Action of the Week Archive

The toxic herbicide dicamba is once again at the center of a larger story about states’ authority to regulate pesticides more stringently than federal dictates and a response to corporate corruption in the marketing of pesticide products. The Trump EPA (U.S. Environmental Protection Agency) has just made it much harder for state regulations to be more protective than federal rules. It did so via a footnote embedded in dozens of pages of regulatory documents related to EPA’s registration of three new dicamba products. 

>>Tell the Biden transition team that EPA must respect states’ rights to protect people and property in their states.

Meanwhile, a report by the Midwest Center for Investigative Reporting found Monsanto and BASF, a German chemical company that worked with Monsanto to launch the system coupling dicamba with resistant crops, knew their dicamba herbicides would cause large-scale damage to fields across the U.S., but decided to push them on unsuspecting farmers anyway, in a bid to corner the soybean and cotton markets with their dicamba-resistant seeds.

For nearly 30 years, state regulators have used Section 24 (“Special Local Needs” section) of FIFRA, the Federal, Insecticide, Fungicide and Rodenticide Act—the law that gives EPA authority to regulate pesticides—to establish specific restrictions, on use of federally registered pesticide products, that go beyond the restrictions mandated by EPA. Like other federal laws, FIFRA allows states room for stronger regulation. EPA has long allowed states to add to the edicts of federal pesticide labels in order to protect workers, crops, and/or the environment under particular local circumstances. However, Section 24 had historically been used to expand allowed labeled uses of pesticides when existing products with their crop restrictions are no longer effective. 

Two subsections of Section 24 are at issue. Section 24(a) allows states to “regulate the sale or use of any federally registered pesticide or device in the State, but only if and to the extent the regulation does not permit any sale or use prohibited by this Act.” Section 24(c) allows states to “provide registration for additional uses of federally registered pesticides formulated for distribution and use within that State to meet special local needs in accord with the purposes of this Act and if registration for such use has not previously been denied, disapproved, or canceled by the Administrator.”

Although a straightforward reading of FIFRA leads to the conclusion—one that EPA is now supporting—that 24(a) should be used to limit a pesticide’s use, and 24(c) to expand uses, EPA has never issued regulations or guidance for the application of 24(a) and has historically directed states to 24(c) when they sought to restrict a pesticide’s use, as several states have done with dicamba. For several decades, EPA has construed 24(c) to mean that states can establish more-restrictive regulations than the federal. Indeed, in 1996, it published this as guidance for states. In the past few years, especially, as EPA has failed to enact constraints on the uses of dicamba, which has caused massive devastation to nontarget crops and trees (as well as to wildlife), many states have moved to establish additional controls on the pesticide’s use.

Since EPA has never published regulations or guidance concerning use of Section 24(a), it is clear that the current action is designed to limit the ability of states to restrict the use of pesticides when EPA has failed to ensure safety.

A number of states, including Indiana, Minnesota, Missouri, South Dakota, North Dakota, Illinois, and Arkansas, have instituted restrictions on dicamba use that surpass those accompanying the federal registration of the compound. Texas, Iowa, Georgia, Kentucky, Alabama, and North Carolina are all eyeing 24(c) requests for stricter-than-federal controls for tighter application windows, additional training requirements, better record keeping, new fine structures for violations, and other modifications of the federal label.

This new (and stealthily announced) EPA impediment to states’ ability to create additional constraints hinges on the agency’s decision to reinterpret what states can do under Section 24(c) of FIFRA. EPA confirmed that the subject footnote represents an official policy change, saying, “EPA has determined that moving forward, EPA may disapprove any state registrations under FIFRA section 24(c) that further restrict use of pesticides registered by EPA, regardless of the chemicals involved. If a state wishes to further restrict use of a pesticide, they must do so under section 24(a) of FIFRA.”

Although some have interpreted this change to mean that state regulators will now have to navigate state legislative or rulemaking processes to use Section 24(a) in order to enact such protections, EPA has not adopted regulations or guidance for implementation of 24(a), so it appears that it is up to states to decide how to use it, as with dicamba, to control the timing, nature, location, or quantity of applications of the pesticide in efforts to diminish the damage it causes to nontarget plants and organisms. In addition, this reversal by EPA overturns decades of precedent, and as Progressive Farmer reports, “breaks EPA’s past promises to the states and threatens to damage the longstanding cooperative relationship between federal and state regulators.”

Although EPA did foreshadow this change in March 2019, state regulators are feeling blindsided. Back then, EPA announced — during one wave of state additions to federal labels on dicamba — that it might alter its handling of states’ requests to enact stricter controls, claiming that the actual language of 24(c) allows states only to permit additional uses of a federally registered pesticide.

EPA said at the time, “Due to the fact that section 24(a) allows states to regulate the use of any federally registered pesticide, and the fact that some states have instead used 24(c) to implement cut-off dates (and/or impose other restrictions), EPA is now re-evaluating its approach to reviewing 24(c) requests and the circumstances under which it will exercise its authority to disapprove those requests.” State regulators reacted to this announcement with great concern: officials from 10 different states urged EPA not to adopt the policy change, as did the National Association of State Departments of Agriculture and the Association of American Pesticide Control Officials (AAPCO).

Here’s where the blindsiding arises: EPA Office of Pesticide Programs director Rick Keigwin said, alongside the 2019 announcement, that no changes would be made to the agency’s 24(c) interpretation without the input of state regulators. “Before adopting any changes in this regard, we will solicit public comment on our proposed new approaches,” he wrote in the spring and summer of 2019. “We look forward to a robust public dialogue with our stakeholders, partners and co-regulators on this matter.”

But that did not happen, state regulators report. “There was no public comment period, no consultation,” said Leo Reed, an Indiana pesticide regulator and president of AAPCO. The existing guidance on 24(c) remains on the EPA website, creating confusion and a “legal limbo” for state regulators. Brook Duer, a staff attorney at Penn State’s Center for Agricultural and Shale Law, opined that even if the literal text of 24(c) comports with EPA’s new interpretation, the decades-old, published interpretation and guidance represent a “binding norm” under federal administrative law. He commented: “So unilaterally reversing it through a footnote, without a more transparent and public process—like what EPA previously represented would be undertaken—is certainly unorthodox and may even create the basis for litigation to prevent the reversal.”

Despite controversy over the rights of local governments to set stricter limits on pesticide use, there is not controversy over the legal rights of states to do so. In fact, some states—most notably California—have extensive pesticide regulatory programs. Since EPA has allowed the blatant abuse by Monsanto/BASF—in purposely using drift damage to force farmers to buy its seeds—states must be allowed to protect their citizens and environment when EPA fails.

>>Tell the Biden transition team that EPA must respect states’ rights to protect people and property in their states.

Letter to EPA Transition Team

In view of the many steps backwards taken by the Trump EPA, it is important to preserve the rights of states to issue more stringent regulations. The Trump EPA has just made it much harder for states to be more protective than EPA—via a footnote embedded in dozens of pages of regulatory documents related to EPA’s registration of three new dicamba weed killer products. This change hurts farmers and consumers.

For nearly 30 years, state regulators have used Section 24 of FIFRA, the Federal, Insecticide, Fungicide and Rodenticide Act to establish specific restrictions on use of federally registered pesticide products that go beyond those mandated by EPA. Like other federal laws, FIFRA allows states room for stronger regulation. EPA has long allowed states to add to the edicts of federal pesticide labels in order to protect workers, crops, and/or the environment under particular local circumstances.

Two subsections of Section 24 are at issue. Section 24(a) allows states to “regulate the sale or use of any federally registered pesticide or device in the State, but only if and to the extent the regulation does not permit any sale or use prohibited by this Act.” Section 24(c) allows states to “provide registration for additional uses of federally registered pesticides formulated for distribution and use within that State to meet special local needs in accord with the purposes of this Act and if registration for such use has not previously been denied, disapproved, or canceled by the Administrator.”

Although a straightforward reading of FIFRA leads to the conclusion—one that EPA is now supporting—that 24(a) should be used to limit a pesticide’s use, and 24(c) to expand uses, EPA has never issued regulations or guidance for the application of 24(a) and has historically directed states to 24(c) when they sought to restrict a pesticide’s use, as several states have done with dicamba due to widespread crop damage associated with the herbicide’s use. In the past few years, as EPA has failed to enact constraints on the uses of dicamba, which has caused massive devastation to nontarget crops, trees, and wildlife, many states have moved to establish additional controls on its use.

Since EPA has never published regulations or guidance concerning use of Section 24(a), it is clear that the current action is designed to limit the ability of states to restrict the use of pesticides when EPA has failed to ensure safety. Meanwhile, it has been disclosed that Monsanto and BASF, partners in developing the system coupling dicamba with herbicide-tolerant crops, knew their dicamba herbicides would cause large-scale damage to fields across the United States, but decided to push them on unsuspecting farmers anyway, in a bid to corner the soybean and cotton markets with their dicamba-resistant seeds.

Several states, including IN, MN, MO, SD, ND, IL, and AR, have instituted restrictions on dicamba use that surpass federal registration requirements. TX, IA, GA, KY, AL, and NC are all eyeing 24(c) requests for tighter application windows, additional training requirements, better record keeping, new fine structures for violations, and other modifications of the federal label.

This new (and stealthily announced) EPA impediment to states’ ability to create additional constraints hinges on the agency’s decision to reinterpret what states can do under Section 24(c) of FIFRA. EPA confirmed that the subject footnote represents an official policy change, saying, “EPA has determined that moving forward, EPA may disapprove any state registrations under FIFRA section 24(c) that further restrict use of pesticides registered by EPA, regardless of the chemicals involved. If a state wishes to further restrict use of a pesticide, they must do so under section 24(a) of FIFRA.”

I urge you, in making the move to a revitalized EPA, to ensure that states have the right to issue stronger protections for their farming communities.

Thank you.

Tell Vilsack to Move Forward, Meet Challenges, Correct the Past

As the President-elect chooses the leadership in his administration, it is critical that we in the affected communities establish our expectations of what is needed from agencies to address critical issues of the day. While we may feel that different choices of personnel could have been made, ultimately, we are looking forward to advancing programs across all agencies that represent meaningful and foundational changes to our social, economic, and environmental norms. As we focus on the appointment of a Secretary of Agriculture, issues of foundational change come into sharp focus, relating to sustainable land management, distribution of resources and access to land, food security, protection of human and ecosystem health, and climate. It is normal, therefore, to look at any individual appointee's past performance and positions as a measure of future decisions or policies that may be advanced.

Ultimately, though, it is the administration that sets the tone, establishes a framework, and forges the direction of the government's programs and policies. President-elect Biden has talked about a framework for policy to which we can and must hold all officials in the administration accountable across all agencies. These key elements of the framework intersect with the protection of health and the environment (including agriculture): (i) science-based decision-making, (ii) systemic change to solve societal problems, (iii) phase out of fossil fuel, and (iv) fight against environmental racism with disproportionate risk imposed on people of color.

>> Tell Mr. Vilsack what's expected at USDA.

Judging from his past record, President-elect Biden's announced pick for Secretary of Agriculture, Tom Vilsack, will need to dramatically change many previous positions in order to implement the elements of President-elect Biden's policy framework. Within this framework, the overall policy priorities of the President-elect include addressing the climate crisis, racial equity, COVID-19, and economic recovery. His “Plan for Rural America” includes helping family farms and other small and medium-sized farms, building a clean energy future, advancing racial equity in rural America, expanding protections for farmworkers, ensuring adequate health care in rural areas, and conserving public lands. These priorities cannot be achieved with chemical-intensive farming practices that rely on petroleum-based pesticides, fertilizers, and bioengineered crops, or continued support for corporate industrial agriculture that undermines the health of people and communities. Therefore, a systemic shift to organic agriculture will be required to meet these priorities.

Organic agriculture practices combat the climate crisis by:

• Reducing Emissions of Nitrogen Oxides. Excessive use of nitrogen fertilizers in chemical-intensive agriculture is driving global nitrous oxide (N2O) emissions higher, putting the world at greater risk of a climate catastrophe, and failure to adequately address nitrous oxide emissions has the potential to impede the ability for the world to keep warming below the 2°C target established under the Paris Climate Agreement, necessitating further cuts in other greenhouse gasses. 
• Sequestering carbon. Regenerative organic systems, which eliminate toxic, petroleum-based pesticides that kill microbial life in the soil, sequester significant amounts of carbon from the atmosphere into on-farm soil carbon and could sequester more than 100% of current annual CO2 emissions. 
• Preserving natural lands and biodiversity. Natural forests are more effective than tree plantations in sequestering carbon. Preserving natural land increases biodiversity, which also reduces dependence on petroleum-based pesticides.

There is no racial justice without environmental justice, and this is particularly true in agriculture. In chemical-intensive agriculture, farmworkers are exposed to toxic agricultural chemicals. Farmworkers are predominately people of color, and dangers to them are discounted in the risk assessments used in the registration of pesticides. Materials used in organic agriculture must not endanger humans or the environment, but non-organic foods—even those with low residues of pesticides on the product—endanger workers and the environment.

Organic food offers greater health benefits in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally significant. Organic dairy products contain significantly higher beneficial fatty acids, antioxidants and vitamins. Organic food production prohibits toxic pesticide use, as distinguished from chemical-intensive agriculture and reduces existing levels of pesticides detected in children and adults. Drinking organic milk can eliminate exposure to pesticide, antibiotic, and synthetic growth hormone residues in those dairy products.

Organic farming is good for the economy. It is more resilient and buffered from economic risk, compared to chemical-intensive agriculture. Greater crop diversity, as required by organic standards, contributes to greater agricultural employment.

Mr. Vilsack, who served as Secretary of Agriculture in the Obama administration, allowed the weakening of organic review procedures by the National Organic Standards Board (NOSB), ignored several NOSB recommendations, and advanced “coexistence” with the expansion of genetically engineered (GE) crops that are responsible for genetic drift, polluting non-GE and organic crops. The expansion of GE crops led to an explosion of glyphosate (Roundup) use, widespread food contamination, as well as the growth of dicamba and 2,4-D, which resulted in vast crop damage and contamination from drift throughout the Midwest. This growth in GE crops has led to insect and weed resistance to pesticides, increased reliance on toxic chemicals, destruction of wildlife habitat, and economic harm to farmers. As Branko Marcetic wrote for In These Times, "While his tenure wasn't uniformly bad—Vilsack resisted Republican attacks on food stamps and upped federal support for organic food—he angered progressive groups by letting poultry factories self-regulate, speeding up the approval process for GMO crops, shelving new regulations on big agriculture at the industry's behest, and stepping in to craft an industry-friendly national GMO-labeling bill intended to replace a pioneering stricter standard in Vermont."

In addition, his record on racial justice has been criticized by the National Black Food and Justice Alliance (NBFJA), National Black Farmers Association, USDA Coalition of Minority Employees, and others. The NBFJA points to actions taken under Vilsack's previous leadership: 

• Routine denial of loans to Black farmers that were easily obtained by white farmers and decreased the overall dollars loaned to Black farmers; 
• Failure to take discrimination complaints seriously; 
• Foreclosure of Black farmers who had pending discrimination complaints; 
• Failure to adequately compensate Black farmers with valid claims; 
• Wrongfully forcing out Shirley Sherrod, the former head of USDA rural development in Georgia and a well-respected civil rights leader; 
• Prioritizing the profits of the poultry industry over the health and safety of working people and families; and 
• Collusion in the distortion of data regarding race, farming, and land.

Mr. Vilsack is currently president and CEO of the U.S. Dairy Export Council, which promotes the sale of conventional, chemical-intensive dairy products—typically produced by factory farms. The Council's literature gives a misleading description of sustainable and regenerative agriculture. Will Mr. Vilsack support strong organic dairy standards?

>> Tell Mr. Vilsack what's expected at USDA.

Letter to Mr. Vilsack

With your appointment to Secretary of Agriculture in the Biden administration, I appreciate your commitment to government service and would like you to open a dialogue on critical issues to the future health of our agricultural system, the people who labor in it, and the environment in which it operates. President-elect Biden has set an important framework in which to make transformational changes in confronting existential crises that directly intersect with agriculture. Key elements of the framework that intersect with the protection of health and the environment (including agriculture) are: (i) science-based decision-making, (ii) systemic change to solve societal problems, (iii) phase out of fossil fuel, and (iv) fight against environmental racism with disproportionate risk imposed on people of color.

Within this framework, the overall policy priorities of the President-elect include addressing the climate crisis, racial equity, COVID-19, and economic recovery. His “Plan for Rural America” includes helping family farms and other small and medium-sized farms, building a clean energy future, advancing racial equity in rural America, expanding protections for farmworkers, ensuring adequate health care in rural areas, and conserving public lands. These priorities cannot be achieved with chemical-intensive farming practices that rely on petroleum-based pesticides, fertilizers, and bioengineered crops, or continued support for corporate industrial agriculture that undermines the health of people and communities. Therefore, a systemic shift to organic agriculture will be required to meet these priorities by:

- Reducing Emissions of Nitrogen Oxides. Failure to adequately address nitrous oxide emissions may impede the ability for the world to keep warming below the 2°C target established under the Paris Climate Agreement.

- Sequestering carbon. Regenerative organic systems sequester significant amounts of carbon from the atmosphere into soil carbon.

- Preserving natural lands and biodiversity. Natural forests help sequester carbon and reduce dependence on petroleum-based pesticides.

You are certainly aware that there have been points of disagreements with policy positions, relating to action and inaction on critical issues. I am terribly concerned about allowing the weakening of organic review procedures by the National Organic Standards Board (NOSB), ignoring NOSB recommendations to strengthen organic integrity, while promoting “coexistence” with the expansion of genetically engineered (GE) crops that are responsible for genetic drift, polluting non-GE and organic crops. As I hope you’re aware, the expansion of GE crops led to an explosion of glyphosate (Roundup) use, widespread food contamination, as well as the growth of dicamba and 2,4-D, which resulted in vast crop damage and contamination from drift throughout the Midwest. This growth in GE crops has led to insect and weed resistance to pesticides, increased reliance on toxic chemicals, destruction of wildlife habitat, and economic harm to farmers. As Branko Marcetic wrote for In These Times, "While his tenure wasn't uniformly bad—Vilsack resisted Republican attacks on food stamps and upped federal support for organic food—he angered progressive groups by letting poultry factories self-regulate, speeding up the approval process for GMO crops, shelving new regulations on big agriculture at the industry's behest, and stepping in to craft an industry-friendly national GMO-labeling bill intended to replace a pioneering stricter standard in Vermont."

I appreciate the mandate of the new administration to think big and take on structural problems with systemic changes. In this context, I look forward to working with you to urgently address the existential threats to health, environment, racial equity, and economic security associated with current agricultural policy and practices.

Thank you.

Once numbering in the millions, barely 29,000 western monarch butterflies were found in California at last count. Pesticides pack a one-two punch against monarchs. Insecticides—particularly neonicotinoids—poison the caterpillars and butterflies as they feed. Glyphosate—the active ingredient in Bayer-Monsanto's Roundup® — is wiping out milkweed, the only food source for monarch caterpillars. This has contributed to monarchs' 90% decline in the past 20 years alone. They could vanish within our lifetimes.

Home and garden stores like Lowe's and Home Depot can play a huge role in ending the use of this toxic pesticide in our backyards and across the country. Already, Lowe's is removing neonicotinoid products from its live plant offerings and store shelves, and Home Depot is eliminating use of neonicotinoids in its live plant offerings. They could stop selling Roundup®. More importantly, they could encourage organic practices through their product offerings and consumer education.

>>Ask Home Depot and Lowe's to get Roundup® off their shelves and promote and educate on organic!
 
Companies like Lowe's and Home Depot could be leaders by removing products containing glyphosate/Roundup® from their physical stores and online—following the example of their competitor, Costco. This would send a powerful message to Bayer that it must phase out this harmful chemical. Instead of replacing Bayer-Monsanto's Roundup® with other toxic products, garden retailers can facilitate a switch to organic by educating consumers and increasing offerings of organic-compatible and other safer alternatives. 

Organic alternatives work within an organic system that includes practices that build soil, cycle nutrients naturally, and increase biodiversity—including soil-building organisms, pollinators, and predators and parasites of plant-eating insects. Attempting to sell organic products as stand-alone “silver bullet” solutions dooms customers to failure, while educating them about the role of those products in an organic system will bring them back for more.

In the absence of effective regulation by the Trump Administration, we need garden retailers to act responsibly. Customers like you played a key role in convincing Home Depot and Lowe's to protect pollinators by committing to stop selling plants grown with bee-killing neonicotinoid pesticides. Now, you can push them to take another vital step in pollinator protection. 

>>Ask Home Depot and Lowe's to get Roundup® off their shelves and promote and educate on organic!

Roundup has been marketed by Bayer/Monsanto as effective and safe, but, in reality, its use delivers human and ecosystem harms. Exposures to it threaten human health (including transgenerational impacts) and the health of numerous organisms. In addition, many target plants are developing resistance to the compound, making it increasingly ineffective as a weed killer, and resulting in ever-more-intensive pesticide use. Glyphosate was classified in 2015 by the International Agency for Research on Cancer (IARC) as a probable human carcinogen.

Last year, a jury ordered Bayer to pay $2 billion to a couple who used glyphosate on their lawn for decades and who both suffered from non-Hodgkin lymphoma. Over 52,000 similar court cases are pending. But instead of removing this product from store shelves, Bayer-Monsanto is trying to settle the lawsuits and keep selling this toxic pesticide. Under the terms of the deals, Roundup® would continue to be sold in the U.S. without any safety warning. 

In light of the increasing evidence of the harm glyphosate can cause, some countries have stepped up restrictions or instituted bans on use of the compound, including Italy, Germany, France, Bahrain, Kuwait, Qatar, Saudi Arabia, United Arab Emirates, Bermuda, Fiji, Luxembourg, and Austria. A growing number of jurisdictions in some countries have taken similar actions. In the U.S., counties, towns, and cities, including Los Angeles, Seattle, and Miami, and many others in California, Florida, Illinois, Maryland, Massachusetts, New York, Washington State, and more, have banned glyphosate applications on public lands. The New York State legislature banned glyphosate last month.

The solution to the current federal “whack-a-mole” approach to mitigating the impacts of glyphosate (and all toxic pesticide) use is a wholesale transition away from the chemical dousing of public lands, agricultural fields, and all manner of maintained turf. Organic approaches to insect, weed, and fungal problems in agriculture and on other lands and landscapes (and in homes, gardens, buildings, et al.) do not involve toxic pesticides, and avoid the health and ecological damage they cause.

In addition to being genuinely protective of human health, organic management systems support biodiversity, improve soil health, sequester carbon (which helps mitigate the climate crisis), and safeguard surface and groundwater quality.

Bayer-Monsanto won't protect butterflies, bees and our health on its own. Garden retailers, with Lowe's and Home Depot leading the way, can help shrink the market for glyphostate/ Roundup® and help keep it out of our backyards and communities, while educating consumers on gardening and land management with an organic systems approach. 

Remind garden retailers they have an important role to play — let them know our health is more important than Bayer's profits.

Letter to Home Depot and Lowe's

Home and garden stores like yours can play a huge role in ending the use of this toxic pesticide in our backyards and across the country. Your step to eliminate use of neonicotinoids in live plant offerings helps protect monarchs and other pollinators. I am writing to ask you to stop selling glyphosate products such as Roundup®—as Costco has done—and encourage organic practices through product offerings and education.

Once numbering in the millions, barely 29,000 western monarch butterflies were found in California at last count. Pesticides pack a one-two punch against monarchs. Insecticides—particularly neonicotinoids—poison the caterpillars and butterflies as they feed. Glyphosate—the active ingredient in Bayer-Monsanto’s Roundup®—is wiping out milkweed, the only food source for monarch caterpillars. This has contributed to monarchs’ 90% decline in the past 20 years alone. They could vanish within our lifetimes.

Roundup has been marketed as effective and safe, but, in reality, its use delivers human and ecosystem harms. Exposures to it threaten human health (including transgenerational impacts) and the health of numerous organisms. In addition, many target plants are developing resistance to the compound, making it increasingly ineffective as a weed killer, and resulting in ever-more-intensive pesticide use. Glyphosate was classified in 2015 by the International Agency for Research on Cancer (IARC) as a probable human carcinogen.

Last year, a jury ordered Bayer to pay $2 billion to a couple who used glyphosate on their lawn for decades and who both suffered from non-Hodgkin lymphoma. Over 52,000 similar court cases are pending. But instead of removing this product from store shelves, Bayer-Monsanto is trying to settle the lawsuits and keep selling this toxic pesticide. Under the terms of the deals, Roundup® would continue to be sold in the U.S. without any safety warning.

Customers ask you for advice. In addition to removing glyphosate products from your shelves, your stores should advise customers to use organic alternatives. Organic alternatives work within an organic system that includes practices that build soil and increase biodiversity—including soil-building organisms, pollinators, and predators and parasites of plant-eating insects. Attempting to sell organic products as stand-alone “silver bullet” solutions dooms customers to failure, while educating them about the role of those products in an organic system will support nature organic land management and organic-compatible products.

We are living during a period that requires retailers, like you, to take responsible action in the face of inadequate federal toxic pesticide restrictions, despite the availability of environmentally responsible practices and products. We urge you to be a responsible retailer by taking glyphosate/Roundup® off your shelves and educating consumers on organic gardening and land management with organic-compatible products.

Thank you for considering my request and promoting good health through organic lawns and gardens.

(Beyond Pesticides, December 7, 2020) The Trump Environmental Protection Agency (EPA) reversed in four years much of the progress made by EPA in decades, and that push continues. The Biden EPA needs to advance a new vision.

Tell President-elect Biden to adopt a new direction for pesticide regulation.

Challenge so-called “benefits” of pesticides.
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. Claimed “benefits” for toxic pesticides need to be judged in comparison to organic production, which is able to produce all types of food and feed. The Organic Trade Association reports that organic sales now exceed $55 billion per year, and the U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $9.9 billion worth of organic food on 5.5 million acres in 2019. EPA assumes benefits of pesticides, rather than measuring them, and does not take into account the development of resistance. The cost-competitive success of organic food production and nonagricultural land management practices make the case that toxic pesticides lack benefits.

Protect pollinators.
Agriculture relies on insect pollinators to facilitate fertilization and maintain annual crop yield. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet many agricultural pesticides are killing pollinators outright, making them more susceptible to parasites and disease, and destroying their habitat. Pollinator protection should be a priority of EPA.  

Protect workers.
Farmworkers are at greatest risk from pesticide exposure. A blatant example of systemic racism is imbedded in risk assessments in environmental regulation. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. For example, EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—and such exposures routinely occur to fenceline communities, farmworkers, and factory workers.

Protect biodiversity.
Roughly a quarter of the global insect population has been wiped out since 1990, according to research published in the journal Science. Monarchs are near extinction and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies, the foundation of so many food chains, and fireflies, the foundation of so many childhood summer memories, for reasons that can be easily prevented with leadership in regulating pesticides. It is likely that the declines we are seeing in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, has been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. Amphibians are also particularly at risk. A new biological evaluation by EPA finds that the widely used weed killer glyphosate/Roundup threatens nearly every animal and plant species on the U.S. list of threatened and endangered species — 93% of them, in fact. This, on top of its cancer-causing properties, supports urgent action to ban the herbicide along with others that destroy habitat and replace them with organic practices and organic compatible products.

Get rid of endocrine-disrupting pesticides.
Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. In 1998, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 21 years, the Endocrine Disruptor Screening Program (EDSP) has made little progress in reviewing and regulating endocrine-disrupting pesticides. Now the program has stalled entirely.

To ensure appropriate follow-through, Congress gave EPA a timeline to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. It started a screening program (Tier 1) and reported results in 2009. According to EPA, Tier 1 Screening (which looks at high exposure chemicals) is not sufficient to implicate a chemical as an endocrine disrupting chemical. It is instead a step to define which chemicals must undergo Tier 2 testing – the only stage that can influence regulatory decision-making. It is unclear when or how EPA will move forward with Tier 2 testing, and how, if at all, any Tier 2 findings will be used to inform actual regulation.

Get rid of neurotoxic pesticides that harm children. 
The target of action by which many pesticides kill is the nervous system. It is not surprising, then, that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides (relative to their body weight) than adults, and whose developing organ systems are typically more sensitive to toxic exposures.

The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child’s neurological, respiratory, immune, and endocrine system, even at low exposure levels. Several pesticide families, such as synthetic pyrethroids, organophosphates, and carbamates, are also known to cause or exacerbate respiratory symptoms like asthma. The American Academy of Pediatrics wrote, “Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.”

And yet the Trump EPA has refused to ban the extremely neurotoxic insecticide chlorpyrifos—an action that was begun during the waning days of the Obama administration. Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA’s action to allow its continued use a failure of both its protective mission and ethics. Further, it is an environmental justice failure, given that risks of exposure fall disproportionately on low-income African American and Latino families, including farmworker families, who are at the greatest risk of harm. The ban on chlorpyrifos will be an important first step in eliminating neurotoxic pesticides.

Tell President-elect Biden to adopt a new direction for pesticide regulation.

Letter to President-elect Biden

I am writing to offer suggestions for priority policies and actions for your incoming EPA, in the area of pesticide regulation. Pesticide regulation needs a change of direction.

Challenge so-called “benefits” of pesticides. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. The standard for claimed “benefits” for toxic pesticides organic production. USDA finds that organic producers in the U.S. produced $9.9 billion worth of organic food in 2019. EPA assumes benefits, rather than measuring them, and does not take into account the development of resistance.

