the necessary power to effect meaningful and transformational change. 

A note on toxic body burden. When it comes to the total amount of toxicants in our body (toxic body burden) from pesticide exposure, workers' occupational exposure to pesticides is not a part of the aggregate risk calculation (or cumulative risk calculation) that the U.S. Environmental Protection Agency (EPA) uses to determine allowable exposure. So, when we, a school district, a parks department, or a business purchase conventional food grown with chemical-intensive practices, we are supporting management practices that permit elevated, inadequately restricted exposure to those who grow our food or manage our parks and playing fields. When EPA was mandated by Congress in the 1996 Food Quality Protection Act (FQPA)—which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)—to start calculating real hazards from dietary and nondietary exposure, as a part of the pesticide registration process, the law explicitly did not, and still does not, require consideration of occupational exposure. 

***See Parks for a Sustainable Future for community assistance in converting parks to organic land management. 

>> >> Tell your governor and mayor to exercise their leadership in recognizing and acting on the importance of worker health to eliminate pesticide use in your community and state.

The targets for this Action are the U.S. state governors and U.S. mayors, as available dependent on residency.

Letter to the Mayor 

On Labor Day, I am writing to ask you to exercise your leadership in recognizing and acting on the importance of worker health as one foundational reason for stopping the use of toxic pesticides. This is a day of reflection and commitment to taking meaningful action for workers who serve our community and are expected to handle toxic pesticides in the process. We can be a part of changing that expectation by stopping the use of toxic pesticides through the adoption of organic land management. In the process, we protect landscapers who are daily applying toxic pesticides and, in the process, protect children, pets, and biodiversity. We also protect those who produce, handle, transport, and dispose of the toxic pesticides used in chemical-intensive land management. 

We can do this now.   

We would hope that federal and state policy would adopt the only ethical policy for the regulation of toxic pesticides, which is a precautionary policy that restricts or eliminates toxic chemical uses based on the preponderance of scientific information. However, in the absence of federal and state action in this regard, it falls to our local elected officials and local government to protect those employees in our community who are working with toxic chemicals.  

I am urging you to stop our parks department from using toxic pesticides now. When we as a community stop toxic pesticide use and adopt organic land management practices, the first in line of exposure—those workers who handle the toxic materials—are protected. We urge you to encourage the same for all school grounds and the cosmetic use of toxic pesticides on private property in our community.  

We also urge you to end town purchasing of food grown with toxic pesticides now. In purchasing organic food, we are protecting those who grow and harvest our food, farmworkers. We urge you to encourage school cafeterias, religious institutions, civic clubs, and others to do the same. 

As we say on Labor Day, our communities must annually renew the commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color who suffer elevated levels of harm. We can do this through the adoption of local policies and practices that eliminate toxic pesticide use, which disproportionately affects workers. 

Toxic Body Burden. When it comes to the total amount of toxicants in our body (toxic body burden) from pesticide exposure, workers’ occupational exposure to pesticides is not a part of the aggregate risk calculation (or cumulative risk calculation) that the U.S. Environmental Protection Agency (EPA) uses to determine allowable exposure. So, when we, a school district, a parks department, or a business purchase conventional food grown with chemical-intensive practices, we are supporting management practices that permit elevated, inadequately restricted exposure to those who grow our food or manage our parks and playing fields. When EPA was mandated by Congress in the 1996 Food Quality Protection Act (FQPA)—which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)—to start calculating real hazards from dietary and nondietary exposure, as a part of the pesticide registration process, the law explicitly did NOT, and still does not, require consideration of occupational exposure. 

Thank you for your consideration of my request. Happy Labor Day and thanks for your work. 

Letter to Governor

On Labor Day, I am writing to ask you to exercise your leadership in recognizing and acting on the importance of worker health as one foundational reason for stopping the use of toxic pesticides. This is a day of reflection and commitment to taking meaningful action for workers who serve our state and are expected to handle toxic pesticides in the process. We can be a part of changing that expectation by stopping the use of toxic pesticides through the adoption of organic land management. In the process, we protect landscapers who are daily applying toxic pesticides and, in the process, protect children, pets, and biodiversity. We also protect those who produce, handle, transport, and dispose of the toxic pesticides used in chemical-intensive land management. 

We can do this now.   

We would hope that federal policy would adopt the only ethical policy for the regulation of toxic pesticides, which is a precautionary policy that restricts or eliminates toxic chemical uses based on the preponderance of scientific information. However, in the absence of federal action in this regard, it falls to our state and local elected officials and state and local government to protect those employees in our state and community who are working with toxic chemicals.  

I am urging you to stop public parks management with toxic pesticides now. When we as a state stop toxic pesticide use and adopt organic land management practices, the first in line of exposure—those workers who handle the toxic materials—are protected. We urge you to advance policies that would do the same for all school grounds and the cosmetic use of toxic pesticides on privately held land statewide.  

We also urge you to end state institutional purchasing of food grown with toxic pesticides now. In purchasing organic food, we are protecting those who grow and harvest our food, farmworkers. We urge you to encourage school cafeterias, religious institutions, civic clubs, and others to do the same. 

As we say on Labor Day, our communities must annually renew the commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color who suffer elevated levels of harm. We can do this through the adoption of local policies and practices that eliminate toxic pesticide use, which disproportionately affects workers. 

Toxic Body Burden. When it comes to the total amount of toxicants in our body (toxic body burden) from pesticide exposure, workers’ occupational exposure to pesticides is not a part of the aggregate risk calculation (or cumulative risk calculation) that the U.S. Environmental Protection Agency (EPA) uses to determine allowable exposure. So, when we, a school district, a parks department, or a business purchase conventional food grown with chemical-intensive practices, we are supporting management practices that permit elevated, inadequately restricted exposure to those who grow our food or manage our parks and playing fields. When EPA was mandated by Congress in the 1996 Food Quality Protection Act (FQPA)—which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)—to start calculating real hazards from dietary and nondietary exposure, as a part of the pesticide registration process, the law explicitly did NOT, and still does not, require consideration of occupational exposure. 

Thank you for your consideration of my request. Happy Labor Day and thanks for your work. 

Considering widespread insecticide spraying for eastern equine encephalitis (EEE) spread by mosquitoes, Beyond Pesticides is calling on the Governor to adopt an ecologically-based mosquito management plan that acknowledges both the threat of EEE and health and environmental harm associated with pesticide exposure.  

[In Massachusetts, the group calls the widespread aerial application of toxic substances antithetical to the state's current development of Biodiversity Conservation Goals, recognizing the cascading crises of biodiversity, public health, and climate change. The state is accepting public comments on the Goals until August 30.] 

“Given the hazards associated with EEE and the pesticides used to combat infected mosquitoes, state and local officials must commit to a rigorous community-based education program to eliminate breeding sites and use of repellents,” said Jay Feldman, executive director of Beyond Pesticides. 

>> Tell your Governor that emergency spray programs will continue unless they tackle the root causes of mosquito breeding and move to adopt ecological mosquito management to prevent the need for toxic pesticide spraying!

Spraying pesticides for adult mosquito control is the least effective method for managing these insects, according to mosquito management experts. Instead, communities, such as Boulder, Colorado, recognized the value of mosquito prevention programs in sync with nature. Beyond Pesticides advocates the adoption of a comprehensive mosquito prevention plan with the following elements: 

1. Preventive actions that manage mosquitoes at their breeding sites; 
2. Larviciding with biological materials; 
3. Surveillance of insects to determine the threat of disease transmission; 
4. Spraying for adult mosquitoes (adulticiding) as a last resort after documentation of previous actions and a finding that preventive actions and larviciding did not meet thresholds of managing infected mosquitoes, with a provision for residents to opt-out; and 
5. Public disclosure and prenotification of spray schedules and pesticide formulations used. 

This week, the Division of Crop and Pest Services in the MA Department of Agriculture announced that aerial spraying would begin in parts of Plymouth County and truck-based spraying in Worcester County on the evening of August 27, and several following days, after the presence of positive mosquito samples for a rare, yet dangerous, EEE. It has been four years since the last EEE detection led to seven deaths and 17 cases in the same counties, leading to the use of Anvil 10+10—a neurotoxic insecticide used in mosquito management.  

While recognizing the public health threat and the need to act, advocates, beekeepers, farmers, and community leaders are deeply concerned at the lack of preventive measures and consideration of ecologically-based mosquito control. 

According to an MDAR Crop and Pest Services 2019 summary report, spraying this product lasted 26 days, treated over 2,048,865 acres across the Commonwealth, and used 9,939 gallons on Anvil 10+10. The product was also applied by air in 2006, 2010, and 2012. The main active ingredients, sumithrin (synthetic pyrethroid insecticide) and piperonyl butoxide/PBO (synergist), have been linked to a range of adverse health effects in humans, including a higher risk of liver disease—which is a tragic irony given that the liver is the primary organ meant to filter out toxic residues including pesticides. These ingredients are also linked to cancer, confirmed neurotoxic and kidney damage, and threats to reproductive health and endocrine disruption. 

Mosquito resistance is also a major concern. Recent studies, including one published in PLOS One earlier this month, found documented proof of resistance to the pyrethroid permethrin in Aedes aegypti in both Spain and Colombia, building on existing research finding pyrethroid resistance through permethrin in mosquito samples collected in Waltham, MA—the county next to Worcester. 

As mentioned in a 2019 petition—led by Public Employees for Environmental Responsibility (PEER), LEAD for Pollinators, and Jones River Watershed Association—to the Commonwealth's Office of Inspector General, State Auditor, and Attorney General, “Agencies conducted three aerial spray events from September 10, 2019 through September 24, 2019, costing Massachusetts taxpayers over $2.2 million, despite the fact that they knew there were no mosquitoes out, and that spraying after the first week of September would result in low efficacy.” 

Anvil 10+10 has also been under major scrutiny after the detection of “forever chemicals,” or PFAS in the products' containers, in a test commissioned by PEER and confirmed by the MA Department of Environmental Protection and the U.S. Environmental Protection Agency (EPA). [See here, here, and here for Beyond Pesticides' Daily News coverage.]  

>> Tell your Governor that emergency spray programs will continue unless they tackle the root causes of mosquito breeding and move to adopt ecological mosquito management to prevent the need for toxic pesticide spraying!

Sumithrin (d-Phenothrin) exposure can result in lung irritation and has been documented to cause asthmatic responses in those exposed. The label for Anvil 10+10 provides a box with a “Note to Physician: Contains petroleum distillate—vomiting may cause aspiration pneumonia.”  

Anvil 10+10 is not a singular ingredient. It is a formulation that also contains piperonyl butoxide (PBO), a chemical listed as an active ingredient but is intended to perform the role of “synergist,” increasing the potency and toxicity of the active ingredient. EPA considers PBO a possible human carcinogen. In addition to the respiratory irritant sumithrin and the possible carcinogen PBO, Anvil 10+10 contains “other ingredients” that are not listed, yet comprise 80% of the product formulation.  

All mosquitoes go through a complicated life cycle called “complete metamorphosis.” According to the American Mosquito Control Association, complete metamorphosis involves four distinct stages – egg, larva, pupa, and adult. The length of time each stage lasts depends on several variables, with temperature having the greatest impact. Eggs are laid in “rafts” on standing bodies of water. The eggs require one to two days in water before hatching into larvae. Larvae, or wrigglers, molt three times during ten to twelve days before pupating. Pupae, or tumblers, metamorphose over one to two days into adults. Adults emerge from their pupal cases approximately twelve to sixteen days after egg laying. A stepwise approach as referenced above considers reduction strategies for further reproduction of mosquitoes before spraying toxic pesticides due to the proliferation of adult insects becomes “necessary” for public health. 

Mosquito-eating birds and organisms are under threat, including many well-known residents of our communities. 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 of 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. 

Beyond Pesticides developed a Public Health Mosquito Management Strategy to advise decision makers and communities based on technical assistance provided by public health officials, environmental health groups, and mosquito control officers. On a personal level, you can nurture a safe haven for birds and other mosquito predators. 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 your Governor that emergency spray programs will continue unless they tackle the root causes of mosquito breeding and move to adopt ecological mosquito management to prevent the need for toxic pesticide spraying.

***For more information, please see Beyond Pesticides' press release here.

The Targets for this Action are the U.S. Governors of the Commonwealth of Massachusetts, the State of New Hampshire, and the State of Rhode Island. ***Additional states to be considered for future Action. 

Thank you for your active participation and engagement! The Action is a multi-step process, so please click submit below to proceed to step two. 

Letter to the MA Governor: 

Considering widespread insecticide spraying for eastern equine encephalitis (EEE) spread by mosquitoes across Massachusetts, I am calling on you to adopt an ecologically-based mosquito management plan that acknowledges both the threat of EEE and health and environmental harm associated with pesticide exposure. Beyond Pesticides calls the widespread aerial application of toxic substances antithetical to the state’s current development of Biodiversity Conservation Goals, recognizing the cascading crises of biodiversity, public health, and climate change. The state is accepting public comments on the Goals until August 30.  

“Given the hazards associated with EEE and the pesticides used to combat infected mosquitoes, state and local officials must commit to a rigorous community-based education program to eliminate breeding sites and use of repellents,” as Beyond Pesticides has said. 

Spraying pesticides for adult mosquito control is the least effective method for managing these insects, according to mosquito management experts. Instead, communities, such as Boulder, Colorado, recognized the value of mosquito prevention programs in sync with nature. Beyond Pesticides advocates the adoption of a comprehensive mosquito prevention plan with the following elements: 

1. Preventive actions that manage mosquitoes at their breeding sites, 

1. Larviciding with biological materials,  

1. Surveillance of insects to determine the threat of disease transmission,  

1. Spraying for adult mosquitoes (adulticiding) as a last resort after documentation of previous actions and a finding that preventive actions and larviciding did not meet thresholds of managing infected mosquitoes, with a provision for residents to opt-out, and 

1. Public disclosure and prenotification of spray schedules and pesticide formulations used. 

While recognizing the public health threat and the need to act, advocates, beekeepers, farmers, and community leaders are deeply concerned at the lack of preventive measures and consideration of ecologically-based mosquito control. 

The main active ingredients, sumithrin (synthetic pyrethroid insecticide) and piperonyl butoxide/PBO (synergist) have been linked to a range of adverse health effects in humans, including a higher risk of liver disease—which is a tragic irony given that the liver is the primary organ meant to filter out toxic residues including pesticides. These ingredients are also linked to cancer, confirmed neurotoxic and kidney damage, and threats to reproductive health and endocrine disruption. Piperonyl butoxide (PBO) specifically is a chemical listed as an active ingredient but is intended to perform the role of “synergist,” increasing the potency and toxicity of sumithrin. The U.S. Environmental Protection Agency considers PBO a possible human carcinogen. In addition to the respiratory irritant sumithrin and the possible carcinogen PBO, Anvil 10+10 contains “other ingredients” that are not listed, yet comprise 80% of the product formulation.   

Anvil 10+10 has also been under major scrutiny after the detection of “forever chemicals,” or PFAS in the products’ containers, in a test commissioned by PEER and confirmed by the MA Department of Environmental Protection and the U.S. Environmental Protection Agency. 

Mosquito resistance is also a major concern. Recent studies, including one published in PLOS One earlier this month, found documented proof of resistance to the pyrethroid permethrin in Aedes aegypti in both Spain and Colombia, building on existing research finding pyrethroid resistance through permethrin in mosquito samples collected in Waltham, MA. 

A stepwise approach as referenced above considers reduction strategies for further reproduction of mosquitoes before spraying toxic pesticides due to the proliferation of adult insects becomes “necessary” for public health.  

Thank you for your consideration. 

Letter to non-MA Governors (NH, RI): 

Considering widespread insecticide spraying for eastern equine encephalitis (EEE) spread by mosquitoes, I am calling on you to adopt an ecologically-based mosquito management plan that acknowledges both the threat of EEE and health and environmental harm associated with pesticide exposure.  

“Given the hazards associated with EEE and the pesticides used to combat infected mosquitoes, state and local officials must commit to a rigorous community-based education program to eliminate breeding sites and use of repellents,” as Beyond Pesticides has said. 

Spraying pesticides for adult mosquito control is the least effective method for managing these insects, according to mosquito management experts. Instead, communities, such as Boulder, Colorado, recognized the value of mosquito prevention programs in sync with nature. Beyond Pesticides advocates the adoption of a comprehensive mosquito prevention plan with the following elements: 

1. Preventive actions that manage mosquitoes at their breeding sites, 
2. Larviciding with biological materials,  
3. Surveillance of insects to determine the threat of disease transmission,  
4. Spraying for adult mosquitoes (adulticiding) as a last resort after documentation of previous actions and a finding that preventive actions and larviciding did not meet thresholds of managing infected mosquitoes, with a provision for residents to opt-out, and 
5. Public disclosure and prenotification of spray schedules and pesticide formulations used. 

While recognizing the public health threat and the need to act, advocates, beekeepers, farmers, and community leaders are deeply concerned at the lack of preventive measures and consideration of ecologically-based mosquito control. 

The main active ingredients, sumithrin (synthetic pyrethroid insecticide) and piperonyl butoxide/PBO (synergist) have been linked to a range of adverse health effects in humans, including a higher risk of liver disease—which is a tragic irony given that the liver is the primary organ meant to filter out toxic residues including pesticides. These ingredients are also linked to cancer, confirmed neurotoxic and kidney damage, and threats to reproductive health and endocrine disruption. Piperonyl butoxide (PBO) specifically is a chemical listed as an active ingredient but is intended to perform the role of “synergist,” increasing the potency and toxicity of sumithrin. The U.S. Environmental Protection Agency considers PBO a possible human carcinogen. In addition to the respiratory irritant sumithrin and the possible carcinogen PBO, Anvil 10+10 contains “other ingredients” that are not listed, yet comprise 80% of the product formulation.   

Anvil 10+10 has also been under major scrutiny after detection of “forever chemicals,” or PFAS in the products’ containers, in test commissioned by PEER and confirmed by the MA Department of Environmental Protection and the U.S. Environmental Protection Agency. 

Mosquito resistance is also a major concern. Recent studies, including one published in PLOS One earlier this month, found documented proof of resistance to the pyrethroid permethrin in Aedes aegypti in both Spain and Colombia, building on existing research finding pyrethroid resistance through permethrin in mosquito samples collected in Waltham, MA. 

A stepwise approach as referenced above considers reduction strategies for further reproduction of mosquitoes before spraying toxic pesticides due to the proliferation of adult insects becomes “necessary” for public health.  

Thank you for your consideration. 

***Due to the importance of the Dacthal decision, we are providing an extended analysis below for those who wish to delve deep into the issue. To skip to the Action form, please click here or on the "Action links" (>>) included below!

While the Environmental Protection Agency (EPA) received accolades for its August 7, 2024, decision to ban the herbicide Dacthal (or DCPA--dimethyl tetrachloroterephthalate), it also leaves many people asking, “Why Dacthal and not other very hazardous pesticides?” The weed killer atrazine (in the triazine chemical family), for example, poses similar elevated hazards to people and the environment, has proven to be impossible to contain, and has viable alternatives. Therefore, we need to challenge EPA to apply the same standard that removed Dacthal from the market to the long list of pesticides that are contributing to a health crisis, biodiversity collapse, and the climate emergency. 

Exposure to atrazine, manufactured by Syngenta, is widespread in the environment. According to EPA, “Pesticide products containing atrazine are registered for use on several agricultural crops, [including] field corn, sweet corn, sorghum, and sugarcane, []wheat, macadamia nuts, and guava, as well as non-agricultural uses such as nursery/ornamental and turf.” It is the second most widely used herbicide in the U.S. after glyphosate (found in Roundup), but banned in the European Union in 2004 and in over 40 countries worldwide. Many organizations have called for the chemical to be banned in the U.S. and have joined in litigation against EPA. 

In the case of Dacthal, EPA used the “imminent hazard” clause of the federal pesticide law to immediately suspend the chemical's use. At the same time, the agency is exercising its authority to prohibit the continued use of Dacthal's existing stocks, a power that EPA rarely uses. The last time EPA issued an emergency action like this was in 1979 when the agency acknowledged miscarriages associated with the forestry use of the herbicide 2,4,5-T—one-half of the chemical weed killer Agent Orange, sprayed over people to defoliate the landscape of Vietnam in the war there—with the most potent form of dioxin, TCDD (2,3,7,8-Tetrachlorodibenzo-p-dioxin). The chemical manufacturer of Dacthal, AMVAC Chemical Corporation, can challenge the agency's findings under the law and seek court review, but EPA's action takes effect immediately while any appeal is considered. Meanwhile, EPA has stopped use under 7 U.S.C. 136 et seq., pursuant to section 6(c)(3) (7 U.S.C. 136d(c)(3)). (See Unit IV.) The prohibition on the use of existing stocks is mandated under Section 6(a)(1). 

>> EPA must apply the standard of the Dacthal decision to atrazine and issue an emergency suspension and prohibit use of existing stocks.

The timeline for review and action on individual pesticides has taken decades since the 1972 overhaul of nation's pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The law's risk-benefit standard allows for high levels of harm, especially to farmworkers and those handling pesticides, as well as public exposure through residues in food, water, and air. EPA's decisions are based on agency risk assessments that use flawed assumptions and ignore vulnerable populations like children and those with preexisting health conditions—like cancer, endocrine system disruption, neurological illness, and other health effects that are exacerbated by exposure. Amendments to FIFRA in 1996, in the Food Quality Protection Act (FQPA), have done little to reduce the ongoing reliance on toxic chemicals in food production and land management, despite the growth of the $70 billion organic industry—still not considered by EPA as a legitimate alternative to be evaluated when determining the “reasonableness” or “acceptability” of risk under pesticide law. Instead, EPA calculates acceptability of risk in the context of available alternative chemicals. In its press release on the Dacthal decision, EPA said, “In deciding whether to issue today's Emergency Order, EPA consulted with the U.S. Department of Agriculture to understand how growers use DCPA and alternatives to this pesticide.” The agency's consultation with USDA evaluated alternative chemicals, not alternative organic management systems and organic-compatible substances. 

The current mechanism that EPA uses to restrict pesticides—negotiated settlements instead of regulatory action—compromises the health of people and the environment, often disproportionately for people of color and workers, who are the first to be exposed as applicators or agricultural workers. Could the Dacthal decision be a watershed moment to change a regulatory process that allows daily pesticide exposure, poisoning, and contamination at rates that EPA deems acceptable—despite the overwhelming science linking real-world pesticide use (homes, parks and playing fields, schools, and farms) to dreaded illnesses, biodiversity collapse, and the climate crisis? (See Pesticide-Induced Diseases Database and the Pesticide Gateway.) 

In making its decision to ban Dacthal, EPA states that it considered: 

1. The seriousness of the threatened harm; 
2. The immediacy of the threatened harm; 
3. The probability that the threatened harm will occur; 
4. The benefits to the public of the continued use of the pesticide; and 
5. The nature and extent of the information before the Agency at the time it makes a decision. 

These criteria could be met for most of the pesticides for which EPA has negotiated settlements with pesticide manufacturers, resulting in partial withdrawals of pesticides from the market and compromises that threaten health and the environment. 

Based on the reasoning in the Dacthal decision, EPA should ban atrazine. 

Atrazine poses immediate serious harms to people and the environment. 
Registration of the endocrine-disrupting herbicide propazine (in the triazine family of frog-deforming endocrine disruptors) was canceled by EPA, eliminating use of the hazardous herbicide by the end of 2022. However, all pesticides in the triazine class, including atrazine and simazine, have similar properties and should be eliminated from use. 

Under an Endangered Species Act review, initiated by EPA only after a lawsuit from health and environmental groups, the triazine chemicals were found to adversely affect a range of species. Propazine was found to harm 64 endangered species, while simazine and atrazine were both likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds, “aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates.” In addition, evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine. 

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

Atrazine has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia (where nasal passages are blocked at birth), and hypospadias (where the opening of a male's urethra is not located at the tip of the penis). The mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH), which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset. 

Despite these endocrine-disrupting effects, EPA reduces the margin of safety and underestimates exposure to children. 

>> EPA must apply the standard of the Dacthal decision to atrazine and issue an emergency suspension and prohibit use of existing stocks. 

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

Although a hefty 200,000 lbs. of propazine were used each year, mainly on sorghum in Texas, Oklahoma, and Kansas, this amount pales in comparison to the over 70 million lbs. of atrazine used throughout the United States. Under an Endangered Species Act review, initiated by EPA only after a lawsuit from health and environmental groups, the triazine chemicals were found adversely affect a range of species. Propazine was found to harm 64 endangered species, while simazine and atrazine were both likely to harm over 50% of all endangered species and 40% of their critical habitats. 

The public does not benefit from continued registration of atrazine. 
While industry consistently lines up local Congressmembers, former EPA officials, and agrichemical lobbyists to pressure EPA to keep triazines in the market, there is no evidence that the herbicides benefit the farmers these officials claim to represent. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would provide an economic benefit to farmers. “The winners,” the research concludes, “in an atrazine free future would include farm workers, farmers and their families, and others who are exposed to atrazine either directly from field uses or indirectly from contaminated tap water along with natural ecosystem that are currently damaged by atrazine.”  

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

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

The Draft Ecological Risk Assessments for the Registration Review of Atrazine, Simazine, and Propazine, dated October 5, 2016, found high risks that were supported by EPA's assessments. EPA states, “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates in these same locations. In the terrestrial environment, there are risk concerns for mammals, birds, reptiles, plants and plant communities across the country for many of the atrazine uses. EPA levels of concern for chronic risk are exceeded by as much as 22, 198, and 62 times for birds, mammals, and fish, respectively. For aquatic phase [stage] amphibians, a weight of evidence analysis concluded there is potential for chronic risks to amphibians based on multiple effects endpoint concentrations compared to measured and predicted surface water concentrations. The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift. Average atrazine concentrations in water at or above 5 μg/L for several weeks are predicted to lead to reproductive effects in fish, while a 60-day average of 3.4 μg/L has a high probability of impacting aquatic plant community primary productivity, structure and function.”  

The agency acknowledges many risks of concern associated with the uses of atrazine, but asserts the serious worker and ecological risks remaining after adoption of all proposed mitigation measures are outweighed by the benefits of atrazine use. EPA has determined that the chlorotriazines (triazines) and their three chlorinated metabolites share a common mechanism of toxicity, and as such, human health risks were assessed together through a triazine cumulative risk assessment. The mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH), which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset. Importantly, this perturbation manifests after a short duration exposure with long-term life-cycle consequences, so it establishes both acute and chronic toxicity levels of concern (LOCs). 

Toxicity and exposure data available to EPA are sufficient to demonstrate that several atrazine uses exceed risk levels of concern. Exposures to children 1-2 years old playing on turf sprayed with atrazine exceed a risk estimate of concern for combined dermal and incidental oral exposures when assuming the maximum labeled rate for spray applications (2.0 lb ai/A). However, a screening aggregate assessment without the FQPA required safety factor was performed assuming that the application rate for turf is reduced to 1.0 lb ai/A, which would not be of concern for 4-day aggregate exposures. Even with this rate reduction, it can be presumed children are still at serious risk. For occupational handlers, EPA identified use scenarios that exceed risk concerns even with the maximum available personal protective equipment and/or engineering controls (proposed mitigation measures). 

Here is how EPA describes its truncated process for DCPA: 

In 2013, the agency issued a Data Call-In (DCI) to AMVAC Chemical Corporation, the sole manufacturer of DCPA, requiring it to submit more than 20 studies to support the existing registrations of DCPA. The required data included a comprehensive study of the effects of DCPA on thyroid development and function in adults and in developing young before and after birth, which was due by January 2016. Several of the studies that AMVAC submitted from 2013-2021 were considered insufficient to address the DCI, while the thyroid study and other studies were not submitted at all. 

In April 2022, EPA issued a very rarely used Notice of Intent to Suspend the DCPA technical-grade product (used to manufacture end-use products) based on AMVAC's failure to submit the complete set of required data for almost 10 years, including the thyroid study. While AMVAC submitted the required thyroid study in August 2022, EPA suspended the registration based solely on AMVAC's continued failure to submit other outstanding data on Aug. 22, 2023, following an administrative hearing.  In November 2023, the data submission suspension was lifted after AMVAC submitted sufficient data. Most DCPA use on turf was voluntarily canceled by AMVAC in December 2023, but unacceptable risks from other uses remained. 

As society and the global community struggle with petrochemical pesticides and their contribution to health threats, biodiversity collapse, and the climate emergency, EPA must acknowledge that Dacthal is one active ingredient among over 1,000 in 56,000 pesticide products whose uses can be eliminated by the use of organic systems that have now been shown to be effective.  

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

By 2032, all petrochemical pesticides must be phased out and replaced by organic systems and substances compatible with the protection of health and the environment and a livable future. 

>> EPA must apply the standard of the Dacthal decision to atrazine and issue an emergency suspension and prohibit use of existing stocks.

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

Letter to EPA: 

I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. The weed killer atrazine fits the criteria used to ban Dacthal and it too should be banned immediately.  

In deciding to ban Dacthal, EPA says it considered the seriousness, immediacy, and likelihood of the threatened harm; benefits to the public of continued use; and nature and extent of the information before EPA. 

Atrazine poses immediate serious harms to people and the environment. Under an Endangered Species Act review, the triazines were found to adversely affect many species. Atrazine is likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds impacts on aquatic and terrestrial ecology. Evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine. 

Atrazine also poses significant threats to human health. It has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia and hypospadias. The mechanism of toxicity—perturbation of the neuroendocrine system—results in reproductive and developmental alterations.  

Mitigation measures have not eliminated harm. In typical fashion, EPA proposed minor label changes to mitigate risks identified in its registration review, deciding not out of concerns relating to human health and environmental protection, but to provide “regulatory certainty” for farmers and local officials. Environmental and health harms continue. 

The public does not benefit from continued use of atrazine. There is no evidence that atrazine benefits farmers. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would economically benefit farmers. Claims that losing atrazine will lead to reduced corn yields and increased prices have been refuted by these researchers. Because much of the corn grown in the U.S. is intended for ethanol producers and livestock feed, corn prices are heavily determined by the demand from these two sectors, compared to production costs.  

Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.”  

EPA has sufficient information to ban atrazine. EPA has long known about atrazine’s threats to wildlife, including its ability to chemically castrate male frogs. EPA’s ecological risk assessment found high risks: “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates. . . The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift.”  

EPA has determined that the triazines and their chlorinated metabolites share a common mechanism of toxicity—perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary—leading to a disturbance in the ovulatory surge of luteinizing hormone, resulting in reproductive and developmental alterations. These risks exceed levels of concern, including children and workers.  

Please apply the standard of the Dacthal decision to atrazine. Issue an emergency suspension and prohibit use of existing stocks. 

