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Action of the Week Archive

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

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03/14/2025 — FDA Must Establish Tolerances for Pesticides Used in Mixtures

With emerging independent scientific findings of adverse human health effects of pesticide mixtures, it is time for the U.S. Food and Drug Administration (FDA), a part of the U.S. Department of Health and Human Services, to use its broad authority under the Federal Food, Drug, and Cosmetic Act to “ensur(e) that human foods and animal feeds are safe” from pesticide residues. Under various memoranda of understanding between FDA, the U.S. Environmental Protection Agency (EPA), and the U.S. Department of Agriculture (USDA) going back decades, FDA should consult with EPA on a range of safety issues ignored by the agency, including  a recent data published in Pesticide Biochemistry and Physiology, which “suggest that combined [pesticide] exposure may further amplify the toxicity and compromise the intestinal barrier.” Where EPA fails to consider exposure to mixtures of pesticides in our diet, FDA must.  

The researchers in this recent study found that the toxic effects of the insecticides abamectin and spirodiclofen, as well as the fungicide fluazinam, individually and in combination caused serious adverse effects to the intestines, raising an alarm not considered by EPA. In exposing mice and in vitro colorectal cells to these pesticides, both singularly and in mixtures, the results show the disruption of intestinal functions caused by the interaction of pesticides in mixtures. These findings highlight the need to assess potential synergistic effects of pesticide mixtures as a part of the regulatory review process. FDA must recommend regulatory action in this regard. 

>> Tell Secretary of Health and Human Services Robert F. Kennedy, Jr. to instruct FDA to recommend tolerances for mixtures of pesticides. 

“Currently, most studies investigating the effects of pesticide residues on the barrier function of Caco-2 cells [human colorectal adenocarcinoma cells used as a model of the intestinal epithelial barrier] concentrate on the exposure to a single residue, while the potential toxic effects arising from the concurrent presence of multiple pesticide residues remain largely overlooked,” the authors say. As previously reported, scientists and health advocates have urged prioritizing further studies on the effect of mixtures on organisms for many decades, given that exposure in the environment is not limited to a single pesticide at a time.  

"[R]ecent studies have increasingly highlighted the toxic effects of abamectin on non-target organisms and human cells,” the researchers state. The combination of pesticides is widely used due to widespread resistance among red spider mites to individual pesticides. The interaction effects of commonly used pesticides remain largely unexplored. This study exposes a mechanism for the synergistic effects of concurrent exposure to a combination of pesticides and highlights the importance of considering synergy in risk assessments. “These findings enhance our understanding of the interactions among multiple pesticide residues and further clarify the complexity of these interactions and their impact on human exposure,” the authors conclude. (See additional coverage on health effects from pesticide mixtures here and here.)  

Additional research referenced in the study supports the findings of intestinal damage from pesticide exposure. This includes: 

  • The insecticide imidacloprid, which “induces disruption of the intestinal epithelial barrier, specifically through the down-regulation of tight junction protein complexes” and has enhanced toxicity against the gut microbiota in mice with co-exposure to zinc oxide. (See studies here and here.) 
  • The insecticide chlorpyrifos, which is “observed to disrupt the integrity of the gut barrier in mice, resulting in increased entry of lipopolysaccharides into the body.” (See study here.) 
  • The fungicide carbendazim, which when combined with epoxiconazole or fluazinam has synergistic effects in Caco-2 cells, according to a study in Food Chemistry

The findings are very concerning, given that pesticide residues in food are introduced directly to the intestines. As the researchers note, “The intestinal tract functions as a congenital barrier for homeostasis, preventing pathogenic bacteria, toxins, and other harmful substances from entering the body.” They continue: “Pesticides ingested through the diet are absorbed and transported into the human body, directly interacting with intestinal epithelial cells. This exposure results in alterations to cell permeability and integrity, ultimately compromising the barrier function of these cells.” 

The complex interactions among pesticide mixtures are not fully understood but represent a significant threat to human health The U.S. Environmental Protection Agency (EPA) fails to adequately regulate mixtures of chemicals to which organisms are exposed in the real world. Risk assessments have been highly criticized as inadequately addressing the full range of adverse effects that put human health and the health of all organisms at risk. (See more on regulatory deficiencies here and here.) 

Scientists and advocates have long asked EPA to evaluate and regulate full formulations of pesticides, and their mixtures, instead of assessing active ingredients singularly. As the body of knowledge base evolves, so should the systems for assessments that are meant to inform decisions that have a wide impact on human and ecosystem health. 

Given both the known and still unevaluated effects of pesticides, including the impact of mixtures and synergistic effects, Beyond Pesticides urges the elimination of petrochemical pesticides and synthetic fertilizers by 2032. As a holistic solution, organic land management practices offer both health and environmental benefits, with proven commercial viability and effectiveness in both agricultural and nonagricultural uses. 

>>Tell Secretary of Health and Human Services Robert F. Kennedy, Jr. to instruct FDA to recommend tolerances for mixtures of pesticides. 

The target for this Action is the U.S. Department of Health and Human Services. 

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 prepared message text if editing. 

For more information, please stay tuned for the Daily News post on March 17, 2025 [and the Daily News post from March 13, 2025].

Letter to HHS Secretary Kennedy:

Under your authority to protect the safety of the food supply from pesticide residues, it is critical that you recommend the setting of tolerances for pesticide mixtures, an area of health concern not currently considered by the U.S. Environmental Protection Agency (EPA). Study results published in Pesticide Biochemistry and Physiology “suggest that combined [pesticide] exposure may further amplify the toxicity and compromise the intestinal barrier.” The researchers found that the insecticides abamectin and spirodiclofen, and the fungicide fluazinam, individually and in combination cause serious disruption of intestinal functions caused by the interaction of pesticides in mixtures. These findings highlight the need to assess potential synergistic effects of pesticide mixtures as a part of the regulatory review process. Under memoranda of understanding with EPA, please instruct the U.S. Food and Drug Administration (FDA) to recommend tolerances based on combined exposure when pesticides are used together. 

“Currently, most studies investigating the effects of pesticide residues on the barrier function of Caco-2 cells [human colorectal adenocarcinoma cells used as a model of the intestinal epithelial barrier] concentrate on the exposure to a single residue, while the potential toxic effects arising from the concurrent presence of multiple pesticide residues remain largely overlooked,” the authors say. This study exposes a mechanism for the synergistic effects of concurrent exposure to a combination of pesticides and highlights the importance of considering synergy in risk assessments and the setting of pesticide tolerance to protect health.  

Additional research referenced in the study supports the findings of intestinal damage from pesticide exposure, including disruption of the intestinal epithelial barrier by imidacloprid, enhancing toxicity of zinc oxide to gut microbiota; disrupt the integrity of the gut barrier in mice by chlorpyrifos, resulting in increased entry of lipopolysaccharides into the body, and synergistic effects of carbendazim combined with epoxiconazole or fluazinam in Caco-2 cells.  

The findings are very troubling, since pesticide residues in food are introduced directly to the intestines. As the researchers note, “The intestinal tract functions as a congenital barrier for homeostasis, preventing pathogenic bacteria, toxins, and other harmful substances from entering the body.” They continue: “Pesticides ingested through the diet are absorbed and transported into the human body, directly interacting with intestinal epithelial cells. This exposure results in alterations to cell permeability and integrity, ultimately compromising the barrier function of these cells.” 

The complex interactions among pesticide mixtures are not fully understood but represent a significant threat to human health. EPA fails to adequately regulate mixtures of chemicals to which organisms are exposed in the real world. Risk assessments have been highly criticized as inadequately addressing the full range of adverse effects that put human health and the health of all organisms at risk. Since establishing tolerances for pesticide residues is the responsibility of FDA, I ask you to require FDA to set tolerances based on combined exposure when pesticides are used together. 

Given both the known and still unevaluated effects of pesticides, including the impact of mixtures and synergistic effects, petrochemical pesticides can be better regulated through the setting of tolerances and replaced by organic land management practices, which have proven commercial viability and effectiveness in both agricultural and nonagricultural uses. 

Thank you. 

03/07/2025 — Act for Women’s Health on This International Women’s Day!

***Note, the Action will not be available between 6:30 AM - 12:30 PM ET on Sunday, March 9, 2025, due to systems maintenance. We deeply apologize for the inconvenience.

In furtherance of the 2025 International Women's Day (IWD) goal of accelerating action, Beyond Pesticides asks you to consider the ways in which the regulation of (or failure to restrict) toxic chemicals poses disproportionate harm to women. On this day, and every day, pesticides' adverse effects on women, inadequate regulatory recognition of elevated pesticide risks to women, and the gaps in research related to pesticides and women's health must empower a louder and larger driving force in the elimination of petrochemical pesticide and fertilizer use and transition to organic practices. 

>> Tell Congress to insist on eliminating pesticides that endanger women's health. 

Pesticides disproportionately affect women's health in many ways, including ovarian and breast cancerspontaneous abortionstillbirths, and other negative birth outcomesdevelopmental effects, and adverse neurodevelopment (brain function and development) among infants. Notably, many of these health effects are hormonally responsive. Chemicals that act like hormones—endocrine disruptors—may cause or contribute to these problems. 

Endocrine disruptors (EDCs) are chemicals that can, even at low exposure levels, disrupt normal hormonal (endocrine) function. Endocrine disruptors function by: (1) mimicking the action of a naturally produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; (2) blocking hormone receptors in cells, thereby preventing the action of natural hormones; or (3) affecting the synthesis, transport, metabolism, and excretion of hormones, thus altering the concentrations of natural hormones. 

EDCs include many pesticides, exposures to which have been linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson's, Alzheimer's, and childhood and adult cancers. EDCs can wreak havoc not only on humans but also, on wildlife and ecosystems. 

In 1996 Congress required EPA to determine whether pesticides disrupt the endocrine system of humans and other organisms. The Environmental Protection Agency (EPA) in February 2024 issued a proposal for modifying its approach to the implementation of the Endocrine Disruptor Screening Program (EDSP). On October 11, EPA published a notice of a proposed partial settlement agreement and consent decree in response to a suit by the Center for Food Safety on behalf of Alianza Nacional de Campesinas, et al. challenging the agency's failure to test and regulate endocrine-disrupting pesticides. 

EPA's 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 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 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 (EDSTAC) advice and the agency's original EDSP implementation policy and science decisions.  

While the consent decree does commit 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 to protect human health and the environment. The February 2024 comments of Beyond Pesticides detail these requirements.

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 it is obliged to suspend or deny any pesticide registration until it has sufficient data to demonstrate no unreasonable adverse endocrine risk. 

The history and status of endocrine disruption research are summarized in Beyond Pesticides' comments and the October 29, 2024 Daily News post. 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.  

>> Tell Congress to insist on eliminating pesticides that endanger women's health. 

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 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 from 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 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 on whether a chemical can perturb and cause adverse endocrine outcomes in the human population and vice versa. 

FQPA 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.” SDWA addresses drinking water contaminants as well. EPA must make use of all available scientifically relevant endocrine disruption research findings and avoid deviating from established international efforts for screening/testing endocrine disruptors that incorporate human and wildlife-relevant studies. Recognizing that mammalian data informs 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.”  

According to data from the American Cancer Society, breast cancer is the most common cancer in the U.S. (2024). Genetic factors play only a minor role in breast cancer incidences, while exposure to external environmental factors (i.e., chemical exposure) may play a more notable role. For breast cancer, one in ten women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how external stimuli—like environmental pollution from pesticides—can drive breast cancer development.  

Most types of breast cancers are hormonally responsive and thus dependent on the synthesis of either estrogen or progesterone. Hormones generated by the endocrine system—and the synthetic chemicals that mimic them—greatly influence breast cancer incidents among humans. Several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with breast cancer risk. 

Many studies have long demonstrated that childhood and in-utero exposure to DDT increases the risk of developing breast cancer later in life. Many current-use pesticides and chemical contaminants play a role in similar disease prognoses, including mammary tumor formation. Recent research from the Silent Spring Institute links 28 different EPA-registered pesticides with the development of mammary gland tumors in animal studies. Many of these chemicals are endocrine disruptors and thus have implications for breast cancer risk. 

A 2020 study reveals that exposure to acetylcholinesterase (AChE) inhibitors like organophosphates (OP) can cause sex-specific differences in depression symptoms among adolescent girls through endocrine disruption. Furthermore, this study demonstrates that, in the general population, OP exposure causes an increased risk of total cancer for female non-smokers, breast cancer for female smokers, and prostate cancer for male smokers from OP exposure.  

>> Tell Congress to insist on eliminating pesticides that endanger women's health. 

Proper prevention practices, like buyinggrowing, and supporting organics, can eliminate exposure to toxic pesticides. Organic agriculture has many health and environmental benefits, as it curtails the need for chemical-intensive agricultural practices. Regenerative organic agriculture nurtures soil health through organic carbon sequestration, preventing pests and generating a higher return than chemical-intensive agriculture. For more information on why organic is the right choice, see the Beyond Pesticides webpage, Health Benefits of Organic Agriculture.  

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

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing. 

Letter to U.S. Senators and Representative:

In furtherance of the 2025 International Women’s Day (IWD) goal of accelerating action, please commit to eliminating the ways in which the regulation of (or failure to restrict) toxic chemicals pose disproportionate harm to women.

Pesticides disproportionately affect women’s health in many ways, including ovarian and breast cancer, spontaneous abortion, stillbirths, and other negative birth outcomes, developmental effects, and adverse neurodevelopment (brain function and development) among infants. Notably, many of these health effects are hormonally responsive. Chemicals that act like hormones—endocrine disruptors—may cause or contribute to these problems.