Protect pollinators. Agriculture relies on insect pollinators for fertilization and annual crop yields. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet many agricultural pesticides kill pollinators outright, make them more susceptible to parasites and disease, and destroy their habitat.

Protect workers. Farmworkers are at greatest risk from pesticide exposure. Systemic racism is imbedded in environmental risk assessments. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA excludes worker exposure. Risk assessments do not include exposures to multiple chemicals—that routinely occur to fenceline communities, farmworkers, and factory workers.

Protect biodiversity. Roughly a quarter of the global insect population has been wiped out since 1990. It is likely that declines in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, have been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. EPA finds that the widely used weed killer glyphosate/Roundup threatens 93% of animal and plant species on the U.S. list of threatened and endangered species. This, on top of its cancer-causing properties, supports a ban on the herbicide along with others that destroy habitat.

Get rid of endocrine-disrupting pesticides. Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. EPA is stalled and ignoring its responsibility.

Get rid of neurotoxic pesticides that harm children. The target of action by which many pesticides kill is the nervous system. It is not surprising, then that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides (relative to their body weight) than adults, and whose developing organ systems are typically more sensitive to toxic exposures.

And yet, the Trump EPA has refused to complete the ban of the extremely neurotoxic insecticide chlorpyrifos that was begun during the Obama administration. Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA’s action to allow its continued use a failure of its mission and an environmental justice, since risks of fall disproportionately on low-income African American and Latino families. The ban on chlorpyrifos will be an important first step in eliminating neurotoxic pesticides.

Under your leadership, a revitalized EPA will take our nation in a new direction—one that requires the agency to think holistically, shift away from petroleum-based pesticides, and fertilizers, and embrace solutions that protect ecosystems that sustain all life.

Thank you.

The “environment” is central to President-elect Biden’s priorities: climate change, COVID-19, and the next pandemic, racial equity, and economic recovery. The new administration should include an EPA administrator who understands the relationships among these and other environmental issues and has a clear vision of the changes needed to dramatically change our course, currently heading for ecological destruction.

Tell President-elect Biden to appoint an EPA Administrator who is an environmentalist with broad environmental credentials and a vision that embraces a dramatic transition away from hazardous chemicals and polluting practices at this perilous time.

Let’s start with what the past four years has taught us about who we do NOT want as EPA Administrator. We do not want an industry lobbyist, someone whose work has been funded with industry money, who has represented industry in litigation or as a lobbyist, who has attacked environmentalists, or has never read Silent Spring. Such a person is not qualified to provide the leadership needed to address priority issues and understand the interconnections necessary to address the crises associated with climate, health, and biodiversity decline.

On the other hand, a strong candidate will support holistic thinking, with an understanding of interrelationships in ecosystems. This requires an understanding of  1) the relationship between a healthy environment and a healthy economy; 2) disproportionate risk and environmental racism; 3) the importance of standing up to polluting industries; 4) the existential threats facing the country and the globe; and 5) the failure of risk assessment and unrealistic risk mitigation measures that poison people and the environment, and destroy life; and 6) the need for meaningful results, rather than politically expedient compromises.

Relationships Among Priorities and Relationship to Environment

Climate change has been shown to increase people’s susceptibility to COVID-19, disproportionately affect the low income and people of color, and pose a major threat to the economy. COVID-19 affects our response to climate emergencies, disproportionately affects minorities, and has had a severe impact on the economy. The data is clear that racial injustice is inextricably linked to the climate crisis, the disproportionate impact of the pandemic on black and brown essential workers, and an imbalanced economy that functions poorly in ensuring everyone an equitable share of United States wealth and promise. Because of this, environmental leadership must work hand-in-hand with economic decisions that affect sustainabilty—only sustainability can bring us solutions to the urgent issues of climate change, pandemics, and racial inequity. Currently, all environmental decisions are screened and controlled by the White House’s Office of Management and Budget, which fails to address the disparities that are causing unimaginable harm in the interest of “economic health.” We cannot achieve sustainability until we change our relationship with the “environment”—that is, the total biosphere of the Earth. An EPA administrator must be empowered to challenge these foundational problems.

Climate Change

President-elect Biden has prioritized climate change, having appointed John Kerry to the cabinet post of “Climate Envoy,” and is likely to choose someone who is strong on this issue to head EPA. Climate change, however, is affected by, and affects, other environmental and health concerns. It is important that the Biden EPA work across agencies to ensure a coordinated approach—so that industry production and use practices, individual and multiple chemicals effects, and background sensitivities associated with elevated risk factors can be addressed in the context of their interrelationships.

The leadership provided by this holistic analysis must prioritize the solutions as a replacement for polluting practices and widespread harm. For example, toxic pesticides kill nontarget organisms, including pollinators, soil micro- and macrofauna, predators and parasites of pests, and plants that support the agroecosystem, are unnecessary to achieve productive, cost competitive, and profitable food production, and can be replaced by organic agriculture. EPA leadership can and must question the reasonableness of the conventional wisdom that toxic chemical dependency (including fossil-fuel based toxic pesticides and synthetic fertilizers) is acceptable, given the viability and nontoxic practices. This can be achieved under current risk standards of most environmental laws with the appropriate leadership that takes seriously the existential threats that we face and the viability of alternatives that eliminate toxic practices. We have entered a period that requires toxic chemical and fossil fuel elimination, driven by communities across the country that understand the threats and are forcing a change in their community practices. We need leadership at the top of EPA that is willing to listen to local leaders and urgently change the path we are currently on.  

COVID-19

EPA has a number of responsibilities that affect the pandemic and the prevention of another future pandemic. Exposure to toxic chemicals—especially those affecting the respiratory, immune, and nervous systems—makes people more susceptible to the disease. EPA’s programs can recognize the threats to vulnerable population groups and tighten the reins on controlling how and when we use toxic chemicals—leading to a phase-out. In the case of disinfectants, EPA lists disinfectants that can be used to destroy the virus on surfaces, but has done so without providing information about the risks of using those disinfectants and the availability of safer materials.

Racial Equity

A blatant example of systemic racism is imbedded in risk assessments in environmental regulation. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. For example, EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—and such exposures routinely affect fenceline communities, farmworkers, and factory workers.

Work with Other Agencies

Achieving the goals expressed by President-elect Biden will require cooperation among agencies. While the Climate Envoy position is an important step forward, EPA must step up to fulfill its mandate and ensure our future and the future of following generations.

The EPA administrator must have the experience to regulate and the background to understand that it is critically and urgently important to:

• cooperate with USDA in considering the viability of organic agriculture in eliminating the use of toxic pesticides and fertilizers. Coordinating ecological management of forests with USDA will help in fighting climate change.
• work with the Department of the Interior (DOI) to facilitate the protection of natural areas, which serve as a carbon sink and assist in combating climate change. DOI can also assist in protecting indigenous cultures that have much wisdom to offer for protecting natural systems.
• work with the Department of Energy to ensure that our pursuit of energy sources supports life and protects our biosphere.
• intersect with the Food and Drug Administration on pharmaceuticals and other toxicants in waterways, Department of Health and Human Services on public health protections, the Fish and Wildlife Service on endangered species, U.S. Geological Survey in monitoring water quality, and the National Oceanic and Atmospheric Administration in climate and marine issues.

In order to solve the problems we are facing, we must stop treating EPA and other federal agencies as silos that work on discrete and isolated problems. In fact, readers of Beyond Pesticides Daily News know that the body of science screams for us to act on the confluence of issues that converge to threaten human life and sustainability of planet. Therefore, the new EPA Administrator should be a visionary with a holistic vision for a sustainable society and a livable future.

Tell President-elect Biden to appoint an EPA Administrator who is an environmentalist with broad environmental credentials and a vision that embraces a dramatic transition away from hazardous chemicals and polluting practices at this perilous time.

Letter to President-elect Biden

Dear President-elect Biden:

Congratulations on your election.

I ask that you appoint an administrator of the Environmental Protection Agency (EPA) who understands the relationships among environmental issues, with a clear vision of the changes needed to dramatically change our course away from ecological destruction.

The past four years have taught us who we do NOT want as EPA Administrator—someone whose work has been funded with industry money, represented industry in litigation or as a lobbyist, attacked environmentalists, never read Silent Spring. Such a person is not qualified to provide the leadership to address priority issues and understand the interconnections associated with climate, health, and biodiversity decline.

A strong candidate will support holistic thinking with an understanding of interrelationships in ecosystems—with an understanding of the relationship between a healthy environment and a healthy economy; disproportionate risk and environmental racism; the importance of standing up to polluting industries; the existential threats facing the country and the globe; the failure of risk assessment and unrealistic risk mitigation measures that poison people and the environment; and the need for meaningful results rather than politically expedient compromises.

The environment is central to your interrelated priorities of climate change, COVID-19, racial equity, and economic recovery. Climate change increases susceptibility to COVID-19, disproportionately affects the low income and people of color, and poses a major threat to the economy. COVID-19 affects climate emergency response, minorities, and the economy. Racial injustice is inextricably linked to the climate crisis, the disproportionate impact of the pandemic on essential workers, and an imbalanced economy.

An EPA administrator must be empowered to make environmental and economic decisions to achieve sustainability—necessary for solutions to the urgent issues of climate change, pandemics, and racial inequity and requiring a new relationship with the Earth.

Your priority of climate change is affected by, and affects, other environmental and health concerns. It is important to work across agencies to ensure a coordinated approach—both because they are important in their own right and because of their relationship to climate change. Cooperation among agencies is needed to promote organic agriculture, conserve natural areas and marine ecosystems, preserve indigenous cultures, and monitor resources.

EPA must prioritize solutions to replace practices causing widespread harm. Toxic pesticides kill nontarget organisms, including pollinators, soil micro- and macro-fauna, predators and parasites of pests, and plants that support the agroecosystem, are unnecessary for productive, cost competitive, and profitable food production, and can be replaced by organic agriculture. EPA leadership must thus question the reasonableness of conventional wisdom accepting toxic chemical dependency. EPA must listen to communities across the country that understand the threats and are changing their practices.

EPA’s responsibilities affect pandemics. Exposure to toxic chemicals—especially those affecting the respiratory, immune, and nervous systems—increases susceptibility to COVID-19. EPA lists disinfectants that can be used to destroy the virus on surfaces without information about their risks and the availability of safer materials.

Risk assessments contain a blatant example of systemic racism. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact on workers, people of color, and others at risk. For example, EPA does not include workers in calculating aggregate exposure to pesticides. Risk assessments do not include exposures to multiple chemicals—which routinely affect fenceline communities, farmworkers, and factory workers.

I look forward to a new EPA Administrator who is a visionary with a holistic vision for a sustainable society and a livable future.

Thank you.

The Biden transition plan for combatting climate change caused by agriculture does not mention organic. Yet research shows the potential of organic agriculture for reducing and preventing climate change. These studies also apply to land management in cities, parks, and playing fields.

>>Tell the Biden transition team to harness the power of organic to combat climate change.

Organic agriculture practices combat climate change by:

Reducing Emissions of Nitrogen Oxides. Excessive use of nitrogen fertilizers in chemical-intensive agriculture is driving global nitrous oxide (N2O) emissions higher than any projected scenario, putting the world at greater risk of a climate catastrophe. According to research published by an international team of scientists in the journal Nature, failure to adequately address nitrous oxide emissions has the potential to impede the ability for the world to keep warming below the 2°C target established under the Paris Climate Agreement, necessitating further cuts in other greenhouse gasses. 

A 2018 study from the University of Virginia and The Organic Center found that “reactive” nitrogen, in the form readily available to be taken up by plants, is conserved in organic systems. Jessica Shade, PhD of The Organic Center, noted that the research was “significant and timely because its findings show that many common organic farming practices—like composting and the use of manure fertilization in place of synthetic fertilizers—can recycle reactive nitrogen that is already in the global system, rather than introducing new reactive nitrogen into the environment, and thus have a much smaller environmental impact.”

Sequestering carbon. Organic systems sequester significant amounts of carbon from the atmosphere into on-farm soil carbon. A report from the Rodale Institute expounds on these benefits. It reads, “Simply put, recent data from farming systems and pasture trials around the globe show that we could sequester more than 100% of current annual CO2 emissions with a switch to widely available and inexpensive organic management practices, which we term 'regenerative organic agriculture.' These practices work to maximize carbon fixation while minimizing the loss of that carbon once returned to the soil, reversing the greenhouse effect.”

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

The Biden transition team for agriculture, which has made mitigating climate change a major emphasis, must focus its attention on promoting organic agriculture. It can start by appointing organic leaders as Secretary and other leadership positions.

Unfortunately, a movement by promoters of chemical-intensive agriculture has fooled some environmentalists into supporting toxic “regenerative” agriculture. The so-called “regenerative agriculture” promoted by these groups ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients and also for the heat and energy driving chemical reactions. It is important to see through this deception. 

>>Tell the Biden transition team to harness the power of organic to combat climate change.

Letter to Biden Transition Team

I am writing because the Biden transition plan for combatting climate change caused by agriculture has overlooked a crucial element—organic agriculture. Research shows the potential of organic agriculture for reducing and preventing climate change. These studies also apply to land management in cities, parks, and playing fields.

Organic agriculture practices combat climate change by:

- Reducing Emissions of Nitrogen Oxides. Excessive use of nitrogen fertilizers in chemical-intensive agriculture is driving global nitrous oxide (N2O) emissions higher than any projected scenario, putting the world at greater risk of a climate catastrophe. According to research published by an international team of scientists in the journal Nature, failure to adequately address nitrous oxide emissions has the potential to impede the ability for the world to keep warming below the 2°C target established under the Paris Climate Agreement, necessitating further cuts in other greenhouse gasses.

A 2018 study from the University of Virginia and The Organic Center found that “reactive” nitrogen, in the form readily available to be taken up by plants, is conserved in organic systems. Jessica Shade, PhD of The Organic Center, noted that the research shows “that many common organic farming practices—like composting and the use of manure fertilization in place of synthetic fertilizers—can recycle reactive nitrogen that is already in the global system, rather than introducing new reactive nitrogen into the environment, and thus have a much smaller environmental impact.”

- Sequestering carbon. Organic systems sequester significant amounts of carbon from the atmosphere into on-farm soil carbon. A report from the Rodale Institute expounds on these benefits. It reads, “Simply put, recent data from farming systems and pasture trials around the globe show that we could sequester more than 100% of current annual CO2 emissions with a switch to widely available and inexpensive organic management practices, which we term ‘regenerative organic agriculture.’ These practices work to maximize carbon fixation while minimizing the loss of that carbon once returned to the soil, reversing the greenhouse effect.”

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

Unfortunately, a movement by promoters of chemical-intensive agriculture has fooled some environmentalists into supporting toxic “regenerative” agriculture. The so-called “regenerative agriculture” promoted by these groups ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients and also for the heat and energy driving chemical reactions. It is important to see through this deception.

I support your emphasis on mitigating climate change. You must focus on promoting organic agriculture as a solution. Please start by appointing organic leaders as USDA Secretary and other leadership positions.

Thank you.

Since the U.S. Department of Agriculture (USDA) sits at the nexus of complex and systemic problems that need urgent attention—pesticide-dependent genetically engineered crops, the integrity of certified organic agriculture, and the climate crisis—the choice of the agency’s head is critical to meeting the challenges necessary to sustaining life.

USDA has long been a big promoter of chemical-intensive agriculture. With President-elect Joe Biden committed to priorities of addressing health care, systemic racism, and climate change, the time is now for USDA to change the way it does business. We need an organic advocate in the Secretary of Agriculture, who must be committed to transitioning chemical-intensive agriculture to organic practices—thereby eliminating petroleum-based pesticides and synthetic fertilizers, sequestering atmospheric carbon, protecting farmworker and farmer health, delivering a safe food supply, and ensuring clean air, water, and healthy terrestrial and aquatic ecosystems.

>>Tell President-elect Biden to appoint an organic leader as USDA Secretary.

The purview of USDA is far-ranging—from SNAP (food stamps) to agricultural support programs to research to inspections and other regulations. And the National Organic Program. Research includes programs promoting pesticides and genetically engineered crops. USDA’s history with President-elect Biden’s priority issues has not been good historically. Promotion of chemical-intensive production hurts health as well as the environment and leads to increased climate change. Chemical-intensive agriculture is systemically racist—disproportionately exposing black, indigenous, and people of color to hazardous chemicals from their production through use and disposal, while food deserts in low income neighborhoods offer low quality processed food contaminated with chemical residues.

We need an organic leader at USDA—a catalyst who will promote healthy organic food for all, as well as agricultural production practices that prevent climate change and environmental degradation.

There are plenty of possibilities from which to choose:

• Public officials include organic farmers like Congresswoman Chellie Pingree (D-Maine), Senator Jon Tester (D-Montana), and Lieutenant Governor David Zuckerman (D-Vermont). 
• State Agriculture commissioners Jim Hightower (Texas) and Kate Greenberg (D-Colorado). She worked on organic and regenerative farms and was a leader with the National Young Farmers Association.
• Organic and regenerative farmers who have worked at USDA, including Francis Thicke, PhD, who is an organic farmer and former National Organic Standards Board member and USDA National Program Leader for Soil Science, and Shirley Sherrod, who was the Georgia State Director of Rural Development.
• Organic and regenerative farmers and ranchers who, because of historic discrimination, have never been offered political appointments, but have proven themselves as leaders, include John Boyd, founder of the National Black Farmers Association, Karen Washington, co-founder of Black Urban Growers, and Winona LaDuke, founder of the White Earth Land Recovery Project, to name just a few.

>>Tell President-elect Biden to appoint an organic leader as USDA Secretary.

Letter to President-elect Biden's Agriculture Transition Team

I am writing to you because I am concerned that people—like former Senator Heidi Heitkamp—who have been suggested as the Secretary of Agriculture in the Biden administration will take us in the wrong direction and not meet the existential crises of the climate crisis and biodiversity devastation. We have a plethora of dedicated leaders to choose from who have exhibited a deep commitment to advancing organic agriculture—thereby eliminating petroleum-based pesticides and synthetic fertilizers, sequestering atmospheric carbon, protecting farmworker and farmer health, delivering a safe food supply, and ensuring clean air, water, and healthy terrestrial and aquatic ecosystems.

The purview of USDA is far-ranging—from SNAP (food stamps) to agricultural support programs to research to inspections and other regulations. And the National Organic Program. Research includes programs promoting pesticides and genetically engineered crops. USDA’s history with the Biden priority issues has not been good in the past. Promotion of chemical-intensive production hurts health as well as the environment and leads to increased climate change. Chemical-intensive agriculture is systemically racist—disproportionately exposing black, indigenous, and people of color to hazardous chemicals from their production through use and disposal, while food deserts in low income neighborhoods offer low quality processed food contaminated with chemical residues.

We need an organic leader at USDA—a catalyst who will promote organic food for all, as well as production that prevents climate change and environmental degradation.

There are plenty of possibilities to choose from:

• Public officials include organic farmers like Congresswoman Chellie Pingree (D-Maine), Senator Jon Tester (D-Montana) and Lieutenant Governor David Zuckerman (D-Vermont).
• State Agriculture commissioners Jim Hightower (Texas) and Kate Greenberg (D-Colorado). She worked on organic and regenerative farms and was a leader with the National Young Farmers Association.
• Organic and regenerative farmers who have worked at USDA, including  Francis Thicke, PhD, who was USDA’s National Program Leader for Soil Science, and Shirley Sherrod, who was the Georgia State Director of Rural Development.
• Organic and regenerative farmers and ranchers who, because of historic discrimination, have never been offered political appointments, but have proven themselves as leaders, include John Boyd, founder of the National Black Farmers Association, Karen Washington, co-founder of Black Urban Growers, and Winona LaDuke, founder of the White Earth Land Recovery Project, to name just a few.

Please select an organic leader for Secretary of Agriculture, who must be committed to transitioning from chemical-intensive agriculture to organic practices—thereby eliminating petroleum-based pesticides and synthetic fertilizers, sequestering atmospheric carbon, protecting farmworker and farmer health, delivering a safe food supply, and ensuring clean air, water, and healthy terrestrial and aquatic ecosystems.

Thank you.

Letter to Congress

I am writing to you because I am concerned that people—like former Senator Heidi Heitkamp—who have been suggested as the Secretary of Agriculture in the Biden administration will take us in the wrong direction and not meet the existential crises of the climate crisis and biodiversity devastation. We have a plethora of dedicated leaders to choose from who have exhibited a deep commitment to advancing organic agriculture—thereby eliminating petroleum-based pesticides and synthetic fertilizers, sequestering atmospheric carbon, protecting farmworker and farmer health, delivering a safe food supply, and ensuring clean air, water, and healthy terrestrial and aquatic ecosystems.

The purview of USDA is far-ranging—from SNAP (food stamps) to agricultural support programs to research to inspections and other regulations. And the National Organic Program. Research includes programs promoting pesticides and genetically engineered crops. USDA’s history with the Biden priority issues has not been good in the past. Promotion of chemical-intensive production hurts health as well as the environment and leads to increased climate change. Chemical-intensive agriculture is systemically racist—disproportionately exposing black, indigenous, and people of color to hazardous chemicals from their production through use and disposal, while food deserts in low income neighborhoods offer low quality processed food contaminated with chemical residues.

We need an organic leader at USDA—a catalyst who will promote organic food for all, as well as production that prevents climate change and environmental degradation.

There are plenty of possibilities to choose from:

• Public officials include organic farmers like Congresswoman Chellie Pingree (D-Maine), Senator Jon Tester (D-Montana) and Lieutenant Governor David Zuckerman (D-Vermont).
• State Agriculture commissioners Jim Hightower (Texas) and Kate Greenberg (D-Colorado). She worked on organic and regenerative farms and was a leader with the National Young Farmers Association.
• Organic and regenerative farmers who have worked at USDA, including Francis Thicke, PhD, who was USDA’s National Program Leader for Soil Science, and Shirley Sherrod, who was the Georgia State Director of Rural Development.
• Organic and regenerative farmers and ranchers who, because of historic discrimination, have never been offered political appointments, but have proven themselves as leaders, include John Boyd, founder of the National Black Farmers Association, Karen Washington, co-founder of Black Urban Growers, and Winona LaDuke, founder of the White Earth Land Recovery Project, to name just a few.

Please select an organic leader for Secretary of Agriculture, who must be committed to transitioning from chemical-intensive agriculture to organic practices—thereby eliminating petroleum-based pesticides and synthetic fertilizers, sequestering atmospheric carbon, protecting farmworker and farmer health, delivering a safe food supply, and ensuring clean air, water, and healthy terrestrial and aquatic ecosystems.

Thank you.

Now that we have learned what a pandemic looks and feels like, with the astounding levels of infection, hospitalization, and death from COVID-19, we must take serious steps to prevent another pandemic on the horizon—this one tied to bacterial resistance to antibiotics. An important article in The Lancet points to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”

>>Tell your Congressional Representative and Senators it is urgent that the National Action Plan for Combating Antibiotic-Resistant Bacteria be initiated.

Two contributors to antimicrobial resistance (AMR) that are being highlighted are in agriculture and use of antibiotics in medicine when not warranted.

The misuse of antibiotics in agriculture includes antibiotics used to control certain bacterial diseases in plant agriculture (especially oxytetracycline and streptomycin). While crop uses are important contributors to breeding bacterial resistance, they are small compared to their uses in livestock production. Antibiotics are used largely as additives to animal feed to ward off any potential infections and to promote unnaturally rapid growth (the latter of which translates to higher profits), rather than being used to treat bacterial infections (although that does happen and products from treated animals can go to market with residues). Both of these objectives compensate for the overcrowded and unsanitary conditions of concentrated animal feeding operations (CAFOs), which scientists believe are contributing to the next pandemic. Use of antibiotics is prohibited in all certified organic production. Although the standards of the National Organic Program require that sick animals be treated, meat and other products from such animals cannot be sold with the imprimatur of the Certified Organic designation.

Another leading cause of AMR is the unnecessary use of antibiotics in human medicine. Antibiotics may be given prophylactically to prevent infection or during the course of a viral infection, which cannot be cured with antibiotics. A study from summer 2020 shows that a shocking 72% of COVID-19 patients received antibiotics even when they were not clinically indicated. The authors note: “AMR might worsen under COVID-19 due to the overuse of antibiotics in humans, continuing misuse in agriculture, and the dearth of antimicrobials in the development pipeline.”

The co-authors of The Lancet articles also discuss how the AMR phenomenon that underlies this rise can exacerbate COVID-19 risks. They observe that, across five countries, COVID-19 diagnoses are associated with bacterial infections (with 3.5% diagnosed concurrently and 14.3% post-COVID-19). The prevalence is higher in patients who require intensive care. 

In 2015, the White House released a comprehensive action plan to curtail antibiotic misuse and accelerate new antimicrobials and vaccines—the National Action Plan for Combating Antibiotic-Resistant Bacteria. Implementation has been uneven and, at times, contradictory. In 2017, the U.S. Food and Drug Administration banned use of antibiotics as growth promoters in livestock, but the same year, the U.S. Department of Agriculture (USDA) rejected the World Health Organization's  guidance to limit antibiotic use in livestock feed. There have been unprecedented nationwide budget cuts to hospital-based AMR programs. Ignoring the looming pandemic, in 2019, the U.S. Environmental Protection Agency approved an expansion of medically important antibiotics such as streptomycin and oxytetracycline as pesticides to increase crop yields, and the USDA removed federal oversight of meat inspection at pork processing plants.

Failing to confront AMR undermines decades of advances in medicine and public health. The COVID-19 pandemic should serve as a wake-up call that progress on the national action plan is critical for public health.

>>Tell your Congressional Representative and Senators it is urgent that the National Action Plan for Combating Antibiotic-Resistant Bacteria be initiated.

Letter to Congress

I am writing to ask you to take urgent action to prevent the next pandemic related to bacterial resistance. Now that we have learned what a pandemic looks and feels like with the astounding levels of infection, hospitalization, and death from COVID-19, we must take serious steps to prevent another pandemic on the horizon. An important article in The Lancet points to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”

Two contributors to antimicrobial resistance (AMR) that are being highlighted are in agriculture and use of antibiotics in medicine when not warranted.

The misuse of antibiotics in agriculture includes antibiotics used to control certain bacterial diseases in plant agriculture (especially oxytetracycline and streptomycin). While crop uses are important contributors to breeding bacterial resistance, they are small compared to their uses in livestock production. Antibiotics are used largely as additives to animal feed to ward off any potential infections and to promote unnaturally rapid growth, rather than being used to treat bacterial infections (although that does happen and products from treated animals can go to market with residues). Both of these objectives compensate for the overcrowded and unsanitary conditions of concentrated animal feeding operations (CAFOs), which scientists believe are contributing to the next pandemic.

Another leading cause of AMR is the unnecessary use of antibiotics in human medicine. Antibiotics may be given prophylactically to prevent infection or during the course of a viral infection, which cannot be cured with antibiotics. A study from summer 2020 shows that a shocking 72% of COVID-19 patients received antibiotics even when they were not clinically indicated. The authors note: “AMR might worsen under COVID-19 due to the overuse of antibiotics in humans, continuing misuse in agriculture, and the dearth of antimicrobials in the development pipeline.”

The co-authors of The Lancet articles also discuss how the AMR phenomenon that underlies this rise can exacerbate COVID-19 risks. They observe that, across five countries, COVID-19 diagnoses are associated with bacterial infections (with 3.5% diagnosed concurrently and 14.3% post-COVID-19). The prevalence is higher in patients who require intensive care.

In 2015, the White House released a comprehensive action plan to curtail antibiotic misuse and accelerate new antimicrobials and vaccines—the National Action Plan for Combating Antibiotic-Resistant Bacteria. Implementation has been uneven and, at times, contradictory. In 2017, the US Food and Drug Administration banned use of antibiotics as growth promoters in livestock, but the same year, the US Department of Agriculture (USDA) rejected WHO’s guidance to limit antibiotic use in livestock feed. There have been unprecedented nationwide budget cuts to hospital-based AMR programs. In 2019, the U.S. Environmental Protection Agency approved expansion of medically important antibiotics such as streptomycin and oxytetracycline as pesticides to increase crop yields, and the USDA removed federal oversight of meat inspection at pork processing plants.

Failing to confront AMR undermines decades of advances in medicine and public health. The COVID-19 pandemic should serve as a wake-up call that progress on the national action plan is critical for public health.

Please encourage federal agencies, including EPA, USDA, and FDA, to take urgent action to implement the National Action Plan for Combating Antibiotic-Resistant Bacteria.

Thank you.

It’s not just the top of the ballot that deserves our attention. The facts are the facts. The records of elected U.S. Senators and U.S. Representatives speak for themselves. The decisions affecting public health and the environment of the past four years—with real impact now and for future generations—do not happen without the support of the majority in the U.S. Senate. If you’ve been taking action with Beyond Pesticides Action of the Week, you know this because you have been communicating with Congress for the past four years on key issues that determine whether there will be a sustainable future.

Policies that ignore the science are upheld or rejected in state legislatures through state policy. And local elected officials on city, town, and county councils make decisions on whether to allow the poisoning of our parks and waterways or push for organic land management. School board members determine whether our children are exposed to toxic pesticides on playing fields. Where do the candidates on your ballot stand? 

For those you know who don’t want to consider the facts, share the undoing of basic protections of our families and community with them. 

Vote Now! Tell Your Family and Friends to Vote!

Remember, many rules have changed during the pandemic, making it harder to figure out how to cast your ballot. This interactive guide can help you ensure your vote is counted.

Beyond Pesticides reports daily on the most up-to-date science and the dramatic failure of regulatory standards. With you, we dig deep into health and environmental effects of public policy. We work with decision makers and businesses that care about our children and our future. We measure not words but actions. 

