02
Apr
Lawsuit Challenges EPA Allowance of Antibiotic Streptomycin in Citrus
(Beyond Pesticides, April 2, 2021) Having raised the alarm for many years (and most recently in November 2020) on the dangers of the burgeoning antibiotic resistance crisis, Beyond Pesticides has joined a coalition of public interest groups in a lawsuit against the U.S. Environmental Protection Agency (EPA) for its approval of use of the medically important antibiotic streptomycin on citrus trees. Beyond Pesticides executive director Jay Feldman comments: “It is past time to take urgent action to transition away from practices in agriculture that are dependent on antibiotics, advance organic farm management, and avoid new deadly pandemics. This lawsuit is an important action to reverse the previous administration’s decision to ignore the science and allow expanded use of an antibiotic in agriculture.”
According to the National Resources Defense Council (NRDC), the suit charges that EPA “failed to ensure that the approved uses of streptomycin as a pesticide would not cause unreasonable harm to human health or the environment and failed to adequately assess impacts to endangered species.” The coalition of plaintiffs includes Beyond Pesticides, NRDC, Center for Biological Diversity, Environmental Confederation of Southwest Florida, Farmworker Association of Florida, Farmworker Justice, Migrant Clinicians Network, and U.S. PIRG. The coalition is represented in the suit by Earthjustice and in-house counsel.
In a related action, Beyond Pesticides has also sued Sargento Foods, Inc. for its misleading claims of “no antibiotics” in its products. The lawsuit alleges that the company’s cheese products are made with milk from cows administered antibiotics, and that those antibiotic compounds are detectable in some of the company’s products.
Broadly speaking, all pesticides are “antibiotics” in the sense that they kill biological organisms. But some, such as the commonly used herbicides glyphosate, dicamba, and 2,4-D (as well as some of the “inert” ingredients in their formulations) are demonstrably driving antibiotic resistance in some human pathogenic bacteria, per research Beyond Pesticides covered in 2017. To wit: exposure to these herbicides generally negatively alters bacterial response to antibiotics such as tetracycline, ampicillin, and ciprofloxacin, all of which are used medically to treat a range of serious diseases.
The antibiotic resistance (also referred to as anti-microbial, or AMR resistance) crisis is one of human bacterial infections becoming increasingly resistant to the antibiotics most commonly prescribed by healthcare professionals to resolve such infections. This causes infections to be much harder to treat, to last longer, to require increased medical intervention (incurring the costs that go with that), and sometimes, a complete inability to treat life-threatening infections. This crisis is caused, inevitably, by antibiotics’ very use (and too often, overuse) because they exert strong selection pressure for bacterial strains that exhibit antibiotic resistance. Bacteria can mutate quickly and take rapid advantage of mutations that make them more resistant to antibiotics; thus, resistance develops and spreads as these resistant bacteria reproduce and “thrive.”
Two primary reasons for the rise of AMR — including multi-drug resistance — are the intensive use of antibiotics in agriculture, for both livestock and crops, and unnecessary medical uses. Research reported on by Beyond Pesticides in February 2021 showed that exposure of bacteria (in agricultural soils) to herbicides triggers evolutionary pressures on bacteria similar to those exposed to antibiotics. That Daily News article noted that, “Salmonella and E.coli exposed to the herbicides glyphosate, dicamba, and 2,4-D, triggered a non-specific defense mechanism which, while building resistance to the toxic effects of the herbicides, also resulted in resistance to commonly used antibiotics.” (Learn more about the history of resistance and antibiotics by visiting Beyond Pesticides’ Antimicrobials and Antibacterials website page.)
Beyond Pesticides wrote in 2019, “The contribution of antibiotic use in fruit trees to resistance in human pathogens may not be nearly as important as the use of non-therapeutic antibiotics in livestock and farmed fish, but it does have an impact on the pool of antibiotic-resistant bacteria. . . . The human pathogenic organisms themselves do not need to be sprayed by the antibiotic because movement of genes in bacteria is not solely ‘vertical,’ that is, from parent to progeny, but can be “horizontal”— from one bacterial species to another. So, a pool of resistant soil bacteria can provide the genetic material for resistance in human pathogens.”
Streptomycin, the antibiotic at issue in this lawsuit, is used medically to treat multiple diseases, including endocarditis, tularemia, and plague, but especially, multi-drug resistant tuberculosis. The pharmaceutical belongs to a class of antibiotics considered critically important by the World Health Organization for such uses. NRDC notes that, “The Centers for Disease Control and Prevention and the Food and Drug Administration have expressed concerns about the use of medically important antibiotics as pesticides and have spoken out publicly against it.”
Streptomycin has been banned for agricultural use on crops in many countries, but in the U.S., use of it and oxytetracycline in fruit and vegetable production has been permitted. Recently, the Trump administration EPA issued an emergency use authorization, in 2017, to expand use of these antibiotics to Florida citrus crops to control the bacterial “citrus greening disease,” also known as Huanglongbing. That emergency authorization was to have run out in 2019, but in January of that year, EPA moved to make the authorization permanent. The decision greenlighted the use of more than 650,000 pounds of streptomycin on citrus crops in Florida and California alone, and followed an approval two years prior of oxytetracycline for use on the same citrus crops.