Thank you. 

Letter to U.S. Representative and Senators: 

I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks.  The weed killer atrazine fits the criteria used to ban Dacthal and it too should be banned immediately.  

In deciding to ban Dacthal, EPA says it considered the seriousness, immediacy, and likelihood of the threatened harm; benefits to the public of continued use; and nature and extent of the information before EPA. 

Atrazine poses immediate serious harms to people and the environment. Under an Endangered Species Act review, the triazines were found to adversely affect many species. Atrazine is likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds impacts on aquatic and terrestrial ecology. Evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine. 

Atrazine also poses significant threats to human health. It has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia and hypospadias. The mechanism of toxicity—perturbation of the neuroendocrine system—results in reproductive and developmental alterations.  

Mitigation measures have not eliminated harm. In typical fashion, EPA proposed minor label changes to mitigate risks identified in its registration review, deciding not out of concerns relating to human health and environmental protection, but to provide “regulatory certainty” for farmers and local officials. Environmental and health harms continue. 

The public does not benefit from continued use of atrazine. There is no evidence that atrazine benefits farmers. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would economically benefit farmers. Claims that losing atrazine will lead to reduced corn yields and increased prices have been refuted by these researchers. Because much of the corn grown in the U.S. is intended for ethanol producers and livestock feed, corn prices are heavily determined by the demand from these two sectors, compared to production costs.  

Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.”  

EPA has sufficient information to ban atrazine. EPA has long known about atrazine’s threats to wildlife, including its ability to chemically castrate male frogs. EPA’s ecological risk assessment found high risks: “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates. … The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift.”  

EPA has determined that the triazines and their chlorinated metabolites share a common mechanism of toxicity—perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary—leading to a disturbance in the ovulatory surge of luteinizing hormone, resulting in reproductive and developmental alterations. Data available to EPA demonstrate that several atrazine uses exceed risk levels of concern, including children and workers.  

Tell EPA to apply the standard of the Dacthal decision consistently—to ban atrazine.  

Thank you. 

Organic agriculture in the United States started in the 1940s as a movement of concerned citizens, environmentalists, and farmers. The organic movement in the U.S. was spearheaded by J.I. Rodale, founder of Rodale Press and Rodale Institute (originally Soil and Health Foundation), who was influenced by earlier pioneers including indigenous peoples, George Washington Carver, Lady Eve Balfour in England, Sir Albert Howard in India, and Rudolf Steiner of Austria.  Rodale's interest in promoting a healthy and active lifestyle that emphasized organically grown foods led him to establish the Rodale Organic Gardening Experimental Farm in 1940 and start publishing Organic Farming and Gardening magazine in 1942.

Interest in organic food and organic farming grew in the 1960s after the publication of Silent Spring increased public awareness of the dangers of toxic pesticides, promoted by Rodale's belief that farming practices focused on cultivating healthy soil would lead to healthier foods, and ultimately, healthier people as well. Since then, organic practices have been shown to also have beneficial impacts on biodiversity and climate. The notion of building soil, which is foundational to organic and certified organic production to this day, replaced the reliance on toxic petrochemical pesticides and fertilizers. 

During the 1980s, momentum grew toward codifying principles of organic to not only protect organic consumers, but also reverse pesticide dependency and its resulting impacts from toxic chemical contamination. That momentum culminated in the passage of the Organic Foods Production Act of 1990 (OFPA). That “organic” belongs to the movement of organic farmers, consumers and public interest organizations, environmentalists, scientists, handlers, retailers, and certifiers, was recognized in the guiding role OFPA gives to the National Organic Standards Board (NOSB) consisting of representatives of those groups. While the foundation of organic is strong in rejecting materials and practices that are harmful to biological systems, there are ongoing efforts regarding organic standards and certification at the U.S. Department of Agriculture (USDA) and large agricultural interests that have the effect, whether intentional or not, of undermining public trust in the organic label.  

>>Tell USDA that organic agriculture must require practices that build soil and raise animals on pasture, so hydroponics and concentrated animal feeding operations (CAFOs) should not be certified. Tell Congress to support increased funding for the Organic Certification Cost Share Program.

National Organic Standards Board and key issues. Just as the NOSB shows that organic belongs to the organic community and is not just a premium brand, it is the disempowering of the NOSB that marks the theft of organic. Although members of the NOSB are meant to represent various sectors of the organic community, it is USDA, not the organic community, who selects members of the board. When USDA redefined the requirement to reevaluate allowed synthetic substances in organic production and processing—the “sunset” provision—it weakened the default assumption that synthetic substances (on a five-year review cycle) are removed from the National List of Allowed and Prohibited Substances unless a supermajority of the board agreed on its relisting. It redefined “sunset,” defying its common meaning, to retain a listing unless a supermajority votes to remove it. USDA denies the primary principle of organic agriculture—the critical importance of soil health—by allowing hydroponics to be certified organic. It has also allowed certified livestock producers to confine animals for extended periods of time, without showing necessity, in concentrated animal feeding operations (CAFOs). 

Certification of organic practices. A less obvious way that organic is being stolen is the way certification is currently managed. OFPA allows USDA leeway in the structure of the certification system. USDA's approach results in inconsistency and “certifier shopping.” Certifying agents are private businesses that collect fees for the service from the certified producer or handler and have an incentive to give their customers (producers) what they want—hence, some certifiers (but not all) certify “organic” hydroponic or CAFO operations. Other ways of structuring organic certification that have been suggested by the Northeast Organic Dairy Producers Association and André Leu of Regeneration International have not been adopted in the U.S. In the short-term, one way of offsetting the costs of certification is the Organic Certification Cost Share Program. In the long-term, it must be recognized that organic agriculture performs a social good in saving the earth and therefore certification must be subsidized.

Solving existential crises. Chemical-intensive agriculture is a major contributor to climate change and biodiversity loss. Its dependence on toxic pesticides and chemical fertilizers results in human disease and contamination of air, land, and water. Organic agriculture can reverse or mitigate all these problems—as long as it is the organic as originally conceived, embodying the four principles of organic agriculture, as stated by Regeneration International, that are essential in determining whether practices are regenerative or degenerative. 

• Health: Organic agriculture should sustain and enhance the health of soil, plant, animal, human, and planet as one and indivisible. 

• Ecology: Organic agriculture should be based on living ecological systems and cycles, work with them, emulate them and help sustain them. 

• Fairness: Organic agriculture should build on relationships that ensure fairness with regard to the common environment and life opportunities. 

• Care: Organic agriculture should be managed in a precautionary and responsible manner to protect the health and well-being of current and future generations and the environment. 

As organic is being attacked, it continues to help mitigate the crises in public health, climate, and biodiversity by providing: 

• A definition of organic agriculture that defines health-biodiversity-climate friendly practices; 

• A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests; 

• A rigorous process for an allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list; 

• A third-party certification and enforcement system; 

• A process for public participation to ensure a feedback loop for continuous improvement; and

• Funding to ensure elements are carried out in a robust way. 

Taking Back Organic Principles and Practices. However, the problems identified above have prompted some in the organic community to “add-back” or “add-on” to current USDA standards by defining and certifying “real organic” or “regenerative organic.” And now, the same chemical-intensive agriculture interests are trying to hijack the term “regenerative,” which was coined by Robert Rodale “to describe a holistic approach to farming that encourages continuous innovation and improvement of environmental, social, and economic measures.” The word “regenerative” is now used loosely by many who promote minor improvements in agriculture, such as reduced tillage and cover crops. However, when confronted with a definition that allows use of pesticides and chemical fertilizers, it is important to keep in mind what Jeff Moyer, emeritus director of the Rodale Institute who introduced Regenerative Organic Certification (ROC), has aptly stated, "We believe that in order to be regenerative, you have to start by being organic. It's a little disingenuous to say you can regenerate soil health and sequester carbon and still use nitrogen fertilizers and synthetic pesticides. What you're really saying is equivalent to saying, 'I want to be healthy as a person, but I still want to smoke cigarettes.'"   

It is time to reclaim organic from the chemical interests that are in the process of stealing it—and prevent “regenerative,” integral to organic, from being stolen as well. Regenerative organic agriculture—and regenerative must always start with organic—is our hope for mitigating and reversing the damage inflicted on the Earth and her inhabitants by chemical-intensive agriculture. 

>>Tell USDA that organic agriculture must require practices that build soil and raise animals on pasture, so hydroponics and CAFOs should not be certified. Tell Congress to support increased funding for the Organic Certification Cost Share Program.

The targets for this Action are the U.S. Department of Agriculture, the U.S. Department of Agriculture National Organic Program, and the U.S. Congress. 

Letter to USDA Secretary Tom Vilsack and NOP Deputy Administrator Jennifer Tucker: 

Organic agriculture in the United States began in the 1940s as a movement of concerned citizens, environmentalists, and farmers, spearheaded by J.I. Rodale, founder of Rodale Press and Rodale Institute (originally Soil and Health Foundation). Rodale’s interest in promoting a healthy lifestyle emphasizing organically grown foods led him to establish the Rodale Organic Gardening Experimental Farm in 1940 and start Organic Farming and Gardening magazine in 1942. 

Interest in organic farming and food grew in the 1960s as the publication of Silent Spring increased awareness of the dangers of toxic pesticides, furthered by Rodale’s belief that farming practices focused on cultivating healthy soil lead to healthier foods and healthier people. Since then, organic practices have been shown to have beneficial impacts on biodiversity and climate. 

During the 1980s, momentum grew towards codifying principles of organic to not only protect organic consumers but also reverse pesticide dependency and its resulting impacts. That momentum culminated in the passage of the Organic Foods Production Act of 1990 (OFPA). That “organic” belongs to the movement of organic farmers, consumers and public interest organizations, environmentalists, scientists, handlers, retailers, and certifiers, was recognized in the guiding role OFPA gives to the National Organic Standards Board (NOSB) consisting of representatives of those groups. 

Just as the NOSB shows that organic belongs to the organic community, the disempowering of the NOSB marks the theft of organic. Although members of the NOSB represent various sectors of the organic community, USDA, not the organic community, selects members of the board. USDA’s unilateral redefinition of “sunset”—so that, in re-evaluating synthetic materials allowed in organic, they are now presumed to be renewed, contrary to the meaning of “sunset” in every other legal setting. 

USDA denies the primary principle of organic agriculture—the critical importance of soil health—by allowing hydroponics to be certified organic. It has also allowed certified livestock producers to confine animals for extended periods of time in concentrated animal feeding operations (CAFOs). 

OFPA allows USDA leeway in the structure of the certification system, and USDA’s approach results in inconsistency and “certifier shopping.” Certifying agents are private businesses that collect fees for the service from the certified producer and have an incentive to give their customers what they want—hence, some certifiers (but not all) certify “organic” hydroponic or CAFO operations. Other ways of structuring organic certification should be considered. In the short-term, the Organic Certification Cost Share Program may offset costs. 

Chemical-intensive agriculture is a major contributor to climate change and biodiversity loss. Its dependence on toxic pesticides and chemical fertilizers results in human disease and environmental contamination. Organic agriculture can reverse or mitigate all these problems—if it is organic as originally conceived. 

As the problems identified above have prompted some in the organic community to separate themselves from USDA by defining and certifying “real organic” or “regenerative organic,” chemical-intensive agriculture interests try to hijack the term “regenerative,” which Robert Rodale used to prioritize soil health. The word “regenerative” is now used loosely by many who combine chemical-intensive practices with minor improvements in agriculture, such as reduced tillage and cover crops. However, such steps outside an organic system are not regenerative.  

Please ensure that organic certification requires practices that build soil and animals on pasture, so hydroponics and CAFOs should not be certified. 

Thank you. 

Letter to U.S. Representative and Senators: 

Organic agriculture in the United States began in the 1940s as a movement of concerned citizens, environmentalists, and farmers, spearheaded by J.I. Rodale, founder of Rodale Press and Rodale Institute (originally Soil and Health Foundation). Rodale’s interest in promoting a healthy lifestyle emphasizing organically grown foods led him to establish the Rodale Organic Gardening Experimental Farm in 1940 and start Organic Farming and Gardening magazine in 1942. 

Interest in organic farming and food grew in the 1960s as the publication of Silent Spring increased awareness of the dangers of toxic pesticides, furthered by Rodale’s belief that farming practices focused on cultivating healthy soil lead to healthier foods and healthier people. Since then, organic practices have been shown to have beneficial impacts on biodiversity and climate. 

During the 1980s, momentum grew towards codifying principles of organic to not only protect organic consumers, but also reverse pesticide dependency and its resulting impacts. That momentum culminated in the passage of the Organic Foods Production Act of 1990 (OFPA). That “organic” belongs to the movement of organic farmers, consumers and public interest organizations, environmentalists, scientists, handlers, retailers, and certifiers, was recognized in the guiding role OFPA gives to the National Organic Standards Board (NOSB) consisting of representatives of those groups. 

Just as the NOSB shows that organic belongs to the organic community, the disempowering of the NOSB marks the theft of organic. Although members of the NOSB represent various sectors of the organic community, USDA, not the organic community, selects members of the board. Another step was USDA’s unilateral redefinition of “sunset”—so that, in re-evaluating synthetic materials allowed in organic, they are now presumed to be renewed, contrary to the meaning of “sunset” in every other legal setting. 

USDA denies the primary principle of organic agriculture—the critical importance of soil health—by allowing hydroponics to be certified organic. It has also allowed certified livestock producers to confine animals for extended periods of time in concentrated animal feeding operations (CAFOs). 

OFPA allows USDA leeway in the structure of the certification system, and USDA’s approach results in inconsistency and “certifier shopping.” Certifying agents are private businesses that collect fees for the service from the certified producer and have an incentive to give their customers what they want—hence, some certifiers (but not all) certify “organic” hydroponic or CAFO operations. Other ways of structuring organic certification should be considered. In the short-term, the Organic Certification Cost Share Program may offset costs. 

Chemical-intensive agriculture is a major contributor to climate change and biodiversity loss. Its dependence on toxic pesticides and chemical fertilizers results in human disease and environmental contamination. Organic agriculture can reverse or mitigate all these problems—if it is organic as originally conceived. 

As the problems identified above have prompted some in the organic community to separate themselves from USDA by defining and certifying “real organic” or “regenerative organic,” chemical-intensive agriculture interests try to hijack the term “regenerative,” which Robert Rodale used to prioritize soil health. The word “regenerative” is now used loosely by many who combine chemical-intensive practices with minor improvements in agriculture, such as reduced tillage and cover crops. However, such steps outside an organic system are not regenerative.  

Please ensure that organic certification requires practices that build soil and animals on pasture, so hydroponics and CAFOs should not be certified. Please support the Organic Certification Cost Share Program in the Farm Bill. 

Thank you. 

The biodiversity crisis is one of multiple crises that are compounding one another. While human actions are contributing to an ongoing Holocene or sixth mass extinction, we are also facing crises in human disease and climate change. The Endangered Species Act (ESA) focuses on the species and habitats most at risk of extinction. However, the statement of purpose also recognizes the importance of conserving the ecosystem on which they depend.  

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 contributed to the crisis in the first place. 

>> Tell EPA and Congress to support measures that protect endangered species and their habitats and to reject measures that weaken that protection.

The near extinction of a species of vulture brings into focus the importance of maintaining biodiversity for protecting human health. The loss of these underappreciated carrion eaters in India led to pollution of waterways by effluent from rotting carcasses and a burgeoning population of feral dogs, many of whom carried rabies. Similarly, in Wisconsin, researchers found that the presence of wolves reduced vehicle collisions with deer by 24%—an economic benefit 63 times greater than the cost of wolves killing livestock. 

The World Health Organization (WHO) summarizes the connections between biodiversity and human health: 

• Biodiversity provides many goods and services essential to life on Earth. The management of natural resources can determine the baseline health status of a community.  
• Biodiversity supports human and societal needs, including food and nutrition security, energy, development of medicines and pharmaceuticals and freshwater, which together underpin good health. It also supports economic opportunities, and leisure activities that contribute to overall well-being. [For example, 70% of all cancer drugs today are natural or based on nature. Other potential benefits include a fungus that can eat plastic.] 
• Land use change, pollution, poor water quality, chemical and waste contamination, climate change and other causes of ecosystem degradation all contribute to biodiversity loss and can pose considerable threats to human health. [“You rely on nature if you want to survive: It gives you food, it gives you water, it gives you trees that will protect the quality of the air you breathe,” says Maria Neira, MD, director of the Department of Environment, Climate Change, and Health for WHO. “It's common sense: You need to protect what is protecting you. If we don't, we are the losers, not the planet.”] 
• Human health and well-being are influenced by the health of local plant and animal communities, and the integrity of the local ecosystems that they form. [We depend on an ecological balance that regulates our planet's oxygen, water, and nutrient cycles to pollinate, nourish, and support all the organisms we consume.]  
• Infectious diseases cause over one billion human infections per year, with millions of deaths each year globally. [Approximately two-thirds of known human infectious diseases are shared with animals, and most recently emerging diseases are associated with wildlife. Habitat destruction brings humans and wildlife into closer contact, dramatically increasing the risk of diseases caused by pathogens jumping to humans from wild animals.] 

Biodiversity loss is harming our health and threatening the basic ecological cycles that keep us alive. “We are out of harmony with nature,” United Nations (UN) Secretary-General António Guterres told world leaders at the 2022 Biodiversity COP 15 (Conference of the Parties). “Humanity has become a weapon of mass extinction. … And ultimately, we are committing suicide by proxy.” 

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

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

>> Tell EPA and Congress to support measures that protect endangered species and their habitats and to reject measures that weaken that protection.

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

While it is well known that climate change affects biodiversity, the reverse is not so well appreciated. Biodiversity is essential for limiting climate change. As summarized by the United Nations,  

• When human activities produce greenhouse gases, around half of the emissions remain in the atmosphere, while the other half is absorbed by the land and ocean. These ecosystems—and the biodiversity they contain—are natural carbon sinks, providing so-called nature-based solutions to climate change. 
• Protecting, managing, and restoring forests, for example, offers roughly two-thirds of the total mitigation potential of all nature-based solutions. Despite massive and ongoing losses, forests still cover more than 30 percent of the planet's land. 
• Peatlands—wetlands such as marshes and swamps—cover only 3 percent of the world's land, but they store twice as much carbon as all the forests. Preserving and restoring peatlands means keeping them wet so the carbon doesn't oxidize and float off into the atmosphere.  
• Ocean habitats such as seagrasses and mangroves can also sequester carbon dioxide from the atmosphere at rates up to four times higher than terrestrial forests can. Their ability to capture and store carbon make mangroves highly valuable in the fight against climate change. 
• Conserving and restoring natural spaces, both on land and in the water, is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving nature's ability to absorb emissions.  

Action is urgently needed to conserve—protect and enhance—biodiversity. Among the targets for 2030 set by the nations at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world's lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since 17% and 10% of the world's terrestrial and marine areas respectively are now protected, this will require intensive actions that protect species and their habitats from toxic and other destructive threats, while restoring degraded ecosystems. The Kunming-Montreal Global Biodiversity Framework (GBF) adopted by COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.”  

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 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's recent proposals to “protect” endangered species from herbicides and insecticides are totally inadequate. 

Congress is also considering measures that would weaken endangered species—and hence, biodiversity—protection. Five joint resolutions—S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86—have been introduced to roll back ESA regulations adopted in the Biden administration to those enacted in the Trump administration. S. 4753, “A bill to reform leasing, permitting, and judicial review for certain energy and minerals projects, and for other purposes,” has been passed out of the Senate Committee on Energy and Natural Resources. It weakens ESA protections by creating much shorter timelines for judicial review, additional categorical exclusions from the National Environmental Policy Act (NEPA) that could result in less science and planning for projects, tighter deadlines for agencies to complete the permitting process without increased capacity or funds. The Department of the Interior and its land management agencies have been consistently underfunded and understaffed. Shortening their deadlines without fixing those issues would lead to a rushed permitting process and limited public engagement.  

>>Tell EPA and Congress to support measures that protect endangered species and their habitats and to reject measures that weaken that protection.

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

Letter to EPA:

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 contributed to the crisis in the first place. 

Biodiversity is critical for human health. It provides many goods and services essential to life on earth, supports human and societal needs, influences human health and well-being, and protects against exposure to zoonotic diseases. Biodiversity loss harms our health and threatens the ecological cycles that keep us alive.  

Biodiversity is essential for limiting climate change. It provides land and sea ecosystems that are natural carbon sinks, forests with two-thirds of the total mitigation potential of all nature-based solutions, wetlands covering 3 percent of the world’s land and storing twice as much carbon as all the forests, and seagrasses and mangroves that can sequester carbon dioxide at rates up to four times higher than terrestrial forests.  

Conserving and restoring biodiversity is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving Earth’s ability to absorb emissions.  

Among the targets for 2030 set by the United Nations Convention on Biological Diversity (CBD) at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since only 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, actions that protect species and their habitats from toxic and other destructive threats are critical, while restoring degraded ecosystems. COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.” 

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 endangered insects on a global level. Pesticides threaten food webs in aquatic and marine environments, warp the growth and reproduction of all animals, and are a leading factor driving declines in bird populations. 

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

At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. The UN Environment Program (UNEP) identifies the global food system as the primary driver of biodiversity loss, pointing to the conversion of natural ecosystems to crop production and pasture with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases. In contrast, organic producers are required to conserve biodiversity. 

Thus, a major reason that species are endangered is that EPA has registered pesticides that harm them. EPA must protect endangered species by eliminating the use of toxic pesticides and encouraging organic production.  

Thank you. 

Letter to U.S. Representative and Senators: 

The biodiversity crisis is one of multiple crises that compound one another. While human actions are contributing to a sixth mass extinction, we are also facing crises in human disease and climate change.  

Biodiversity is critical for human health. It provides many goods and services essential to life on earth, supports human and societal needs, influences human health and well-being, and protects against exposure to zoonotic diseases. Biodiversity loss harms our health and threatens the ecological cycles that keep us alive.  

Biodiversity is essential for limiting climate change. It provides land and sea ecosystems that are natural carbon sinks, forests with two-thirds of the total mitigation potential of all nature-based solutions, wetlands covering 3 percent of the world’s land and storing twice as much carbon as all the forests, and seagrasses and mangroves that can sequester carbon dioxide at rates up to four times higher than terrestrial forests.  

Conserving and restoring biodiversity is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving Earth’s ability to absorb emissions.  

Among the targets for 2030 set by the United Nations Convention on Biological Diversity (CBD) at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since only 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, actions that protect species and their habitats from toxic and other destructive threats are critical, while restoring degraded ecosystems. COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.” 

The Endangered Species Act (ESA) focuses on the species and habitats most at risk of extinction. However, the statement of purpose also recognizes the importance of conserving the ecosystem on which they depend. Biodiversity loss is harming our health and threatening the basic ecological cycles that keep us alive. “We are out of harmony with nature,” UN Secretary-General António Guterres told the 2022 Biodiversity COP 15 (Conference of the Parties). “Humanity has become a weapon of mass extinction. … And ultimately, we are committing suicide by proxy.” 

Congress is considering measures that would weaken endangered species—and hence, biodiversity—protection. Five joint resolutions—S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86—have been introduced to roll back ESA regulations adopted in the Biden administration to those enacted in the Trump administration. S. 4753, “A bill to reform leasing, permitting, and judicial review for certain energy and minerals projects, and for other purposes,” has been passed out of the Senate Committee on Energy and Natural Resources. It weakens ESA protections by creating much shorter timelines for judicial review, additional categorical exclusions from the National Environmental Policy Act (NEPA) that could result in less science and planning for projects, tighter deadlines for agencies to complete the permitting process without increased capacity or funds. The Department of the Interior and its land management agencies have been consistently underfunded and understaffed. Shortening their deadlines without fixing those issues would lead to a rushed permitting process and limited public engagement.  

Please support 30X30 and other goals of COP 15. Please oppose S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86 and S. 4753. 

Thank you. 

EPA headlines a July 15, 2024, press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift.” Yet EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions." Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”  

>> Tell EPA and Congress that EPA must protect against all forms of pesticide drift. 

Pesticide drift—more properly designated “chemical trespass”—is a threat to people living in agricultural, rural, suburban, and urban areas, as toxic chemicals move off the treated target site. While drift is a major exposure threat wherever pesticides are being used outdoors—from lawns, gardens, parks, playing fields, rights-of-way, to agricultural fields—pesticide drift is a major threat to those living near treated areas, as wind and rain can carry these chemicals miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to anyone in the application area or working and/or living nearby treated areas.  

Included among those at high risk from drift are families of farmworkers who live near agricultural parcels. Schools, playgrounds, recreational fields, and other facilities at which children are frequent visitors, have been affected by pesticide drift, which is all the more concerning because children have elevated vulnerability to chemicals, given their sizes and developmental stages. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Another study finds that children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia. 

Two participants in a Beyond Pesticides' 2021 National Pesticide Forum session titled “Fighting Chemical Trespass,” were organic farmers who could not sell their then-contaminated crops as organic, and one of them could not sell them at all because the compounds that were sprayed are illegal for use on food crops. That same farmer, formerly in robust health, has suffered serious chronic health consequences, is now legally disabled, and has acquired $100,000 in medical debt as a result of the chemical poisoning she endured across multiple incidents. 

One of the farmers summarized that, as an organic producer, he has huge concerns about such chemical trespass—for the safety of the food he produces, for farmworker safety and health, for the health and integrity of pollinators and other organisms, and the surrounding environment, and of course, economic issues of lost production and income. Towering over the immediate financial concerns is that, once contaminated, a USDA (U.S. Department of Agriculture) Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation. 

That same farmer contends that reform of drift policy at the state level—currently a kaleidoscope of varying, or no, regulations—is critical. He also suggests that organic farmers, in particular, secure personal liability insurance for any health/medical debt they might incur as the result of a drift or spray incident.  

Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency's efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers' “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, EPA's commitment to fulfilling legal requirements under the Endangered Species Act (ESA) for protecting endangered species and their habitats in the midst of an unprecedented rate of global extinction is called into question. 

A major problem with EPA's efforts to address drift is the agency's exclusion of vapor drift. Mitigation measures—such as buffer zones—designed to reduce movement of droplets or dust are inadequate to address pesticides that move much further as vapors after volatilizing from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders. 

Furthermore, EPA's assessment of drift hazard has been flawed by unwarranted assumptions, such as, "The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review." Why would one assume a lower-than-labeled rate anywhere in the treated area? 

When pest management strategies rely on spray and dust pesticide application, drift is inevitable. Aerial pesticide application is of greatest concern, where an estimated 40% of pesticides used are lost to drift. Inert (nondisclosed) ingredients—amines—that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology. Amines are often added to herbicide formulations for glyphosate, dicamba, and 2,4-D products to increase solubility and reduce volatilization. While in theory, amines reduce volatilization by forming herbicide-amine salts that lock the herbicide vapors in place, the researchers found evidence that even new forms of dicamba billed by the agrichemical industry as “low volatility,” and restricted to formulations that include very specific amines, continued to cause drift problems for farmers. 

From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming, it is simply ignored or not realistically restricted. These adverse effects are “unreasonable” because of an alternative—an organic production system—that does not harm human health, other species, or ecosystems and, in addition, helps to mitigate climate change. In its registration decisions, EPA must use organic production as a yardstick, denying any use for which organic production and land management is successful. 

>> Tell EPA and Congress that EPA must protect against all forms of pesticide drift.

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: 

EPA’s press release says, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift.” Yet EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions." Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”  

Pesticide drift (chemical trespass) is a major threat to those living in agricultural, rural, suburban, and urban areas, as chemicals are carried by air and water miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to anyone working or living nearby. Among those at highest risk are farmworker families who live near farms. Children, who are more vulnerable to chemicals, use schools, playgrounds, and recreational fields that are subject to drift. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Additionally, children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia. 

Also affected are organic farmers who cannot sell their contaminated crops as organic or cannot not sell them at all because the compounds that were sprayed are illegal for use on food crops. Organic farmers have huge concerns about such chemical trespass—for the safety of the food they produce, farmworker safety and health, the health and integrity of pollinators and biodiversity, and lost production and income. Once contaminated, a USDA Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation. 

Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to its Draft Herbicide Strategy Framework, weakening "protections” for endangered species from herbicide use. By reducing the stringency of the strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act amid an unprecedented rate of global extinction is called into question. 

 EPA’s failure to consider vapor drift is a major problem. Measures—such as buffer zones—designed to reduce movement of droplets or dust are inadequate in controlling vapors that move far from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders. 

EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, "The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review." Why would one assume a lower-than-labeled rate anywhere in the treated area? 

When pest management strategies rely on spray and dust pesticide application, drift is inevitable. An estimated 40% of pesticides applied by air are lost to drift. Amines that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology. 

From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming. The harm from drift is unreasonable given the alternative—an organic production system—that does not harm human health, other species, or ecosystems and helps to mitigate climate change. In the registration of toxic pesticides, EPA must recognize that successful organic land management eliminates the harm and uncertainties associated with drift.  

Thank you. 

Letter to U.S. Representative and Senators: 

EPA issued a press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift.” Yet it states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions." Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”  

Pesticide drift (chemical trespass) is a major threat to those living near or in agricultural, rural, suburban, and urban areas, as chemicals are carried by air and water miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to those living or working nearby. Among those at highest risk are farmworker families who live near farms. Children, who are more vulnerable to chemicals, use schools, playgrounds, and recreational fields that are subject to drift. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Additionally, children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia. 

Also affected are organic farmers who cannot sell their contaminated crops as organic or cannot sell them at all because the compounds that were sprayed are illegal for use on food crops. Organic farmers have huge concerns about such chemical trespass—for the safety of the food they produce, farmworker safety and health, the health and integrity of pollinators and biodiversity, and lost production and income. Once contaminated, a USDA Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation. 

Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to its Draft Herbicide Strategy Framework, weakening "protections” for endangered species from herbicide use. By reducing the stringency of the strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act amid an unprecedented rate of global extinction is called into question. 

EPA’s failure to consider vapor drift is a major problem. Measures—such as buffer zones—designed to reduce the movement of droplets or dust are inadequate in controlling vapors that move far from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders. 

EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, "The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review." Why would one assume a lower-than-labeled rate anywhere in the treated area? 

When pest management strategies rely on spray and dust pesticide application, drift is inevitable. An estimated 40% of pesticides applied by air are lost to drift. Amines that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology. 

From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming. The harm from drift is unreasonable given the alternative—an organic production system—that does not harm human health, other species, or ecosystems and helps to mitigate climate change.  

Please ensure that in its registration decisions, EPA recognizes that successful organic land management eliminates the harm and uncertainties associated with drift. 