Endocrine disruptors (EDCs) are chemicals that can, even at low exposure levels, disrupt normal hormonal (endocrine) function. Endocrine disruptors function by: (1) mimicking the action of a naturally produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; (2) blocking hormone receptors in cells, thereby preventing the action of natural hormones; or (3) affecting the synthesis, transport, metabolism, and excretion of hormones, thus altering the concentrations of natural hormones.

EDCs include many pesticides, exposures to which have been linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. EDCs can wreak havoc not only on humans but also on wildlife and ecosystems.

In 1996 Congress required EPA to determine whether pesticides disrupt the endocrine system of humans and other organisms. EPA has so far failed to carry out the Congressional mandate.

According to data from the American Cancer Society, breast cancer is the most common cancer in the U.S. (2024). Genetic factors play only a minor role in breast cancer incidences, while exposure to external environmental factors (i.e., chemical exposure) may play a more notable role. For breast cancer, one in ten women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how external stimuli—like environmental pollution from pesticides—can drive breast cancer development. 

Most types of breast cancers are hormonally responsive and thus dependent on the synthesis of either estrogen or progesterone. Hormones generated by the endocrine system—and the synthetic chemicals that mimic them—greatly influence breast cancer incidents among humans. Several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with breast cancer risk.

Many current-use pesticides and chemical contaminants play a role in similar disease prognoses, including mammary tumor formation. Recent research from the Silent Spring Institute links 28 different EPA-registered pesticides with the development of mammary gland tumors in animal studies. Many of these chemicals are endocrine disruptors and thus have implications for breast cancer risk.

A 2020 study reveals that exposure to acetylcholinesterase (AChE) inhibitors like organophosphates (OP) can cause sex-specific differences in depression symptoms among adolescent girls through endocrine disruption. Furthermore, this study demonstrates that, in the general population, OP exposure causes an increased risk of total cancer for female non-smokers, breast cancer for female smokers, and prostate cancer for male smokers from OP exposure. 

In order to protect women, please insist that EPA deny the registration of any pesticide unless it is shown NOT to cause endocrine disruption.

Thank you.

03/05/2025 — Special Action: Help Oregon Eliminate All Uses of Bee-Killing Neonics—Support HB 2679 With Amendments!

UPDATE—Heard on Tuesday, March 3, 2025, in the House Committee on Climate, Energy, and the Environment! 
Please reach out to your state representative by Thursday, March 6, 2025 at 8 AM PT! #SavetheBees

Urge state representatives in the Oregon House to not only consider HB 2679 put forward by state Representative Zach Hudson (D- District 49), but to support amendments to HB 2679 on neonicotinoid insecticides linked to pollinator decline, biodiversity collapse, and human health effects. This bill addresses the need to improve the state's safeguards concerning neonicotinoids, hazardous insecticides that harm pollinators, birds, wildlife, and human health, as well as contaminate surface and drinking water. HB 2679 represents a framework for addressing the gaps in protection left by the U.S. Environmental Protection Agency (EPA) and the Oregon Department of Agriculture (ODA) and begins to tackle resident safety and ecological stability in the state.  

This bill was heard in the Oregon House Committee on Climate, Energy, and the Environment on March 3, 2025, at 8:00 AM Pacific. [PDF agenda][Video

Members of the Committee: Chair John Lively; Vice-Chair, Representative Mark Gamba; Vice-Chair, Representative Bobby Levy; Member, Representative Tom Andersen; Member, Representative Darcey Edwards; Member, Representative Ken Helm; Member, Representative Emerson Levy; Member, Representative Pam Marsh; Member, Representative Courtney Neron; Member, Representative Virgle Osborne; Member, Representative Mark Owens; and Member, Representative Kim Wallan.

>> Urge your state representatives in the Oregon House to not only consider HB 2679, but also to further amendments that eliminate all uses of neonicotinoids including agricultural applications in Oregon!

This legislation is supported by a large body of peer-reviewed scientific findings and similar protections have been passed in states such as Nevada, Maine, New Jersey, New York, and Vermont. The science on the dangers that neonicotinoids pose to pollinators and other wildlife is clear, yet federal agencies have not acted substantively. Because they are systemic pesticides, the chemical moves through the vascular system of the plant and is expressed through the plant's pollen, nectar, and guttation droplets, causing indiscriminate poisoning to foraging pollinators and insects generally. The chemical effectively turns the plant into a delivery vehicle for poison. Therefore, to the extent that this chemical is left on the market in Oregon, whether restricted use or not, it is being indiscriminately spread in the environment.  

We appreciate that the proposed legislation stops the application of neonicotinoids on residential properties. However, there are several loopholes that subject nontarget insects to poisoning. These limitations in the legislation should be corrected with amendments that prohibit: 

  • Production and/or sale of plants treated with neonicotinoids, either applied to the plant or through a treated seed. The bill allows poisoned plants to be sold in the state, permitting unsuspecting consumers to purchase and plant ornamental plants, trees, or vegetation containing neonicotinoids in their vascular system and then express them through pollen, nectar, and guttation droplets.

  • Use, sale, and production of neonicotinoid-treated seeds. The bill allows seeds treated with neonicotinoids to be sold to consumers, resulting in the contamination of soil and poisoning of nontarget insects.  

  • Use of neonicotinoids around the foundation of homes and buildings. The bill allows the application of neonicotinoids around the foundations of houses and buildings, which indiscriminately expose any insects, including pollinators, foraging or pollinating any ornamental plants, trees, or vegetation around those buildings.   

  • All uses, including “restricted uses,” of neonicotinoid insecticides. Their continued use, whether general or restricted use, will continue the apocalyptic threat to pollinators and insects that is ongoing. Therefore, all references to “restricted use” should be deleted from the bill and the section should read: '(3) Except as provided in subsections (4) and (5) of this SECTION 2.(3), a person may not apply a neonicotinoid pesticide, sell a neonicotinoid-treated plant, or produce a neonicotinoid-treated seed in the state.” This replaces the current language in this section which refers only to “residential landscape.”  

Please see the comments submitted by Beyond Pesticides for more information on: Neonicotinoids and Human Health, Ecological and Environmental Effects, and Alternatives to Neonicotinoids!

While supporting the elimination of all uses of neonicotinoids, it must be noted that these chemicals are merely the "poster children" for broader problems associated with pesticide registration and use. At a time of cascading and intersecting public health, biodiversity, and climate crises, it is vital to ban chemical classes causing immense harm while also moving towards an approach that incentivizes sustainable practices that do not necessitate toxic chemical use. 

Eliminating neonicotinoids will not cause major disruptions to the pest management or pest service industry. Pest problems in landscaped areas and in agriculture can be prevented through practices that improve soil health and promote biodiversity and habitat for pest predators. If pest problems do become an issue, a wide range of products, classified either as compatible with certified organic or minimum risk under federal law, are available and represent cost-effective alternatives.   

Oregon has the opportunity to reverse pollinator declines caused by neonicotinoid insecticides, while concurrently increasing protection for public health and the wider environment. Passing HB 2679 with our proposed amendments, while also advocating for the consideration of further pesticide reform policies that will prevent the allowance of all damaging pesticides, is the next step for the benefit of all Oregonians.

>> Urge your state representatives in the Oregon House to not only consider HB 2679, but also to further amendments that eliminate all uses of neonicotinoids including agricultural applications in Oregon.

The Targets for this Action are state Representatives in the state legislature of Oregon.

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, 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.

Letter to Oregon state Representatives:

We write to request your support with amendments to HB 2679 on neonicotinoid insecticides linked to pollinator decline, biodiversity collapse, and human health effects. This bill addresses the need to improve state safeguards concerning neonicotinoids, hazardous insecticides that harm pollinators, birds, wildlife, and human health, as well as contaminate surface and drinking water. HB 2679 represents a framework for addressing the gaps in protection left by the U.S. Environmental Protection Agency (EPA) and the Oregon Department of Agriculture (ODA) and begins to tackle resident safety and ecological stability in the state.

The science on the dangers that neonicotinoids pose to pollinators and other wildlife is clear, yet federal agencies have not acted substantively. Because they are systemic pesticides, the chemical moves through the vascular system of the plant and is expressed through the plant’s pollen, nectar, and guttation droplets, causing indiscriminate poisoning to foraging pollinators and insects generally. The chemical effectively turns the plant into a delivery vehicle for poison. Therefore, to the extent that this chemical is left on the market in Oregon, whether restricted use or not, it is being indiscriminately spread in the environment.

We appreciate that the proposed legislation stops the application of neonicotinoids on residential properties. However, there are several loopholes that subject nontarget insects to poisoning. These limitations in the legislation should be corrected with amendments that prohibit:

*Production and/or sale of plants treated with neonicotinoids, either applied to the plant or through a treated seed. The bill allows poisoned plants to be sold in the state, permitting unsuspecting consumers to purchase and plant ornamental plants, trees, or vegetation containing neonicotinoids in their vascular system and then express them through pollen, nectar, and guttation droplets.

*Use, sale, and production of neonicotinoid-treated seeds. The bill allows seeds treated with neonicotinoids to be sold to consumers, resulting in the contamination of soil and poisoning of nontarget insects.

*Use of neonicotinoids around the foundation of homes and buildings. The bill allows the application of neonicotinoids around the foundations of houses and buildings, which indiscriminately expose any insects, including pollinators, foraging or pollinating any ornamental plants, trees, or vegetation around those buildings.

*All uses, including “restricted uses,” of neonicotinoid insecticides. Their continued use, whether general or restricted use, will continue the apocalyptic threat to pollinators and insects that is ongoing. Therefore, all references to “restricted use” should be deleted from the bill and the section should read: ‘(3) Except as provided in subsections (4) and (5) of this SECTION 2.(3), a person may not apply a neonicotinoid pesticide, sell a neonicotinoid-treated plant, or produce a neonicotinoid-treated seed in the state.” This replaces the current language in this section which refers only to “residential landscape.”

Eliminating neonicotinoids will not cause major disruptions to the pest management or pest service industry. Pest problems in landscaped areas and in agriculture can be prevented through practices that improve soil health and promote biodiversity and habitat for pest predators. If pest problems do become an issue, a wide range of products, classified either as certified organic or minimum risk under federal law, are available and represent cost-effective alternatives.

Oregon has the opportunity to reverse pollinator declines caused by neonicotinoid insecticides, while concurrently increasing protections for public health and the wider environment. We urge the passage of HB 2679 with proposed amendments from Beyond Pesticides. https://bp-dc.org/bp-testimony-hb2679-3.3.2025

Thank you.

02/28/2025 — Take Action Against Plastics, Data Shows They Intensify Pesticide Toxicity

A recent literature review in Agriculture covering over 90 scientific articles documents how microplastics increase the bioavailability, persistence, and toxicity of pesticides used in agriculture. Because of their widespread infiltration into the environment and the bodies of all organisms, including humans, plastics contamination requires a holistic strategy to protect life— with consideration given to practices and chemical use that reduce or eliminate harm. Pesticides and other toxic chemicals are adsorbed (adhered) to microplastics, resulting in bioaccumulation and widespread contamination.  

This adds to the complexity of the pesticide problem, a part of the complex interactions of pesticides in the environment and human body that is largely ignored by federal regulatory agencies. While most environmental policies attempt to clean up or mitigate health threats, accumulating data on the harm associated with plastics and related contamination reinforces the necessity for all government agencies to participate in a comprehensive strategy to eliminate plastics and pesticides. However, with drastic cuts and uncertainty at the federal level, the public must look for state and local opportunities to advance policies and programs that protect health and the environment. 

>> Tell your governor and state legislators to pass a “beyond plastics” bill to reduce harm from microplastics and their interaction with pesticides and other toxic chemicals AND >> Tell Secretary of Health and Human Services Robert F. Kennedy, Jr. to use the Federal Food and Drug Administration to get plastics out of food. 

There are many uses of plastic—from artificial turf to plastic mulch to water pipes—that release toxic chemicals in use and micro- or nanoplastics as they degrade and should be eliminated. However, one broad class of plastic can be singled out because it is destined for immediate disposal—and disintegration into microplastics. Single-use plastics are therefore the target of statewide legislation that has been passed in Vermont and New Jersey.  

Beyond Plastics has drafted a model bill for statewide legislation to eliminate single-use plastics. This bill bans many of the most common sources of single-use plastic pollution—plastic bags, plastic straws, stirrers, splash guards, polystyrene, and balloon releases. 

Beyond Pesticides is working to get plastics out of organic agricultural production, processing, and packaging, and out of food production in general. The use of natural organic materials in compost and mulch is foundational to organic. Beyond Pesticides has urged the National Organic Standards Board to call for the elimination of plastic in organic to be a research priority so that restrictions can be adopted as soon as possible. See Beyond Pesticides' comments

Please note that some states have passed harmful preemption laws that prevent the banning of plastic bags and other items. Click here to find out if your state has passed a preemption law for plastics. If so, you will not be able to pass the Beyond Plastics bill and should focus on trying to get your state to strike down its preemption law. (See here for background on preemption for pesticides.) 

There are many uses of plastic in food production and packaging that release toxic chemicals and micro- or nanoplastics. This has created a public health threat. A study published in the New England Journal of Medicine (2024) found that out of a total of 257 patients completing the study, polyethylene was detected in the 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. Microplastics have also been found in human lungs, blood, feces, breast milk, the brain, and 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 storage containers.

The evolving science on plastics contamination and their interaction with pesticides is yet another reason to transition to holistic land management systems that take on the challenge of eliminating hazardous chemical use. Organic land management policy creates the holistic systems framework through which plastics can be eliminated in agriculture. Again, eliminating plastic is important not only because of the direct effects of plastic pollution on human health and the environmentbut also because they provide a vehicle for antibiotics, pesticides, and other toxic chemicals to enter into our bodies and the ecosystem, often with enhanced toxicity.  

