Action of the Week Archive

Although the influence of regulated corporations has historically silenced science that threatens profits – as shown by industry reaction to Rachel Carson’s Silent Spring – attacks on science in federal agencies have increased in the Trump administration. EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. The U.S. Department of Agriculture has discontinued collecting data on honeybees. The U.S. Fish and Wildlife Service refused to designate critical habitat for the endangered rusty patched bumblebee.

Tell your Congressional Representative to cosponsor H.R. 1709, the Scientific Integrity Act, and thank those who already have cosponsored.

H.R. 1709, the Scientific Integrity Act, was introduced by Rep. Paul Tonko of New York, in an effort to restore scientific integrity to government agency decision-making. The bill begins with the premise that “science and the scientific process should inform and guide public policy decisions on a wide range of issues, including improvement of public health, protection of the environment, and protection of national security.” It prohibits scientific misconduct, suppression of scientific findings, intimidation of researchers, and creation of barriers to communicating scientific or technical findings. It limits the actions an agency may take in the process of approving dissemination of scientific results and gives individual researchers the right to review public statements by agencies for accuracy.

Without reliance on science, agency policies are arbitrary and capricious – the standard of irresponsibility in government. There are currently 230 cosponsors of the Scientific Integrity Act. You will be automatically directed to the appropriate page thank those cosponsors or request others to cosponsor the bill.

Thank you Letter to Cosponsors

Although the influence of regulated corporations has historically silenced science that threatens profits – as shown by industry reaction to Rachel Carson’s Silent Spring – attacks on science in federal agencies have increased in the Trump administration. EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. The U.S. Department of Agriculture has discontinued collecting data on honeybees. The U.S. Fish and Wildlife Service refused to designate critical habitat for the endangered rusty patched bumblebee.

That is why I am writing to thank you for cosponsoring H.R. 1709, the Scientific Integrity Act, to restore scientific integrity to government agency decision-making. The bill prohibits scientific misconduct, suppression of scientific findings, intimidation of researchers, and creation of barriers to communicating scientific or technical findings. It limits the actions an agency may take in the process of approving dissemination of scientific results and gives individual researchers the right to review public statements by agencies for accuracy.

Without reliance on science, agency policies are arbitrary and capricious – the standard of irresponsibility in government.

Thank you for cosponsoring H.R. 1709.

Sincerely,

Letter to Representatives who have not yet cosponsored H.R. 1709:

Although the influence of regulated corporations has historically silenced science that threatens profits – as shown by industry reaction to Rachel Carson’s Silent Spring, attacks on science in federal agencies have increased in the Trump administration. For example, EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. The U.S. Department of Agriculture has discontinued collecting data on honeybees. The U.S. Fish and Wildlife Service refused to designate critical habitat for the endangered rusty patched bumblebee.

H.R. 1709, the Scientific Integrity Act, was introduced by Rep. Paul Tonko of New York, in an effort to restore scientific integrity to government agency decision-making. The bill begins with the premise that “science and the scientific process should inform and guide public policy decisions on a wide range of issues, including improvement of public health, protection of the environment, and protection of national security.” It prohibits scientific misconduct, suppression of scientific findings, intimidation of researchers, and creation of barriers to communicating scientific or technical findings. It limits the actions an agency may take in the process of approving dissemination of scientific results and gives individual researchers the right to review public statements by agencies for accuracy.

Without reliance on science, agency policies cannot fail to be arbitrary and capricious – the standard of irresponsibility in government. There are currently 230 cosponsors of the Scientific Integrity Act. I ask that you join them.

Please cosponsor H.R. 1709.

Sincerely,

The U.S. Environmental Protection Agency is proposing changes to the way farmworkers and bystanders are protected from toxic pesticide applications. Billed as “improvements” that will “reduce regulatory burdens for farmers,” the actions would instead significantly shrink Application Exclusion Zones (AEZs), buffer areas where individuals are not supposed to enter during a pesticide application, putting farmworkers and bystanders at risk.

Tell your Congressional Representative and Senators that EPA must protect farmworkers.

“Although the proposal is framed as a narrow revision, it would in fact eliminate, reduce, or weaken various AEZ provisions,” said Farmworker Justice attorney Iris Figueroa to Politico. “These changes threaten to increase exposure to toxic pesticide drift for farmworkers and their families.”

EPA’s proposal, announced in a press release featuring the heads of industry associations like the American Farm Bureau, would do the following:

• Make AEZs applicable only to a farm owners’ property. Under the current rules, pesticide handlers are required to keep individuals out of an area where pesticides are applied both on and off site.
• Exempt on-farm family members from all aspects of the AEZ. EPA says this will allow farmers and their family “to decide whether to stay in their homes or…on their property during certain pesticide applications, rather than compelling them to leave even when they feel safe remaining.” Feeling safe is not the same as being safe–one is based on emotions and the other on science.
• State that suspended pesticide applications may continue when an individual leaves an AEZ, and revise criteria determining when a pesticide application is subject to an AEZ. These changes backtrack safety requirements and would shrink the type of pesticide applications covered under this rule.

The agrichemical industry has lobbied against the AEZ and other farmworker protections since they were revised during the Obama administration. The Obama-era revision occurred after 25 years of inaction on farmworker rights and was worked out with both industry and farmworker advocates at the table. Early in Trump’s presidency, then EPA-head Scott Pruitt announced his intent to revisit several provisions that were recently put in place. This included the requirement that farmworkers be 18 to apply highly toxic pesticides, a clause which allows farmworkers have a “designated representative” obtain information about where and when pesticides were applied, and the AEZ. The EPA proposal has garnered support from Ranking Member of the House Committee on Agriculture Congressman Mike Conaway.

As recent as October 2018, and even after 28 Senators wrote EPA to oppose any changes, the agency had intended to revise each of these reforms. But it appears that in late 2018, an agreement was reached as part of a deal cut by lawmakers and the administration that permitted confirmation of Alexandra Dunn to the EPA Office of Chemical Safety and Pollution Prevention in exchange for EPA concessions that would improve pesticide safety measures. Beyond Pesticides wrote, “While advocates are generally pleased with the outcome of the apparent deal, the irony that deals needed to be made for an agency with protection in its name to do its job is not lost.”

As noted at the time of the deal, AEZs were not included in this agreement. Last week’s announcement shows EPA delivered for industry interests within the year.

Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s and is completely unacceptable for any industry today. It is critical that government agencies work towards enforcing laws agreed to by consensus between industry and advocates, rather than work with industry in its attempts to renege on these deals.

Tell your Congressional Representative and Senators that EPA must protect farmworkers.

Letter:

I am writing to ask you to tell the EPA that it must protect farmworkers, and that its recent proposal to rollback protections, under the guise of “reducing regulatory burdens for farmers” is unacceptable.

EPA’s actions would significantly shrink Application Exclusion Zones (AEZs), buffer areas where individuals are not supposed to enter during a pesticide application, putting farmworkers at risk. “Although the proposal is framed as a narrow revision, it would in fact eliminate, reduce, or weaken various AEZ provisions,” said Farmworker Justice attorney Iris Figueroa. “These changes threaten to increase exposure to toxic pesticide drift for farmworkers and their families.”

Currently, the average life expectancy for a farmworker is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s and is completely unacceptable for any industry today. It is critical that government agencies work towards enforcing laws agreed to by consensus between industry and advocates, rather than work with industry in its attempts to renege on these deals.

Please tell EPA to revoke the proposal to weaken the AEZ requirements.

Sincerely,

In recognition of the harm that climate change is causing to communities, the U.S. House of Representatives formed the Select Committee on the Climate Crisis to “investigate, study, make findings, and develop recommendations on policies, strategies, and innovations to achieve substantial and permanent reductions in pollution and other activities that contribute to the climate crisis, which will honor our responsibility to be good stewards of the planet for future generations.”

>> Tell the U.S. House Select Committee on the Climate Crisis to promote organic agriculture and land care.

Regenerative organic agriculture reduces emissions of carbon dioxide and nitrous oxide. In nonorganic, chemical-intensive agriculture, greenhouse gas emissions result from the use of nitrogen fertilizer, synthetic herbicides and insecticides, fossil fuel consumption associated with farm equipment, and the transportation of materials and products to and from the farm. The manufacture of synthetic fertilizers and pesticides is a major source of energy use in chemical-intensive agriculture--the manufacture and use of synthetic nitrogen fertilizers alone are responsible for as much as 10 percent of direct global agricultural emissions. This is important because pound-for-pound, nitrous oxide is 300 times as potent as carbon dioxide in warming the planet.

Besides reducing energy use, organic agriculture helps combat climate change by sequestering carbon in the soil. Organic agriculture also produces farms resilient to climate change because high soil organic matter content and mulching help to prevent nutrient and water loss. In addition, organic agriculture increases biodiversity, which is needed to meet the challenges of new insects, diseases, and weeds.

The same advantages accrue to other land management systems, such as city parks and playgrounds.

The Committee is seeking input in the form of responses to 13 questions by November 22. Among them are the following:

Cross-Cutting Policies Innovation (5a.) Where should Congress focus an innovation agenda for climate solutions? Please identify specific areas for federal investment and, where possible, recommend the scale of investment needed to achieve results in research, development and deployment.

Agriculture (6.) What policies should Congress adopt to reduce carbon pollution and other greenhouse gas emissions and maximize carbon storage in agriculture? (7.) What policies should Congress adopt to help farmers, ranchers, and natural resource managers adapt to the impacts of climate change?

Oceans, Forestry and Public Lands (8.) How should Congress update the laws governing management of federal lands, forests, and oceans to accelerate climate adaptation, reduce greenhouse gas emissions and maximize carbon storage? 

Non-CO2 Greenhouse Gases (9.) What policies should Congress adopt to reduce emissions of non-CO2 greenhouse gases, including methane, nitrous oxide, and fluorinated gases?

Carbon Removal (10.) How can Congress accelerate development and deployment of carbon removal technology to help achieve negative emissions? 

Resilience and Adaptation (11.) What policies should Congress adopt to help communities become more resilient in response to climate change?

In order to promote organic management systems, the following actions are needed:

• Greater investment in research into organic production systems. One area that is particularly in need of research is organic no-till. Specifically, increase funding for the Organic Agriculture Research and Extension (OREI) initiative to $50 million annually. We need to maintain, expand, and continually improve NRCS working lands programs, including the Environmental Quality Incentives Program and Conservation Stewardship Program.
• Greater investment into the development of seeds and breeds that are well-adapted to local conditions.
• Expanding domestic organic production. Domestic demand for organic products exceeds domestic production. Organic producers face unique challenges and we need a comprehensive approach to increase production.
• Support for farmers making the transition to organic production. Support for the Organic Transitions Program is extremely important. We need to keep organic farmers on the land to ensure that we maintain soil carbon sequestration capacity. Maintain USDA programs, such as the Agriculture Conservation Easement Program, to protect farmland from development.
•  Increased pasture-based livestock systems in agriculture research and marketing programs. Especially under intensive rotation and management, they can help increase carbon sequestration in the soil.
• Help for on-farm and community renewable energy systems. Locally-based, farm- and community-scale renewable energy systems not only reduce carbon emissions, but create a more resilient energy infrastructure.
• Removal of barriers to organic land management by local governments. It is essential to eliminate laws that preempt localities from regulating the use of pesticides.
• Protecting the integrity of organic products, so that the market can work to incentivize organic production. This includes ensuring that USDA does not stand in the way of essential reforms supported by the organic community.

These same actions address our biodiversity crisis that is evidenced by crashes in insect and bird populations.

>> Tell the U.S. House Select Committee on the Climate Crisis to promote organic agriculture and land care.

Suggested Letter:

I wish to address several of the issues raised by the Committee for public comment, particularly questions 5a, 6, 7, 8, 9, 10, and 11. The following actions are needed to reduce greenhouse gas emissions, protect biodiversity, and increase resilience in the face of climate change.

• Greater investment in research into organic production systems. One area that is particularly in need of research is organic no-till. Specifically, increase funding for the Organic Agriculture Research and Extension (OREI) initiative to $50 million annually. We need to maintain, expand, and continually improve NRCS working lands programs, including the Environmental Quality Incentives Program and Conservation Stewardship Program.

• Greater investment into the development of seeds and breeds that are well-adapted to local conditions.

• Expanding domestic organic production. Domestic demand for organic products exceeds domestic production. Organic producers face unique challenges and we need a comprehensive approach to increase production.