Thank you. 

Numerous studies have documented the devastating impacts on public health, wildlife, and pollinators caused by the broad use of PFAS chemicals and the resulting environmental contamination. While it acknowledges PFAS as an urgent public health and environmental issue, the U.S. Environmental Protection Agency (EPA) continues to register hundreds of PFAS pesticide ingredients. In addition, the agency has allowed the ongoing use of fluorinated pesticide storage containers, despite its findings that these containers leach PFAS chemicals into pesticide products—which are then dispersed into the air, water, and soil.

A petition submitted on July 23, 2024, by the Center for Food Safety (CFS) on behalf of CFS and twelve other petitioners, including environmental and farm groups, asks EPA to: “1️⃣ ban PFAS as pesticide ingredients; 2️⃣ adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; 3️⃣ prohibit the use of PFAS-containing containers for pesticide storage; 4️⃣ mandate reporting of PFAS contamination from pesticide registrants; and 5️⃣ prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.” 

>> Tell EPA to approve the petition filed by the Center for Food Safety—joined by 12 environmental and farm petitioners—and eliminate the distribution of PFAS chemicals through pesticides. Tell Congress to urge EPA to act immediately.

The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products, such as the mosquito insecticide Anvil 10+10, raises alarm about the extent of PFAS contamination and its potential impact on public health, including contamination of drinking water and waterways. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—as the plastic containers leach PFAS. 

As PEER notes, PFOA and twelve other PFAS chemicals are formed during the fluorination of high-density polyethylene (HDPE) plastic containers by Inhance Technologies, LLC of Houston, Texas. Inhance is the sole U.S. company conducting this type of fluorination. Studies by EPA, independent researchers, and Inhance itself show that PFAS leaches from the walls of containers into their contents, thus exposing millions of people to PFAS without their knowledge. In February 2024, EPA announced a new methodology for detecting dangerous low levels of PFAS in plastic containers. The leaching of PFAS from plastic containers into various products, including pesticides, food, cosmetics, and cleaning supplies, poses a significant risk to millions of Americans through exposure via ingestion, inhalation, and dermal contact.

The number of pesticide ingredients classified as PFAS in the United States heavily depends on EPA's definitions. Many experts describe EPA's initial definition as significantly underinclusive compared to state and international definitions. EPA took a further step away from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas.

In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states, including Colorado, Washington, Maine, Maryland, New York, and California, encompasses a broader range of compounds.

In the context of pesticide ingredients, the “one fully fluorinated carbon” definition encompasses up to 200 pesticide ingredients. Maine will prohibit these starting in 2030, following its ban on pesticides that include intentionally added PFAS and pesticides contaminated with PFAS. This definition covers bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, and the main ingredient in over 600 pesticide formulations today, which recent testing has found elevated amounts of bifenthrin in numerous agricultural crops, exceeding the agency's safety levels. 

PFAS have been linked to various health issues, including cancer, reproductive problems, and immune system dysfunction. Concerns about safety in the use of fluorinated plastic containers used for packaging are based on exposure to PFAS not just from leaching into the contents of the plastic containers, but also from handling the exterior of the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, from pregnant women through children and the elderly, experience disproportionate risks of exposure. (See here and here). The chemicals have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. As new drinking water health advisories issued by EPA show, PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health. 

Certified organic agriculture can play a crucial role in addressing the widespread contamination of PFAS as the only viable solution in the long run. Organic agriculture prohibits the use of petrochemical pesticides and fertilizers under a robust regulatory system created by the Organic Food Production Act and overseen by the National Organic Standards Board (NOSB), which reports directly to the U.S. Secretary of Agriculture. As the only agricultural system with public input and standards as defined by federal law, organic promotes sustainable farming practices that prioritize soil health and biodiversity. As the governing body responsible for setting organic standards, the NOSB must take a leadership role in developing a comprehensive strategy for eliminating plastics and PFAS from organic production and packaging, ensuring that organic agriculture remains a safe and sustainable alternative to conventional farming. 

Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. For more information on why organic is the healthy choice, see Beyond Pesticides' webpage, Health Benefits of Organic Agriculture.  

>> Tell EPA to approve the petition filed by the Center for Food Safety—joined by 12 environmental and farm petitioners—and eliminate the distribution of PFAS chemicals through pesticides. Tell Congress to urge EPA to act immediately.

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: 

Numerous studies document the devastating impacts on public health, wildlife, and pollinators caused by the broad use of PFAS chemicals and the resulting environmental contamination. While acknowledging PFAS as an urgent public health and environmental issue, EPA continues to register hundreds of PFAS pesticide ingredients and allows the ongoing use of fluorinated pesticide storage containers, despite its own findings that these containers leach PFAS chemicals into pesticide products—which are then dispersed into the air, water, and soil. 

The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products raises alarm about the extent of PFAS contamination and its potential impact on public health. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—plastic containers that leached PFAS.  Studies by EPA, independent researchers, and manufacturers show that PFAS leaches from the walls of containers into the contents, thus exposing millions of people to PFAS without their knowledge. Exposure to PFAS comes not just from leaching into the contents of the plastic containers, but also from handling the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, including pregnant women, children, and the elderly, experience disproportionate risk. The chemicals have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. EPA’s drinking water health advisories find PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health. 

The number of pesticide ingredients classified as PFAS in the United States heavily depends on EPA’s definitions. EPA further retreated from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas. In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states encompasses a broad range of compounds, among them up to 200 pesticide ingredients, such as bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, a main ingredient in over 600 pesticide formulations, which recent testing has found to exceed EPA safety levels in numerous agricultural crops. 

A petition submitted by the Center for Food Safety (CFS) on behalf of CFS and twelve other petitioners asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.” 

Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. 

Please approve the Center for Food Safety petition filed on July 23, 2024 on behalf of itself and 12 environmental and farm petitioners to eliminate the distribution of PFAS chemicals through pesticides. 

Thank you. 

Letter to U.S. Representative and Senators: 

Numerous studies have document the devastating impacts on public health, wildlife, and pollinators caused by the broad use of PFAS chemicals and the resulting environmental contamination. While acknowledging PFAS as an urgent public health and environmental issue, EPA continues to register hundreds of PFAS pesticide ingredients and allows the ongoing use of fluorinated pesticide storage containers, despite its own findings that these containers leach PFAS chemicals into pesticide products—which are then dispersed into the air, water, and soil. 

The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products raises alarm about the extent of PFAS contamination and its potential impact on public health. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—plastic containers that leach PFAS.  Studies by EPA, independent researchers, and manufacturers show that PFAS leaches from the walls of containers into the contents, thus exposing millions of people to PFAS without their knowledge. Exposure to PFAS comes not just from leaching into the contents of the plastic containers, but also from handling the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, including pregnant women, children, and the elderly, experience disproportionate risk. The chemicals have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. EPA’s drinking water health advisories find PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health. 

The number of pesticide ingredients classified as PFAS in the United States heavily depends on EPA’s definitions. EPA further retreated from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas. In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states encompasses a broad range of compounds, among them up to 200 pesticide ingredients, such as bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, a main ingredient in over 600 pesticide formulations, which recent testing has found to exceed EPA safety levels in numerous agricultural crops. 

A petition submitted by the Center for Food Safety (CFS) on behalf of CFS and twelve other petitioners asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.” 

Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. 

Please urge EPA to approve the Center for Food Safety petition filed on July 23, 2024 on behalf of itself and 12 environmental and farm petitioners and eliminate the distribution of PFAS chemicals through pesticides. 

Thank you. 

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

>> Tell your Governor and Mayor to ensure ecological mosquito management by eliminating the use of pesticides that threaten 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 including 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 of 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 state of Massachusetts' Department of Fish and Game, under the direction of the Governor, is currently developing Biodiversity Conservation Goals and environmentalists are asking that mosquito management be incorporated into their interagency effort.) 

On a personal level, you can nurture a safe haven for birds and other mosquito predators. 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. 

You probably have noticed that it's hot. Really hot. Climate change is a real crisis and requires serious action. Actually, climate change is one of multiple crises that are compounding one another. While climate change may be most apparent—128^o F in Death Valley, heat waves in India, the U.S., and globally, the earliest Category 5 hurricane on record, another wildfire season, etc.—we are also facing crises in human disease and biodiversity collapse. 

Heat makes the health effects of pesticides more serious. Climate change is intensifying the impacts of habitat destruction and toxic chemicals on biodiversity. We cannot afford to let anyone capitalize on marketing schemes making false claims of climate change mitigation.  

>> Regenerative agriculture must be organic.

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

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

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

Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers. In addition, studies have found organically grown plant foods and milk to be nutritionally superior to those produced by chemical-intensive agriculture.  

The National Organic Program provides for clarity and enforceability, while providing processes that are open and transparent to growers, consumers, and the public at large. As an established program, it also has its own funding mechanism. We must demand that any definition of “regenerative” must—at a minimum—meet organic standards.  

>> Regenerative agriculture must be organic.

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

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

Agriculture must—across the board and on an expedited five-year schedule—shift to organic practices. Organic practices both sequester carbon and eliminate petrochemical pesticides and synthetic fertilizers. Importantly, the data show that organic agriculture now operates without sacrificing productivity or profitability. While the vested economic interests in the petroleum and chemical industry cling to the status quo, there are good jobs and money to be made in a green economy.  

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

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

We need a national land management plan.  Preserving natural land increases biodiversity, reduces dependence on petroleum-based pesticides, and is more effective in sequestering carbon. Biodiversity buffers against damage from climate change by allowing systems to evolve with changing conditions. Preserving natural lands and transitioning farms to organic production should be the cornerstones of combating climate change.   

>> Regenerative agriculture must be organic.

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: 

As Congress considers elements of the next Farm Bill, climate change is an extremely urgent crisis to address. And while climate change may be most apparent—128o F in Death Valley, heat waves in India, the U.S., and globally, the earliest Category 5 hurricane on record, another wildfire season, etc.—we are also facing crises in human disease and biodiversity collapse. 

Heat makes the health effects of pesticides more serious. Climate change is intensifying the impacts of habitat destruction and toxic chemicals on biodiversity.  

We cannot afford to let anyone capitalize on marketing schemes making false claims of climate change mitigation. Regenerative agriculture must be organic.  

Organic agriculture mitigates climate change and therefore must be dramatically expanded. Agriculture is a major contributor to the climate emergency. Research shows that even if fossil fuel emissions were eliminated immediately, emissions from the global food system alone would make it impossible to limit warming to 1.5°C and difficult even to realize the 2°C target. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced greenhouse gas (GHG) emissions.  

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

Organic farms are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.”  

Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers. In addition, studies have found organically grown plant foods and milk to be nutritionally superior to those produced by chemical-intensive agriculture.  

The National Organic Program provides clarity and enforceability while providing processes that are open and transparent to growers, consumers, and the public at large. As an established program, it also has its own funding mechanism. Any definition of “regenerative” must—at a minimum—meet organic standards.  

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

We need a national plan to shift to 100% organic farming in the coming five years. Please support a shift to organic in the Farm Bill and reject language that (i) undermines, or preempts, local and state authority to enact more stringent land management policies protective of health and the environment, and (ii) establishes immunity from lawsuits for chemical companies that fail to warn farmers and consumers of pesticide hazards.   

Thank you.  

Acephate, a member of the highly toxic organophosphate (OP) family of insecticides, is so toxic that EPA is proposing to ban all uses except the systemic injection into trees. A comment period is open, and EPA is accepting comments through Wednesday, July 31, after extending the earlier July deadline. With this remaining use, EPA is still not recognizing that systemic neonicotinoid pesticides can cause serious environmental harm to the ecosystem through indiscriminate poisoning of organisms. 

>> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically. 

EPA proposes to cancel all uses of acephate other than tree injection to eliminate all risks of concern it has identified that exceed its level of concern for dietary/drinking water risk, residential and occupational risks, and risks to non-target organisms. As Beyond Pesticides points out, although the tree injection method does not pose excessive dietary or aggregate health risk and does not pose any untoward occupational or post-application human health risks of concern, there are significant ecological risks posed that the agency has neglected. Rather than assessing the ecological risks of tree injection uses, the agency assumes that the use does not pose significant risk to nontarget organisms. On the contrary, the tree injection uses do pose serious risks to pollinator and certain bird species that cannot be mitigated and should therefore be included in the acephate cancellations.  

In tree injection, the pesticide is injected directly into a tree trunk where it is taken up quickly by the vascular system and distributed. Because acephate and its degradate methamidophos are very soluble and systemic insecticides, the chemical is transported to all parts of the tree—including pollen, sap, resin, leaves, etc. Honey bees and certain bird species such as hummingbirds, woodpeckers, sapsuckers, tree creepers, nuthatches, chickadees, etc. can be exposed to residues within acephate-injected trees. Honey bees are exposed not only by collecting contaminated pollen, but more so from collecting sap and resins used for producing hive-important propolis. Similarly, birds are exposed to toxic acephate/methamidophos residues when feeding on contaminated tree sap, wood-boring insects/larvae, and leaf-chewing insects/larvae. 

Although it has limited data, EPA has determined that acephate uses may present risks of concern to honey bees. However, the full suite of pollinator studies has not yet been submitted for acephate or methamidophos; therefore, no adult acute oral, chronic toxicity data or larval toxicity data are available for honey bees. These data gaps represent significant uncertainties for the assessment of the impact of acephate on pollinators as sensitivity may vary according to life stage and length of exposure (adult vs. larval and acute vs. chronic, respectively). Adverse incidents with probable and highly probable causality, including bee kills, have been associated with acephate and/or methamidophos exposure to honey bees. It is reasonable to presume that tree injection application of acephate does not attenuate the risk to honey bees compared to foliar treatment and, given the higher dosage per tree from injection, may actually increase exposure and therefore toxic risk. The agency proposes a pollinator hazard statement for the tree injection uses stating, “This product is highly toxic to bees.” This label statement is totally insufficient to protect bees and other organisms or to communicate the seriousness of the risk. 

The risks of acephate use and the tree injection method specifically have not yet been fully evaluated for threatened and endangered species. EPA must complete its listed species assessment and any necessary consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service before completing the acephate registration review, paying careful attention to listed avian and insect species using trees subject to injection use for feeding, forage, and nesting. 

The agency completed a weight-of-evidence endocrine disruptor analysis for acephate in 2015, which concluded that no further data to assess the potential for impacts on the estrogen, androgen, or thyroid pathways are needed for humans or wildlife. However, more recent information suggests the endocrine disrupting potential for acephate and its degradate methamidophos through non-receptor-mediated pathways may be of concern, so EPA should update its assessment on the endocrine disruption risks for acephate. 

Moreover, EPA concludes in its benefits assessment that the tree injection use of acephate generally provides low pest management benefits because several effective alternatives are available for most insect pests. Therefore, from a risk-benefit standpoint the high risk to bees and birds from acephate tree injection treatments are unreasonable. 

>> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically.

Despite prioritizing review of OP pesticides, EPA has failed to take action to protect those most exposed and most vulnerable to their neurotoxic effects—farmworkers and children. In 2021, Earthjustice and others petitioned EPA to cancel the registrations of these highly neurotoxic pesticides. This spring, Consumer Reports' (CR) most comprehensive investigation ever of pesticides in produce found that exposure to two broad classes of chemicals—organophosphates and carbamates—are the most hazardous, linked to an increased risk of cancer, diabetes and cardiovascular disease. Based on those findings, CR petitioned EPA to “ban these classes of pesticides from use on fruit and vegetables.” 

In addition to the issues identified above, EPA fails to consider endocrine disruption. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife.  

Notably, USDA certified organic food products are not permitted to be produced with toxic pesticides. Pesticide residues found in organic products, with rare exception, are a result of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. Not only is the production of organic food better for human health and the environment than chemical-intensive production, but emerging science reveals also what organic advocates have been saying for a long time—in addition to lacking the toxic residues of conventional foods, organic food is more nutritious and it does not poison the people and contaminate the communities where the food is grown. 

A study published by The Organic Center reveals that organic food is higher in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally beneficial. Another study published in the Journal of Agricultural Food Chemistry looks specifically at the total phenolic content of marionberries, strawberries, and corn, and found that organically grown products contain higher total phenolics. Phenolics are important for plant health (defense against insects and diseases), and human health for their “potent antioxidant activity and wide range of pharmacologic properties, including anticancer, antioxidant, and platelet aggregation inhibition activity.”   

In view of the advantages of organic production, EPA must use organic production as the yardstick when weighing risks and benefits of pesticides. No pesticide should be allowed to be used if the crop can be produced organically. 

>> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically.

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

Thank you for your active participation and engagement! 

Document ID: EPA-HQ-OPP-2008-0915-0058

Proposed submission to EPA (please submit by 5 PM ET on July 31, 2024)

Acephate, a highly toxic organophosphate (OP), is so toxic that EPA is proposing to ban all uses except the systemic injection into trees. With this remaining use, EPA is still not recognizing that systemic neonicotinoid pesticides can cause serious environmental harm to the ecosystem through indiscriminate poisoning of organisms. 

EPA proposes to cancel all uses of acephate other than tree injection to eliminate all risks of concern it has identified that exceed its level of concern. Although tree injection does not pose excessive dietary or aggregate health risk or occupational or post-application human health risks of concern, there are significant ecological risks that the agency has neglected. Rather than assessing the ecological risks of tree injection uses, it assumes that the use will not pose significant risk to nontarget organisms. On the contrary, tree injection uses do pose serious risks to pollinator and certain bird species that cannot be mitigated.  

In tree injection, the pesticide is injected directly into a tree trunk where it is quickly taken up by the vascular system and distributed throughout the tree. Because acephate and its degradate methamidophos are soluble and systemic insecticides, the chemical is transported to all parts of the tree—including pollen, sap, resin, leaves. Honey bees and certain bird species such as hummingbirds, woodpeckers, sapsuckers, tree creepers, nuthatches, chickadees, can be exposed to residues within acephate-injected trees. Honey bees are exposed not only by collecting contaminated pollen, but more so from collecting sap and resins used for producing propolis. Similarly, birds are exposed to toxic acephate/methamidophos residues when feeding on contaminated tree sap, wood boring insects/larvae, and leaf chewing insects/larvae. 

Although it has limited data, EPA has determined that acephate uses may present risks of concern to honey bees. Data gaps represent significant uncertainties for the assessment of the impact of acephate on pollinators. It is reasonable to presume that tree injection application of acephate does not attenuate the risk to honey bees compared to foliar treatment and, given the higher dosage per tree from injection, may actually increase exposure and therefore toxic risk. The agency proposes a pollinator hazard statement for the tree injection uses, “This product is highly toxic to bees.” This label statement is totally insufficient to protect bees and other organisms. 

The risks of acephate use and the tree injection method specifically have not yet been fully evaluated for threatened and endangered species and must be included in the acephate registration review, with attention to listed avian and insect species that use trees subject to tree injection for feeding, forage, and nesting. 

Recent information suggests the endocrine-disrupting potential for acephate and its degradate methamidophos may be of concern, so EPA must update its assessment on the endocrine disruption risks for acephate before allowing continued use. 

Moreover, EPA concludes in its benefits assessment that the tree injection use of acephate generally provides low pest management benefits because several effective alternatives are available for most insect pests. Therefore, the high risks to bees and birds from acephate tree injection treatments are unreasonable and should be canceled. 

EPA has failed to take action to protect those most exposed and most vulnerable to the toxic effects of pesticides. EPA fails to consider endocrine disruption, vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues.  

USDA certified organic food products are not permitted to be produced with toxic pesticides and should be used as the yardstick when weighing risks and benefits of pesticides. No toxic pesticide should be allowed to be used if the crop can be produced organically.  

Thank you.

Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. EPA is now considering two new dicamba registrations that continue use of the chemical in its most drift-prone application uses.

>>Tell EPA to ban use of dicamba and other drift-prone pesticides. 

Pesticide drift harms people, crops, and wildlife. The term “drift” applies to airborne movement off the target site—though pesticides may also move as runoff and in soil carried by water or wind. Drift may consist of particles or droplets of pesticide as it is applied or vapors that evaporate and are carried in the air. Farmers and applicators may take steps to avoid drift—including buffer zones, thickening agents, and attention to wind direction—but drift-prone pesticides like dicamba are not always controlled by these actions. Those harmed by the drift are generally not those whose crops are sprayed, so the risk-benefit analysis pits farmer against farmer, neighbor against neighbor, even resulting in a murder.  

The manufacturers of dicamba-based herbicides—who also sell seeds of crops engineered to tolerate dicamba—benefit from this conflict, as farmers buy the engineered seeds in an effort to defend themselves against drift damage, a strategy encouraged by pesticide manufacturers. 

Despite a finding of dicamba's harm and EPA's failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA's 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. And now proposed registrations would allow those uses to continue. The comment period on the Bayer application has closed, but comments on the virtually-identical application for BASF's Engenia® are open until July 5. ➡️ Click here to see Beyond Pesticides' comments. 

The proposed label for Engenia® allows for application preplant, at-planting, preemergent, and postemergent (in-crop) for broadleaf weeds. In dicamba-tolerant soybeans, there is a June 12 cutoff date with applications allowed before, during, and after planting, including over-the-top. In dicamba-tolerant cotton, similar conditions apply but with a cutoff date of July 30. This is different from the Bayer CropScience proposal where no over-the-top application was specified for soybeans. The new proposed uses, since they increase use of dicamba and subsequent harm from pesticide drift, should be denied for failure to meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirement of no unreasonable adverse effects on the environment. 

Increasing global temperatures need to also be factored into the decision-making process. All dicamba formulations have the potential to volatilize since dicamba has a high vapor pressure. Increases in air temperature can cause dicamba to turn into a gas even after successful application on target surfaces. Since volatilization increases as temperatures increase, this is more and more concerning as temperatures are rising higher each year. The length, intensity, and onset of seasons has changed, which can be attributed to climate change. The longer and hotter summers will exacerbate dicamba volatilization, therefore any proposal that allows dicamba application in late spring and summer will lead to more drift--especially for postemergent and over-the-top applications. 

Although pesticides are by definition harmful, what makes these adverse effects “unreasonable” is the existence of an alternative—an organic production system—that does not harm human health, other species, or ecosystems and, in addition, helps to mitigate climate change. In its registration decisions, EPA must use organic production as a yardstick, denying any use for which organic production is successful. This includes the proposed uses. 

>>Tell EPA to ban use of dicamba and other drift-prone pesticides.

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!

Document ID: EPA-HQ-OPP-2024-0154-0236

Proposed submission to EPA (please submit by 5 PM ET on July 5, 2024)

Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. EPA is now considering two new dicamba registrations that continue use of the chemical in its most drift-prone application uses. 

Pesticide drift harms people, crops, and wildlife. The term “drift” applies to airborne movement off the target site—though pesticides may also move as runoff and in soil carried by water or wind. Drift may consist of particles or droplets of pesticide as it is applied or vapors that evaporate and are carried in the air. Farmers and applicators may take steps to avoid drift—including buffer zones, thickening agents, and attention to wind direction—but drift-prone pesticides like dicamba are not always controlled by these actions. Those harmed by the drift are generally not those whose crops are sprayed, so the risk-benefit analysis pits farmer against farmer, neighbor against neighbor, even resulting in a murder.  

The manufacturers of dicamba-based herbicides—who also sell seeds of crops engineered to tolerate dicamba—benefit from this conflict, as farmers buy the engineered seeds in an effort to defend themselves against drift damage, a strategy encouraged by pesticide manufacturers. 

Despite a finding of dicamba’s harm and EPA’s failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA’s 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. And now proposed registrations would allow those uses to continue.  

The proposed label for Engenia® allows for application preplant, at-planting, preemergent, and postemergent (in-crop) for broadleaf weeds. In dicamba-tolerant soybeans, there is a June 12 cutoff date with applications allowed before, during, and after planting, including over-the-top. In dicamba-tolerant cotton, similar conditions apply but with a cutoff date of July 30. This is different from the Bayer CropScience proposal where no over-the-top application was specified for soybeans. The new proposed uses, since they increase use of dicamba and subsequent harm from pesticide drift, should be denied for failure to meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirement of no unreasonable adverse effects on the environment. 

Although pesticides are by definition harmful, what makes these adverse effects “unreasonable” is the existence of an alternative—an organic production system—that does not harm human health, other species, or ecosystems and, in addition, helps to mitigate climate change. In its registration decisions, EPA must use organic production as a yardstick, denying any use for which organic production is successful. This includes the proposed uses. 

Increasing global temperatures also need to be considered. All dicamba formulations have the potential to volatilize since dicamba has a high vapor pressure. Increases in air temperature can cause dicamba to turn into a gas even after successful application on target surfaces. Since volatilization increases as temperatures increase, this is more and more concerning as temperatures are rising higher each year. The length, intensity, and onset of seasons has changed, which can be attributed to climate change. The longer and hotter summers will exacerbate dicamba volatilization, therefore any proposal that allows dicamba application in late Spring and Summer will lead to more drift--especially for postemergent and over-the-top applications. 

EPA must not approve the proposed expanded use of dicamba and must cancel uses of all drift-prone pesticides. 

Thank you.

As Pollinator Week draws to a close, it is important to note that all species—and ecosystems—are threatened by the failure of the U.S. Environmental Protection Agency (EPA) to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA is required to register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.” Under ESA, EPA must, like all federal agencies, “seek to conserve endangered species and threatened species and shall utilize their authorities in furtherance of the purposes” of the ESA—which are “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” through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.” 

>> Tell EPA that to meet its obligations under FIFRA and ESA, it must facilitate a transition to organic practices. Tell Congress to ensure that EPA meets its statutory obligations. 

In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to FIFRA, whether those harms are “unreasonable” depends on a weighing of the costs and benefits. Under a related law, the Federal Food, Drug, and Cosmetic Act, EPA sets allowable residue limits of pesticides in food (tolerances) utilizing risk assessments that have embedded in them the assumption that toxic pesticides are necessary for crop production. In fact, EPA starts with the position that farmers cannot farm without these toxic chemicals, an assumption that clouds and undermines the regulatory process and keeps farmers on the pesticide treadmill. In its Draft Herbicide Strategy Framework update, EPA says, “Without certain pesticide products, farmers could have trouble growing crops that feed Americans and public health agencies could lack the tools needed to combat insect-borne diseases.” Not true. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured. 

The only way to truly protect pollinators, insects, birds, and other species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Converting the world's agricultural systems to organic would have a tremendously positive impact on threatened populations. Organic farming enhances biodiversity in the ecosystem and mitigates environmental degradation and climate change, all of which are necessary for the recovery of threatened and endangered species.  

By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. Organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world. Organic farming methods increase carbon sequestration in soils, reducing atmospheric carbon dioxide levels through practices that enhance soil organic carbon, such as using cover crops and organic soil amendments. Furthermore, organic farming reduces the reliance on fossil fuels by eliminating synthetic fertilizers and pesticides, which are energy-intensive to produce.  

As part of its update to EPA's ESA Workplan, EPA has created a “Mitigation Menu Website” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.” In this spirit, a range of people, including grower groups, gathered earlier in the year for a series of workshops in the Pacific Northwest to discuss possible mitigation measures. According to a report written by commercial beekeeper Steve Ellis (more background), concrete decisions were not reached at the workshops as participants recognized the complexities in crafting pesticide product label restrictions to protect endangered species. Mr. Ellis concluded: “If it's so complex that it's impossible, then no one wins.” 

Even if EPA can fix some of the technological problems with its website, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are entirely voluntary. There is no enforcement mechanism and no way to ensure that the pesticides are used as directed or that mitigation measures are implemented properly. In addition, EPA is making allowances for use of a pesticide when impacts cannot be avoided. Specifically, EPA plans to allow the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species.” How EPA will ensure that such offsets happen or that they successfully contribute to the conservation of a species of concern has not been described. It also does nothing to protect the habitat necessary for the long-term survival of the species in its ecosystem.

The only way to truly protect endangered species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Instead of creating a complicated work-around that will not address the urgent health, biodiversity, and climate crises, EPA must cancel registrations of pesticides that harm endangered species and facilitate a widescale conversion to organic practices. 

>>Tell EPA that to meet its obligations under FIFRA and ESA, it must facilitate a transition to organic practices. Tell Congress to ensure that EPA meets its statutory obligations.

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!

Look for additional actions on the Beyond Pesticides website that you can take to help pollinators all year long!

Art Page submissions: Sara from Denton, MD: "Winged Wonders" and "Sunflower Pollinators,” Marion from Media, PA: "Eastern Tiger Swallowtail" and "Bumblebee on Oriental Chives," David from Wilmington, NC: "Golden Northern Bumblebee on Downy Sunflower," Julia from Manassas, VA: "New England Aster with Monarch Butterfly," Barbara from Bend, OR: "Bumble and Lupine," Darla from Lehighton, PA: "Bee in my Flower Garden" and "Butterfly in my Flower Garden."

Letter to EPA:

At the close of Pollinator Week, I want to remind you that all species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA may register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.” Under ESA, EPA must “seek to conserve endangered species and threatened species and . . . utilize their authorities in furtherance of the purposes” of the ESA—which are “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” through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.”

In registering and reregistering pesticides, EPA allows uses that harm humans, other organisms, and ecosystems. EPA starts with the position that farmers cannot farm without these toxic chemicals, which fails to eliminate unreasonable risk. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured.

By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. By eliminating petrochemical pesticides and fertilizers, organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world.

As part of its update to EPA’s ESA Workplan, EPA created a “Mitigation Menu” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.” Farm groups that discussed possible mitigation measures in a series of workshops recognized the complexities in crafting restrictions and pesticide product label changes to protect endangered species. In the words of one participant, “If it’s so complex that it’s impossible, then no one wins.”

Even if EPA can address complications, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are voluntary, with no enforcement mechanism to ensure that the pesticides are used as directed or mitigation measures are implemented properly. Moreover, EPA makes allowances to use a pesticide when impacts cannot be avoided—allowing the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species,” with unknown effectiveness.

The only way to protect endangered species and the ecosystem is to stop the use of pesticides. Instead of creating a complicated workaround that fails to protect, EPA must cancel registrations of pesticides that harm endangered species and facilitate a widescale conversion to organic practices.

Thank you.

Letter to U.S. Representative and Senators:

At the close of Pollinator Week, I want to remind you that all species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA may register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.” Under ESA, EPA must “seek to conserve endangered species and threatened species and... utilize their authorities in furtherance of the purposes” of the ESA—which are “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” through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.”

In registering and registering pesticides, EPA allows uses that harm humans, other organisms, and ecosystems. EPA starts with the position that farmers cannot farm without these toxic chemicals, which fails to eliminate unreasonable risk. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured.

By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. By eliminating petrochemical pesticides and fertilizers, organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world.