And now we vote. For our future. For life.

A high percentage of the disinfectants approved by EPA for use against coronavirus contain quaternary ammonia compounds (quats). EPA's approved list is used by schools and other institutions—unfortunately, without guidance for avoiding harmful effects.

Quats are very toxic. They are especially dangerous in the context of a respiratory pandemic. Quats increase the risk for asthma and allergic sensitization. Evidence from occupational exposures shows increased risk of rhinitis and asthma with exposure to quats. Quats are on the Association of Occupational and Environmental Clinics list of asthmagens and may be a more potent asthmagen than bleach.

>>Tell the EPA and Congress that EPA must not recommend toxic disinfectants without the context of their damaging impacts and other necessary protective measures.

One quat, benzalkonium chloride, has also been associated with dermatitis. Quats appear to be sensitizers and irritants to the skin and mucous membranes and are suspected to display an immunologic cross-reactivity between each other and with other chemical compounds containing ammonium ion.

Quats also are mutagenic and reproductive toxicants. Some quats have shown to be mutagenic and to damage animal DNA and DNA in human lymphocytes at much lower levels than are present in cleaning chemicals. Mice whose cages were cleaned with QACs had very low fertility rates.

The continued zeroing in on disinfectants distracts schools from the more important role of measures to reduce airborne exposure in schools. Measures to accomplish this include reducing the time spent indoors, engineering controls that increase ventilation while preventing air movement from one person to another, and use of air filtration.

EPA's List N disinfectants do not differentiate by levels of toxicity and potential harm to people, especially children. Beyond Pesticides has created a safer list, drawn from List N, which enables people and decision-makers to avoid chemicals that harm.

EPA allows the registration of pesticides that are known to present hazards even though there are less hazardous pesticides on the market. That's because EPA does not do an alternatives analysis and determine whether a less toxic material and/or a practice can get the job done just as effectively. Instead, EPA conducts risk assessments that are admittedly filled with uncertainties in addition to what is known about a chemical's effects—such as impacts on people with preexisting conditions (comorbidities), effects of multiple exposures to the same and other chemicals (mixtures), and numerous other factors not considered by EPA.

TAKE ACTION: Tell EPA and Congress that EPA must not recommend toxic disinfectants without the context of their damaging impacts and other necessary protective measures.

Letter to EPA and Congress

A high percentage of the disinfectants approved by EPA for use against coronavirus contain quaternary ammonia compounds (quats). EPA’s approved list is used by schools and other institutions—unfortunately, without guidance for avoiding harmful effects.

Quats are very toxic. They are especially dangerous in the context of a respiratory pandemic. Quats increase the risk for asthma and allergic sensitization. Evidence from occupational exposures shows increased risk of rhinitis and asthma with exposure to quats. Quats are on the Association of Occupational and Environmental Clinics list of asthmagens and may be a more potent asthmagen than bleach.

One quat, benzalkonium chloride, has also been associated with dermatitis. Quats appear to be sensitizers and irritants to the skin and mucous membranes and are suspected to display an immunologic cross-reactivity between each other and with other chemical compounds containing ammonium ion.

Quats also are mutagenic and reproductive toxicants. Some quats have shown to be mutagenic and to damage animal DNA and DNA in human lymphocytes at much lower levels than are present in cleaning chemicals. Mice whose cages were cleaned with QACs had very low fertility rates.

The continued zeroing in on disinfectants distracts schools from the more important role of measures to reduce airborne exposure in schools. Measures to accomplish this include reducing the time spent indoors, engineering controls that increase ventilation while preventing air movement from one person to another, and use of air filtration.

EPA’s List N disinfectants does not differentiate by levels of toxicity and potential harm to people, especially children. Beyond Pesticides has created a safer list, drawn from List N, which enables people and decision-makers to avoid chemicals that harm.

EPA allows the registration of pesticides that are known to present hazards even though there are less hazardous pesticides on the market. That’s because EPA does not do an alternatives analysis and determine whether a less toxic material and/or a practice can get the job done just as effectively. Instead, EPA conducts risk assessments that are admittedly filled with uncertainties in addition to what is known about a chemical’s effects—such as impacts on people with preexisting conditions (comorbidities), effects of multiple exposures to the same and other chemicals (mixtures), and numerous other factors not considered by EPA.

EPA must not recommend toxic disinfectants without providing the context of their damaging impacts and other necessary protective measures.

Thank you.

(Beyond Pesticides, October 19, 2020) The COVID-19 epidemic has made clear to the general public what we at Beyond Pesticides have been stressing since our inception—some populations have disproportionate risk of severe outcomes, exposures to toxic chemicals can affect susceptibility to disease, comorbidity increases risk, and bad government can kill you.

As Trump declares that “unborn children have never had a stronger defender in the White House,” we are reminded of Erik Jansson, who ran the National Network to Prevent Birth Defects and helped to convene the founding meeting of Beyond Pesticides, and took on then-Administrator of EPA Anne Gorsuch, calling her a “baby killer” because of policies that allowed exposures to toxic chemicals—exposures that endangered children and fetuses. Those were harsh words in the 1980s even when the Reagan administration’s environmental and toxics policies were tied to elevated harm to people, and children in particular. In today’s world, scientists and medical doctors are regularly linking elevated death rates from coronavirus to the federal government’s inadequate coronavirus policy and its attack on science. And, they are pointing to those in charge.

Policies and decisions under the Trump administration that threaten the health of children and the unborn include:

• COVID-19 misinformation. According to a Cornell University study, Trump is the single largest driver of misinformation around COVID, and, says Scientific American, that misinformation kills people.
• Poisoning children. In a move that challenges the preponderance of independent peer-reviewed scientific findings on children’s health, EPA stripped away protections that limit children’s exposure to class of chemicals associated with childhood cancer, autism other learning disorders, and asthma. The result of the agency’s actions will be a dramatic increase in the use of synthetic pyrethroids, insecticides found in indoor and outdoor bug sprays, bug bombs, and often used on conventionally grown fruits and vegetables.
• Ignoring the recommendations of EPA scientists to ban chlorpyrifos. Chlorpyrifos is a cholinesterase inhibitor that binds irreversibly to the receptor sites of acetylcholinesterase (AChE), an enzyme that is critical to normal nerve impulse transmission. In so doing, chlorpyrifos inactivates the enzyme, damages the central and peripheral nervous systems, and disrupts neurological activity. The compound is associated with harmful reproductive, renal, hepatic, and endocrine disrupting effects, and most notably, with neurodevelopmental impacts, especially in children. It is a neurological toxicant that damages their brains and leads to compromised cognitive function, attention deficit disorder, developmental delays, lowered IQs, and a host of other developmental and learning anomalies.
• Failure to regulate per- and polyfluoroalkyl substances (PFAS). EPA Administrator Wheeler “told reporters he believes the agency’s voluntary 70-part-per-trillion health-advisory level for the chemicals is ‘a safe level for drinking water,’ despite the fact that this level is more than six times higher than what the Department of Health and Human Services considers safe.” The Union of Concerned Scientists (UCSUSA) says, “[S]cientific evidence suggests that children may be especially vulnerable to PFAS exposure. For many children, exposure begins almost immediately, first through placental transfer and then through breast milk after birth. While medical professionals still recommend breastfeeding because of its many benefits, the idea that something so natural has been tainted with harmful, manmade chemicals is disturbing.”
• Weakening air pollution regulations. Weakening air pollution regulations serves polluting industries but harms children, whose lungs are still developing and are more exposed through active, outdoor activities. Air pollution levels can also affect developing brains.
• Disregards scientific consensus on climate change. According to UCSUSA, “[T]he complete failure of this administration to accept climate science and act to reduce carbon emissions is putting our children and future generations at risk. Children are particularly vulnerable to the impacts of a warming world. Extreme heat can cause pregnant women to experience abnormally high blood pressure, liver and kidney damage, and premature births, and children are more susceptible to undernutrition, dehydration, and asthma and other respiratory diseases.”
• Failure to reduce lead in drinking water and paint. There is no safe level for children of exposure to lead, which is, according to the World Health Organization (WHO), a highly potent neurotoxin that even at low doses can cause irreversible damage to the nervous system of children.
• EPA proposed lowering the age at which farmworker children are allowed to apply pesticides to 16. In 2015, the WPS was revised to set a minimum age of 18 for pesticide application. In 2018, after being sued for not implementing the minimum age requirement, EPA proposed lowering the age to 16. EPA dropped its proposal to lower the age for pesticide handlers after negotiating with Congress. Despite EPA’s reversal, a change in the statute such as that proposed in H.R. 3394 would prevent the agency or the courts from allowing 16-year-olds to be hired to apply pesticides in the future.
• Dismantling of EPA’s and other regulatory programs. The range of government decisions, or the failure to act, is causing real harm to people, and too numerous to list here, but we can add ignoring EPA scientists’ call for an asbestos ban.   

In addition to moves that directly affect the health of children, there are many more that affect the future environment—the environment in which those children will live. Several lists of Trump administration actions that hurt health and the environment are available online, including those compiled by National Geographic, The New York Times, Union of Concerned Scientists, Scientific American, and World Resources Institute. Concern for the far-reaching impacts of the Trump administration on the environment and health and its attacks on science, have prompted some organizations to take a first-ever stand on the presidential election. These include the New England Journal of Medicine and Scientific American.

Of course, these Trump administration policies are supported by the leadership in the U.S. Senate and among leaders in many state legislatures across the country. As we sit on the precipice of existential threats to health and the environment, we appreciate all those who participate in Beyond Pesticides’ Action of the Week. The issues of concern have been covered in our actions, where we thank all those who participate.  

NOW IT’S TIME TO VOTE. NOW IT’S TIME TO ASK OUR FAMILY, FRIENDS,  AND NEIGHBORS TO VOTE.

Remember, many rules have changed during the pandemic, making it harder to figure out how to cast your ballot. This interactive guide can help you ensure your vote is counted.

As the prestigious journal Nature publishes an article titled “How Trump Damaged Science — and Why It Could Take Decades to Recover,” the Trump Administration's EPA is again damaging science, particularly science used to protect our health.

EPA is proposing to drop toxicity tests that look at lethal effects of acute exposures to pesticides through the skin. Given pesticide exposure patterns, this represents a dramatic step backwards in determining the harmful effects of pesticide products on the market and in wide use. The move is part of EPA's effort to eliminate animal testing of pesticides—a move that should be replaced by the ban of unnecessary toxic pesticides. Reducing toxicity testing must take place only with the use of the precautionary principle.

TAKE ACTION: Tell Congress to Insist that EPA thoroughly test all pesticides for health hazards.

Aly Cohen, MD, FACR and Fred vom Saal, PhD point out in their new book, Non-Toxic Guide to Living in a Chemical World, “Human skin is the largest organ in the human body; it acts like a sponge, absorbing substances directly through its many intricate layers right into the bloodstream.” Farmworkers are routinely exposed to pesticides on their skin, and children playing on athletic fields sprayed with pesticides are also exposed through their skin. 

Jeffrey Shaman, PhD, an epidemiologist at Columbia University in New York City, who was interviewed for the Nature article said of Trump's actions concerning the coronavirus, “He has sabotaged efforts to keep people safe.” The article summarizes the effects of this administration, “As he seeks re-election on 3 November, Trump's actions in the face of COVID-19 are just one example of the damage he has inflicted on science and its institutions over the past four years, with repercussions for lives and livelihoods. The president and his appointees have also back-pedalled on efforts to curb greenhouse-gas emissions, weakened rules limiting pollution and diminished the role of science at the US Environmental Protection Agency (EPA). Across many agencies, his administration has undermined scientific integrity by suppressing or distorting evidence to support political decisions, say policy experts.”

With the damage done by the executive branch, Congress must assert its oversight role to prevent laws that protect public health and the environment—laws that, after decades, have cleaned up our air, water, and land—from being completely undone.

TAKE ACTION: Tell Congress to Insist that EPA thoroughly test all pesticides for health hazards.

Letter to Congress:

I am writing to ask you to assert oversight over the actions of the executive branch that continue to disregard science and threaten our health.

As the prestigious journal Nature publishes an article titled “How Trump Damaged Science — and Why It Could Take Decades to Recover,” the Trump Administration’s EPA is again damaging science, particularly science used to protect our health.

EPA is proposing to drop toxicity tests that look at lethal effects of acute exposures to pesticides through the skin. Given pesticide exposure patterns, this represents a dramatic step backwards in determining the harmful effects of pesticide products on the market and in wide use. The move is part of EPA’s effort to eliminate animal testing of pesticides—a move that should be replaced by the ban of unnecessary toxic pesticides. Reducing toxicity testing must take place only with the use of the precautionary principle.

Aly Cohen, MD, FACR and Fred vom Saal, PhD point out in their new book, Non-Toxic Guide to Living in a Chemical World, “Human skin is the largest organ in the human body; it acts like a sponge, absorbing substances directly through its many intricate layers right into the bloodstream.” Farmworkers are routinely exposed to pesticides on their skin, and children playing on athletic fields sprayed with pesticides are also exposed through their skin.

Jeffrey Shaman, PhD, an epidemiologist at Columbia University in New York City, who was interviewed for the Nature article said of Trump’s actions concerning the coronavirus, “He has sabotaged efforts to keep people safe.” The article summarizes the effects of this administration, “As he seeks re-election on 3 November, Trump’s actions in the face of COVID-19 are just one example of the damage he has inflicted on science and its institutions over the past four years, with repercussions for lives and livelihoods. The president and his appointees have also back-pedalled on efforts to curb greenhouse-gas emissions, weakened rules limiting pollution and diminished the role of science at the US Environmental Protection Agency (EPA). Across many agencies, his administration has undermined scientific integrity by suppressing or distorting evidence to support political decisions, say policy experts.”

With the damage done by the executive branch, Congress must assert its oversight role to prevent the undoing of laws intended to protect public health and the environment—laws that, after decades, have cleaned up our air, water, and land.

Thank you for your attention to this important issue.

In another example of trading health and environmental protection for the support of special interests, EPA announces the misleading and fraudulently named, “EPA Supports Technology to Benefit America's Farmers.” This time, EPA announces plans to “streamline the regulation of certain plant-incorporated protectants (PIPs).” Named to sow confusion, PIPs are plants engineered with pesticides in them. PIPs are known in general for two problems arising from incorporating pesticidal ingredients into crops: residues that cannot be washed off and production of crop-eating insects that are resistant to the incorporated pesticide that blankets the agricultural landscape. 

>> Tell Congress that EPA needs to listen to science, not pesticide manufacturers and biotech companies that are causing problems for farmers and the environment.

This time, EPA is proposing to exempt from regulation certain PIPs created by biotechnological techniques that are cisgenic (using genes derived from sexually compatible species), such as CRISPR. The distinction that EPA seeks to make between cisgenic plants and transgenic plants (in which the gene of interest may come from any species) is not supported by science. In fact, cisgenic techniques make use of genetic material other than the targeted genes, and that may come from species that are not sexually compatible with the crop. The bottom line: these genetically engineered organisms introduce havoc into biological systems and the local ecology.

According to an analysis by Les Touart, PhD, Beyond Pesticides' senior science and policy manager, ”Experiments confirm that cisgenesis can result in significant unanticipated changes to a plant. The results of these experiments show that a trait introduced via a cisgene can result in plants that differ in unanticipated and dramatic ways from their conventionally bred counterparts. The differences observed would have important implications relevant to health and ecological risk assessments.”

Two important confounding aspects that EPA ignores are the likely move by the biotech industry to use multiple genetic manipulations—EPA has never been good at assessing risks of multiple stressors—and pleiotropy. Pleiotropy is the fact that a single gene controls more than one trait, so that introduction of a genetic change may have unanticipated impacts.

The other important effect of the use of PIPs is the certain development of resistance in pest organisms. Resistance creates severe economic impacts on farmers and the food production system because it leads to crop failures and requests to use more toxic compounds on for so-called pest emergencies. These resistance events, of course, are predictable outcomes that should not qualify for emergency use of unregistered pesticides under a loophole in the federal pesticide law. Because PIPs present a constant exposure to the pesticide, they present a constant selection pressure for resistance. Resistance to Bacillus thuringiensis (Bt) arising from its incorporation as a PIP in corn has resulted in the loss of effectiveness of this biological insecticide and the use of more toxic insecticides as a replacement. (See Beyond Pesticides' draft comment on PIPs to EPA.)

Simultaneous with this proposal, EPA has issued a proposal to address the development of resistance to Bacillus thuringiensis (Bt) in PIP corn and cotton. The proposal does not address or impact the biology of pest populations developing resistance, but only the recognition and identification of such resistance. Science shows that continued reliance on chemical or PIP insecticides only continues the cycle of pests developing resistance and continued need for new chemistry or technologies. Options not considered in EPA's new resistance management framework include organic management practices, which uses crop rotation and the employment of biological control measures and enhancements. 

Even in chemical-intensive agriculture, crop rotation is a good management option because it reduces the possibility of existing pests developing resistance to a particular insecticide by breaking the cycle of continual exposure that causes selection pressure. Crop rotation is more advantageous than use of refuges (buffers where the insecticides are not used), which have failed results due to ongoing pesticide dependency. Likewise, a variety of biological controls as alternatives to reliance on insecticide treatments are available and can be encouraged with proper management for lepidopteran pests resistant to Bt crops. EPA's resistance proposal, therefore, only serves as a façade, while the agency allows the use of more genetically engineered crops. (See Beyond Pesticides' draft comment on resistance management to EPA.)

>> Tell Congress that EPA needs to listen to science, not pesticide manufacturers and biotech companies that are causing problems for farmers and the environment.

Letter to Congress

I am writing to ask you to ask the U.S. Environmental Protection Agency (EPA) to stop harming farmers and the environment by ignoring the science of pest management and pesticide dependency. In another example of trading health and environmental protection for the support of special interests, EPA misleadingly announces, “EPA Supports Technology to Benefit America’s Farmers,” to “streamline the regulation of certain plant-incorporated protectants (PIPs).” PIPs are known for two problems arising from incorporating pesticidal ingredients into crops: residues that cannot be washed off and production of crop-eating insects that are resistant to the incorporated pesticide.

EPA proposes to exempt from regulation certain PIPs created by cisgenic biotech techniques such as CRISPR that use genes derived from sexually compatible species. The distinction that EPA seeks to make between cisgenic plants and transgenic plants (in which the gene of interest may come from any species) is not supported by science. In fact, cisgenic techniques make use of genetic material other than the targeted genes, which may come from species that are not sexually compatible with the crop.

According Beyond Pesticides’ senior science and policy manager, Les Touart, PhD, ”Experiments confirm that cisgenesis can result in significant unanticipated changes to a plant. The results of these experiments show that a trait introduced via a cisgene can result in plants that differ in unanticipated and dramatic ways from their conventionally bred counterparts. The differences observed would have important implications relevant to health and ecological risk assessments.”

Two important confounding aspects that EPA ignores are the likely move by the biotech industry to use multiple genetic manipulations—EPA has never been good at assessing risks of multiple stressors—and pleiotropy. Pleiotropy is the fact that a single gene controls more than one trait, so that introduction of a genetic change may have unanticipated impacts.

The other important effect of the use of PIPs is the certain development of resistance in pest organisms. Because PIPs present a continuous exposure to the pesticide, they present a constant selection pressure for resistance. Resistance to Bacillus thuringiensis (Bt) arising from its incorporation as a PIP in corn has resulted in the loss of effectiveness of this biological insecticide and the use of more toxic insecticides as a replacement—often through the use of a loophole in the pesticide law that identifies the predictable resulting insect resistance and population explosion as an emergency.

EPA has also issued a proposal to address the development of resistance to Bt in PIP corn and cotton. The proposal does not address or impact the biology of pest populations developing resistance, but only the recognition and identification of such resistance. Science shows that continued reliance on chemical or PIP insecticides only continues the cycle of pests developing resistance. EPA fails to consider agricultural practices used in organic agriculture, including crop rotation and biological control. Crop rotation is always a good management option because it reduces the possibility of existing pests developing resistance to a particular insecticide by breaking the cycle of continual exposure that causes selection pressure. Likewise, a variety of biological controls are available that can be encouraged to manage lepidopteran pests resistant to Bt crops. EPA’s resistance proposal, therefore, only serves as a façade while the agency allows the use of more genetically engineered crops.

Please tell EPA to listen to scientists, not the companies it is supposed to regulate. Ecology and toxicology support the need for incentives to adopt organic agriculture.

Thank you for your consideration of this request.

These comments are due by October 5 at 11:59 pm EDT. Separate comments to the National Organic Standards Board are due October 1 at 11:59 EDT.

After hearing for years about inadequate enforcement of the rules governing organic production, USDA has issued a massive draft rule on strengthening organic enforcement (SOE). The draft rule presented to the public constitutes an impressive and far-reaching rewrite of the regulations implementing the Organic Foods Production Act (OFPA). However, unlike the process by which the initial regulations were established in 2002, the National Organic Standards Board (NOSB) was only consulted on a portion of the elements in this draft rule. Public engagement was, thus, also limited.

USDA’s National Organic Program (NOP) is accepting comments on its draft rule via Regulations.gov. Please use this opportunity to remind USDA of the proper public process while commenting on the proposed rule itself. Please join us in asking for an extension of the pubic comment to facilitate fuller public scrutiny.

Tell USDA that strengthening organic enforcement starts with the National Organic Standards Board.

USDA must involve the NOSB and public as required by law.

Section 2119 of OFPA states the Secretary shall establish the NOSB to advise the Secretary on “… the implementation of this title.” Furthermore, the law states, “The board shall provide recommendations to the Secretary regarding the implementation of this title.” [emphasis added]

The promulgation of the original rule was preceded by a thorough discussion by the NOSB, intended by Congress to be a diverse panel of expert stakeholders, with abundant opportunity for public input from the most knowledgeable and experienced community and industry participants. This process was clearly fulfilling the intent of Congress.

Although the current draft SOE rule includes many meritorious elements, a number of them have not been discussed publicly. Given the narrow time window for public comments, concurrent with stakeholders and public interest groups working on formal comments pursuant to the upcoming NOSB meeting, and taking into account the impact this pandemic has had on the productivity of many organizations, a wide discussion within the organic community has not been possible—although a number of separate stakeholder constituencies have been discussing this rule in isolation without benefit of widely sharing their knowledge and perspectives.

Thus, an extension of the comment deadline is necessary to allow an opportunity for the organic community to collaborate on this proposal prior to proceeding to final rulemaking. Such an industry-wide discussion must be orchestrated by the NOSB and we recommend scheduling a third meeting during 2021 for that purpose.

Improvements in Organic Enforcement are Needed

As a starting point, Beyond Pesticides and its investigative arm OrganicEye, in general, support the detailed comments submitted by the National Organic Coalition (NOC). Furthermore, we also support the comments related to strengthening oversight on imports submitted by the Organic Farmers Agency for Relationship Marketing (OFARM).

In addition, we would emphasize the following points:

1. There is no reason for a 10-day delay in communicating electronic certificates. They are electronic! They should be transmitted simultaneously with shipment. Twenty-four hours is more than adequate. 
2. This rule is massive and, despite many meritorious elements, adds, in the aggregate, tremendous additional regulatory burdens. As such, it deserves additional time to be thoroughly and thoughtfully evaluated, including through public discussions, before public comment closes. 
3. Regarding a recommendation on accreditation of organic certifiers by the NOSB in October 2018,  it is time to look at risk-based oversight of certified operations, rather than putting honest farmers through the ringer every year with inspections and audits while massive fraud is being simultaneously perpetrated by malefactors. Although OFPA requires annual inspections, farmers and small processors who have demonstrated a high level of compliance and low risk should be given the option of yearly virtual inspections, using artificial intelligence and a national database to compare acreage, production, and sales, along with more comprehensive, periodically staggered, full site inspection/audits. This will free up resources in the certification and inspection sector for a much more aggressive approach to unannounced inspections, testing, and full, comprehensive audits. It should be noted that the IRS does not audit every taxpayer every year. Holding the hammer of unexpected and comprehensive audits ensures a high level of compliance.
4. A new, more efficient, and focused approach to inspections and audits of certified organic operations must be coupled with more aggressive penalties, enforcement action, and monitoring. It has become standard practice for NOP to negotiate settlements with alleged perpetrators, leaving some in business without substantive penalties. For the current or proposed regulatory oversight to be effective, prosecution of willful violators to the full extent of the law is needed as an effective deterrent.
5. USDA should mandate strict criteria for residue testing and unannounced inspections, including assisting in the selection of audit targets based, in part, on complaints and other reports from the public. The draft rule allows for far too much discretion by certifiers. Given that certified entities hire their certifier, clear criteria are especially important. Establishing enforcement requirements for certifiers is also critical if USDA reduces the emphasis on annual inspections/audits and shifts to more random and risk-based auditing.

How to Submit Comments

1. Navigate to the gov comment page. 
2. Enter your comment and identifying information. You may copy, paste, and edit the points below. See our video tutorial for steps in doing this.
3. Press the “Submit” button.

Here are points you may want to include:

• This rule is massive and, despite many meritorious elements, adds, in the aggregate, tremendous additional regulatory burdens. As such, it deserves additional time to be thoroughly and thoughtfully evaluated, including through public discussions, before public comment closes. This should be facilitated by the National Organic Standards Board.
• I support the detailed comments submitted by the National Organic Coalition (NOC) and the comments related to strengthening oversight on imports submitted by the Organic Farmers Agency for Relationship Marketing (OFARM).
• There is no reason for a 10-day delay in communicating the electronic certificates. They are electronic! They should be transmitted simultaneously with shipment. Twenty-four hours would be more than adequate.
• Consider risk-based oversight of certified operations rather than putting honest farmers through the ringer every year with inspections and audits while massive fraud is simultaneously perpetrated by malefactors. Farmers and small processors who have demonstrated a high level of compliance and low risk should be given the option of yearly virtual inspections, using artificial intelligence and a national database to compare acreage, production, and sales, along with more comprehensive, periodically staggered, full site inspection/audits. This will free up resources in the certification and inspection sector for a much more aggressive approach to unannounced inspections, testing, and full, comprehensive audits. Note that although the IRS does not audit every taxpayer every year, the hammer of unexpected and comprehensive audits ensures a high level of compliance.
• A new, more efficient, and focused approach to inspections and audits must be coupled with more aggressive penalties, enforcement action, and monitoring. It has become standard practice for NOP to negotiate settlements with alleged perpetrators, leaving some in business without substantive penalties. Willful violators need to be prosecuted to the full extent of law, as a deterrent, for any current or proposed regulatory oversight to be effective.
• USDA should mandate strict criteria for residue testing and unannounced inspections, including assisting in the selection of audit targets based, in part, on complaints and other reports from the public. The draft rule allows for far too much discretion by certifiers. Given that certified entities hire their certifier, clear criteria are especially important. Establishing enforcement requirements for certifiers is also critical if USDA reduces the emphasis on annual inspections/audits and shifts to more random and risk-based auditing.

Tell USDA that strengthening organic enforcement starts with the National Organic Standards Board.

In separate comments, please don’t forget to submit comments on NOSB proposals by October 1 at 11:59 pm EDT. Click on the link below to see our analysis and suggested comments.

While you are visiting Regulations.gov, please remember to tell the National Organic Standards Board to support core organic values.

(Beyond Pesticides, September 21, 2020) The National Organic Standards Board (NOSB) meets online October 28-30 to debate issues—after hearing public comment October 20 and 22—concerning how organic food is produced. Written comments are due October 1. They must be submitted through Regulations.gov.

Everywhere we look, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, organisms large and small entangled in plastic, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. As we focus on one of the most blatant examples of environmental abuse—the dispersal of toxic chemicals across the landscape—it is important to seek a solution. Organic can be a big part of the solution, but only if it doesn’t stray from its core values and practices.

Tell the National Organic Standards Board to support core organic values.

From its very beginnings, the organic sector has been driven by an alliance of farmers and consumers who defined the organic standards as a holistic approach to protecting health and the environment, with a deep conviction that food production could operate in sync with nature and be mindful of its interrelationship with the natural world—protecting and enhancing the quality of air, water, land, and food. Organic is not just an alternative for people seeking better food—though it is that—or a more profitable way of farming—though we hope it is that, too. It is a path to prevention of total ecological collapse. We constantly return to the foundations of organic for inspiration and guidance. When we comment on NOSB proposals, we are not interested in what is less harmful. We feel an urgency to prevent ecological disaster. 

As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong, our Fall 2020 NOSB web page which will be up within the week. Comment on all issues that interest you. 