• Support for farmers making the transition to organic production. Support for the Organic Transitions Program is extremely important. We need to keep organic farmers on the land to ensure that we maintain soil carbon sequestration capacity. Maintain USDA programs, such as the Agriculture Conservation Easement Program, to protect farmland from development.

• Increased pasture-based livestock systems in agriculture research and marketing programs. Especially under intensive rotation and management, they can help increase carbon sequestration in the soil.

• Help for on-farm and community renewable energy systems. Locally-based, farm- and community-scale renewable energy systems not only reduce carbon emissions, but create a more resilient energy infrastructure.

• Removal of barriers to organic land management by local governments. It is essential to eliminate laws that preempt localities from regulating the use of pesticides.

• Protecting the integrity of organic products, so that the market can work to incentivize organic production. This includes ensuring that USDA does not stand in the way of essential reforms supported by the organic community.

Thank you for considering these suggestions.

Beyond Pesticides is proud to support the work of Herbicide Free Campus, a national campaign stemming from student awareness and activism at the University of California. As a major university that has national influence, a strong policy at the University of California Berkeley will have strong influence on other institutions and the generations of students passing through its system.

Already, Beyond Pesticides supporters from California have sent over 400 messages to UC President Janet Napolitano urging this positive change. Now, we're asking our national network to lift up the voices of students who are fighting for a toxic-free future. 

The spraying of toxic herbicides for weed control on campuses exposes students, workers and the general public to chemicals linked to health problems such as cancer and reproductive issues.

>> Support student activists by putting pressure on UC President Napolitano

Any day now, the University of California system will decide whether or not to continue using glyphosate and other toxic herbicides — including Roundup — on their campuses.

The University of California previously announced a temporary ban on the use of cancer-causing glyphosate, the main ingredient in Roundup, but this ban doesn't stop the UC system from using other dangerous herbicides.

Student activists are asking UC to commit to transitioning to all organic land care maintenance on all University of California campuses by 2025. This could be an opportunity for the University of California, which prides itself on its commitment to sustainability, to join other universities such as Harvard, the University of Colorado at Boulder, Yale, University of Pennsylvania, and others as a national leader in the field.  

>> Tell University of California President Napolitano to issue a full, permanent ban on glyphosate and Proposition 65 herbicides and make the UC system organic!

Letter to the president of UC:

First of all, I would like to thank you for temporarily suspending the use of glyphosate-based herbicides on the University of California campuses and for establishing an Herbicide task force in order to consider long-term approaches to land management.

In anticipation of your Nov. 1 decision I am writing to ask you - for the sake of future generations - to permanently ban toxic herbicides and commit to transitioning to all organic land care maintenance on all University of California campuses by 2025. Organic alternatives exist. This could be an opportunity for the University of California, which prides itself on its commitment to sustainability, to join other universities such as Harvard, the University of Colorado at Boulder, Yale, University of Pennsylvania, and others as a national leader in the field.  

I understand that you will be stepping down after August 2020. This is an opportunity to leave a legacy in the field of sustainability and stand up for public health and the environment. We can’t wait to celebrate with you.

Thank you,

USDA’s National Organic Standards Board (NOSB) should remove nonorganic celery powder from the National List of Allowed and Prohibited Substances for use in organic food production.

It has been long-established that nitrates and nitrites, used to prevent bacterial growth in processed meats, react with protein to create nitrosamines, which are widely considered to be possible carcinogens. The World Health Organization considers processed meat “a known carcinogen.”

Tell NOSB to remove carcinogenic nonorganic celery powder from organic processed meat.

For too long the meat industry, including organic processors, have engaged in a form of subterfuge by being able, and in fact required, to label meat preserved with celery powder as “no nitrates or no nitrites added” or “uncured.”

The use of conventional celery powder, with amped up applications of synthetic nitrogen fertilizer, creates the same functional and biological impacts as synthetic nitrates/nitrates as a meat preservative.

The federal laws governing organics are clear. To legally use a synthetic compound, or a natural or agricultural material that is not certified organic, in the production of certified organic product, it must appear on the list of approved substances. And to do so, proposed materials must not damage the environment or human health, must be essential to the production of a given food or crop, and must be compatible with organic philosophy.

There is little doubt that the continuance of celery powder on the National List violates the trust of consumers who seek out organic food as a safe haven from what is conventionally offered in the supermarket and all too often contains dangerous and risky ingredients.

Tell NOSB to remove carcinogenic nonorganic celery powder from organic processed meat.

Letter:

Dear NOSB Chair Behar,

We, the undersigned, respectfully request that USDA's National Organic Standards Board (NOSB) recommend removal of nonorganic celery powder from the National List of Allowed and Prohibited Substances for use in organic food production.

It has been long-established that nitrates and nitrites, used to prevent bacterial growth in processed meats, react with protein to create nitrosamines, which are widely considered to be possible carcinogens. The World Health Organization considers processed meat “a known carcinogen.”

For too long the meat industry, including organic processors, have engaged in a form of subterfuge by being able, and in fact required, to label meat preserved with celery powder as “no nitrates or no nitrites added” or “uncured.”

The use of conventional celery powder, with amped up applications of synthetic nitrogen fertilizer, creates the same functional and biological impacts as synthetic nitrates/nitrates as a meat preservative.

The federal laws governing organics are clear. To legally use a synthetic compound, or a natural or agricultural material that is not certified organic, in the production of certified organic product, it must appear on the list of approved substances. And to do so, proposed materials must not damage the environment or human health, must be essential to the production of a given food or crop, and must be compatible with organic philosophy.

There is little doubt that the continuance of celery powder on the National List, violates the trust of consumers who seek out organic food as a safe haven from what is conventionally offered in the supermarket and all too often contains dangerous and risky ingredients.

We respectfully ask members of the NOSB to prohibit the use of nonorganic celery powder in the preparation of certified organic meat products.

EPA is requesting comment on its proposal to require data that will help it determine synergistic effects of some pesticides. EPA has received on a pressure on a number of fronts, including a report by the Center for Biological Diversity, a report by its own Inspector General, a letter from 35 Congressional Representatives, and research pointing to the unavoidability of synergistic effects—the chemical combinations that cause greater effects when mixed together than the sum of the individual chemical effects. Despite all of the evidence that synergism is the rule rather than the exception, EPA’s consideration focuses on a narrow range of cases in which pesticide product patents make claims of synergy.

Tell EPA to always investigate synergy and to determine need for pesticides.

One such product is Dow’s Enlist Duo, which combines glyphosate and 2,4-D in an attempt to overcome weed resistance. The focus on products and tank mixes where synergism is a selling point brings to light the fact that as a rule, EPA does not request efficacy data in registering pesticides not intended to protect public health. Thus, although required by law to weigh pesticide risks and benefits, EPA rarely has data to make that determination.

Comment at Regulations.gov. Make the following points:

Pesticides occur in mixtures in air, soil, water, and agricultural products. The impacts of mixtures must be considered in all registration decisions.

• The decision that a pesticide does not cause unreasonable adverse effects considering all the risks and benefits requires EPA to determine whether a pesticide is effective. Therefore, efficacy data should be required for all pesticides.
• Synergistic effects of pesticides may involve interactions with pharmaceutical chemicals and naturally-occurring processes in humans and other organisms.
• Synergistic effects may be mediated in the environment. For example, an herbicide may destroy habitat for an animal that is also poisoned by an insecticide.
• EPA must investigate possible synergistic effects of all pesticides.

Written comments may be submitted through Regulations.gov until 11:59 pm ET October 24, 2019. 

Not sure how to use our suggested language to comment? Follow these simple steps:

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Tell Your Member of Congress to Sign On the PAW & FIN Conservation Act!

Your voice is making a difference! Last month, thousands of individuals took action through Beyond Pesticides and other environmental groups to express concern to their federal lawmakers about the Trump Administration's assault on the Endangered Species Act (ESA). In response, Representatives Grijalva, Beyer, and Dingell in the House, and Senator Udall in the Senate have introduced the PAW and FIN Conservation Act of 2019. This law will roll back Interior Department regulations that would weaken this landmark law protecting species from extinction. 

>>Tell your member of Congress to co-sponsor the PAW and FIN Conservation Act of 2019!

The PAW and FIN Act reverses rules which will: (i) weaken the consultation process designed to prevent harm to endangered animals and their habitats from federal agency activities; (ii) curtail the designation of critical habitat and weakens the listing process for imperiled species; and (iii) eliminate all protections for wildlife newly designated as “threatened” under the Act.

Biodiversity is under threat in the US and throughout the world. Pollinator declines are well known, and now scientists are indicating we are in the midst of an insect apocalypse.  Declines at the bottom of the food chain are even more concerning given reports of “biological annihilation” and a 6th mass extinction among mammals and other vertebrate species. 

Every species very species is like a book in the library of life, and losing a species is like burning that book. It means we will forever miss out, and never truly understand how its story connects with the chronicles of life on Earth. Even obscure or uncharismatic species may hold the key to curing diseases and other medical breakthroughs.  

>> Tell your federal lawmakers to join the fight to protect the Endangered Species Act!

The ESA has helped prevent the extinction of 291 species since it was first passed in 1973; a 99% success rate. It's critically important that we take action today to keep this effective legislation working.  Please consider following up with a phone call urging your elected official to cosponsor the PAW and FIN Conservation Act.

Letter to Congress

Please help stop the Interior Department’s attacks on the endangered species act by cosponsoring the PAW and FIN Conservation Act of 2019. This legislation, introduced by Representatives Grijalva, Beyer, and Dingell in the House, and Senator Udall in the Senate, will undo regulations intended to gut the letter, spirit, and intent of the Endangered Species Act (ESA).

The new rules announced by the administration this week: (i) weaken the consultation process designed to prevent harm to endangered animals and their habitats from federal agency activities; (ii) curtail the designation of critical habitat and weakens the listing process for imperiled species; and (iii) eliminate all protections for wildlife newly designated as “threatened” under the Act.

Biodiversity is under threat in the US and throughout the world. Pollinator declines are well known, and now scientists are indicating we are in the midst of an insect apocalypse.  Declines at the bottom of the food chain are even more concerning given reports of “biological annihilation” and a 6th mass extinction among mammals and other vertebrate species.

In the face of these declines, it is critical that we protect those already at heightened risk. Every species is like a book in the library of life, and losing a species is like burning that book. It means we will forever miss out, and never truly understand how its story connects with the chronicles of life on Earth. Even obscure or uncharismatic species may hold the key to curing diseases and other medical breakthroughs.

The ESA has helped prevent the extinction of 291 species since it was first passed in 1973; a 99% success rate. It’s critically important that we take action today to keep this effective legislation working. Please become a cosponsor of the PAW and FIN Conservation Act.

Thank you.

The Fall 2019 National Organic Standards Board (NOSB) meeting dates have been announced and public comments are due by October 3, 2019. Your comments and participation are critical to the integrity of the organic label. Written comments may be submitted through Regulations.gov until 11:59 pm ET October 3, 2010. Reservations for in-person and webinar comments close at the same time.

The proposals of the NOSB, as a part of its ongoing review of practices and materials, are published for public comment.  Beyond Pesticides/OrganicEye is providing the public with a listing and analysis of the issues under consideration by the Board when it meets in Pittsburgh, PA on October 23 – 25, 2019. You can view USDA’s announcement of the NOSB’s meeting and proposals here.

Issues before the NOSB include materials allowed in organic production as well as some policy issues. Materials are either being considered for initial use in organics or the subject of a five-year Sunset Review. To be allowed, materials must have evidence demonstrating that they meet Organic Foods Production Act (OFPA) requirements of essentiality, no adverse effects on humans and the environment, and compatibility with organic practices.

Major issues before the NOSB at the Fall 2019 meeting include:

Take nitrates out of organic meat!
The Organic Foods Production Act (OFPA) prohibits the addition of nitrates to organic food because of the known health effects, but producers of organic processed meat products, along with producers of nonorganic “nitrate free” meats, have found a way around that prohibition –celery powder. The high levels of nitrate fertilizer allowed in nonorganic production concentrate in some vegetables, including celery, but organically grown celery does not contain high enough levels of nitrate to be used in curing meat. Celery powder has been listed as an allowed nonorganic agricultural ingredient since 2007.

