23
Dec
Trump EPA Gives Neurotoxic Insecticide Chlorpyrifos Another Thumbs Up, Ignoring Brain Effects in Children
(Beyond Pesticides, December 23, 2020) The litany of parting shots by the waning Trump administration got longer on December 4, when the Environmental Protection Agency (EPA) announced a proposed interim decision on the very toxic pesticide chlorpyrifos, functionally continuing its registration for many agricultural uses. The interim decision purports to put in place new limitations on use of this pesticide, but they are wholly inadequate to the threat this compound represents — to young children, most concerningly, as well as to farmworkers, critical species and ecosystems, and the public. Chlorpyrifos should not be re-registered for use — i.e., its sale and use should be banned altogether, as Beyond Pesticides has asserted for years.
Chlorpyrifos is an organophosphate pesticide used on scores of food crops, for mosquito (and other pest) control, and for some turf management (golf courses, especially). It has been demonstrated to be highly neurotoxic, especially to young children, leading to impaired cognitive function, developmental delays, lower IQs, attention deficit disorder, and a variety of other pervasive developmental and learning disorders. The essence of the compound’s toxicity to developing brains lies in its function as a cholinesterase inhibitor; chlorpyrifos binds to the receptor sites for acetylcholinesterase (AChE), an enzyme that is critical to normal nerve impulse transmission. In so doing, chlorpyrifos inactivates AChE, damages the central and peripheral nervous systems, and disrupts neurological activity. In addition to its neurotoxic impacts, the compound is associated with harmful reproductive, renal, hepatic, and endocrine disrupting effects.
The Center for Food Safety (CFS) writes: “The interim ‘decision’ leaves much undecided, including safety thresholds for chlorpyrifos exposure and possible mitigation measures, which EPA is currently negotiating with chlorpyrifos manufacturers.” CFS also excoriates this latest decision: “EPA has long been aware of the pesticide’s toxicity. While most residential uses of chlorpyrifos were banned nearly two decades ago, the agency permitted its continued use in agriculture, creating a double-standard in which rural kids and farmworkers are left unprotected. People are exposed to chlorpyrifos in food and water, but also through inhalation of spray drift and vapor.”
CFS legal director George Kimbrell commented on the interim decision: “True to form, the Trump Administration has placed corporate dollars over public health. If allowed to stand, its proposal to continue registering this neurotoxic insecticide would cause irreparable harm to farmworkers and future generations. Everything possible must be done to ensure the Biden Administration reverses this proposal and once and for all bans this pesticide.”
Having covered chlorpyrifos for many years, Beyond Pesticides concurs. It has reported on the tortuous path of EPA’s relationship, as well as legislative, legal, and state responses, to chlorpyrifos. In April 2019, Beyond Pesticides provided a timeline of relevant developments whose highlights are worth reviewing:
2001: EPA negotiates “successful” cancellation of chlorpyrifos for residential use
2007: Pesticide Action Network North America (PANNA) and Natural Resources Defense Council file petition requesting EPA revoke all tolerances for chlorpyrifos
2015: Obama administration proposes revocation of all tolerances for chlorpyrifos
2016: EPA’s revised human health risk assessment does not change the proposal to ban chlorpyrifos; Donald Trump is elected president
2017: Scott Pruitt reverses order; a coalition of environmental groups led by Earthjustice promptly sues EPA
2018:
June: Hawaii becomes first state in U.S. to outright ban chlorpyrifos, effective 2022
August: court orders chlorpyrifos ban, finding EPA violated the law; Trump administration appeals the ruling
December: Sen. Brian Schatz (HI) introduces the Prohibit Chlorpyrifos Poisoning Students Act
2019:
January: Rep. Nydia Velásquez (NY) reintroduces The Ban Toxic Pesticides Act, H.R.230, which would ban chlorpyrifos from commerce
March:
- Senator Tom Udall (D-NM) reintroduces Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act of 2019
- Oregon lawmakers consider House Bill 3058 and Senate Bill 853, nearly identical attempts to ban chlorpyrifos
- documents obtained by the Center for Biological Diversity reveal that the Trump administration knew and actively concealed the fact that chlorpyrifos jeopardizes the existence of 1,399 endangered species
April:
- proposed chlorpyrifos ban in Maryland (HB275, SB270) fails to pass for the second year in a row
- Senator Kirsten Gillibrand (NY) introduces Safe School Meals for Kids Act to restrict schools from purchasing or serving food with any detectable amount of chlorpyrifos
Since April 2019, there have been more developments:
2019:
May: New York State legislature passes a bill to phase out and eventually ban the use of chlorpyrifos
