23
Aug
Tell EPA Misleading Biopesticide Classification Must Be Redefined
(Beyond Pesticides, August 23, 2021) “Biopesticides”—widely regarded as an alternative to chemical pesticides and hence given a special status in regulation—need a better definition. “Biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term can be misleading and mixes contradictory approaches. It is troublesome when we continue to look for product replacements or substitutions for agricultural practices that are clearly ineffective, and in the process avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions.
The U.S. Environmental Protection Agency (EPA) uses the following definition for “biopesticides”:
- Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals);
- Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient;
- Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce.
EPA requires much less data to register a biopesticide and registers it in much less time. There are currently 390 biochemical and microbial active ingredients registered as biopesticides and 34 PIP active ingredients. In effect, EPA encourages their use by regulating them less stringently, characterizing them in the following ways: (i) they are “usually inherently less toxic,” (ii) that they “generally affect only the target pest and closely related organisms,” (iii) that they “often are effective in very small quantities and often decompose quickly,” and (iv) that “used as a component of Integrated Pest Management (IPM) programs, biopesticides can greatly reduce the use of conventional pesticides” [emphasis added]. The broad category “biopesticides” and waffle words used by EPA reflect hidden hazards.
For example, PIPs are certain to result in pesticide resistance because they are incorporated into plant tissue, thus exposing insects to the pesticide regardless of whether the plant is under serious attack. These certainly should not be part of IPM because their use is prophylactic. The vast majority of PIPs incorporate Bacillus thuringiensis, which has resulted in widespread resistance to a relatively innocuous biological insecticide, making it unusable as a rescue treatment. PIPs occur throughout the plant, resulting in broad exposure—principally to livestock, but sometimes to humans—to not only the active ingredient, but the “genetic material necessary for its production.” Little is known about the persistence of these genetic bits in the environment, nor what their impacts on ecosystems might be.
With less data required, we have less information concerning potential hazards of biopesticides. Besides genetically engineered organisms, these include synthetic analogues of naturally occurring biochemicals. Synthetic pheromones have effects on human health that depend on the application method, “inert ingredients,” and retrieval/disposal. In addition, only a small fraction of known insect pheromones (which have effects that are mimicked by commercially available synthetic pheromones) have been thoroughly examined for their toxic or other pharmacological effects on non-target (including mammalian) species. Pheromones as used in pest management are synthetic analogs of parts of the pheromones found in nature. Because they lack the complexity of natural pheromones, they also lack the specificity of those pheromones. Thus, some pheromone products designed to disrupt the mating of pest insects can affect the behavior of many non-pests. In addition, microencapsulated pheromones may be a hazard to honeybees.
Some bioprotectant products may be ecologically sound and nontoxic; indeed, some fungi appear to hold great promise. Despite the lack of specificity, pheromone products have permitted growers to avoid the use of more toxic controls. They can be used in a way that complements alternative pest management methods, but synthetic analogs must be fully tested.
Letter to EPA Administrator Michael Regan
“Biopesticides” are widely regarded as an alternative to chemical pesticides and hence given a special status in regulation. However, “biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term is misleading in that it does not, as defined by EPA or others, denote a group of materials that naturally produced. It is also troublesome to encourage product replacements or substitutions and, in the process, avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions.
The U.S. Environmental Protection Agency (EPA) includes as “biopesticides”:
1) Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals);
2) Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient;
3) Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce.
EPA requires much less data and time to register a biopesticide. In effect, EPA encourages their use by regulating them less stringently, characterizing them in the following ways: (i) they are “usually inherently less toxic,” (ii) that they “generally affect only the target pest and closely related organisms,” (iii) that they “often are effective in very small quantities and often decompose quickly,” and (iv) that “used as a component of Integrated Pest Management (IPM) programs, biopesticides can greatly reduce the use of conventional pesticides.” The broad category “biopesticides” and waffle words used by EPA reflect hidden hazards.
For example, PIPs are certain to result in pesticide resistance because they are incorporated into plant tissue, thus exposing insects to the pesticide regardless of whether the plant is under serious attack. These certainly should not be part of IPM because their use is prophylactic. The use of PIPs incorporating Bacillus thuringiensis has resulted in widespread resistance to a relatively innocuous biological insecticide, making it unusable as a rescue treatment. PIPs occur throughout the plant, resulting in broad exposure—principally to livestock, but sometimes to humans—to not only the active ingredient, but the “genetic material necessary for its production.” Little is known about the persistence of these genetic bits in the environment, nor what their impacts on ecosystems might be.
With less data required, we have less information concerning potential hazards of biopesticides. Besides genetically engineered organisms, these include synthetic analogs of naturally occurring biochemicals. Only a small fraction of known insect pheromones (or the synthetic analogs in commercially available synthetic pheromones) have been thoroughly examined for their toxic or other pharmacological effects on non-target species. Pheromones as used in pest management lack the complexity and specificity of natural pheromones. Thus, some pheromone products designed to disrupt the mating of pest insects can affect the behavior of many non-pests. In addition, microencapsulated pheromones may be a hazard to honeybees.
Some bioprotectant products may be ecologically sound and nontoxic. Indeed, some fungi appear to hold great promise. Despite the lack of specificity, pheromone products have permitted growers to avoid the use of more toxic controls and can complement alternative pest management methods, but synthetic analogs must be fully tested.
It’s time for EPA to redefine “biopesticide.” It is deceptive and misleading. The definition should not include genetically modified organisms or synthetic analogs of naturally occurring biochemicals.
Thank you.