Nitrates are prohibited in organic food because of their impacts on human health, which include methemoglobinemia, hypotension, risk of pregnancy complications, a number of reproductive effects, and cancer. In addition, the Beyond Pesticides Eating with a Conscience database identifies impacts of pesticides used in producing nonorganic celery, including farmworker poisonings, contamination of water, wildlife poisoning, and pollinator impacts. The NOSB must deny the relisting of celery powder.

Keep genetic engineering out of organic! 
The NOSB continually updates its assessment of which methods meet the criteria for “excluded methods” in organic production—that is, genetic engineering. At this meeting, the Materials Subcommittee proposes to add induced mutagenesis developed via use of in vitro nucleic acid techniques to the list of excluded methods and embryo transfer, or embryo rescue, in livestock, without use of hormones in recipient animals, is proposed to be listed as “not excluded.” We support these recommendations, except that there should be no use of hormones in either donor or recipient.

The U.S. Department of Agriculture (USDA) appears to have forgotten the lesson learned 20 years ago when it was forced to ban genetic engineering (GE) in organic regulations. At a July 17 hearing called by the U.S. House Agriculture Subcommittee on Biotechnology, Horticulture, and Research on “Assessing the Effectiveness of the National Organic Program,” Greg Ibach, the USDA’s Under Secretary for Marketing and Regulatory Programs, stated, “There is the opportunity to open the discussion to consider whether it is appropriate for some of these new technologies, including gene editing, to be eligible to be used to enhance organic production.” In view of this statement, we believe it is important to stress that gene editing, like other forms of genetic engineering, is unacceptable in organic production.

Stop supporting organic CAFOs!
The addition of synthetic methionine to organic poultry rations has a long and controversial history –not because of direct health effects on organic consumers, but because it facilitates industrial-style production of poultry.

Poultry production in concentrated animal feeding operations (CAFOs) needs synthetic methionine because of the lack of outdoor access and the choice of fast-growing breeds.
The “need” for synthetic methionine is a result of choices regarding breeds, stocking rates (both density and group size), and outdoor access. Increasingly, consumers are turning to eggs and meat produced in pastured poultry systems, which require fewer synthetic inputs. There have also been advances in the use of insects –specifically black soldier fly larvae—as a source of natural methionine.

The European Union does not allow the use of synthetic methionine in organic poultry, but does require more space per bird, fewer birds per house, and more access to the outdoors. Significantly, the EU also requires that poultry be of slow-growing breeds or be slaughtered at an older age. All these factors contribute to the welfare of poultry.

Research shows that methionine acts as a growth promoter above and beyond its role as a protein building block. Manipulating methionine in the diet through additions of synthetic methionine is effectively using a synthetic growth promoter and is comparable to the use of rBGH to enhance milk production.

Sunset gives the NOSB the opportunity to reconsider past decisions and reinstitute a process of continuous improvement. The NOSB should delist synthetic methionine or add an expiration date to force serious reconsideration.

Written comments may be submitted through Regulations.gov until 11:59 pm ET October 3, 2019.

Not sure how to use our suggested language to comment? Follow these simple steps:

1. Select the text in our comments (place your cursor before the first word in the text, then press and hold down the left mouse button and, without releasing the button, move the cursor to the end of the comments).
2. Copy the selected text by selecting the Ctrl and C keys simultaneously.
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5. Personalize your comments before entering your contact information and selecting “Continue”.

Please go to Beyond Pesticides’ Keeping Organic Strong (KOS) webpage to learn more about these and other substantive issues, and to provide a unique public comment to the NOSB. We will continue to update the KOS page in advance of the public comment deadline on October 3.

Thank you for helping to protect and uphold organic integrity!

USDA’s proposed new rules on genetically engineered (GE) crops exempt almost all GE crops from regulation and allow the company that makes them to decide whether they are safe. The rules proposed by USDA’s Animal and Plant Health Inspection Service (APHIS) benefit companies like Monsanto/Bayer and Dow, but fail to protect farmers, consumers, and the environment. Please tell APHIS to abandon its proposal and support a regulatory system that is consistent with modern science.

>> Tell USDA not to allow companies to approve their own GE crops.

The rules would govern USDA’s role in the outdated and fatally flawed “Coordinated Framework for the Regulation of Biotechnology.” The Framework fails to account for the unique risks of genetic engineering, using existing laws like the Plant Protection Act to address issues for which they were not designed. This proposal weakens the APHIS regulations even more.

All genetically engineered (GE) organisms—plants, animals, or microorganisms—should be subjected to systematic assessments of human and environmental effects and indirect economic effects (such as contamination of organic or non-GE crops leading to rejection in foreign markets, spread of resistant pests, etc.) before being allowed on the market. These assessments must be made available to the public for comment. All products from GE organisms in the marketplace should be labeled as such to allow consumer choice and to permit tracking of unintended health effects. Companies that develop GE organisms should be required to disclose any GE trait, marker genes, or other genetic constructs that might be present in a commercial GE seed product, including traits and genes for obsolete, no longer marketed traits. In addition, the definition of genetic engineering should be broad enough to include all the newer genetic engineering techniques, such as RNAi or the new gene-editing technologies (such as CRISPR-cas9, TALEN, ZNF, and meganucleases).

In particular, APHIS regulations should:

• Base the regulation of GE organisms on the unique hazards they present;
• Include “synthetic biology” in the definition of regulated genetic engineering;
• Prohibit developers from exempting themselves from regulation;
• Regulate PMPIs—plant-made pharmaceutical and industrial chemicals;
• Ensure that PIPs—plant incorporated protectants—are regulated at all scales;
• Address hazards other than “plant pest” risks, including: The unwelcome presence of GE genes in neighboring fields of organic or identity-preserved crops, the creation of new compounds in a plant, formed in the plant’s detoxification of herbicides, the movement of genes for manufacture of industrial or pharmaceutical chemicals into crop plants, the creation of “superweeds” (plant pests) through selection for resistance to herbicides continually used on GE crops, the overuse of herbicides in cropping systems dependent on the use of herbicides sprayed over herbicide-tolerant crops, destruction of habitat adjacent to farm fields by overuse of nonselective herbicides sprayed over herbicide-tolerant crops, selection for resistance in insects targeted by PIPs, reduction in populations of insects due to effects of PIPs and destruction of habitat adjacent to fields sprayed by nonselective herbicides over herbicide-tolerant crops, and health effects suffered by those exposed to excessive use of herbicides.

Clicking on the link below will sign your name to our petition, which we will send to APHIS. To be even more effective, submit your own comments through the Regulations.gov website. Feel free to copy from the language in the petition and/or that in the Beyond Pesticides comments[TS1] .

>> Tell USDA not to allow companies to approve their own GE crops.

Petition:

USDA Docket APHIS-2018-0034-0037 

The “Coordinated Framework for the Regulation of Biotechnology” fails to account for the unique risks of genetic engineering, using existing laws like the Plant Protection Act to address issues for which they were not designed. This proposal weakens the APHIS regulations even more.

All genetically engineered (GE) organisms—plants, animals, or microorganisms—should be subjected to systematic assessments of human and environmental effects and indirect economic effects (such as contamination of organic or non-GE crops leading to rejection in foreign markets, spread of resistant pests, etc.) before being allowed on the market. These assessments must be made available to the public for comment. All products from GE organisms in the marketplace must be labeled as such to allow consumer choice and to permit tracking of unintended health effects. Companies that develop GE organisms should be required to disclose any GE trait, marker genes, or other genetic constructs that might be present in a commercial GE seed product, including traits and genes for obsolete, no longer marketed traits. In addition, the definition of genetic engineering should be broad enough to include all the newer genetic engineering techniques such as RNAi or the new gene-editing technologies (such as CRISPR-cas9, TALEN, ZNF, and meganucleases).

In particular, APHIS regulations should:

• Base the regulation of GE organisms on the unique hazards they present;
• Include “synthetic biology” in the definition of regulated genetic engineering;
• Prohibit developers from exempting themselves from regulation;
• Regulate PMPIs—plant-made pharmaceutical and industrial chemicals;
• Ensure that PIPs –plant incorporated protectants—are regulated at all scales;
• Address hazards other than “plant pest” risks, including: The unwelcome presence of GE genes in neighboring fields of organic or identity-preserved crops, the creation of new compounds in a plant, formed in the plant’s detoxification of herbicides, the movement of genes for manufacture of industrial or pharmaceutical chemicals into crop plants, the creation of “superweeds” (plant pests) through selection for resistance to herbicides continually used on GE crops, the overuse of herbicides in cropping systems dependent on the use of herbicides sprayed over herbicide-tolerant crops, destruction of habitat adjacent to farm fields by overuse of nonselective herbicides sprayed over herbicide-tolerant crops, selection for resistance in insects targeted by PIPs, reduction in populations of insects due to effects of PIPs and destruction of habitat adjacent to fields sprayed by nonselective herbicides over herbicide-tolerant crops, and health effects suffered by those exposed to excessive use of herbicides.

It Is Time to Stop the Attack on Organic and Protect the Family Farmers Who Safeguard the Earth and Our Health

Listening to and talking with dairy farmers at the National Organic Standards Board meeting in Seattle last week, it is clear that organic consumers and farmers everywhere need to rise up to protect the standards of organic. This is the only way we can ensure a livable future—clean air, water, air, and a reversal of the climate crisis and the insect apocalypse. While there are numerous problems with the current administration's attack on organic across the board—and we are focused on the range of problems, dairy is a good place where we must join together before more organic family farmers literally go out of business. Organic dairy is the first place families look to protect their children.

Tell USDA and your members of Congress to protect organic family farmers who safeguard the environment and animal welfare.

As a result of abuses in government management of organic, we are seeing an attack on organic that can be corrected with the adoption of proposed rules that have been waiting to be adopted—the Origin of Livestock and the Access to Pasture rules. Without these rules, former Wisconsin dairy farmer, Jim Goodman, wrote in the Washington Post last December:

When six dairy farms in Texas feed their thousands of cows a diet of organic grain and stored forage, with no discernible access to a blade of grass, they end up producing more milk than all 453 organic dairy farms in Wisconsin combined. Then they ship it north, undercutting our price. We can't make ends meet and are forced out of the business. We played by the rules, but we no longer have a level playing field.

The Real Organic Project has explained the situation as follows:

The crux of the problem with the current rule for origin of dairy livestock is that there exists a two-track system for conversion of conventional dairy animals to organic. One track is that a whole herd can be converted to organic over a 12-month period, but thereafter no animals can be transitioned from conventional to organic on that farm. The other track is that for herds that did not use the one-time conversion, producers can continuously transition dairy animals into organic over time, using a 12-month conversion period for each animal transitioned.

A further complication is that some NOP accredited certifying organizations allow farms to continuously transition dairy cows from conventional to organic and other certifying organizations do not allow that.

Numerous public comments over the years of rulemaking have pointed out that this two-track system creates an uneven playing field for organic dairy producers. The National Organic Program proposed rule of April 28, 2015 would have fixed that problem by removing the option for an open-ended conversion of conventionally raised dairy animals to organic, as called for by an overwhelming majority of public comments. USDA has never finalized that proposed rule on the origin of livestock, putting family farmers in jeopardy. Furthermore, the Western Organic Dairy Producers Association has called for the elimination of the one-time transition of dairy herds from conventional to organic, maintaining that there are now enough organic dairy animals in the organic market to grow the organic dairy industry. 

According to the Organic Farmers Association, consistent enforcement of the access to pasture rule, including identification of high risk dairy operations such as those with more than 1000 milking and dry cows, is needed to meet USDA's Farm Bill and Legislative Principles priority to “Protect the integrity of the USDA organic certified seal and deliver efficient, effective oversight of organic production practices to ensure organic products meet consistent standards for all producers, domestic and foreign.” 

Tell USDA and your members of Congress to protect organic family farmers who safeguard the environment and animal welfare.

Help stop another attack on local authority in Maine – a bellwether state that has upheld local pesticide restrictions and leads the nation. Maine has led the nation in supporting the local democratic process as communities across the state have adopted pesticide use standards on public and private property that are more restrictive than state laws.

This will be the third attack on local authority in recent years – each time beaten back with public opposition. This time preemption language has been introduced as a clause in the innocuous sounding bill LD 1518, An Act to Establish a Fund for Portions of the Operations and Outreach Activities of the University of Maine Cooperative Extension Diagnostic and Research Laboratory and To Increase Statewide Enforcement of Pesticide Use. The language was introduced by Rep. Stephen Stanley (D), who ran unopposed in the 2018 Democratic primary.