We especially encourage comments on the topics below, keeping in mind this definition from the organic regulations: 

“Organic production. A production system that is managed in accordance with the [Organic Foods Production] Act and regulations…to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.”  Meeting these goals, essential to a sustainable future, requires strong adherence to these organic standards. To adopt practices and materials that weaken organic, undermines the future. In this spirit, we urge the following:

1. Do Not Allow Virgin Paper in Organic Crop Production Aids. The Crops Subcommittee proposes to allow planting aids—including paper pots, seed tape, and plant collars—made from virgin paper. To date, the National Organic Program has allowed only recycled paper to be used in crop production (as mulch and in compost). Virgin paper—especially virgin paper from wood pulp—results in much greater environmental impacts than recycled paper and does not foster cycling of resources. Use of virgin paper made from hemp reduces some of these impacts but adds the impacts of agricultural hemp production. Virgin paper from wood pulp should not be allowed as a crop input in organic production. 
2. Get Plastic Out of Organic. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—on a wide range of organisms. Although concerns were first raised about microplastics in the marine environment, impacts on terrestrial organisms are increasingly documented. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Biodegradable biobased mulch film (BBMF) has been allowed in organic production since 2014, but no products meeting the requirements set by the NOSB are produced, so the NOSB is considering loosening the requirements (annotation). Furthermore, use of BBMF results in bits of microplastic that are not fully degraded. Synthetic mulches should not replace natural mulches like hay, straw, and wood chips. The annotation of BBMF should not loosen up restrictions on the bioplastic film.
3. Protect Marine Life. Seaweeds (marine algae) and fish byproducts are used as inputs into organic crop production, but there is concern about the impacts of overharvesting and destructive harvesting methods, so the Materials Subcommittee proposes to allow marine algae to be used only when the harvest meets specific conditions. These requirements should be adopted by the NOSB, along with strong enforcement provisions. Separate action on fish products proposed by the Crops Subcommittee is too weak because it is unenforceable and allows the commercial use of bycatch. Only fish byproducts from postconsumer waste should be allowed as soil inputs.
4. Tell the National Organic Program to Finally Take Action on “Inert” Ingredients. After years of NOSB action and NOP inaction on “inerts,” the Crops Subcommittee proposes the only action it can to stimulate NOP into action—it proposes to remove List 4 from the National List. According to the Organic Foods Production Act, NOP cannot allow the use of synthetic materials that are not supported by the NOSB. “Inert” ingredients are neither chemically nor biologically inert. They make up the bulk of pesticide products—sometimes as much as 99%–and have not been subjected to the scrutiny by the NOSB that has been applied to the few active pesticidal ingredients allowed in organic production. The NOSB must approve the Crops Subcommittee motion to remove the listing of List 4 “Inerts” and implement prior NOSB recommendations.             

Submit comments now.

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

We don’t need to use toxic weed killers to manage unwanted vegetation in Lake Tahoe, given the havoc they will wreak on a treasured and sacred ecosystem. The Tahoe Regional Planning Agency and Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) are accepting comments on a draft environmental impact report/ environmental impact statement (EIR/EIS) analyzing environmental impacts of a proposed Tahoe Keys Lagoons Aquatic Weed Control Methods Test (“Project”). Unless we all speak up, the Project could involve the application of herbicides to Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and should be selected for the proposed weed control test program.

Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm.

Located on the border of California and Nevada, Lake Tahoe is treasured for its scenic and ecological values not just by residents of those states, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an “Outstanding National Resource Water” under the Clean Water Act, and is recognized nationally and globally as a natural resource of special significance. 

The herbicides chosen for consideration in this program—florpyrauxifen-benzyl, triclopyr, and endothall—pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally superior choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program.

Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts.

See Beyond Pesticides’ detailed comments.

Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm.

Letter to Tahoe Regional Planning Agency/Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) 

I am writing to agree with the draft EIR/EIS authors that the Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and ask that the Tahoe Regional Planning Agency/Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) choose this alternative for the proposed weed control test program.

Lake Tahoe is treasured for its scenic and ecological values not just by residents of California and Nevada, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an “Outstanding National Resource Water” under the Clean Water Act and is recognized nationally and globally as a natural resource of special significance.

The herbicides chosen for consideration in this program pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally best choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program.

Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts.

Please see comments submitted by Beyond Pesticides, which I support. Thank you for your consideration of these comments.

 

We don't need to use toxic weed killers to manage unwanted vegetation in Lake Tahoe, given the havoc they will wreak on a treasured and sacred ecosystem. The Tahoe Regional Planning Agency and Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) are accepting comments on a draft environmental impact report/ environmental impact statement (EIR/EIS) analyzing environmental impacts of a proposed Tahoe Keys Lagoons Aquatic Weed Control Methods Test (“Project”). Unless we all speak up, the Project could involve the application of herbicides to Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and should be selected for the proposed weed control test program.

>> Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm.

Located on the border of California and Nevada, Lake Tahoe is treasured for its scenic and ecological values not just by residents of those states, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an "Outstanding National Resource Water" under the Clean Water Act, and is recognized nationally and globally as a natural resource of special significance. 

The herbicides chosen for consideration in this program—florpyrauxifen-benzyl, triclopyr, and endothall—pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally superior choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program.
Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts.

See Beyond Pesticides' detailed comments.

>> Protect Lake Tahoe from toxic weed killers—take action by Sept. 3, 11:59 pm.

Letter to TRPA/LRWQCB:

I am writing to agree with the draft EIR/EIS authors that the Action Alternative 1: Testing of Non-Herbicidal Methods Only is the environmentally best choice and ask that the Tahoe Regional Planning Agency/Lahontan Regional Water Quality Control Board (TRPA/LRWQCB) choose this alternative for the proposed weed control test program.

Lake Tahoe is treasured for its scenic and ecological values not just by residents of California and Nevada, but by many others. The Washoe Tribe considers the lake to be a sacred life-sustaining water, the center of the world. The lake is designated an "Outstanding National Resource Water" under the Clean Water Act and is recognized nationally and globally as a natural resource of special significance.

The herbicides chosen for consideration in this program pose risks of potential health and environmental harm not fully assessed in the EIR/EIS, and the non-herbicidal methods alone may prove sufficiently effective for the weed control sought. The Proposed Project, Action Alternatives, and the No Action Alternative all could have potentially significant effects to water quality issues (water temperature, turbidity, dispersal of aquatic fragments, changes in pH, dissolved oxygen, total phosphorus, and total nitrogen concentrations) and aquatic community stability (species diversity, species dominance, seasonal succession). The limited herbicide spot-treatment usage as part of the Proposed Project poses substantial localized risks to human health and environment. A full-scale herbicide use throughout the Tahoe Keys lagoons would be seriously detrimental to the Keys and potentially to the broader Lake Tahoe. The Action Alternative 1: Testing of Non-Herbicidal Methods Only would have the least potential for any serious and unwanted effects. Action Alternative 1 is the environmentally best choice and will likely demonstrate the effectiveness of non-herbicidal methods in controlling the aquatic weed problem. TRPA/LRWQCB should select this alternative for the proposed weed control test program.

Separate from the weed test control program, nutrient inputs into the Tahoe Keys from residential and landscape fertilizer use and vehicular (auto and boat) exhaust emissions contribute to the eutrophication and weed problem in the Keys and Lake Tahoe in general. TRPA/LRWQCB should continue and expand existing efforts limiting nutrient inputs that aggravate aquatic weed proliferation in the Tahoe Keys lagoons and will continue to hinder weed control efforts.

Please see comments submitted by Beyond Pesticides, which I support. Thank you for your consideration of these comments.

Sincerely,

USDA’s Farm Service Agency (FSA) announced on August 10 that it will be reducing reimbursement rates for the organic certification cost share program, which provides reimbursements to organic farms and handling operations. The August 10 Federal Register notice stated that FSA is “revising the reimbursement amount to 50 percent of the certified organic operation’s eligible expenses, up to a maximum of $500 per scope.” The 2018 Farm Bill clearly set reimbursement rates at 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per regulated activity. This change hurts the transition to organic production at a time when it is crucial that the organic sector grows—eliminating petroleum-based pesticides and synthetic fertilizers that are contributing to devastating pollution, the climate crisis, and biodiversity decline.

This action by USDA is unwarranted and completely unacceptable. The 2018 Farm Bill provided new funding for the program and also directed USDA to use the program’s carryover balances from previous years to fund the program for fiscal years 2019 through 2023. Given these sources of funding, there should be plenty of funds available for the program’s operation in fiscal year 2020. Either USDA’s accounting for this program is flawed or the agency has decided to disregard the Congressional funding directives in the 2018 Farm Bill. In addition, the FSA has done a huge disservice to the organic community in this time of crisis by delaying the release of funds by many months while organic operations struggle to stay in business as they weather a pandemic and loss of markets. Organic, direct market, and diversified operations have largely been excluded from existing USDA pandemic relief programs, including the Coronavirus Food Assistance Program, while the top 1% of recipients got more than 20% of the money, totaling $1.2 billion.

Organic operations should apply for certification cost-share assistance as soon as they are able to do so with their state agency or local FSA office. Operations have until October 31, 2020 to apply for funding. FSA has stated that “if additional funding is authorized at a later time, FSA may provide additional assistance to certified operations that have applied” for the organic certification cost share program.

TAKE ACTION: Tell Congress to restore organic funding taken away by USDA.

Letter to Congress:

I am writing to express my outrage that USDA’s Farm Service Agency has chosen to reduce support for the organic certification cost share program in the midst of a pandemic. The organic certification cost share program provides organic farmers and handling operations with modest reimbursement of up to $750 to cover a portion of their annual certification fees. This decision was announced via an August 10 Federal Register notice that stated FSA is “revising the reimbursement amount to 50 percent of the certified organic operation’s eligible expenses, up to a maximum of $500 per scope.”

This unilateral action by USDA is unwarranted and completely unacceptable and disregards the Congressional funding directives in the 2018 Farm Bill. The 2018 Farm Bill clearly set reimbursement rates at 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per scope.

In addition, the FSA has done a huge disservice to the organic community in this time of crisis by delaying the release of funds by many months while organic operations struggle to stay in business as they weather a pandemic and loss of markets. Organic, direct market, and diversified operations have largely been excluded from existing USDA pandemic relief programs, including the Coronavirus Food Assistance Program, while the top 1% of recipients got more than 20% of the money, totaling $1.2 billion.

If the USDA wants organic farms and our regional economies to survive and thrive, it should be helping organic operations during the pandemic. Producers and other organic operations need this support now more than ever because they are faced with loss of markets due to COVID-19 and increasing costs as they modify their operations to keep workers and customers safe and implement new sanitation and staffing procedures.

I urge you to communicate with FSA to ensure that the full organic certification cost share reimbursement is reinstated. In addition, given USDA’s delay in announcing the funding availability, I urge you to extend the deadlines for state agencies to apply to administer the program, and for organic operations to apply for the assistance.

Please sign onto the letter from Representatives Plaskett, Davis, Brindisi, and Newhouse urging USDA to reinstate the maximum reimbursement rate for the organic certification cost share program, as well as extend all applicable program deadlines to ensure that farmers who are still dealing with COVID-19 impacts have ample time to access these funds.

To sign onto the letter, you can contact Tiana Thomas in Rep. Plaskett’s office ([email protected]), Robert Dougherty in Rep. Brindisi’s office ([email protected]), Janie Costa in Rep. Rodney Davis’ office ([email protected]), or Travis Martinez in Rep. Newhouse’s office ([email protected]). The letter will close at COB on Monday, August 24.

Thank you.

Once numbering in the millions, barely 29,000 western monarch butterflies were found in California at last count. Pesticides pack a one-two punch against monarchs. Insecticides—particularly neonicotinoids—poison the caterpillars and butterflies as they feed. Glyphosate—the active ingredient in Bayer-Monsanto’s Roundup® — is wiping out milkweed, the only food source for monarch caterpillars. This has contributed to monarchs’ 90% decline in the past 20 years alone. They could vanish within our lifetimes.

Home and garden stores like Lowe’s and Home Depot can play a huge role in ending the use of this toxic pesticide in our backyards and across the country. Already, Lowe’s is removing neonicotinoid products from its live plant offerings and store shelves, and Home Depot is eliminating use of neonicotinoids in its live plant offerings. They could stop selling Roundup®. More importantly, they could encourage organic practices through their product offerings and consumer education.

Ask Home Depot and Lowe’s to get Roundup® off their shelves and promote and educate on organic!

Companies like Lowe’s and Home Depot could be leaders by removing products containing glyphosate/Roundup® from their physical stores and online—following the example of their competitor, Costco. This would send a powerful message to Bayer that it must phase out this harmful chemical. Instead of replacing Bayer-Monsanto’s Roundup® with other toxic products, garden retailers can facilitate a switch to organic by educating consumers and increasing offerings of organic-compatible and other safer alternatives. 

Organic alternatives work within an organic system that includes practices that build soil, cycle nutrients naturally, and increase biodiversity—including soil-building organisms, pollinators, and predators and parasites of plant-eating insects. Attempting to sell organic products as stand-alone “silver bullet” solutions dooms customers to failure, while educating them about the role of those products in an organic system will bring them back for more.

In the absence of effective regulation by the Trump Administration, we need garden retailers to act responsibly. Customers like you played a key role in convincing Home Depot and Lowe’s to protect pollinators by committing to stop selling plants grown with bee-killing neonicotinoid pesticides. Now, you can push them to take another vital step in pollinator protection. 

Ask Home Depot and Lowe’s to get Roundup® off their shelves and promote and educate on organic!

Roundup has been marketed by Bayer/Monsanto as effective and safe, but, in reality, its use delivers human and ecosystem harms. Exposures to it threaten human health (including transgenerational impacts) and the health of numerous organisms. In addition, many target plants are developing resistance to the compound, making it increasingly ineffective as a weed killer, and resulting in ever-more-intensive pesticide use. Glyphosate was classified in 2015 by the International Agency for Research on Cancer (IARC) as a probable human carcinogen.

Last year, a jury ordered Bayer to pay $2 billion to a couple who used glyphosate on their lawn for decades and who both suffered from non-Hodgkin lymphoma. Over 52,000 similar court cases are pending. But instead of removing this product from store shelves, Bayer-Monsanto is trying to settle the lawsuits and keep selling this toxic pesticide. Under the terms of the deals, Roundup® would continue to be sold in the U.S. without any safety warning. 

In light of the increasing evidence of the harm glyphosate can cause, some countries have stepped up restrictions or instituted bans on use of the compound, including Italy, Germany, France, Bahrain, Kuwait, Qatar, Saudi Arabia, United Arab Emirates, Bermuda, Fiji, Luxembourg, and Austria. A growing number of jurisdictions in some countries have taken similar actions. In the U.S., counties, towns, and cities, including Los Angeles, Seattle, and Miami, and many others in California, Florida, Illinois, Maryland, Massachusetts, New York, Washington State, and more, have banned glyphosate applications on public lands. The New York State legislature banned glyphosate last month.

The solution to the current federal “whack-a-mole” approach to mitigating the impacts of glyphosate (and all toxic pesticide) use is a wholesale transition away from the chemical dousing of public lands, agricultural fields, and all manner of maintained turf. Organic approaches to insect, weed, and fungal problems in agriculture and on other lands and landscapes (and in homes, gardens, buildings, et al.) do not involve toxic pesticides, and avoid the health and ecological damage they cause.

In addition to being genuinely protective of human health, organic management systems support biodiversity, improve soil health, sequester carbon (which helps mitigate the climate crisis), and safeguard surface and groundwater quality.

Bayer-Monsanto won’t protect butterflies, bees and our health on its own. Garden retailers, with Lowe’s and Home Depot leading the way, can help shrink the market for glyphostate/ Roundup® and help keep it out of our backyards and communities, while educating consumers on gardening and land management with an organic systems approach. 

Remind garden retailers they have an important role to play — let them know our health is more important than Bayer’s profits.

Letter to Lowe’s and Home Depot

Home and garden stores like yours can play a huge role in ending the use of this toxic pesticide in our backyards and across the country. Your step to eliminate use of neonicotinoids in live plant offerings helps protect monarchs and other pollinators. I am writing to ask you to stop selling glyphosate products such as Roundup®—as Costco has done—and encourage organic practices through product offerings and education.

Once numbering in the millions, barely 29,000 western monarch butterflies were found in California at last count. Pesticides pack a one-two punch against monarchs. Insecticides—particularly neonicotinoids—poison the caterpillars and butterflies as they feed. Glyphosate—the active ingredient in Bayer-Monsanto’s Roundup®—is wiping out milkweed, the only food source for monarch caterpillars. This has contributed to monarchs’ 90% decline in the past 20 years alone. They could vanish within our lifetimes.

Roundup has been marketed as effective and safe, but, in reality, its use delivers human and ecosystem harms. Exposures to it threaten human health (including transgenerational impacts) and the health of numerous organisms. In addition, many target plants are developing resistance to the compound, making it increasingly ineffective as a weed killer, and resulting in ever-more-intensive pesticide use. Glyphosate was classified in 2015 by the International Agency for Research on Cancer (IARC) as a probable human carcinogen.

Last year, a jury ordered Bayer to pay $2 billion to a couple who used glyphosate on their lawn for decades and who both suffered from non-Hodgkin lymphoma. Over 52,000 similar court cases are pending. But instead of removing this product from store shelves, Bayer-Monsanto is trying to settle the lawsuits and keep selling this toxic pesticide. Under the terms of the deals, Roundup® would continue to be sold in the U.S. without any safety warning.

Customers ask you for advice. In addition to removing glyphosate products from your shelves, your stores should advise customers to use organic alternatives. Organic alternatives work within an organic system that includes practices that build soil and increase biodiversity—including soil-building organisms, pollinators, and predators and parasites of plant-eating insects. Attempting to sell organic products as stand-alone “silver bullet” solutions dooms customers to failure, while educating them about the role of those products in an organic system will support nature organic land management and organic-compatible products.

We are living during a period that requires retailers, like you, to take responsible action in the face of inadequate federal toxic pesticide restrictions, despite the availability of environmentally responsible practices and products. We urge you to be a responsible retailer by taking glyphosate/Roundup® off your shelves and educating consumers on organic gardening and land management with organic-compatible products.

Thank you for considering my request and promoting good health through organic lawns and gardens.

Despite pressure to reopen schools, concerns persist about the threat to the health of children, teachers, school staff, and families. There are many complex social, scientific, and logistical issues involved in a decision to reopen schools for in-person teaching. 

>>Tell Congress and governors that schools must reopen only when safe. Schools must have adequate resources to ensure safety.

Beyond Pesticides joins the National Education Association (NEA), American Federation of Teachers (AFT), National Parent and Teacher Association (PTA), and others in calling for a well-thought-out approach to reopening schools only when it is shown that:

• The pandemic is under control in the community—as evidenced, for example, by an average daily community infection rate among those tested for COVID-19 below 5% and a transmission rate below 1%.
• Protections have been put in place to keep the virus under control and protect students and staff. These include accommodations for students and staff at high risk; measures and building retrofits to protect against all forms of transmission; procedures for detecting disease, quarantining, and notification; involvement of families and educators in decisions; monitoring; and enforcement.
• Plans are in place that ensure continuous learning equitably for all students, with training for educators, families, and students in the process of virtual instruction, and access to devices and high-speed internet for every student and teacher.

The risks of reopening schools come from both COVID-19, caused by the SARS-CoV-2 virus, and the measures that schools may take to protect students, family members, teachers, and staff. The health risks from the virus to young children (elementary school age) appear to be smaller than the risks to adults, although transmission or spread of the virus to adults is of concern.

Avoid Dangerous Disinfectant Use
As schools closed earlier in the year, attention was focused on virus-contaminated surfaces. While EPA has certified a large number of disinfectants as effective against SARS-CoV-2 (List N), many of these chemicals are hazardous and actually weaken the respiratory, immune, and nervous systems. At the same time, there are many safer disinfectants on EPA's list that are effective against the virus.

In terms of disinfecting surfaces, where half-lives (an indicator of the time of potential exposure) of the virus range up to 6.8 hours, school districts have been concerned with the costs involved in repeated disinfectant applications. In the interest of disinfecting many classrooms quickly, schools have been investigating, and sometimes investing in, devices that apply disinfectants as a fog or fine mist into the indoor ambient air. Such devices pose special risks, as a result of inhalation or absorption from resulting surface residues.

Fogging reduces disinfectant efficacy. First, devices are not registered by EPA, and EPA does not generally recommend fogging applications, or wide area spraying of disinfectants, to control COVID-19 and warns, “A disinfectant product's safety and effectiveness may change based on how you use it. If a pesticide product's label does not include disinfection directions for use with fogging, fumigation, wide-area, or electrostatic spraying, EPA has not reviewed any data on whether the product is safe and effective when used by those methods.” In 2013, EPA sent a letter requesting supporting data to those manufacturers whose antimicrobial (disinfection) products claim to control microorganisms when applied by fogging or misting. EPA cites the following reasons for believing that fogging and misting are not adequately effective:

• Application by fogging/misting results in much smaller particle sizes, different surface coverage characteristics, and potentially reduced efficacy when compared to sanitization or disinfection product applications by spraying, sponging, wiping, or mopping. 
• The absence of pre-cleaning in the presence of soil contamination, potential reaction with or absorption of the active ingredient for different surfaces, and humidity/temperature fluctuations can also impact distribution and efficacy of the product. 
• A surface treated by fogging/misting does not receive the same amount of active ingredient per unit area as the standard methods of application and, as a result, product efficacy may be greatly reduced.

Cleaning must precede disinfecting. Second, in order to be effective, disinfectants must be applied to clean surfaces. EPA refers to CDC's recommendation to clean and disinfect surfaces, using a detergent or soap and water prior to disinfection.

Fogging and aerosols adversely affect lungs. Finally, fogs and fine mists are aerosols of very small particles that can be carried deep into the lungs, where they cause more damage. According to the American Lung Association, “The differences in size make a big difference in where particles affect us. Our natural defenses help us to cough or sneeze some coarse particles out of our bodies. However, those defenses do not keep out smaller fine or ultrafine particles. These particles get trapped in the lungs, while the smallest are so minute that they can pass through the lungs into the bloodstream, just like the essential oxygen molecules we need to survive.” 

Electrostatic sprayers are also under consideration. They apply a positive charge to an area-wide spray as it leaves the nozzle, which causes droplets to be attracted to negatively charged surfaces. Users claim better, 360 degree, coverage when using electrostatic sprayers to disinfect a room. EPA has made it a priority to evaluate electrostatic sprayers as a delivery mechanism for disinfectants that it lists as effective (List N).

Fogging does not save labor time. There are several caveats to the use of electrostatic sprayers. First, charged particles may be deposited on the applicator, including in the nose, so personal protective equipment, said to be optional in advertising, should be used. Second, since CDC recommends cleaning first to ensure greater efficacy of disinfecting, it is not clear that spraying disinfectant saves very much time if it is necessary to first clean the surfaces. Paper and other absorbent materials must be removed from the space where the spraying is conducted. Finally, research shows that electrostatic application of disinfectant is not as effective as conventional cleaning and disinfection. In the future, it is possible that electrostatic sprayers may improve, and be subject to independent efficacy review by EPA. The issues of the need to pre-clean, remove papers, and provide PPE will remain. Thus, if the goal is to provide a quick application method that does not require hands-on treatment, then no area-wide spraying is adequate at this time.

Please see Beyond Pesticides' fact sheet on reopening schools and web page on Disinfectants and Sanitizers for more information.

Airborne Transmission of COVID-19
We now know that the spread of the SARS-CoV-2 virus is mainly person-to-person through the air, although spread through contaminated surfaces does play a role. The virus can remain infective as aerosol for at least three hours. A recent study finds, ”replication of SARS-CoV-2 in older children leads to similar levels of viral nucleic acid as adults, but significantly greater amounts of viral nucleic acid are detected in children younger than 5 years.” With average class sizes ranging from 15 to 24 students across elementary and secondary schools, and an average class time of more than 6 hours per day, the potential for spread of the virus can be great in the absence of controls of airborne virus. None of the disinfectants—even those applied as fog—control airborne virus.

The safest way to minimize the chance of contracting COVID-19 through the air is to minimize time spent indoors and practice social distancing with masks both indoors and outdoors. Schools that do decide to reopen indoor classrooms for in-person instruction will need to take precautions to remove viruses from the air. If schools can be retrofitted with engineering controls for air exchange and filtration, virus removal may be maximized. Such removal will still require the use of social distancing and face coverings to minimize exposure from larger droplets that do not remain suspended in the air, as well as surface cleaning and disinfection and handwashing.

Engineering controls include increasing ventilation with outside air, improving natural ventilation, use of evaporative coolers in hot, dry climates, improving the HVAC (heating, ventilation, and air conditioning) system, and use of a portable air cleaner or purifier. Ultraviolet (UV) light is also being investigated for its effectiveness in deactivating the virus. Critically, it is important to pay attention to patterns of air flow as well as rates of ventilation and purification. One early indicator of the importance of airborne transmission of the virus came from a restaurant in Guangzhou, China, where a presymptomatic person infected ten others who were downwind of the infected person in the air conditioning airflow. The American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) offers advice to retrofit and improve HVAC systems.

Transportation. Transportation cannot be ignored because it an area of high transmittal with numerous touch points and shared air space, raising similar issues to building spaces. Increased use of private transportation to schools will increase air pollution (which aggravates the respiratory system) and place higher burdens on those who cannot afford it. ASHRAE offers guidance for safer travel and maintenance of systems on transit vehicles.

Reopening schools safely will not be cheap. A report issued by the Government Accountability Office (GAO) on June 4, 2020 finds, “About half (an estimated 54 percent) of public school districts need to update or replace multiple building systems or features in their schools, according to GAO's national survey of school districts.” The upgrades or retrofits needed in an attempt to protect students and staff from the coronavirus are in addition to GAO-cited repairs, although in some cases—such as the 41% of upgrades needed for HVAC systems—COVID-19 protection could take the place of already-needed upgrades. Nevertheless, additional funding will be required to make facilities and transportation safer and pay for day-to-day maintenance and disinfection. 

>>We call upon Congress and governors to appropriate emergency funding to schools to ensure that all students, teachers, and staff can be protected from the pandemic before returning to school.

Letter to Congress and Governors:

I am writing because I am very concerned that schools are being pressured to reopen before they can do so safely—and lack the resources to ensure the safety of in-person classes. I am concerned that some schools seem to view unsafe disinfection measures—such as fogging—as necessary shortcuts in view of staffing and funding shortfalls.

I join with the National Education Association, American Federation of Teachers, National Parent and Teacher Association, and others in asking you to do your part to ensure the safety of all in our schools—students, teachers, and other staff.

The safety of all in our schools will require:

* Delaying reopening until the pandemic is under control in the community—as evidenced, for example, by an average daily community infection rate among those tested for COVID-19 below 5% and a transmission rate below 1%.

* Protections to be put in place to keep the virus under control and protect students and staff. Since we now know that the virus is airborne, upgrades to heating, ventilation, and cooling (HVAC) systems will be essential. Transportation must be included.

* Plans—developed in cooperation with the school community—to be in place to ensure continuous learning equitably for all students.

*Federal funding to support upgrades to buildings, buses, and electronic devices and access.

Already funding falls short of that required for the upkeep and upgrade of school buildings. A report issued by the Government Accountability Office (GAO) on June 4, 2020 finds, “About half (an estimated 54 percent) of public school districts need to update or replace multiple building systems or features in their schools, according to GAO's national survey of school districts.” The upgrades or retrofits needed to protect students and staff from the coronavirus are in addition to those repairs, although in some cases—such as the 41% of upgrades needed for HVAC systems—COVID-19 protection could take the place of already-needed upgrades. Nevertheless, additional funding will be required to make facilities and transportation safer and pay for day-to-day maintenance and disinfection.

Please see information at bp-dc.org/backtoschool

Thank you for your help with this urgent issue.

The effects of pesticide use are important, yet ignored, factors affecting people of color (POC) who face elevated risk from Covid-19 as essential workers, as family members of those workers, and because of the additional or cumulative risk that pesticides pose. As a part of this deadly combination, exposure to pesticides occurs at work, in community parks, schools and playing fields, and through food residues. EPA is ignoring the real hazards resulting from a combination of exposures that is reflected in the statistics that have emerged—with farmworkers suffering a rate of coronavirus five times higher and landscapers three times higher than community rates. Why is this the case? Because pesticide exposure weakens the respiratory, immune, and nervous system and makes those exposed more susceptible to the coronavirus. 

EPA has the power to immediately, on an emergency basis, adjust allowable pesticide use and exposure, recognizing that we have alternative practices and products to meet food production and landscaping needs.

Tell Congress to require EPA to examine the contribution of pesticide exposure to Covid-19 and protect those at greatest risk, people of color.

Farmworkers and landscapers have been deemed essential employees during the coronavirus outbreak, but without mandated safety protocols or government assistance, have experienced an explosion in Covid-19 cases. Workers in these industries are primarily Latinx people of color, many of whom are undocumented. According to a report published by the University of California Los Angeles, Latinx Californians aged 50 to 64 have died from the virus at rate five times higher than white people of the same age.

Most people in the U.S. suffer from one or more chronic conditions identified as putting people at increased risk of dying from Covid-19. The diseases, which involve disruption of the immune system, include metabolic diseases of obesity, diabetes, liver, kidney, and cardiovascular disease, respiratory diseases including asthma, allergy, emphysema, and chronic obstructive pulmonary disease (COPD), in addition to autoimmune diseases, such as rheumatoid arthritis, multiple sclerosis, Crohn’s disease, and lupus. The chronic inflammation induced by these diseases makes a dangerous heightened response to coronavirus more likely. 

While metabolic, respiratory, and autoimmune disease is widespread, the poor working conditions to which farmworkers and landscapers are subject put them at disproportionate risk of pesticide-induced diseases. Occupational exposure to pesticides is, in fact, a form of institutionalized racism, putting people of color at disproportionate risk of death from Covid-19. 

It is essential that when EPA weighs risks and benefits of pesticide use, it does not allow risks to workers and people of color to be ignored or undervalued. An appraisal of the contribution of pesticide use and exposure to health outcomes of Covid-19 is urgently needed. 

Tell Congress to require EPA to examine the contribution of pesticide exposure to Covid-19 and protect those at greatest risk, people of color.

Letter to Congress

I am writing out of concern for disproportionate risks to people of color arising from pesticide exposure during this pandemic. Please take emergency steps to require EPA to examine the contribution of pesticide exposure to the severity of Covid-19.