>> Tell your governor and state legislators to pass a “beyond plastics” bill to reduce harm from microplastics and their interaction with pesticides and other toxic chemicals AND >> Tell Secretary of Health and Human Services Robert F. Kennedy, Jr. to use the Federal Food and Drug Administration to get plastics out of food. 

The targets for this Action are the U.S. state governors and state legislatures, and the U.S. Department of Health and Human Services. 

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing. 

↪️ For more information, please stay tuned for the Daily News post on March 3, 2025.

Letter to state legislators and governor: 

A recent literature review in Agriculture covering over 90 scientific articles documents how microplastics increase the bioavailability, persistence, and toxicity of pesticides used in agriculture. Because of their widespread infiltration into the environment and the bodies of all organisms, including humans, plastics contamination requires a holistic strategy to protect life— with consideration given to practices and chemical use that reduce or eliminate harm. Pesticides and other toxic chemicals are adsorbed (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. While most environmental policies attempt to clean up or mitigate health threats, accumulating data on the harm associated with plastics and related contamination reinforces the necessity for all government agencies to participate in a comprehensive strategy to eliminate plastics and pesticides. Unfortunately, with drastic cuts and uncertainty at the federal level, we must look for state and local opportunities to advance policies and programs that protect health and the environment. 

There are many uses of plastic—from artificial turf to plastic mulch to water pipes—that release toxic chemicals in use and micro- or nanoplastics as they degrade and should be eliminated. However, one broad class of plastic can be singled out because it is destined for immediate disposal—and disintegration into microplastics. Single-use plastics are therefore the target of statewide legislation that has been passed in Vermont and New Jersey.  

Beyond Plastics has drafted a model bill (https://bp-dc.org/beyond-plastics-bill) for statewide legislation to eliminate single-use plastics. This bill bans many of the most common sources of single-use plastic pollutionplastic bags, plastic straws, stirrers, splash guards, polystyrene, and balloon releases. 

The evolving science on plastics contamination and their interaction with pesticides is yet another reason to transition to holistic land management systems that take on the challenge of eliminating hazardous chemical use. Organic land management policy creates the holistic systems framework through which plastics can be eliminated in agriculture.  

Again, eliminating plastic is important not only because of the direct effects of plastic pollution on human health and the environment, but also because they provide a vehicle for antibiotics, pesticides, and other toxic chemicals to enter into our bodies and the ecosystem, often with enhanced toxicity. 

Please introduce legislation based on the Beyond Plastics model bill. 

Thank you. 

Letter to Secretary Robert F. Kennedy, Jr.  

A recent literature review in Agriculture covering over 90 scientific articles documents how microplastics increase the bioavailability, persistence, and toxicity of pesticides used in agriculture. Because of their widespread infiltration into the environment and the bodies of all organisms, including humans, plastics contamination requires a holistic strategy to protect life— with consideration given to practices and chemical use that reduce or eliminate harm. Pesticides and other toxic chemicals are adsorbed (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. While most environmental policies attempt to clean up or mitigate health threats, accumulating data on the harm associated with plastics and related contamination reinforces the necessity for all government agencies, with the Department of Health and Human Services leading, to participate in a comprehensive strategy to eliminate plastics and pesticides.  

There are many uses of plastic in food production and packaging that release toxic chemicals and micro- or nanoplastics. This has created a public health threat. A study published in the New England Journal of Medicine (2024) 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. Microplastics have also been found in human lungs, blood, feces, breast milk, the brain, and 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 storage containers.  

Please use your authority to instruct FDA to eliminate through regulation microplastics from our food and water supply. 

Thank you. 

02/21/2025 — Tell State Legislators To Focus on Ecosystem Protection, Not Just Individual Pesticides

As the public looks for opportunities to advance policies and programs that protect health and the environment in the absence of federal programs, state legislatures such as Connecticut are considering bills similar to the New York Birds & Bees Protection Act, which zero in on individual pesticides in a strategy of “whac-a-mole.” While these efforts help to educate the public on the systemic hazards of pesticides—and show individual pesticides to be the poster children for failed regulation that is inadequately protective—they could offer an opportunity to go broader in forcing state regulatory restrictions of pesticides and facilitating the transition to regenerative organic practices that are healthy for ecosystems and people. 

>> Tell state legislators to focus on ecosystem protection, not just individual pesticides. 

Over the past several years, state legislatures have led the charge on public safety and neonicotinoid regulations. The State of New York adopted the Birds and Bees Protection Act in January 2024 to ban the use of neonicotinoid insecticides by 2029; Vermont followed suit with a nearly identical bill. New Jersey and Maine are additional East Coast states that have the strongest laws on the books to eliminate all outdoor (nonagricultural) uses of bee-toxic neonicotinoid insecticides. In addition, many local governments have adopted ordinances protecting pollinators within their jurisdictions and governing pesticide use in parks, public places, and both public and private property. As Connecticut considers similar legislation, Beyond Pesticides submitted comments to the legislature urging a “more robust response to an ecological crisis that is defined by a large body of peer-reviewed scientific findings.” The testimony states: “It is important that the proposed legislation prioritize ecological pest management practices, best defined in federal law as 'organic,' as the alternative that must be assessed as an alternative to the use of neonicotinoids and related compounds because of the numerous deficiencies in the evaluation of pesticides by EPA on which the State of Connecticut relies for determinations of safety... Continued dependence on pesticides, as the current bill language allows, fails to respond to the pesticide treadmill effect that elevates pest populations by depressing ecological balance while increasing pest resistance to pesticide applications and reducing plant resiliency to pest populations.” 

In addressing specific chemicals or classes of chemicals—such as neonicotinoids, glyphosate, and dicamba—legislators must point to many other reasons for addressing pesticides at a state and local level, beginning with the failure of the U.S. Environmental Protection Agency (EPA) to carry out its mission to protect human health and the environment. In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), whether those harms are “unreasonable” depends on a weighing of costs and benefits. 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 tremendous positive impact on threatened populations. Organic farming enhances biodiversity in the ecosystem and mitigates environmental degradation and climate change, all of which is necessary for the recovery of threatened and endangered species. And we cannot afford to let anyone capitalize on marketing schemes making false claims of climate change mitigationRegenerative 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 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. Any definition of “regenerative” must—at a minimum—meet organic standards.  

>> Tell state legislators to focus on ecosystem protection, not just individual pesticides. 

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.'"  

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 by allowing systems to evolve with changing conditions. Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change.   

While all these changes are needed at a national—indeed, international—level, the current political climate makes it unlikely that these changes will be adopted by Congress and federal agencies. It is therefore crucial for state and local legislatures to step into the vacuum they have created. States can be a proving ground for changes that are urgently needed. In advancing legislation to eliminate individual bad-actor chemicals that have caught public attention, the language can include (or amendments can be attached) that: 

1. Defines “delineated allowable substances” as a part of the state pesticide registration process.” as a part of the state pesticide registration process. These allowed substances may include:   

(a) Natural, organic or “non-synthetic.” A substance that is derived from mineral, plant, or animal matter and does not undergo a “synthetic” process as defined in the Organic Foods Production Act, 7 U.S.C. § 6502(21), as the same may be amended from time to time.  

(b) Pesticides determined to be “minimum risk pesticides” pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and listed in 40 C.F.R. § 152.25(f)(1) or (2), as may be amended from time to time. 

2. Eliminates chemical fertilizers that adversely affect soil health and the natural cycling of nutrients necessary for plant resiliency, thus decreasing vulnerability to plant diseases, infestation, and drought conditions; 

3. Establishes clear and enforceable definitions; 

4. Requires a systems plan (establishes baseline for management practices intended to create resiliency and prevent pests); 

5. Creates a rigorous standard for allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list, which should follow the process laid out in the Organic Foods Production Act

6. Incorporates a certification and enforcement system (third party enforcement); 

7. Maintains a process for public participation to ensure a feedback loop for continuous improvement; and 

8. Allocates adequate funding to ensure elements are carried out in a robust way. 

>> Tell state legislators to focus on ecosystem protection, not just individual pesticides. 

The targets for this Action are the U.S. state governors and state legislatures.

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing. 

↪️ For more information, please stay tuned for the upcoming Daily News post on February 24, 2025.

Letter to State Legislators and Governors: 

As the public looks for opportunities to advance policies and programs that protect health and the environment in the absence of federal programs, state legislatures are considering bills that zero in on individual pesticides. While these efforts help to educate the public on the systemic hazards of pesticides and show individual pesticides to be the poster children for regulation that is inadequately protective, they offer an opportunity to address crises in human disease and biodiversity collapse and more broadly effect change at the state level facilitating a transition to regenerative organic practices that are healthy for ecosystems and people. 

In addressing specific chemicals or classes of chemicals legislators must point to many other reasons for addressing pesticides at a state and local level, beginning with the failure of the U.S. Environmental Protection Agency (EPA) to carry out its mission to protect human health and the environment. In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), whether those harms are “unreasonable” depends on a weighing of costs and benefits. 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. 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. 

Organic agriculture can mitigate climate change. Agriculture is a major contributor to climate change. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced greenhouse gas (GHG) emissions.  

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 for clarity and enforceability, while remaining open and transparent to growers, consumers, and the public at large.  

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 harmful materials. 

We need to shift to 100% organic farming immediately. Please advance legislation that both eliminates individual bad-actor chemicals that have caught public attention and includes the following language: 

  1. Define “delineated allowable substances” as a part of the state pesticide registration process that may include:
    (a) Natural, organic or "non-synthetic" as defined in the Organic Foods Production Act, 7 U.S.C. § 6502(21).  
    (b) Pesticides determined to be “minimum risk pesticides” and listed in 40 C.F.R. § 152.25(f)(1) or (2). 
  2. Eliminate chemical fertilizers that adversely affect soil health and the natural cycling of nutrients; 
  3. Establishes clear and enforceable definitions; 
  4. Require a systems plan as a baseline for management; 
  5. Create a rigorous standard for allowed/prohibited substances list, which should follow the process laid out in the Organic Foods Production Act; 
  6. Incorporate third party enforcement; 
  7. Maintain a process for public participation to ensure a feedback loop for continuous improvement; and 
  8. Allocate adequate funding. 


Thank you. 
 

02/19/2025 — Help Push for Bill To Advance Ecologically-Based Mosquito Management in the Commonwealth

Help lead a legislative effort in Massachusetts to adopt state law that increases restrictions on pesticides used for mosquito management, while ensuring the adoption of ecological practices protective of health and the environment. To accomplish this, it is vital to support HD1554/SD1219 with amendments ensuring that effective pest management practices do not rely on toxic pesticides, which are hazardous to people and the environment.  

Protecting against the transmission of insect-borne diseases requires special attention to “source reduction” or management of breeding sites since the neurotoxic chemicals typically used are harmful to people and biodiversity. Legislation under consideration in Massachusetts, while citing the important principle of “ecological pest management,” must carefully define required practices that ensure more rigorous attention to (i) the prevention of standing water and related habitats for mosquito breeding, (ii) a clear definition of allowed “least-toxic” chemicals (larvicides) for habitat control, (iii) preventive use of repellents and proper clothing, and (iv) action threshold from surveillance data if infected mosquitoes are found. 

We are encouraging members of the legislature to join the effort to stop hazardous pesticide spraying for mosquitoes by cosponsoring HD1554/SD1219 as a vehicle for attaching amendments that achieve adequate control by adopting practices that bring down the mosquito population. At the same time, this approach protects the biodiversity necessary to balance the benefits of natural controls. 

>> Help Push for Bill To Advance Ecologically-Based Mosquito Management in the Commonwealth.

Mosquito management in the case of insect-borne diseases requires careful attention to practices that ensure the protection of health and biodiversity. Unfortunately, mosquito control programs are often hazardous to people and the environment because of the hazardous neurotoxic chemicals that are used, which end up causing harmful exposure to vulnerable groups of people who have elevated risk factors.

The pesticides typically used for mosquito spraying are hazardous to people. The class of pesticides commonly used are synthetic pyrethroids, which are nerve poisons that are particularly dangerous for those with compromised immune and nervous systems and can be endocrine disruptors that cause general adverse effects at very low doses.

Pesticides commonly used in mosquito vector control are dangerous for the general insect population that birds depend on for nourishment. They adversely affect bee populations, with studies showing that pesticide exposure can increase the vulnerability of bees to diseases and parasites. And, the pesticides drift into waterways and disrupt aquatic life.

The spraying of pesticides to kill adult mosquitoes is not effective. While aerial application is the least effective, studies have repeatedly shown that trying to control adult mosquitoes is the least effective way to manage mosquito populations.

Because of this, legislation should ensure that the focus of a mosquito management program is primarily on eliminating the breeding sites, with the use of biological controls, where necessary, for targeting the larval stage of mosquito development. In this context, monitoring is critical to determining if and when mosquito spraying is to be used; it also offers the opportunity to disclose the dangers of the chemicals to the neighborhoods and communities where any chemicals are in use. 

The legislation must define: 

  • Mosquito management practices to target breeding sites; 
  • Public education and practices that should be adopted around buildings and landscapes; 
  • Acceptable repellents and outdoor clothing; 
  • Least-toxic larvicides and larviciding practices; 
  • Surveillance and threshold action levels for spraying; 
  • Disclosure of chemicals used in spray program; and, 
  • Notice of steps people should take to try to prevent exposure to toxic sprays.  

The debate on ecological pest management is important to people and their communities to develop effective mosquito management programs while curtailing the widespread broadcasting of toxic chemicals with nontarget exposure. The goal of the legislation must be to avoid the use of toxic chemicals through a robust program that manages mosquito breeding sites and provides robust public education on the steps that are critical to ecological pest management. 

>> Help Push for Bill To Advance Ecologically-Based Mosquito Management in the Commonwealth.