The bill's language establishes barriers to local decision making, giving sole authority to the state to determine the acceptability of local pesticide restrictions.  As drafted, the bill would force municipalities to submit a request to ban a substance to a statewide board, which would make the decision as to whether the community could block the chemicals.

§1471-CC. Elimination of use of pesticide in political subdivision
A political subdivision of the State that wants to eliminate use in the political subdivision of a pesticide registered by the United States Environmental Protection Agency shall submit a request to eliminate use of the pesticide to the board. The board shall determine whether the pesticide should be further regulated based upon the board's expertise in toxicology and available scientific information relating to the adverse environmental, health and other effects of the pesticide under Title 7, section 610, 26 subsection 1. The board's review must include participation of the officers of the political subdivision and board staff and may include experts and other interested parties as the board determines appropriate.

The language in the bill represents a dramatic change in the state of Maine. Local authority allows communities the authority to represent the concerns of local residents, consider the science and need for pesticides, and affirm the importance of local jurisdictions considering local environmental conditions. A recent study, Anti-community state pesticide preemption laws prevent local governments from protecting people from harm, finds that state pesticide preemption laws “compromise public health and economic well-being” by preventing localities from enacting pesticide use restrictions on private property that are more restrictive than their state's regulations. In the words of the authors, “By eliminating the ability of local governments to enact ordinances to safeguard inhabitants from health risks posed by pesticides, state preemption laws denigrate public health protections.” The study, published in the International Journal of Agricultural Sustainability, reviews scientific and historical evidence of the failure of state and federal pesticide laws to protect localities from pesticide poisoning, and highlights the inability of localities to compensate for that failure under present laws. Communities seeking to protect their residents typically issue community-wide restrictions to ensure protection of shared community resources, including air, land, and waterways, from pesticide drift, runoff, and other nontarget effects —as is the case with other community decisions on recycling, smoking, and zoning. The study's authors document how industry influence led to the adoption of state laws that undermine the ability of localities to enact protective pesticide standards they determine are necessary to protect public health and the environment.

Maine Residents: Use this link to message Governor Janet T. Mills and the Maine Committee on Agriculture, Conservation, and Forestry.

Non-residents: Tell the Maine Committee on Agriculture, Conservation, and Forestry that you care about this attack on public health and the environment.

It is time for all local and state governments and school districts to stop the use of glyphosate/Roundup. The last month has seen a level of activity that supports immediate action. A second jury came in with the verdict that the herbicide caused plaintiffs’ non-Hodgkin’s lymphoma (NHL) —this time handing the manufacturer, Monsanto/Bayer, a bill for $80 million ($5 million in compensatory damages and $75 million in punitive damages).

Tell your Governor to act now to stop the use of glyphosate/Roundup.

Insurance companies are now backing away from Roundup. Harrell’s is a company that sells chemical pesticides, synthetic fertilizers, and “adjuvants and colorants,” among other products, primarily to golf courses, and to the horticulture-nursery, turf, and landscape sectors. The company announced on March 11 that it stopped selling products containing glyphosate as of March 1, 2019 because neither its current insurance company nor others the company consulted would underwrite coverage for the company for any glyphosate-related claims.

Harrell’s CEO stated: “During our annual insurance renewal last month, we were surprised to learn that our insurance company was no longer willing to provide coverage for claims related to glyphosate due to the recent high-profile lawsuit and the many thousands of lawsuits since. We sought coverage from other companies but could not buy adequate coverage for the risk we would be incurring. So we had no choice other than to notify our Harrell’s Team and customers that we would no longer offer products containing glyphosate.”

The announcement stands in contrast to a Fox Business story shortly after the verdict in the Johnson v. Monsanto case. That article reported, “Top U.S. retailers such as Home Depot, Target, Walmart and Amazon are sticking by Monsanto’s controversial weedkiller Roundup one week after a California jury awarded a school groundskeeper $289 million for proving the spray caused him to develop non-Hodgkin’s lymphoma.” Indeed, insurer (and perhaps re-insurer) concern may well increase in light of the deluge of lawsuits glyphosate use has triggered.

Meanwhile scientific studies linking glyphosate to serious adverse effects still keep coming in. A recent study by Fabiana Manservisi, Corina Lesseur, et al., published in Environmental Health on March 12, shows glyphosate-based herbicides are associated with endocrine and reproductive effects. This is on top of the scientific findings by the World Health Organization that the chemical probably causes cancer. A meta-study in February 2018 concluded that there is a “compelling link between exposures to GBH [glyphosate-based herbicides] and increased risk of NHL.” Still the U.S. Environmental Protection Agency fails to act.

On March 1, the City of Miami established a ban, which went into immediate effect, on the use of any glyphosate-based herbicides (including Roundup compounds) by the city and any of its contractors.

It is time to stop glyphosate use or risk continued exposure to the state’s populations and adverse health effects, along with the financial exposure that the threat of litigation brings.

Beyond Pesticides and other organizations that have worked for many years to educate stakeholders and policy makers about the dangers of pesticides, stand ready to assist the state and communities in transforming pest management by eliminating a reliance on toxic pesticides and adopting organic management practices.

Tell your Governor to act now to stop the use of glyphosate/Roundup.

Letter to Your Governor:

It is time for all local and state governments and school districts to stop the use of glyphosate/Roundup. The last month has seen a level of activity that supports immediate action. A second jury came in with the verdict that the herbicide caused plaintiffs’ non-Hodgkin’s lymphoma (NHL) —this time handing the manufacturer, Monsanto/Bayer, a bill for $80 million ($5 million in compensatory damages and $75 million in punitive damages).

Insurance companies are now backing away from Roundup. Harrell’s is a company that sells chemical pesticides, synthetic fertilizers, and “adjuvants and colorants,” among other products, primarily to golf courses, and to the horticulture-nursery, turf, and lt is time for all local and state governments and school districts to stop the use of glyphosate/Roundup. The last month has seen a level of activity that supports immediate action. A second jury came in with the verdict that the herbicide caused plaintiffs’ non-Hodgkins lymphoma (NHL) —this time handing the manufacturer, Monsanto/Bayer, a bill for  $80 million ($5 million in compensatory damages and $75 million in punitive damages).

Insurance companies are now backing away from Roundup. Harrell’s is a company that sells chemical pesticides, synthetic fertilizers, and other products, primarily to golf courses and the horticulture-nursery, turf, and landscape sectors. The company announced on March 11 that it stopped selling products containing glyphosate as of March 1, 2019 because neither its current insurance company nor others Harrell’s consulted would underwrite coverage for any glyphosate-related claims.

Harrell’s CEO stated: “During our annual insurance renewal last month, we were surprised to learn that our insurance company was no longer willing to provide coverage for claims related to glyphosate due to the recent high-profile lawsuit and the many thousands of lawsuits since. We sought coverage from other companies but could not buy adequate coverage for the risk we would be incurring. So we had no choice other than to notify our Harrell’s Team and customers that we would no longer offer products containing glyphosate.”

Concern has increased since a Fox Business story shortly after the verdict in the Johnson v. Monsanto case, which reported, “Top U.S. retailers such as Home Depot, Target, Walmart and Amazon are sticking by Monsanto’s controversial weedkiller Roundup one week after a California jury awarded a school groundskeeper $289 million for proving the spray caused him to develop non-Hodgkin’s lymphoma.” Indeed, insurer (and perhaps re-insurer) concern may well increase in light of the deluge of lawsuits glyphosate use has triggered.

Meanwhile scientific studies linking glyphosate to serious adverse effects still keep coming in. A recent study published in Environmental Health on March 12, shows glyphosate-based herbicides are associated with endocrine and reproductive effects. This is on top of the scientific findings by the World Health Organization that the chemical probably causes cancer. A meta-study in February 2018 concluded that there is a “compelling link between exposures to GBH [glyphosate-based herbicides] and increased risk of NHL.” Still the U.S. Environmental Protection Agency fails to act.

On March 1, the City of Miami established an immediate ban on the use of any glyphosate-based herbicides by the city and any of its contractors.

It is time to stop glyphosate use or risk continued exposure to the state’s populations and adverse health effects, along with the financial exposure that the threat of litigation brings.

Beyond Pesticides and other organizations that have worked for many years to educate stakeholders and policy makers about the dangers of pesticides, stand ready to assist the state and communities in transforming pest management by eliminating a reliance on toxic pesticides and adopting organic management practices.

Thank you for your attention to this important matter.

National Organic Standards Board (NOSB) meets next month in Seattle, Washington to debate issues concerning what goes into your organic food. Written comments are due April 4. The format for messaging the NOSB requires copying and pasting comments into regulations.gov, so we apologize that this is not a “single click” action. Please add a personal message about why this is important to you at the top of your comments, if possible.

Lend your voice to continuous improvement by learning about issues and submitting comments to regulations.gov (directions below, or click here).

From the very beginning, with the passage of the Organic Foods Production Act (OFPA) in 1990, “organic” has meant “continuous improvement ” in organic food production. The primary mechanism for this is the high level of public involvement that comes from twice-annual meetings of the stakeholder board and decisions related to the allowance of substances/materials used in organic production.

The second mechanism is the sunset process, which helps move synthetic substances out of organic production as we learn more about hazards and alternatives. Those substances allowed in organic production must be placed on the National List of Allowed and Prohibited Substances and may be re-listed every five years after a mandatory rigorous assessment of their adverse effects from cradle-to-grave, and a determination of their necessity, given alternative practices and products.  Imagine what could happen if pesticide registrations went through a rigorous reevaluation and relisting process like this every five years!

Items on the NOSB agenda include voting on materials allowed in organic production and policies, as well as discussion of policies and sunset materials on which the NOSB will vote in the Fall. We have identified some priority issues of both kinds. Starred issues are voting issues.

To comment on these priority issues, highlight the entirety of the comments below (including headers) and hit “copy”

Then click here to go to Regulations.gov and paste into the comment field.

Add a personal message about why this is important to you at the top!

PRIORITY COMMENTS: 

Reject Petition to Allow Silver Dihydrogen Citrate* [HS]
Silver dihydrogen citrate poses health and environmental risks, particularly the risk of increasing resistance to antibiotics and silver-based medications. Both ionic silver and nanosilver are toxic not only to microbes, but to other species as well. The petition for SDC must be denied to protect human health and the environment and ensure the effectiveness of remaining antimicrobial medications.

Reject Petition to Allow Allyl Isothiocyanate (AITC)* [CS]
Allyl isothiocyanate (AITC) must not be included on the National List because it does not meet any of the criteria in OFPA for allowing an exemption. It poses environmental and health hazards, is not essential for organic production, and is not compatible with organic practices. It would be difficult to find a practice less compatible with organic production than soil fumigation with a “broad-spectrum antimicrobial compound that effectively kills both plant pathogens and beneficial soil microorganisms.” Organic production uses practices that feed soil organisms who feed crop plants. It creates healthy soil food webs. Using a toxic chemical to wipe out soil biology is the antithesis of organic practices.

Reject Petition to Allow Collagen Gel Casings* [HS]
Collagen gel casings should not be added to the list of allowed nonorganic agricultural materials because collagen gel casings are synthetic, the listing discourages the development of organic collagen gel casings, and the contamination from nonorganic feedlots and other practices poses environmental and health hazards.

Non-organic collagen gel casings derived from animals raised in concentrated animal feeding operations (CAFOs) contaminate organic products with toxic pesticides and other chemicals widely recognized as hazardous to farmworkers, the environment, and consumers. 

Any agricultural commodity can be produced organically, so listing on §606 only stifles organic production of new organic crops and promotes chemical-intensive production. Instead of petitioning for the use of casings made from meat contaminated with pesticides and antibiotics, processors should devote their efforts to eliminating practical obstacles to sourcing organic collagen.

Protect Marine Environment by Limiting Marine Materials [MS]
We must set enforceable, protective rules for the use of marine algae in organic production. Enforceability implies rules that are verified by on-site inspection and that will stand up to legal challenge. Rules must protect the marine ecosystem and biological communities.

An annotation is the most effective way to introduce enforceable, protective rules for marine algae. Annotations are not subject to discretionary alteration without a decisive vote of the NOSB. On the other hand, because the listings are reviewed on a five-year cycle, they can be updated when needed. 