The effects of pesticide use are important, yet ignored, factors affecting people of color who face elevated risk from Covid-19 as essential workers, as family members of those workers, and because of the additional or cumulative risk that pesticides pose. As a part of this deadly combination, exposure to pesticides occurs at work, in community parks, schools and playing fields, and through food residues. EPA is ignoring the real hazards resulting from a combination of exposures—reflected in the statistics showing that farmworkers suffer a rate of coronavirus five times higher and landscapers three times higher than community rates. Why? Because pesticide exposure weakens the respiratory, immune, and nervous system and makes those exposed more susceptible to the coronavirus.

Farmworkers and landscapers have been deemed essential employees during the coronavirus outbreak, but without mandated safety protocols or government assistance, have experienced an explosion in Covid-19 cases. Workers in these industries are primarily Latinx people of color, often undocumented. According to a report published by the University of California Los Angeles, Latinx Californians aged 50 to 64 have died from the virus at rate five times higher than white people of the same age.

Most people in the U.S. suffer from one or more chronic conditions identified as putting people at increased risk of dying from Covid-19. The diseases, which involve disruption of the immune system, include metabolic diseases of obesity, diabetes, liver, kidney, and cardiovascular disease, respiratory diseases including asthma, allergy, emphysema, and chronic obstructive pulmonary disease (COPD), in addition to autoimmune diseases, such as rheumatoid arthritis, multiple sclerosis, Crohn’s disease, and lupus. The chronic inflammation induced by these diseases makes more likely a dangerous heightened response to coronavirus.

While metabolic, respiratory, and autoimmune disease is widespread, the poor working conditions to which farmworkers and landscapers are subject put them at disproportionate risk of pesticide-induced diseases. Occupational exposure to pesticides may be seen as institutionalized racism, putting black and brown people at disproportionate risk of death from Covid-19.

Farmworkers and landscapers have been deemed essential employees during the coronavirus outbreak, but without mandated safety protocols, adequate regulatory review, or government assistance, have experienced an explosion in Covid-19 cases. Workers in these industries are primarily Latinx people of color, many of whom are undocumented. According to a report published by the University of California Los Angeles, Latinx Californians aged 50 to 64 have died from the virus at rate five times higher than white people of the same age.

It is essential that when EPA weighs risks and benefits of pesticide use, it does not allow risks to workers and people of color to be ignored or undervalued. An appraisal of the contribution of pesticide use and exposure to health outcomes of Covid-19 is urgently needed. Please mandate EPA to perform an emergency assessment of the contribution of pesticide exposure to Covid-19 vulnerability. To highlight the urgency of this assessment, EPA should be given three months to put in place temporary measures based on scientific literature and advice of medical personnel, with permanent measures to be codified within a year.

Thank you for your attention to this urgent issue.

Evian bottled water, produced by the French company Danone, is supposed to be so pure that scientists will calibrate their measuring devices with it. But new data from Swiss researchers finds it to be contaminated with a toxic fungicide. “The fact that even the Evian springs in the French Alps, which are hardly affected by humans, contain pesticide residues is alarming and shows the far too careless handling of these substances,” Roman Wiget, president of the international drinking water association AWBR told the German-language Swiss weekly. The answer is not to simply ban another toxic pesticide, only to be followed by another toxic pesticide, but foundational changes to agriculture and land management with a shift to organic practices. 

Tell Evian to protect water quality and the integrity of its purity claim by prominently supporting a worldwide shift to organic agriculture and land management.

Danone claims that the purity of Evian bottled water comes from its source in Cachat Spring at the base of the French Alps in the town of Évian-les-Bains, France, where it is “[p]rotected under a fortress of geological layers built by glaciers 30,000 years ago, it slowly travels through natural snowy, glacial rocks naturally filtering it.” Evian publishes results of water quality testing, supporting its claims of water high in natural minerals and lacking detections of synthetic chemicals.

Findings of the transformation products of the fungicide chlorothalonil, which is unlikely to have been used near the source of Evian water, demonstrate the fact that pesticides cannot be controlled. Evian, as a purveyor of “pure” water for people who are concerned about the contamination of their own local water supplies, should take actions to protect its water.

Chlorothalonil is a dangerous, highly toxic pesticide. As a probable human carcinogen, there is no safe dose. The transformation products found in Evian bottled water can be removed by carbon filtration, but such treatment results in contaminated carbon and places the burden of removal on Evian, rather than the chemical companies. Although other pesticides have not been found so far in Evian’s water, there is no reason to believe that the Cachat Spring is safe from contamination from other chemicals as long as chemical-intensive agriculture and land management is the norm.

As of 2020, chlorothalonil use is banned in the EU. However, long-distance transport is evidently responsible for the contamination of Cachat Spring water, and the presence of currently used pesticides in the Arctic is evidence of cause for concern. It is particularly worrisome that groundwater, as a principal source of drinking water, is increasingly found to be contaminated with pesticides, even those used far from the site where the groundwater is withdrawn. Action is required worldwide, and we are urging Danone to become a leader in protecting the environment and its brand.

Evian should protect the purity of its water by supporting Beyond Pesticides’ international campaign to transition to organic agriculture. This effort not only protects groundwater, but it confronts the apocalyptic challenges we face as a global community with the climate crisis and the devastation of biodiversity. In the short-term, Danone should protect its consumers and its integrity by using filtration to remove chemical contaminants and labeling when they cannot be removed. However, using filtration is only a limited short-term fix that does not address underlying chemical dependency on hazardous and persistent pesticides that are not needed for land management. 

Tell Evian to protect water quality and the integrity of its purity claim by prominently supporting a worldwide shift to organic agriculture and land management.

Thank YOU for all you do,
— The Beyond Pesticides Team

Letter to Antoine Portmann, President and General Manager, Danone Waters of America:

I am writing in reaction to findings that chlorothalonil transformation products have been found in Evian’s bottled water. Chlorothalonil is a dangerous, highly toxic pesticide. As a probable human carcinogen, there is no safe dose. The transformation products found in Evian bottled water can be removed by carbon filtration, but such treatment results in contaminated carbon and places the burden of removal on Evian, rather than the chemical companies.

Although other pesticides have not been found so far in Evian’s water, there is no reason to believe that the Cachat Spring is safe from contamination from other chemicals. The answer is not to simply ban another toxic pesticide, only to be followed by another toxic pesticide, but make foundational changes to agriculture and land management with a shift to organic practices. I am writing to implore Evian and the Danone company to prominently support a worldwide shift to organic agriculture and land management.

The Evian company is a victim of outdated, antiquated farming and land management practices, supported by the chemical industry that is poisoning the water supply worldwide. Evian bottled water is supposed to be so pure that scientists will calibrate their measuring devices with it. The fact that even the Evian springs in the French Alps, which are protected from most human impacts, contain pesticide residues is alarming and demonstrates that pesticides cannot be controlled. Evian, as a purveyor of “pure” water for people who are concerned about the contamination of their own local water supplies, should take actions to protect its water supply not through a chemical-by-chemical response, but with holistic and systemic change.

As of 2020, chlorothalonil use is banned in the EU. However, long-distance transport is evidently responsible for the contamination of Cachat Spring water, and the presence of currently used pesticides in the Arctic is evidence of cause for concern. It is particularly worrisome that groundwater, as a principal source of drinking water, is increasingly found to be contaminated with pesticides, even those used far from the site where the groundwater is withdrawn. Action is required worldwide.

I request that Evian protect the purity of its water by supporting Beyond Pesticides’ international campaign to transition to organic agriculture and land management. This effort not only protects groundwater, but it confronts the apocalyptic challenges we face as a global community with the climate crisis and the devastation of biodiversity. In the short-term,

Danone should protect its consumers and its integrity by using filtration to remove chemical contaminants and labeling when they cannot be removed. However, using filtration is only a limited short-term fix that does not address underlying chemical dependency on hazardous and persistent pesticides that are not needed for land management. The company should protect its consumers and its integrity by using filtration to remove chemical contaminants and labeling when they cannot be removed.

The contamination caused by toxic pesticide use, no longer needed to grow food or manage land safely and economically, has cascading effects and requires an urgent holistic response. I am asking you— will Danone become a leader in advancing organic agriculture and land management?

Thank you, in advance, for your response.

Does your community spray toxic pesticides for mosquitoes? In a well-intentioned but ill-informed attempt to prevent mosquito-borne illness such as West Nile virus, many communities spray insecticides (adulticides) designed to kill flying mosquitoes. If your community is one of these, then your public officials need to know that there is a better, more-effective, way to prevent mosquito breeding.

>>Tell your public officials to stop spraying pesticides and adopt a safe, effective mosquito management plan.

The problem with mosquito pesticides. Two classes of insecticides are favored by mosquito spray programs—organophosphates and synthetic pyrethroids. In order to better target flying mosquitoes, adulticides are generally applied as ultra-low-volume (ULV) formulations that will float in the air longer than usual. 

Pesticides are toxic chemicals and can exacerbate respiratory illnesses like Covid-19.
Organophosphates, which include malathion (Fyfanon), naled (Dibrom), and chlorpyrifos (Mosquitomist for public health uses only) are highly toxic pesticides that affect the central nervous, cardiovascular, and respiratory systems. Symptoms of poisoning in humans include numbness, tingling sensations, headache, dizziness, tremors, nausea, abdominal cramps, sweating, incoordination, blurred vision, difficulty breathing, slow heartbeat, loss of consciousness, incontinence, convulsions, and death. Some organophosphates have been linked to birth defects, cancer, and brain effects. Breakdown times range from a few days to several months, depending on conditions.

Synthetic pyrethroids, which include resmethrin (Scourge), sumithrin (Anvil), and permethrin, are adulticides patterned after pyrethrum (an insecticide derived from chrysanthemum plants), that have been chemically engineered to have greater toxicity and longer breakdown times. Almost all synthetic pyrethroid mosquito products use synergists like piperonyl butoxide (PBO), which increases potency and compromises the body's ability to detoxify the pesticide. PBO causes a range of short- and long-term effects, including cancer and adverse impacts on liver function and the nervous system. Symptoms of synthetic pyrethroid poisoning include: dermatitis and asthma-like reactions, eye and skin irritation, and flu-like symptoms. Synthetic pyrethroids are endocrine disruptors and have been linked to breast and prostate cancer. People with asthma and pollen allergies should be especially cautious. Exposure has resulted in deaths from respiratory failure. Breakdown times range from a few hours to several months.

Mosquito spraying also hurts the environment. 
Naled, an organophosphate commonly used for mosquito control, affects a variety of non-target animals, including fish, insects, aquatic invertebrates, and honey bees. Naled is moderately acutely toxic to mammals, moderately to very highly toxic to freshwater fish and birds, highly toxic to honey bees, and very highly toxic to freshwater aquatic invertebrates, and estuarine fish and invertebrates. Elevated mortality rates among honey bees have been documented after nighttime aerial ULV applications of naled. Average yield of honey per hive is significantly lower in exposed hives.

Synthetic pyrethroids are highly toxic to fish and honey bees, even in low doses. Beneficial insects, including mosquito predators like dragonflies, will be killed by synthetic pyrethroids and organophosphates. 

Pesticides used to treat adult mosquitoes are not effective.
Spraying to kill adult mosquitoes (adulticiding) is usually the least effective mosquito control method. For example, efforts to control the transmission of malaria are encountering a big, though predictable, problem—the mosquitoes that transmit malaria are developing resistance to at least five of the insecticides that have been central to limiting transmission of the disease. A study released in late June reveals a dramatic increase in resistance to pyrethroid insecticides and DDT across sub-Saharan Africa. This signals the failure of a mainstay chemical approach to the spread of malarial mosquitoes; this same problem—resistance—occurs in chemical management of agricultural pests and weeds, and with antibiotics to treat human bacterial infections. This study underscores a point Beyond Pesticides has made repeatedly—resistance to pesticides (whether insecticides, herbicides, biocides, fungicides, or medical antibiotics) is inevitable. The solution to containing the spread of mosquito-borne diseases lies not in the use of more and different chemicals, but in nontoxic approaches that respect nature and ecological balance.

Preventing the problem. Beyond Pesticides offers resources for managing mosquitoes and mosquito-borne disease without the use of toxic pesticides. A better mosquito management plan protects public health and the environment. There are steps that can be taken to eliminate breeding sites around homes and buildings, and throughout the community. For example:

• Clean up standing water on residential property.
• Get rid of unnecessary debris, such as old tires, on residential and commercial property.
• At least twice a week, empty water from toys, buckets, birdbaths, swimming pool covers, and any other areas where water can collect.
• Drill holes in swing tires, and in the bottoms of recycling bins and other outside containers.
• Clean out rain gutters and make sure they drain properly.
• Where water cannot be emptied, the bacterial larvicide Bacillus thurigiensis israelensis is a least-toxic option.
• Turn garbage can covers right side up.
• Utilize safe repellents and other methods to protect against mosquito bites.
• Establish community-wide public awareness campaigns.

Local public policy is key to long-term solutions. Outbreaks of disease-carrying mosquitoes often result from habitat disturbance, such as deforestation, impairing wetlands, and spraying insecticides. Restoring the health of ecosystems helps keep mosquitoes under control. Native minnows, for example, can provide effective control of mosquito larvae breeding in standing water.

Spread the word by using Beyond Pesticides' door hangers.

>>Tell your public officials to stop spraying pesticides and adopt a mosquito management plan that protects public health and the environment.

Soil is central to organic production. Therefore, hydroponic operations should not be considered eligible for organic certification, and the National Organic Program (NOP) must take a clear position in opposition to hydroponics and other non-soil-based methods in organic production, including containers. Organic farmers and consumers strongly agree that organic production must be soil-based. 

Tell NOP hydroponics is not organic! Educate your congressional representatives and senators.

NOP authorizes the certification of hydroponic operations as organic. This undermines the authenticity of organic farming and creates unequal competition, market instability, and consumer distrust in organic certification.

Organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on environmentally beneficial methods such as green manure, crop rotation, and biological pest management.

On March 3, 2020, the Center for Food Safety (CFS) filed a lawsuit challenging the USDA’s decision to allow hydroponics operations to be certified organic. Organic farmers and consumers believe that the organic label means two things: grown in the soil and farmed in a manner that builds soil biology and the natural cycling of nutrients. Hydroponics meet neither of these requirements and involves methods of growing crops that is dependent on soluble synthetic nutrients.

Soil Ecology Supports Healthy Crops
Historically, perhaps the most important principle of organic production is the “Law of Return,” which, together with the rule “Feed the soil, not the plant” and the promotion of biodiversity, provide the ecological basis for organic production and land management. Together these three principles describe a production system that works with natural systems.

The Law of Return says that we must return to the soil what we take from the soil. Non-crop organic matter (residue) is returned directly or through composting plant materials or manures. To the extent that the cash crop removes nutrients, they must be replaced by cover crops, crop rotation, or additions of off-site materials, when necessary. 

Although some hydroponic producers may compost residues, they do not return the residues to the hydroponic system and close the loop. Inputs of organic matter reported by hydroponic practitioners are produced off-site, with no return to their production system. While most organic growers depend on some off-site inputs, most of the fertility in a soil-based system comes from practices that recycle organic matter produced on-site.

The cycling of organic matter and on-site production of nutrients—as from nitrogen-fixing bacteria and microorganisms that make nutrients in native mineral soil fractions available to plants—is essential to organic production. The Law of Return is not about feeding plants, but about conserving the biodiversity of the soil-plant-animal ecological community.

“Feed the soil, not the plant” reminds us that the soil is a living superorganism that supports plant life as part of an ecological community. We do not feed soil organisms in isolation, to have them process nutrients for crop plants; we feed the soil to support a healthy soil ecology, which is the basis of terrestrial life. Feeding the soil is intended to support the soil ecosystem is intrinsically counter to a hydroponic system. Hydroponics, in bypassing the soil ecology, rely on added plant nutrients that feed the plants.

Additionally, creating a structure to house hydroponic goes against the legal requirement in federal organic law: “The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.” 

Biodiversity Conservation
Finally, biological diversity is important to the health of natural ecosystems and agroecosystems. The definition of “organic production” in the federal organic regulations requires the conservation of biodiversity. As stated in the NOP Guidance on Natural Resources and Biodiversity Conservation (NOP 5020),

The preamble to the final rule establishing the NOP explains: “The use of ‘conserve’ [in the definition of organic production] establishes that the producer must initiate practices to support biodiversity and avoid, to the extent practicable, any activities that would diminish it. Compliance with the requirement to conserve biodiversity requires that a producer incorporate practices in his or her organic system plan that are beneficial to biodiversity on his or her operation.” (76 FR 80563) 

Biodiversity promotes ecological balance, which protects farms from outbreaks of damaging insects and disease. It supports the health of the soil through the progression of the seasons and stresses associated with weather and farming. It supports our health by offering a diversity of foods. On a soil-based organic farm, many practices support biodiversity—from crop rotations to interplanting to devoting space to hedgerows and other non-productive uses. Many of these practices can and should be used by farmers producing food in greenhouses. However, hydroponics is considered a monocultural environment that does not support biodiversity. Thus, it is not enough for a hydroponics producer to say it is not diminishing soil and plant biodiversity—the operation must take active steps to support biodiversity.

Organic production allows exceptions to soil-grown produce like mushrooms, which grow on ecologically appropriate substrate such as manure or wood and sprouts. Sprouts are not required to be grown in soil because sprout production is a way of processing seeds. However, these exceptions imply that organic production is soil-based.

The ecological system of a hydroponic nutrient system is more like a fermentation chamber—a means of processing plant nutrients—than the soil ecosystem of an organic farm.

Integral to the Organic Foods Production Act (OFPA) is the understanding that soil is alive, not merely a medium for supporting plants, as is the case, to a large extent, in  “conventional” chemical-intensive agriculture. “Conventional” farmers pour poisonous synthetic fertilizers into soil without the protecting the ecological community. Interestingly, in defining organic in OFPA, organic producers compared conventional agriculture to hydroponics because it bypasses the soil. 

Practitioners of hydroponics have learned the value of biology in their nutrient solutions. However, the biology of fermentation tanks is not “soil ecology,” although it is merely an artificial mimic of soil ecology and a reductionist approach to manipulating nature.

Threatening the Value of the Organic Label
Organic farmers and consumers view the current interpretation of organic as a threat to the integrity of the organic seal, impacting every organic farmer and consumer in every state. The consideration of hydroponic production in organic is an issue that impacts every aspect of the organic industry. Members of the organic industry consistently rank this issue, maintaining consumer’s confidence in the organic seal, as a top priority and mandatory to their success.

However, it is critical that we address any compliance limitations of organic certification systems when it occurs and ensure corrective action in a timely fashion with full transparency. Without this kind of response, public trust in the organic food label will suffer dramatically. Additionally, to the extent that the enforcement system is known to be highly rigorous, it will decrease the likelihood of aberrant behavior.

One factor leading consumers to purchase organic produce is its perceived greater nutrient value. Research supports that perception—showing that nitrate concentrations in leafy vegetables are significantly different for hydroponic, conventional, and in-ground organic systems, with desired nutrients generally more concentrated in organic vegetables.

Prior to the coronavirus outbreak, the organic industry was meeting with congressional staff to explain its position. We need your help to continue that effort as your outreach to NOP and your elected official is critical to our success.

Because of the high turnover of congressional staff, groups opposing this policy need to continuously educate our elected officials on this issue.

We urge you to take action by sending a letter to NOP and your congressional representative. 

Tell NOP hydroponics is not organic! Educate your congressional representatives and senators.

Thank you!
The Beyond Pesticides Team

EPA’s proposed interim decision (PID) on the weed killer clopyralid is inadequate to protect human health, property, nontarget plants, and pollinators from damage. Clopyralid poses unreasonable adverse effects that cannot be remedied by EPA’s proposed fixes. It should be banned.

Sign the petition by noon Monday, July 6! Tell EPA to ban the persistent toxic herbicide clopyralid.

Clopyralid is a toxic persistent herbicide used to control broadleaf weeds on lawns and turf, range, pastures, right-of ways, and on several crops. Approximately 1.6 million pounds of clopyralid is used on 20 million acres per year in the U.S. on agricultural land, but it is also commonly used to kill dandelions, clover, and thistles. Lawn care operators applied over a million pounds of clopyralid in 2013.

Clopyralid is notorious for causing damage to nontarget plants. The registration was modified in 2002 to delete residential turf uses from the clopyralid product label. Additionally, under the amended label professional applicators are required to notify property managers not to compost clippings from treated grass. EPA proposes to expand the prohibition to include school turf, but clopyralid products will continue to be used on golf courses and certain other forms of nonresidential turf, as well as farm, ranch, and forestry uses.

Clopyralid causes environmental and property damage through drift, runoff, use of treated plant material (such as straw or grass clippings) for mulch or compost, contaminated irrigation water, and urine or manure from animals consuming treated vegetation. Clopyralid is “considered volatile,” according to EPA, meaning that it can evaporate from foliage and soil after application, move away from the application site, and “adversely affect nontarget broadleaf plants.” EPA calculated that volatilization of only one percent of applied clopyralid would be enough to damage nontarget plants.

Clopyralid can cause damage to sensitive plants at levels of 10 parts per billion. It is not broken down in composting facilities, and composters are very concerned about carry-over of clopyralid and other persistent herbicides, such as aminopyralid, aminocyclopyrachlor, and picloram into compostable materials. Clopyralid can enter the composting facility through lawn clippings, hay, straw, crop residues, and manure. Compost facilities now test for residues of persistent herbicides, but such tests are time-intensive and expensive.

In November 2002, the registration of clopyralid for use on residential lawns was voluntarily cancelled by the registrant, Dow AgroSciences. However, compost feedstocks are contaminated by other uses that are still allowed. Residues from any of these uses may find their way to composting facilities. Grass clippings, hay, and straw may also be used as mulch, allowing direct transfer of the herbicide to susceptible plants.

The contaminated mulch and compost may be used by homeowners, landscapers, or organic farmers. In the case of homeowners, it can mean the loss of expensive plantings. Landscapers may be liable for damages. In the case of organic farmers, it can mean the loss of a crop and possibly the loss of organic certification.

Clopyralid is not metabolized by animals but passes through in urine and feces. Thus, farmers and composters are advised to avoid manure from animals that may have eaten hay or feed that may be contaminated with it or other persistent herbicides. EPA proposes label amendments to mitigate these problems. If these label restrictions are followed, they may minimize the spread of clopyralid residues into sensitive areas. Doing so, however, reduces the availability of organic nutrients for crops and compost makers, thus burdening organic farmers and composters. This places undue burdens on those who do not benefit from the use of the herbicide and makes agriculture less sustainable. Instead, registrations of clopyralid and other persistent herbicides should be cancelled.

All herbicides, especially those targeting broadleaved plants, pose the risk of removing plants that provide food and habitat for pollinators. Some of those pollinators may be threatened or endangered species. As EPA admits, it has not evaluated risks to threatened and endangered species. Nor has it completed endocrine disruption evaluation. Since both of these are very sensitive consequences—that may result from much lower exposures than those evaluated thus far—reregistration must not proceed until those evaluations—including consultation with U.S. Fish and Wildlife Service and National Marine Fisheries Service—are complete. 

Although EPA downplays them, clopyralid does present human health risks. Clopyralid is classified by EPA in acute toxicity class III as slightly toxic. Laboratory studies have shown that clopyralid is a severe eye irritant and dermal irritation has also been noted, which can lead to skin sensitization for prolonged skin exposures. Some developmental and reproductive effects have been observed in laboratory animals. The livers and kidneys of rats as well as the livers of dogs were affected by changes in weight and decreased red blood cell counts. Another study found that weights of rabbit fetuses decreased at both low and high doses of clopyralid. Skeletal abnormalities were also observed in these fetuses at all doses. Clopyralid products also contain toxic contaminants and “inert” or “other” ingredients.

Resistance to herbicides is an expected consequence of their use, so any perceived benefit of using an herbicide must be discounted by its reduced lifespan as an effective weed control. There are currently 514 unique cases (combinations of species and sites of action) of herbicide resistant weeds globally, with 262 species (152 dicots and 110 monocots). Weeds have evolved resistance to 23 of the 26 known herbicide sites of action and to 167 different herbicides. Herbicide resistant weeds have been reported in 93 crops in 70 countries. Resistance to clopyralid is known in four species, and resistance to other synthetic auxins has been documented in other species. 

The growth of organic agriculture demonstrates the viability of nontoxic alternatives in agriculture. Nonorganic producers are looking to organic practices for help in dealing with the problem of herbicide resistance. In turf systems, managers are increasingly successful using organic systems, often mandated by local ordinances.

The use of clopyralid poses risks to human health, property, and the environment that are borne mostly by those who do not receive any benefit from the use of the herbicide. The risks are not outweighed by benefits, so the registration of clopyralid should be cancelled.

See Beyond Pesticides comments for more details and references.

Sign the petition by noon Monday, July 6! Tell EPA to ban the persistent toxic herbicide clopyralid.

Bayer’s Monsanto is requesting non-regulated status for corn that will increase the use of drift-prone and toxic herbicides. This means that the planting of a new genetically engineered (GE) variety of corn, which requires substantial weed killer use, will not be restricted in any way. The syndrome of ‘more-corn, more-pesticides, more-poisoning, more-contamination’ must stop—as we effect an urgent systemic transformation to productive and profitable organic production practices. Because USDA is proposing to allow a new herbicide-dependent crop under the Plant Protection Act, the agency must, but does not, consider the adverse impacts associated with the production practices on other plants and the effects on the soil in which they are grown. Business as usual is not an option for a livable future.

Sign the petition. Tell USDA we don’t need more use of 2,4-D, Dicamba, and other toxic herbicides associated with the planting of new GE corn.

Bayer-Monsanto has developed multi-herbicide tolerant MON 87429 maize, which is tolerant to the herbicides 2,4-D, dicamba, glyphosate, glufosinate, and aryloxyphenoxypropionate (AOPP) acetyl coenzyme A carboxylase (ACCase) inhibitors (so-called “FOP” herbicides, such as quizalofop). Now the company wants this corn to be deregulated—allowing it to be planted and the herbicides use without any restrictions. The petition below, and our formal comments explain the dangers in greater detail. 

2,4-D is a phenoxy herbicide that is as well known for its propensity to drift as it is for its damaging health and environmental effects. Approval of Bayer-Monsanto’s application would result in adverse impacts and contamination, along with the demonstrated plant-damaging effects. Over the decades of its use, 2,4-D has been linked to an increased risk of birth defects, reduced sperm counts, increased risk of non Hodgkin lymphoma, Parkinson’s disease, and hormone disruption, as well as other health problems.  

2,4-D drift has long been a known problem to off-site locations, endangered species, and non-target crops. Many forms of 2,4-D volatilize above 85oF and 2,4-D drift has been known to damage tomatoes, grapes, and other plants. Herbicide concentrations 100 times below the recommended label rate have been reported to cause injury to grapes.

Dicamba is a selective benzoic acid herbicide similar in structure and mode of action to phenoxy herbicides like 2,4-D. We have concerns that increased use of dicamba will lead to elevated human and environmental exposures, and especially via contamination of waterways. Concerns about dicamba drift have already proved to be valid. First registered in the late 1960s, dicamba has been linked to cancer, reproductive effects, neurotoxicity, birth defects, and kidney and liver damage. It is also toxic to birds, fish and other aquatic organisms, and known to leach into waterways after an application. It is a notoriously drift-prone herbicide. Studies and court filings show dicamba able to drift well over a mile off-site after an application.

Glyphosate is a broad spectrum, post-emergent, non-selective systemic herbicide used on non-cropland, as well as a variety of crops. It has seen the largest use in crops that are genetically engineered to be tolerant to it, where it can kill most grassy and broadleaved plants. Glyphosate products, such as Monsanto’s Roundup, are formulated with surfactants and other ingredients to increase its effectiveness as a weed killer.

Reviews of glyphosate and glyphosate-based herbicides demonstrate a growing scientific consensus and concern about their health, environmental, and social impacts. A group of well-known and respected scientists collaborated on a consensus “Statement of Concern” stating that glyphosate is more persistent in the environment than previously believed and that evidence has accumulated over the past two decades, showing that glyphosate-based herbicides have serious impacts on human health and the environment, the extent of which has yet to be fully determined. Epidemiological studies—in which exposure is to formulated products rather than the technical grade active ingredient glyphosate—have found a positive association between exposure to glyphosate-based herbicides and cancer.

On March 20, 2015, the  International Agency for Research on Cancer (IARC) announced that it had classified glyphosate as a class 2A carcinogen, as “probably carcinogenic to humans.” This category is the most definitive of any based on standard laboratory animal testing. An April 2019 report by the Agency for Toxic Substances and Disease Registry (ATSDR) — an agency of U.S. Department of Health and Human Services — documented evidence of findings that support glyphosate’s carcinogenicity.

Glyphosate is also an antibiotic and, as such, has negative impacts on the human gut biota. The imbalance (dysbiosis) of bacteria in the gut has been associated with many modern diseases. Use of antibiotics, like glyphosate, in agriculture allows residues of antibiotics and antibiotic-resistant bacteria to emerge on agricultural lands, move through the environment, contaminate waterways, and ultimately reach consumers in food. Both the human gut and contaminated waterways provide incubators for antibiotic resistance. 