The targets for this Action are state representatives and senators in the state legislature of Massachusetts.

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, 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.

 

Sample Letter for Non-Sponsors

I humbly request your support for comprehensive reform for mosquito management policy in the Commonwealth by co-sponsoring HD 1554/SD1219 with amendments based on information provided below. In the bill’s current form, there are two main areas that I believe should be strengthened.

Definition of least-toxic management tools– I ask that EPA-registered repellents and List 25(b) federally exempt minimum risk products (detailed below) be included in the bill as criteria for recommended least-toxic management tools. I would like to stress that an ecological pest management plan must focus on source reduction (reducing and managing breeding sites). The ecological approach also recognizes that relying on spraying with adulticides is ineffective. Prevention of disease outbreaks is threatened by reliance on chemical biocides—whether to antibiotics, antimicrobials, or insecticides—to which pathogens and their vectors develop resistance. There are numerous examples of least toxic ingredients for mosquito management from EPA Registered Repellants and List 25(b) Federally Exempt Minimum Risk products. For more in-depth analysis, see here. (bp-dc.org/EPM-Commonwealth-2025)

Public education resources and threshold for adulticide uses. With disease threat, what will the conditions for adulticide be in the new program. This is where the language must be very clear on monitoring required with sentinel species. We need to separate nuisance mosquitoes from those serving as a disease vector. I urge the incorporation of more specific language on what kind of monitoring of mosquitoes is required to establish a dangerous level of infected mosquitoes, as well as specific best practices in public education resources.

Mosquito management experts agree that providing information for public education materials is crucial to ensuring that best practices are widely distributed and accessible. A non-exhaustive list of best practices to eliminate breeding sites include:
*Cleaning up standing water on residential property;
*Getting rid of unnecessary debris on residential and commercial property, such as old tires;
*Emptying water from toys, buckets, birdbaths, swimming pool covers, and any other areas twice per week where water may be collecting;
*Drilling holes in the bottom of recycling bins, swing tires and other outside containers.
*Cleaning out rain gutters and make sure they drain properly; and
*Turning garbage can covers right side up.

Similarly, a non-exhaustive list of best practices for minimizing mosquito bites include:
*Ensuring that window and door screening is properly maintained;
*Wearing protective clothing if going outside when mosquitoes are most active, which is often in the early morning and evening;
*Putting on a hat, wear long sleeves, and tuck pants into socks—especially in highly infested areas;
*Wearing light colors, as they are less attractive to mosquitoes;
*Setting up large fans for home barbeques or other outdoor gatherings;
*Using citronella candles or yellow outdoor light bulbs to repel mosquitoes;
*Filling holes or depressions in trees with sand or mortar, or drain after each rain;
*Stocking ornamental ponds with mosquito-eating fish, like mosquitofish, fathead minnows, killifish, and bluegill; and
*Avoiding using misting systems as a convenient, but ineffective, method of applying mosquito control insecticides. Misters pose unique dangers to human health due to inhalation and dermal absorption of the fine pesticide mist and the resulting chemical drift. (They were banned in Connecticut in 2018.)

For more in-depth analysis, see here. (bp-dc.org/EPM-Commonwealth-2025)

Now is a pivotal moment to demonstrate your leadership in improving mosquito management systems in the Commonwealth. I hope that you keep in mind the spirit of the state’s Biodiversity Conservation Goals in considering this legislation and our suggested amendments.

Sample Letter for Co-Sponsors

I appreciate your commitment to pushing for comprehensive mosquito management policy reform in the Commonwealth and asking you to co-sponsor this bill with amendments based on information provided below. In the bill’s current form, there are two main areas that I believe should be strengthened.

Definition of least-toxic management tools– I ask that EPA-registered repellents and List 25(b) federally exempt minimum risk products (detailed below) be included in the bill as criteria for least-toxic management tools. I would like to stress that an ecological pest management plan must focus on source reduction (reducing and managing breeding sites). The ecological approach also recognizes that relying on spraying with adulticides is ineffective.  Prevention of disease outbreaks is threatened by reliance on chemical biocides—whether to antibiotics, antimicrobials, or insecticides—to which pathogens and their vectors develop resistance. There are numerous examples of least toxic ingredients for mosquito management from EPA Registered Repellants and List 25(b) Federally Exempt Minimum Risk products. For more analysis, see here. (bp-dc.org/EPM-Commonwealth-2025)

Public education resources and threshold for adulticide uses. With disease threat, what will the conditions for adulticides be in the new program? This is where the language must be very clear on monitoring required with sentinel species. We need to separate nuisance mosquitoes from those serving as a disease vector. I urge the incorporation of more specific language on what kind of monitoring of mosquitoes is required to establish a dangerous level of infected mosquitoes, as well as specific best practices in public education resources.

Mosquito management experts agree that providing information for public education materials is crucial to ensuring that best practices are widely distributed and accessible. A non-exhaustive list of best practices to eliminate breeding sites include:
*Cleaning up standing water on residential property;
*Getting rid of unnecessary debris on residential and commercial property, such as old tires;
*Emptying water from toys, buckets, birdbaths, swimming pool covers, and any other areas twice per week where water may be collecting;
*Drilling holes in the bottom of recycling bins, swing tires and other outside containers.
*Cleaning out rain gutters and make sure they drain properly; and
*Turning garbage can covers right side up.

Similarly, a non-exhaustive list of best practices for minimizing mosquito bites include:
*Ensuring that window and door screening is properly maintained;
*Wearing protective clothing if going outside when mosquitoes are most active, which is often in the early morning and evening;
*Putting on a hat, wear long sleeves, and tuck pants into socks—especially in highly infested areas;
*Wearing light colors, as they are less attractive to mosquitoes;
*Setting up large fans for home barbeques or other outdoor gatherings;
*Using citronella candles or yellow outdoor light bulbs to repel mosquitoes;
*Filling holes or depressions in trees with sand or mortar, or drain after each rain;
*Stocking ornamental ponds with mosquito-eating fish, like mosquitofish, fathead minnows, killifish, and bluegill; and
*Avoiding using misting systems as a convenient, but ineffective, method of applying mosquito control insecticides. Misters pose unique dangers to human health due to inhalation and dermal absorption of the fine pesticide mist and the resulting chemical drift. (They were banned in Connecticut in 2018.)

For more analysis, see here. (bp-dc.org/EPM-Commonwealth-2025)

Thank you again for your leadership in improving mosquito management systems in the Commonwealth. I hope that you keep in mind the spirit of the state’s Biodiversity Conservation Goals in considering this legislation and our suggested amendments.

02/14/2025 — Advance State Tax Policies for Organic Transition, As Federal Government Reduces Support

As the public looks for opportunities to advance policies and programs that protect health and the environment in the absence of federal programs, New York State Senator Patricia Canzoneri-Fitzpatrick (R-NY) has introduced legislation (S1306) that would exempt farmland that is in transition to certified organic practices from property tax for up to three years. Creative proposals like this will be critical to the elimination of petrochemical pesticides and fertilizers that contribute to health, biodiversity, and climate crises. 

Reuters' P.J. Huffstutter and Leah Douglas reported that: “[T]he U.S. Department of Agriculture has frozen some funding for farmers as it goes through a sweeping review, despite assurances from the Trump administration that programs helping farmers would not be affected in the government overhaul. The impact has been immediate and wide-ranging, from cash assistance for ranchers to fix cattle watering systems to help for corn growers wanting to plant cover crops that curb wind erosion.” Among the funding programs affected are several upon which organic farmers depend, including the Organic Certification Cost Share Program (OCCSP), which helps organic farms and businesses offset certification costs. Without it, certification costs will increase significantly in 2025 and may force some farms to abandon organic certification altogether. 

>> Tell your state legislators and the governor to support the transition to organic with state tax policy.

In view of the uncertainty introduced by the federal funding freeze and the documented benefits of transitioning to organic production, states need to step in to support and incentivize organic as a common good that protects health and the environment and saves taxpayer costs associated with the externalities of chemical-intensive farming. These costs include those associated with fires, floods, and severe weather; daily health and cleanup expenses associated with contamination of air, land, and water; crop and productivity losses; and depressed ecosystem services (including loss of pollinators). 

State legislation like S1306 and grassroots-powered action have become more important in tackling these urgent health and environmental crises. Incentives to adopt organic practices are one important and effective way to stop the use of petrochemical pesticides and fertilizers that release greenhouse gases (carbon dioxide, nitrous oxide, and methane) while enhancing the health of soil microbial life and the drawdown of atmospheric carbon sequestration. 

  • If you are a New York resident, consider reaching out to your elected officials to voice your support for S1306.
  • If you live in another state, ask your governor and state legislators to promote similar legislation. 

>> Tell your state legislators and governor to support the transition to organic with state tax policy. 

The targets for this Action are the U.S. state governors and state legislatures.

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing. 

For more information, please stay tuned for the upcoming Daily News post on February 17, 2025.

 

02/10/2025 — Special Action—Failure to Warn: Help Stop Missouri Bill To Protect Chemical Companies from Lawsuits

Updated on February 20, 2025—HB 544 passed in the MO House, 85-72! The state senate message is still live—please join us in taking action! [For Missouri residents]

Help stop legislation in Missouri (SB14) that will shield pesticide manufacturers from being sued by people who have been harmed by their products. Beyond Pesticides is a national, grassroots organization that represents community-based organizations and a range of people seeking to improve protections from pesticides and promote alternative pest management strategies that reduce or eliminate reliance on toxic pesticides.

This legislation is moving fast! Unfortunately, HB 544 passed in the House this morning, 85 to 72! However, there is still time to inform the state Senate that it is unacceptable to deny people who have not been fully warned of the hazards of pesticides the right to sue the manufacturers that have harmed them. This is a basic right that must not be taken away by state law. SB 14 passed the Senate Agriculture, Food Production, and Outdoor Recreation Committee on January 30th

If this bill were to pass, it will strike a blow for consumer safety for all toxic products. In a climate where there is less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect our health and the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff's injury,” says Ms. Rollins. 

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year where bills were introduced in Missouri, Iowa, and Idaho. We mobilized last year with little warning, and we were able to defeat these bills. Currently, bills have been introduced in seven states. The focus of these bills is to protect chemical corporations, not people. 

>> Please ask your state Senator to OPPOSE HB 544/SB14 by clicking here.

Thank you!

The Targets for this Action are Senators in the state legislature of Missouri.

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, 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.

For more information, please see our Myths & Facts and Missouri resource page, as well as the Failure-to-Warn and Pesticide Immunity Bills resource hub.

Letter to the Missouri House: [Deactivated from the Action page on February 20, 2025]

I am writing to ask you to oppose HB 544, a bill aimed to modify "labeling for certain pesticides," that will shield pesticide manufacturers from being sued by people who have been harmed by their products. The chemical companies have argued unsuccessfully all the way to the U.S. Supreme Court that they should not be required to warn consumers about the dangers of their products. So now they are asking the Missouri legislature to do what they have not been able to do in the courts—prevent people harmed by toxic products from suing them.

As you may know, HB 544 just passed the House Agriculture Committee on February 4th.

If this bill were to pass, it will strike a blow for consumer and farmer safety for all toxic products. In a climate where there is less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect those who use potentially hazardous materials, public safety, and the health of the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff’s injury,” says Ms. Rollins. For more information, see Myths & Facts sheet (bp-dc.org/failure-to-warn-myths-and-facts-sheet) and Missouri state resource page. (https://www.beyondpesticides.org/resources/failure-to-warn/bills-to-track/midwest-target-states)

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year to at least seven states. The focus of these bills is to protect chemical corporations, not people.

Please oppose HB 544 and ensure that those who are harmed by toxic products are compensated.

Thank you!

Letter to Missouri Senate: [Updated on February 20, 2025 to reflect passage in the House]

I am writing to ask you to oppose SB 14, a bill aimed to create "a provision relating to pesticide labeling requirements," that will shield pesticide manufacturers from being sued by people who have been harmed by their products. The chemical companies have argued unsuccessfully all the way to the U.S. Supreme Court that they should not be required to warn consumers about the dangers of their products. So now they are asking the Missouri legislature to do what they have not been able to do in the courts—prevent people harmed by toxic products from suing them.

As you may know, SB 14 passed the Senate Agriculture, Food Production, and Outdoor Recreation on January 30th. Unfortunately, the partner bill HB 544 passed in the House this morning, 85 to 72, adding urgency to this issue!

If this bill were to pass, it will strike a blow for consumer and farmer safety for all toxic products. In a climate where there is less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect those who use potentially hazardous materials, public safety, and the health of the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff’s injury,” says Ms. Rollins.

For more information, see Myths & Facts sheet (bp-dc.org/failure-to-warn-myths-and-facts-sheet) and Missouri state resource page. (https://www.beyondpesticides.org/resources/failure-to-warn/bills-to-track/midwest-target-states)

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year to at least seven states. The focus of these bills is to protect chemical corporations, not people.

Please oppose SB 14 and ensure that those who are harmed by toxic products are compensated.

Thank you!

02/08/2025 — Special Action—Failure to Warn: Help Stop Oklahoma Bill To Protect Chemical Companies from Lawsuits [Inactive]

Action Inactive—HB 1755 was defeated after the legislative sponsor pulled the bill after public backlash.
Thank you for taking action! [For Oklahoma residents]

Help stop legislation in Oklahoma (HB 1755) that will shield pesticide manufacturers from being sued by people who have been harmed by their products. Beyond Pesticides is a national, grassroots organization that represents community-based organizations and a range of people seeking to improve protections from pesticides and promote alternative pest management strategies that reduce or eliminate reliance on toxic pesticides. 