Evaluating Sanitizers [MS]
The Materials Subcommittee has outlined many of the issues that should be covered regarding sanitizers, but they need to be addressed within a framework that first identifies the needs for cleaning and sanitizing materials in organic production and handling.

Such a review should start with the questions:

1. For what purposes are cleaning and sanitizing materials needed?
2. Are specific cleaning and sanitizing materials required by law?

Both in terms of a strict reading of OFPA and common sense, all cleansers and antimicrobials used in organic production and handling should be on the National List.

Stop Methionine [LS]
The NOSB should delist synthetic methionine (an alternative to natural amino acids) or add an expiration date to force serious reconsideration. The current listing of methionine is based on inadequate support for a regulatory decision that reverses a previous NOSB decision to phase out methionine and incentivize alternative approaches to managing poultry. 

The listing of synthetic methionine must be considered in the context of an organic management system. The “need” for synthetic methionine is a result of choices regarding poultry flock breeds, stocking rates (both density and group size), and outdoor access. Increasingly, consumers are turning to eggs and meat produced in pastured poultry systems, which require fewer synthetic inputs. In the time since the last consideration of synthetic methionine by the NOSB, there have been advances in the use of insects — specifically black soldier fly larvae — as a source of natural methionine. However, organic poultry producers and the NOSB should not limit their consideration to one source.

Synthetic methionine is not necessary for animal welfare. Studies show that reduced stocking rates (both density and group size), outdoor access, and slower-growing birds (who use the outdoors more effectively), but not synthetic methionine and cysteine, have a positive impact on the welfare of poultry.

Lend your voice to continuous improvement by learning about issues and submitting comments to regulations.gov (directions below, or click here).

Researchers at Penn State University used publicly available USGS data to tabulate total neonicotinoid-treated seed use in the US. As shown in the above image, as of 2011, 34 to 44% of soybeans (blue) and 79 to 100% of maize acres (red) were planted with treated seeds. [Photo Credit: Ian Grettenberger, Penn State]

EPA is misusing a regulatory loophole – the “treated articles exemption” – to allow systemic insecticides to be used in mass quantities, without regulating or labeling them as required under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). EPA does not currently assess adverse effects on the environment and public health wrought by widespread use of neonicotinoid insecticides delivered through seeds coated with the insecticides, resulting in widespread exposure to one of the most environmentally damaging classes of chemicals on the market.

>> Tell your Congressional delegation that EPA must fully regulate treated seeds to protect the environment and public health.

Pesticide-coated seeds are now ubiquitous, yet their far-reaching impacts on wildlife and human health continue to go unregulated. The introduction and spread of seed-delivered pesticides to major field crops, beginning around 2003, caused a massive increase in total neonicotinoid use nationwide. As of 2011, 34 to 44% of soybeans and 79 to 100% of maize acres were planted with coated seeds, accounting for an astounding 35-fold increase in nationwide neonicotinoid use from baseline rates prior to 2003 (Douglas and Tooker, 2015). Alarmingly, because the national pesticide survey conducted by the National Agricultural Statistics Service fails to include seed-applied neonicotinoids, their reports give the misleading impression that neonicotinoid use has declined over the past few decades.

Seed coating technologies have dramatically altered the landscape of pesticide contamination nationwide. U.S. croplands are currently planted with roughly 3.5 million kilograms of neonicotinoid-coated seeds each year (Tooker and Douglas, 2017). On top of causing massive increases in the total extent and per-acre rate of neonicotinoid application, seed treatments increase the proportion of neonicotinoids applied that enter soil and groundwater. From 90 to 99% of active ingredient delivered through seed treatments is lost to air, soil, and water --including environmental losses caused by the release of contaminated seed dust during mechanical planting (Wood and Goulson, 2017). Neonicotinoids in seed dust can reach concentrations up to five orders of magnitude higher than their acute contact LD50 values, leading to documented mass honey bee poisonings (Wood and Goulson, 2017). Inaction by EPA has led state regulators to avoid investigating these bee deaths from exposure to dust from planting seeds treated with neonicotinoid insecticides. 

Neonicotinoid-coated seeds pose far-reaching risks to wildlife, above and beyond those posed by neonicotinoids delivered in other forms. In EPA's 2017 ecological assessment of neonicotinoids, coated seeds in particular were identified as posing the highest dietary risks to birds --exceeding the agency's level of concern as much as 200-fold.

There is substantial evidence that neonicotinoid-coated seeds cause unreasonable harm to aquatic invertebrates – the foundation of healthy aquatic ecosystems. An EPA Aquatic Risk Assessment for imidacloprid, released in 2017, found that imidacloprid threatens the health of U.S. waterways with significant risks to aquatic insects and cascading effects on aquatic food webs.

In addition to threatening wildlife, the widespread use of neonicotinoid-treated seeds also puts human health at risk. The mass leaching of seed-delivered pesticides may lead to unreasonable adverse effects on public health via contamination of drinking water. Recent studies have found neonicotinoids pervasive in finished drinking water (Klarich et al. 2017; Sultana et al. 2018). Alarmingly, University of Iowa researchers found that finished drinking water frequently contains metabolites of the neonicotinoid imidacloprid that have never been evaluated for their potential risks to human and environmental health. Experts warn that these metabolites may morph further into new forms of chlorinated disinfection byproducts during routine water treatment processes, with potential for high toxicity to humans due to loss of insect specificity.

The continued under-regulation of treated seeds is in violation of EPA's federal mandate to regulate and fully assess the risks posed by pesticides as they are commonly applied.

Forget about single-pesticide issues: this affects every single one of them. EPA is allowing massive data gaps to persist for each and every pesticide product it registers by conducting the bulk of its health and environmental risk assessments using active ingredients alone. With its current practices, EPA is failing its federal mandate to protect public health and the environment and misleading the public about what is “safe.”

Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients.

When pesticides are sprayed on our crops, lawns, and roadsides, and enter into our waterways, groundwater and drinking water, we are exposed to whole formulations, whole tank mixtures, and whole pesticide combinations, not just active ingredients (those that the manufacturer claims are the only ingredients that attack the target pest). It is the whole formulation that makes the poison, and that whole formulation must be regulated.

Active ingredients are far from the whole story of pesticide poisoning. Despite their name, “inert” ingredients are very often not chemically, biologically, nor toxicologically inert or innocuous. According to a peer-reviewed study, as of 2006, more than 500 ingredients that were listed as “inert” in some products serve as the active ingredient in other products. Many “inert” ingredients are known to state, federal, and international agencies to be hazardous to human health. One of the most hazardous ingredients in common formulations of the popular herbicide Roundup is a surfactant, which is classified as an “inert,” and therefore not listed on the label. A 2013 study found that some Roundup adjuvants are 9,661 times more toxic to human cells than the active ingredient glyphosate. The real threats of herbicides, fungicides, and insecticides are masked when EPA only tests active ingredients.

Synergy between ingredients adds yet another layer to the stack of untested threats. Ingredients added to formulations are specifically selected for their ability to make the active ingredient more potent, yet these effects are ignored in the vast majority of EPA-required testing. A 2016 Center for Biological Diversity (CBD) Investigative report found that 69% of recently approved pesticide patent applications claimed or demonstrated synergy between ingredients in the product.

Based on EPA’s current policies, the agency does not require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor does it require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.

To put it another way: EPA has no idea whether the pesticide products it registers and claims pose an “acceptable risk” could cause cancer, chronic disease, developmental delays, or infertility. EPA has no idea whether the pesticide products it registers could harm or kill birds, fish, aquatic invertebrates, or honey bees. These data gaps are alarming and unacceptable, and a misinterpretation of the law.

Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients.

If you have a moment, please take a few minutes to navigate to EPA’s public comment page and tell EPA directly that it must require whole mixture testing. By clicking on ‘Comment Now!’ you can become part of the official decision-making process in this critical, far-reaching issue. See below for suggested comments (which you can cut-and-paste into the EPA docket), or personalize your own.

(Suggested Comment):

I am writing in support of the policy amendments detailed in the petition, “Seeking Revised Testing Requirements of Pesticides Prior to Registration,” Docket # EPA-HQ-OPP-2018-0262-0001.

Whole pesticides must be tested across all areas of toxicity in the same form in which they are commonly applied, in order to comply with FIFRA and adequately protect the environment and public health.

Based on published policies (40 C.F.R § 158.500-660), EPA does not currently require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor does it require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.

By requiring only the active ingredient for the majority of pesticide risk assessment tests, EPA is failing to adequately protect against known widespread hazards of “inert” ingredients and their synergistic effects on whole pesticide toxicity.

EPA must fulfill its federal mandate and test whole pesticide formulations and mixtures, as they are commonly applied. Anything less falls short of adequate protection under the law.

Sincerely,

We must stop the expanded commercialization of genetically engineered pesticides. The failure of the U.S. Environmental Protection Agency (EPA) to fully evaluate environmental impacts of gene-manipulating pesticides raises serious concerns in light of the agency’s ongoing failure to predict ecological effects of pesticides, such as the dramatic decline of pollinators.

With the release of a 2019 peer-reviewed scientific article, Environmental Fate of RNA Interference Pesticides: Adsorption and Degradation of Double-Stranded RNA Molecules in Agricultural Soils, on the potential impact on soil and non-target microorganisms in soil, the study’s co-author, Kimberly Parker, PhD, remarked, “The ecological risk assessment of these emerging pesticides necessitates an understanding of the fate of dsRNA [double stranded RNA] molecules in receiving environments, among which agricultural soils are most important.”

This technology, given that it is systemic to the plant and leaves traces in the soil, can cause widespread indiscriminate poisoning—as has been seen with bees, butterflies, birds, and the larger catastrophic decline of insect populations.

Tell your members of Congress that the ecological effects of RNAi gene-manipulating pesticides raise serious questions—they have not been fully studied by EPA and, until they are, the agency should issue a moratorium on their release.

Previously, technical hurdles in measuring dsRNA had stymied scientists’ ability to quantify the genetic material and its degradation products in soil, but these investigators are now able to “tag” the molecule so it can be followed through a series of simulated soil systems representative of those in the “real” world. The work of these researchers marks the beginning of understanding the ecological risks of these emerging dsRNA pesticides.

The dsRNA pesticides work by impeding the expression of essential proteins in target pest insects via a cellular mechanism called RNA interference (RNAi). In RNAi, the messenger RNA of the target organism (pest) is adversely affected and it is left either stunted or dead.

In the biochemical genetic engineering (GE) sector, “gene silencing” technology is engineered into plants so that they can, functionally, produce their own pesticides. EPA quietly registered Monsanto’s (now Dow’s) first product using this genetic engineering technology in the summer of 2017 and it is expected to be on the market in 2019 or 2020.

For decades, the silver bullet strategy to controlling the corn rootworm has eluded companies advancing approaches that do not take into account crop and soil management systems known to prevent insect problems, such as those utilized by organic farmers. Previous attempts that incorporate Bt (Bacillus thuringiensis, a bacterium that produces a toxin that kills some pests and non-pests) have been met with insect resistance over time. With the gene-manipulating pesticide, when the rootworm ingests the dsRNA in the corn plant’s tissue—grown from GE corn seeds called SmartStax Pro—a gene in the insect that is essential for rootworm survival gets turned off.

Too many mistakes have been made with the proliferation of pesticides and herbicide-tolerant genetically engineered crops, resulting in harm to consumers, farmers, and other organisms. With this new study, it is clear that we know less than we should to allow the marketing of a new pesticidal plant. Given that we have the tools to grow food productively and profitably without it, there is no need for EPA to move ahead without complete understanding of serious potential hazards.

Tell your members of Congress that the ecological effects of RNAi gene-manipulating pesticides raise serious questions—they have not been fully studied by EPA and, until they are, the agency should issue a moratorium on their release.

Last week, U.S. Representative Earl Blumenauer (D-OR) reintroduced the Saving America's Pollinators Act (H.R.1337) to cancel specific bee-toxic pesticides and establish a review and cancellation process for all pesticides that are potentially harmful to pollinators. The specific pesticides targeted in the bill include the systemic insecticides imidacloprid, clothianidin, thiamethoxam, dinotefuran, acetamiprid, sulfoxaflor, flupyradifurone, and fipronil. The bill also establishes requirements for review of other potentially bee-toxic chemicals by an independent pollinator protection board, and requires annual reports on the health and population status of pollinators. The bill creates a sustainable model for pollinator protection in the face of ongoing obstruction by an increasingly industry-influenced EPA. There are 29 cosponsors to date.