As part of its update to EPA’s ESA Workplan, EPA created a “Mitigation Menu” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.” Farm groups that discussed possible mitigation measures in a series of workshops recognized the complexities in crafting restrictions and pesticide product label changes to protect endangered species. In the words of one participant, “If it’s so complex that it’s impossible, then no one wins.”

Even if EPA can address complications, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are voluntary, with no enforcement mechanism to ensure that the pesticides are used as directed or mitigation measures are implemented properly. Moreover, EPA makes allowances to use a pesticide when impacts cannot be avoided—allowing the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species,” with unknown effectiveness.

The only way to protect endangered species and the ecosystem is to stop the use of pesticides. Please ensure that instead of creating a complicated workaround that fails to protect, EPA cancels registrations of pesticides that harm endangered species and facilitates a widescale conversion to organic practices.

Thank you.

The week of June 17 is National Pollinator Week, which gives us the opportunity to recognize—and take action to protect—these important members of the ecosystem. Pollinators—bees, butterflies, birds, bats, and other organisms—make a critical contribution to plant health, crop productivity, and the preservation of natural resources, but their existence is threatened by their pesticide-contaminated habitat. Throughout the week, we will suggest actions that you can take to promote the health of pollinators. Although these actions can include the establishment of pollinator-friendly plants, the first step is providing a safe place for pollinators to live, eat, reproduce, and take refuge from predators and adverse weather. In other words, pollinator conservation begins with organic management of their environment. 

>>Tell your Governor to adopt organic practices on state lands. 

Pollinators––bees, butterflies, birds, bats, and other organisms––make a critical contribution to plant health, crop productivity, and the preservation of natural resources. However, pesticides consistently act as a key contributor to dramatic pollinator declines. Much research attributes the decline of insect pollinators over the last several decades to the interaction of multiple environmental stressors, from climate change to pesticide use, disease, habitat destruction, and other factors. Roughly a quarter of the global insect population has disappeared since 1990, according to research published in the journal Science. Monarchs are nearing extinction, and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies, the foundation of many food chains, and fireflies, the foundation of many childhood summer memories. The declines in many bird species likely have close links to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, have been lost since the 1970s. In a world where habitat loss and fragmentation show no sign of abating, scientists have concluded that the globe cannot afford to continue to subject its critically important wild insects to these combined threats.  

Toxic pesticide residues also threaten ecosystem functions needed to support life, frequently found in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. The scientific literature demonstrates pesticides' long history of adverse environmental effects, especially on wildlife, biodiversity, and human health. Notably, pesticides are immensely harmful to pollinators. The pervasiveness of pesticide exposure combined with climate change threatens global species biodiversity. The globe is currently undergoing Earth's sixth mass extinction, with one million species of plants and animals at risk. With the increasing rate of biodiversity loss, it is essential to provide protection from pesticides by adopting organic agriculture and land care methods. A study in the journal Nature found that, “The interaction between indices of historical climate warming and intensive agricultural land use is associated with reductions of almost 50% in 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.” 

Over the last decade and a half, increasing scientific evidence shows a clear connection between the role of pesticides in the decline of honey bees and wild pollinators. In the U.S., an increasing number of pollinators, including the American bumblebee and monarch butterfly, are being added or in consideration for listing under the Endangered Species Act, with specific chemical classes like systemic neonicotinoid insecticides putting 89% or more of U.S. endangered species at risk. Pesticides intensify pollinators' vulnerability to health risks (such as pathogens and parasites), with pesticide-contaminated conditions limiting colony productivity, growth, and survival. Past research finds that notorious bee-killing neonicotinoid insecticides kill bees outright, resulting in a range of complex damage, including their ability to impede bees' olfactory senses and adversely affect their vision and flying ability. Other chemicals like glyphosate weaken bees' ability to distinguish between colors. A 2018 study found that commonly used neonicotinoid insecticides begin to kill off bumblebees during their nest-building phase, as exposure makes it more difficult for a queen to establish a nest. Exposure to neonicotinoids results in bumblebee colonies that are much smaller than colonies not exposed to these systemic insecticides. Spray applications of various agrichemicals affect the visitation patterns of pollinators through a range of different processes. Neonicotinoid exposure decreases pollination frequency, resulting in fewer social interactions as the chemical alters bumblebee feeding behavior and degrades the effectiveness of bumblebees' classic “buzz pollination” process. A study published in 2017 determined that fungicides also play a significant role in bumblebee declines by increasing susceptibility to pathogens.  

Organic practices require not only refraining from the use of synthetic pesticides and fertilizers, but also taking positive actions to promote biodiversity. Providing organic habitats can protect pollinators, and all species, including humans, that depend on their ecosystem services.

Look for additional actions on the Beyond Pesticides website that you can take to help pollinators!

>>Tell your Governor to adopt organic practices on state lands.

The targets for this Action are the U.S. Governors.

Thank you for your active participation and engagement!

Letter to Governors:

National Pollinator Week, the week of June 17, gives us the opportunity to recognize—and protect—important members of our ecosystem. Pollinators—bees, butterflies, birds, bats, and other organisms—make a critical contribution to plant health, crop productivity, and the preservation of natural resources, but their existence is threatened by their pesticide-contaminated habitat. Providing pollinator-friendly plants is insufficient unless pollinators have safe places to live, eat, reproduce, and take refuge from predators and adverse weather. In other words, pollinator conservation begins with organic management of their environment. 

Pollinators—bees, butterflies, birds, bats, and other organisms—make a critical contribution to plant health, crop productivity, and the preservation of natural resources. However, pesticides are a key contributor to dramatic pollinator declines. Research attributes the decline of insect pollinators over the last several decades to the interaction of multiple environmental stressors, including climate change, pesticide use, disease, and habitat destruction. Roughly a quarter of the global insect population has disappeared since 1990. Monarchs are nearing extinction, and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies and fireflies. Declines in many bird species, with three billion birds, or 29% of bird abundance lost since the 1970s, likely have close links to insect declines. Scientists have concluded that the globe cannot afford to continue to subject its critically important wild insects to these combined threats.  

Toxic pesticide residues also threaten ecosystem functions needed to support life, frequently found in soils, water, and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. The scientific literature demonstrates pesticides’ long history of adverse environmental effects, especially on wildlife, biodiversity, and human health. Notably, pesticides are immensely harmful to pollinators. The pervasiveness of pesticide exposure combined with climate change threatens global species biodiversity. The globe is currently undergoing Earth’s sixth mass extinction, with one million species of plants and animals at risk. With the increasing rate of biodiversity loss, it is essential to provide protection from pesticides by adopting organic agriculture and land care methods. A study in the journal Nature found that “The interaction between indices of historical climate warming and intensive agricultural land use is associated with reductions of almost 50% in 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.” 

Over the last decade and a half, increasing scientific evidence shows a clear connection between the role of pesticides in the decline of honey bees and wild pollinators. Pesticides intensify pollinators’ vulnerability to health risks (such as pathogens and parasites), limiting colony productivity, growth, and survival. Spray applications of various agrichemicals affect the visitation patterns of pollinators through a range of different processes. 

Organic practices require not only refraining from the use of synthetic pesticides and fertilizers, but also taking positive actions to promote biodiversity. Providing organic habitats can protect pollinators, and all species, including humans, that depend on their ecosystem services. Please ensure that all of our state lands—including highway rights-of-way—are managed using organic methods. This will protect pollinators and people! 

Thank you. 

Target will hold its AGM Meeting on Wednesday, June 12, 2024! 

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.

Join us and a coalition of partner organizations from Friends of the Earth urging the CEO of Target, Brian Cornell, to take clear, measurable action on pollinator-toxic pesticides in its supply chain as the Target 2024 Annual Meeting of Shareholders approaches on June 12, 2024, at 1 PM Eastern! 

⬇️ Click below to send the following message!

Dear CEO Brian Cornell,

I urge Target to help protect bees, butterflies, and other pollinators by strengthening its pollinator health policy and taking clear, measurable action on pollinator-toxic pesticides in its supply chain. Bees and other pollinators are a cornerstone of Target's food supply. One of three bites of food we eat depends on pollinators, but they are in great peril. At current rates, forty percent of insect pollinators face extinction. Scientists around the world are warning that we are in the midst of an “insect apocalypse,” due in part to the overuse of toxic pesticides.  

>> Urge Target CEO Brian Cornell to protect pollinators by addressing the use of pesticides in its supply chain, increasing transparency, and urging a transition towards organic practices.

Target is falling behind competitors in pollinator protection. Target fell to 15th place on the 2023 Bee-Friendly Retailer Scorecard. Meanwhile, other companies are stepping up and taking action. Giant Eagle is eliminating the most pollinator-toxic neonicotinoids from its produce supply chain by 2025. And, Giant Eagle, Walmart, Whole Foods, and Kroger are requiring that all fresh produce suppliers adopt ecological farming methods called integrated pest management (IPM), as verified by a vetted list of third-party certifications. While these are important steps in the right direction, given the role pesticides play in the health and environmental crises we're facing, we need to go further.  

In order to protect pollinators, Target must address the use of pesticides that are driving pollinator declines by setting clear, timebound targets towards eliminating the use of toxic pesticides in its supply chains as well as taking meaningful action to transition towards organic and other ecological farming methods.  

To protect pollinators, people, and the planet, I urge Target to:  

Phase Out Toxic Pesticides: Establish a pollinator health policy that includes targets for phasing out and eliminating neonicotinoids, glyphosate, organophosphates, and other pollinator-toxic pesticides, as well as the implementation of alternative, least-toxic pest management strategies in company supply chains.  

Grow Organic: Increase USDA-certified organic food and beverages to at least 15 percent of overall offerings, prioritizing sourcing from domestic growers.  

Increase Transparency: Publicly disclose company policies and progress related to these actions.  

As one of the largest grocery retailers in the U.S., it's important that Target show leadership in making its food supply safer for farmers, farmworkers, consumers, and pollinators.  

>> Urge Target CEO Brian Cornell to protect pollinators by addressing the use of pesticides in its supply chain, increasing transparency, and urging a transition towards organic practices.

The target for this Action is the Target CEO Brian Cornell.

Thank you for your active participation and engagement!

The Biden administration, like others before it, has been removing obstacles to the spread of genetic engineering (GE) in agriculture. Two tools in expanding the use of GE are a document issued jointly last month by the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA), “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology” (Framework) and September 12, 2022, Executive Order 14081, “Advancing Biotechnology and Biomanufacturing Innovation for a Sustainable, Safe, and Secure Bioeconomy,” which aims to accelerate biotechnology innovation and grow the bioeconomy across multiple sectors. 

Although both of these documents address a broad range of biotechnology applications, the agricultural applications are noteworthy because they deny the reality of evolution, pose environmental and health hazards, and enrich chemical companies at the expense of farmers. 

>>Tell USDA, FDA, and EPA to replace agricultural provisions in the Framework with policies that discourage GE crops and promote organic agriculture. 

Two commonly used GE methods used in chemical-intensive agriculture are the creation of herbicide-tolerant crops and “plant-incorporated protectants” (PIPs). Both deny the existence of evolution, but weeds and insects do evolve resistance to the technology. With more than 70% of all GE crops altered to be herbicide resistant, the increased planting of herbicide-resistant GE crops has led to the evolution of "super weeds," the destruction of pollinator habitat, increased drift damage to neighboring fields, and increased use of herbicides. With the incorporation of Bacillus thuringiensis (Bt) genes into crop plants, insects evolved resistance to Bt toxins, and biotech companies started “stacking” genes for more toxins into their seeds, which merely delayed the inevitable.  

In deciding to ban GE corn, Mexico compiled a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, a report by CBAN (the Canadian Biotechnology Action Network) states, “Most GM corn plants are genetically modified to kill insect pests. The GM plants express a toxin from the soil bacteria Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects but not others. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops are different from this natural Bt in structure, function, and biological effects.” The report continues, “In fact, peer-reviewed studies across the scientific literature continue to find that Bt toxins in GM plants can harm insects (spiders, wasps, ladybugs, and lacewings, for example) that are not the intended targets.” 

Instead of trying to fight natural biological processes, organic agriculture works with the biology of crops and the surrounding ecosystem. Organic producers are required “to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” In doing so, not only do they respond to consumers' demand for healthful food uncontaminated by toxic pesticides, but they also contribute to the health of farmers and farmworkers, protect the land, air, and water from toxic chemicals, and help mitigate climate change. 

Federal agencies should not be promoting GE crops but should instead encourage a rapid transformation to organic agriculture nationwide.  

Consumers can avoid food with GE ingredients by buying organic food. 

>>Tell USDA, FDA, and EPA to replace agricultural provisions in the Framework with policies that discourage GE crops and promote organic agriculture.

The targets for this Action are the U.S. Department of Agriculture, the U.S. Environmental Protection Agency, the U.S. Food and Drug Administration, and the U.S. Congress.

Thank you for your active participation and engagement!

Letter to Secretary of Agriculture Tom Vilsack, EPA Administrator Michael Regan, and FDA Commissioner Robert Califf: 

The Biden administration, like others before it, has been removing obstacles to the spread of genetic engineering (GE) in agriculture. Two tools in expanding the use of GE are a document issued jointly last month by the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA), “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology” (Framework) and the September 12, 2022 Executive Order 14081, “Advancing Biotechnology and Biomanufacturing Innovation for a Sustainable, Safe, and Secure Bioeconomy,” which aims to accelerate biotechnology innovation and grow the bioeconomy across multiple sectors. 

Although both of these documents address a broad range of biotechnology applications, the agricultural applications are noteworthy because they deny the reality of evolution, pose environmental and health hazards, and enrich chemical companies at the expense of farmers. 

Two commonly used GE methods used in chemical-intensive agriculture are the creation of herbicide-tolerant crops and “plant-incorporated protectants” (PIPs). Both deny the existence of evolution, but weeds and insects do evolve resistance to the technology. With more than 70% of all GE crops altered to be herbicide resistant, the increased planting of herbicide-resistant GE crops has led to the evolution of "super weeds," the destruction of pollinator habitat, increased drift damage to neighboring fields, and increased use of herbicides. With the incorporation of Bacillus thuringiensis (Bt) genes into crop plants, insects evolved resistance to Bt toxins, and biotech companies started “stacking” genes for more toxins into their seeds, which merely delayed the inevitable.  

In deciding to ban GE corn, Mexico compiled a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, a report by CBAN (the Canadian Biotechnology Action Network) states, “Most GM corn plants are genetically modified to kill insect pests. The GM plants express a toxin from the soil bacteria Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects but not others. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops are different from this natural Bt in structure, function, and biological effects.” The report continues, “In fact, peer-reviewed studies across the scientific literature continue to find that Bt toxins in GM plants can harm insects (spiders, wasps, ladybugs, and lacewings, for example) that are not the intended targets.” 

Instead of trying to fight natural biological processes, organic agriculture works with the biology of crops and the surrounding ecosystem. Organic producers are required “to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” In doing so, not only do they respond to consumers’ demand for healthful food uncontaminated by toxic pesticides, but they also contribute to the health of farmers and farmworkers, protect the land, air, and water from toxic chemicals, and help mitigate climate change. 

Your agency should not be promoting GE crops but should instead encourage a rapid transformation to organic agriculture nationwide.  

Thank you. 

Letter to U.S. Representative and Senators: 

The Biden administration, like others before it, has been removing obstacles to the spread of genetic engineering (GE) in agriculture. Two tools in expanding the use of GE are a document issued jointly last month by the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA), “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology” (Framework) and the September 12, 2022 Executive Order 14081, “Advancing Biotechnology and Biomanufacturing Innovation for a Sustainable, Safe, and Secure Bioeconomy,” which aims to accelerate biotechnology innovation and grow the bioeconomy across multiple sectors. 

Although both of these documents address a broad range of biotechnology applications, the agricultural applications are noteworthy because they deny the reality of evolution, pose environmental and health hazards, and enrich chemical companies at the expense of farmers. 

Two commonly used GE methods used in chemical-intensive agriculture are the creation of herbicide-tolerant crops and “plant-incorporated protectants” (PIPs). Both deny the existence of evolution, but weeds and insects do evolve resistance to the technology. With more than 70% of all GE crops altered to be herbicide resistant, the increased planting of herbicide-resistant GE crops has led to the evolution of "super weeds," the destruction of pollinator habitat, increased drift damage to neighboring fields, and increased use of herbicides. With the incorporation of Bacillus thuringiensis (Bt) genes into crop plants, insects evolved resistance to Bt toxins, and biotech companies started “stacking” genes for more toxins into their seeds, which merely delayed the inevitable.  

In deciding to ban GE corn, Mexico compiled a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, a report by CBAN (the Canadian Biotechnology Action Network) states, “Most GM corn plants are genetically modified to kill insect pests. The GM plants express a toxin from the soil bacteria Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects but not others. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops are different from this natural Bt in structure, function, and biological effects.” The report continues, “In fact, peer-reviewed studies across the scientific literature continue to find that Bt toxins in GM plants can harm insects (spiders, wasps, ladybugs, and lacewings, for example) that are not the intended targets.” 

Instead of trying to fight natural biological processes, organic agriculture works with the biology of crops and the surrounding ecosystem. Organic producers are required “to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” In doing so, not only do they respond to consumers’ demand for healthful food uncontaminated by toxic pesticides, but they also contribute to the health of farmers and farmworkers, protect the land, air, and water from toxic chemicals, and help mitigate climate change. 

Please ensure that federal agencies are not promoting GE crops but instead encourage a rapid transformation to organic agriculture nationwide.  

Thank you. 

The House Agriculture Committee voted on May 23 to move the Farm, Food, and National Security Act out of committee after a contentious markup and onslaught of amendments that undermine water health, soil health, biodiversity, and local democratic authority to protect people and the environment from toxic pesticide exposure. The enthusiastic applause from industrial agriculture reveals its support for a system that relies on petrochemical-based pesticides—leading to economic instability, ecosystem collapse, and the degradation of democratic institutions. 

>> Tell Your U.S. Representative and Senators to support a Farm Bill that promotes a sustainable future.

The Federal Crop Insurance Program—which protects chemical-intensive farmers from the economic consequences of their actions—illustrates the problem. With support for entrenched dependency on petrochemical pesticides and fertilizers, the committee's bill requires taxpayers to pay through the government's crop insurance program for escalating losses caused by chemical-intensive farming practices, contributing to yield losses that the U.S. Department of Agriculture says are due to “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease...”  

However, the frequency of these climate disasters can no longer be attributed to “natural causes.” Climate change contributes to “natural” disasters including storms, drought, wildfires, extreme temperatures, and more—including earthquakes and volcanic activity. Agriculture is a major contributor to climate change. In a recent article in Science, Clark et al. show that even if fossil fuel emissions were eliminated immediately, emissions from the global food system alone would make it impossible to limit warming to 1.5°C and difficult even to realize the 2°C target. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced GHG emissions. Last year was a historic year of billion-dollar weather and climate disasters. 

In addition, the increase in commodity crop subsidies reliant on expensive pesticides and chemicals (accumulating $59.7 billion in production expenses for farmers as of 2022) will continue to be a significant factor in federal spending on interest payments on the national debt in the years ahead unless the Farm Bill stops propping up agricultural production systems that are contributing to costly environmental and revenue crises.  

The same industry interests that seek to increase federal spending on crop insurance for chemical-intensive agriculture are also in support of weakening local democratic institutions and decision-making processes with federal preemption language that directly impacts the ability of local governments and the courts to protect the public, including farmers, from associated harms.

>> Tell Your U.S. Representative and Senators to support a Farm Bill that promotes a sustainable future.

There are two central critiques of the House Farm Bill relating to federal preemption of local authority to restrict pesticides and the ability to litigate on harm caused by pesticides. The legislation:

1. Takes away the right to sue for failure to warn when harmed by pesticides. In Section 10204 of the House Farm Bill, language shields (gives immunity to) the producers and users of toxic pesticides from liability lawsuits associated with the harm that their products cause. The provision will block lawsuits like those successfully advanced against Bayer/Monsanto for adverse health effects, like cancer, associated with exposure to their products and companies' failure to warn about these effects on EPA approved product labels. 

2. Eliminates the rights of states and local governments to restrict pesticides and protect public health and the environment. In Sections 10204 and 10205, the attack on local and state authority to restrict pesticides is a bottom-line issue. Local restrictions on pesticide use in the face of ongoing poisoning and contamination have shown that effective land management does not require toxic pesticide use. Historically, localities have exercised their democratic right to protect public health and safety where state and federal standards are not adequately protective of their residents. Local governments have exercised this right in many areas affecting the health of people and the environment, such as with smoking, recycling, dog waste, and other standards. 

The House Farm Bill also threatens to undermine rulemaking and administrative accountability under provisions of the Endangered Species Act (ESA) and Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) that are intended to protect biodiversity and provide for public participation in decision making.  

For example, the bill removes the requirement for reinitiation of consultation on an approved land management plan when new threatened or endangered species or habitats are designated or new information becomes available about them—which would undermine protection for such species and habitats. The House Farm Bill would also expand the U.S. Forest Service's ability to exclude destructive practices like logging or road building from environmental review pursuant to the National Environmental Policy Act (NEPA) on 3,000 to 10,000-acre projects.  

Another provision would open the door for federal agencies to declare industry interests more valid than the interests of organizations fighting for stringent pesticide regulations that impact public health, biodiversity, and climate.  

The House bill contains additional problematic provisions undermining ecosystems and public health, including the continuation of a decade-long attack on the Clean Water Act (CWA) permitting program under the National Pollutant Discharge Elimination System (NPDES) that threatens local governments' ability to regulate pesticide discharge into waterways.  

The House Farm Bill fails on numerous levels to protect public health, ecosystems health, and long-term stability of the U.S. agricultural economy. Investing the same amount of funding and political will into the National Organic Program would not only ensure financial stability for farmers across the spectrum of markets, but also serve as a bulwark against the impending crises of climate change, biodiversity loss, and public health exacerbated by intervention from the toxic pesticide industry and their allies. 

>> Tell Your U.S. Representative and Senators to support a Farm Bill that promotes a sustainable future.

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

Thank you for your active participation and engagement!

Letter to U.S. Representatives and Senators: 

The House Agriculture Committee voted on May 23 to move the Farm, Food, and National Security Act (House Farm Bill) out of committee along with amendments undermining ecosystem health and local democratic authority. The enthusiastic applause from industrial agriculture reveals its support for a system that relies on petrochemical-based pesticides—leading to economic instability, ecosystem collapse, and the degradation of democratic institutions. 

The Federal Crop Insurance Program—which protects chemical-intensive farmers from the economic consequences of their actions—illustrates the problem. With support for entrenched dependency on petrochemical pesticides and fertilizers, the committee’s bill requires taxpayers to pay through the government’s crop insurance program for escalating losses caused by chemical-intensive farming practices, contributing to yield losses that the U.S. Department of Agriculture (USDA) says are due to “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease...”  

These climate disasters can no longer be attributed to “natural causes.” Climate change contributes to disasters such as storms, drought, wildfires, extreme temperatures, and more. Agriculture is a major contributor to climate change. In a recent article in Science, Clark et al. show that even if fossil fuel emissions were eliminated immediately, emissions from the global food system alone would make it impossible to limit warming to 1.5°C and difficult even to realize the 2°C target.  

The same industry interests that seek to increase federal spending on crop insurance for chemical-intensive agriculture are also in support of weakening local democratic institutions and decision-making processes with federal preemption language that directly impacts the ability of local governments and the courts to protect the public, including farmers, from associated harms. The House Farm Bill takes away the right to sue for failure to warn when harmed by pesticides and eliminates the rights of states and local governments to restrict pesticides and protect public health and the environment. Historically, localities have exercised their democratic right to protect public health and safety where state and federal standards are not adequately protective of their residents—a right exercised in many areas affecting the health of people and the environment, such as smoking, recycling, and dog waste. It is essential to maintain these rights. 

The House bill also threatens to undermine rulemaking and administrative accountability under provisions of the Endangered Species Act and Federal Insecticide, Fungicide, and Rodenticide Act that are intended to protect biodiversity and provide for public participation in decision making, such as removing the requirement to reinitiate consultation on an approved land management plan when new threatened or endangered species or habitats are designated, or new information becomes available about them and expanding the U.S. Forest Service’s ability to exclude destructive practices from environmental review under the National Environmental Policy Act. 

The House bill contains additional problematic provisions undermining ecosystems and public health, including the continuation of a decade-long attack on the Clean Water Act permitting program under the National Pollutant Discharge Elimination System (NPDES) that threatens local governments’ ability to regulate pesticide discharge into waterways.  

The House Farm Bill fails to protect public health, ecosystems health, and long-term stability of the U.S. agricultural economy. Investing funding and political will into the National Organic Program would not only ensure financial stability for farmers across the spectrum of markets, but also serve as a bulwark against the ongoing crises of climate change, biodiversity loss, and public health exacerbated by the toxic pesticide industry and their allies. 

Thank you. 

In view of the reliance on a loosely defined notion of “regenerative agriculture” that is becoming accepted as encompassing solutions to mitigate climate change, improve soil health, restore biodiversity, enhance ecosystems, and contribute to human health, it is refreshing to see the California Department of Food and Agriculture (CDFA) embark on a process of formulating a definition. However, past experience with poorly defined and unenforceable terms like Integrated Pest Management (IPM) and Sustainable Agriculture raises issues of concern that this well-intentioned effort to define regenerative could undermine the growth and continuous improvement in the widespread transition to certified organic practices that are necessary to eliminate the use of petrochemical pesticides and fertilizers and meet the existential environmental and health crises of our time. Given that 40 percent of all vegetables grown in the U.S. come from California, virtually all consumers of food have a stake in this debate on regenerative in the state. 

>>Tell CDFA and USDA that regenerative agriculture starts with organic. Comments to CDFA are due May 29, 2024.

CDFA's Environmental Farming Act Science Advisory Panel (SAP) proposes a framework for developing a definition: 

• Being applicable, relevant, and useful for California Agriculture. 
• Leading to positive impacts on California's environmental, social, human health, and economic goals, including climate goals. 
• Providing measurable and verifiable outcomes, keeping in mind variability throughout the state, and – emphasizing outcomes farmers and ranchers can easily measure and that are not economically burdensome to measure. 
• Allowing for context-specific outcomes (in terms of scale, geographic location, diverse and/or innovative agricultural systems, goals, etc.) 
• Include the idea that building soil health, including elements of physical quality, carbon sequestered, soil biodiversity, and alleviation of climate change (e.g., practices funded by the CDFA Healthy Soils Program) as a foundational element. 

However, that framework will be ineffective if definitions, policies, and rules fail to meet the following criteria: 

• Definition clarity and enforceability; 
• Systems plan (establishes baseline for management practices intended to create resiliency and prevent pests); 
• Rigorous standard for allowed/prohibited substances list with mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list; 
• Certification and enforcement system (third party enforcement); 
• Process for public participation to ensure a feedback loop for continuous improvement; and 
• Funding to ensure elements are carried out in a robust way. 

Regenerative agriculture must be organic. Organic agriculture, which has been widely adopted in California, fits the framework proposed by the SAP as well as the criteria above.  

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

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

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

Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers. In addition, studies have found organically grown plant foods and milk to be nutritionally superior to those produced by chemical-intensive agriculture. 

The National Organic Program provides for clarity and enforceability, while providing processes that are open and transparent to growers, consumers, and the public at large. As an established program, it also has its own funding mechanism. CDFA should start by defining “regenerative” as—at a minimum—meeting organic standards. 

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

>>Tell CDFA and USDA that regenerative agriculture starts with organic. Comments to CDFA are due May 29, 2024.

The target for this Action is the California Department of Food and Agriculture's Environmental Farming Act Science Advisory Panel and the U.S. Department of Agriculture. 

Thank you for your active participation and engagement!

Proposed letter to CDFA's SAP (if not using our form, please email [email protected])

We support the urgent need to adopt regenerative agricultural practices that mitigate climate change, improve soil health, restore biodiversity, enhance ecosystems, and contribute to human health. Past experience with poorly defined and unenforceable terms like Integrated Pest Management (IPM) and Sustainable Agriculture raises serious problems that well-intentioned efforts to define regenerative could repeat and, in the process, stifle the growth and continuous improvement of certified organic practices. Organic is a necessary baseline or foundation of a new regenerative standard because it eliminates the use of petrochemical pesticides and fertilizers in meeting the existential environmental and health crises of our time. A standard for “regenerative” must do this as well if it is to be helpful and not harmful in advancing the critical changes needed in this time of crises.

CDFA’s Environmental Farming Act Science Advisory Panel (SAP) proposes a framework for developing a definition. However, that framework will be ineffective if definitions, policies, and rules fail to meet these criteria:

1. Definition clarity and enforceability;
2. Systems plan (establishes baseline for management practices intended to create resiliency and prevent pests);
3. Rigorous standard for allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
4. Certification and enforcement system (third party enforcement);
5. Process for public participation to ensure a feedback loop for continuous improvement; and
6. Funding to ensure elements are carried out in a robust way.

Regenerative agriculture must be organic.
Organic agriculture, which has been widely adopted in California, fits the issues in the framework proposed by the SAP as well as the criteria above.

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

While recognizing practices that sequester carbon in the soil “regenerative agriculture” employing toxic chemicals ignores the direct climate impacts of synthetic nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact thatpesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients as well as for the heat and energy driving chemical reactions. It is important to see through this deception.

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

Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers.

The USDA organic seal is backed by an enforceable inspection system. CDFA should start by defining “regenerative” as—at a minimum—meeting organic standards.

Thank you.

Letter to Agriculture Secretary Tom Vilsack 

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

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

Agriculture must—across the board and on an expedited five-year schedule—shift to organic practices. Organic practices both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. Importantly, the data show that organic agriculture now operates without sacrificing productivity or profitability. While the vested economic interests in the petroleum and chemical industry cling to the status quo, there are good jobs and money to be made in a green economy. 

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

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

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

Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change.  

Thank you. 

At a time when serious measures are desperately needed to shift away from toxic pesticides to organic management systems, the California Assembly voted on Wednesday, May 22, 2024 to move forward with legislation that will codify continued reliance on hazardous materials that are no longer necessary. This is the wrong legislation to meet the existential challenges that are threatening our health, biodiversity, and the climate. The bill, AB2509, will enshrine in law integrated pest management (IPM) as a methodology for land management that continues to rely on hazardous materials that are unnecessary to achieving the pest management goal. If passed, not only will this bill fail to solve the long-term problems associated with vegetation management, but it will also contribute to the escalating and existential crises of our time.

Please contact your state senator as soon as you read this by clicking on the >> link below!

You can read Beyond Pesticides' written testimony on the bill before it passed out of committee here. 

>> Tell your state legislators to move beyond the IPM model and demand a vegetation management plan in alignment with an organic management system.