HB 1755 was referred to House Agriculture Committee on February 4th and was put on the House Agriculture Committee hearing calendar for February 11, 2025 at 2:30pm EST/1:30pm CST. Update—HB 1755 was defeated after the legislative sponsor pulled the bill after public backlash.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff's injury,” says Ms. Rollins. 

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year when bills were introduced in Missouri, Iowa, and Idaho. We mobilized last year with little warning, and we were able to defeat these bills. Currently, bills have been introduced in eleven states and defeated in three. The focus of these bills is to protect chemical corporations, not people.  

>> Please ask your state Senator and Representative to OPPOSE HB 522 by clicking here [Inactive].

The Targets for this Action are state Representatives and Senators in the state legislature of Montana.

Thank you for your active participation and engagement! 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.

For more information, see our Myths & Facts and Montana resource page, as well as the Failure-to-Warn and Pesticide Immunity Bills resource hub.

Letter to the Oklahoma House: [Original text from February 8, 2025]

I am writing to ask you to oppose HB 1755, "An Act relating to agriculture; providing pesticide warning labels are sufficient under certain circumstances," that will shield pesticide manufacturers from being sued by people who have been harmed by their products. The chemical companies have argued unsuccessfully all the way to the U.S. Supreme Court that they should not be required to warn consumers about the dangers of their products. So now they are asking the Oklahoma legislature to do what they have not been able to do in the courts—prevent people harmed by toxic products from suing them.

As you may know, HB 1755 was referred to the House Agriculture Committee on February 4th.

If this bill were to pass, it would strike a blow for consumer and farmer safety for all toxic products. In a climate where there is less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect those who use potentially hazardous materials, public safety, and the health of the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff’s injury,” says Ms. Rollins. For more information, see Myths & Facts sheet (bp-dc.org/failure-to-warn-myths-and-facts-sheet) and Oklahoma state resource page. (https://www.beyondpesticides.org/resources/failure-to-warn/bills-to-track/plains-target-states)

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year to at least seven states. The focus of these bills is to protect chemical corporations, not people.

Please oppose HB 1755 and ensure that those who are harmed by toxic products are compensated.

Thank you!

02/07/2025 — Petition Would Prohibit State Pesticide Warnings and Restrictions

The public comment period is closed as of March 24, at 11:59 PM Eastern!
Due to updates to the Regulations website, we are now able to offer a click-and-submit form
to the Regulations docket! Please fill out the form linked below to submit! 

 

The U.S. Environmental Protection Agency (EPA) has an open public comment period ending March 24, 2025 on a petition filed by the attorneys general (AGs) of 11* states to prohibit state authority to warn of pesticide hazards and issue product label restrictions, just as the federal government appears to be shutting down or severely cutting back its environmental protection programs. The petition asks EPA to prohibit “any state labeling requirements inconsistent with EPA findings and conclusions from its human health risk assessment on human health effects, such as a pesticide's likelihood to cause cancer, birth defects, or reproductive harm.”

The only conclusion that can be derived from this petition is that the AGs do not care if the people, including farmers, of their states are harmed by pesticides, and they should not be able to seek compensation if they suffer adverse effects. People who argue that the chemical industry is subject to federal or state government overregulation to protect health and safety, are the same people who often argue, like in this petition, that the government should prohibit people from seeking justice in the courts if they are harmed because of inadequate disclosure and government regulation.

>>Tell EPA to protect states' rights to warn citizens of the dangers of pesticides.

While the petition is short and does not cite specifics, it clearly targets California's Proposition 65 warnings on glyphosate (RoundupTM) weed killer products, but could have much broader effect in an anything goes regulatory climate under the Trump administration. For instance, since the mechanism typically used to convey use restrictions is the pesticide product label, prohibiting a state's authority to issue warning labels undermines its regulatory authority. If states cannot convey their restrictions on the label, it is unlikely that a user of the product will be aware of the restrictions. Similarly, the courts have upheld a state's and manufacturer's “duty to warn” of pesticide hazards as a right and responsibility that is not at odds with “misbranding” regulations under federal pesticide law. (See more details on this below.)

In 2019, during the previous Trump administration, EPA told California's Office of Environmental Health Hazard Assessment (OEHHA) that its label language for glyphosate violated the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Subsequently, California's Office of Environmental Health Hazard Assessment (OEHHA) explained to EPA:

Proposition 65 is a right-to-know law that requires businesses to provide a clear and reasonable warning prior to exposing people in California to chemicals that have been listed as carcinogens or reproductive toxins. The warnings provide an important public health benefit by allowing individuals to make informed decisions about their exposures to listed chemicals.

Proposition 65 requires the listing “at a minimum” of chemicals that the International Agency for Research on Cancer (IARC) places in certain carcinogenicity classifications. In 2015, IARC placed glyphosate in a classification that mandated California's listing of the chemical under Proposition 65. Because glyphosate is now listed as a carcinogen under Proposition 65, Proposition 65 requires businesses to provide warnings if their products that contain glyphosate would result in exposures, unless those exposures fall below a certain level. 

California OEHHA asked EPA whether language citing IARC's classification would be allowed, and, in 2022, the Biden EPA said that with that specificity, it would. While California allows several options for communicating the Prop 65 warning for pesticides, historically, the label has been used to convey warnings about pesticides. In judgments awarding damages to those suffering from cancer as a result of exposure to glyphosate, courts have pointed to the failure to warn users of the hazards. A Pesticides and You article (2005) by H. Bishop Dansby explains the U.S. Supreme Court decision on “failure to warn” in Bates v. Dow Agrosciences (U.S. Supreme Court, No. 03-388, 2005): “Manufacturers have a legal duty to provide adequate warnings about the potential risks associated with their products, including pesticides. This duty arises from the recognition that manufacturers possess knowledge about the potential dangers of their products and have a responsibility to inform consumers about these risks.” 

With regard to pesticide regulation, FIFRA clearly states, “A State may regulate the sale or use of any federally registered pesticide or device in the State, but only if and to the extent the regulation does not permit any sale or use prohibited by this Act,” which is followed by a clause requiring uniformity of labeling. By focusing on the uniformity of labels, the AG petition would prohibit the state from requiring product labels to warn users of potential hazards, thus subjecting users to greater risk of illness and eliminating the incentive for manufacturers to develop safer products. It should also be noted that many local laws require service providers, such as lawn care operators or exterminators, to provide the labels of pesticide products that will be used in their contracts.

States and local governments are often at the leading edge in protecting people, land, and water from hazards. 

The attack on state authority, as well as local authority, to restrict pesticides is a bottom-line or foundational issue for public health and environmental protection. 

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. EPA should not be telling states and local governments that they cannot exercise this right, one that has been used effectively to regulate smoking, recycling, dog waste, and other standards. In fact, the U.S. Supreme Court reached this conclusion in its decision in Mortier (see more and court decision). Further, the AGs in the petition are attempting an end-run around the Supreme Court's decision in Bates (see court decision), in which Dow Chemical unsuccessfully argued that their registration with EPA preempted any litigation against them for the harm caused by their product, and more specifically that FIFRA's labeling requirements preempted cases arguing failure-to-warn or inadequate labeling. Here is Beyond Pesticides' piece on the right of local government in a state that does not preempt its local jurisdictions (municipalities) from restricting pesticides more stringently than the state and the federal government. And, see the Maryland Court decision.
 
The ramifications of any prohibition on state authority to require label changes is extremely broad because the label is typically the mechanism used by federal and state regulatory authorities to communicate legal use restrictions of a pesticide product. If a state is prohibited from conveying pesticide restrictions or warning via the pesticide product label, it is unlikely that the user will, for practical purposes, be aware of the restrictions or warnings.

>>Please submit a comment to EPA asking them to reject the AG petition and support the right of states and local governments to protect their residents, land, and water. . 

The target for this Action is Regulations.gov. (See here.)

*The 11 states filing the petition include: Alabama, Arkansas, Georgia, Indiana, Iowa, Louisiana, Montana, Nebraska, North Dakota, South Carolina, and South Dakota. 

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing. 

Letter to EPA:

Please deny the attorneys general (AGs) petition, which misrepresents the authority and responsibility of state governments in their role to protect public health and safety.

While the petition targets California Prop 65 warnings on glyphosate products, it goes much further in restricting the authority of states to restrict pesticides under FIFRA. In 2019, EPA told California’s Office of Environmental Health Hazard Assessment (OEHHA) that its label language for glyphosate violated the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Subsequently, OEHHA explained to EPA:

Proposition 65 is a right-to-know law that requires businesses to provide a clear and reasonable warning prior to exposing people in California to chemicals that have been listed as carcinogens or reproductive toxins. The warnings provide an important public health benefit by allowing individuals to make informed decisions about their exposures to listed chemicals.

Proposition 65 requires the listing “at a minimum” of chemicals that the International Agency for Research on Cancer (IARC) places in certain carcinogenicity classifications. In 2015, IARC placed glyphosate in a classification that mandated California’s listing of the chemical under Proposition 65. Because glyphosate is now listed as a carcinogen under Proposition 65, Proposition 65 requires businesses to provide warnings if their products that contain glyphosate would result in exposures, unless those exposures fall below a certain level.

California OEHHA asked EPA whether language citing IARC's classification would be allowed, and in 2022, EPA said that with that specificity, it would. While California allows several options for communicating the Prop 65 warnings, historically, the label has been used to convey warnings about pesticides. In jury verdicts awarding damages to those suffering from cancer as a result of exposure to glyphosate, courts have pointed to the failure to warn users of the hazards. A Pesticides and You article (2005) by H. Bishop Dansby explains the U.S. Supreme Court decision on “failure to warn” in Bates v. Dow Agrosciences (U.S. Supreme Court, No. 03-388, 2005): “Manufacturers have a legal duty to provide adequate warnings about the potential risks associated with their products, including pesticides. This duty arises from the recognition that manufacturers possess knowledge about the potential dangers of their products and have a responsibility to inform consumers about these risks.”

With regard to pesticide regulation, FIFRA clearly states, “A State may regulate the sale or use of any federally registered pesticide or device in the State, but only if and to the extent the regulation does not permit any sale or use prohibited by this Act,” which is followed by a clause requiring uniformity of labeling. By focusing on the uniformity of labels, the AG petition would prohibit the state from requiring product labels to warn users of potential hazards, thus subjecting users to greater risk of illness.

States and local governments often take creative measures to protect people, land, and water from hazards. States and local governments believe in their right to protect their residents from poisoning and contamination, a right that has been upheld by the U.S. Supreme Court. The only conclusion that can be derived from the petition is that the AGs do not care if the people, including farmers, of their states are harmed by pesticides, and they should not be able to seek compensation if they suffer adverse effects due to a failure to warn on a pesticide label. The courts have upheld a state’s and manufacturer’s “duty to warn” of pesticide hazards as a right and responsibility that is not at odds with “misbranding” regulations under federal pesticide law.

Please uphold the rights of states and deny the AG petition.

Thank you.

02/03/2025 — Special Action—Failure to Warn: Help Stop Wyoming Bill To Protect Chemical Companies from Lawsuits [Inactive]

Action Inactive—HB 285 was defeated after the bill failed to move out of committee.
Thank you for taking action! [For Wyoming residents]

Help stop legislation in Wyoming (HB 285) that would shield pesticide manufacturers from being sued by people who have been harmed by their products. Beyond Pesticides is a national grassroots organization that represents community-based organizations and a range of people seeking to improve protections from pesticides and promote alternative pest management strategies that reduce or eliminate a reliance on toxic pesticides.

HB 285 was referred to the House Agriculture Committee on January 28 and was put on the House Agriculture Committee hearing calendar for February 6, 2025. Update—HB 285 was defeated after failing to move out of committee.

If this bill were to pass, it would strike a blow for consumer safety for all toxic products. In a climate where there is less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect our health and the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff's injury,” says Ms. Rollins.  

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year, where bills were introduced in Missouri, Iowa, and Idaho. We mobilized last year with little warning, and we were able to defeat these bills. Currently, bills have been introduced in seven states. The focus of these bills is to protect chemical corporations, not people.

>> Please ask your state Representative to OPPOSE HB 285 by clicking here. [Inactive].

Thank you for your active participation and engagement! 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.

For more information, see our Myths & Facts and Wyoming resource page, as well as the Failure-to-Warn and Pesticide Immunity Bills resource hub.

Letter to the Wyoming House: [Original text from February 8, 2025]

I am writing to ask you to oppose HB 285, "An Act relating to public health and safety; providing standards for a pesticide manufacturer's or seller's duty to warn consumers or the public about pesticide risks as specified," that will shield pesticide manufacturers from being sued by people who have been harmed by their products. The chemical companies have argued unsuccessfully all the way to the U.S. Supreme Court that they should not be required to warn consumers about the dangers of their products. So now they are asking the Wyoming legislature to do what they have not been able to do in the courts—prevent people harmed by toxic products from suing them.

As you may know, HB 285 was referred to the House Agriculture Committee on January 28th. A hearing is scheduled for this committee to discuss the bill on February 6th.

If this bill were to pass, it would strike a blow for consumer and farmer safety for all toxic products. In a climate where there is less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect those who use potentially hazardous materials, public safety, and the health of the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff’s injury,” says Ms. Rollins. For more information, see Myths & Facts sheet (bp-dc.org/failure-to-warn-myths-and-facts-sheet) and Wyoming state resource page. (https://www.beyondpesticides.org/resources/failure-to-warn/bills-to-track/northwest-target-states)

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year to at least seven states. The focus of these bills is to protect chemical corporations, not people.

Please oppose HB 285 and ensure that those who are harmed by toxic products are compensated.

Thank you!

