16
Aug
Tell EPA: It Must Ban Pesticides Unless Shown Not To Be Endocrine Disruptors
(Beyond Pesticides, August 16, 2021) The failure of the U.S. Environmental Protection Agency (EPA) to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine-disrupting chemicals must end. The Office of the Inspector General (OIG) for EPA has issued a damning report on the agency’s progress in protecting the population from potentially damaging endocrine disruption impacts of exposures to synthetic chemical pesticides (and other chemicals of concern) that shows the situation to be even worse than previously reported. The OIG’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” As a result, according to the OIG, “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.”
Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.
Over recent decades, evidence has mounted showing that many pesticides interfere with hormones—and are therefore endocrine-disrupting chemicals (EDCs). In 1996, the promise of screening pesticides for endocrine disruption generated support from environmentalists and public health advocates for the Food Quality Protection Act (FQPA), which traded the absolute prohibition of carcinogens in food of the Delaney Clause for a risk assessment standard that is subject to manipulation and an underestimation of real-life hazards. And now, 25 years later, we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.
The endocrine system consists of a set of glands (thyroid, gonads, adrenal and pituitary) and the hormones they produce (thyroxine, estrogen, testosterone and adrenaline), which are responsible for the activation, regulation, and de-activation of a huge variety of functions in, especially, development, reproduction, growth, metabolism, the cardiac and circulatory system, sleep, mood, and behavior, among others. Hormones are signaling molecules that travel through the bloodstream and elicit responses in other parts of the body. The hormones secreted by the endocrine glands travel through the bloodstream to various organs and tissues, where they communicate critical regulatory messages.
The ingredients in many pesticides (and in many consumer products) act as endocrine disruptors in humans and other animals in several ways. They may: (1) mimic actions of hormones the body produces (e.g., estrogen or testosterone), causing reactions similar to those generated by the naturally produced hormones; (2) block hormone receptor cells, thereby preventing the actions of natural hormones; or (3) affect the synthesis, transport, metabolism, and/or excretion of hormones, thus altering the concentrations of natural hormones in tissues or at receptor sites.
As the OIG report notes, “Small disturbances in endocrine function, particularly during certain highly sensitive stages of the life cycle, such as pregnancy and lactation, can lead to profound and lasting effects. Adverse endocrine-related effects in humans may include breast cancer, diabetes, obesity, infertility, and learning disabilities.” In addition, there are both direct and indirect implications of EDCs, such as other cancers, Parkinson’s disease, multiple reproductive disorders and anomalies (e.g., polycystic ovary syndrome, testicular dysgenesis syndrome, endometriosis, and reduced sperm count), alteration of the gut biome and resultant dysfunction, and metabolic disorders apart from diagnosable diabetes.
The OIG report finds that EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP), which is responsible for testing all pesticide chemicals for endocrine-disrupting activity in humans, has failed to implement a section of the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by the 1996 Food Quality Protection Act — the legislation that requires such testing. In addition, the report states that OCSPP’s Office of Pesticide Programs (OPP) has not implemented a 2015 recommendation that 17 pesticides undergo additional testing as EDCs in wildlife so that an ecological risk assessment could be effectively conducted.
The report indicates that EPA has not created the tools (e.g., strategic guidance documents or performance measures) necessary to implement effectively the agency’s Endocrine Disruptor Screening Program (EDSP), created in 1998. In particular, EDSP has not “conducted annual internal program reviews to monitor or assess progress in fulfilling regulatory requirements, and the EDSP has not effectively communicated with internal and external stakeholders. Moreover, previous OCSPP leadership provided acceptable corrective actions to meet the recommendations in a 2011 EPA Office of Inspector General report regarding the EDSP, yet failed to actually implement those corrective actions beyond an initial period of compliance with them. Lastly, some EPA staff indicated that they were instructed to function as if the EDSP was eliminated from the EPA’s budget. Because the EDSP has not had effective internal controls in place since 2015, it cannot have reasonable assurance that the objectives of the program will be accomplished and that resources will be allocated efficiently and effectively.”
In 2017, Europe’s Pesticide Action Network refined an earlier estimate by the European Union that more than 50 pesticide active ingredients operate as endocrine disruptors. (That earlier list included those identified by TEDX, The Endocrine Disruption Exchange, which was launched by pioneering ED scientist Theo Colborn, PhD.) The update short-listed 37 pesticides of ED concern out of the nearly 500 on the market in Europe in 2015. In 2009, EPA created an EDSP “List 1” of 67 pesticides and “high production volume chemicals” used as pesticide inert ingredients that the agency deemed should be evaluated first for ED impacts. (EPA later reduced this list to 52 chemicals because 15 were subsequently canceled or discontinued.)