>>Tell your Representative to cosponsor the Saving America's Pollinators Act!

The current bill is the fifth version of Saving America's Pollinators Act (SAPA), which was first introduced by U.S. Representative Conyers (D-MI) in 2013. The newest version differs from previous bills in its bold definition of who should have responsibility for assessing harm to pollinators. SAPA 2019 calls for the establishment of a Pollinator Protection Board, to be composed of expert scientists, beekeepers, farmers, members of environmental organizations and other key stakeholders, nearly all of whom must not have any conflict of interest or affiliation with industry. The Pollinator Protection Board would be charged with annual review of potentially bee-toxic pesticides, to ensure continued assessments the initial suspensions. Beyond Pesticides holds the position that such continuous oversight free from conflict of interest is necessary to adequately protect vital pollinators, especially in the face of worsening mass declines. The current SAPA creates a similar board structure and authorities to the Organic Foods Production Act.

“Pollinators and other insects are vital to our economy and our livelihoods. This analysis is a call to action to do all we can to protect these valuable insects,” Rep. Blumenauer said, referencing a recent study “that paints a terrifying picture for the future of insects and our planet.”

Numerous scientific studies implicate systemic insecticides as key contributors to the global decline of pollinator populations. Systemic insecticides have been found to weaken both behavioral and immune resistance to parasites, pathogens, and temperature stress in honey bees and native pollinators. Several independent studies of managed and wild bees in the field have shown significant colony and population declines as a direct result of neonicotinoid crop treatment (1, 2, 3). There is widespread consensus in the scientific community that systemic insecticides are responsible for pollinator declines and need to be restricted, as evidenced by a 2018 “Call to restrict neonicotinoids” published in Science and signed by 233 scientists. 

“The health of our food system depends on the health of our pollinators. The status quo is like flying blind – we shouldn't be using these pesticides when we don't know their full impact,” said Rep. Blumenauer in the introduction to the previous iteration of the bill. “The EPA has a responsibility to get to the bottom of this issue and protect pollinators.”

EPA scientists have found that neonicotinoids pose far-reaching risks to birds and aquatic invertebrates, in addition to pollinators. EPA's risk assessments find deadly impacts to birds from neonicotinoid-treated seeds, poisoned insect prey, and contaminated grasses. University researchers have found that tiny amounts of neonicotinoids are enough to cause migrating songbirds to lose their sense of direction and become emaciated. A 2018 study by U.S. Geological Survey (USGS) researchers found neonics widespread in the Great Lakes at levels that harm aquatic insects—the foundation of healthy aquatic ecosystems.

Human health is also at stake. A recent study by USGS and the University of Iowa found two metabolites of imidacloprid in drinking water that have never been evaluated for their potential risks to human and environmental health. Experts warn that these metabolites may morph further into new forms of chlorinated disinfection byproducts (DBPs) during routine water treatment processes, with potential for high toxicity to humans due to loss of insect-specificity.

Canada's pesticide regulatory agency recently proposed a phase-out of two widely used neonicotinoids, thiamethoxam and clothianidin, based on harms to bees and aquatic ecosystems. In 2018, Europe instituted a ban on neonicotinoids for outdoor use based on based on the General Court of the European Union's 2018 ruling upholding their harms to pollinators.

Rep. Blumenauer is offering a legislative remedy to address the U.S. pollinator crisis. But Congress won't act unless members hear from their constituents. Read the latest draft of the bill to understand how the new act would transform pollinator protection in the U.S., and urge your representative to support the Saving America's Pollinator Act 2019. With managed honey bee losses remaining at unsustainable levels and wild pollinators and insects of all taxa at risk of extinction, it is time for the U.S. to finally protect pollinators.

The bill has 29 cosponsors to date: Rep. Cartwright, Matt [D-PA-8], Rep. Castor, Kathy [D-FL-14], Rep. Clark, Katherine M. [D-MA-5], Rep. Cohen, Steve [D-TN-9], Rep. Connolly, Gerald E. [D-VA-11], Rep. DeFazio, Peter A. [D-OR-4], Rep. DeLauro, Rosa L. [D-CT-3], Rep. Gabbard, Tulsi [D-HI-2], Rep. Haaland, Debra A. [D-NM-1], Rep. Huffman, Jared [D-CA-2], Rep. Jackson Lee, Sheila [D-TX-18], Rep. Kaptur, Marcy [D-OH-9], Rep. Keating, William R. [D-MA-9], Rep. Kuster, Ann M. [D-NH-2], Rep. Lee, Barbara [D-CA-13], Rep. Lewis, John [D-GA-5], Rep. Lieu, Ted [D-CA-33], Rep. McCollum, Betty [D-MN-4], Rep. McGovern, James P. [D-MA-2], Rep. Omar, Ilhan [D-MN-5], Rep. Pingree, Chellie [D-ME-1], Rep. Quigley, Mike [D-IL-5], Rep. Raskin, Jamie [D-MD-8], Rep. Ryan, Tim [D-OH-13], Rep. Schakowsky, Janice D. [D-IL-9], Rep. Tonko, Paul [D-NY-20], Rep. Velazquez, Nydia M. [D-NY-7], Rep. Wasserman Schultz, Debbie [D-FL-23], Rep. Watson Coleman, Bonnie [D-NJ-12].

The following congress members who previously cosponsored SAPA bills have not yet cosponsored SAPA 2019:  Rep. Aguilar, Pete [D-CA-31], Rep. Beatty, Joyce [D-OH-3], Rep. Beyer, Donald S., Jr. [D-VA-8], Rep. Bishop, Sanford D., Jr. [D-GA-2], Rep. Carson, Andre [D-IN-7], Rep. Cartwright, Matt [D-PA-17], Rep. Chu, Judy [D-CA-27], Rep. Clarke, Yvette D. [D-NY-9], Rep. Clay, Wm. Lacy [D-MO-1], Rep. Cummings, Elijah E. [D-MD-7], Rep. Davis, Susan A. [D-CA-53], Rep. DelBene, Suzan K. [D-WA-1], Rep. DeSaulnier, Mark [D-CA-11], Rep. Doggett, Lloyd [D-TX-35], Rep. Eshoo, Anna G. [D-CA-18], Rep. Grijalva, Raul M. [D-AZ-3], Rep. Himes, James A. [D-CT-4], Rep. Horsford, Steven [D-NV-4], Rep. Jeffries, Hakeem S. [D-NY-8], Rep. Johnson, Eddie Bernice [D-TX-30], Rep. Johnson, Henry C. Hank, Jr. [D-GA-4], Rep. Langevin, James R. [D-RI-2], Rep. Larsen, Rick [D-WA-2], Rep. Larson, John B. [D-CT-1], Rep. Levin, Sander M. [D-MI-9], Rep. Lofgren, Zoe [D-CA-19], Rep. Lowenthal, Alan S. [D-CA-47], Rep. Maloney, Carolyn B. [D-NY-12], Rep. Matsui, Doris O. [D-CA-6], Rep. Meeks, Gregory W. [D-NY-5], Rep. Meng, Grace [D-NY-6], Rep. Nadler, Jerrold [D-NY-10], Rep. Norcross, Donald [D-NJ-1], Rep. Norton, Eleanor Holmes [D-DC-At Large], Rep. Pascrell, Bill, Jr. [D-NJ-9], Rep. Pocan, Mark [D-WI-2], Rep. Price, David E. [D-NC-4], Rep. Roybal-Allard, Lucille [D-CA-40], Rep. Ruppersberger, C. A. Dutch [D-MD-2], Rep. Rush, Bobby L. [D-IL-1], Rep. Schiff, Adam B. [D-CA-28], Rep. Smith, Adam [D-WA-9], Rep. Speier, Jackie [D-CA-14], Rep. Takano, Mark [D-CA-41], Chris [D-MD-8], Rep. Vargas, Juan [D-CA-51], Rep. Waters, Maxine [D-CA-43].

A new study by Friends of the Earth and allies found that found that breakfast cereal, apples, applesauce and pinto beans made and sold by Kroger contains residues of toxic pesticides linked to a range of serious health and environmental problems.

This is alarming. Kid-friendly food like applesauce and cheerios should not contain dangerous pesticides. Kids are the most vulnerable to these pesticides and shouldn't be exposed to brain-damaging or cancer-causing pesticides when they eat their breakfast or snacks. The connection between pesticides and cancer, learning disabilities, and other diseases is supported by hundreds of studies in Beyond Pesticides' Pesticide-Induced Diseases Database.

>> Join the national week of action by either delivering a letter to Kroger in person, or sending an email to Kroger Chief Executive Rodney McMullen

These new tests, which corroborate numerous residue studies, mean that Kroger customers may be purchasing food with the intent of providing safe and healthy food for their families, but end up unknowingly exposing them to toxic pesticides.

The pesticides found in Kroger's food are harmful to human health and pollinators. We found residues of cancer-causing glyphosate, brain-damaging organophosphates and bee-killing neonicotinoid pesticides.

Organophosphates can cause damage to children's developing brains, including reduced IQ, loss of memory and attention deficit disorders, as well as acute pesticide poisoning in adults and children. They also poison farmworkers and wildlife, including pollinators, birds and aquatic organisms. 

Glyphosate aka Monsanto's Roundup® is linked to cancer and has contributed to the widespread die-off of monarch butterflies. Monarchs have declined by over 90 percent in the past two decades and are on the brink of extinction.

Bee-killing neonicotinoids have contributed to widespread bee die-offs, which are critical to every one in three bites of food we eat and many of the foods sold at Kroger.  These pesticides are also associated with endocrine disruption and may lead to changes in behavior and attention.

Kroger should not be selling any food to consumers that is grown with these toxic pesticides. 

>> Join the national week of action by either delivering a letter to Kroger in person, or sending an email to Kroger Chief Executive Rodney McMullen

We know Kroger has the power to stop selling products grown with toxic pesticides. Costco adopted a policy to phase out neonicotinoids and chlorpyrifos (an organophosphate pesticide) on the fruits, vegetables and garden plants that it sells. The policy demonstrates that it is possible for supermarkets to eliminate toxic pesticides from store shelves. Kroger has no excuse. It can commit to stop stocking its shelves with food grown with brain damaging organophosphates, Monsanto's Roundup® and Bayer's neonicotinoids.

We must shift the market fast if we want to protect public health and save bees and other pollinators. These dangerous pesticides can't be on supermarket store shelves. Especially the the healthiest and most affordable foods supermarkets sell. 

Please help us ramp up pressure on Kroger immediately to make sure it doesn't turn away from the results of this report and takes immediate action. 

>> Join the national week of action by either delivering a letter to Kroger in person, or sending an email to Kroger Chief Executive Rodney McMullen

At the request of Beyond Pesticides, the Environmental Protection Agency (EPA) has extended its public comment period on antibiotics in citrus production until March 14. With this extra time, please share this action widely to stop this threat.

If you have already written your member of Congress to comment on this, please consider distributing this action broadly and submitting a comment to EPA.

We have a two-part action for you to take.

1. Use our online form to send a letter to Congress.
2. Leave a comment on the EPA docket at regulations.gov.Please personalize our messages by adding your own story, or that of a loved one. Let your representatives and the EPA know why you want to prevent bacterial resistance!

Background
Despite the building national and international crisis of deadly bacterial resistance to antibiotics, this new allowance would expand on an emergency use decision the Environmental Protection Agency made in 2017. It permits up to 480,000 acres of citrus trees in Florida to be treated with more than 650,000 pounds of streptomycin per year; 23,000 citrus acres in California will likely be treated annually.

The World Health Organization has called bacterial resistance “one of the biggest threats to global health, food security, and development today.” The two approved antibacterial chemicals to be used as pesticides in citrus production are streptomycin and oxytetracycline. Their use was permitted by the U.S. Environmental Protection Agency (EPA) under an emergency exemption in May, 2017 for a citrus greening disease caused by the bacterium Candidatus Liberibacter asiaticus (CLas) in Florida citrus crops through December of 2019.

The Environmental Protection Agency announced March 15, “EPA is issuing these tolerances without notice and opportunity for public comment as provided in FFDCA [Federal Food, Drug and Cosmetic Act] section 408(l)(6).” EPA states, “[T]ime-limited tolerances are established for residues of streptomycin in or on fruit, citrus, group 10-10, at 2 ppm, and the dried pulp of these commodities at 6 ppm.” For oxytetracycline, EPA is allowing residues “in or on all commodities of fruit, citrus, group 10-10, at 0.4 ppm.” [See below; organic standards do not allow antibiotic use.] Now, EPA is moving forward with a permanent allowance of these chemicals.