AB2509 contains two elements that must be corrected in light of state and national reliance on petrochemical pesticides (including herbicides) that are a threat to the health of the residents of California and the long-term sustainability of its environment. Those who have been involved in IPM as practitioners and academics have concluded that the approach and its definition have not lived up to the expectations that it would eliminate, rather than just “reduce,” the use of hazardous pesticides and fertilizers and replace them with practices and materials in sync with nature. 

Published in Agronomy for Sustainable Development. 41(38), 2021, researchers wrote an article entitled "Integrated pest management: good intentions, hard realities"—a review in which the authors state, “More than half a century after its conception, IPM has not been adopted to a satisfactory extent and has largely failed to deliver on its promise. Despite six decades of good intentions, harsh realities need to be faced for the future... IPM has arguably reached its limits.” The research team, all of whom have worked as IPM scientists and proponents, seems to mourn that IPM has “lost its way” over the decades—moving from ecological and health concerns as primary to its current state, in which (usually chemical) control methods are central. 

>> Tell your state legislators to move beyond the IPM model and demand a vegetation management plan in alignment with an organic management system. 

In contrast to AB2509, language is needed that specifically requires a systems approach to land management and the use of mechanical, biological, and a list of allowed materials compatible with the ecological systems approach governed by a systems-based land management plan. As we consistently and repeatedly say, sustainable management systems are needed that address the existential health and environmental crises of our time with carefully defined allowed materials in alignment with National Organics Standards and the List of Allowed and Prohibited Substances. Please see the Keeping Organic Strong page on our website for additional information.

A plan for a sustained solution, therefore, requires an emphasis on healing the disturbance (to which end, so-called “invasives” may sometimes be helpful), rather than killing the opportunist colonizer. Removal of such opportunist colonizers may be necessary based on an ecological assessment and an evaluation of the options to ensure a long-term solution compatible with environmental health, but the use of toxic chemicals is no longer justified in the process. 

Communities and land managers confront species that are defined by law or in the common parlance as “invasive.” While the solution has been to identify those species and then allow the toxic pesticide use exemption under community land management policies and state law, a sustained solution protective of health and the environment requires a more analytical approach that evaluates the species, the problem it poses, and the underlying causes that have invited and support the unwanted organism.  

In this context, the threshold for action, the type of action, and the health of the ecosystem in which the organism lives are factors that require consideration. When confronted with an unwanted plant, consideration must be given to both the short- and long-term solution, ensuring that the immediate action does not create a greater problem in the future.  

The tools exist to effect a strategy for managing unwanted plants that is protective of our health and the environment. It starts with asking the right questions. 

>> Tell your state legislators to move beyond the IPM model and demand a vegetation management plan in alignment with an organic management system.

The target for this Action is the California State Senate, previously the California State Assembly.

Thank you for your active participation and engagement!

A global transition to organic agriculture and land care is necessary if we are to seriously take on the challenges of the public health crisis, biodiversity collapse, and the climate emergency. Approximately every five years, Congress passes a Farm Bill, a comprehensive omnibus bill setting policy and funding for agricultural and food programs. The Farm Bill offers an opportunity to grow organic agriculture; however, this cannot be done at the expense of attacking the rights of states and local governments to restrict pesticides and protect public health and the environment. 

>>Tell your U.S. Congressional Representative and Senators to support organic agriculture in the Farm Bill, but not at the expense of undermining local and state authority to enact more stringent restrictions of pesticides.

The attack on local and state authority to restrict pesticides is a bottom-line issue. As momentum builds for local restrictions on pesticide use in the face of ongoing poisoning and contamination, it is clear that effective land management does not require toxic pesticide use. Historically, local municipalities have exercised their democratic right to protect public health and safety where state and federal standards are not adequately protective of their residents. Congress should not be stepping into states to tell local governments that they cannot exercise this right, as they have done with smoking, recycling, dog waste, and other standards. The House Republican bill states boldly that, “A political subdivision of a state shall not impose any requirement relating to the sale, distribution, labeling, application, or use of any pesticide or device,” challenging the right of states and localities to exercise local governance and the democratic process. This language, at this point, is not in the Senate Democrats' bill. 

While Farm Bill negotiations have been stalled for months, the Democrat-led Senate and Republican-led House of Representatives presented their respective visions to amend the 2024 Farm Bill. The office of U.S. Senator Debbie Stabenow (D-MI), chair of the Senate Agriculture Committee, released an initial Senate framework for the (now 2024) Farm Bill. At the same time, U.S. Representative Glenn Thompson (R-PA), chair of the House Agriculture Committee, released an outline of the House version, then followed up with more details and legislative language ("Farm, Food, and National Security Act of 2024"). 

While the anti-democratic Republican language in the House makes the overall bill unacceptable, the Senate Democrats' proposal includes robust support for expanding and strengthening organic product supply chains and domestic production, recognizing their economic, ecological, and public health benefits. House Republican language in support of organic is undermined by a framework that preempts local restrictions of pesticides.  

With the chemical industry and allied companies pushing for the preemption of state authority over local democratic decision making, contained in the House Republican bill, advocates are concerned that the same industry lobby will seek to shield the producers and users of toxic pesticides from liability lawsuits associated with the harm that their products cause. This would block lawsuits like those successfully advanced against Bayer/Monsanto for adverse health effects, like cancer, associated with exposure to their products and companies' failure to warn about these effects. 

Advocates are seeking to eliminate provisions in the House Republican bill that preempt a state and local government's right to restrict pesticides, while supporting the following elements in the Senate and House framework that nurtures the growth of organic agriculture by: 

• Addressing organic certification costs; 
• Funding organic oversight and enforcement; 
• Supporting organic transition; 
• Addressing bottlenecks in organic regulatory actions; 
• Providing mandatory funding for organic research and data collection; 
• Making organic programs work for organic farmers; and 
• Establishing an Organic Agriculture Research Coordinator who will coordinate and establish annual strategic priorities. 

The bipartisan consensus that organic supply chains and markets must continue to be nurtured as recognition of their importance to sustainability, rather than put on the legislative chopping block, is welcomed. Certified organic agriculture has grown over the past four decades from a voluntary standard—organized by farmers and grassroots consumers and organizations representing farmers, environmentalists, community leaders, physicians, and rural and urban communities—to a $70 billion industry. In the same period, considerable scientific literature continues to underscore the significance of a wholesale transition to organic from chemical-intensive food systems to adequately address the cascading crises of climate change, biodiversity loss, and public health. 

With the chemical industry and those who use their products in agriculture and land management increasing their lobbying efforts, the Agricultural Labeling Uniformity Act (ALUA) and Ending Agricultural Trade Suppression Act (EATS Act) have effectively been included in the 2024 House Republican Farm Bill provisions that inevitably undermine local and state authority to enact more stringent agricultural and land management policies that would support public health, biodiversity, and climate action. The EATS Act's stated purpose is to “prevent States and local jurisdictions from interfering with the production and distribution of agricultural products,” effectively preempting local and state health and environmental concerns regarding agricultural land use. Meanwhile, ALUA threatens to undermine local and state authority to protect the health of their residents from toxic pesticide use on public land—effectively overturning decades of Supreme Court precedent. 

>>Tell your U.S. Congressional Representative and Senators to support organic agriculture in the Farm Bill, but not at the expense of undermining local and state authority to enact more stringent restrictions of pesticides.

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

Thank you for your active participation and engagement!

Letter to U.S. Senators and Representatives: 

I am writing to ask you to support a Farm Bill that helps to grow organic agriculture, but does not undermine, or preempt, state and local authority to restrict toxic pesticides. A global transition to organic methods is necessary if we are to seriously take on the challenges of the public health crisis, biodiversity collapse, and the climate emergency. We cannot achieve these changes with organic if preemption language in the House Republican bill is adopted.   

The attack on local and state authority to restrict pesticides is a bottom-line issue. As momentum builds for local restrictions on pesticide use in the face of ongoing poisoning and contamination, it is clear that effective land management does not require toxic pesticide use. Historically, localities have exercised their democratic right to protect public health and safety where state and federal standards are not adequately protective of their residents. Congress should not be stepping into states to tell local governments that they cannot exercise this right, as they have done with smoking, recycling, dog waste, and other standards. The House Republican bill states boldly that, “A political subdivision of a state shall not impose any requirement relating to the sale, distribution, labeling, application, or use of any pesticide or device,” challenging the right of states and localities to exercise local governance and the democratic process. This language, at this point, is not in the Senate Democrats’ bill.  

While the anti-democratic Republican language in the House makes the overall House bill unacceptable, the Senate Democrats’ proposal includes robust support for expanding and strengthening organic product supply chains and domestic production, recognizing its economic, ecological, and public health benefits. House Republican language in support of organic is undermined by a framework that preempts local restrictions of pesticides.   

Please seek to eliminate provisions in the House Republican bill that preempt the state and local government’s right to restrict pesticides while supporting the following elements in the Senate and House framework that nurtures the growth of organic agriculture by:  

*Addressing organic certification costs;  
*Funding organic oversight and enforcement;  
*Supporting organic transition;  
*Addressing bottlenecks in organic regulatory actions;  
*Providing mandatory funding for organic research and data collection;  
*Making organic programs work for organic farmers; and  
*Establishing an Organic Agriculture Research Coordinator who will coordinate and establish annual strategic priorities.  

Let’s make the Farm Bill a bipartisan consensus bill that builds a positive future, by growing organic supply chains and markets with the recognition of their importance to sustainability. Certified organic agriculture has grown over the past four decades from a voluntary standard organized by farmers and grassroots consumers and organizations representing farmers, environmentalists, community leaders, physicians, and rural and urban communities to a $70 billion industry. In the same period, considerable scientific literature continues to underscore the significance of a wholesale transition to organic from chemical-intensive food systems as a way to adequately address the cascading crises of climate change, biodiversity loss, and public health.   

Please support organic agriculture in the Farm Bill and reject language that undermines, or preempts, local and state authority to enact more stringent land management policies that protect health and the environment.  

Thank you. 

Please join us today by calling on New Hampshire Governor Chris Sununu to veto House Bill (HB) 1698. This bill would allow the aerial spraying of pesticides by drones up to 20 feet in the air without notifying the public, threatening the well-being of pollinators, wildlife, and New Hampshire residents who may cross their path. HB 1698 passed both the House and Senate as of last week, and it is slated to cross the Governor's desk potentially within the week! 

>> Tell Governor Sununu to veto HB 1698-FN exempting aerial application of pesticides using drones from notification processes, exposing Granite State families and pollinators to poisons hazardous to our health. 

House Bill 1698 exempts the application of pesticides using drones from notification procedures. The bill adds a new paragraph to RSA 430:34-a, stating that the notification requirements for aerial pesticide application do not apply to the aerial application of pesticides by a person with a valid certificate of registration or permit, while using unmanned aircraft for agricultural purposes at a height not exceeding 20 feet above ground level. The bill will take effect 60 days after its passage. 

There was an attempt to add a floor amendment in the 11th hour that would have established a notification provision if drone spraying occurred within 200 feet of an apiary site, however it failed to pass. Without this provision, there will be no notification requirements if the bill were to be passed into law in its current form. 

This proposed legislation language flies in the face of what can and should be New Hampshire's comprehensive approach to ensure those at greatest risk from pesticide exposure—children, those with preexisting health conditions, essential workers, and landscapers—are fully protected. The bill's language is unacceptable, given the known harms of pesticide drift through the air, waterways, and soil.   

Beyond Pesticides opposes HB 1698-FN based on decades of experience reviewing the latest scientific analysis regarding commonly used toxic pesticides in public and private spaces. Beekeepers across the state, including New Hampshire Beekeepers' Association, have expressed sharp opposition to this bill as a threat to their livelihoods and surrounding ecosystems that depend on pollinators.  

Click here to view Beyond Pesticides' testimony in opposition to the bill.

Please urge the Governor to take action today—thank you for your help protecting public health in New Hampshire! 

>> Tell Governor Sununu to veto HB 1698-FN exempting aerial application of pesticides using drones from notification processes, exposing Granite State families and pollinators to poisons hazardous to our health.

The target for this Action is the New Hampshire Governor Chris Sununu.

Letter to Governor Sununu:

As a constituent, I urge you to take immediate action to veto HB 1698-FN, which would harm New Hampshire's pollinators and environment. Pesticide drift, which is inevitable in aerial spraying, can cause acute poisoning and/or chronic health impacts in New Hampshire farmworkers, their families, or residents in the application area or working in nearby treated fields, including schools, playgrounds, recreational fields, and other facilities frequented by young children.  

House Bill 1698 exempts the application of pesticides using drones from notification procedures when they are sprayed up to 20 feet in the air. Any language short of notification at any height will muddy the waters and leave communities open to public health risks. There was an attempt to add a floor amendment in the 11th hour that would have established a notification provision if drone spraying occurred within 200 feet of an apiary site, however it failed to pass. Without this provision or one like it, there would be no notification requirements if the bill were to be enacted into law in its current form.

This bill exempts the aerial application of pesticides using drones from notification processes, potentially endangering pollinators crucial for our food system and biodiversity due to pesticide drift. Pesticides harm pollinators and pose risks to human health and wildlife.

With federal officials' complete inaction, the Granite State must play a critical role in protecting its residents’ public health and unique local environment. Let's come together to protect our pollinators and ecosystems. Your voice will make a difference in safeguarding New Hampshire's natural heritage.

I appreciate your commitment to this vital cause. Together, we can advocate for policies that prioritize the well-being of our ecosystems.  

Please veto HB 1698-FN in its entirety. Thank you for your leadership!

USDA is proposing new regulations for organic certification of mushrooms and pet food. While the proposals are needed and long overdue, there are problems that need correcting: (i) re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources. 

>>Tell USDA to ensure that certified organic fungi and pet food are truly organic. 

Mushrooms: Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards as well. Fungi deserve, and need, their own scope of certification which recognizes their unique biology and can foster consistency in their cultivation and certification. 

Additionally, there are already some organic fungal products in the marketplace that are not mushrooms, such as drink powders made from lion's mane mycelium as well as the fruiting body and mycelium extract dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling but would fit better under a separate fungi scope. Framing new production standards to include only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for future innovative products to become certified. Conversely, framing new production standards to include all fungi would not only provide a better fit for current organic fungal products, but provide ample room for additional markets to develop. 

In 2001, the NOSB recommended that organic mushrooms must be grown on organic substrate. Since fungi are composed of digested substrate, only mushrooms grown on organic substrate—manure derived from organic sources or untreated wood that is grown without prohibited substances—can validly claim the organic seal. 

Pet Food: While Beyond Pesticides supports bringing organic pet food production into conformance with livestock standards, when incorporating meat into its products, it disagrees with the NOSB recommendation and USDA's proposal to allow the use of synthetic taurine for all pet food. The allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the Organic Foods Production Act, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by a manufacturer, it is difficult to argue that it is not available in its natural form. As Nature's Logic® states on its website: 

Since our foods are made from high levels of animal protein, all Nature's Logic diets naturally contain sufficient levels of the Omega-3 fatty acids, eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA). They also exceed AAFCO*'s protein amino acid requirements for arginine, histidine, isoleucine leucine, lysine, methionine-cystine, methionine, phenylalanine-tyrosine, phylalanine, taurine, threonine, tryptophan, and valine. 

Therefore, Beyond Pesticides is urging USDA to reject the recommendation to add taurine to the National List for pet food. Note that synthetic taurine has been petitioned and rejected for allowance in baby formula. 

>>Tell USDA to ensure that certified organic fungi and pet food are truly organic.

The target for this Action is the U.S. Department of Agriculture, with public comments via Regulations.gov.

Thank you for your active participation and engagement!

Proposed comment to the USDA:

USDA’s proposed regulations for organic certification of mushrooms and pet food are needed and long overdue, but there are problems that need correcting: (i) re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources. 

Mushrooms. Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised of carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards. They require their own scope of standards, recognizing their unique biology, which fosters consistency in their cultivation and certification. 

There are already organic fungal products in the marketplace that are not mushrooms, but made from mycelium, such as drink powders and dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling, but would fit better under a separate fungi scope. New production standards including only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for innovative products to become certified. Framing new production standards to include all fungi would not only provide a better fit for current organic fungal products, but provide ample room for additional markets to develop. 

In 2001, the NOSB recommended that organic mushrooms must be grown on organic substrate. Since fungi are composed of digested substrate, only mushrooms grown on organic substrate—manure derived from organic sources or untreated wood that is grown without prohibited substances—can validly claim the organic seal. 

Please modify the proposed mushroom standard to: 1) give fungi—not mushrooms—a separate scope; 2) cover all fungi forms; and 3) require that certified organic fungi be grown on organic substrate. 

Pet Food: The pet food rule attempts to bring pet food production and materials standards in line with organic standards. It also adds an allowed synthetic amino acid, taurine, to the National List of Allowed and Prohibited Substances. Some pet food manufacturers maintain that the amino acid is necessary to fulfill a macronutrient requirement for cats and dogs.  

I support bringing organic pet food production into conformance with organic standards and incorporating meat into its products. However, I disagree with USDA’s proposal to allow the use of synthetic taurine for all pet food. The allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the Organic Foods Production Act, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by at least one manufacturer—Nature’s Logic®—it is difficult to argue that the substance is not available in its natural form. The original recommendation to add taurine for pet food was made in 2008, and it should be revisited by the NOSB before adding it into the regulations. 

I urge USDA to reject the recommendation to add taurine to the National List for pet food.  

Thank you. 

According to a new analysis by Consumer Reports (CR), the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. CR's results are based on Consumer Reports-adjusted reference doses for all pesticides, including those linked to endocrine disruption, as mandated by the Food Quality Protect Act (FQPA) of 1996. As a result, CR is petitioning EPA to cancel the registrations of organophosphate (OP) and carbamate pesticides. 

To sign on and support Consumer Report's petition, please make sure to click the check box at the bottom of the form linked below!

>>Support CR's petition and tell EPA / Congress to ban all toxic pesticides when the crop can be produced organically.

EPA's failure to consider endocrine disruption is only one of many problems with relying on the agency's tolerances as an indication of acceptable risk of pesticide use. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife. 

Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a result of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. Not only is the production of organic food better for human health and the environment than chemical-intensive production, but emerging science reveals also what organic advocates have been saying for a long time—in addition to lacking the toxic residues of conventional foods, organic food is more nutritious and it does not poison the people and contaminate the communities where the food is grown. 

A study published by The Organic Center reveals that organic food is higher in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally beneficial. Another study published in the Journal of Agricultural Food Chemistry looks specifically at the total phenolic content of marionberries, strawberries, and corn, and found that organically grown products contain higher total phenolics. Phenolics are important for plant health (defense against insects and diseases), and human health for their “potent antioxidant activity and wide range of pharmacologic properties, including anticancer, antioxidant, and platelet aggregation inhibition activity.”   

In view of the advantages of organic production, EPA must use organic production as the yardstick when weighing risks and benefits of pesticides. No pesticide should be allowed to be used if the crop can be produced organically. 

>> Support CR's petition and tell EPA / Congress to ban all toxic pesticides when the crop can be produced organically.

The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress, with an option to support Consumer Report's petition.

Thank you for your active participation and engagement!

Letter to EPA: 

According to a new analysis by Consumer Reports (CR), the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. CR’s results are based on including endocrine disruption, as mandated by the Food Quality Protect Act (FQPA) of 1996. As a result, CR is petitioning EPA to cancel the registrations of organophosphate (OP) and carbamate pesticides. I support CR’s petition, and request that EPA further evaluate pesticides compared to the organic production of crops. 

EPA’s failure to consider endocrine disruption is only one of many problems with relying on the agency’s tolerances as an indication of acceptable risk of pesticide use. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife. 

Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a result of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. Not only is the production of organic food better for human health and the environment than chemical-intensive production, but emerging science reveals also what organic advocates have been saying for a long time—in addition to lacking the toxic residues of conventional foods, organic food is more nutritious. 

A study published by The Organic Center reveals that organic food is higher in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally beneficial. Another study published in the Journal of Agricultural Food Chemistry looks specifically at the total phenolic content of marionberries, strawberries, and corn, and found that organically grown products contained higher total phenolics. Phenolics are important for plant health (defense against insects and diseases), and human health for their “potent antioxidant activity and wide range of pharmacologic properties including anticancer, antioxidant, and platelet aggregation inhibition activity.”   

In view of the advantages of organic production, EPA must use organic production as the yardstick when weighing risks and benefits of pesticides. No pesticide should be allowed to be used if the crop can be produced organically. 

Thank you. 

Letter to U.S. Representative and Senators:

According to a new analysis by Consumer Reports (CR), the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. CR’s results are based on including endocrine disruption, as mandated by the Food Quality Protect Act (FQPA) of 1996. As a result, CR is petitioning EPA to cancel the registrations of organophosphate (OP) and carbamate pesticides. I support CR’s petition, and request that EPA further evaluate pesticides compared to the organic production of crops. 

EPA’s failure to consider endocrine disruption is only one of many problems with relying on the agency’s tolerances as an indication of acceptable risk of pesticide use. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife. 

Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a result of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. Not only is the production of organic food better for human health and the environment than chemical-intensive production, but emerging science reveals also what organic advocates have been saying for a long time—in addition to lacking the toxic residues of conventional foods, organic food is more nutritious. 

A study published by The Organic Center reveals that organic food is higher in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally beneficial. Another study published in the Journal of Agricultural Food Chemistry looks specifically at the total phenolic content of marionberries, strawberries, and corn, and found that organically grown products contained higher total phenolics. Phenolics are important for plant health (defense against insects and diseases), and human health for their “potent antioxidant activity and wide range of pharmacologic properties including anticancer, antioxidant, and platelet aggregation inhibition activity.”   

In view of the advantages of organic production, EPA must use organic production as the yardstick when weighing risks and benefits of pesticides. No pesticide should be allowed to be used if the crop can be produced organically. 

Thank you. 

Pesticide and chemical manufacturers have descended on state legislators in Missouri with legislation to shield them from liability lawsuits filed by people injured from exposure to their products. The chemical industry is asking for immunity from lawsuits on adverse effects that are not fully disclosed and legislation has already moved through the Missouri House of Representatives.  

So far, the industry has successfully introduced its bill in at least four states. This activity is spurred on by the thousands of successful cases involving the weed killer Roundup/glyphosate that have resulted in large jury awards against Bayer/Monsanto in the billions of dollars. While sponsors of these bills claim that the labels on pesticide products provide sufficient warning of hazards, users have been misled by advertising that falsely touts product safety. In fact, pesticides are registered by EPA under standards of what the agency calculates as “acceptable” harm, despite the availability of less or nontoxic alternatives. Reminiscent of previous battles, the chemical industry is now leaning on elected officials, both in state legislatures and the U.S. Congress, to do its bidding in blocking, or preempting, court action.  

>>Tell your state legislators to protect the right of citizens to seek redress against pesticide manufacturers from harm caused by their products.  

In 1991, after losing the landmark U.S. Supreme Court case Wisconsin Public Intervenor v. Mortier, which upheld the right of local governments to restrict pesticide use under federal pesticide law, the pesticide industry went to every state legislature to preempt local authority. Preemption language was quickly enshrined in the state law of 43 states. Now, after being rebuffed by the Supreme Court in 2022 in an attempt to overturn large liability judgments against Monsanto/Bayer for glyphosate hazards, the industry is asking state legislatures to block future liability for pesticide manufacturers whose products cause harm. So far, similar bills to limit liability have been introduced in four states, and more are expected.    

As an example of such legislation, a bill recently approved by the Missouri House will provide pesticide manufacturers with legal protection from “failure-to-warn" liability. This legal approach has been pivotal for those who have used pesticide products and are seeking redress because of harm caused.  

The Missouri House, by a slim margin, voted in favor of HB 2763. The companion bill, SB 1416, if passed by the Missouri Senate, will provide legal protection to pesticide manufacturers from “failure-to-warn" liability.  

While other causes of action are often pursued, the overwhelming majority of successful cases for pesticide injury lawsuits fall under “failure-to-warn" claims. Brigit Rollins, a National Agricultural Law Center staff attorney, describes this liability framework as “a type of civil tort that is frequently raised in product liability cases. Unlike negligence and design defect...failure to warn does not argue that a product has physical faults. Instead, a plaintiff typically raises failure to warn claims to allege that a product manufacturer failed to provide adequate warnings or instructions about the safe use of a product.” Under the new push in Missouri and several state legislatures, this legal framework would be moot, leaving victims around the United States without effective legal recourse and releasing industry actors such as Bayer/Monsanto from billions of dollars in ongoing and future settlements. As of 2022, Bayer settled over 1,000 lawsuits, paying out approximately $11 billion, and faces an additional 30,000 lawsuits now pending.  

Glyphosate litigation is a notable example of why the dependence on EPA's labels provides inadequate protection—in this case, for users of the pesticide, but also for neighboring farms, farmworkers and bystanders, consumers of contaminated food and water, and the biosphere. Legislators who choose to restrict the right of injured parties to seek recompense from pesticide manufacturers are doing their constituents a tremendous disservice. 

>>Tell your state legislators to protect the right of citizens to seek redress against pesticide manufacturers from harm caused by their products.

The target for this Action is the Missouri State Legislature. 

Letter to Missouri state legislators:

I am writing to ask you to oppose SB 1416 because it would shield pesticide and toxic chemical manufacturers from lawsuits when users of their products are injured from their exposure to the chemicals.  

Legislation like this is popping up around the country and is unfair to people who have been harmed, despite their compliance with product labels. As you may know, numerous cases against Bayer/Monsanto involving the weed killer glyphosate (RoundupTM) have resulted in large jury awards and settlements for those who have been harmed. The manufacturer has appealed verdicts to the U.S. Supreme Court twice and has been rebuffed each time, so they are now asking states to prevent victims from seeking compensation. Although sponsors of these bills claim that the pesticide label is a sufficient warning, users have been misled by advertising touting the products’ safety. 

The Missouri House voted in favor of HB 2763 by a slim margin. If the companion bill, SB 1416, passes the Missouri Senate, it will provide legal protection to pesticide manufacturers from “failure-to-warn" liability. This legal approach has been pivotal for pesticide users seeking redress from exposure to glyphosate-based herbicide products such as Roundup and other toxic pesticide products.  

While other causes of action are often pursued, the overwhelming majority of successful cases for pesticide injury lawsuits fall under “failure-to-warn" claims. Brigit Rollins, a National Agricultural Law Center staff attorney, describes this liability framework as “a type of civil tort that is frequently raised in products liability cases. Unlike negligence and design defect...failure to warn does not argue that a product has physical faults. Instead, a plaintiff typically raises failure to warn claims to allege that a product manufacturer failed to provide adequate warnings or instructions about the safe use of a product.” Under the new push in the Missouri legislature, this legal framework would be moot, leaving victims without effective legal recourse and releasing industry actors such as Bayer from billions of dollars in ongoing and future settlements. As of 2022, Bayer settled over 1,000 lawsuits paying out approximately $11 billion and faces an additional 30,000 lawsuits pending. 

Glyphosate litigation is a notable example of why the dependence on EPA’s labels provides inadequate protection—in this case, for users of the pesticide, but also for neighboring farms, farmworkers and bystanders, consumers of contaminated food and water, and the biosphere. Legislators who choose to restrict the right of injured parties to seek compensation from pesticide manufacturers are doing their constituents a tremendous disservice. 

I urge you to oppose SB 1416 as it will restrict the rights of injured parties in our state—whether they be users of the pesticide, neighboring farms, farmworkers, landscapers, bystanders, consumers of contaminated food and water, or defenders of nature—to recover damages from pesticide manufacturers. 

Thank you. 

While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring. 

>> Tell EPA to ban carcinogenic pesticides. Tell your Congressional Representative and Senators to support S. 269 and H.R. 5085, the Protect America's Children from Toxic Pesticides Act of 2023 (PACTPA).

Many studies indicate prenatal and early-life exposure to environmental toxicants increases disease susceptibility. For decades, studies have long demonstrated that childhood and in-utero exposure to the U.S.-banned insecticide DDT increases the risk of developing breast cancer later in life. Risks from exposure to pesticides and other toxic chemicals during pregnancy include pesticides and children's sleep disorders; prenatal exposures to a multitude of chemicals; insecticides and childhood leukemia; and insecticides and Attention Deficit/Hyperactivity Disorder. 

A study published in Environmental Research suggests occupational (work-related) exposure to pesticides among nonpregnant women and men may increase childhood cancer risk for offspring. Low levels of pesticide exposure during pregnancy or childhood cause adverse health effects, from metabolic disorders to mental and physical disabilities. Moreover, several studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer, specifically focusing on leukemia. Acute leukemia is the most common type of childhood cancer, accounting for one of three cancer cases in children ages 0 to 14. Although the disease is rare, incidents have been steadily increasing among adolescents over the last 30 years.  

Researchers at the National Institute of Pediatrics and National Polytechnic Institute found positive associations between pesticide exposure and heightened risk of certain childhood cancers. The finding is derived from a meta-analysis of 174 studies published between 2013 and 2023 and reported in the International Journal of Molecular Science. The authors note, “Although [pesticide exposure] association with childhood cancer has not been fully demonstrated, we found that more than 80% of the epidemiological studies show positive associations [with forms of childhood cancer].” 

Even household cleaners, many of which are pesticides, can increase nephroblastoma (kidney cancer) and brain tumor risk in children. Furthermore, long-term exposure to organophosphate (OP) pesticides increases adverse health and cancer risks, specifically among women. Since DDT and its metabolite DDE residues, current-use pesticides, and other chemical pollutants contaminate the environment, exposure to these chemical mixtures can synergize to increase toxicity and disease effects. 

A literature review published in Ciência & Saúde Coletiva finds that environmental exposure to all classes of pesticides (fungicides, herbicides, insecticides) is associated with childhood astrocytoma (brain/central nervous system [CNS] tumor). CNS tumors represent half of all malignant neoplasms (tumors) in children. 

>> Tell EPA to ban carcinogenic pesticides. Tell your Congressional Representative and Senators to support S. 269 and H.R. 5085, the Protect America's Children from Toxic Pesticides Act of 2023 (PACTPA).

A 2024 Environmental Research study found an association between adverse neurodevelopment (brain function and development) among infants and exposure to the herbicide glyphosate during pregnancy, which becomes more pronounced at 24 months. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure, leading to reduced melatonin levels that ultimately disrupt circadian rhythm and lead to sleep disorders later in life, according to a 2023 study in Antioxidants. 

In addition to maternal/prenatal exposure to herbicides, children experience exposure to pyrethroid insecticides early in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life, according to a study published in Frontiers in Public Health in 2023. Moreover, pediatricians strongly agree that pregnant mothers and young children should avoid pesticide exposure during critical development periods.