It is not only humans who are affected. Hermaphroditic frogs, polar bears with penis-like stumps, panthers with atrophied testicles and intersex fish with immature eggs in their testicles have all been linked to endocrine disruption. The popular herbicide atrazine chemically castrates and feminizes exposed male tadpoles. The mosquito-killing S-methoprene larvicide alters early frog embryo development. Distorted sex organ development and function in alligators is linked to the organochlorine insecticide dicofol. The ubiquitous antibacterial chemical triclosan alters thyroid function in frogs, while its chemical cousin triclocarban enhances sex hormones in rats and in human cells. In her book, Our Stolen Future, Dr. Colborn states that the decline of animal species can no longer be simply explained by habitat destruction and human disturbance, but also by reproductive failures within populations brought on by the influence of endocrine-disrupting chemicals.
The OIG report documents the repeated failures of EPA to meet deadlines set by Congress to develop and implement EDC testing. OIG findings are consistent with those reported by Sharon Lerner in her article in The Intercept, “Whistleblowers Expose Corruption in EPA Chemical Safety Office.” The article evinced not only laxity and managerial allegiance to industry interests, but also, downright corruption on the part of some managers at EPA.
EPA now issues Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption.
The report concludes: “In 1996, Congress directed the EPA to establish the EDSP, and the program received approximately $7.5 million in funding in fiscal year 2021. Yet, the EDSP can show only limited results. Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.”
The OIG report issued a series of 10 recommendations, directed to OCSPP Assistant Administrator Freedhoff, that address:
- tiered testing for ED impacts
- timelines for such testing
- strategic planning
- development of performance metrics
- improved communication, including to the public
- internal program review
- improved transparencyns
Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.
Letter to U.S. Environmental Protection Agency Administrator Michael Regan
I am writing to ask you to act now to meet a statutory mandate to protect humans and wildlife from dire health consequences. The failure of EPA to meet its statutory responsibility to protect against exposure to endocrine-disrupting chemicals (EDCs) must end. The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) has issued a damning report on the agency’s progress in protecting the population from EDCs used as pesticides, as mandated by the Food Quality Protection Act (FQPA) of 1996, which required EPA to establish a program to screen and test pesticides and other widespread chemical substances for endocrine-disrupting effects. The OIG’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” As a result, according to the OIG, “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.”
As the OIG report notes, “Small disturbances in endocrine function, particularly during certain highly sensitive stages of the life cycle, such as pregnancy and lactation, can lead to profound and lasting effects. Adverse endocrine-related effects in humans may include breast cancer, diabetes, obesity, infertility, and learning disabilities.” There are other direct and indirect implications of EDCs, such as other cancers, Parkinson’s disease, multiple reproductive disorders and anomalies (e.g., polycystic ovary syndrome, testicular dysgenesis syndrome, endometriosis, and reduced sperm count), alteration of the gut biome and resultant dysfunction, and metabolic disorders apart from diagnosable diabetes.
The OIG report finds that EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP), which is responsible for testing all pesticide chemicals for endocrine-disrupting activity in humans, has failed to implement the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by the 1996 Food Quality Protection Act. In addition, the report states that OCSPP’s Office of Pesticide Programs (OPP) has not implemented a 2015 recommendation that 17 pesticides undergo additional testing as EDCs in wildlife so that an ecological risk assessment could be effectively conducted.
The report indicates that EPA has not created the tools necessary to implement the agency’s Endocrine Disruptor Screening Program (EDSP), created in 1998. The OIG report documents the repeated failures of EPA to meet deadlines set by Congress to develop and implement EDC testing. “In 1996, Congress directed the EPA to establish the EDSP, and the program received approximately $7.5 million in funding in fiscal year 2021. Yet, the EDSP can show only limited results. Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.”
The OIG statement that “some EPA staff indicated that they were instructed to function as if the EDSP was eliminated from the EPA’s budget” is consistent with those reported by Sharon Lerner in her The Intercept article, “Whistleblowers Expose Corruption in EPA Chemical Safety Office,” which showed not only laxity and managerial allegiance to industry interests, but also downright corruption on the part of some managers at EPA.
The OIG report issued a series of 10 recommendations that address:
- tiered testing for ED impacts
- timelines for such testing
- strategic planning
- development of performance metrics
- improved communication, including to the public
- internal program review
- improved transparency
Please ensure that your agency meets its responsibility to protect the health of people and wildlife.
Thank you.