The Northwest Center for Alternatives to Pesticides summarizes the effects of glufosinate:

Glufosinate is a broad-spectrum herbicide that kills plants by inhibiting the enzyme glutamine synthetase, an enzyme also found in animals, including humans. Glufosinate chemically resembles glutamine, a molecule used to transmit nerve impulses in the brain. Neurotoxic symptoms observed in laboratory animals following ingestion, dermal exposure, or inhalation of glufosinate include convulsions, diarrhea, aggressiveness, and disequilibrium. Dogs appear to be the laboratory animal most sensitive to glufosinate. Ingestion of glufosinate for two weeks caused heart and circulatory failure resulting in death. Exposure of pregnant laboratory animals to glufosinate caused an increase in premature delivery, miscarriages, the number of dead fetuses, and arrested development of fetal kidneys. Concentrations of a glufosinate-containing herbicide of less than one part per million cause mortality of oyster and clam larvae. Several species of disease-causing fungi are resistant to glufosinate, while a beneficial fungus that parasitizes disease-causing fungi is very susceptible to glufosinate. This means that use of glufosinate can have “important microbiological consequences.

Quizalofop is a developmental and reproductive toxin and recognized as an endocrine disruptor by the EU. It carries the signal word “Danger” and requires full protective equipment. The label carries the signal word “Danger,” warning of health and environmental hazards.

Dicamba and 2,4-D vapor drift and subsequent crop injury to sensitive broadleaf crops have been frequent problems. Abnormal leaf growth, floral development, reduced yield, and reduced quality have all been observed from dicamba drift. These impacts have severe economic consequences for non-GE and organic farmers. The burden should not be placed on these farmers to protect themselves from drift with best management practices. 

The Animal and Plant Health Inspection Services (APHIS) cannot assume that the environmental impacts associated with herbicide drift will be mitigated by the registration requirements established by EPA on pesticide labels. Unfortunately, label directions have been shown to have no effect on decreasing spray drift. In fact, EPA has acknowledged this and has attempted to review and revise pesticide labeling guidance. EPA’s efforts to mitigate against potential risks from drift by requiring buffer zones and application restrictions have proven ineffective. 

USDA Must Deny Monsanto’s Petition. APHIS has a responsibility under the law, the Plant Protection Act, to prohibit and/or restrict any plant or plant product that poses a risk to the environment. APHIS must fully review the salient impacts of multi-herbicide-tolerant MON 87429 corn, and the expected increase in use of drift-prone and toxic herbicides and reject the petition for deregulation. 

GE crops are not the solution for glyphosate resistant weeds created by glyphosate-resistant GE crops. Had a proper environmental assessment been conducted by APHIS on previous GE decisions, the economic and environmental threat of resistant, invasive weeds may have been avoided. It is time for the agency to focus on other sustainable, integrated methods for long-term weed management, which allow our nation’s farmers to get off the toxic treadmill. 

USDA/APHIS must not escalate the American agricultural economy’s broad reliance on herbicides because of the failure of glyphosate GE technologies. Now is the time to concede that GE technologies have not lived up to their promises and encourage our nation’s farmers to return to more sustainable methods of farming.

Sign the petition. Tell USDA we don’t need more use of 2,4-D, Dicamba, and other toxic herbicides associated with the planting of new GE corn.

Thank you!
The Beyond Pesticides Team

In the wake of the national groundswell for equity and justice in the face of rampant inequality and police brutality against people of color, we acknowledge, during Pollinator Week, holistic actions are needed to solve systemic societal problems that cause racial disparities. Those fighting for environmental justice understand that the harms inflicted by toxic chemical production and use cause disproportionate adverse effects on people of color—from fenceline communities near chemical production plants, to the hazardous and inhumane working conditions in agricultural fields, to the elevated risk factors for black and brown people from toxic pesticide exposure patterns. 

Pollinator Week reminds us that we must nurture the ecosystem, which we depend on for life, with a fierce commitment to its inhabitants and a focus on those at highest risk. Therefore, this week is a time to renew our commitment to environmental justice and seek the adoption of policies and practices in our communities, and across the nation and the world, that recognize the urgency to address the disproportionate harm inflicted by toxic pesticide use. 

>>TAKE ACTION! Here are three things you can do today.

Protect Low-Income and People of Color Communities—As The Black Institute in New York City wrote in its report, Poison Parks (2020), “Unfortunately, people of color that live in low-income neighborhoods bear the brunt of poor environmental policy and suffer from environmental racism.” 

As quoted in the report by Reverend Dr. Benjamin F. Chavis, Jr., founder of the United Church Commission on Racial Justice, “Environmental racism is racial discrimination in environmental policy-making. It is racial discrimination in the enforcement of regulation and laws, in the deliberate targeting of communities of color for toxic waste disposal and the siting of polluting industries. It is racial discrimination in the official sanctioning of the life-threatening presence of poisons and pollutants in communities of color; and, it is racial discrimination in the history of excluding people of color from mainstream environmental groups, decision-making boards, commissions, and regulatory bodies.”

People in communities of color are more likely to be exposed to toxic pesticides and other forms of pollution. As white and more affluent communities influence law and policy to stop industrial site construction and toxic chemical exposure, polluting industries target low-income and people of color areas. While wealthy and white individuals have the opportunity to manage their lawns without toxic pesticides, low-income and black and brown families, particularly those in urban areas with dense housing, often have public parks as their only green space. In its report, The Black Institute documents New York City public spaces in low-income people of color communities being sprayed with the weed killer glyphosate at significantly higher rates than other parts of the city.

Green space is a critical component of a healthy ecosystem that we depend on for public health. Studies find that throughout the country, urban low-income and people of color communities have less access to healthy outdoor areas. Poisoning the few parcels of green space communities of color have access to is a grave injustice. By expanding access to pesticide-free green spaces, we expand the ability for people in low-income and people of color communities to experience the joy and wonders of the natural world. Creating these lasting connections with the natural world is interwoven with a healthy ecosystem that supports critical species, such as pollinators. We protect people when we protect pollinators.

Protect Workers—Farmworkers are at disproportionate risk of pesticide poisoning. According to Farmworker Justice, 76% of all farmworkers identify as Latino/Hispanic. Most are men; 28% are female. The majority are married with children. For the critical work they perform, farmworkers receive poverty wages, averaging under $20,000 a year. 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. 

Farmworkers are not covered under the laws of the U.S. Department of Labor’s Occupational Health and Safety Administration (OSHA), but by inadequate federal pesticide law known as worker protection regulations, governed by the U.S. Environmental Protection Agency (EPA). It took over 25 years to introduce modest updates to these rules (under the Obama Administration in 2015), but the Trump Administration immediately began to unwind farmworker safeguards. The Administration recently put forth proposals that would eliminate, reduce, or weaken application exclusion zones (buffer areas where individuals are not supposed to enter during a pesticide application) and curtail labor rights for both foreign and domestic farmworkers.

As Farmworker Justice wrote, “At the same time that the Administration seeks to transform the farm labor force of 2.4 million people into a workforce of 21st-century indentured servants, it is demonizing hard-working immigrants and ratcheting up cruel, heartless and counterproductive arrests and deportations, targeting many of our nation’s current experienced and valued farmworkers.”
Protecting farmworkers from toxic chemicals will lead to heathier foods and healthier pollinator populations. Demand justice and just conditions; stand in solidarity with farmworkers.

Demand Food Justice—Low-income and people of color are more likely to live in areas with little to no access to fresh, healthy foods. Moreover, when there is some access to this food, fruits and vegetables are often prohibitively expensive. Farmers markets and organic products are often out of reach due to their expense, distance, and operating times. 

Foods that are most affordable are often conventional products treated with toxic pesticides. Not only do these chemicals put individuals at greater risk of pesticide induced diseases, they also poison farmworkers and their families. 

Increasing people’s access to healthy, pesticide-free foods will protect pollinators. Declines in pollinator populations are likely to increase global malnutrition and disease. Vulnerable communities are most likely to be impacted by this effect. Produce will not disappear overnight, but become increasingly expensive and out of reach, particularly for those already living in areas with precarious access to fresh foods. 

Support Black Lives Matter—A systemically racist culture that does not respect the rights of low-income and black and brown people is not one with the capacity to solve the pollinator crisis; it is not one that can help repair the natural world. Beyond Pesticides stands with Black Lives Matter. Read our statement. This week and from now on, support, through your time and energy and donations, organizations that are working to advance black food sovereignty, and farmworker rights. 

TAKE ACTION—Three Things You Can Do Today

1. Make your local green spaces places where community and local ecology thrive. Get pesticides out of your local parks and playing fields by pushing for the adoption of organic land management policies. For information and strategies you can use, see Beyond Pesticides Tools for Change.
2. Stand up for farmworkers. Tell your congressional representative and senators that EPA must protect farmworkers from toxic pesticide exposure. 
3. Make a donation to The Black Institute. The Black Institute isn’t a think-tank, it’s an action-tank. Through a head, heart, and feet strategy, TBI injects new ideas for achieving racial equity and justice into the policy realm. The Black Institute is a leader in advancing organic land management legislation in New York City that bans toxic pesticides. Donate now.

On May 7, President Trump issued an executive order (EO) purporting to “promote American seafood competitiveness and economic growth,” while, in fact, permitting offshore aquaculture in federal waters with reduced environmental safeguards. Instead, we need stronger federal regulation in order to protect the environment and public health.

This EO adds to the Trump Administration’s shameful record of dismantling environmental protections, failing to enforce those that do exist, undermining science, and weighing agrochemical and other industry interests over those of the public and the environment. The EO will further erode regulations that have governed the operation of so-called “fish farms” and open enormous marine areas to exploitation by this industry.

Tell Congress to save our oceans.

U.S. aquaculture is a $1.5 billion industry, with almost 3,000 operations. Regulation of aquaculture is shared by a number of federal, state, and local agencies. Much of the regulation is at the state and local level because each state and locality may regulate permitting based on zoning, water use, waste discharge, wildlife management, processing, and other aspects of aquaculture operations. 

Trump’s EO reduces federal regulation by designating the National Oceanic and Atmospheric Administration (NOAA) as the lead agency in the U.S.’s exclusive economic zone, the ocean waters spanning from three to 200 miles of the U.S. coastline. Prior to this EO, such facilities were not permitted in this zone. The EO shortens timelines for federal decisions to 90 days for drafting of a permit, and two years for environmental review. Center for Food Safety lead counsel George Kimbrell said in a Seattle Times article, “NOAA [has] wanted to do this sort of industrial [aquaculture] permitting not just in the Gulf of Mexico but in the Pacific and along the Atlantic coast.” NOAA has also pursued rulemaking for the industry in waters off of Hawaii and other Pacific islands. 

The order cites the need for “removing outdated and unnecessarily burdensome regulations,” reducing “burdens on domestic fishing,” and increasing production. However, federal regulations are needed to address collapsing fisheries, rebuilding fish stocks, and guiding the industry in a more sustainable direction. Even without this order, oceans are rapidly losing biodiversity due to global climate change, pollution, overfishing, and by-catch. 

The environmental impacts of coastal and offshore aquaculture include the pollution from fish farm effluent, antibiotic and pesticide inputs and residues, impacts on local marine ecosystems, coastal habitat loss, and genetic and health risks to wild marine populations. Pesticides may contaminate the ocean through the use of insecticides to control sea lice in farmed salmon or from residues in farmed fish food pellets. In addition, the high-density environment of the fish pen increases the likelihood of disease, which can infect wild populations; nets and other gear cause injury or death to wild creatures who get entangled in them; and the waste from net pens can add significant sources of organic matter into coastal ecosystems, potentially altering the local food chain, depleting the water of oxygen, and generating toxic algal blooms. Furthermore, feed for farmed fish is dependent on wild-caught fish as an input.

Meanwhile, with global supply chains in disarray and so many restaurants closed, there is no way to process, store, or sell more product—an economic disruption that will not be remedied by increasing supply. 

The federal government should implement strong safeguards on the industry that avoid harmful impacts on wild marine fish stocks and other organisms, reduce water pollution, eliminate the use of pesticides in aquaculture, and prevent habitat destruction. Investment in ocean and coastal habitat restoration and improved, science-based monitoring and management of fisheries and aquaculture enterprises are also needed. 

Tell Congress to save our oceans.

Thank you!
The Beyond Pesticides Team

Letter to Congress

On May 7, President Trump issued an executive order (EO) purporting to “promote American seafood competitiveness and economic growth,” while, in fact, permitting offshore aquaculture in federal waters with reduced environmental safeguards. Instead, we need stronger federal regulation in order to protect the environment and public health.

This EO adds to the Trump administration’s shameful record of dismantling environmental protections, failing to enforce those that do exist, undermining science, and weighing agrochemical and other industry interests over those of the public and the environment. The EO will further erode regulations that have governed the operation of so-called “fish farms,” and open enormous marine areas to exploitation by this industry.

Oceans cover 71% of Earth’s surface and hold about 97% of the planet’s water. Phytoplankton provide 50% of Earth’s oxygen, and the ocean is a vast sink for carbon dioxide. Regardless of whether we eat fish and shellfish, we need our oceans to be healthy in order to survive. Even without this EO, our oceans are threatened. According to the United Nations Educational, Scientific, and Cultural Organization (UNESCO):

• By the year 2100, without significant changes, more than half of the world’s marine species may stand on the brink of extinction.
• Today, 60% of the world’s major marine ecosystems that underpin livelihoods have been degraded or are being used unsustainably.
• Increased atmospheric CO2, as it dissolves in the oceans, acidifies them and threatens plankton, the basis of oceanic food chains. Acidification can corrode coral reefs and the shells of mollusks.
• Commercial overexploitation of the world’s fish stocks is so severe that it has been estimated that up to 13 percent of global fisheries have ‘collapsed.’

In the face of these threats—and others—to the oceans, it is important that we not backslide any further. Instead of promoting further industrial exploitation and pollution of the oceans, we need regulation of aquaculture that:

• Prohibits the use of pesticides and antibiotics;
• Prohibits genetically engineered fish and shellfish;
• Prohibits the use of plastic in net pens and other structures;
• Prohibits overcrowding that leads to parasites and diseases in net pens; and
• Requires protection of the benthos (organisms living at the bottom of the water body) in shellfish operations.

In addition, more Marine Protected Areas are essential to conserve the biodiversity of the oceans and to maintain productivity, especially of fish stocks.

Please act to strengthen protections for our oceans.

Thank you.

EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. These three states (and others) have received emergency exemptions for this use for the nine previous years and it must not be allowed for a tenth year. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses.

Sign the Petition to EPA and Send a Letter to Your Congressional Representative and Senators: EPA Must Deny Routine “Emergency” Exemptions

As a neocotinoid insecticide, dinotefuran presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack.

Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems.

With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. In fact, an organic systems plan must not allow the use of synthetic pesticides unless the use of management techniques—including crop rotation, crop nutrient management, sanitation, “selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases,” management of predators and parasites, and use of lures, traps, and repellents—are shown to be insufficient. In addition, the synthetic chemicals they use must meet stringent requirements prohibiting harm to human health and the environment. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption.

In 2006, EPA promulgated regulations making it easier to issue repeat emergency exemptions, despite the fact that the definition of an emergency condition requires an “urgent, non-routine situation.” In the case of dinotefuran, EPA has approved 125 emergency exemptions in eight states from 2011 through 2019 to kill brown marmolated stinkbugs in pome and stone fruits. The emergency exemptions were approved for all nine years in five states, eight years in two states, and four years in one state.

EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration.

If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working.

Sign the Petition to EPA and Send a Letter to Your Congressional Representative and Senators: EPA Must Deny Routine “Emergency” Exemptions

Please sign the petition by June 10.

It will be delivered to EPA before the end of the comment period on June 11. A copy will be delivered to your congressional Representative and Senators.

Please also consider adding to your impact by submitting your own comments to Regulations.gov.

Thank you,
The Beyond Pesticides Team

PETITION TO EPA:

To EPA Docket EPA-HQ-OPP-2020-0264:

Beyond Pesticides and the undersigned oppose granting emergency exemptions for dinotefuran to control brown marmorated stinkbugs in pome and stone fruits.

EPA’s allowance of an emergency pesticide application of a pesticide every year for nine years is not justifiable and it must not be allowed for a tenth year. EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. The three states (along with others) have received emergency exemptions for this use for the nine previous years. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses.

Dinotefuran, as a neonicotinoid insecticide,  presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack.

Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems.

With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. In fact, an organic system plan must not allow the use of synthetic pesticides unless the use of management techniques—including crop rotation, crop nutrient management, sanitation, “selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases,” management of predators and parasites, and use of lures, traps, and repellents—are shown to be insufficient. In addition, the synthetic chemicals they use must meet stringent requirements prohibiting harm to human health and the environment. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption.

In 2006, EPA promulgated regulations making it easier to issue repeat emergency exemptions, despite the fact that the definition of an emergency condition requires an “urgent, non-routine situation.” In the case of dinotefuran, EPA has approved 125 emergency exemptions in eight states from 2011 through 2019 to kill brown marmolated stinkbugs in pome and stone fruits. The emergency exemptions were approved for all nine years in five states, eight years in two states, and four years in one state.

EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration.

If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working.

Thank you.

Letter to Congress

Please tell EPA not to grant emergency exemptions for the bee-toxic insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits.

EPA’s allowance of an emergency pesticide application of a pesticide every year for nine years is not justifiable and it must not be allowed for a tenth year. EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. The three states (along with others) have received emergency exemptions for this use for the nine previous years. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses.

Dinotefuran, as a neonicotinoid insecticide, presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack.

Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems.

With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption.

EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials.. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration.

If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working.

Thank you.

 

During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of the National Organic Program at USDA to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. The NOSB has only one alternative left to force USDA action—denying relisting at the Fall meeting.

>>Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now.

Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.”

In fact, the ingredients not listed on a label of a pesticide product—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to disclose and test all ingredients in pesticide products, as well as the full formulation. The research tested the toxicity of the herbicide glyphosate, so-called “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, they studied a number of other pesticides.

Although GBH products are not permitted in organic production, the results of the Defarge et al study are relevant to decisions concerning materials used in organic crops and livestock. The scientists found that for GBH products, glyphosate was not the major toxic component–to either plants or human cells–and that formulations, as well as glyphosate alone, are endocrine disruptors at low concentrations. Glyphosate alone did not show herbicidal effects on tomato plants for five days following application. Formulations that included POEA (polyethoxylated tallowamine) are the most toxic to plants and human cells, and POEA itself is highly toxic to plants and animals. GBH formulations are no more toxic to plants than the formulants (“inert” ingredients). The researchers concluded, “Hence G [glyphosate] did not appear to be the main active substance of the herbicide, but rather the formulants.”

The researchers also identified a number of other toxic substances in the products, including arsenic, chromium, cobalt, nickel, and lead. Arsenic was present in almost all samples. This research challenges the apparent assumption by NOP that “inert” ingredients are less important to review than “active” ingredients. The “active” ingredients in pesticide products used in organic production receive intense scrutiny before the NOSB allows their use. However, “inert” ingredients –which, as the Defarge et al study demonstrates, may actually be the active ingredients— have not received any scrutiny by the NOSB for compliance with OFPA criteria.

In the Beyond Pesticides report “Inert” Ingredients Used in Organic Production, we summarize what is known about the toxicity of the 127 “inerts” then known to be used in organic production, compared to the 39 synthetic active ingredients on the National List. More “inerts” than active ingredients used in organic production have been shown to be acutely toxic, neurotoxic, carcinogenic, nephrotoxic or hepatotoxic, sensitizers, endocrine disruptors, and toxic to aquatic organisms.

NOP must respond to the NOSB recommendations that “inert” ingredients used in organic production be reviewed by the NOSB according to OFPA criteria by initiating actions to carry out NOSB recommendations.

>>Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now.

Letter to Secretary Perdue, Administrator Tucker, NOP Deputy Administrator Tucker:

I am concerned that the National Organic Program (NOP) has not followed through with recommendations from its advisory board, the National Organic Standards Board (NOSB), to fully review “inert” ingredients in pesticide products used in organic production according to the standards of the Organic Foods Production Act.

During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of NOP to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. NOP inaction leaves NOSB with only one alternative—denying relisting at the Fall meeting.

Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.”

In fact, ingredients not listed on a pesticide product label—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, reported in “Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides” (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini, tested the toxicity of the herbicide glyphosate, so-called “inerts” in glyphosate-based herbicides (GBH), and the pesticide formulations–looking at toxicity to target organisms, toxicity to human cells, and endocrine-disrupting activity. In addition to the GBH products, they studied a number of other pesticides.

Although GBH products are not permitted in organic production, the results of the Defarge et al study are relevant to decisions concerning materials used in organic crops and livestock. The scientists found that for GBH products, glyphosate was not the major toxic component–to either plants or human cells–and that formulations, as well as glyphosate alone, are endocrine disruptors at low concentrations. The researchers concluded, “Hence G [glyphosate] did not appear to be the main active substance of the herbicide, but rather the formulants.”

The researchers also identified a number of other toxic substances in the products, including arsenic, chromium, cobalt, nickel, and lead. This research challenges the apparent assumption by NOP that “inert” ingredients are less important to review than “active” ingredients. The “active” ingredients in pesticide products used in organic production receive intense scrutiny before the NOSB allows their use. However, “inert” ingredients–which, as the Defarge et al study demonstrates, may actually be the active ingredients—have not received any scrutiny by the NOSB for compliance with OFPA criteria.

In the report “Inert” Ingredients Used in Organic Production, Beyond Pesticides summarizes what is known about the toxicity of the 127 “inerts” then known to be used in organic production, compared to the 39 synthetic active ingredients on the National List. More “inerts” than active ingredients used in organic production have been shown to be acutely toxic, neurotoxic, carcinogenic, nephrotoxic or hepatotoxic, sensitizers, endocrine disruptors, and toxic to aquatic organisms.

NOP must respond to the NOSB recommendations that “inert” ingredients used in organic production be reviewed by the NOSB according to OFPA criteria by initiating actions to carry out NOSB recommendations.

Thank you.

For years, USDA has been looking the other way as giant corporate agribusinesses, primarily producing conventional eggs and poultry, have squeezed family-scale farmers out of the market and misled and defrauded consumers.

Due to a lawsuit challenging the Trump administration on the scuttling of new rules that would make it harder for factory farms to qualify for organic status, USDA is seeking input on what was previously an error-filled and biased economic assessment of the rulemaking.

Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings.

If you would prefer to write your own custom comment you can submit it on Regulations.gov.

Letter to National Organic Program (Jenny Tucker, Ph.D.

To the National Organic Program:

Please include my comment below in evaluating the economic analysis report pursuant to the Organic Livestock and Poultry Practices rulemaking.

Docket number: AMS-NOP-20-0037

Both the current and previous OLPP analyses include the following misstatements and omissions:

1. It is a misconception to refer to, and judge, the economic impacts of the OLPP as if the requirement for outdoor access was a new and onerous regulation. In fact, from the beginning of the USDA organic program, “all” organic livestock have been required to have access to the outdoors. The new proposed rule does nothing more than create some enforceable benchmarks to facilitate oversight by USDA and its accredited third-party certifiers. 
   
   
2. Analyzing the economic impact, as if this were a new regulatory obligation, is misdirected. All organic livestock producers should have been providing meaningful outdoor access from day one. 
   
   
3. Factoring in impacts on retail pricing is not germane to this decision-making. The size of the market is irrelevant. When consumers pay a premium for organic eggs and poultry, they expect that the birds are being managed in accordance with the law, which requires outdoor access and promotion of the natural instinctive behaviors of the animals. 
   
   
4. True organic management of meat birds and laying hens is not currently possible in the massive industrial-sized buildings that USDA has allowed to be certified. Investments were made in these structures while it was known that elements in the organic industry were challenging the legality of the operations and, thus, their investments have always been at risk. 
   
   
5. In England and the European Union, organic birds have always had access to the outdoors in smaller flocks. Subsequently, the price differential between conventional and organic eggs has been greater. However, the market share for organic in many of those countries surpasses that of the United States. Organic consumers already assume that they are buying eggs and poultry produced with a higher level of animal welfare. They are currently being defrauded. The question of their willingness to pay a premium is irrelevant. 
   
   
6. If some of the larger operators are forced to exit, entrepreneurs will quickly scale-up to meet new market demand. The shift to producers who comply with both the spirit and letter of the law should not be a factor in implementing the new rulemaking. 
   
   
7. Regardless of how much outdoor space is provided, it is not possible to offer legitimate access when birds are housed in giant, multitiered aviary systems.  Buildings housing as many as 100,000-200,000 birds prevent the expression of instinctual behavior, a regulatory requirement, as it would be necessary to walk over thousands of other birds in order to access a door. Believing otherwise is a myth perpetuated by corporate interests in egg production. 
   
   
8. Because USDA’s analysis starts from the wrong baseline—one that is not consistent with the law–the analysis omits the economic injury to family-scale farmers who are currently complying with the regulations by allowing birds meaningful access to the outdoors that continues when the OLPP is not implemented. Furthermore, there are many family farmers who have been prevented from entering the organic market for poultry meat and eggs because, as it has grown, market share has been dominated by giant conventional ag companies that have gamed the system to achieve lower operating costs and higher profitability.

 

In conclusion, any economic analysis of the impact of new rulemaking should be viewed through the prism of the Organic Foods Production Act and its current regulations. To do otherwise places family farmers at a competitive disadvantage and perpetuates a fraudulent myth that the majority of organic poultry, managed by corporate agribusiness, is truly “organic.”

Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings.

Protecting ourselves from Covid-19 requires not only that we avoid contact with the virus, but also that we avoid exposing ourselves to chemicals that may disrupt our immune or respiratory systems. But when it comes to pesticide products—and disinfectants are pesticides—we encounter once again the problem of so-called “inert,” or nondisclosed, ingredients.

Tell EPA and Congress that ALL Ingredients in Pesticides Must Be Disclosed.

“Inert” ingredients are not necessarily chemically or biologically harmless. “Inert” or “other” ingredients—as distinguished from “active” ingredients—are generally the majority of the product formulation that makes up the liquid, spray, dust, or granule, but does not specifically attack the pest, according to the manufacturer. They include emulsifiers, solvents, carriers, aerosol propellants, fragrances, and dyes. Many “inerts” are quite toxic, and may be “active” ingredients in other products. “Inert” ingredients may also be described as “adjuvants” or “formulants.” “Inerts” are typically not listed on the label, and hence are often called “secret ingredients.”

Beyond Pesticides reviews the disinfectants on EPA’s List N, which are approved for use against the novel coronavirus, but it is only possible to review the active ingredients. One product on the list, for example, contains 99.7784% “other ingredients.” Unfortunately, although this product may contain mostly water, it also may be composed mostly of such “inert” ingredients as 4-chlorotoluene, ethylbenzene, or petroleum distillates, all of which (among others) can weaken the respiratory and/or immune systems, making an exposed person more susceptible to Covid-19. We don’t know.

While it has never been acceptable to hide product ingredients on pesticide products, the current pandemic makes this information crucial for consumers who want to protect themselves and their families. Whether it is disinfectants or pesticide products in use in the home, yard, and community the secrecy on this public health issue must end, and EPA has the authority to require labeling . Please urge EPA use its legal authority to require disclosure of all ingredients on pesticide labels to protect public health.

Tell EPA and Congress that ALL Ingredients in Pesticides Must Be Disclosed.

Letter to EPA Administrator and Office of Pesticide Program Director

I am writing you because the current pandemic has brought home to me the importance of disclosure of all ingredients in pesticide products that can exacerbate the public’s vulnerability to Covid-19. Protecting ourselves from Covid-19 requires not only that we avoid contact with the virus, but also that we avoid exposing ourselves to chemicals that may disrupt our immune and respiratory systems. But when it comes to pesticides—and disinfectants are pesticides—I encounter the problem of so-called “inert” ingredients.

“Inert” ingredients are not necessarily chemically or biologically inert. Many are quite toxic, and may be “active” ingredients in other products. “Inert” or “other” ingredients—as distinguished from “active” ingredients—are simply those for which the pesticide manufacturer does not make a pesticidal claim. “Inerts” are typically not listed on the label, and hence they are “secret ingredients.” They include emulsifiers, solvents, carriers, aerosol propellants, fragrances, and dyes.

In deciding on a disinfectant to use in my home, I review products on EPA’s List N, which are approved for use against the novel coronavirus, but it is only possible to review the active ingredients. One product on the list, for example, contains 99.7784% “other ingredients.” Unfortunately, although this product may contain mostly water, it also may be composed mostly of such “inert” ingredients as 4-chlorotoluene, ethylbenzene, or petroleum distillates, all of which (among others) can weaken my respiratory and/or immune systems, making me more susceptible to Covid-19. I don’t know because “inert” ingredients are not disclosed.

While it has never been acceptable to hide product ingredients on pesticide products, the current pandemic makes this information crucial for consumers who want to protect themselves and their families. Whether it is disinfectants or pesticide products in use in the home, yard, and community the secrecy on this public health issue must end, and EPA has the authority to require labeling. Please require disclosure of all ingredients on pesticide labels as a matter of public health protection.

Thank you.

Letter to U.S. Senators and Representative

I am writing you because the current pandemic has brought home to me the importance of disclosure of all ingredients in pesticide products that can exacerbate the public’s vulnerability to Covid-19. Protecting ourselves from Covid-19 requires not only that we avoid contact with the virus, but also that we avoid exposing ourselves to chemicals that may disrupt our immune and respiratory systems. But when it comes to pesticides—and disinfectants are pesticides—I encounter the problem of so-called “inert” ingredients.

“Inert” ingredients are not necessarily chemically or biologically inert. Many are quite toxic, and may be “active” ingredients in other products. “Inert” or “other” ingredients—as distinguished from “active” ingredients— are simply those for which the pesticide manufacturer does not make a pesticidal claim. “Inerts” are typically not listed on the label, and hence they are “secret ingredients.” They include emulsifiers, solvents, carriers, aerosol propellants, fragrances, and dyes.