The state of pesticide regulation and of research into pesticide impacts is inadequate and like nothing so much as a game of “whack-a-mole.” A single pesticide or class of pesticides is studied, a paper is written, and policymakers and regulators may or may not pay attention. Then another one happens, and another, and another, ad infinitum. The pattern of “progress” is similar on the regulation side: individual pesticides registered (aka, approved) by the U.S. Environmental Protection Agency (EPA) are reviewed “on the regular” — but only every 15 years, barring an emergent and urgent concern. Given the cascade of discovery of harmful impacts over the past couple of decades, 15 years has become a very long window to allow continued use without review. 

When EPA undertakes a more timely review due to an urgent concern, it still considers one chemical at a time. Even more fundamentally, its approach to regulation, in the face of evidence of harm, is often characterized by tweaking the use of toxic pesticides “at the margins” — requiring a change to the text on a pesticide label, reducing the time frame in which a compound can be used, restricting application to trained applicators, or other piecemeal actions that are generally wholly inadequate to reducing the health and environmental harms of these compounds being unleashed into the environment. 

EPA also continues to fall short on multiple research and regulatory fronts, failing to consider synergistic impacts, multiple exposure vectors, and endocrine disruption effects, among other things. In addition, the agency is far too dependent on industry-generated research, influenced by agrochemical industry lobbying and sometimes in downright collusion with industry. 

It is unconscionable to continue tweaking restrictions on pesticides with known hazards and broad uncertainties about the effect of mixtures, synergistic effects, and cumulative risk, given the availability of organic systems that eliminate those hazards economically and solve the looming environmental threats. Buying, growing, and supporting organic land management can reduce human and environmental contamination from pesticides. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices. Numerous studies find that pesticide metabolite levels in urine significantly decrease when switching to an all-organic diet. 

Globally, cancer is one of the leading causes of death, with over eight million people succumbing to the disease every year. Notably, the International Agency for Cancer Research (IARC) predicts a 67.4 percent rise in new cancer cases by 2030. Thus, it is critical that both government officials and the public understand the health implications of pesticide use and exposure on humans, especially when pesticides increase chronic disease risk. 

Some elected officials are attempting to take action. The Protect America's Children from Toxic Pesticides Act of 2023 (PACTPA), S. 269 and H.R. 5085, 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. 

>> Tell EPA to ban carcinogenic pesticides. Tell your Congressional Representative and Senators to support S. 269 and H.R. 5085, the Protect America's Children from Toxic Pesticides Act of 2023 (PACTPA).

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:

Occupational exposure to pesticides among nonpregnant women and men may increase childhood cancer risk for offspring. Studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer, specifically leukemia. Acute leukemia is the most common type of childhood cancer, accounting for one of three cancer cases in children ages 0 to 14, and incidence has been steadily increasing among adolescents over the last 30 years.   

Even household cleaners, many of which are pesticides, can increase kidney and brain cancer risk in children. Long-term exposure to organophosphate pesticides increases adverse health and cancer risks. A literature review published found environmental exposure to all classes of pesticides is associated with childhood brain/central nervous system tumors, representing half of all malignant tumors in children.  

Adverse neurodevelopment among infants is associated with exposure to glyphosate during pregnancy. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure. In addition to maternal/prenatal exposure to herbicides, children experience exposure to pyrethroid insecticides early in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life.   

Moreover, pediatricians strongly agree that pregnant mothers and young children should avoid pesticide exposure during critical development periods.  

The state of pesticide regulation and research into pesticide impacts is inadequate and resembles a game of “whack-a-mole,” in which single pesticides or a class of pesticides are studied for specific effects. The EPA only considers one chemical at a time, ignoring research showing that the synergy of exposure to multiple chemicals in the environment increases toxicity and disease effects. All of these effects have environmental justice implications since farmworkers are most exposed.  

More fundamentally, the approach to regulation in the face of evidence of harm, characterized by tweaking the use of toxic pesticides—requiring a change to the text on a pesticide label, reducing the time frame in which a compound can be used, restricting application to trained applicators, or other piecemeal actions—is wholly inadequate to reduce the health and environmental harms of these compounds being unleashed into the environment.  

It is unconscionable to continue tweaking restrictions on pesticides with known hazards and broad uncertainties about the effect of mixtures, synergistic effects, and cumulative risk, given the availability of organic systems that eliminate those hazards economically and solve the looming environmental threats. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices. 

Our children’s health requires the elimination of cancer-causing pesticides.  

Thank you. 

Letter to U.S. Representative and Senators who are co-sponsors of PACTPA: 

I am writing out of concern that our pesticide law is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects. 

The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269 and H.R 5085, addresses many of the issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S. I am happy to see that you have joined this effort to protect our nation’s children. In addition to thanking you for your co-sponsorship of the legislation, I’m writing to ask you to also seek broader protections, especially necessary to protect children. 

Despite an impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, please consider amending the legislation to: 

* 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. 

Thank you for your consideration and sponsorship of this legislation. 

Letter to U.S. Representative and Senators who are NOT co-sponsors of PACTPA: 

I am writing out of concern that our pesticide law is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects.  

The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269 and H.R 5085, addresses many of the problems with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S.  

PACTPA 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 have been linked to neurodevelopmental damage in children;  
- Neonicotinoid insecticides, which have been shown to cause developmental defects, heart deformations, and muscle tremors in unborn children;  
- Paraquat, one of the most acutely toxic herbicides in the world—already banned in 32 countries, including the European Union.  

* Removes dangerous pesticides from the market by:  

- Creating a petition process to enable individual citizens to petition the EPA to identify dangerous pesticides so that dangerous pesticides would not remain on the market indefinitely;  
- Closing 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;  
- 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 pesticide manufacturers to prevent future injury;  
- Requiring that all pesticide label instructions be written in Spanish and in any language spoken by more than 500 pesticide applicators.  

Despite this impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment.

To eliminate this toxic core, please support legislation to:  

* 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—hence threatening the climate.  

* Deny and cancel registrations of all pesticides posing a threat to any endangered species.  

Thank you. 

Please join us today by calling on state senators in New Hampshire to oppose House Bill (HB) 1698. This bill would allow the aerial spraying of pesticides by drones up to 20 feet in the air without notifying the public, threatening the well-being of pollinators, wildlife, and humans who may cross their path. The hearing for HB 1698 is scheduled for April 18, 2024, at 1:20 PM in Room 103, before the Senate Energy and Natural Resources Committee. To sign up to testify, please see the NH Calendar linked here. 

>> Tell your state senator to oppose HB 1698-FN exempting aerial application of pesticides using drones from notification processes, exposing Granite State families and pollinators to poisons hazardous to our health. 

House Bill 1698 exempts the application of pesticides using drones from notification procedures. The bill adds a new paragraph to RSA 430:34-a, stating that the notification requirements for aerial pesticide application do not apply to the aerial application of pesticides by a person with a valid certificate of registration or permit, while using unmanned aircraft for agricultural purposes at a height not exceeding 50 feet above ground level. The bill will take effect 60 days after its passage. 

This proposed legislation language flies in the face of what can and should be New Hampshire's comprehensive approach to ensure those at greatest risk from pesticide exposure—children, those with preexisting health conditions, essential workers, and landscapers—are fully protected. The bill's language is unacceptable, given the known harms of pesticide drift through the air, waterways, and soil.  

Beyond Pesticides opposes HB 1698-FN based on decades of experience reviewing the latest scientific analysis regarding commonly used toxic pesticides in public and private spaces. Click here to view Beyond Pesticides' testimony in opposition to the bill.

Please take action today—thank you for your help protecting public health in New Hampshire!

>> Tell your state senator to oppose HB 1698-FN exempting aerial application of pesticides using drones from notification processes, exposing Granite State families and pollinators to poisons hazardous to our health.

The target for this Action is the N.H. State Senate, including members of the Senate Energy and Natural Resources Committee.

Letter to state senators:

As a constituent, I urge you to take immediate action to oppose HB 1698-FN and its amendment, which would harm New Hampshire's pollinators and environment. House Bill 1698 exempts the application of pesticides using drones from notification procedures when they are sprayed up to 50 feet in the air (up to 20 feet in the air in the amendment). I further urge you not to compromise on decreasing the height, given that any language short of notification at any height will muddy the waters and leave communities open to public health risks.

This bill exempts the aerial application of pesticides using drones from notification processes, potentially endangering pollinators crucial for our food system and biodiversity due to pesticide drift. Pesticides harm pollinators and pose risks to human health and wildlife. Pesticide drift can cause acute poisoning and/or chronic health impacts in farmworkers, their families, or anyone in the application area or working in nearby treated fields, including schools, playgrounds, recreational fields, and other facilities frequented by young children.

With federal officials' complete inaction, the Granite State government must play a critical role in protecting its residents’ public health and unique local environment. Let's come together to protect our pollinators and ecosystems. Your voice can make a difference in safeguarding New Hampshire's natural heritage.

I appreciate your commitment to this vital cause. Together, we can advocate for policies that prioritize the well-being of our ecosystems.

Please oppose HB 1698-FN in its entirety. Thank you for your consideration!

In a move that defies the most basic principles of worker and public health protection, the U.S. Environmental Protection Agency (EPA) has warned farmworkers of the risks of the weed killer dacthal (dimethyl tetrachloroterephthalate or DCPA) instead of taking immediate steps necessary to eliminate exposure to the chemical. EPA's press release says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA and will be pursuing action to address the serious, permanent, and irreversible health risks associated with the pesticide as quickly as possible.”

>>Tell EPA to immediately suspend the registration of dacthal, while Congress must urge the agency to take immediate action.

EPA states that it “found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.” 

Although it suggests several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA's press release gives an astonishing history of the agency's failure to act, acknowledging that DCPA use on turf was voluntarily canceled in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include "non-golf turf uses; sod farms, commercial turf, and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism. 

EPA's reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. EPA does have imminent hazard authority, which it can use to remove pesticides from use while it works through the legal process. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.  

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, "US pesticide regulation is failing the hardest-hit communities. It's time to fix it," finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others (see earlier coverage) on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. In a piece posted earlier this year by Beyond Pesticides, the serious weaknesses in the worker protection standard for farmworkers are documented.   

In view of the serious health risks acknowledged by EPA, the agency must immediately suspend the registration of dacthal, pending any other actions. 

>>Tell EPA to immediately suspend the registration of dacthal, while Congress must urge the agency to take immediate action.

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: 

In a move that defies the most basic principles of worker and public health protection, EPA has warned farmworkers of the risks of dacthal (dimethyl tetrachloroterephthalate or DCPA), instead of taking steps to eliminate the risks. EPA’s press release says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA and will be pursuing action to address the serious, permanent, and irreversible health risks associated with the pesticide as quickly as possible.” 

EPA states that it “found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.”  

Despite suggesting several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, admitting that DCPA use on turf was voluntarily canceled by in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include "non-golf turf uses; sod farms, commercial turf and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism.

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing. 

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, US pesticide regulation is failing the hardest-hit communities: It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. The serious weaknesses in the worker protection standard for farmworkers have also been documented.   

In view of the serious health risks acknowledged by EPA, the agency must immediately suspend the registration of dacthal pending any other actions. 

Thank you for considering these comments. 

Letter to Congress: 

In a move that defies the most basic principles of worker and public health protection, EPA has warned farmworkers of the risks of the weed killer dacthal (dimethyl tetrachloroterephthalate or DCPA), instead of taking steps to eliminate the risks. EPA’s press release says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA and will be pursuing action to address the serious, permanent, and irreversible health risks associated with the pesticide as quickly as possible.” In view of the serious health risks acknowledged by EPA, please urge EPA to immediately suspend the registration of dacthal, pending any other actions. 

EPA states that it “found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.” 

Despite suggesting several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, admitting that DCPA use on turf was voluntarily canceled by in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include "non-golf turf uses; sod farms, commercial turf and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism. 

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing. 

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, US pesticide regulation is failing the hardest-hit communities: It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. The serious weaknesses in the worker protection standard for farmworkers have also been documented.   

Thank you for consideration of my request. 

Corporate interests continue to rule environmental and economic policies, the latest example being a U.S.-initiated trade war that threatens the sovereignty of Mexico in its effort to protect health and the environment with the country's ban on imported genetically engineered (GE or GM) corn and the use of the deadly herbicide glyphosate. Mexico has already announced a delay in the planned April 1 ban on the importation, production, distribution, and use of glyphosate. This is all taking place with pressure from the United States government and U.S. corporations under the U.S.-Mexico-Canada Agreement (USMCA), the trade agreement that replaced the North America Free Trade Agreement (NAFTA) in 2020. This is all happening despite reports that the Biden administration is seeking to “tackle corporate abuses,” apparently limited to tax reform and encouraging competition. 

>>Tell the U.S. Trade Representative and the U.S. Secretary of State to withdraw opposition to Mexico's ban on imported GE corn.

Mexico's 2023 decision to stop importation of GE corn into its country is examined in a report by CBAN, which highlights the scientific rationale underpinning Mexico's decision to “safeguard the integrity of native corn from GM contamination and to protect human health.” Mexico's decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under USMCA. In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban. So far, no public update from the Office of the U.S. Trade Representative has been released. 

Within Mexico, there is over a decade of judicial and executive actions against the spread of GE crops, as well as the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed, effective immediately, within the country's borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, citing the need for more research and prohibited agrichemical biotech companies, including Monsanto, DuPont Pioneer, Syngenta, PHI Mexico, and Dow AgroSciences, from planting or selling GE corn seed in Mexico. Then in 2020, Mexico announced the phaseout of glyphosate from use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.  

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry intervenes whenever decisions are published finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or advance restrictions on genetically engineered or modified crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies, including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy. 

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts on insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, the CBAN report states, “Most GM corn plants are genetically modified to kill insect pests. The GM plants express a toxin from the soil bacterium Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects but not others. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops are different from this natural Bt in structure, function, and biological effects.” The report continues, “In fact, peer-reviewed studies across the scientific literature continue to find that Bt toxins in GM plants can harm insects (spiders, wasps, ladybugs, and lacewings, for example) that are not the intended targets.” 

>>Tell the U.S. Trade Representative and the U.S. Secretary of State to withdraw opposition to Mexico's ban on imported GE corn.

Message: I am writing to ask you to please withdraw U.S. opposition to Mexico's ban on imported GE corn. Despite reports that the administration seeks to “tackle corporate abuses,” it appears limited to tax reform and encouraging competition, while corporate interests continue to override existential health and environmental concerns. The attempt to stop Mexico's ban is a case in point. Mexico's decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The U.S. immediately challenged the phase-out of GE corn imports as a trade violation under USMCA. Over the last decade, Mexico has taken judicial and executive actions against the spread of GE crops and the use of toxic petrochemical pesticides, from an injunction two years after prohibiting agrichemical biotech companies from planting or selling GE corn seed to announcing a glyphosate phaseout by 2024. With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” Mexico's decision has a scientific basis—most GE corn plants are genetically modified to kill insect pests via a toxin from the soil bacterium Bacillus thuringiensis that differs from its natural form and can harm nontarget arthropods. The industry often challenges decisions finding that GE crops (or the chemical they depend on) are harmful, often leading to U.S. government and corporate agribusiness to pressure other governments. Please do not continue the cycle and immediately cease U.S. opposition. Thank you.

>>Tell the U.S. Trade Representative and the U.S. Secretary of State to withdraw opposition to Mexico's ban on imported GE corn.

The targets for this Action are the U.S. Trade Representative Katherine Tai and the U.S. Secretary of State Antony J. Blinken, with an option to send a message to the Office of the President of the United States.

Thank you for your active participation and engagement!

Letter to U.S. Trade Representative Katherine Tai 

I am writing to ask you to withdraw U.S. opposition to Mexico’s ban on imported GE corn. Despite reports that the Biden administration seeks to “tackle corporate abuses,” the actions of the U.S. government appear to be limited to tax reform and encouraging competition, while corporate interests continue to override existential health and environmental concerns. A case in point is the attempt to stop Mexico’s ban on imported genetically engineered (GE or GM) corn.  

In 2023, Mexico decided to stop importation of GE corn into its country. Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA). In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban.  

Over the last decade, Mexico has taken judicial and executive actions against the spread of GE crops and the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, and prohibited agrichemical biotech companies from planting or selling GE corn seed in Mexico, citing the need for more research. In 2020, Mexico announced a phase-out of glyphosate’s use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.   

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry challenges decisions finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or restrict GE crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies, including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.  

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts on insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, most GE corn plants are genetically modified to kill insect pests, expressing a toxin from the soil bacterium Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops differ from this natural Bt in structure, function, and biological effects. In fact, peer-reviewed studies continue to find that Bt toxins in GM plants can harm nontarget arthropods, including spiders, wasps, ladybugs, and lacewings.  

Please immediately cease U.S. opposition to Mexico’s ban on imported GE corn.  

Thank you. 

Letter to Secretary Blinken: 

I am writing to ask you to withdraw U.S. opposition to Mexico’s ban on imported GE corn. Despite reports that the administration seeks to “tackle corporate abuses,” these actions appear to be limited to tax reform and encouraging competition, while corporate interests continue to override existential health and environmental concerns. A case in point is the attempt to stop Mexico’s ban on imported genetically engineered (GE or GM) corn.  

In 2023, Mexico decided to stop the importation of GE corn into its country. Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA). In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban.  

Over the last decade, Mexico has taken judicial and executive actions against the spread of GE crops and the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, and prohibited agrichemical biotech companies from planting or selling GE corn seed in Mexico, citing the need for more research. In 2020, Mexico announced a phase-out of glyphosate’s use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.   

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry challenges decisions finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or restrict GE crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies, including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.  

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts on insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, most GE corn plants are genetically modified to kill insect pests, expressing a toxin from the soil bacterium Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops differ from this natural Bt in structure, function, and biological effects. In fact, peer-reviewed studies continue to find that Bt toxins in GM plants can harm nontarget arthropods, including spiders, wasps, ladybugs, and lacewings.  

Please immediately cease U.S. opposition to Mexico’s ban on imported GE corn.  

Thank you. 

Join Beyond Pesticides in commenting on priority issues that protect health and the environment for the upcoming meeting of the National Organic Standards Board (NOSB). The NOSB is receiving written comments from the public on key issues. This precedes the upcoming public comment webinar on April 23 and 25 and deliberative hearing April 29 through May 1—concerning how organic food is produced. >>Written comments must be submitted by 11:59 pm EDT April 3 through the link provided here and below! 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 3. Links to the virtual comment webinars will be provided approximately one week before the webinars.  

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 public involvement in the current public comment period. This is required to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But we will only keep organic strong and growing stronger if we participate in voicing our position on key issues to the stakeholder advisory board, the NOSB. We have identified key issues for the upcoming NOSB meeting below. 

>>Click here to submit your written comment to the National Organic Standard Board by April 3.

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. There is no other food label category that is defined and codified in federal law, fully embraces health and biodiversity protection and enhancement, offers ongoing opportunities for public input and oversight, and is enforced with an inspection and certification system. Your comments help to make our food system what we need it to be for health, regenerative practices, and sustainability of the planet. 

A draft meeting agenda is available here.  And a detailed agenda, along with the proposals, are available here. 

Written comments are due by 11:59 pm ET on Wednesday, April 3, 2024, as well as registration for oral comments. Oral comment sign-ups fill up fast! >> Sign up for oral comments here.  

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 2024 Beyond Pesticides' issues webpage.  

Here are some of our high priority issues for the upcoming NOSB meeting (see others here):

• Make elimination of plastic in organic a research priority. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well documented. We need research into ways to replace all forms of plastic in organic production and handling.
  
  Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment. 
  
  Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products.
  
  The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics (of which 90% are at the nanoscale) with a majority containing unidentifiable chemicals. The number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. When they exposed cod eggs, embryos, and larvae to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans.
  
  Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta. 
  
  

• Remove toxic nonylphenol ethoxylates from teat dips. Iodine, whose use in teat dips will be considered for relisting, is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors containing nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), in the class known as alkylphenols and their ethoxylates, are strong endocrine disruptors with impacts on many species, including gender changes. A number of alternatives are available. NPEs were banned in Europe ten years ago (in all products), and China has banned dairy product imports with NPE residues above 10 ppb. There are many commercially available non-NPE iodine-based disinfectants and teat dips that can be used instead. Iodine “without alkylphenols or alkylphenol ethoxylates” should only be listed. 

• Improve the science upon which the NOSB bases decisions. The NOSB Policy and Procedures Manual (PPM) states, “A Subcommittee cannot proceed with a recommendation to list a material if it is determined that there is insufficient valid scientific information on that material's impact on the environment, human health and its compatibility with organic principles.” When proposals have been based on Technical Reviews using the current template, they have frequently contained inadequate scientific support. These shortcomings often involve ancillary substances, nanoparticles, and excluded (GE) methods. The changes proposed on the agenda will improve the NOSB's ability to make decisions based on science. 

>> Click here to submit your written comment to the National Organic Standard Board by April 3. 

The targets for this Action are the U.S. National Organic Standards Board, a federal advisory board of dedicated public volunteers from across the organic community under the U.S. Department of Agriculture's Agricultural Marketing Service.

Thank you for your active participation and engagement!

Comment to the NOSB:

Dear NOSB, 

Please consider the following: 

(1) Make elimination of plastic in organic a research priority. 

Plastic is found in every facet of organic production and handling despite adverse effects to human and environmental health. We need research to replace all forms of plastic in organic. 

Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.  

Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products. 

A bottled water study finds almost a quarter of a million bits of microplastics (of which 90% are at the nanoscale) with a majority containing unidentifiable chemicals. The number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified. When cod eggs, embryos, and larvae are exposed to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans. 

Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta. 

(2) Remove toxic nonylphenol ethoxylates from teat dips. 

Iodine, whose use in teat dips will be considered for relisting, is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors containing nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), in the class known as alkylphenols and their ethoxylates, are strong endocrine disruptors with impacts on many species, including gender changes. A number of alternatives are available. NPEs were banned in Europe ten years ago (in all products), and China has banned dairy product imports with NPE residues above 10 ppb. There are many commercially available non-NPE iodine-based disinfectants and teat dips that can be used instead. Iodine “without alkylphenols or alkylphenol ethoxylates” should only be listed. 

(3) Improve the science upon which the NOSB bases decisions. 

The NOSB Policy and Procedures Manual (PPM) states, “A Subcommittee cannot proceed with a recommendation to list a material if it is determined that there is insufficient valid scientific information on that material’s impact on the environment, human health and its compatibility with organic principles.” When proposals have been based on Technical Reviews using the current template, they have frequently contained inadequate scientific support. These shortcomings often involve ancillary substances, nanoparticles, and excluded (GE) methods. The changes proposed on the agenda will improve the NOSB’s ability to make decisions based on science. 

Thank you for your consideration of my comments. 

Plastics are everywhere—and that includes the human body. Pesticides and other toxic chemicals are absorbed (adhered) to microplastics, resulting in bioaccumulation and widespread contamination. This adds to the complexity of the problem, which is largely ignored by federal regulatory agencies. As we learn about the risks associated with plastics and related contamination, it becomes urgently necessary for all government agencies to participate in a comprehensive strategy to eliminate them. 

>>Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food.

The human and environmental health implications of plastic and related contamination are becoming increasingly well-documented. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—on a wide range of organisms. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.  

Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. A study published by researchers at Columbia and Rutgers universities in the January 2024 Proceedings of the National Academy of Sciences reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale.  

Researchers at Norway's MicroLEACH project published a study analyzing the components of 50 common-use items—plastic bags, disposable cups, dishwashing gloves, car tire granules, children's toys and balloons. They found, as in previous studies, that many hazardous chemicals are in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown. 

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

In other new studies, out of a total of 257 patients who completed the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, and breast milk. They have even shown up in the brain as well as the placenta. 

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers. 

>>Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food.

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. Department of Agriculture, and the U.S. Food and Drug Administration.

Thank you for your active participation and engagement!

Letter to EPA: 

Because of the absorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask EPA to develop drinking water standards and ambient water quality standards for microplastics. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.  

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are absorbed to their surface. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.   

Researchers at Columbia and Rutgers universities in the January 2024 Proceedings of the National Academy of Sciences report that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Researchers checked for seven types of plastic but were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. Tap water also contains microplastics in many places. The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.”   

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown. They also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.  

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and the placenta.  

Highly hazardous PFAS (per- and polyfluoroalkyl substances) leach out of plastic containers and contaminate food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.  

Please do your part to eliminate microplastics from our water supplies.  

Thank you. 

Letter to USDA: 

Because of the absorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask USDA to discourage the use of plastic in agriculture. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.  

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size. They can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are absorbed to their surface. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.   

Soil organisms and edible plants have been shown to ingest microplastic particles. Earthworms can move microplastics through the soil, and microplastics can move through the food chain to human food. Microplastics can have a wide range of negative impacts on the soil, which are only beginning to be studied but include a reduction in the growth and reproduction of soil microfauna.   

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown. The scientists also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.  

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and the placenta.  

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.  

Please do your part to eliminate microplastics from our food and environment by discouraging the use of plastic mulch and other plastics in agriculture.  

Thank you. 

Letter to FDA: 

Because of the absorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask FDA to develop standards for food containers and food contact materials to eliminate movement of plastics and associated contaminants into food and bottled water. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them. 

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—which can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are absorbed to their surface. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.  

A study published by researchers at Columbia and Rutgers universities reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Researchers were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. Tap water also contains microplastics in many places, although in much lower concentrations. The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.”  

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals far beyond the known impurities, metabolites, and degradation products. The scientists also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans. 

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and the placenta. 

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers. 

Please do your part to eliminate microplastics from our food and water supplies. 

Thank you. 

Move SB645 Forward with an Amendment to Cover all Pesticides!

Our team would like to share testimony that Beyond Pesticide developed for a hearing in the Michigan Senate on a provision in the state's pesticide law that provides for notification of pesticide use to members of the public on the state's notification registry. While we do not believe that notification of pesticide spray events is adequately protective when nontoxic alternatives could and should be used, we thought this was an opportunity to expand the notification rules to all people, not just those with a medical condition. We also thought it was important to notify legislators that notification should cover all pesticides, not just those classified as “restricted use” because of their high acute toxicity (headaches, nausea, dizziness, rashes, etc.). We shared with legislators our factsheets on the 40 Most Commonly Used Lawn Pesticides (appended to our testimony) to make the point that so-call “general use” pesticides can cause a range of acute and chronic health effects, including cancer, neurological, immunological, endocrine-disrupting, and reproductive health effects, and more. 

We just learned that the hearing on this legislation has been postponed, and may be cancelled, so we sent the testimony to the chair of the Committee on Natural Resources and Agriculture, Senator Sue Shink. 

>>Tell your state senators to protect Michiganders and move SB 645 forward with an amendment to cover all pesticides. 

In our written testimony, we call for an amendment to exclude the words “other than a general-use pesticide” from the law (1994 PA 451, 324.8316b(1) Pesticide notification registry; notification requirements; exclusions; definitions). Our recommendation is based on the understanding that all pesticides are registered as poisons and can harm children, pets, and families, and public health protection from pesticides starts with notification for all pesticides, so that people can avoid exposure. 

While we appreciate that the legislation eliminates the requirement that those qualifying for the registry have a medical condition, not including notification for general use pesticides undercuts the purpose of the legislation because of the science identifying adverse effects associated with the use of these chemicals. Given the poisonous nature of pesticides, people have a right-to-know that they are going to be exposed so that they can try to take action to avoid exposure. Parents may want to remove their children from the area. Pet owners may want to remove their pets. People may want to close windows or turn off units that circulate outside air to the indoor environment. 

Our "click-and-submit" form linked will allow you to contact your state senator with the click of a mouse! For sponsors of the bill, (Sens. Sue Shink, Jeff Irwin, Rosemary Bayer, Mallory McMorrow, John Cherry, Stephanie Chang, and Erika Geiss), please thank and urge them to adopt our proposed amendment to SB645, as well as move the legislation forward. If your Senator has not yet co-sponsored the legislation, please call on them to cosponsor the legislation and support our proposed amendment.

Beyond this bill, please consider joining with Beyond Pesticides Parks for a Sustainable Future Program and take toxic petrochemical pesticides and fertilizers, out of your community by adopting organic land management principles and practices. We work with local and city governments, and school districts and universities to transition playing fields, parks, and landscapes to organic land management. To learn more, see our Parks for a Sustainable Future page and contact Rika Gopinath ([email protected]), Community Policy and Action Manager at Beyond Pesticides who facilitates new and existing projects. 

>>Tell your state senators to protect Michiganders and move SB 645 forward with an amendment to cover all pesticides.

The target for this Action is the Michigan State Senate.

Thank you for your active participation and engagement!

Letter to cosponsors of SB 645:

I am writing to thank you for sponsoring SB 645 to provide for notification of pesticide use to members of the public on the state’s notification registry and urge you to move this legislation ahead this term with an amendment to cover all pesticides, including general use pesticides. I understand that the hearing on this legislation has been postponed or cancelled. Therefore, I respectfully request that SB 645 move forward with an amendment to cover all pesticides.

In terms of the amendment to SB 645, I am asking you to exclude the words “other than a general-use pesticide” from the law (1994 PA 451, 324.8316b(1) Pesticide notification registry; notification requirements; exclusions; definitions). My recommendation is based on the understanding that all pesticides are registered as poisons and can harm children, pets, and families, and public health protection from pesticides starts with notification for all pesticides, so that people can avoid exposure. “General use” pesticides can cause a range of acute and chronic health effects, including cancer, neurological, immunological, endocrine-disrupting, reproductive health effects, and more.

Given the poisonous nature of pesticides, people have a right-to-know that they are going to be exposed so that they can try to take action to avoid exposure. Parents may want to remove their children from the area. Pet owners may want to remove their pets. People may want to close windows or turn off units that circulate outside air to the indoor environment.

Thank you for seeking to move through the Committee on Natural Resources and Agriculture!

Letter to state senators who are not cosponsors:

I am writing to ask you to cosponsor SB 645 to provide for notification of pesticide use to members of the public on the state’s notification registry and urge you to help move this legislation ahead with an amendment to cover all pesticides, including general use pesticides. Please urge that this legislation move through the legislative process this term.

In terms of the amendment to SB 645, I am asking you to exclude the words “other than a general-use pesticide” from the law (1994 PA 451, 324.8316b(1) Pesticide notification registry; notification requirements; exclusions; definitions). My recommendation is based on the understanding that all pesticides are registered as poisons and can harm children, pets, and families, and public health protection from pesticides starts with notification for all pesticides, so that people can avoid exposure. “General use” pesticides can cause a range of acute and chronic health effects, including cancer, neurological, immunological, endocrine-disrupting, and reproductive health effects, and more.