See Agricultural Uses of Antibiotics Escalate Bacterial Resistance. Beyond Pesticides, with other organizations, led a successful effort to remove antibiotics from organic apple and pear production because of their contribution to antibiotic resistance and the availability of alternative practices and inputs.

As bacteria become resistant to the most commonly prescribed antibiotics, the results are longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. The development and spread of antibiotic resistance is the inevitable effect of antibiotic use. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance. Both antibiotics proposed for expanded use are important for fighting human disease. Tetracycline is used for many common infections of the respiratory tract, sinuses, middle ear, and urinary tract, as well as for anthrax, plague, cholera, and Legionnaire’s disease, though it is used less frequently because of resistance. Streptomycin is used for tuberculosis, tularemia, plague, bacterial endocarditis, brucellosis, and other diseases, but its usefulness is limited by widespread resistance (U.S. National Library of Medicine, 2006).

Exposure to antibiotics can disturb the microbiota in the gut. In addition to interfering with digestion, a disrupted gut microbiome can contribute to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. Furthermore, the human immune system is largely composed of microbiota.

Actions

1. Using this form, Tell your U.S. Senators and Representative to urge EPA to reject the use of antibiotics in food production, including citrus production.
2. Please put your comment in the EPA docket at REGULATIONS.GOV (a few extra clicks!)

You can cut-and-paste the language below (“Comment to EPA”) and submit it to the EPA docket at Regulations.gov. If you have a personal story with antibiotic resistance, please begin your comment with that. Reach out to others, including medical personnel, who can share their experiences with EPA.

Comment to EPA (cut-and-paste in EPA’s REGULATIONS.GOV; add personal perspective)

I write to urge EPA to reject the use of antibiotics, including streptomycin and oxytetracycline, in citrus production. This creates a public health threat that EPA must consider in real terms, as it relates to longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. Antibiotic resistance is a real and urgent public health threat and represents an existential threat to modern civilization. 

Antibiotic resistance kills over 23,000 people each year, according to the Centers for Disease Control and Prevention (CDC). In addition to the CDC, the World Health Organization has cited this escalating problem as one of the biggest public health challenges of our time.

“By 2050, resistance is estimated to add 10 million annual deaths globally with a cumulative cost to the world economy of US$100 trillion,” said Jack Heinemann, PhD, University Canterbury’s School of Biological Sciences. Exposure to antibiotics can disturb the microbiota in the gut. In addition to interfering with digestion, a disrupted gut microbiome can contribute to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. The human immune system is largely composed of microbiota.

Note that it may not be widely appreciated that use of antibiotics on fruit trees can contribute to resistance to the antibiotic in human pathogens. The human pathogenic organisms themselves do not need to be sprayed by the antibiotic because movement of genes in bacteria is not solely “vertical,” that is from parent to progeny—but can be “horizontal”— from one bacterial species to another. So, a pool of resistant soil bacteria or commensal gut bacteria can provide the genetic material for resistance in human pathogens.

Consider the real cost to the American people and internationally and prohibit the use of streptomycin in citrus production by setting a tolerance or allowable residue of zero.

 Thank you.

Tell Oregon Department of Agriculture to Ban This Tree-Killing Pesticide

Aminocyclopyrachlor (ACP) is a tree-killing pesticide masquerading as a broadleaf herbicide. The Oregon Department of Agriculture (ODA) has the opportunity to lead the country in banning this inherently dangerous chemical. According to ODA, nearly 1,500 dead or dying trees have been reported along Oregon's iconic US Highway 20, home to old growth ponderosa pines. Many of these 150- to 300-year old trees are now dead from ACP exposure. ODA indicated that “because [ACP] is a relatively new herbicide it is unknown how many trees stressed from past applications of [ACP] will die in the future.” 

>> Even at tiny levels, ACP run-off and drift kills trees. Tell Oregon's Department of Agriculture to lead the country in completely banning its use. 

In 2014, DuPont chemical company settled a nearly $2 million lawsuit with the U.S. Environmental Protection Agency (EPA) after the herbicide (under the brand name Imprelis®) was found to kill trees at golf courses, homeowners associations, businesses, and private residences. Despite this history, regulators left ACP on the market. Its use was banned on lawns and turfgrass, but allowed for roadside rights-of-way. A couple years ago, Bayer purchased the rights to ACP from DuPont and continues to market and sell the chemical under the brand names Perspective®, Streamline®, and Viewpoint®. It should be no surprise to officials that this tree-killing herbicide is killing trees, but we must now deal with their errors of judgment. 

ODA announced late last year that it was temporarily banning the use of ACP on roadsides while it put together a new rule. That rule is now available for public comment, and while it would make this temporary ban on roadside uses permanent, Oregon officials stopped short of a complete ban, allowing a limited one-time per year exemption from the ban when spraying an invasive weed in a limited area. While this is an important step, it is clear that there is enough evidence to completely ban the use of this chemical in Oregon. 

>>Tell ODA to strengthen its final rule on ACP and completely ban the chemical from use in the state!

Although ODA's new rule prohibits roadside right-of way spraying, it does not ban all uses of the chemical. In effect, this is simply setting the stage for the next round of news stories picturing ACP-poisoned trees.

Real action against tree-killing ACP is needed now. ODA will accept public comments from any U.S. resident, so regardless of where you are in the country, send the letter below to ODA today! Deadline for comments is 2/26/2019. 

At the federal level, Beyond Pesticides joined with our partners at the Center for Biological Diversity and Beyond Toxics to file a Freedom of Information Act request in order to get more information about this tree-killing pesticide. We'll keep fighting EPA's approval of this herbicide, but please help encourage the state of Oregon to step up and lead the way!

Although the rusty patched bumblebee was placed on the endangered species list in 2017, the Trump Administration has failed to put in place legally required safeguards for the species. The U.S. Department of the Interior (DOI) must designate locations where additional protections could help restore the endangered bumblebee's population. 

>>Tell Your U.S. Representative and U.S. Senators to Urge U.S. Department of Interior Acting Secretary David Bernhardt to protect the endangered rusty patched bumblebee as required by law.

DOI's failure to comply with requirements under the Endangered Species Act (ESA) is consistent with the Trump Administration's continued disregard for ongoing pollinator declines and environmental protections in general. Under ESA, DOI is required to determine “critical habitat” that contains physical and biological requirements a listed species needs in order to recover. That area must be designated within one year of placing a species on the endangered list, using best available scientific data. The Trump Administration's DOI has failed to do so under either former Director Ryan Zinke or Acting Director David Bernhardt. Without determining critical habitat, the administration is in violation of the ESA, and the survival of a critical endangered species is threatened.

The rusty patched bumblebee has a historical range that included habitat throughout the Northeast and Midwest United States. The Washington Post notes that, “The rusty patched bumblebee was so prevalent 20 years ago that pedestrians in Midwestern cities had to shoo them away.” However, pesticide use, climate change, disease, and habitat loss led to significant declines over the last several decades. Since then, their populations have dwindled and their overall decline is estimated at 91 percent.

The Trump Administration has dragged its feet on protecting the rusty patched bumblebee since the beginning of its term. The species was proposed for ESA listing under the Obama Administration in 2016, and finalized in 2017 only a week before the new Administration took office. However, on his first day in office, President Trump directed federal agencies to postpone the effective date of any regulations that had been published to the federal register but not yet put into effect. This move effectively reversed the ESA listing of the rusty patched bumblebee. In March 2017, the species was finally placed onto the endangered list. 

Unfortunately, the Trump Administration's actions in this case are more of the norm rather than the exception. In August of last year, DOI reversed a long-standing policy that prohibited the use of systemic, bee-toxic neonicotinoid insecticides on National Wildlife Refuges. The Administration has also worked on the pesticide industry's behalf to slow down the implementation of farmworker protections and continue the allowance of another highly toxic insecticide chlorpyrifos.

>>Tell Your U.S. Representative and U.S. Senators to Urge U.S. Department of Interior Acting Secretary David Bernhardt to protect the endangered rusty patched bumblebee as required by law.

A September 2018 report from the Office of Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA) identified issues important to protecting health and the environment. The EPA's response to the report left many of these problems unresolved. 

Measures and Management Controls Needed to Improve EPA's Pesticide Emergency Exemption Process (Report No. 18-P-0281, September 25, 2018), finds that the agency's practice of routinely granting “emergency” approval for pesticides through its Section 18 program does not effectively measure risks to human health or the environment.

>>Tell Congress to Ask the EPA Administrator to Close the “Emergency” Pesticide Use Loophole, and Adopt All the Recommendations of the Office of the Inspector General

Under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA has the authority to approve the temporary emergency use of unapproved pesticides if the agency determines the pesticide is needed to prevent the spread of an unexpected outbreak of crop-damaging insects, for example. But this provision has been widely abused.

The inspector general recommends EPA “develop and implement applicable outcome-based performance measures to demonstrate the human health and environmental effects of the EPA's emergency exemption decisions.” 

EPA disagreed and said, [T]he development of an outcome-based performance measure for the Section 18 emergency exemption process was neither appropriate nor feasible.” EPA's response demonstrates that the current Section 18 program, which allows chronic overuse of emergency exemptions, is neither appropriate nor adequately protective of public health.

OIG's report finds “significant deficiencies in the OPP's [Office of Pesticide Programs] online database management, in its draft Section 18 emergency exemption standard operating procedure and application checklist, and in its reports to Congress and the Office of Management and Budget.” Specifically, the report notes EPA “does not have outcome measures in place to determine how well the emergency exemption process maintains human health and environmental safeguards. The program office also does not have comprehensive internal controls to manage the emergency exemption data it collects,” and “OPP does not consistently communicate emergency exemption information with its stakeholders.”

Beyond Pesticides has firmly opposed the current use of Section 18. Through the Section 18, or emergency exemption program, EPA allows the use of pesticides that are not registered for a particular crop, or in some cases not registered for use at all, but making progress toward registration. EPA can set tolerances for affected crops that are time-limited, usually for the season in which they are allowed or sometimes longer. For example, in March 2017 EPA announced it is allowing residues of antibiotics in Florida orange juice, after approving an emergency exemption for the antibiotics streptomycinand oxytetracycline –allowing their use for a bacterial disease, citrus greening (Candidatus Liberibacter asiaticus (CLas) bacterium that causes Huanglongbing), in Florida citrus crops through December of 2019, and further exacerbating bacterial resistance. Organic citrus growers use cultural practices, soil fertility focused on soil biology, and biological controls to manage the disease.

Beyond Pesticides has found a growing number of requests for Section 18 emergency exemptions from states over the last ten years for the use of pesticides to control various resistant weed and insect pests that do not meet the criteria for “non-routine” or “emergency” conditions set forth in FIFRA, and/or whose pesticide use would pose elevated risks to the environment. Additionally, a number of requests and subsequent, almost annual, issuance of Section 18 exemptions essentially replace one Section 18 exemption with another. Continuous exemptions for the same or similar pest problem over a number of years indicates that the case is not “non-routine” and undermines the intent of the program, which is to provide temporary relief from unforeseen problems.

A Center for Biological Diversity report finds as of 2017, EPA had granted 78 “emergency” exemptions for sulfoxaflor, a pesticide that the EPA itself concluded is highly toxic to bees. EPA has approved emergency exemptions to allow sulfoxaflor use on more than 17.5 million acres of U.S. cotton and sorghum farms – use sites where the pesticide is not currently registered. Other exemptions are given to states to combat herbicide-resistant weeds, which have proliferated across the U.S. over the last decade and should not be considered an “emergency” situation; resistance is a predictable consequence of pesticide use.

Reoccurring problems like weed resistance to herbicides should be a wake-up call for farmers and EPA to reevaluate and implement alternative biological and cultural management practices for the long-term prevention of diseases, ending the reliance on the “chemical fix” that will exacerbate the problem when pest resistance to the chemical inevitably occurs.

>>Tell Congress to Ask the EPA Administrator to Close the “Emergency” Pesticide Use Loophole, and Adopt All the Recommendations of the Office of the Inspector General.