In deciding on a disinfectant to use in my home, I review products on EPA’s List N, which are approved for use against the novel coronavirus, but it is only possible to review the active ingredients. One product on the list, for example, contains 99.7784% “other ingredients.” Unfortunately, although this product may contain mostly water, it also may be composed mostly of such “inert” ingredients as 4-chlorotoluene, ethylbenzene, or petroleum distillates, all of which (among others) can weaken my respiratory and/or immune systems, making me more susceptible to Covid-19. I don’t know because “inert” ingredients are not disclosed.

While it has never been acceptable to hide product ingredients on pesticide products, the current pandemic makes this information crucial for consumers who want to protect themselves and their families. Whether it is disinfectants or pesticide products in use in the home, yard, and community the secrecy on this public health issue must end, and EPA has the authority to require labeling.  Please urge EPA to require disclosure of all ingredients on pesticide labels, as a matter of public health protection.

Thank you.

Exemptions to the Fair Labor Standards Act allow children to work unlimited hours in agriculture at the age of 12 and allow child farmworkers to perform hazardous work at the age of 16. These exemptions apply only to farm labor and are significantly less stringent than law applying to other sectors. U.S. Representative Lucille Roybal-Allard of California has reintroduced H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety (CARE) to correct these inconsistencies, which harm farmworker children.

Tell your Congressional Representative to co-sponsor H.R. 3394. Thank those who are co-sponsors of the bill.

Currently, children ages 12-13 may not be employed outside the home in non-agriculture labor, but may work in agriculture outside of school hours. Children ages 14-15 may work in non-agriculture only with strict limitations on time of day and hours per week, but may work in agriculture outside of school hours without any restrictions. The minimum age for hazardous work in agriculture, such as pesticide handling, is 16, but is 18 for non-farm labor. H.R. will make the restrictions for agriculture child labor consistent with non-agriculture labor. The bill does not apply to the sons and daughters of farmers working on their family farm.

The worker protection standard (WPS) is an EPA regulation that includes restrictions to protect farmworkers applying pesticides. In 2015, the WPS was revised to set a minimum age of 18 for pesticide application. In 2018, after being sued for not implementing the minimum age requirement, EPA proposed lowering the age to 16. EPA dropped its proposal to lower the age for pesticide handlers after negotiating with Congress. Despite EPA’s reversal, a change in the statute such as that proposed in H.R. 3394 would prevent the agency or the courts from allowing 16-year-olds to be hired to apply pesticides in the future.

Children of farmworkers are those most threatened by this discrepancy. The health of children of farmworkers is at risk in other ways from the use of toxic pesticides. Doctors annually diagnose up to 20,000 poisonings among agricultural workers – and that statistic only represents what is publicly reported. Working mothers are exposed to chemicals that can have long-lasting impacts on their unborn children, such as brain function damage. As a result of their working conditions, farmworker life expectancy is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s. We need to correct the injustices suffered by farmworkers and their families.

Tell your Congressional Representative to co-sponsor H.R. 3394. Thank those who are co-sponsors of the bill.

Letter to Congress – Request to Cosponsor

I am writing to ask you to cosponsor H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety, which will make the protection of children on farms consistent with that of children working in non-agricultural work.

Exemptions to the Fair Labor Standards Act allow children to work unlimited hours in agriculture at the age of 12 and allow child farmworkers to perform hazardous work at the age of 16. These exemptions apply only to farm labor and are significantly less stringent than law applying to other sectors. Representative Lucille Roybal-Allard of California has reintroduced H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety (CARE) to correct these inconsistencies, which harm farmworker children.

Currently, children ages 12-13 may not be employed outside the home in non-agriculture labor, but may work in agriculture outside of school hours. Children ages 14-15 may work in non-agriculture only with strict limitations on time of day and hours per week, but may work in agriculture outside of school hours without any restrictions. The minimum age for hazardous work in agriculture, such as pesticide handling, is 16, but is 18 for non-farm labor. H.R. 3394 will make the restrictions for agriculture child labor consistent with non-agriculture labor. The bill does not apply to the sons and daughters of farmers working on their family farm.

Children of farmworkers are those most threatened by this discrepancy. The health of children of farmworkers is at risk in other ways from the use of toxic pesticides. Doctors annually diagnose up to 20,000 poisonings among agricultural workers – and that statistic only represents what is publicly reported. Working mothers are exposed to chemicals that can have long-lasting impacts on their unborn children, such as brain function damage. As a result of their working conditions, farmworker life expectancy is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s. We need to correct the injustices suffered by farmworkers and their families.

Please cosponsor H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety.

Thank you for your attention to this important issue.

Thank You Letter to Current Cosponsors

I am writing to thank you for co-sponsoring H.R. 3394, the Children’s Act for Responsible Employment and Farm Safety, which will make the protection of children on farms consistent with that of children working in non-agricultural work.

Children of farmworkers are those most threatened by the current discrepancy. The health of children of farmworkers is at risk in other ways from the use of toxic pesticides. Doctors annually diagnose up to 20,000 poisonings among agricultural workers – and that statistic only represents what is publicly reported. Working mothers are exposed to chemicals that can have long-lasting impacts on their unborn children, such as brain function damage. As a result of their working conditions, farmworker life expectancy is 49 years, compared to 78 for the general population. This is similar to the life expectancy of individuals living in the 1850s.

We need to correct the injustices suffered by farmworkers and their families.

Thank you for your support.

Federal guidance and orders by most Governors have identified “landscaping” as an essential activity that is permitted in spite of stay at home or shelter in place requirements.

As USDA takes public comments on its updated dietary guidelines, it important that sustainable, regenerative organic food production practices are an integral part. Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations intended to promote public health and prevent chronic diseases. The next review and a draft updated version, the 2020–2025 Dietary Guidelines for Americans, is currently underway.

USDA says that the dietary guidelines provide “information that helps Americans make healthy choices for themselves and their families.” In order to make healthy food choices, the guidelines must go beyond the traditional parameters to include how the food is produced. How food is produced affects the health of Americans not only as a result of the nutritional quality of the food, but also due to environmental contamination.

Sign the petition to USDA and send a letter to Congress. Tell them that organic food must be emphasized in new dietary guidelines.

Although research on the nutritional density of organic produce is equivocal, showing some higher levels of antioxidants, results are decidedly clear for animal products. Pastured organic animal products—including beef, lamb, pork, dairy, poultry, and eggs—have been shown to be superior to that of products of chemical-intensive crops and confined animals in their distribution of fatty acids.

The differences to consumers go beyond nutritional value. Organic food is generally free of residues of pesticides and antibiotics. Pesticide residues are found in 70% of the food sold in the U.S., and residues of antibiotics are common in nonorganic milk. These residues may not exceed EPA tolerances, but lower levels may still have health effects. EPA does not take into account the combined effects of different pesticides that may occur on an item of produce (or in a meal), which often exceed the sum of the residues. It does not take into account the combined effects of all the ingredients of a single pesticide product. Despite a requirement in the Food Quality Protection Act that EPA implement screening of pesticides for endocrine disrupting chemicals (EDCs) by 1999, pesticides are still not evaluated for their endocrine disruption potential, which can occur at levels far below those that cause the effects for which EPA tests.

Among the endocrine disruptors that are particularly relevant in the context of these guidelines are obesogens. As stated in an article by Drs. Amanda Janesick and Bruce Blumberg, “Recently, EDCs have been implicated in metabolic syndrome and obesity. Adipose tissue is a true endocrine organ and, therefore, an organ that is highly susceptible to disturbance by EDCs. A subset of EDCs, called ‘obesogens,’ promote adiposity by altering programming of fat cell development, increasing energy storage in fat tissue, and interfering with neuroendocrine control of appetite and satiety.”

In addition to the direct impacts of pesticide food residues on consumers, chemical-intensive agriculture contaminates air, water, and land, affecting the health of Americans in other ways. Pesticides in the air can aggravate asthma and other respiratory problems. Pesticides run off into streams and leach into groundwater, contaminating drinking water. Farmworkers should also be protected by these food guidelines because their health is threatened by the poisons that are applied to fields where they work.

Organic food production sequesters more carbon in the soil than conventional chemical-intensive agriculture, helping to mitigate climate change. Health hazards of climate change range from injury and death from a higher frequency of more severe storms to northward migration of tropical diseases and their insect vectors.

USDA organic certification is the only system of food labeling that is subject to independent public review and oversight, assuring consumers that toxic, synthetic pesticides used in conventional agriculture are replaced by management practices focused on soil biology, biodiversity, and plant health. This eliminates commonly used toxic chemicals in the production and processing of food that is not labeled organic–pesticides that contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish and other wildlife.

The updated dietary guidelines should incorporate this information and recommend that Americans consume, to the extent possible, organic produce and organic pastured animal products.

Sign the petition to USDA and send a letter to Congress. Tell them that organic food must be emphasized in new dietary guidelines.

Petition to USDA

As USDA takes public comments on its updated dietary guidelines, it important that sustainable, regenerative organic food production practices are an integral part. Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations that are supposed, minimally, to promote public health and prevent chronic diseases. The next review and a draft updated version, the 2020–2025 Dietary Guidelines for Americans, is currently underway. The 2015 Dietary Guidelines Advisory Committee (DGAC) examined the evidence on sustainable diets for the first time, but this topic was not included within the scope of work for the 2020 DGAC. The 2015 committee concluded that “in general, a dietary pattern that is higher in plant-based foods, such as vegetables, fruits, whole grains, legumes, nuts, and seeds, and lower in animal-based foods is more health promoting and is associated with lesser environmental impact ([greenhouse gas] emissions and energy, land, and water use) than is the current average U.S. diet.” [1]

USDA says that the food guidelines provide “information that helps Americans make healthy choices for themselves and their families.” In order to make healthy food choices, the guidelines must go beyond the traditional parameters to include how the food is produced. How food is produced affects the health of Americans not only as a result of the nutritional quality of the food, but also due to environmental contamination.

Although research on the nutritional density of organic produce is equivocal, showing some higher levels of antioxidants [2], results are decidedly clear for animal products. Pastured organic animal products—including beef [3], lamb [4], pork [5], dairy [6], poultry [7], and eggs [8]—have been shown to be superior to that of products of chemical-intensive crops and confined animals in their distribution of fatty acids.

The differences to consumers go beyond nutritional value. Organic food is generally free of residues of pesticides and antibiotics. Pesticide residues are found in 70% of the food sold in the U.S., and residues of antibiotics are common in nonorganic milk. [9] These residues may not exceed EPA tolerances, but lower levels may still have health effects. EPA does not take into account the combined effects of different pesticides that may occur on an item of produce (or in a meal), which often exceed the sum of the residues. It does not take into account the combined effects of all the ingredients of a single pesticide product. Despite a requirement in the Food Quality Protection Act that EPA implement screening of pesticides for endocrine disrupting chemicals (EDCs) by 1999, pesticides are still not evaluated for their endocrine disruption potential, which can occur at levels far below those that cause the effects for which EPA tests.

Among the endocrine disruptors that are particularly relevant in the context of these guidelines are obesogens. As stated in an article by Drs. Amanda Janesick and Bruce Blumberg, “Recently, EDCs have been implicated in metabolic syndrome and obesity. Adipose tissue is a true endocrine organ and, therefore, an organ that is highly susceptible to disturbance by EDCs. A subset of EDCs, called ‘obesogens,’ promote adiposity by altering programming of fat cell development, increasing energy storage in fat tissue, and interfering with neuroendocrine control of appetite and satiety.” [10]

In addition to the direct impacts of pesticide food residues on consumers, chemical-intensive agriculture contaminates air, water, and land, affecting the health of Americans in other ways. Pesticides in the air can aggravate asthma and other respiratory problems. Pesticides run off into streams and leach into groundwater, contaminating drinking water. Farmworkers should also be protected by these food guidelines because their health is threatened by the poisons that are applied to fields where they work. [11]

Organic food production sequesters more carbon in the soil than conventional chemical-intensive agriculture, helping to mitigate climate change. [12] Health hazards of climate change range from injury and death from a higher frequency of more severe storms to northward migration of tropical diseases and their insect vectors.

USDA organic certification is the only system of food labeling that is subject to independent public review and oversight, assuring consumers that toxic, synthetic pesticides used in conventional agriculture are replaced by management practices focused on soil biology, biodiversity, and plant health. This eliminates commonly used toxic chemicals in the production and processing of food that is not labeled organic–pesticides that contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish and other wildlife.

The updated dietary guidelines should incorporate this information and recommend that Americans consume, to the extent possible, organic produce and organic pastured animal products.

References

[1] DGAC (Dietary Guidelines Advisory Committee). 2015. Scientific Report of the 2015 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Health and Human Services and the Secretary of Agriculture. Washington, DC: US Department of Agriculture.

[2] Bernacchia, R., Preti, R. and Vinci, G., 2016. Organic and Conventional Foods: Differences in Nutrients. Italian Journal of Food Science, 28(4).

[3] Bjorklund, E.A., Heins, B.J., DiCostanzo, A. and Chester-Jones, H., 2014. Fatty acid profiles, meat quality, and sensory attributes of organic versus conventional dairy beef steers. Journal of Dairy Science, 97(3), pp.1828-1834.

[4] Popova, T., 2007. Effect of the rearing system on the fatty acid composition and oxidative stability of the M. longissimus lumborum and M. semimembranosus in lambs. Small Ruminant Research, 71(1-3), pp. 150-157.

[5] Practical Farmers of Iowa, 2019. Research Report: Fatty acid comparisons of grain and forage-fed pork. https://practicalfarmers.org/wp-content/uploads/2019/04/18.L.Nutrient-Density-Profiles-for-Conventional-vs.-Pasture-Raised-Pork.pdf.

[6] Benbrook, C.M., Davis, D.R., Heins, B.J., Latif, M.A., Leifert, C., Peterman, L., Butler, G., Faergeman, O., Abel-Caines, S. and Baranski, M., 2018. Enhancing the fatty acid profile of milk through forage-based rations, with nutrition modeling of diet outcomes. Food science & nutrition, 6(3), pp.681-700.

[7] Tufarelli, V., Ragni, M. and Laudadio, V., 2018. Feeding forage in poultry: a promising alternative for the future of production systems. Agriculture, 8(6), p.81.

[8] Karsten, H.D., Patterson, P.H., Stout, R. and Crews, G., 2010. Vitamins A, E and fatty acid composition of the eggs of caged hens and pastured hens. Renewable Agriculture and Food Systems, 25(1), pp.45-54.

[9] Pesticide residues found in 70% of produce sold in US even after washing, The Guardian. March 20, 2019. Welsh, J.A., Braun, H., Brown, N., Um, C., Ehret, K., Figueroa, J. and Barr, D.B., 2019. Production-related contaminants (pesticides, antibiotics and hormones) in organic and conventionally produced milk samples sold in the USA. Public health nutrition, 22(16), pp.2972-2980.

[10] Janesick, A.S. and Blumberg, B., 2016. Obesogens: an emerging threat to public health. American journal of obstetrics and gynecology, 214(5), pp.559-565.

[11] https://beyondpesticides.org/resources/eating-with-a-conscience/overview.

[12] Ghabbour, E.A., Davies, G., Misiewicz, T., Alami, R.A., Askounis, E.M., Cuozzo, N.P., Filice, A.J., Haskell, J.M., Moy, A.K., Roach, A.C. and Shade, J., 2017. National comparison of the total and sequestered organic matter contents of conventional and organic farm soils. In Advances in Agronomy (Vol. 146, pp. 1-35). Academic Press.

Letter to Congress

Congress requires a review of its Dietary Guidelines—recommendations to promote public health and prevent chronic diseases—every five years. The 2020–2025 Dietary Guidelines for Americans review is currently underway. The 2015 Dietary Guidelines Advisory Committee (DGAC) examined the evidence on sustainable diets for the first time, but this topic was not included within the scope of work for the 2020 DGAC.

USDA says food guidelines provide “information that helps Americans make healthy choices for themselves and their families.” The guidelines must include production practices that affect the health of Americans not only through the nutritional quality of the food, but also due to environmental contamination.

Research on the nutritional density of organic produce shows some higher levels of antioxidants. Pastured organic animal products—including beef, lamb, pork, dairy, poultry, and eggs—have been shown to be superior to that of products of chemical-intensive agriculture in their distribution of fatty acids.

Organic food is generally free of residues of pesticides and antibiotics. Pesticide residues are found in 70% of the food sold in the U.S., and residues of antibiotics are common in nonorganic milk. Even when residues do not exceed EPA tolerances, they may have health effects. EPA does not take into account the combined effects of different pesticides or of all the ingredients of a single pesticide product. Despite a requirement in the Food Quality Protection Act that EPA implement screening of pesticides for endocrine disrupting chemicals (EDCs) by 1999, pesticides are still not evaluated for their endocrine disruption potential, which can occur at levels far below those that cause the effects for which EPA tests.

Among the EDCs that are particularly relevant in the context of these guidelines are obesogens. As stated in an article by Drs. Amanda Janesick and Bruce Blumberg, “Recently, EDCs have been implicated in metabolic syndrome and obesity. Adipose tissue is a true endocrine organ and, therefore, an organ that is highly susceptible to disturbance by EDCs. A subset of EDCs, called ‘obesogens,’ promote adiposity by altering programming of fat cell development, increasing energy storage in fat tissue, and interfering with neuroendocrine control of appetite and satiety.”

In addition to the impacts on consumers, pesticides in the air can aggravate asthma and other respiratory problems. Pesticides run off into streams and leach into groundwater, contaminating drinking water. The health of farmworkers is threatened by the poisons applied to fields where they work.

Organic food production sequesters more carbon in the soil than conventional chemical-intensive agriculture, helping to mitigate climate change. Health hazards of climate change range from injury and death from a higher frequency of more severe storms to northward migration of tropical diseases and their insect vectors.

USDA organic certification is the only system of food labeling that is subject to independent public review and oversight, assuring consumers that toxic synthetic pesticides used in conventional agriculture are replaced by management practices focused on soil biology, biodiversity, and plant health, protecting Americans from pesticides that contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife.

The updated dietary guidelines should incorporate this information and recommend that Americans consume, to the extent possible, organic produce and organic pastured animal products.

Thank you.

The Trump administration’s U.S. Fish and Wildlife Service (USFWS) is moving forward with a proposal to grow genetically engineered crops (GECs) on National Wildlife Refuges in the Southeast United States, including 131 refuges in 10 states, Puerto Rico, and the U.S. Virgin Islands.

Ask Congress to help stop the dangerous proposal to allow genetically engineered crops on National Wildlife Refuges in the southeast United States.

The proposal is the subject of a draft environmental assessment and opens the door to escalating uses of GE crops and harmful pesticides in wildlife refuges.

In 2014, public pressure and lawsuits by environmental groups led to the Obama administration’s decision to phase out GE crops and ban neonicotinoid insecticide use on national wildlife refuges. On August 2, 2018, the Trump administration’s USFWS issued a memorandum that reversed the prohibition. The reversal allows the refuge system to make decisions on the use of GECs and neonics on a case-by-case basis in compliance with the National Environmental Policy Act (NEPA), which is also under attack by the Trump administration. The Center for Biological Diversity, Center for Food Safety, and others quickly challenged the 2018 reversal memorandum with a lawsuit.

National Wildlife Refuges are federal public lands specifically designated to protect fish and wildlife. The Southeastern Region is comprised of almost 4 million acres of refuge lands and waters that provide vital habitat for dozens of endangered species known to be imperiled by pesticide use—including bats, birds, freshwater mussels, and fish like the pallid sturgeon and Alabama cavefish. “It’s a no-brainer that this kind of pesticide-intensive agriculture shouldn’t be allowed on public lands that are critical to wildlife conservation and preservation of the unique ecosystems of the southeastern U.S.,” said Hannah Connor, an attorney at the Center for Biological Diversity.

Approximately 44,000 acres of refuge lands in the Southeastern Region currently incorporate to farming, with corn, soybeans and rice the most commonly farmed crops. Genetically engineered corn and soybeans are typically designed to survive spraying with herbicides like glyphosate, dicamba, and 2-4,D—allowing farmers to use these pesticides prophylactically after the crops have sprouted. Increased pesticide use often coincides with wildlife feeding and breeding times, when pesticides can be especially harmful.

Glyphosate use on GE crops have significantly contributed to monarch butterflies’ 80-90% decline over the past two decades. This is because the pesticide is a potent killer of milkweed, the monarch caterpillar’s only food.

USFWS’ Draft Programmatic Environmental Assessment notes the adverse impact of “commercial pesticides” (and their citations read “neonics”). Remarkably, the authors argue that genetically engineered crops, as opposed to “non-GEC,” use fewer commercial pesticides, an argument that has long been refuted—especially as most GECs are designed to be used with pesticides.

USFWS announced a public comment period for its proposal and Draft Programmatic Environmental Assessment. They will accept input through April 10, 2020. Comments and questions must be submitted in writing to [email protected] or mailed to Pamala Wingrove, Branch Chief, Conservation Planning, USFWS, Southeast Region, 1875 Century Boulevard NE, Atlanta, GA, 30345. Meanwhile, please ask your U.S. Representative and Senators to weigh in.

Ask Congress to help stop the dangerous proposal to allow genetically engineered crops on National Wildlife Refuges in the southeast United States.

Letter to Congress

I am appalled at the U.S. Fish and Wildlife Service (USFWS) proposal to allow the cultivation of genetically engineered crops on National Wildlife Refuges in the Southeast United States, including 131 refuges in 10 states, Puerto Rico and the U.S. Virgin Islands.

The proposal would open the door to escalating uses of GE crops and harmful pesticides in wildlife refuges. In 2014, public pressure and lawsuits by environmental groups led to the Obama administration’s decision to phase out GE crops and ban neonicotinoid insecticide use on national wildlife refuges. On August 2, 2018, the Trump administration’s FWS issued a memorandum that reversed the prohibition. The reversal allows the refuge system to make decisions on the use of GECs and neonics on a case-by-case basis.

National wildlife refuges are federal public lands specifically designated to protect fish and wildlife. The Southeastern Region is comprised of almost 4 million acres of refuge lands and waters that provide vital habitat for dozens of endangered species known to be imperiled by pesticide use—including bats, birds, freshwater mussels, and fish like the pallid sturgeon and Alabama cavefish.

Approximately 44,000 acres of refuge lands in the Southeastern Region currently incorporate farming, with corn, soybeans and rice the most commonly farmed crops. Genetically engineered corn and soybeans are typically designed to survive spraying with herbicides like glyphosate, dicamba, and 2-4,D—allowing farmers to use these pesticides prophylactically after the crops have emerged. Increased pesticide use often coincides with wildlife feeding and breeding times, when pesticides can be especially harmful.

USFWS’ Draft Programmatic Environmental Assessment notes the adverse impact of “commercial pesticides” (and their citations read “neonics”). Remarkably, the authors argue that genetically engineered crops, as opposed to “non-GEC,” use fewer commercial pesticides, an argument that has long been refuted—especially as most GECs are designed to be used with pesticides.

I request that you urge USFWS to abandon its proposal because it is unwise and dangerous to the species that the refuges are mandated to protect.

Thank you.

Support Organic Farmers as They Provide Nutrition that Heals

As we all heed calls for social distancing to avoid spread of COVID-19, elected officials are looking for ways to support those who are suffering from adverse economic impact. In doing this, it is especially important to focus on those organic family farmers who grow our food and have had their markets disrupted.

Tell Congress to Help Organic Farmers Hurt by the Pandemic

Congress has already passed an $8 billion response package earlier this month and just passed H.R. 6201, the Families First Coronavirus Response Act, providing additional appropriations to address testing, emergency nutrition assistance, temporary paid leave, and increased federal funding for unemployment insurance. Now a much bigger, trillion-dollar economic stimulus bill is in the works.

Ideas for the trillion-dollar spending package are proliferating as fast as the virus. While direct payments to individuals have been mentioned, so have various subsidies to businesses. We need to warn politicians not to exploit the coronavirus pandemic to subsidize large corporations without protections for workers. Rather, our Representatives need to ensure that the money goes to help those who have been directly affected.

In a letter to House Speaker Nancy Pelosi, U.S. Representative Chellie Pingree detailed the impact of the COVID-19 pandemic on farmers in local and regional markets. Noting that trade mitigation payments have not benefited farmers who sell products through local and regional markets, Rep. Pingree urged Speaker Pelosi to take actions to support these farmers, including emergency disaster payments, emergency farm loans, and suspending FSA loan payments. “We should provide emergency disaster payments to farmers selling fresh and minimally processed foods in local and regional markets that have been negatively impacted by the COVID-19 pandemic,” wrote Rep. Pingree.

Organic farmers are among these who have been hardest hit. When asked to provide ideas for how organic farmers could be helped, in addition to the recommendations of Rep. Pingree, many representing organic farmers offer these suggestions:

• Ensure that farmers markets and farm stands have the same status as retail stores when it comes to social gathering and loss of income.
• Increase the cost share in organic certification, paid up front, and allow certifiers to waive fees until September
• Help make connections with local farms when addressing food programs.
• Establish a program to provide relief workers for sick farmers.
• Disaster payments should cover both crops not harvested or sold, as well as those that can move to emergency food needs; organic is paid at the organic price.
• Allow Supplemental Nutrition Assistance Program (SNAP) payments to be made on-line directly to farms.
• Provide funds for farms quickly moving to set up “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction as farmers markets may be limited, or even farmers feel unsafe selling at farmers markets.

Tell Congress to Help Organic Farmers Hurt by the Pandemic

Letter to Congress

As we all heed calls for social distancing to avoid spread of COVID-19, we also see the need to support those organic family farmers who grow our food and have had their markets disrupted. Please ensure that the stimulus measures actually help those who need it.

Ideas for a trillion dollar spending package are proliferating as fast as the virus. While direct payments to individuals have been mentioned, so have various subsidies to businesses. Please avoid the temptation to exploit the coronavirus pandemic to subsidize large corporations without protections for workers. Rather, ensure that the money goes to help those who have been directly affected. Please put the money to work where it will help those who have been directly affected.

In a letter to House Speaker Nancy Pelosi, Representative Chellie Pingree detailed the impact of the COVID-19 pandemic on farmers in local and regional markets. Noting that trade mitigation payments have not benefited farmers who sell products through local and regional markets, Rep. Pingree urged Speaker Pelosi to take actions to support these farmers, including emergency disaster payments, emergency farm loans, and suspending FSA loan payments. “We should provide emergency disaster payments to farmers selling fresh and minimally processed foods in local and regional markets that have been negatively impacted by the COVID-19 pandemic,” she wrote.

Organic farmers are among these who have been hardest hit. When asked to provide ideas for how organic farmers could be helped, in addition to the recommendations of Rep. Pingree, many representing organic farmers offer these suggestions:

* Ensure that farmers markets and farm stands have the same status as retail stores when it comes to social gathering and loss of income.

* Increase the federal cost share in organic certification, paid up front, and allow certifiers to waive fees until September.

* Help make connections with local farms when addressing food programs.

* Establish a program to provide relief workers to assist sick farmers.

* Disaster payments should cover both crops not harvested or sold, as well as those that can move to emergency food needs; organic is paid at the organic price.

* Allow SNAP payments to be made on-line directly to farms.

* Provide funds for farms quickly moving to set up “on-farm” stands, curbside pickup, and other direct to consumer “no-touch” distribution channels that minimize interaction as farmers markets may be limited, or even farmers feel unsafe selling at farmers markets.

I believe that these targeted suggestions will help all of us by helping farmers to provide the health-giving nutrition we need during these times.

Thank you.

Sincerely,

 

Agriculture both suffers from the impacts of the climate crisis and contributes significantly to global warming. Representative Chellie Pingree of Maine has introduced H.R. 5861 aimed at achieving a 50% reduction in agricultural emissions by 2030 and net zero emissions by 2040, relative to 2010 levels.

Tell Your Congressional Representative to Cosponsor H.R. 5861.

July of 2019 was the hottest month ever recorded on Earth. The last time atmospheric carbon dioxide levels were this high (over 415 ppm) was during the Pliocene period – between 5.3 and 2.6 million years ago. We have seen changing precipitation and temperature patterns, resulting in flooding of some agricultural regions and droughts in others, crops and livestock varieties no longer suited to the geographical area where they have been produced, and new problems with insects, weeds, and disease.

The Intergovernmental Panel on Climate Change (IPCC) finds that Agriculture, Forestry, and Other Land Use contributes about 23% of total net anthropogenic emissions of greenhouse gases. At the same time, organic production can help reduce greenhouse gas emissions and sequester carbon in the soil.

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 best time to have addressed global warming was 20 years ago, but the second-best time is now. Organic, regenerative agricultural practices help mend the earth from the ground up. Rep. Pingree’s Agriculture Resilience Act establishes specific goals and responsibilities in order to “accelerate the ability of agriculture and the food system to first achieve net zero carbon emissions and then go further to be carbon positive by removing additional carbon dioxide from the atmosphere.”

Tell Your Congressional Representative to Cosponsor H.R. 5861.

Letter to Congress

Agriculture both suffers from the impacts of the climate crisis and contributes significantly to global warming.  I am writing to ask you to cosponsor H.R. 5831, which is aimed at achieving a 50% reduction in agricultural emissions by 2030 and net zero emissions by 2040, relative to 2010 levels.

July of 2019 was the hottest month ever recorded on Earth. The last time atmospheric carbon dioxide levels were this high (over 415 ppm) was during the Pliocene period – between 5.3 and 2.6 million years ago. We have seen changing precipitation and temperature patterns, resulting in flooding of some agricultural regions and droughts in others, crops and livestock varieties no longer suited to the geographical area where they have been produced, and new problems with insects, weeds, and disease.