02/03/2025 — Special Action—Failure to Warn: Help Stop Mississippi Bill To Protect Chemical Companies from Lawsuits [Inactive]

Action Inactive—HB 1221/SB 2472 was defeated after the bills failed to move out of committee.
Thank you for taking action! [For Mississippi residents]

Help stop legislation in Mississippi (HB 1221/SB 2472) that would shield pesticide manufacturers from being sued by people who have been harmed by their products. Beyond Pesticides is a national grassroots organization that represents community-based organizations and a range of people seeking to improve protections from pesticides and promote alternative pest management strategies that reduce or eliminate a reliance on toxic pesticides.

HB 1221 failed to pass the House Judiciary Committee on February 4. SB 2472 failed to pass the Senate Judiciary Committee on February 13. Update—HB 1221 and SB 2472 were defeated after failing to move out of committee.

If this bill were to pass, it would strike a blow for consumer safety for all toxic products. In a climate with less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect our health and the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff's injury,” says Ms. Rollins.  

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year, where bills were introduced in Missouri, Iowa, and Idaho. We mobilized last year with little warning, and we were able to defeat these bills. Currently, bills have been introduced in eleven states. The focus of these bills is to protect chemical corporations, not people.

>> Please ask your state Representative and Senator to OPPOSE HB 1221/SB 2472 by clicking here. [Inactive].

Thank you for your active participation and engagement! 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.

For more information, see our Myths & Facts and Mississippi resource page, as well as the Failure-to-Warn and Pesticide Immunity Bills resource hub.

Letter to the Mississippi Senate: [Original text from February 14, 2025]

I am writing to ask you to oppose SB 2472, a bill that will shield pesticide manufacturers from being sued by people who have been harmed by their products. The chemical companies have argued unsuccessfully all the way to the U.S. Supreme Court that they should not be required to warn consumers about the dangers of their products. So now they are asking the Mississippi legislature to do what they have not been able to do in the courts—prevent people harmed by toxic products from suing them.

SB 2472 failed to pass the Senate Judiciary Committee on February 13. Update—SB 2472 was defeated after failing to move out of committee.

If this bill were to move forward, it would strike a blow for consumer and farmer safety for all toxic products. In a climate with less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect those who use potentially hazardous materials, public safety, and the health of the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff’s injury,” says Ms. Rollins. For more information, see the Myths & Facts sheet (bp-dc.org/failure-to-warn-myths-and-facts-sheet)and Mississippi state resource page. (https://www.beyondpesticides.org/resources/failure-to-warn/bills-to-track/southeast-target-states)

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year to at least seven states. The focus of these bills is to protect chemical corporations, not people.

If the bill is re-introduced, please oppose SB 2472 and ensure that those who are harmed by toxic products are compensated.

Thank you!

Letter to the Mississippi House: [Original text from February 14, 2025]

I am writing to ask you to oppose HB 1221, a bill that will shield pesticide manufacturers from being sued by people who have been harmed by their products. The chemical companies have argued unsuccessfully all the way to the U.S. Supreme Court that they should not be required to warn consumers about the dangers of their products. So now they are asking the Mississippi legislature to do what they have not been able to do in the courts—prevent people harmed by toxic products from suing them.

HB 1221 failed to pass the House Judiciary Committee on February 4th. Update—HB 1221 was defeated after failing to move out of committee.

If this bill were to move forward, it would strike a blow for consumer and farmer safety for all toxic products. In a climate with less regulation, the ability to sue creates an incentive for manufacturers to develop safer products that protect those who use potentially hazardous materials, public safety, and the health of the environment—not to mention the compensation it provides to those harmed.

Failure-to-warn claims serve as the basis for the overwhelming majority of pesticide injury litigation of the past decade, according to legal professionals, including Brigit Rollins, JD, staff attorney at National Agriculture Law Center. Failure-to-warn is a legal argument grounded in the common law of state court systems across the nation. “Almost every pesticide injury lawsuit filed in the past ten years has included a claim that the pesticide manufacturer failed to warn the plaintiff of the health risks associated with using their product and that such failure caused the plaintiff’s injury,” says Ms. Rollins. For more information, see the Myths & Facts sheet (bp-dc.org/failure-to-warn-myths-and-facts-sheet)and Mississippi state resource page. (https://www.beyondpesticides.org/resources/failure-to-warn/bills-to-track/southeast-target-states)

Petrochemical-based pesticide manufacturers, predominately German-owned Bayer-Monsanto, are expanding their all-out push from last year to at least seven states. The focus of these bills is to protect chemical corporations, not people.

If the bill is re-introduced, please oppose HB 1221 and ensure that those who are harmed by toxic products are compensated.

Thank you!

01/31/2025 — Tell Congress To Ensure Integrity in Federal Agencies

In what promises to be a threat to the integrity of federal agencies, President Trump summarily fired at least 17 Inspectors General (IGs) on January 24 across 18 agencies—eliminating, at least for some critical time period, independent oversight of all agency decisions in the new administration. An IG acts independently of the agency head to investigate corruption, fraud, and abuse in the agency and report to Congress. As The Washington Post used to, but no longer displays on its masthead, “Democracy Dies in Darkness.” 

>> Tell Congress to ensure the integrity of federal agencies through the appointment of independent Inspectors General.

Although IGs—like department heads—are appointed by the President and confirmed by the U.S. Senate, the law defines their role to be independent of politics. The Inspector General Act of 1978 states, “There shall be at the head of each Office an Inspector General who shall be appointed by the President, by and with the advice and consent of the Senate, without regard to political affiliation and solely on the basis of integrity and demonstrated ability in accounting, auditing, financial analysis, law, management analysis, public administration, or investigations.” [Emphasis added.] The act also provides that the President may remove an IG, but states, “If an Inspector General is removed from office or is transferred to another position or location within an establishment, the President shall communicate in writing the reasons for any such removal or transfer to both Houses of Congress, not later than 30 days before the removal or transfer.” [Emphasis added.] Because Trump failed to provide the 30-day notice and justification as required by law, some claim that the action is illegal, while others regard the infraction as a technicality.  

However, even some who do not seem especially concerned by the President's dismissal action say that the real impact of the unexpected presidential action will be determined by the replacements of the fired IGs and the time frame in which new appointments are made. The intended effect of the law will be advanced only if the Senate insists on the independence and integrity of the new appointees. 

The now former IG at the Interior Department, Mark Greenblatt (appointed by Mr. Trump five years ago), was quoted in The New York Times: “This raises an existential threat with respect to the primary independent oversight function in the federal government. We have preserved the independence of inspectors general by making them not swing with every change in political party.” 

The independence of the IGs gives them an important role in ensuring the integrity of agency actions. For example, the IG of the Environmental Protection Agency has in recent years investigated and reported to Congress on: pet collars containing pesticides that continue to be used without assurance that there are no unreasonable adverse effects on the environment, including pets; deviation from established procedures in registering dicamba; EPA's failure to assess risks from endocrine disrupting chemicals; inadequacies of management controls to implement the revised Worker Protection Standard; and failure to follow the typical intra-agency review and clearance process during the development and publication of the January 2021 perfluorobutane sulfonic acid, or PFBS, toxicity assessment. It also reported on programmatic issues, including: emergency exemptions; a special local needs programtransparency of cancer risk assessmentstate cooperative agreements; and implementing stronger internal controls to decrease the risk of issuing a pesticide registration that does not comply with regulatory requirements.  

IGs also play a role in protecting whistleblowers who come forward with information about misconduct within the agency, such as lack of integrity in chemical risk assessment. EPA's IG reported on retaliation against whistleblowers in 2024.  

>>Tell Congress to ensure the integrity of federal agencies through the appointment of independent Inspectors General. 

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

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing. 

↪️ For more information, please stay tuned for the upcoming Daily News post on February 3, 2025.

Letter to U.S. Representative: 

In what promises to be a threat to the integrity of federal agencies, President Trump summarily fired at least 17 Inspectors General (IGs) on January 24 across 18 agencies—eliminating, at least for some critical time period, independent oversight of all agency decisions in the new administration. An IG acts independently of the agency head to investigate corruption, fraud, and abuse in the agency and report to Congress. As The Washington Post used to, but no longer displays on its masthead, “Democracy Dies in Darkness.” 

Although IGs—like department heads—are appointed by the President and confirmed by the Senate, the law defines their role to be independent of politics. The Inspector General Act of 1978 states, “There shall be at the head of each Office an Inspector General who shall be appointed by the President, by and with the advice and consent of the Senate, without regard to political affiliation and solely on the basis of integrity and demonstrated ability in accounting, auditing, financial analysis, law, management analysis, public administration, or investigations.” [Emphasis added.] The act also provides that the President may remove an IG, but states, “If an Inspector General is removed from office or is transferred to another position or location within an establishment, the President shall communicate in writing the reasons for any such removal or transfer to both Houses of Congress, not later than 30 days before the removal or transfer.” [Emphasis added.] Because Trump failed to provide the 30-day notice and justification as required by law, some claim that the action is illegal, while others regard the infraction as a technicality.  

However, even some who do not seem especially concerned by the President’s dismissal action say that the real impact of the unexpected presidential action will be determined by the replacements of the fired IGs and the time frame in which new appointments are made. The intended effect of the law will be advanced only if the Senate insists on the independence and integrity of the new appointees. 

The now former IG at the Interior Department, Mark Greenblatt (appointed by Mr. Trump five years ago), was quoted in The New York Times: “This raises an existential threat with respect to the primary independent oversight function in the federal government. We have preserved the independence of inspectors general by making them not swing with every change in political party.” 

The independence of the IGs gives them an important role in ensuring the integrity of agency actions. For example, the IG of the Environmental Protection Agency has in recent years investigated and reported to Congress on: pet collars containing pesticides that continue to be used without assurance that there are no unreasonable adverse effects on the environment, including pets; deviation from established procedures in registering dicamba; EPA’s failure to assess risks from endocrine disrupting chemicals; inadequacies of management controls to implement the revised Worker Protection Standard; and failure to follow the typical intra-agency review and clearance process during the development and publication of the January 2021 perfluorobutane sulfonic acid, or PFBS, toxicity assessment. It also reported on programmatic issues, including: emergency exemptions; a special local needs program; transparency of cancer risk assessment; state cooperative agreements; and implementing stronger internal controls to decrease the risk of issuing a pesticide registration that does not comply with regulatory requirements.  

IGs also play a role in protecting whistleblowers who come forward with information about misconduct within the agency, such as lack of integrity in chemical risk assessment. EPA’s IG reported on retaliation against whistleblowers in 2024.  

Please request a U.S. Government Accountability Office report on the importance of IGs and their independence. 

Thank you. 

Letter to U.S. Senators:

In what promises to be a threat to the integrity of federal agencies, President Trump summarily fired at least 17 Inspectors General (IGs) on January 24 across 18 agencies—eliminating, at least for some critical time period, independent oversight of all agency decisions in the new administration. An IG acts independently of the agency head to investigate corruption, fraud, and abuse in the agency and report to Congress. As The Washington Post used to, but no longer displays on its masthead, “Democracy Dies in Darkness.” 

Although IGs—like department heads—are appointed by the President and confirmed by the Senate, the law defines their role to be independent of politics. The Inspector General Act of 1978 states, “There shall be at the head of each Office an Inspector General who shall be appointed by the President, by and with the advice and consent of the Senate, without regard to political affiliation and solely on the basis of integrity and demonstrated ability in accounting, auditing, financial analysis, law, management analysis, public administration, or investigations.” The act also provides that the President may remove an IG, but states, “If an Inspector General is removed from office or is transferred to another position or location within an establishment, the President shall communicate in writing the reasons for any such removal or transfer to both Houses of Congress, not later than 30 days before the removal or transfer.” Because Trump failed to provide the 30-day notice and justification as required by law, some claim that the action is illegal, while others regard the infraction as a technicality.  

However, even some who do not seem concerned by the President’s dismissal say that the real impact of the unexpected presidential action will be determined by the replacements of the fired IGs and the time frame in which new appointments are made. The intended effect of the law will be advanced only if the Senate insists on the independence and integrity of the new appointees. 

The now former IG at the Interior Department, Mark Greenblatt (appointed by Mr. Trump five years ago), was quoted in The New York Times: “This raises an existential threat with respect to the primary independent oversight function in the federal government. We have preserved the independence of inspectors general by making them not swing with every change in political party.” 

The independence of the IGs gives them an important role in ensuring the integrity of agency actions. For example, the IG of the Environmental Protection Agency has investigated and reported to Congress on: pet collars containing pesticides that continue to be used without assurance that there are no unreasonable adverse effects on the environment, including pets; deviation from established procedures in registering dicamba; EPA’s failure to assess risks from endocrine disrupting chemicals; inadequacies of management controls to implement the revised Worker Protection Standard; and failure to follow the typical intra-agency review and clearance process during development and publication of the January 2021 perfluorobutane sulfonic acid, or PFBS, toxicity assessment. It also reported on programmatic issues: emergency exemptions; a special local needs program; transparency of cancer risk assessment; state cooperative agreements; and implementing stronger internal controls to decrease the risk of issuing a pesticide registration that does not comply with regulatory requirements.  

IGs also play a role in protecting whistleblowers who come forward with information about misconduct within the agency, such as lack of integrity in chemical risk assessment. EPA’s IG reported on retaliation against whistleblowers in 2024.  

Please vote to confirm only proposed IGs who meet the criteria for independence and integrity required by law. Please request a U.S. Government Accountability Office report on the importance of IGs and their independence. 

Thank you. 

***
Why we TAKE ACTION:

During these times, Beyond Pesticides urges sending a message even to those who refuse to listen. As we strive to adopt the changes essential for a livable future, we must create a record that is based on science, even when the science and the facts are dismissed by those in power. To this end, the failure of action to address the existential health, biodiversity, and climate crises by those in Congress and the administration, empowers lower levels of government and some corporations to step into the void left by those whose actions or inaction threaten life.