People have a right-to-know that they are going to be exposed to pesticides so that they can try to take action to avoid exposure. Parents may want to remove their children from the area. Pet owners may want to remove their pets. People may want to close windows or turn off units that circulate outside air to the indoor environment.

Thank you for your consideration of cosponsoring SB 645.

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 public involvement in the current public comment period to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But, we will only keep organic strong and growing stronger if we participate in voicing our position on key issues to the stakeholder advisory board, the National Organic Standards Board (NOSB). We have identified key issues for the upcoming NOSB meeting below!

The NOSB is receiving written comments from the public on key issues through April 3, 2024. This precedes the upcoming public comment webinar on April 23 and 25 and the deliberative hearing on April 29 through May 1—concerning how organic food is produced. Written comments must be submitted by 11:59 pm EDT on April 3 through the "click-and-submit" form below or via Regulations.gov.

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 3. Links to the virtual comment webinars will be provided approximately one week before the webinars.  

>>Submit your written comment to the National Organic Standard Board by April 3. 

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. 

A draft meeting agenda is available here.  And a detailed agenda, along with the proposals, are available here. 

Written comments are due by 11:59 pm ET on Wednesday, April 3, 2024, as well as registration for oral comments. Oral comment sign-ups fill up fast! >> Sign up for oral comments here.  

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 2024 Beyond Pesticides' issues webpage.  

Some of our high priority issues for the upcoming NOSB meeting: 

• Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production. Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks” that might include, for example, “compostable” food containers. 
  
  Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don't know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.” Biosolids—fortunately never allowed in organic production—should be a lesson to remember. 

• Eliminate nonorganic ingredients in processed organic foods as a part of the sunset review. 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) only 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. 
   
• Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment. The NOSB has passed repeated recommendations instructing USDA's National Organic Program (NOP) to replace the generic listings for “inerts” that may be biologically and chemically active (currently using EPA Lists 3, 4A, and 4B “inerts”) with specific substances approved for use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert” ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.
  
  OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active” ingredients, but not to “inert” ingredients, which make up the largest part of pesticide products—up to 90% or more.
  
  A comparison of the hazards posed by active and “inert” ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts” than actives pose a hazard. The NOSB and NOP must act on “inerts” NOW and meet the standards of the Organic Foods Production Act. 

>>Submit your written comment to the National Organic Standard Board by April 3. 

The targets for this Action are the U.S. National Organic Standards Board, a federal advisory board of dedicated public volunteers from across the organic community under the U.S. Department of Agriculture's Agricultural Marketing Service.

Thank you for your active participation and engagement!

Comments (via Regulations.gov)

I would like to address three priority issues in this comment that are of concern to me as a stakeholder in organic.

(1) Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production.

Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks” that might include, for example, “compostable” food containers.

Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don’t know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.” Biosolids—fortunately never allowed in organic production—should be a lesson to remember.

(2) Eliminate nonorganic ingredients in processed organic foods as a part of the sunset review.

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) only 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.

(3) Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment.

The NOSB has passed repeated recommendations instructing USDA’s National Organic Program (NOP) to replace the generic listings for “inerts” that may be biologically and chemically active (currently using EPA Lists 3, 4A, and 4B “inerts”) with specific substances approved for use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert” ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.

OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active” ingredients, but not to “inert” ingredients, which make up the largest part of pesticide products—up to 90% or more.

A comparison of the hazards posed by active and “inert” ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts” than actives pose the hazard. The NOSB and NOP must act on “inerts” NOW and meet the standards of the Organic Foods Production Act.

Thank you for your consideration of my comments.

In light of a critical Office of Inspector General (OIG) report on multiple systemic failures by the U.S. Environmental Protection Agency's (EPA) Office of Pesticide Programs (OPP) to protect people and their pets, it is time to elevate our sustained voice for change. And, as we point out serious regulatory and statutory problems, it helps to shift consumer demand for alternative practices and products that do not use petrochemical pesticides. Please continue to raise your voice with us!

>>Tell EPA to start protecting people and pets from pesticide poisoning. 

The most recent OIG report, published on February 29, 2024, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that the "EPA's response to reported pesticide incidents [poisonings and deaths] involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets." At the time the animal effects made headlines in 2021, the agency defended the product's registration, telling the media that, despite these incidents, EPA deemed Seresto collars “'eligible for continued registration' based on best available science, including incident data... No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars— the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.

Key to EPA's deficiency in regulating the chemicals in Seresto pet collars is the agency's failure to evaluate the full pesticide formulation in the collars and the synergistic effect of the mixture of chemicals. As Beyond Pesticides pointed out in 2021 when the poisonings and deaths made headlines, a 2012 study found [flumethrin and imidacloprid] have a 'synergistic effect,' meaning they are more toxic together on fleas...“ However, EPA consistently fails to evaluate the synergistic effects of pesticides, a 2016 EPA bulletin concluded: “The risk of the combination of the two active ingredients, flumethrin and imidacloprid, was not assessed because the two chemicals act in completely different ways.” Similarly, as Beyond Pesticides has pointed out repeatedly, EPA does not do an adequate job of evaluating the risks and harms of exposures to multiple pesticide compounds, as well as those of so-called  “inert” or “other” pesticide ingredients that are not disclosed on the product label.  

The OIG points out that EPA's handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA's pesticide registration program, including (but not limited to): 

• Failure to address combined effects of multiple pesticides; 
• Failure to investigate impacts on pets; 
• Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment; 
• Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and 
• Failure to assure the public of the safety of the products. 

Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. If the labeling is not protecting people, then the agency is not fulfilling its responsibility to protect public health and safety and the pesticide products should not be allowed on the market. This ongoing harm to humans and the biosphere must be taken as a sign that pesticide use must be eliminated. When faced with evidence of harm from a pesticide, EPA must take steps to halt its use.  

>>Tell EPA to start protecting people and pets from pesticide poisoning. 

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: 

More proof of multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) to protect people and their pets from pesticides was presented in a report of the Office of Inspector General (OIG) report, published on February 29, 2024.  

The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data... No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars—the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment. 

The OIG points out that EPA’s handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to): 

• Failure to address combined effects of multiple pesticides; 
• Failure to investigate impacts on pets; 
• Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment; 
• Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and 
• Failure to assure the public of the safety of the products. 

Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. When EPA cannot protect against ongoing harm to humans and the biosphere with the labeling it approves on pesticide products, it must remove the pesticide product from the market. When faced with evidence of harm from a pesticide, despite its labeling restrictions and warnings, EPA must take steps to halt its use.  

The deaths and poisonings associated with Seresto animal collars requires EPA to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects. When will you do this? 

Thank you for your consideration. 

Letter to Congress: 

More proof of multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) to protect people and their pets from pesticides was presented in a report of the Office of Inspector General (OIG) report, published on February 29, 2024.  
 
The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data. . . . No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars— the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment. 

The OIG points out that EPA’s handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to): 

• Failure to address combined effects of multiple pesticides; 
• Failure to investigate impacts on pets; 
• Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment; 
• Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and 
• Failure to assure the public of the safety of the products. 

Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. When EPA cannot protect against ongoing harm to humans and the biosphere with the labeling it approves on pesticide products, it must remove the pesticide product from the market. When faced with evidence of harm from a pesticide, despite its labeling restrictions and warnings, EPA must take steps to halt its use.  

Please let EPA know that the deaths and poisonings associated with Seresto animal collars requires it to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects. 

Thank you for your consideration. 

Please join us today by calling on state lawmakers in Colorado to support the Local Government Authority to Regulate Pesticides bill (HB24-1178), sponsored by Representatives Cathy Kipp and Meg Froelich and Senators Lisa Cutter and Sonya Jaquez Lewis. 

>>Urge Colorado legislators to assert local rights to address toxic pesticides!

Local control over pesticides has been prohibited by Colorado state law since 2006. HB24-1178 would offer local governments the tools to address disproportionate exposures through ordinances and regulations that provide solutions to align with specific community needs. 

Federal pesticide law establishes national standards for protection, allowing state and local governments the authority to regulate pesticide use more strictly. The U.S. Supreme Court specifically upheld this delegation of authority in the 1991 case of Wisconsin Public Intervenor v. Mortier, ruling 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.

While federal law allows local governments the right to craft protections for the health and safety of their residents, state of Colorado law takes away that authority with a preemption provision. Therefore, under the current state law, communities are unable to tackle emerging local challenges to public health and environmental issues—especially important when neither the federal not state government is adequately protective. 

Expanded local control would allow communities to: 

• Protect water sources 
• Increase notification of pesticide applications 
• Create buffer zones to protect sensitive natural resources 
• Increase protections for vulnerable populations, such as children, the elderly, and people of color 

HB24-1178 is vital as it would grant local communities the authority to ban petrochemical pesticides linked to our ongoing public health, biodiversity, and climate crises and return limited local control to municipalities.

Colorado communities today have their hands tied as petrochemical pesticides disproportionately impact people of color communities, harm children's health, devastate pollinator populations, and pollute waterways. With complete inaction by federal officials, and state agencies that merely rubber stamp EPA's toxic pesticide approvals, there is a critical role for local governments to play in the protection of their residents' public health and their unique local environment. 

Please take action today—thank you for your help promoting local democracy in Colorado!  

For more information, please see the following factsheets on local authority and HB 24-1178, pesticides as an environmental justice issue, and pesticides and climate change.

>>Urge Colorado legislators to assert local rights to address toxic pesticides.

Co-sponsors: Representatives Andrew Boesenecker, Kyle Brown, Manny Rutinel, Stephanie Vigil, Mike Weissman, Steven Woodrow, Jenny Willford, and Junie Joseph, in addition to Senators Faith Winter and Kevin Priola.

The targets for this Action are the Colorado State House and the Colorado State Senate. 

Letter to the Colorado General Assembly: 

As your constituent, I am urging you to support the Local Government Authority to Regulate Pesticides bill (HB24-1178), establishing local control over pesticides. This legislation is critical as it will grant local communities the authority to restrict pesticides linked to our ongoing public health, biodiversity, and climate crises. I further urge you not to compromise on local community authority, given that any language short of a full repeal will muddy the waters and leave communities open to litigation.  

Currently, Colorado communities' hands are tied as petrochemical pesticides disproportionately impact people of color communities, harm children’s health, devastate pollinator populations, and pollute waterways. With complete inaction by federal officials, and a state agency with an unfortunate record of merely rubber stamping EPA’s toxic pesticide approvals, there is a critical role for local governments to play in the protection of their residents’ public health and their unique local environment.  

In 1991, the U.S. Supreme Court found, “FIFRA nowhere seeks to establish an affirmative permit scheme for the actual use of pesticides,” and the law “does not equate registration and labeling requirements with a general approval to apply pesticides throughout the Nation without regard to regional and local factors, like climate, population, geography and water supply.” Local officials must have the right to protect their most vulnerable community members like children, the elderly, and the immunocompromised from toxic exposure. They know the playgrounds, local swimming areas, and drinking water sources, conservation areas with vulnerable species, and other sensitive or unique local environments that are in need of protection.    

Local pesticide ordinances are likely to increase the business of local and regional landscaping companies, as folks looking for natural land care methods will look to established experts or new green companies to manage their landscapes. Rather than hurt local companies, returning "limited local control" to municipalities has the potential to incentivize a new green, sustainable industry in communities.   

Please support HB24-1178 establishing local control over pesticides today. 

Thank you. 

Letter to sponsors and cosponsors: 

As your constituent, I would like to thank you for your sponsorship of the Local Government Authority to Regulate Pesticides bill (HB24-1178), establishing local control over pesticides. This legislation is critical as it will grant local communities the authority to restrict pesticides linked to our ongoing public health, biodiversity, and climate crises. I further urge you not to compromise on local community authority, given that any language short of a full repeal will muddy the waters and leave communities open to litigation.   

Currently, Colorado communities' hands are tied as petrochemical pesticides disproportionately impact people of color communities, harm children’s health, devastate pollinator populations, and pollute waterways. With complete inaction by federal officials, and a state agency with an unfortunate record of merely rubber stamping EPA’s toxic pesticide approvals, there is a critical role for local governments to play in the protection of their residents’ public health and their unique local environment.   

In 1991, the U.S. Supreme Court found, “FIFRA nowhere seeks to establish an affirmative permit scheme for the actual use of pesticides,” and the law “does not equate registration and labeling requirements with a general approval to apply pesticides throughout the Nation without regard to regional and local factors, like climate, population, geography and water supply.” Local officials must have the right to protect their most vulnerable community members like children, the elderly, and the immunocompromised from toxic exposure. They know the playgrounds, local swimming areas, and drinking water sources, conservation areas with vulnerable species, and other sensitive or unique local environments that are in need of protection.     

Local pesticide ordinances are likely to increase the business of local and regional landscaping companies, as folks looking for natural land care methods will look to established experts or new green companies to manage their landscapes. Rather than hurt local companies, returning "limited local control" to municipalities has the potential to incentivize a new green, sustainable industry in communities.    

Thank you again for championing the health of our community! 

PFAS (Per- and Polyfluorinated Substances), commonly referred to as “forever chemicals,” are of grave concern and should not be introduced through pesticides into the environment, our homes, and crop production. PFAS are found in many pesticides used in homes, emergency rooms, health care facilities, schools, and lawncare. Under Maryland's definition of PFAS, they also are active ingredients in 1,000 pesticides used in the state, contaminating our homes and gardens, food, water, and soil.

>>Tell your Delegate to protect Marylanders and eliminate PFAS pesticides in our state—vote for HB 1190!

PFAS is a group of harmful chemicals that stay in our bodies forever and are associated with serious illnesses such as cancer, reproductive damage, endocrine disruption, and developmental issues in children. In every case, there are natural practices and products that do not harm people and the environment.  

The Maryland General Assembly is considering a ban of PFAS pesticides. HB 1190 is a commonsense bill prohibiting by June 1, 2025 the sale and by December 31, 2025 the use of pesticides with PFAS as an active ingredient. 

Your Delegate needs to hear from you about how important it is for Maryland to adopt this legislation. Please contact your Delegate TODAY!  

"If the intent was to spread PFAS contamination across the globe, there would be few more effective methods than lacing pesticides with PFAS.” — Kyla Bennett, Public Employees for Environmental Responsibility (PEER) science policy director and attorney; scientist formerly with EPA.

>>Tell your legislators to protect Marylanders and eliminate PFAS pesticides in our state—vote for HB 1190. 

The targets for this Action are the Maryland State House delegates, including members of the Health and Government Operations Committee and the Public Health and Minority Health Disparities Subcommittee.

Thank you for your active participation and engagement!

Letter to Delegates

I'm writing today to urge you to pass HB 1190 - "Pesticides – PFAS Chemicals – Prohibitions."

I am concerned that PFAS, known as "forever chemicals," are a growing and persistent threat to the health and safety of Marylanders and our environment. There are 14,000 EPA-identified toxic PFAS that stay in our bodies forever and are associated with serious illnesses such as cancer, reproductive damage, endocrine disruption, and developmental issues in children.

HB 1190 is a commonsense bill prohibiting the sale and use of pesticides in Maryland with PFAS listed as an active ingredient. This bill impacts less than 8% of pesticides sold in Maryland. It will not cause hardship since plenty of natural alternative products and practices are available.

PFAS are already in our drinking water—in the Chesapeake Bay and in our soil, food, and bodies. Maryland has issued fish advisories for PFAS in parts of the state. Every exposure adds to the impact on our bodies. It only makes sense to take this simple step to stop this unnecessary PFAS contamination source. Maine and Minnesota have already passed laws preventing pesticides containing these forever chemicals from being sold.

You have the opportunity to turn off this PFAS tap from pesticides and reduce their threat to Marylanders’ health, homes and gardens, farmland and water, while reducing the astronomical costs states and towns are bearing to clean up PFAS contamination.

I urge you to help stop the proliferation of PFAS pesticides in Maryland and support HB 1190.

Thank you!

Letter to Health and Government Operations Committee

Please see the above Delegate letter

Contrary to popular opinion, the blame for the obesity epidemic cannot be attributed solely to diet broadly, but relates directly to pesticide and toxic chemical exposures, including residues in food, that may lead to Type 2 diabetes, heart disease, high blood pressure, kidney failure, a breakdown of cartilage and bone within joints, and other metabolic disorders. An increasing body of research shows that exposure to certain pesticides and environmental contaminants initiates various changes in metabolism leading to obesity—not only in the exposed person, but also in offspring. According to medical researchers, obesity “is a complex disease which has reached pandemic dimensions” and has multigenerational effects. The prevalence of obesity increased three-fold from 1980 to 2019.    

>>Tell EPA not to register pesticides that contain obesogens. Tell USDA's Food and Nutrition Service to require organic school lunches.

Environmental obesogens are endocrine-disrupting chemicals that “may increase adipose tissue deposition, expand adipocytic size, regulate appetite and satiety, and slow metabolism to induce the occurrence of obesity.” A recent review of the literature finds, “Environmental obesogens have the potential to induce adipogenesis, increase energy storage, and interfere with appetite and homeostasis within the neuroendocrine system, thereby promoting the development of obesity. Since the obesogen hypothesis was proposed in 2006, more than 50 chemicals have been identified as environmental obesogens. Furthermore, the increasing usage of newly developed chemical products has led to the detection of increasing amounts of new contaminants in the environment, which may have obesogenic effects and cause potential risks to human health.” 

The current list of identified environmental obesogens includes pesticide active ingredients such as chlorpyrifos, atrazine, organotins, and triclosan, as well as contaminants and other ingredients that may be found in pesticide products such as dioxins, phthalates, per- and polyfluoroalkyl substances (PFAS), alkylphenols, and polyaromatic hydrocarbons (PAHs). In addition to the effects of a single obesogen, two or more obesogens may have a synergistic effect, as shown by the interaction of tributyltin (TBT) and perfluorooctanesulfonate (PFOS).  

The inability of the Environmental Protection Agency (EPA) to prevent exposure to obesogens through the use of pesticides is one more failure of the agency to carry out its mandated consideration of endocrine disrupting pesticides. It is evidence of a failed pesticide regulatory system that does not consider and promote nontoxic and beneficial alternatives, such as organic agriculture—which the agency could do under its mandate to protect against “unreasonable adverse effects” to people and the environment in the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

While childhood obesity is recognized as a serious problem, the National School Lunch Program of the U.S. Department of Agriculture (USDA)—although improved by the Healthy, Hunger-Free Kids Act of 2010—still provides lunches laced with obesogenic pesticides. To take meaningful steps against childhood obesity, school lunches must be organic. 

>>Tell EPA not to register pesticides that contain obesogens. Tell USDA's Food and Nutrition Service to require organic school lunches. 

The targets for this Action are the U.S. Environmental Protection Agency, the U.S. Department of Agriculture (Food and Nutrition Service), and the U.S. Congress.  

Thank you for your active participation and engagement!

Letter to EPA: 

Contrary to popular opinion, the blame for the obesity epidemic cannot be attributed solely to diet broadly, but relates directly to pesticide and toxic chemical exposures, including residues in food, that may lead to Type 2 diabetes, heart disease, high blood pressure, kidney failure, a breakdown of cartilage and bone within joints, and other metabolic disorders. An increasing body of research shows that exposure to certain pesticides and environmental contaminants initiates various changes in metabolism leading to obesity—not only in the exposed person, but also in offspring. According to medical researchers, obesity “is a complex disease which has reached pandemic dimensions” and has multigenerational effects. The prevalence of obesity increased three-fold from 1980 to 2019.  

Environmental obesogens are endocrine-disrupting chemicals that “may increase adipose tissue deposition, expand adipocytic size, regulate appetite and satiety, and slow metabolism to induce the occurrence of obesity.” A recent review of the literature finds, “Environmental obesogens have the potential to induce adipogenesis, increase energy storage, and interfere with appetite and homeostasis within the neuroendocrine system, thereby promoting the development of obesity. Since the obesogen hypothesis was proposed in 2006, more than 50 chemicals have been identified as environmental obesogens. Furthermore, the increasing usage of newly developed chemical products has led to the detection of increasing amounts of new contaminants in the environment, which may have obesogenic effects and cause potential risks to human health.” 

The current list of identified environmental obesogens includes pesticide active ingredients such as chlorpyrifos, atrazine, organotins, and triclosan, as well as contaminants and other ingredients that may be found in pesticide products such as dioxins, phthalates, per- and polyfluoroalkyl substances (PFAS), alkylphenols, and polyaromatic hydrocarbons (PAHs). In addition to the effects of a single obesogen, two or more obesogens may have a synergistic effect, as shown by the interaction of tributyltin (TBT) and perfluorooctanesulfonate (PFOS).  

The inability of the Environmental Protection Agency (EPA) to prevent exposure to obesogens through the use of pesticides is one more failure of the agency to carry out its mandated regulation of endocrine disrupting pesticides. It is evidence of a failed pesticide regulatory system that does not consider and promote nontoxic and beneficial alternatives, such as organic agriculture—which the agency could do under its mandate to protect against “unreasonable adverse effects” to people and the environment in the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).  

Please ensure that pesticide risk assessments include the harms arising from exposure to obesogens. Please also ensure that the baseline against which “benefits” of pesticides are measured is organic agriculture. 

Thank you. 

Letter to Food and Nutrition Service Deputy Under Secretary Stacy Dean, USDA Secretary Vilsack, and Members of Congress: 

Consistent with the mission of the Food and Nutrition Service to end hunger and obesity through the administration of 15 federal nutrition assistance programs, including the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Supplemental Nutrition Assistance Program (SNAP), and school meals, it is important that school lunches be free of chemical obesogens. The only way to ensure this is to require that school lunches be prepared with organic ingredients.

Contrary to popular opinion, the blame for the obesity epidemic cannot be attributed solely to diet broadly, but relates directly to pesticide and toxic chemical exposures, including residues in food, that are known as obesogens and associated with a number of related health conditions—high blood pressure, high blood sugar, excess body fat around the waist, and abnormal cholesterol levels collectively known as the “metabolic syndrome.” Metabolic syndrome increases the risk of heart disease, stroke, and type 2 diabetes. Avoiding pesticide exposure is a good way to avoid obesogens, so organic food should be part of every strategy—including school lunch programs—designed to provide healthy nutrition to children.

Childhood obesity is a serious problem in the U.S., leading to a host of health problems in childhood and later in life. Juvenile obesity is highest in Hispanic, African American, and lower income groups, which provides an opportunity for the U.S. Department of Agriculture’s (USDA) school lunch program to have a positive impact.

Environmental obesogens are endocrine-disrupting chemicals that “may increase adipose tissue deposition, expand adipocytic size, regulate appetite and satiety, and slow metabolism to induce the occurrence of obesity.” A recent review of the literature finds, “Environmental obesogens have the potential to induce adipogenesis, increase energy storage, and interfere with appetite and homeostasis within the neuroendocrine system, thereby promoting the development of obesity. Since the obesogen hypothesis was proposed in 2006, more than 50 chemicals have been identified as environmental obesogens. Furthermore, the increasing usage of newly developed chemical products has led to the detection of increasing amounts of new contaminants in the environment, which may have obesogenic effects and cause potential risks to human health.” 

The current list of identified environmental obesogens includes pesticide active ingredients such as chlorpyrifos, atrazine, organotins, and triclosan, as well as contaminants and other ingredients that may be found in pesticide products such as dioxins, phthalates, per- and polyfluoroalkyl substances (PFAS), alkylphenols, and polyaromatic hydrocarbons (PAHs). In addition to the effects of a single obesogen, two or more obesogens may have a synergistic effect, as shown by the interaction of tributyltin (TBT) and perfluorooctanesulfonate (PFOS). 

The National School Lunch Program (NSLP)—as a federally assisted meal program operating in public and nonprofit private schools and residential childcare institutions to provide “nutritionally balanced, low-cost or free lunches to children each school day”—must play a leadership role in removing hazardous chemicals from the meals it feeds to children. In providing free or reduced cost lunches to qualified children, NSLP is an excellent way to ensure that children can receive obesogen-free meals. However, since many pesticides are obesogens, those school lunches must be organic.

Please initiate a policy requiring organic school lunches. 

Thank you. 

Pesticide and chemical manufacturers have descended on state legislators with legislation to shield them from liability lawsuits filed by people injured from exposure to their products. So far, the industry has been successful in getting their bill introduced in at least four states. This activity is spurred on by the thousands of cases involving Roundup/glyphosate that have resulted in large jury awards and settlements against Bayer/Monsanto in the billions of dollars. While sponsors of these bills claim that the labels on pesticide products provide sufficient warning of hazards, users have been misled by advertising that falsely touts product safety. Reminiscent of previous state legislative battles, the chemical industry is now leaning on elected officials, whether in state legislatures or the U.S. Congress, to do its bidding in blocking, or preempting, court action.

In 1991, after losing the landmark U.S. Supreme Court case Wisconsin Public Intervenor v. Mortier that upheld the right of local governments to restrict pesticide use, the pesticide industry went to every state legislature to preempt local authority. Preemption language was quickly enshrined in the state law of 43 states. Now, after being rebuffed by the Supreme Court in 2022 in an attempt to overturn large liability judgments against Monsanto/Bayer for glyphosate hazards, the industry is asking state legislatures to block future liability for pesticide manufacturers whose products cause harm. So far, similar bills to limit liability have been introduced in four states, and more are expected.   

>>Tell your state legislators to protect the right of citizens to seek redress against pesticide manufacturers from harm caused by their products. 

Last week, the Idaho Senate rejected SB 1245, which would have provided legal protection to pesticide manufacturers from “failure-to-warn" liability. This legal framework has been pivotal not only for pesticide users seeking redress from exposure to glyphosate-based herbicide products such as Roundup, but also applies to any toxic pesticide products. Proponents of SB 1245 argue, “[This bill] protect[s] companies that produce safe pesticides critical to agriculture in Idaho and beyond.” Idaho Press continues,” Sen. Harris said the bill does not restrict lawsuits against pesticide manufacturers for a number of claims, including product defects, drift or misapplication, or if the manufacturer fraudulently conceals known facts about the product.”  

While other causes of action are often pursued, the overwhelming majority of successful cases for pesticide injury lawsuits fall under “failure-to-warn" claims. Brigit Rollins, a staff attorney at the National Agricultural Law Center, describes this liability framework as, “a type of civil tort that is frequently raised in products liability cases. Unlike negligence and design defect...failure to warn does not argue that a product has physical faults. Instead, a plaintiff typically raises failure to warn claims to allege that a product manufacturer failed to provide adequate warnings or instructions about the safe use of a product.” Under the new push in several state legislatures, this legal framework would be moot, rendering victims around the United States without effective legal recourse and releasing industry actors such as Bayer from billions of dollars in ongoing and future settlements. As of 2022, Bayer settled over 1,000 lawsuits paying out approximately $11 billion and faces an additional 30,000 lawsuits pending. 

Glyphosate litigation is a notable example of why the dependence on EPA's labels provides inadequate protection—in this case, for users of the pesticide, but also for neighboring farms, farmworkers and bystanders, consumers of contaminated food and water, and the biosphere. Legislators who choose to restrict the right of injured parties to seek recompense from pesticide manufacturers are doing their constituents a tremendous disservice.

>>Tell your state legislators to protect the right of citizens to seek redress against pesticide manufacturers from harm caused by their products.

The targets for this Action are the U.S. state legislatures, herein named via state law as the State Legislature, Legislature, General Assembly, General Court, and/or Legislative Assembly.  

Thank you for your active participation and engagement!

Letter to state legislators:

I am writing to ask you to reject any legislation that may be introduced in the state legislature to shield pesticide and toxic chemical manufacturers from lawsuits when users of their products are injured from their exposure to the chemicals. Legislation like this is popping up around the country and is unfair to people who have been harmed, despite their compliance with product labels. As you may know, numerous cases against Bayer/Monsanto involving the weed killer glyphosate (RoundupTM) have resulted in large jury awards and settlements for those who have been harmed. The manufacturer has appealed verdicts to the U.S. Supreme Court twice and has been rebuffed each time, so they are now asking states to prevent victims from seeking compensation. Although sponsors of these bills claim that the pesticide label is a sufficient warning, users have been misled by advertising touting the products’ safety.

As an example of such legislation, a bill recently rejected by the Idaho Senate would have provided legal protection to pesticide manufacturers from “failure-to-warn" liability. This legal approach has been pivotal for pesticide users seeking redress from exposure to glyphosate-based herbicide products such as Roundup as well as other toxic pesticide products. Proponents of SB 1245 argue, “[This bill] protect[s] companies that produce safe pesticides critical to agriculture in Idaho and beyond.” Idaho Press continues,” Sen. Harris said the bill does not restrict lawsuits against pesticide manufacturers for a number of claims, including product defects, drift or misapplication, or if the manufacturer fraudulently conceals known facts about the product.”

While other causes of action are often pursued, the overwhelming majority of successful cases for pesticide injury lawsuits fall under “failure-to-warn" claims. Brigit Rollins, a staff attorney at the National Agricultural Law Center, describes this liability framework as, “a type of civil tort that is frequently raised in products liability cases. Unlike negligence and design defect...failure to warn does not argue that a product has physical faults. Instead, a plaintiff typically raises failure to warn claims to allege that a product manufacturer failed to provide adequate warnings or instructions about the safe use of a product.” Under the new push in several state legislatures, this legal framework would be moot, rendering victims without effective legal recourse and releasing industry actors such as Bayer from billions of dollars in ongoing and future settlements. As of 2022, Bayer settled over 1,000 lawsuits paying out approximately $11 billion and faces an additional 30,000 lawsuits pending.

Glyphosate litigation is a notable example of why the dependence on EPA’s labels provides inadequate protection—in this case, for users of the pesticide, but also for neighboring farms, farmworkers and bystanders, consumers of contaminated food and water, and the biosphere. Legislators who choose to restrict the right of injured parties to seek recompense from pesticide manufacturers are doing their constituents a tremendous disservice.

I urge you to reject such legislation restricting the rights of injured parties in our state—whether they be users of the pesticide, neighboring farms, farmworkers, landscapers, bystanders, consumers of contaminated food and water, or defenders of nature—to recover damages from pesticide manufacturers.

Thank you.

The use of per- and polyfluoroalkyl substances (PFAS) in industrial and commercial applications has led to widespread contamination of water and biosolids used for fertilizer, poisoning tens of millions of acres of land and posing a significant threat to the biosphere, public health, gardens, parks, and agricultural systems. Farmers and rural communities, in particular, bear the brunt of this contamination, as it affects their drinking water, soil quality, and livestock health.  

>>Tell Congress that the Farm Bill must include the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act to protect farmers and rural communities from PFAS contamination. 