The Intergovernmental Panel on Climate Change (IPCC) finds that Agriculture, Forestry, and Other Land Use contributes about 23% of total net anthropogenic emissions of greenhouse gases. At the same time, organic production can help reduce greenhouse gas emissions and sequester carbon in the soil.

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 best time to have addressed global warming was 20 years ago, but the second-best time is now. Organic, regenerative agricultural practices help mend the earth from the ground up. Rep. Pingree’s Agriculture Resilience Act establishes specific goals and responsibilities in order to “accelerate the ability of agriculture and the food system to first achieve net zero carbon emissions and then go further to be carbon positive by removing additional carbon dioxide from the atmosphere.”

Please cosponsor H.R. 5831.

Thank you.

As in the in the past, President Trump once more proposes a budget that slashes funding for essential scientific research and environmental protection. His budget proposal includes cuts of nearly 10 percent to Health and Human Services (HHS) and 26 percent to the Environmental Protection Agency (EPA). And in the Department of Agriculture (USDA), he would again attempt to cut back on the Supplemental Nutrition Assistance Program (food stamps). Climate change appears to be absent.

Tell your Congressional delegation to hold the line on EPA’s budget to protect health, resources, and the economy!

Although agency heads, like Secretary of Agriculture Sonny Perdue, support the President’s budget, nonprofit advocates for scientific research and environmental protection are more negative. “The administration’s proposed budget cuts to research risk slowing our nation’s science just when it is reaping benefits for all Americans in the forms of better health, a stronger economy, a more sustainable environment, a safer world, and awe-inspiring understanding,” said Sudip Parikh, chief executive of the American Association for the Advancement of Science.

Even as the new coronavirus spreads, the Center for Disease Control and Prevention (CDC), is targeted for a 16 percent reduction. CDC has responsibilities that go well beyond infectious diseases and drug abuse. The Agency for Toxic Substances and Disease Registry, established as part of the Superfund program, is part of CDC that creates toxicological profiles—comprehensive evaluations of toxic chemicals found at toxic waste sites.

The proposed 26 percent reduction in EPA’s budget would eliminate nearly 50 programs, including large cuts to research and development and elimination of funding for the Energy Star program. “Congress should toss this Trump budget into the dustbin of history like they’ve done with the other ones,” said former EPA Administrator Gina McCarthy, who served during the Obama administration and is now head of the Natural Resources Defense Council.  

The U.S. House of Representatives, which is constitutionally invested with the “power of the purse,” will be looking closely at cuts in the proposed budget. “Like the three budgets before this, the Trump budget request will likely face bipartisan opposition, but we can’t take anything for granted. As a member of the House Appropriations Committee, I will fight for funding to support the long-term health and wellbeing of all Americans and reject this reckless budget from President Trump,” said U.S. Representative Chellie Pingree of Maine.

Tell your Congressional delegation to hold the line on EPA’s budget to protect health, resources, and the economy!

Letter to Congress

Please support a budget that fully funds scientific research and environmental protection programs.

Although his appointed agency heads support the President’s budget, nonprofit advocates for scientific research and environmental protection are more negative. “The administration’s proposed budget cuts to research risk slowing our nation’s science just when it is reaping benefits for all Americans in the forms of better health, a stronger economy, a more sustainable environment, a safer world, and awe-inspiring understanding,” said Sudip Parikh, chief executive of the American Association for the Advancement of Science.

Even as the new coronavirus spreads, the Center for Disease Control and Prevention (CDC), is targeted for a 16 percent reduction. CDC has responsibilities that go well beyond infectious diseases and drug abuse. The Agency for Toxic Substances and Disease Registry, established as part of the Superfund program, is part of CDC that creates toxicological profiles—comprehensive evaluations of toxic chemicals found at toxic waste sites.

President Trump’s proposed 26 percent reduction in EPA’s budget would eliminate nearly 50 programs, including large cuts to research and development and elimination of funding for the Energy Star program. “Congress should toss this Trump budget into the dustbin of history like they’ve done with the other ones,” said former EPA Administrator Gina McCarthy, who is now head of the Natural Resources Defense Council.

This is false economy. It endangers the American public and its air, land, water, and biodiversity. EPA is responsible for enforcing the Safe Drinking Water Act, with a goal of making the nation’s waters fishable and swimmable. EPA enforces the Clean Air Act, which has cleaned up American cities, reducing illness and property damage from smog. And EPA is responsible for overseeing the clean-up of contaminated sites, thus preventing further pollution and illness. The agency also regulates pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

All of EPA’s programs require the application of science to public policy.

EPA has been plagued with budget constraints for many years, but now, with such drastic cuts, programs spearheaded by EPA to protect air, water, people, and wildlife from toxic pollution will suffer–a goal made clear by the Trump Administration. Eliminating resources needed to prevent problems means that more money will need to be spent repairing damage and treating disease.

EPA plays a critical role in reviewing science and implementing laws protecting human health and the environment. Science itself has been under attack by the Trump Administration, as evidenced by its issuance of scientific grant and hiring freezes at EPA and other agencies nationwide, along with a ban on science communications through social media platforms.

Please support a budget that fully funds scientific research and environmental protection programs.

Sincerely,

Through the publication of Rachel Carson’s Silent Spring, pesticide dangers became a major driver for the environmental movement. Perhaps the most effective piece of environmental legislation is the National Environmental Policy Act (NEPA). Because NEPA requires a wide-ranging evaluation of the potential environmental impacts of federal actions, as well as alternatives, it serves as a model for environmental decision making. Now key elements of NEPA are under attack by the Trump Administration.

Ask your Congressional Representatives to pressure the White House to retract the proposed changes. At the same time, add your signature to the Beyond Pesticides public comment to Council on Environmental Quality (CEQ).

NEPA established the Council on Environmental Quality (CEQ) as the agency within the White House that is responsible for carrying out the purposes of the act. The regulations established by the CEQ have persisted through changes in administrations for more than 30 years without major modification. Changes proposed by the Trump Administration’s CEQ threaten this model decision-making process.

NEPA is a procedural law. It sets no environmental standards, but sets a standard for evaluating environmental impacts of proposed federal actions. It requires that federal agencies consider the short-term, long-term, and cumulative impacts of actions and disclose them to the public. Courts have ruled, for example, that registration of a pesticide by EPA is not sufficient to address environmental concerns under NEPA.

The Trump CEQ proposal will weaken NEPA regulations in a number of ways:

• It will limit the scope of required review to exclude from NEPA review non-federal projects with minimal federal funding or minimal federal involvement.
• It will remove the requirement for cumulative impact analysis, an important component of NEPA review. This removes the examination of greenhouse gas emissions.
• It advises agencies to evaluate the applicability of NEPA in a way that conflicts with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act.”
• It defines the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant.”
• It establishes tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments. While this may eliminate some wasted time, it also limits the depth of analysis.

Ask your Congressional Representatives to pressure the White House to retract the proposed changes. At the same time, add your signature to the Beyond Pesticides public comment to Council on Environmental Quality (CEQ).

Petition to CEQ

(Comment to CEQ that must be submitted to Regs.gov by March 10. https://www.regulations.gov docket number CEQ-2019-0003)

NEPA requires that federal agencies perform a comprehensive, cumulative, in-depth analysis of the environmental impacts of proposed federal actions and alternatives to them. NEPA establishes a standard of decision-making for all federal agencies. CEQ’s proposed changes to NEPA regulations are unacceptable and should be scrapped. They would:

*Unreasonably limit the scope of required review;

*Remove the requirement for cumulative impact analysis and the examination of greenhouse gas emissions;

*Conflict with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act;”

*Define the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant;” and

*Establish tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments, limiting the depth of analysis.

Thank you for your consideration.

Letter to Congress

I am writing to ask that you intervene with the Council on Environmental Quality to prevent the issuance of regulations that would weaken environmental decision making.

Through the publication of Rachel Carson’s Silent Spring, pesticide dangers became a major driver for the environmental movement. Perhaps the most effective piece of environmental legislation is the National Environmental Policy Act (NEPA). Because NEPA requires a wide-ranging evaluation of the potential environmental impacts of federal actions, as well as alternatives, it serves as a model for environmental decision making. Now key elements of NEPA are under attack by the Trump Administration.

NEPA established the Council on Environmental Quality (CEQ) as the agency within the White House that is responsible for carrying out the purposes of the act. The regulations established by the CEQ have persisted through changes in administrations for more than 30 years without major modification. Changes proposed by the Trump Administration’s CEQ threaten this model decision-making process.

NEPA is a procedural law. It sets no environmental standards, but sets a standard for evaluating environmental impacts of proposed federal actions. It requires that federal agencies consider the short-term, long-term, and cumulative impacts of actions and disclose them to the public. Courts have ruled, for example, that registration of a pesticide by EPA is not sufficient to address environmental concerns under NEPA.

The Trump CEQ proposal will weaken NEPA regulations in a number of ways:

*It will limit the scope of required review to exclude from NEPA review non-federal projects with minimal federal funding or minimal federal involvement.

*It will remove the requirement for cumulative impact analysis, an important component of NEPA review. This removes the examination of greenhouse gas emissions.

*It advises agencies to evaluate the applicability of NEPA in a way that conflicts with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act.”

*It defines the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant.”

*It establishes tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments. While this may eliminate some wasted time, it also limits the depth of analysis.

Please tell the CEQ to revoke these proposed regulations.

Thank you.

In more bad news from the insect world, recent research published in the Proceedings of the National Academy of Sciences reveals a precipitous decline in numbers of mayflies where they have been historically abundant. The research finds that in the Northern Mississippi River Basin, seasonal emergence of burrowing mayfly (genus Hexagenia) adults declined by 52% from 2012 to 2019; in the Western Lake Erie Basin, from 2015 to 2019, the reduction was a shocking 84%. Neonicotinoid insecticides are a significant factor in this decline because mayflies are extremely vulnerable to their impacts, even at very low exposure levels.

Ask Congress to tell EPA, USDA, and the Department of Interior to develop a joint effort to ensure that its decisions and compliance with its authorizing statutes address the crisis of the threat to mayflies.

Ephemeroptera to entomologists—“mayflies” to the rest of us—is an insect order comprising keystone species, on which other species in an ecosystem are very dependent, and without which, the ecosystem would undergo drastic change. The plummeting mayfly “count” is especially alarming because mayflies are a critical, primary food source in aquatic and terrestrial ecosystems, and provide an important ecological service. As the research study notes, “Seasonal animal movement among disparate habitats is a fundamental mechanism by which energy, nutrients, and biomass are transported across ecotones. A dramatic example of such exchange is the annual emergence of mayfly swarms from freshwater benthic [lake or river bottom] habitats. . . . Annual . . . emergences represent the exchange of hundreds of tons of elemental nutrients, thousands of tons of biomass, billions of organisms, and trillions of calories worth of energy to the surrounding terrestrial habitat. . . . A single emergence event can produce 87.9 billion mayflies, releasing 3,078.6 tons of biomass into the airspace over several hours.” According to Purdue University ecologist Jason Hoverman, PhD, “Mayflies serve critical functions in both aquatic and terrestrial ecosystems. Because of their important role as prey, reductions in their abundance can have cascading effects on consumers throughout the food web.” Without this critical keystone species, an important food source and nutrient recycler would be lost.

Thus, although neonics are directly toxic to many insects, the role of pesticides in destabilization of ecosystems is not necessarily direct. Beyond direct toxicity, pesticides can significantly reduce, change the behavior of, or destroy populations of plants and animals. These effects can ripple up and down food chains, causing what is known as a trophic cascade. The loss or reduction of populations at any trophic level—including amphibians, insects, or plants—can result in changes that are difficult to perceive, but nonetheless equally damaging to the stability and long-term health of an ecosystem.

Three phenomena account for most of the decrease in mayfly populations: (1) dramatically increased use of neonicotinoid pesticides, to which mayflies are highly sensitive; (2) algal blooms, especially in Lake Erie, caused primarily by runoff of agricultural fertilizers and other nutrient-dense pollutants; and (3) the warming impacts of the climate crisis, which include higher water temperatures that can wreak havoc with the development of these tiny creatures.

Because the threats to mayflies cut across regulatory boundaries, it is important for federal agencies to cooperate in protecting them. Action must be taken to protect vulnerable waterways from neonicotinoid contamination. The frequency of detections in U.S. waterways cannot be overlooked. Such routine detections, even at low levels, indicate that our waterways are being overloaded with mobile and persistent chemicals at highly elevated concentrations.  Thus far, little action has been taken to restrict the use of these chemicals in response to the independent scientific literature and EPA risk data that identify direct threats to aquatic invertebrates, as well as indirect threats to higher trophic organisms. Federal benchmarks based on testing on insensitive species are not protective of more sensitive species. Similarly, action is needed to prevent runoff from agricultural fields and feedlots and adopt climate-friendly policies.

Ask Congress to tell EPA, USDA, and the Department of Interior to develop a joint effort to ensure that its decisions and compliance with its authorizing statutes address the crisis of the threat to mayflies.

Letter to Congress

I am writing to call your attention to a serious ecological problem that requires a coordinated effort across government agencies.

Recent research published in the Proceedings of the National Academy of Sciences reveals a precipitous decline in numbers of mayflies where they have been historically abundant. In the Northern Mississippi River Basin, seasonal emergence of burrowing mayfly adults declined by 52% from 2012 to 2019; in the Western Lake Erie Basin, from 2015 to 2019, the reduction was a shocking 84%.

The plummeting mayfly “count” is alarming because mayflies are a critical, primary food source in aquatic and terrestrial ecosystems, and provide an important ecological service. As the research study notes, “Seasonal animal movement among disparate habitats is a fundamental mechanism by which energy, nutrients, and biomass are transported across ecotones…A single emergence event can produce 87.9 billion mayflies, releasing 3,078.6 tons of biomass into the airspace over several hours.”

According to Purdue University ecologist Jason Hoverman, PhD, “Mayflies serve critical functions in both aquatic and terrestrial ecosystems. Because of their important role as prey, reductions in their abundance can have cascading effects on consumers throughout the food web.” Without these critical keystone species, important food sources and nutrient recyclers would be lost.

Three phenomena account for most of the decrease in mayfly populations: (1) dramatically increased use of neonicotinoid pesticides, to which mayflies are highly sensitive; (2) algal blooms, especially in Lake Erie, caused primarily by runoff of agricultural fertilizers and other nutrient-dense pollutants; and (3) the warming impacts of the climate crisis, which include higher water temperatures that can wreak havoc with the development of these tiny creatures.

Because threats cut across regulatory boundaries, it is important for federal agencies to cooperate in protecting mayflies. U.S. waterways are being overloaded with mobile and persistent chemicals at highly elevated concentrations.  Little action has been taken to restrict the use of toxic chemicals despite independent scientific literature and EPA risk data that identify direct threats to aquatic invertebrates, as well as indirect threats to higher trophic organisms. Similarly, action is needed to prevent runoff from agricultural fields and feedlots and adopt climate-friendly policies.

Thank you,

United States military veterans suffering from bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms after their exposure to Agent Orange will remain unprotected and uncompensated until at least late 2020, according to a letter sent by Veterans Affairs (VA) Secretary Robert Wilkie to U.S. Senator Jon Tester (D-MT).

Send a letter to Veterans Affairs (VA) Secretary Robert Wilkie insisting that bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms be added to the VA’s list of eligible conditions.

Congress included a provision in the must-pass December federal spending bill requiring VA to provide legislators “a detailed explanation” for the now multi-year delay in determining whether to list the diseases. The provision is intended to cut through the ongoing delays, but there is no indication VA is going to meet the 30-day deadline. “The longer VA continues to drag its feet on expanding the list of conditions associated with Agent Orange, the longer our veterans continue to suffer—and die—as a result of their exposure,” Senator Tester said in a statement to the news site Connecting Vets. He continued, “It’s time for VA to stop ignoring the overwhelming evidence put forth by scientists, medical experts and veterans and do right by those who served. Any prolonging of their suffering is unacceptable.” 

The delay is seen by advocates for veterans as a serious lack of support and compensation at a time when the current administration is mobilizing the military. In October 2019, U.S. Senator Sherrod Brown’s (D-OH) attempt to introduce a resolution requiring the Trump Administration’s VA to list the diseases was shot down by U.S. Senate Veterans Affairs Committee Chairman Johnny Isakson (R-GA), citing costs. Rick Weidman, legislative director of Vietnam Veterans for America, summed up his response to ProPublica, “If you can afford the goddamn war, you can afford to take care of the warriors.”

“Some might accuse this body that we are waiting for them to die, as hard as it is to say that,” Sen. Brown said on the Senate floor. He continued, “Veterans shouldn’t have to fight this one at a time … we did this to them. The American government decided to spray Agent Orange. We knew it was harmful.”

According to Military Times, 83,000 veterans suffer from bladder cancer, Parkinson’s-like symptoms or hypothyroidism, and an untold number have high blood pressure. It is imperative that soldiers who fight for their country know they will be compensated when they fall ill as a result of their service.

Agent Orange, given its name because it was stored in orange striped drums, contained the active ingredients 2,4-D and 2,4,5-T. This formulation was contaminated with the highly toxic 2,3,7,8-tetrachlorodibenzo-p-dioxin (also called TCDD or simply dioxin) and is now banned. Not only were soldiers exposed on the battlefield, but many veterans who flew in post-Vietnam UC-123 Agent Orange spray aircraft had their health devastated by residual contamination.  

The Vietnam government is part of an ongoing lawsuit against Bayer’s Monsanto as the manufacturer of the deadly herbicide during the war. Recent reports find that dioxin continues to contaminate Vietnam’s soils, water, sediment, fish, aquatic species, and food supply.

While Agent Orange is banned, 2,4-D, which comprised one half of its make-up, is still one of the most widely used herbicides on lawns, school grounds, and parks today. It is considered a possible human carcinogen, and has been linked to liver damage and endocrine disruption in humans, in addition to being toxic to wildlife, pets and beneficial insects. Previous research from the U.S. Environmental Protection Agency has detected dioxin contamination in a number of 2,4-D herbicide products produced for consumer sale.

Send a letter to Veterans Affairs (VA) Secretary Robert Wilkie insisting that bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms be added to the VA’s list of eligible conditions.

Letter to Secretary Robert Wilkie

Dear Secretary Wilkie:

I am writing in support of United States military veterans suffering from bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms after their exposure to Agent Orange—who remain unprotected and uncompensated.

The VA continues to drag its feet on expanding the list of conditions associated with Agent Orange, and our veterans continue to suffer—and die—as a result of their exposure. As Senator Tester said, “It’s time for VA to stop ignoring the overwhelming evidence put forth by scientists, medical experts and veterans and do right by those who served. Any prolonging of their suffering is unacceptable.”

Your delay is evidence of a serious lack of support and compensation for veterans at a time when the current administration is mobilizing the military. Opponents of compensation cite costs, while others, like Rick Weidman, legislative director of Vietnam Veterans for America, say, “If you can afford the goddamn war, you can afford to take care of the warriors.”

“Some might accuse this body that we are waiting for them to die, as hard as it is to say that,” U.S. Senator Sherrod Brown said on the Senate floor. He continued, “Veterans shouldn’t have to fight this one at a time … we did this to them. The American government decided to spray Agent Orange. We knew it was harmful.” According to Military Times, 83,000 veterans suffer from bladder cancer, Parkinson’s-like symptoms or hypothyroidism, and an untold number have high blood pressure.

It is imperative that soldiers who fight for their country know they will be compensated when they fall ill as a result of their service. Please add bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms to the VA’s list of eligible conditions.

Thank you.

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

Ask your U.S. Representative to support and cosponsor the Migratory Bird Protection Act. Thank those who are already cosponsors.

Songbirds Threatened. The poisonous farm fields that migratory birds forage reduce their weight, delay their travel, and ultimately jeopardize their survival, according to “A neonicotinoid insecticide reduces fueling and delays migration in songbirds,“ published in the journal Science. Like their effects on insect pollinator populations, neonicotinoid insecticides generally do not cause acute poisoning and immediate death, but instead precipitate a cascade of sublethal impacts reducing their fitness in the wild. As the authors told Environmental Health News, the study is a call not simply to ban neonics or one class of chemical, but to change the entire farming system toward more sustainable bird and bee-friendly practices.

Bird Habitat Threatened in Arkansas. A citizen science monitoring project of Audubon Arkansas found evidence of contamination from the weed killer dicamba far from the genetically engineered soybean and cotton fields, documenting nearly 250 observations of dicamba symptomology across 17 Arkansas counties. Community scientists were trained by Audubon to detect dicamba symptoms. Dan Scheiman, PhD, bird conservation director for the organization, after launching the project this spring, said, “Spraying dicamba on millions of acres of soybean and cotton is an uncontrolled experiment that puts sensitive habitats at unacceptable risk. In a landscape full of genetically engineered crops, the atmospheric build-up of volatized dicamba may result in significant damage to our state natural areas, wildlife management areas, national wildlife refuges, family farms, and the wildlife they harbor.”

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit. The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials use the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines, and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.

Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

On January 8, U.S. Representative Alan Lowenthal and 18 bipartisan cosponsors introduced the Migratory Bird Protection Act (H.R. 5552) to restore the critical protections removed by the Trump Administration.

Ask your U.S. Representative to support and cosponsor the Migratory Bird Protection Act. Thank those who are already cosponsors.

Letter to request cosponsorship

I am writing to ask you to restore important protections for migratory birds by cosponsoring H.R. 5552, the Migratory Bird Protection Act.

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

Songbirds Threatened: The poisonous farm fields that migratory birds forage reduce their weight, delay their travel, and ultimately jeopardize their survival, according to “A neonicotinoid insecticide reduces fueling and delays migration in songbirds,“ published in the journal Science. Like their effects on insect pollinator populations, neonicotinoid insecticides generally do not cause acute poisoning and immediate death, but instead precipitate a cascade of sublethal impacts reducing their fitness in the wild. As the authors told Environmental Health News, the study is a call not simply to ban neonics or one class of chemical, but to change the entire farming system toward more sustainable bird and bee-friendly practices.

Bird Habitat Threatened in Arkansas: A citizen science monitoring project of Audubon Arkansas found evidence of contamination from the weed killer dicamba far from the genetically engineered soybean and cotton fields, documenting nearly 250 observations of dicamba symptomology across 17 Arkansas counties. Community scientists were trained by Audubon to detect dicamba symptoms. Dan Scheiman, PhD, bird conservation director for the organization, after launching the project this spring, said, “Spraying dicamba on millions of acres of soybean and cotton is an uncontrolled experiment that puts sensitive habitats at unacceptable risk. In a landscape full of genetically engineered crops, the atmospheric build-up of volatized dicamba may result in significant damage to our state natural areas, wildlife management areas, national wildlife refuges, family farms, and the wildlife they harbor.”

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit. The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials used the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.
Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

Please cosponsor the Migratory Bird Protection Act (H.R. 5552) introduced by Representative Alan Lowenthal and 18 bipartisan cosponsors to restore the critical protections removed by the Trump Administration.

Letter to current cosponsors

I am writing to thank you for cosponsoring H.R. 5552, the Migratory Bird Protection Act.

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit.  The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials used the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.

Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

Thank you for cosponsoring H.R. 5552, the Migratory Bird Protection Act.

In the midst of recalls of romaine lettuce contaminated with a pathogenic strain of E. coli, states and counties across the country are calling for a moratorium on large confined animal feeding operations (CAFOs). Now Senator Cory Booker is seeking to pass similar legislation at the national level. These industrial-scale operations are commonly referred to as “factory farms.”

>>Tell your U.S. Senator to cosponsor the Farm System Reform Act.

In the last week of November 2019, the Centers for Disease Control and Prevention (CDC) issued a food safety alert concerning a multistate outbreak of E. coli linked to romaine lettuce harvested from Salinas, California. As of November 25, 67 cases had been reported across 19 states, 39 of which required hospitalization, including six who developed kidney failure. The E. coli strain causing the outbreak — O157:H7, also known as STEC — is genetically identical to that responsible for lettuce-related outbreaks in 2017 and 2018. STEC is a dangerous, Shiga toxin-producing type of E. coli. Other outbreaks occurred earlier in 2019 as well.

Dangerous strains of E. coli, including O157:H7, are typically associated with cattle in feedlot conditions. The first of the two outbreaks in 2018 was traced back to manure runoff from a CAFO in the vicinity of the lettuce farm, which polluted water that was used to irrigate the lettuce fields. CAFOs are a major source of water contamination throughout the U.S. As noted by the Arizona Department of Environmental Quality, "Nationwide and in Arizona, the potential for surface and ground water pollution exists through livestock facility discharge of manure-contaminated run off to natural waterways and through wastewater leaching to aquifers. Water and air pollution lead the list of concerns that have led to a number of state and local initiatives to institute moratoria on new and expanded CAFOs. Iowa, which has experienced an explosion of CAFOs, is the example these people want to avoid. In South Dakota, Lyle Reimnitz, who lives a half-mile from a Davison County hog farm with a permit for 8,000 sows, says, “I don't want to see South Dakota become another Iowa,” he said. “We don't need all our rivers and streams polluted. I know everybody wants cheap meat, but that comes at a terrible price for people who live here.”

In Wisconsin, supporters of a statewide moratorium on CAFOs are urging concerned citizens to ask County Supervisors, Town Board Members, and City Councilors to pass resolutions supporting a state-wide CAFO moratorium. In California, a report on dairy CAFOs found that “major production externalities are still imposed upon the communities in which Concentrated Animal Feeding Operations (CAFOs) are located, due in large part to lack of resources, information, enforcement capability and political will on the part of local and regional regulatory agencies.” And, in Indiana, a report by the Indiana Business Research Center found, “For town residential properties, having the closest RLO [regulated livestock operation, or CAFO] upwind of the residence reduced the sale price by $4,980.00 and if the closest RLO contained dairy cattle, the sale price was further reduced by $32,340.00 for every 100 mature head.” In addition to these concerned citizens, the American Public Health Association has also called for a moratorium on CAFOs.

A majority of Americans say they want more stringent oversight of large-scale livestock operations, according to a national poll by Johns Hopkins University's Center for a Livable Future released December 10, 2019.

Traditional family farmers, and groups like the National Farmers Union, favor judicious regulatory controls due to the overall deleterious impacts these industrial agricultural sites have on rural communities. Other impacts include odors and fugitive dust that might contain antibiotic-resistant organisms.

Senator Booker's bill, the Farm System Reform Act, would require that "corporate integrators" are "responsible for pollution and other harm caused by CAFOs,” which would be phased out by 2040.  

>>Tell your U.S. Senator to cosponsor the Farm System Reform Act.

Letter to Congress

I am writing to ask you to cosponsor the Farm System Reform Act, unveiled by Senator Cory Booker in December.

In the midst of recalls of romaine lettuce contaminated with a pathogenic strain of E. coli, states and counties across the country are calling for a moratorium on large confined animal feeding operations (CAFOs). Sen. Booker’s bill seeks a moratorium at the national level.

In the last week of November 2019, the Centers for Disease Control and Prevention (CDC) issued a food safety alert concerning a multistate outbreak of E. coli linked to romaine lettuce harvested from Salinas, California. As of November 25, 67 cases had been reported across 19 states, 39 of which required hospitalization, including six who developed kidney failure. The E. coli strain causing the outbreak — O157:H7, also known as STEC — is genetically identical to that responsible for lettuce-related outbreaks in 2017 and 2018. STEC is a dangerous, Shiga toxin-producing type of E. coli. Other outbreaks occurred earlier in 2019 as well.

E. coli O157:H7 is typically associated with cattle. The first of the two outbreaks in 2018 was traced back to manure runoff from a CAFO in the vicinity of the lettuce farm, which polluted water that was used to irrigate the lettuce fields. CAFOs are a major source of water contamination throughout the U.S. As noted by the Arizona Department of Environmental Quality, “Nationwide and in Arizona, the potential for surface and ground water pollution exists through livestock facility discharge of manure-contaminated run off to natural waterways and through wastewater leaching to aquifers.”

Water and air pollution lead the list of concerns that have led to a number of state and local initiatives to institute moratoria on new and expanded CAFOs. Iowa, which has experienced an explosion of CAFOs, is the example these people want to avoid. In South Dakota, Lyle Reimnitz, who lives a half-mile from a Davison County hog farm with a permit for 8,000 sows, says, “I don’t want to see South Dakota become another Iowa,” he said. “We don’t need all our rivers and streams polluted. I know everybody wants cheap meat, but that comes at a terrible price for people who live here.”

In Wisconsin, supporters of a statewide moratorium on CAFOs are urging concerned citizens to ask County Supervisors, Town Board Members, and City Councillors to pass resolutions supporting a state-wide CAFO moratorium. In California, a report on dairy CAFOs found that “major production externalities are still imposed upon the communities in which Concentrated Animal Feeding Operations (CAFOs) are located, due in large part to lack of resources, information, enforcement capability and political will on the part of local and regional regulatory agencies.” In Indiana, a report by the Indiana Business Research Center found, “For town residential properties, having the closest RLO [regulated livestock operation, or CAFO] upwind of the residence reduced the sale price by $4,980.00 and if the closest RLO contained dairy cattle, the sale price was further reduced by $32,340.00 for every 100 mature head.” In addition to these concerned citizens, the American Public Health Association has also called for a moratorium on CAFOs.

A majority of Americans say they want more stringent oversight of large-scale livestock operations, according to a national poll by Johns Hopkins University’s Center for a Livable Future released December 10, 2019.

Please cosponsor Senator Booker’s bill, the Farm System Reform Act, which would require that “corporate integrators” are “responsible for pollution and other harm caused by CAFOs” and phase them out by 2040.

Thank you.