(Beyond Pesticides, January 22, 2019) Earlier this month, U.S. Representative Nydia Velásquez (D-NY) introduced The Ban Toxic Pesticides Act, H.R.230 which bans the insecticide chlorpyrifos from commerce.

Chlorpyrifos is a toxic chemical that has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children. As a result of a revised human health risk assessment, the Environmental Protection Agency (EPA) developed a regulation to ban chlorpyrifos in 2016. Under the Trump Administration, the EPA has taken steps to reverse the regulation.

“It’s unconscionable for EPA to turn a blind eye as children and workers are exposed to this poison,” Velázquez said.  “If the EPA won’t do its job when it comes to chlorpyrifos, then Congress needs to act – and do so quickly.”

Ask your U.S. Representative to Co-Sponsor H.R. 230 to Stop the Use of the Toxic Insecticide Chlorpyrifos, which Is Damaging Children’s Brains. 

Chlorypyrifos is a widely used pesticide. Agriculture companies annually spray 6 million pounds of the substance on crops like citrus, apples, and cherries.  In the same family as Sarin gas, the substance was initially developed prior to World War II as a chemical weapon. It can overstimulate the nervous system to cause nausea, dizziness, and confusion. With very high exposures (accidents or spills), it can cause respiratory paralysis and even death. When applying the chemical to fields, workers must wear protective garments such as respirators. Workers are then blocked from entering the fields from 24 hours up to 5 days after application due to the chemical exposure risk.

In August, the U.S. 9th Circuit Court of Appeals ordered the Environmental Protection Agency (EPA) to implement its previous proposed ban of the chemical in the U.S. However, the Administration is appealing the ruling, seeking to prevent implementation of the Obama-era ban.

Rep. Valázaquez states, “As long as there are efforts underway in the courts or administratively to undo the ban on this toxic pesticide, I’ll be working to see chlorypyrifos removed from commerce through the legislative process.”

There is a strong recent history of action of introducing legislation to remove chlorpyrifos from use. The same legislation being proposed by Valazquez was introduced in the last Congress as H.R. 3380, Pesticide Protection Act (2017). In the closing days of the 115th Congress, U.S. Senator Brian Schatz (D-Hawai‘i) introduced a bill to ban chlorpyrifos. The Prohibit Chlorpyrifos Poisoning Students Act (S. 3764) would elevate Hawai‘i’s state ban to the national level, banning the use of the chemical near (within 300 feet of) schools in 2019 and banning its sale and distribution altogether the following year. The legislation follows a 2017 bill introduced by Senator Tom Udall (D-NM), Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act, S. 1624, that deems any food with chlorpyrifos residues to be adulterated and therefore illegal.

EPA negotiated a cancellation of all residential uses (with the exception of golf courses and disease-carrying mosquitoes) in 2000 after finding significant neurotoxic effects on children. In June, 2018, Hawai‘i became the first state to ban chlorpyrifos, effective 2022.

Given the abundant research demonstrating deleterious effects of chlorpyrifos on human health –including a 2016 EPA human risk assessment that found the agency’s exposure threshold is exceeded for children, and citing concerns about chlorpyrifos levels in the air in schools, homes, and communities — it is critical to support a complete ban on the chemical.

H.R. 230 has 56 house representative co-sponsors. If your representative has already signed on, you will be prompted to send them a thank you note that encourages them to keep advocating for human and environmental health.

Ask your U.S. Representative to Co-Sponsor H.R. 230 to Stop the Use of the Toxic Insecticide Chlorpyrifos, which Is Damaging Children’s Brains. 

Letter to U.S. Representatives:

I am writing to request that you co-sponsor The Ban Toxic Pesticides Act, H.R.230. Introduced by Rep. Nydia Velásquez, the act bans the insecticide chlorpyrifos from commerce. Chlorpyrifos is a toxic chemical that has been linked to damaging and often irreversible health outcomes in workers, pregnant women, and children.

 EPA negotiated a cancellation of all residential (with the exception of golf courses and disease-carrying mosquitoes) uses in 2000, after determining that the neurotoxic effects to children exceeded reasonable levels. A 2016 revised EPA human health risk assessment of chlorpyrifos found that the agency’s exposure threshold is exceeded for children, citing concerns about levels in the air at schools, homes, and communities in agricultural areas. As a result, the EPA developed a regulation to ban chlorpyrifos. Under the Trump Administration, the EPA has taken steps to reverse the regulation despite clear human health hazards.

In June of 2018, Hawai‘i became the first state to ban chlorpyrifos (effective in 2022). The evidence of deleterious effects and momentum of policy change make it clear: there is an urgent need to extend protection from chlorpyrifos to children and others in all states.

Please confirm with me that you will co-sponsor H.R. 230, The Ban Toxic Pesticides Act.

Thank you.

Sincerely,

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Co-sponsors in the last (115th) Congress (56): Chairman Raúl M. Grijalva, Rep. David N. Cicilline, Rep. Debbie Wasserman Schultz, Rep. McNerney, Rep. Peter DeFazio, Rep. Blumenauer, Rep. Bonamici, Rep. Roybal-Allard, Rep. Quigley, Rep.
Lee, Rep. Chu, Rep. Eleanor H. Norton, Rep. Frederica S. Wilson, Rep. Gabbard, Rep. Jackson Lee, Rep. Peter Welch, Rep. Mark Pocan, Rep. Espaillat, Rep. Lipinski, Rep. Kathy Castor, Rep. Carolyn B. Maloney, Rep. Steve Cohen, Rep. Ro Khanna, Rep. Tim Ryan, Rep. Yvette D. Clarke, Rep. Chris Smith, Rep. Pramilia Jayapal, Rep. Carol Shea-Porter, Rep. Bonnie Watson Coleman, Rep. Gregory Meeks, Rep. Albio Sires, Rep. Nanette Diaz Barragán, Rep. Dwight Evans, Rep. Betty McCollum, Rep. Zoe Lofgren, Rep. Jerry Nadler, Rep. Jan Schakowsky, Rep. Raskin, Rep. McGovern, Rep. Ted W. Lieu, Rep. Bobby Rush, Rep. Pingree, Rep. Grace Meng, Rep. Adam Smith, Rep. Huffman, Rep. Fudge, Rep. Colleen Hanabusa, Rep. Donald M. Payne, Jr, Rep. Tony Cárdenas, Rep. Matt Cartwright, Rep. Pete Visclosky, Rep. Jimmy Gomez, Rep. Jackie Speier, Rep. Grace Napolitano, Rep. Seth Moulton, Rep. Katherine Clark.

Tell Congress to stop the Trump administration from opening the floodgates to permit widespread use of antibiotics in citrus production (grapefruits, oranges and tangerines). 

Despite the building national and international crisis of deadly bacterial resistance to antibiotics, this new allowance would expand on an emergency use decision the Environmental Protection Agency made in 2017. It permits up to 480,000 acres of citrus trees in Florida to be treated with more than 650,000 pounds of streptomycin per year; 23,000 citrus acres in California will likely be treated annually. 

The World Health Organization has called bacterial resistance “one of the biggest threats to global health, food security, and development today.” 

>> Tell your U.S. Representative and Senators to urge EPA to reject the use of antibiotics in food production, including citrus production.

The two approved antibacterial chemicals to be used as pesticides in citrus production are streptomycin and oxytetracycline. Their use was permitted by the U.S. Environmental Protection Agency (EPA) under an emergency exemption in May, 2017 for a citrus greening disease caused by the bacterium Candidatus Liberibacter asiaticus (CLas) in Florida citrus crops through December of 2019.

The Environmental Protection Agency announced March 15, “EPA is issuing these tolerances without notice and opportunity for public comment as provided in FFDCA [Federal Food, Drug and Cosmetic Act] section 408(l)(6).” EPA states, “[T]ime-limited tolerances are established for residues of streptomycin in or on fruit, citrus, group 10-10, at 2 ppm, and the dried pulp of these commodities at 6 ppm.” For oxytetracycline, EPA is allowing residues “in or on all commodities of fruit, citrus, group 10-10, at 0.4 ppm.” [See below; organic standards do not allow antibiotic use.] Now, EPA is moving forward with a permanent allowance of these chemicals. 

In addition, both the active and inert ingredients in common herbicides advance antibiotic resistance. Learn more about the history of Resistance and Antibiotics by visiting Beyond Pesticides' Antimicrobials and Antibacterials program page.  Pose the question to policy makers: Will we now see an “Antibiotics rebellion”?

Beyond Pesticides, with other organizations, led a successful effort to remove antibiotics from organic apple and pear production because of their contribution to antibiotic resistance and the availability of alternative practices and inputs.

As bacteria become resistant to the most commonly prescribed antibiotics, the results are longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. The development and spread of antibiotic resistance is the inevitable effect of antibiotic use. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance. Both antibiotics proposed for expanded use are important for fighting human disease. Tetracycline is used for many common infections of the respiratory tract, sinuses, middle ear, and urinary tract, as well as for anthrax, plague, cholera, and Legionnaire's disease, though it is used less frequently because of resistance. Streptomycin is used for tuberculosis, tularemia, plague, bacterial endocarditis, brucellosis, and other diseases, but its usefulness is limited by widespread resistance (U.S. National Library of Medicine, 2006).

Exposure to antibiotics can disturb the microbiota in the gut. In addition to interfering with digestion, a disrupted gut microbiome can contribute to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. Furthermore, the human immune system is largely composed of microbiota.

>> Tell your Senators and Representative to urge EPA to reject the use of antibiotics in food production, including citrus production.

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As the dust settles on the final Farm Bill, which passed the U.S. Senate and House of Representatives last month, it is clear that neither the substance nor the process on a range of issues meet the urgent need to address key sustainability issues that put the future in peril.  

We must not allow this Farm Bill to be the final word on a number of critical environmental issues facing the nation and world. That is why it is absolutely critical that we get to work immediately, with the new Congress, to set a new course that transforms the institutions of government that are holding back the urgently needed transition to a green economy.

>> Tell your Senators and Representative to support a Green New Deal that restructures food and agriculture programs.

On the Farm Bill, our victories were mostly measured in terms of what we were able to remove from the Farm Bill—not the standard of achievement that we need to face critical environmental threats.

The good. Our major victory in the Farm Bill does not move us forward, but simply protects the status quo of our democracy—protecting the power of states and local government to adopt pesticide restrictions that are more stringent than the federal government. With your help and the help of a broad network of local officials nationwide, we were able to stop a preemption provision from being inserted in the federal pesticide law. Although the victory was in defeating this provision, the chemical industry has awakened a new front in the pesticide reform movement. As a result of this provision, there is new momentum to reassert the rights of local governments and repeal state-level preemption of municipalities. Other environmental setbacks to the Endangered Species Act, Clean Water Act, and farmworker protection were taken out of the final bill. So, thank you to all who participated in this important process.

The bad. We were unable to remove an amendment to organic law that introduces confusion on the mandate to sunset all synthetics used in organic agricultural production and processing, forcing the National Organic Standards Board (NOSB) and USDA to reassess the science and necessity of these inputs with the most rigorous scrutiny by requiring a super-majority vote of the board every five years to allow continued use of these synthetics—the same standard used when synthetics are initially petitioned. The growth of organic is essential to solving our key environmental challenges, from the dramatic decline in biodiversity to global climate change. Nothing should be done to undercut the integrity of the organic standard setting process. Additionally, new language in the organic law allows farmer, handler, and retailer positions on the NOSB to be filled by employees of farmers, handlers, and retailers, making the decision making process less robust.

The ugly. The Farm Bill sets policy on food and farm issues for the next five years and should not be the result of backroom negotiations in Congress, as it was this round. Important and controversial issues deserve public hearings in which all members of Congress and the public can participate, and all perspectives can be heard.

More on organic. There were some “wins” for organic in continued funding for programs important to organic production and research, and necessary improvements to oversight and enforcement of organic imports.

New leadership. Increasing support is being shown for a proposal by U.S. Representative Alexandria Ocasio-Cortez of New York to form a House Select Committee for a Green New Deal that addresses economic and environmental reforms while ensuring a functioning democracy. A Green New Deal  provides a framework for supporting agriculture that helps farmers, consumers, and the environment by advancing organic agriculture. In the words of commentator and former Texas Agriculture Commissioner Jim Hightower, “Everybody does better when everybody does better.” We need new food and farm policy that benefits all farmers and consumers.

>> Tell your Senators and Representative to support a Green New Deal that restructures food and agriculture programs.