Led by Chellie Pingree (D-ME), U.S. Senators Tammy Baldwin (D-WI), and Susan Collins (R-ME), a bipartisan and bicameral bill—the Relief for Farmers Hit with PFAS Act—has been introduced to provide assistance and relief to those affected by PFAS. A second bill, the Healthy H2O Act, introduced by Representatives Pingree and David Rouzer (R-NC) and Senators Baldwin and Collins, provides grants for water testing and treatment technology directly to individuals and non-profits in rural communities. 

There are more than 9,000 synthetic (human-made) chemical compounds in the PFAS family, which includes the most well-known subcategories, PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid). These PFAS compounds have been dubbed “forever chemicals” for their persistence in the environment (largely because they comprise chains of bonded fluorine–carbon atoms, those bonds being among the strongest ever created). PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply, among other sources, is a ubiquitous and concerning contaminant across the globe. PFAS contamination of drinking water resources is a serious and growing issue for virtually all U.S. states, as Environmental Working Group (EWG) demonstrates via its interactive map, and for hydrologic ecosystems around the world. 

The widespread exposure to these compounds arises from multiple sources: 

• Contamination of drinking water and wastewater treatment resulting in fertilizers produced from biosolids (processed output from treatment plants), as well as residues in food packaging some pesticides; 
• extensive “legacy” (historic) use in fabric and leather coatings, household cleaning products, firefighting foams, stain-resistant carpeting, and other products; 
• historic and current industrial uses in the aerospace, automotive, construction, and electronics sectors; and 
• current uses in many personal care products (e.g., shampoo, dental flosses, makeup, nail polish, some hand sanitizers, sunscreens); water-and-stain-proof and -resistant fabrics and carpeting; food packaging; and non-stick cookware, among others. 

Although some of these uses and resulting contamination have been phased out, many persist, including several related to food processing and packaging. The flooding of the materials stream with thousands of persistent synthetic PFAS compounds since their first uses in the 1950s allows them to remain widespread in the environment and in human bodies. People can be exposed to PFAS compounds in a variety of ways, including occupationally, through food sources, via drinking contaminated water (another enormous emerging issue; see below), ingesting contaminated dust or soil, breathing contaminated air, and using products that contain, or are packaged in materials that use, the chemicals. 

The U.S. Environmental Protection Agency (EPA) notes, “[B]ecause of their widespread use and their persistence in the environment, many PFAS are found in the blood of people and animals all over the world and are present at low levels in a variety of food products and in the environment. PFAS are found in water, air, fish, and soil at locations across the nation and the globe. Scientific studies have shown that exposure to some PFAS in the environment may be linked to harmful health effects in humans and animals.”

Among the potential health risks of some PFAS compounds for humans are: 

• impacts on the immune system (including decreased vaccine responses); 
• endocrine disruption; 
• reproductive impacts, including lowered infant birth weight; 
• developmental delays in children; 
• increased risk of hypertension, including in pregnant people (eclampsia); 
• alterations to liver enzymes; 
• increased risk of some cancers, including prostate, kidney, and testicular; 
• increase in circulatory cholesterol levels; 
• increased risk of cardiometabolic diseases (via exposure during pregnancy); and 
• possible increased risk of COVID-19 infection and severity. 

>>Tell Congress that the Farm Bill must include the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act to protect farmers and rural communities from PFAS contamination. 

After years of advocate pressure, EPA has begun to take action under its PFAS Strategic Roadmap—including “designat[ing] two of the most widely used per- and polyfluoroalkyl substances [PFOA and PFOS] as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as 'Superfund;'” issuing interim updated drinking water health advisories for PFOA and PFOS); issuing final health advisories on two others that had been considered “replacement” chemicals for manufacturing uses—perfluorobutane sulfonic acid and its potassium salt (PFBS) and hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (the so-called “GenX chemicals”). 

PFAS compounds have been found to contaminate water and irrigation sources, and soils themselves — often through the use of fertilizers made from so-called “biosludge” (biosolids) from local waste treatment plants. In addition, these plants may discharge millions of gallons of wastewater into waterways, contaminating them; current waste and water treatment generally does not eliminate PFAS compounds from the treated effluent water. Biosolids and wastewater have long been sources of exposure concerns related to pesticides, industrial chemicals, pharmaceuticals, personal care products, and household chemicals; PFAS contamination is now rising as a specific and concerning addition to that nasty list. 

These forever (and perhaps “everywhere”) compounds may be contaminating nearly 20 million acres of productive agricultural land in the U.S. A significant portion of farmers, perhaps 5%, is using biosludge from local treatment plants as fertilizer on their acreage. The use of biosludge was thought by many, a decade ago, to be a sensible use of the waste products from treatment; it was even encouraged by many state agricultural department programs, but now it is recognized that these products present threats when spread on fields that produce food—or anywhere that presents the possibility of human, organism, or environmental exposures to potentially toxic PFAS compounds. Notably, there are currently no federal requirements to test such sludge “fertilizers” for the presence of PFAS. 

Recognizing the impacts on the agricultural sector from PFAS, the state of Maine has taken the lead in both state and federal efforts to support farmers who have been affected by PFAS contamination, including the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act.

In short, these bills would achieve the following: 

• The Healthy H2O Act addresses PFAS contamination in water supplies by providing funding for water testing, treatment, and remediation. By allocating resources to support the implementation of effective PFAS filtration systems, it can ensure that farmers and rural communities have access to clean and safe water, protecting both human health and agricultural productivity. 
• The Relief for Farmers Hit with PFAS Act provides financial assistance and support to farmers affected by PFAS contamination. By establishing a comprehensive assistance program, we can help farmers mitigate the economic burdens resulting from PFAS-related disruptions and implement necessary remediation efforts. Additionally, this act supports research and education initiatives to enhance farmers' awareness and understanding of PFAS risks and best management practices. 

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

>>Tell Congress that the Farm Bill must include the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act to protect farmers and rural communities from PFAS contamination.

The targets for this Action are the U.S. Senate and the U.S. House of Representatives.  

Thank you for your active participation and engagement!

Letter to Senators with request to cosponsor 

I am writing to urge you to cosponsor S.747, the Relief for Farmers Hit with PFAS Act, and S. 806, the Healthy H2O Act—and push for their inclusion in the Farm Bill—in order to help farmers who have been impacted by PFAS (perfluoroalkyl and polyfluoroalkyl substances) contamination. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill will authorize $500 million over FY 2023-2027 to the U.S Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; research on soil and water remediation systems, and the viability of those systems for farms; and improving rural drinking water. This money, if appropriated, comes from taxpayers, not those responsible for the contamination. 

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

Since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine disrupting chemicals that have not been adequately restricted. Thus, while I urge you to pass these bills offering relief to farmers harmed by PFAS, we must also do all that we can to prevent further contamination. 

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

Thank you. 

Letter to Senate sponsors/cosponsors [See below.] 

Thank you for cosponsoring S.747, the Relief for Farmers Hit with PFAS Act, and S. 806, the Healthy H2O Act, to help farmers who have been impacted by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. Please seek to have the provisions of these bill incorporated into the Farm Bill. As indicated by the title of the first bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill authorize $500 million over FY 2023-2027 to the U.S Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; research on soil and water remediation systems, and the viability of those systems for farms; and improving rural drinking water. This money, if appropriated, comes from taxpayers, not those responsible for the contamination. 

Again, please help to ensure that these pieces of legislation become part of the Farm Bill. 

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

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

Thank you. 

Letter to Representatives with request to cosponsor 

I am writing to urge you to cosponsor H.R. 1517, the Relief for Farmers Hit with PFAS Act, and H.R. 1721, the Healthy H2O Act—and push for their inclusion in the Farm Bill—in order to help farmers who have been impacted by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill will authorize $500 million over FY 2023-2027 to the U.S Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; research on soil and water remediation systems, and the viability of those systems for farms; and improving rural drinking water. This money, if appropriated, comes from taxpayers, not those responsible for the contamination. 

Again, please help to ensure that these pieces legislation become part of the Farm Bill. 

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

Since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine disrupting chemicals that have not been adequately restricted. Thus, while I urge you to pass these bills offering relief to farmers harmed by PFAS, we must also do all that we can to prevent further contamination. 

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

Thank you. 

Letter to Representative sponsors/cosponsors 

Thank you for cosponsoring H.R. 1517, the Relief for Farmers Hit with PFAS Act, and H.R. 1721, the Healthy H2O Act, to help farmers who have been impacted by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the first bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill authorize $500 million over FY 2023-2027 to the U.S Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; research on soil and water remediation systems, and the viability of those systems for farms; and improving rural drinking water. This money, if appropriated, comes from taxpayers, not those responsible for the contamination. 

Again, please help to ensure that these pieces of legislation become part of the Farm Bill. 

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

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

Thank you. 

Senate cosponsors of S.747 (Sponsored by Sen. Susan Collins [R-ME]: Sen. King, Angus S., Jr. [I-ME]*, Sen. Shaheen, Jeanne [D-NH]*, Sen. Gillibrand, Kirsten E. [D-NY], Sen. Hassan, Margaret Wood [D-NH], Sen. Baldwin, Tammy [D-WI], Sen. Sanders, Bernard [I-VT], Sen. Lujan, Ben Ray [D-NM], Sen. Welch, Peter [D-VT], Sen. Heinrich, Martin [D-NM].

Senate cosponsors of S.806 Sponsored by Sen Tammy Baldwin [D-WI]: Sen. Collins, Susan M. [R-ME]*, Sen. Smith, Tina [D-MN]*, Sen. Shaheen, Jeanne [D-NH]*, Sen. King, Angus S., Jr. [I-ME]*, Sen. Wyden, Ron [D-OR], Sen. Padilla, Alex [D-CA], Sen. Gillibrand, Kirsten E. [D-NY], Sen. Lujan, Ben Ray [D-NM], Sen. Welch, Peter [D-VT], Sen. Cardin, Benjamin L. [D-MD].

Representative cosponsors of HR.1517 Sponsored by Rep. Chellie Pingree [D-ME]: Rep. Golden, Jared F. [D-ME-2]*, Rep. Leger Fernandez, Teresa [D-NM-3]*, Rep. Slotkin, Elissa [D-MI-7], Rep. Perez, Marie Gluesenkamp [D-WA-3], Rep. Courtney, Joe [D-CT-2], Rep. Fitzpatrick, Brian K. [R-PA-1], Rep. Kuster, Ann M. [D-NH-2], Rep. Balint, Becca [D-VT-At Large], Rep. Hoyle, Val T. [D-OR-4].

Representative cosponsors of HR.1721 Sponsored by Rep. Chellie Pingree [D-ME]: Rep. Rouzer, David [R-NC-7]*, Rep. Gallagher, Mike [R-WI-8]*, Rep. Valadao, David G. [R-CA-22], Rep. McCollum, Betty [D-MN-4], Rep. Fitzpatrick, Brian K. [R-PA-1], Rep. Brown, Shontel M. [D-OH-11], Rep. Slotkin, Elissa [D-MI-7], Rep. Lawler, Michael [R-NY-17], Rep. Harder, Josh [D-CA-9], Rep. Levin, Mike [D-CA-49], Rep. Sorensen, Eric [D-IL-17], Rep. Rose, John W. [R-TN-6], Rep. Schiff, Adam B. [D-CA-30], Rep. Stansbury, Melanie Ann [D-NM-1], Rep. Vasquez, Gabe [D-NM-2], Rep. Van Orden, Derrick [R-WI-3], Rep. Molinaro, Marcus J. [R-NY-19], Rep. Caraveo, Yadira [D-CO-8], Rep. Courtney, Joe [D-CT-2], Rep. Craig, Angie [D-MN-2], Rep. Salinas, Andrea [D-OR-6], Rep. Crockett, Jasmine [D-TX-30], Rep. Kuster, Ann M. [D-NH-2], Rep. Perez, Marie Gluesenkamp [D-WA-3], Rep. McGovern, James P. [D-MA-2], Rep. Matsui, Doris O. [D-CA-7], Rep. Davis, Donald G. [D-NC-1], Rep. Tokuda, Jill N. [D-HI-2], Rep. Pappas, Chris [D-NH-1], Rep. Kilmer, Derek [D-WA-6].

Please urge your senators to sign on and oppose efforts in Congress to take away local governments' ability to protect our residents and workers from harmful pesticides.

Targeted Action: Arizona, California, Colorado, Connecticut, Delaware, Georgia, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, New Jersey, New Mexico, New York, Ohio, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, Washington, and Wisconsin.

There is still ongoing movement in federal Farm Bill negotiations to preempt local communities from restricting pesticides. So, we're requesting that you urge your senators to sign on to a “Dear Colleague” letter opposing federal preemption of local authority on pesticide use. The Congressional letter emphasizes the importance of preserving the rights of state, county, and local governments to protect their communities and enact policies that align with local needs. The letter argues that curtailing these powers would undermine public safety and jeopardize environmental and public health standards. 

It is critical that local governments have the authority to adopt pesticide restrictions that are more protective than those of the federal government, as affirmed by the 1991 U.S. Supreme Court decision in Wisconsin Public Intervenor v. Mortier. The court found that federal pesticide law (Federal Insecticide, Fungicide, and Rodenticide Act—FIFRA), as currently written, does not preempt local authority.  

As the Senate continues its work, please urge your senators to reject any and all harmful pesticide policy riders that would diminish local authority.

For more information, click here for additional background and prior coverage in the House!

Senators can directly access the letter to sign-on electronically via QUILL.

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

Thank you for your active participation and engagement!

Letter to U.S. Senators Requesting Sign-On

I am writing to ask you to join with U.S. Senator Corey Booker and others in signing on to a “Dear Colleague” letter opposing any effort in the 2023 Farm Bill, an annual appropriations bill, or other legislation amendments that will limit local and state authority to protect our community from toxic pesticide exposure. The letter expresses strong opposition to any provisions or amendments to any legislative vehicle that limits existing state and local authority to regulate pesticides—including restrictions on state labeling requirements or state and local regulatory processes. This is a critically important issue of protecting our families’ health, our environment, and the democratic process to set policies that best suit our local needs.

My request grows out of my strong opposition to any efforts to limit longstanding state and local authority to protect people, animals, and the environment from pesticides. As you know, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) establishes the authority of the U.S. Environmental Protection Agency to oversee the registration, distribution, sale, and use of pesticides in the United States. Congress has long understood FIFRA to set a federal floor for pesticide policy without impeding state, county, and local governments’ authority to enact supplementary standards. Hundreds of towns and cities have adopted laws and ordinances to keep their communities safe from pesticides. These include laws to restrict pesticide use at schools, parks, playgrounds, and workplaces, and protect drinking water supplies, pollinators, and wildlife. Overall, local authority also permits communities to address conditions unique to their jurisdictions, from vulnerable population groups to sensitive ecosystems.

The U.S. Supreme Court in 1991 ruled that democratically elected local governments hold the power, under our current law, to address the specific needs of their communities. State and local governments are often best positioned to respond quickly to emerging risks within our communities, and proposals to weaken our ability to respond could have a significant adverse effect on public safety.

The Dear Colleague letter expresses strong opposition to language in a House bill, H.R. 4288, the Agricultural Labeling Uniformity Act, which forbids states from requiring manufacturers to disclose known risks about their pesticide products, such as carcinogenicity. This undermines transparency, informed choice in the market, and consumer redress when there is a failure to warn.

I again urge you to sign on to Senator Booker’s “Dear Colleague” letter. Senators may sign on through this QUILL link: https://quill.senate.gov/letters/letter/14965/opt-in/view/e04e0ed9-d650-4262-9971-978b715c9b8b/.

Thank you for your consideration of this request. I look forward to you letting me know that you are taking action on this critical matter.

Thank you to Sen. Booker (sponsor) and Sen Van Hollen, Jr.

Thank you for leading the charge with your “Dear Colleague” letter opposing any effort in the 2023 Farm Bill, an annual appropriations bill, or other legislation amendments that will limit local and state authority to protect our community from toxic pesticide exposure. I appreciate your strong opposition to any provisions or amendments to any legislative vehicle that limits existing state and local authority to regulate pesticides—including restrictions on state labeling requirements or state and local regulatory processes. This is a critically important issue of protecting our families’ health, our environment, and the democratic process to set policies that best suit our local needs.

I strongly oppose any efforts to limit longstanding state and local authority to protect people, animals, and the environment from pesticides. I appreciate your recognition of the hundreds of towns and cities that have adopted laws and ordinances to keep their communities safe from pesticides. These include laws to restrict pesticide use at schools, parks, playgrounds, and workplaces, and protect drinking water supplies, pollinators, and wildlife. As you know, local authority also permits communities to address conditions unique to their jurisdictions, from vulnerable population groups to sensitive ecosystems.

We know from the 1991 U.S. Supreme Court ruling that democratically elected local governments hold the power, under our current law, to address the specific needs of their communities. And, we know historically that state and local governments are often best positioned to respond quickly to emerging risks within our communities, and proposals to weaken our ability to respond could have a significant adverse effect on public safety.

I appreciate the Dear Colleague letter expressing strong opposition to language in a House bill, H.R. 4288, the Agricultural Labeling Uniformity Act, which forbids states from requiring manufacturers to disclose known risks about their pesticide products, such as carcinogenicity. This undermines transparency, informed choice in the market, and consumer redress when there is a failure to warn.

Thank you for your leadership on this important effort to protect health and the environment.

In the wake of intense criticism of the U.S. Environmental Protection Agency's scientific integrity, the agency has announced updates to its scientific integrity guidelines and is asking for public comment until February 23, 2024. As the agency acknowledges in its 2012 Scientific Integrity Policy: “EPA's ability to protect human health and the environment depends upon the integrity of the science on which it relies. The EPA Scientific Integrity Policy provides both a vision and a roadmap for scientific integrity at the Agency. Issued in 2012, the Policy builds upon EPA's significant earlier scientific integrity efforts and addresses four areas: Promotion of a culture of scientific integrity at EPA; Release of scientific information to the public; Peer review and the use of federal advisory committees; Professional development of government scientists.” 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you for your active participation and engagement!

Comment to EPA:

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

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

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

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

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

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

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

Thank you for your consideration of these comments.

EPA is accepting comments through Friday on its long-held policy of exempting “treated objects,” including seeds and paint, from pesticide registration. Although EPA does not ask the most important question—“Should pesticide-treated seeds and paint be exempt from the scrutiny given pesticide products?”—this comment period offers an opportunity to respond to EPA's questions and express our viewpoints. 

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

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

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

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

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

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

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

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

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

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

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

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

Thank you for your active participation and engagement!

Suggested Comments to EPA:

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

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

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

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

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

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

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

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

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

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

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

Thank you for this opportunity to comment.

After failing to comply with the 1996 Congressional mandate to determine whether pesticides disrupt the endocrine system of humans and other organisms, the U.S. Environmental Protection Agency (EPA) is revisiting its approach to the implementation of the Endocrine Disruptor Screening Program (EDSP) with a new proposal that falls short of what is required to protect people and ecosystems. The proposal is open for public comment by February 26, 2024.

A detailed examination can be found in draft comments by Beyond Pesticides. 

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

Because of its limited scope, the EPA's proposed framework for review of endocrine disrupting properties of pesticides is an abrogation of its responsibilities under the 1996 Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA) as well as the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Safe Drinking Water Act (SDWA). The limitations in EPA's proposal, which do not comply with Congressional intent and statutory mandates, include: (i) applying EDSP to humans only; (ii) focusing on certain pesticide active ingredients only, and; (iii) restricting the types of data used to assess endocrine disruption (ED). The proposal reverses the advice of EPA's Endocrine Disruptor Screening and Testing Advisory Committee (EDSTAC) and the agency's original EDSP implementation policy and science decisions. 

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

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

Endocrine disruption as a phenomenon affecting humans and other species has been critically reviewed by several authors. A common thread across these reviews is the notion that chemicals that may disrupt the endocrine systems of humans and wildlife may be pervasive in contaminating their habitats. A pandemic of endocrine-related disorders can be connected with endocrine-disrupting chemicals (EDCs), including attention deficit and hyperactivity disorder (ADHD), autism, diabetes, obesity, childhood cancers, testicular cancer in young men, infertility, male dysgenesis syndrome, hypospadias, low sperm count, loss of semen volume and sperm quality, and increased risk of testicular and prostate cancer. All these disorders have been increasing in incidence and can be traced back to prenatal exposure to EDCs. 

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

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

In summary, the agency cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements enumerated in FIFRA, FQPA, and SDWA. EPA should make use of all available scientifically relevant endocrine disruption research findings and also be wary of deviating from established international efforts for screening/testing endocrine disruptors that incorporate human and wildlife relevant studies. Recognizing that mammalian data inform potential endocrine disruption in other vertebrate taxa (avian, amphibian, fish) and vice versa, the agency should not decouple the mammalian from other vertebrate assays in EDSP screening.  There are more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development (OECD) Conceptual Framework for screening/testing endocrine disrupting effects, and there are additional assays being developed for consideration as well. So, the agency should not limit the range or types of data to be used, but, as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” While currently required data may meet the needs of human risk assessment, it is inadequate to evaluate endocrine effects on wildlife species. It should also be understood that under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk per the mandate in FIFRA. Further, it is not the agency but pesticide registrants (manufacturers) that have the burden to demonstrate with adequate data that their products will not pose unreasonable adverse effects, including the inherently presumed endocrine-disrupting effects.

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

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

Thank you for your active participation and engagement!

Suggested comments to EPA:

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

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

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

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

In summary, EPA cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements of FIFRA, FQPA, and SDWA. EPA must use all available scientifically relevant endocrine disruption research findings and avoid deviating from established international efforts that incorporate human and wildlife studies. Recognizing that mammalian data inform potential endocrine disruption in other vertebrates (avian, amphibian, fish) and vice versa, the agency should not decouple the mammalian from other vertebrate assays in EDSP screening. With more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development Conceptual Framework for screening/testing endocrine disrupting effects and additional assays in development, EPA must not limit the range or types of data to be used, but as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” Currently required data may meet the needs of human risk assessment but is inadequate to evaluate endocrine effects on wildlife species.  

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

Thank you. 

The U.S. Environmental Protection Agency's Draft Biological Evaluation (BE), Effects Determinations, and Mitigation Strategy for Federally Listed and Proposed Endangered and Threatened Species and Designated and Proposed Critical Habitats for 11 Rodenticides, is inadequate—both in its evaluation of risk and measures to mitigate risk—and should not be used as the basis registration of these rodenticides.

A detailed examination can be found in draft comments by Beyond Pesticides. 

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

The Endangered Species Act (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, the ESA has played a pivotal role in preventing these extinctions by safeguarding the most critically endangered species within biological communities. The ESA establishes a framework to categorize species as "endangered" or "threatened," granting them specific protections, but the goal of the ESA is to address the broader issue of biodiversity loss by protecting habitats of species most at risk, or, as stated in the ESA, to “Provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions set forth in subsection (a) of this section.” 

Under the ESA, 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 to the ways it has created the crisis in the first place. 

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

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

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

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

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

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

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

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

Thank you for your active participation and engagement!

Comment to EPA:

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

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

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

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

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

Thank you for considering these comments.

The failure of the National Organic Program (NOP) to consistently require soil-building practices for certification of organic farms presents a serious threat to organic integrity. As a result of this failure, some growers using hydroponic and other practices that do not build the soil are allowed to sell produce as organic. Such produce is not labeled as “hydroponic” or “container-grown.”    

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

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

USDA has an open comment period—closing Monday, January 22—regarding the information that is collected during the organic certification process. To comply with the Organic Foods Production Act (OFPA), the National Organic Program (NOP) must collect information from all certified organic crop producers and all accredited certifying agents on how certified organic crop production operations “foster soil fertility” to verify compliance with OFPA 6513(b). 

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

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

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

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

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

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

Thank you for your active participation and engagement!

Comment to EPA:

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

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

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

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

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

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

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

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

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

Thank you.

EPA has opened a comment period on a petition submitted by Public Employees for Environmental Responsibility, American Bird Conservancy, and 60+ other groups. The petition is asking for rules to be promulgated that require efficacy data to be submitted for systemic insecticides by manufacturers registering these pesticides with EPA.   

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

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

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

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

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

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

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

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

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

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

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

Thank you for your active participation and engagement!

Comment to EPA 

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

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

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

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

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

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

Thank you for your consideration of these comments.

Antibiotic resistance is rising to dangerously high levels in all parts of the world, according to the World Health Organization. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” The authors continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.” 

>>Tell EPA and Congress that antibiotic pesticides must be eliminated.

A federal district court decision last month (December 13) found illegal the U.S. Environmental Protection Agency's (EPA) decision to register the antibiotic streptomycin for use in Florida citrus to control Huanglongbing (HLB), also known as “citrus greening,” a plant disease spread by the Asian citrus psyllid.  

The court found, “[EPA] admits it did not comply with the [Endangered Species Act].” The court also found that EPA failed to show that streptomycin would achieve benefits as a tool for preventing the target disease. The court found, “[W]e have now concluded that the EPA did not fully comply with FIFRA because it (1) failed to include additional data in its pollinator risk assessment or explain why such data was not necessary and (2) suggested that streptomycin could be used to prevent disease without providing evidentiary support for such a claim. 

However, the court was not convinced that EPA fails to protect against the spread of antibiotic resistance and assumed that the restrictions that EPA required for personal protective equipment (PPE) and drift control would adequately mitigate risks, despite a history of noncompliance and uncontrollable movement of pesticides off the target site.  

When antimicrobial or antibiotic pesticides are sprayed on a crop, they induce antibiotic resistance in bacteria that are present by killing susceptible bacteria—which may or may not be pathogenic—allowing resistant bacteria to proliferate. Those resistant bacteria move off the site on produce, workers' clothing, and the wind. Prevention of chemical drift is therefore inadequate to protect against the spread of antibiotic-resistant bacteria. The now well-known phenomenon of horizontal gene transfer (movement of genes in bacteria from one bacterial species to another) means that antibiotic resistance genes in those (possibly harmless) bacteria can move to bacteria that cause disease in plants or humans. 

Streptomycin has been banned for agricultural use on crops in many countries, but in the U.S., its use and the use of oxytetracycline in fruit and vegetable production have been permitted. Under the Trump administration, EPA permitted an emergency use authorization in 2017 to expand use of these antibiotics to Florida citrus crops to control citrus greening. That emergency authorization was to have run out in 2019, but, in January of that year, EPA moved to make the authorization permanent, despite, according to the New York Times, “strenuous objections from the Food and Drug Administration and the Centers for Disease Control and Prevention, which warn that the heavy use of antimicrobial drugs in agriculture could spur germs to mutate so they become resistant to the drugs, threatening the lives of millions of people.” That decision greenlighted the use of more than 650,000 pounds of streptomycin on citrus crops in Florida and California alone, and followed an approval two years prior of oxytetracycline for use on the same citrus crops. Citrus greening has been successfully managed organically in Florida, with a combination of biological controls and cultural practices. 

In addition to use on crops, antimicrobials 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.”

Finally, two facts lead to the conclusion that focusing on materials sold as antibiotics or antimicrobials is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens. These two facts lead to the conclusion that we must stop broadcasting pesticides in the environment and applying them to food. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides had been disseminated in the environment for decades.  

>>Tell EPA and Congress that antibiotic pesticides must be eliminated.

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:

Antimicrobial resistance is rising to dangerously high levels. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” They continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”

A federal district court decision blocked EPA’s decision to register the antibiotic streptomycin for use in Florida citrus to control Huanglongbing (HLB), also known as “citrus greening,” a plant disease spread by the Asian citrus psyllid, finding, “[EPA] admits it did not comply with the ESA.” The court also found that EPA failed to show that streptomycin would achieve benefits in preventing the disease. However, the court was not convinced that EPA fails to protect against the spread of antibiotic resistance and assumed that the restrictions that EPA required for personal protective equipment (PPE) and drift control would adequately mitigate risks.

When antimicrobial pesticides are sprayed on a crop, they induce resistance in bacteria that are present by killing susceptible bacteria—which may or may not be pathogenic—allowing resistant bacteria to proliferate. The resistant bacteria move off the site on crops, workers, and the wind. Prevention of chemical drift is thus inadequate to protect against the spread of antibiotic-resistant bacteria. The fact of horizontal gene transfer means that antibiotic resistance genes in those (possibly harmless) bacteria can move to pathogens.

In 2017, EPA permitted use of these antibiotics in Florida citrus crops. In January 2019, EPA moved to make the authorization permanent despite, according to the New York Times, “strenuous objections from the Food and Drug Administration and the Centers for Disease Control and Prevention, which warn that the heavy use of antimicrobial drugs in agriculture could spur germs to mutate so they become resistant to the drugs, threatening the lives of millions of people.” Two years prior, oxytetracycline was approved for use on the same citrus crops.

In addition to crops, antimicrobials are used to manage synthetic turf. 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 antimicrobial 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.”

Finally, focusing on materials sold as antibiotics or antimicrobials is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens. Thus, we must stop broadcasting pesticides in the environment. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides had been disseminated in the environment for decades.

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

Thank you.

Letter to U.S. Representative and Senators:

Antibiotic resistance is rising to dangerously high levels. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” They continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”

A federal district court decision blocked EPA’s decision to register the antibiotic streptomycin for use in Florida citrus to control Huanglongbing (HLB), also known as “citrus greening,” a plant disease spread by the Asian citrus psyllid, citing failure to comply with the ESA and to show benefits. However, the court was not convinced that EPA fails to protect against the spread of antibiotic resistance and assumed that the restrictions that EPA required for personal protective equipment (PPE) and drift control would adequately mitigate risks.

When antimicrobial pesticides are sprayed on a crop, they induce antimicrobial resistance in bacteria that are present by killing susceptible bacteria—which may or may not be pathogenic—allowing resistant bacteria to proliferate. The resistant bacteria move off the site on crops, workers, and the wind. Prevention of chemical drift is thus inadequate to protect against the spread of antibiotic-resistant bacteria. The fact of horizontal gene transfer means that antibiotic resistance genes in those (possibly harmless) bacteria can move to pathogens.

In 2017, EPA permitted expanding use of these antibiotics in Florida citrus crops. In January 2019, EPA moved to make the authorization permanent despite, according to the New York Times, “strenuous objections from the Food and Drug Administration and the Centers for Disease Control and Prevention, which warn that the heavy use of antimicrobial drugs in agriculture could spur germs to mutate so they become resistant to the drugs, threatening the lives of millions of people.” Two years prior, oxytetracycline was approved for use on the same citrus crops.

In addition to crops, antimicrobials are used to manage synthetic turf. 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.”

Finally, focusing on materials sold as antibiotics or antimicrobials is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens. Thus, we must stop broadcasting pesticides in the environment. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides had been disseminated in the environment for decades.

Please ensure EPA does not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and cancels the registration of those that do.

Thank you.