Please feel free to reach out to the Beyond Pesticides team with feedback. And, In light of the current and future threats, we invite you, if you wish, to click on the image below to join us in a moment of cathartic primal scream therapy before finding a light at the end of the tunnel!

01/27/2025 — Tell U.S. FWS To Fully Protect Endangered Rusty Patched Bumble Bee

The public comment period is closed as of January 27, 2025, at 11:59 PM Eastern!
Due to updates to the Regulations website, we are now able to offer a click-and-submit form
to the Regulations docket! Please fill out the form linked below to submit! 

 

A public comment period ends today, January 27, 2025, on the U.S. Fish and Wildlife Service's (FWS) proposed critical habitat rule to protect the rusty patched bumble bee under the Endangered Species Act (ESA). This proposal is responsive to the agency's 2024 stipulated settlement agreement resulting from years of advocacy and government review and a 2023 court order (NRDC et al. v. U.S. Fish and Wildlife Service, et al.). The proposal follows a 2017 determination by the agency that lists the bumble bee as an endangered species. (See previous Daily News herehereherehere, and here.)

>> Tell the U.S. Fish and Wildlife Service to fully protect the endangered rusty patched bumble bee by finalizing its proposed critical habitat rule with strengthening provisions.

The FWS proposal grows out of a species status assessment (SSA) conducted by “15 scientists with expertise in bumble bee biology, habitat management, and stressors (factors negatively affecting the species).” University of Illinois Urbana-Champaign insect ecologist Jason Robinson, PhD concludes in his paper, “Project-specific bumble bee habitat quality assessment,” “As the first social insect listed under the ESA, the listing of RPBB has required new methods for biological assessment. This species has a complex life cycle requiring a mosaic of different habitat types, with each life cycle stage facing unique challenges and threats.” This is why a critical habitat designation is especially important and timely after seven years since the listing.

When FWS issued its listing announcement in 2017, it said, “Causes of the decline in rusty patched bumble bee populations are believed to be loss of habitat; disease and parasites; use of pesticides that directly or indirectly kill the bees; climate change , which can affect the availability of the flowers they depend on; and extremely small population size. Most likely, a combination of these factors has caused the decline in rusty patched bumble bees." There is substantial research demonstrating that neonicotinoid insecticides, working either individually or synergistically, play a critical role in the ongoing decline of bees and other pollinators due to mounting evidence of toxicity.

When FWS announced the endangered species classification for the rusty patched bumble bee, it wrote: “Before it was declared endangered in 2017, the rusty patched bumble bee experienced a widespread and steep decline, with populations plummeting by about 87 percent in the past two decades. . . The cause of the species' drastic decline is unknown, but evidence suggests a harmful interaction between a disease-causing pathogen and exposure to pesticides. Other threats to the insect include habitat loss and degradation, competition and disease introduction from managed and non-native bees, small population genetics, and climate change. The rusty patched bumble bee lives in colonies, which are formed by solitary queens emerging from overwintering sites. The species needs nectar and pollen-producing flowers for food, undisturbed nesting habitat near food sources, and suitable overwintering areas to survive. The final recovery plan for the rusty patched bumble bee includes actions such as land management to improve floral resources and measures to reduce exposure to pesticides and disease-causing pathogens. Raising awareness about the species and engaging private citizens and groups are also key to recovery.” 

In this context, given the scientific findings, FWS must make sure that its designation of critical habitat takes into account all areas that are necessary to the species' restoration, including agricultural areas and unoccupied spaces.

>> Tell the U.S. Fish and Wildlife Service to fully protect the endangered rusty patched bumble bee by finalizing its proposed critical habitat rule with strengthening provisions. 

The target for this Action is the U.S. Fish and Wildlife Service, via comments through Regulations.gov.

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing.

01/24/2025 — EPA Must Review Complete Data for All Pesticides

The public comment period closes on February 10, 2025, at 11:59 PM Eastern!
Due to updates to the Regulations website, we are now able to offer a click-and-submit form
to the Regulations docket! Please fill out the form linked below to submit! 

 

EPA is proposing “streamlined proposed registration review decisions for several biopesticides.” Because EPA considers the four “biopesticides” to be “low risk,” “[t]he Agency is proposing that no further registration review is necessary for these biopesticides at this time.” Although the biopesticides listed in EPA's proposal for streamlining the registration review process for "low risk biopesticides" can be considered relatively low risk compared to conventional pesticides, the precedent for relying on the original or previous registration data and review is troublesome.

>> Tell EPA to do full registration reviews for all pesticides. 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires that the Environmental Protection Agency (EPA) conduct a registration review of all registered pesticides every 15 years. EPA explains, “[S]cience is constantly evolving, and new scientific information can come to light at any time and change our understanding of potential effects from pesticides.”

The four biopesticides to which this proposal pertains are alpha methyl mannoside (a plant growth regulator to improve the growth of a range of crops); Duddingtonia flagrans strain IAH 1297 (to break the cycle of parasitic nematode infections in grazing animals); Pepino mosaic virus, strain CH2, isolate 1906 (to protect greenhouse tomatoes from other viruses); and sheep fat (to repel animals like deer from ornamentals, trees, shrubs, and other plants). When considering the listed biopesticides in the proposal, EPA's summaries are predominantly dependent on limited actual data, data waiver request rationales, and purported absence of new data or adverse incidents reported. The absence of adverse effect evidence is not evidence of no adverse effects.

For alpha methyl mannoside, all human health data requirements were satisfied by a combination of data, waiver rationales, and the bridging of information from guar gum where high concentrations of mannose polymers are present. For ecological effects, all nontarget toxicology data requirements have been satisfied through guideline studies that demonstrated low acute toxicity for birds, mammals, aquatic organisms, invertebrates, and plants. EPA has concluded that adverse effects are not anticipated to birds, mammals, freshwater fish, aquatic invertebrates, insects, and nontarget plants. Curiously, the agency also determined that effects to federally listed threatened and endangered species and their designated critical habitats are not expected from these uses. However, the mode of action for alpha methyl mannoside, as a plant growth regulator, is to stimulate growth of treated plants. It is unclear why stimulating the growth of listed plant species, if exposed, or plants in the critical habitat of a listed species either plant or animal, if exposed, would not be potentially problematic or negatively affected by excessive growth. This seems worthy of more in-depth consideration as many herbicides function by excessive growth stimulation of target weeds, which can pose serious risks to nontarget plants.

For Duddingtonia flagrans strain IAH 1297, the registrant requested consideration of the history of safe use, the global ubiquity of D. flagrans, and the rationale based on literature sources to satisfy the data requirements for avian toxicity, wild mammal toxicity, aquatic organism testing, nontarget plant testing, and nontarget insect testing. EPA accepted the data waiver requests.

Similarly for Pepino mosaic virus, strain CH2, isolate 1906, scientific rationale was submitted and accepted to satisfy data requirements for Avian oral, Avian inhalation, Wild mammals, Freshwater fish, Freshwater invertebrates, Estuarine/marine fish and invertebrates, Nontarget insects, Honey bees, and Nontarget Plant toxicity/pathogenicity testing. Additionally, some nontarget plant testing, persistence in soil, persistence in water, algal toxicity, duckweed growth inhibition, and vegetative vigor studies were submitted. The results from the nontarget plant testing study are considered supplemental due to several deficiencies in the study, and it is not robust enough to conclude a lack of hazard for nontarget plants. The aquatic plant studies did not adequately describe the positive controls used, why the virus was not detectable at the start of the experiments, and did not describe the concentration (lg/L) of Pepino mosaic virus, strain CH2, isolate 1906 treatment in the Algal toxicity test which may have caused minimal growth inhibition.

EPA distinguishes three classes of biopesticides—biochemical, microbial, and plant-incorporated protectants (PIPs). The agency says, “Because it is sometimes difficult to determine whether a substance meets the criteria for classification as a biochemical pesticide, EPA has established a special committee to make such decisions.” “Biopesticides” are often assumed to be safer than “conventional” pesticides because they are assumed to be “natural.” However, EPA's definition of biopesticides—"derived from such natural materials as animals, plants, bacteria, and certain minerals”—does not mean that they are “natural.” Many of them would not qualify as “nonsynthetic” inputs in organic farming because the organic law requires consideration of manufacturing processes. Since some biopesticides—for example, pheromones—occur in minute quantities naturally, they are produced through chemical synthesis for commercial use. Such synthetic chemicals must be recommended by the National Organic Standards Board before they can be used in organic production and processing. Some microbial pesticides and PIPs would not be allowed because they result from genetic engineering.

Although the biopesticides listed in EPA's proposal for streamlining the registration review process for "low risk biopesticides" can be considered relatively low risk compared to conventional pesticides, the precedent for relying on the original or previous registration data and review is troublesome. EPA's rationale for registration review—that “science is constantly evolving, and new scientific information can come to light at any time and change our understanding of potential effects from pesticides,” should guide the agency in its decisions—especially when previous decisions have depended on limited actual data, data waiver request rationales, and purported absence of new data or adverse incidents reported. 

>> Tell EPA to do full registration reviews for all pesticides. 

The target for this Action is the U.S. Environmental Protection Agency, via comments through Regulations.gov.

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing.

Letter to EPA:

Although biopesticides in the proposal for streamlining the registration review process for "low risk biopesticides" can be considered low risk compared to conventional pesticides, the precedent for relying on the original or previous registration data and review is unacceptable.

The Federal Insecticide, Fungicide, and Rodenticide Act requires that EPA conduct a registration review of all registered pesticides every 15 years. EPA states, “[S]cience is constantly evolving, and new scientific information can come to light at any time and change our understanding of potential effects from pesticides.”

EPA’s summaries concerning Alpha methyl mannoside; Duddingtonia flagrans strain IAH 1297; Pepino mosaic virus, strain CH2, isolate 1906; and sheep fat are predominantly dependent on limited actual data, data waiver request rationales, and purported absence of new data or reported adverse incidents. Absence of adverse effect evidence is not evidence of no adverse effects.

All human health data requirements for alpha methyl mannoside were satisfied by a combination of data, waiver rationales, and data from guar gum where high concentrations of mannose polymers are present. EPA concluded from guideline studies that adverse effects are not anticipated to birds, mammals, freshwater fish, aquatic invertebrates, insects, and nontarget plants. Although the agency also determined that effects to federally listed threatened and endangered species and their designated critical habitats are not expected from these uses, the mode of action as a plant growth regulator is to stimulate growth of treated plants. It is unclear why stimulating growth of listed plant species or plants in a critical habitat of a listed species, either plant or animal, would not result in negative impacts. This seems worthy of more in-depth consideration, as many herbicides function by excessive growth stimulation of target weeds, posing serious risks to nontarget plants.

For Duddingtonia flagrans strain IAH 1297, the registrant requested consideration of the history of safe use, the global ubiquity of D. flagrans, and a rationale based on literature sources to satisfy the data requirements for avian toxicity, wild mammal toxicity, aquatic organism testing, nontarget plant testing, and nontarget insect testing. EPA accepted the data waiver requests.

Similarly for Pepino mosaic virus, strain CH2, isolate 1906, scientific rationale was accepted to satisfy data requirements for avian oral, avian inhalation, wild mammals, freshwater fish, freshwater invertebrates, estuarine/marine fish and invertebrates, nontarget insects, honey bees, and nontarget plant toxicity/pathogenicity testing. Some nontarget plant testing, persistence in soil, persistence in water, algal toxicity, duckweed growth inhibition, and vegetative vigor studies were submitted. The nontarget plant testing study has several deficiencies and is insufficient to support a lack of hazard for nontarget plants. The aquatic plant studies did not adequately describe the positive controls used, why the virus was not detectable at the start of the experiments, and did not describe the concentration of the treatment in the algal toxicity test which may have caused minimal growth inhibition.

The EFSA 2021 peer review of the sheep fat risk assessment found toxicity data were not available for any group of nontarget organisms. A low acute and chronic risk to birds and mammals was presumed. Toxicity data to assess the chronic risk to aquatic organisms was deemed unnecessary.

Although these biopesticides may be considered low risk compared to conventional pesticides, relying on the original or previous registration data and review is problematic. Science is constantly evolving, and new scientific information can come to light that changes our understanding of potential effects from pesticides.

Thank you.

01/17/2025 — In Honoring Martin Luther King Jr. Day, Protect Those Disproportionately Harmed by Pesticides

Dr. Martin Luther King, Jr. reminded us that even the wealthiest of us are dependent on those less fortunate, whose work is not adequately rewarded in our capitalist economy—farmworkers, landscapers, workers in meat-packing and food processing plants, factory workers, hospital workers, sanitation workers—and those workers are disproportionately people of color. So, as we commemorate the legacy of Dr. King as a federal holiday on Monday, January 20, it is fitting to remind our legislators of their duty to protect the most exposed and most vulnerable members of society from the impacts of an economy unnecessarily dependent on toxic chemicals.

>> This Martin Luther King Jr. Day, tell Congress to protect our farmworkers and those at disproportionate risk from toxic chemicals.

Justice for all people converges with the protection of biodiversity, health, and climate. As Dr. King said in his 1967 Christmas sermon, “It really boils down to this: that all life is interrelated. We are all caught in an inescapable network of mutuality, tied into a single garment of destiny. Whatever affects one directly, affects all indirectly. We are made to live together because of the interrelated structure of reality.” 

If we are not protecting the most vulnerable in society, we ultimately adversely affect the entire society because we are intricately linked in the web of life. This is a day to recognize the importance and value of those who are disproportionately affected by toxic chemical production, transportation, use, and disposal (including those who live in fenceline communities near chemical plants or agricultural fields) redouble our focus on their protection, and adopt practices and policies that no longer support environmental racism. On this day, we recognize that we can all individually shift our personal and community practices to organic management and products, and, in so doing, eliminate the cradle-to-grave exposures that disproportionately affect people of color.