Beyond Pesticides issued an action alert at the time, encouraging the public to comment on EPA’s move, and calling for an end to antibiotic use in citrus production, citing the antibiotic resistance crisis. Beyond Pesticides wrote: “Antibiotic resistance is a real and urgent public health threat and represents an existential threat to modern civilization. Antibiotic resistance kills over 23,000 people each year, according to the Centers for Disease Control and Prevention (CDC). In addition . . . the World Health Organization has cited this escalating problem as among the biggest public health challenges of our time.”
Use of antibiotics is currently proscribed in all U.S. Department of Agriculture (USDA) Certified Organic production, but this was not always the case. When Beyond Pesticides Executive Director Jay Feldman was a member of the National Organic Standards Board (NOSB), he was instrumental in the effort to remove antibiotics from organic apple and pear production, which at the time were the last remaining agricultural uses permitted in organic production.
NOSB is now considering a petition to allow use of yet another antibiotic (kasugamycin) for organic apple and pear production. NOSB should reject the petition for this use for the same reasons that streptomycin and tetracycline should be disallowed for crop production. Use of antibiotics in agriculture “feeds the beast” of the antibiotic resistance crisis. Beyond Pesticides offers guidance on speaking out on this issue in the lead-up to the April 2021 NOSB annual meeting.
Uses of antibiotics on crops represent a smaller, but still significant, contributor to the AMR crisis, compared with uses on livestock — largely as additives to animal feed, both to prevent infection and cause unnaturally rapid growth in the animals. Scientists have warned that industrial agriculture’s use of CAFOs (concentrated animal feeding operations) are acting as large-scale petri dishes that will develop increasing amounts of antibiotic-resistant bacteria, and potentially contribute to whatever the next pandemic may be.
As humanity is grappling with the COVID-19 pandemic, health advocates say such warnings should be heeded. The current pandemic is a viral one, but bacterial pandemics are also a threat; think of tuberculosis or bacterial meningitis, and historically, leprosy or the plague. In September 2020, the esteemed medical journal The Lancet published commentary on AMR, noting: “The rise in multidrug-resistant bacterial infections that are undetected, undiagnosed, and increasingly untreatable threatens the health of people in the USA and globally. In 2020 and beyond, we cannot afford to ignore antimicrobial resistance (AMR). Bacterial infections unsuccessfully treated due to AMR claim at least 700,000 lives per year worldwide and are projected to be associated with the deaths of 10 million people per year by 2050, at a cost of US$100 trillion to the global economy through loss of productivity. In the USA, more than 2.8 million multidrug-resistant bacterial infections occur annually, causing at least 35,000 deaths and $20 billion in health-care expenditures.”
The World Health Organization has declared that, “AMR is one of the ten top global public health threats facing humanity.” The use of antibiotics in agriculture is contributing to the potential for such pandemics. Among The Lancet article’s recommendations is this: that the U.S. ban the use of medically important antibiotics in agribusiness.
In its recent special issue of Pesticides and You, Beyond Pesticides made a compelling case for the urgent need to mount a cross-federal-agency strategy for addressing the antibiotic resistance/AMR crisis before it escalates to a full-blown pandemic of one bacterial disease or another. The article notes that the Obama administration released, in 2015, a comprehensive action plan for reducing antibiotic misuse and ramping up progress on new antimicrobials and vaccines. This was called the National Action Plan for Combating Antibiotic-Resistant Bacteria (NAPCARB); its enactment was less than optimal.
What then ensued during the Trump administration is described: “In 2017, the U.S. Food and Drug Administration (FDA) banned use of antibiotics as growth promoters in livestock, but [in] the same year . . . 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, [EPA] approved expansion of medically important antibiotics such as streptomycin and oxytetracycline as pesticides to increase crop yields, and USDA removed federal oversight of meat inspection at pork processing plants.” Taken together, these actions likely advanced the AMR crisis.
Allison Johnson, Sustainable Food Policy Advocate with NRDC, one of the plaintiffs in the subject lawsuit against EPA, sums up the central argument and the spirit of the case: “Allowing life-saving antibiotics to be used as pesticides is an unnecessary and dangerous practice that fuels a growing public health epidemic: antibiotic resistance. The EPA should be championing agricultural practices that protect farm workers and their communities, public health, and the environment — like building healthy soil and diversified farming — not increasing the use of dangerous pesticides.” Beyond Pesticides perennially notes the urgent need for the transition to organic, regenerative agricultural systems. These practices would not only obviate farming’s contribution to the AMR crisis, but also, build healthy soils, support biodiversity, and eliminate toxic inputs and their downstream environmental and health sequelae.
Now, with a new administration in place, Beyond Pesticides reminds federal agencies and the public that continued failure to deal with AMR would “undermine decades of advances in medicine and public health.” COVID-19 ought to be a loud alarm bell for the need to pick up and move forward on NAPCARB through a coordinated and collaborative effort of the agencies whose work is intimately related: EPA, USDA, and FDA. The Biden administration must tackle this, and other, public health and environmental threats with robust systemic change.
Source: https://www.nrdc.org/media/2021/210325
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