October: California announces an early 2020 ban on use of chlorpyrifos
December: NYS Governor Cuomo vetoes the legislature’s bill, but orders the state Department of Environmental Conservation to ban aerial applications immediately and all uses by 2021, using rule-making rather than legislation; this makes it the third state to ban the toxic compound
2020:
February: Corteva announces it will stop producing chlorpyrifos in 2020 because of declining sales
March: the Maryland legislature passes a limited ban on chlorpyrifos
August: a study reveals that research underpinning chlorpyrifos registration by EPA left critical data out of its analysis, resulting in decades of use of a faulty EPA “safe exposure limit”
September: EPA — contravening scientific evidence and its own findings — announces its conclusion that “the science addressing neurodevelopmental effects [of the insecticide chlorpyrifos] remains unresolved”
Then came this interim decision, which proposes to limit uses of chlorpyrifos in some U.S. regions “to better protect human health and the environment,” according to EPA. The decision proposes: (1) “label amendments limiting application to address potential drinking water risks of concern,” (2) “additional personal protection equipment and application restrictions to address potential occupational handler risks of concern,” and (3) “spray drift mitigation, in combination with the use limitations and application restrictions identified to address drinking water and occupational risks, to reduce exposure to non-target organisms.”
The text of the draft interim decision, which sets out the details, can be accessed (as a .pdf) from EPA’s interim decision link. A gander at regional application limits (in the tables in section IV of the draft decision, “Proposed Interim Registration Review Decision”) shows that the proposed “limits” continue to allow “high-benefit agricultural uses,” in the aggregate, on nine crops across 40 states. This is unacceptable for such a dangerous pesticide, to which people can be exposed through diet, water, landscape uses, and/or “use on public health pests, such as mosquitoes, ticks, and fire ants.”
In truth, this decision continues the Trump EPA’s anti-science, anti-regulatory track record. One among many examples is that despite the endocrine-disrupting effects of chlorpyrifos (see evidence here, here, and here), this decision asserts: “there is no evidence demonstrating that chlorpyrifos potentially interacts with estrogen, androgen, or thyroid pathways.”
Further, Beyond Pesticides reported in 2019 on the administration’s concealment of a report showing that 1,399 endangered species are significantly threatened by chlorpyrifos (and two other organophosphate pesticides). This interim decision states, “The proposed mitigation described in this document is expected to reduce the extent of environmental exposure and may reduce risk to listed species whose range and/or critical habitat co-occur with the use of chlorpyrifos. . . . EPA is currently working with the National Marine Fisheries Service (NMFS) under a reinitiated Endangered Species Act (ESA) consultation, and NMFS plans to issue a revised biological opinion for chlorpyrifos in June 2022 [emphasis by Beyond Pesticides]. The U.S. Fish and Wildlife Service (FWS) has not yet completed a biological opinion for chlorpyrifos. EPA will complete any necessary consultation with NMFS and FWS for chlorpyrifos prior to completing the chlorpyrifos registration review.” Thus, vulnerable wildlife and habitat will continue to be at risk for at least another year and a half (barring any change by the coming Biden administration), pending a final EPA registration decision on chlorpyrifos.
Beyond Pesticides wrote in 2019, and continues to maintain, that absent effective national protections, “States should ban chlorpyrifos compounds . . . should undertake organic management on state-owned lands, and should support producers in transitioning away from chemical agriculture and to organic, regenerative, and sustainable practices.
It can be hoped that this interim decision is the last one on pesticide registration to emerge from the exiting Trump EPA, given the regulatory wreckage it has wrought generally and on this compound, in particular. Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA’s continued permitting of its use an extreme failure of the agency’s protective mission. This pesticide should be banned. Public comment on the proposed interim decision is open for 60 days; please tell EPA not to advance uses of chlorpyrifos here.
Sources: https://www.centerforfoodsafety.org/press-releases/6214/center-for-food-safety-decries-epa-proposed-interim-decision-on-brain-damaging-pesticide-chlorpyrifos#:~:text=(December%207%2C%202020%3B%20Washington,the%20Obama%20Administration’s%20EPA%20in and https://www.epa.gov/ingredients-used-pesticide-products/proposed-interim-decision-registration-review-chlorpyrifos
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