Dr. King's words in his 1967 sermon clearly focus on addressing injustices for disenfranchised people. Similarly, with biodiversity collapse looming, it has become exceedingly clear that the protection of ecosystems requires support for those organisms most vulnerable but essential to all life. And just as we need to recognize our dependence on vulnerable humans and protect them, we must similarly recognize and protect vulnerable members of all species integral to the web of life.

Environmental injustice looms large on the horizon. Workers integral to meeting societal needs—especially in agriculture and landscaping—face the threat of deportation. Pesticide regulation, which has failed even under friendly administrations to protect human health, enhance biodiversity, and prevent climate disasters—is in need of reform in order to protect those at greatest risk, and in doing so, protect us all.

We recognize the birthday of Dr. Martin Luther King, Jr. as a new administration takes office. We need to ask all leaders to follow Dr. King's leadership in recognizing the need to protect the most vulnerable among us. 

Here are some actions Congress can take: 

Ensure protection for farmworkers.

Protect all who are at disproportionate risk.  

  • Require EPA to begin meaningful dialogue with Native American 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.” 
     
  • Require that registration decisions take into account cradle-to-grave exposuresHarm done in the manufacture, transportation, and disposal—in addition to use—of pesticides must count as “unreasonable adverse effects.”  
     
  • Prohibit the registration of pesticides that threaten children, biodiversity, or the climate
     
  • Phase out toxic petrochemical pesticides and fertilizers by 2032. 

>> This Martin Luther King Jr. Day, tell Congress to protect our farmworkers and those at disproportionate risk from toxic chemicals. 

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

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing.

Letter to U.S. Representative and Senators:

Dr. Martin Luther King, Jr. reminded us that even the wealthiest of us are dependent on those less fortunate, whose work is not rewarded in our economic system—farmworkers, landscapers, workers in meat-packing and food processing plants, factory workers, hospital workers, sanitation workers —who are predominately people of color. So, on Martin Luther King Day, as we commemorate Dr. King, it is fitting to seek better protections for the most exposed and most vulnerable members of society from the impacts of our economy, which is unnecessarily dependent on toxic chemicals 

Justice for all people converges with the protection of biodiversity, health, and climate. As Dr. King said in his 1967 Christmas sermon, “[A]ll life is interrelated. We are all caught in an inescapable network of mutuality, tied into a single garment of destiny. Whatever affects one directly, affects all indirectly. We are made to live together because of the interrelated structure of reality.”  

Dr. King’s words in his 1967 sermon clearly focus on addressing injustices for disenfranchised people. Similarly, with biodiversity collapse looming, it has become exceedingly clear that the protection of ecosystems requires support for those organisms most vulnerable but essential to all life. And just as we need to recognize our dependence on vulnerable humans and protect them, we must similarly recognize and protect vulnerable members of all species integral to the web of life. 

Environmental injustice looms large on the horizon. Workers integral to meeting societal needs—especially in agriculture and landscaping—face the threat of deportation. Pesticide regulation, which has failed even under friendly administrations to protect human health, enhance biodiversity, and prevent climate disasters, is in need of reform in order to protect those at greatest risk—and in doing so, protect us all. 

As a new administration takes office, we need to ask all leaders to follow Dr. King’s leadership in recognizing the need to protect the most vulnerable among us.  

Here are some actions I would like to see Congress take: 

1. Ensure protection for farmworkers 

Farmworkers need more protections, not industry-friendly compromises, when alternatives are available. Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, to ensure sustenance for the nation and world. Yet, the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers. 

The U.S. must sign the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, which would set a moral standard to treat migrant workers like workers who are citizens. 

Prohibit the use of toxic fumigants that endanger farmworkers and their communities.  

2. Protect all who are at disproportionate risk.  

Require EPA to begin meaningful dialogue with Native American 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.” 

Require that registration decisions take into account cradle-to-grave exposures. Harm done in the manufacture, transportation, and disposal—in addition to use—of pesticides must count as “unreasonable adverse effects.”  

Prohibit the registration of pesticides that threaten children, biodiversity, or the climate. 

Please join me in seeking to phase out toxic petrochemical pesticides and fertilizers by 2032 and replace them with organic management practices that are both effective and cost competitive. 

Thank you. 

01/10/2025 — It’s Time for EPA to Protect the Ecosystem and Move Against the Weed Killer Atrazine

UPDATE—EPA is accepting comments on its proposal until April 5, 2025, through Regulations.gov 
Due to updates to the Regulations website, we are offering a click-and-submit form to the docket! 
***Due to the context, we are providing an extended analysis below for those who wish to delve deep into the issue. To skip below to the Action form, please click here or on the "Action links" (>>) included below!

We have advocated against the use of the weed killer atrazine, and now the U.S. Environmental Protection Agency (EPA) is officially taking comments on whether to issue new restrictions on the chemical's use. As we know, EPA received accolades for its August 7, 2024, decision to ban the weed killer Dacthal (or DCPA--dimethyl tetrachloroterephthalate), leaving many people asking, “Why Dacthal and not other very hazardous pesticides?” The weed killer atrazine (in the triazine chemical family) 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. 

In its current proposal, EPA is choosing to downplay atrazine's risk to ecosystems, allow more contamination with the herbicide, and apply a wishy-washy, ineffective enforcement mechanism. In reevaluating the risk to aquatic systems, EPA has chosen to exclude four of the six experiments that it previously judged to show an effect on aquatic plant communities, which allowed it to increase the allowed concentration of atrazine in surface water from 3.4 ug/L to 9.7 ug/L. If atrazine concentrations exceed that allowed concentration, they will trigger mitigation measures. 

Mitigation is to follow EPA's “herbicide mitigation strategy,” which provides a menu of options providing “flexibility” to pesticide applicators, with no incentive to adopt more ecologically-based approaches such as organic farming and land management

UPDATED—EPA is accepting comments on its proposal until April 5, 2025, through Regulations.gov.  

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

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 over 40 countries worldwideMany 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). 

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 (from homes to 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; 

  1. The immediacy of the threatened harm; 

  1. The probability that the threatened harm will occur; 

  1. The benefits to the public of the continued use of the pesticide; and 

  1. 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 the 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 a 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 pose significant threats to human health and are particularly concerning in the context of the range of chemicals one may be exposed to in today's world. As 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. 

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 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

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 Healthbanning 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 remaining serious worker and ecological risks after the 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 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.  

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

For more information on the dangers of atrazine and its chemical cousins, read Beyond Pesticides comments to EPA, and watch Tyrone Hayes, PhD 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. 

The target for this Action is the U.S. Environmental Protection Agency, via comments through Regulations.gov.

Thank you for your active participation! 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. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing. 

Suggested submission to Regulations.gov: 

In its updated atrazine mitigation proposal, EPA downplays the risk to ecosystems, allows more contamination, and applies a weak, ineffective enforcement mechanism. In reevaluating the risk to aquatic systems, EPA has excluded four of the six experiments that it previously judged to show an effect on aquatic plant communities, allowing it to increase the concentration of atrazine in surface water triggering mitigation from 3.4 ug/L to 9.7 ug/L.

Mitigation is to follow EPA’s “herbicide mitigation strategy,” providing “flexibility” to pesticide applicators through a menu of options, with no incentive to adopt organic farming and land management.

Atrazine fits the criteria used to ban Dacthal and should be banned immediately.

In banning 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. 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. Subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine.

Atrazine 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 has not protected to reasonable harm. Environmental and health harms continue despite label changes.

The public does not benefit from continued use of atrazine. There is no evidence that atrazine benefits farmers. Research in the International Journal of Occupational and Environmental Health, finds 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.

EPA must 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. Several atrazine uses exceed risk 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.

 

01/03/2025 — This New Year, It’s Time—Adopt Policy and Program for Organic Management of Parks and Public Spaces

There is no better time than the beginning of a new year to reflect on what we can do as individuals and collectively to have a meaningful effect on our health, the health of our families and communities, and the legacy of a sustainable world. What follows is a simple step you can take for your health and the health of our planet. 

With the publication of a piece by Harvest Public Media at the end of December, the reporter Héctor Alejandro Arzate captures the power of individuals and communities working together to adopt a rather simple change that is crosscutting in its effect on the health, biodiversity, and climate crises of our time—transitioning our parks and public spaces to organic practices. The article, “These Midwest cities are cutting pesticides from public parks with the help of a national nonprofit,” highlights the work of Jen Schroeder, a mother of two children in Kansas City, who wants, simply, her neighborhood park where her children play to be free of toxic chemical use. She saw a flier in her local Natural Grocers store about Beyond Pesticides' Parks for a Sustainable Future Program, reached out to her Kansas City Parks and Recreation Department, and now the city is moving ahead to transition two pilot sites to organic practices. It happened with a simple reaching out to the Parks Department! With the hands-on assistance of Beyond Pesticides, Parks Departments receive a plan and training from a horticulturalist and learn about organic practices that can be applied across all parks and public spaces. See how you can become a Parks advocate!

>> Ask your Mayor, in the new year, to adopt a policy and program for organic management of your community's parks and public spaces. [In the event that your local mayor is not in the system, we invite you to email this message to them personally!]

In protecting children using their community parks, the organic land management program is creating models for cost-effective programs that meet community expectations, while eliminating the use of petrochemical pesticides and fertilizers. When combined with the growth of certified organic agriculture, the conversion of land management to organic eliminates the petrochemicals associated with endocrine disruption (see a talk by Dr. Tracey Woodruff here) and rising rates of related illnesses, biodiversity decline, and an escalating climate crisis. As the climate crisis causes increasingly erratic weather, more frequent flooding, and widespread fires, organic soil management draws down atmospheric carbon, which reduces the threat of greenhouse gases that contribute to climate disasters. Also, see the effects of synthetic fertilizers

There could not be a more important time for us to all engage in this new year's organic journey whether we choose to emphasize organic choices in our diet, lawn and landscape care, or community involvement. Here is more on the reasons why: 

  1. Health and Safety: Organic foods and parks are free from harmful pesticides, fossil-fuel-based substances, and toxic chemicals, making them safer and healthier for all ages. Visit Beyond Pesticide's 40 Common Lawn and Landscape Chemicals page to learn more about the health impacts of pesticides in communities. See how you can manage your landscape without petrochemical pesticides and fertilizers. 

  2. Environmental Stewardship: Organic land management supports practices that protect pollinators, improve soil health, increase biodiversity, and reduce toxic runoff into water bodies. Learn more about how to protect pollinators in your community by reading BEE Protective

  3. Trust and Transparency: The USDA Certified Organic label ensures strict standards and regulations for organic products, providing trust and transparency for consumers worldwide. We provide oversight for parks that use organic land management. Visit Beyond Pesticide's literature called Save Our Organic to learn more about the power of the organic label and use our Keeping Organic Strong page to keep USDA accountable to the principles and values in the Organic Foods Production Act. 

  4. Just Communities: Supporting organic farming practices can benefit local communities and economies, as well as promote responsible animal welfare and fair labor conditions. Organic parks are the ethical choice to promote environmental justice. The Black Institute's Poison Parks report shines a spotlight on New York City's previous reliance on glyphosate-based herbicides and that people of color communities, including landscapers, bear the burden of this toxic chemical's impact. 

  5. Climate Resilience: Organic farming often exhibits better performance during droughts and challenging environmental conditions. Watering needs are very site-specific and the type of soil impacts drainage. Once established, a deep root system from organic land management requires less water and results in the drawn down of atmospheric carbon, contributing to efforts to reduce the adverse effects of carbon on climate. 

>> Ask your Mayor, in the new year, to adopt a policy and program for organic management of your community's parks and public spaces.[In the event that your local mayor is not in the system, we invite you to email this message to them personally!]

Letter to Mayor: 

I am writing to urge you to use your leadership in the new year to require as a matter of policy and practice the organic management of our community parks and public spaces. My concern about the management of public spaces—used by children and families, those with health vulnerabilities, pets, and wildlife—stems from the hazardous nature of the petrochemical pesticides and fertilizers commonly used. The adverse health and environmental effects are captured on two factsheets, 40 Commonly Used Lawn Pesticides (https://bp-dc.org/40commonpesticides). With this information, we urge you to advance a policy and management decision to stop the use of these hazardous chemicals and transition our parks to organic practices. 

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

Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects, 26 are possible and/or known carcinogens, 24 have the potential to disrupt the endocrine (hormonal) system, 29 are linked to reproductive effects and sexual dysfunction, 21 have been linked to birth defects, 24 are neurotoxic, 32 can cause kidney or liver damage, and 33 are sensitizers and/or irritants. Regarding adverse environmental effects, 21 are detected in groundwater, 24 have the ability to leach into drinking water sources, 39 are toxic to fish and other aquatic organisms vital to our ecosystem, 33 are toxic to bees, 18 are toxic to mammals, and 28 are toxic to birds. 

In adopting organic land management, our community can make an important contribution to solving the threat that petrochemical pesticides and fertilizers pose to biodiversity collapse and the climate crisis. The 2022 United Nations Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) warns that we must adopt policies and practices that reflect the value of Nature’s biodiversity, including pollinators, in supporting human life and activity. This starts with the management of soil and landscapes in our community.  

As the climate crisis causes increasingly erratic weather, more frequent flooding, and widespread fires, organic soil management draws down atmospheric carbon, which reduces the threat of greenhouse gases that contribute to climate disasters. Organic management of our parks enables our community to contribute to solving this existential crisis and elevates our role in climate action. 

Please take advantage of Beyond Pesticides’ offer to assist you and land managers of our community parks in the adoption of organic land management practices through its Parks for a Sustainable Future program. You can contact them at [email protected]. 

I look forward to your reply and working with you in the new year.