10
Feb
Four Pesticides Restricted to Protect Salmon, Thousands of Other Endangered Species Imperiled
(Beyond Pesticides, February 10, 2023) The U.S. Environmental Protection Agency (EPA) announced, on February 1, new measures to protect 28 endangered salmon species (including steelhead trout) from the use of four pesticides that threaten them and their critical habitats. Those compounds comprise three herbicides — metolachlor, bromoxynil, and prometryn, and one soil fumigant, 1,3-Dichloropropene. The protections, aimed at salmon populations in Washington, Oregon, and California, are meant to reduce impacts from pesticide runoff and spray drift, and to minimize potential “take.” (Under the Endangered Species Act (ESA), “take” means, essentially, the unintentional harming or killing of an individual of a protected species — in this case, harm or death from exposures to these toxic pesticide compounds.) Beyond Pesticides and other advocates have for years warned that multiple pesticides are threats to Northwest salmon and other species at risk. This EPA announcement is the second of two, recently, that offer slight redress to the agency’s historical failures to act (see more below).
Indeed, advocates have engaged in multiple litigation efforts over the years to try to force EPA to take action; EarthJustice in 2001 noted some early instances. As Chemical and Engineering News says pointedly, “Environmental groups, which have been suing the EPA for decades to protect endangered species from pesticides, say the new restrictions are long overdue. ‘But there are still more than 1,000 species that don’t have any protection against these four pesticides or hundreds of others that are devastating to imperiled species,’ Lori Ann Burd, environmental health program director at the Center for Biological Diversity, says in a statement. ‘The EPA needs to move quickly to ensure all species are protected from pesticides, before it’s too late.’”
Under the Endangered Species Act of 1973 (ESA) as it relates to pesticide use, EPA is required to consult with the U.S. Fish and Wildlife Service (FWS) or the National Marine Fisheries Service (NMFS) to determine whether a pesticide may adversely affect an ESA listed species (or its critical habitat). If that consultation indicates jeopardy for members of a species or that habitat, EPA must then generate protective regulations to limit use of the pesticide.
In the case of these four pesticides (metalochlor, bromoxynil, 1,3-D [aka telone], prometryn), the final EPA–NMFS finding was that these compounds were “likely to adversely affect” at least one member of the target populations. Although NMFS issued biological opinions in 2021 that “found that registered uses of these pesticides do not jeopardize listed salmon and steelhead species or adversely modify their critical habitats,” those opinions also set out measures to minimize the potential for “take” and any impacts thereof. EPA, sensibly, chose to act on the statutory requirements of ESA for these compounds.
The EPA announcement for the four pesticides describes geographically specific use limitations for them, and lists planned mitigation measures, such as no-spray buffers (between waterways and agricultural fields), retention ponds, and vegetated ditches — all intended to keep the pesticides from migrating into waterways. The new rules also amend labeling requirements (for the pesticides’ containers) that aim to increase education and compliance among applicators, including how to report any related ecological incidents associated with pesticide applications that are observed or experienced.
As Beyond Pesticides lists in its Gateway on Pesticide Hazards (a compendium of information on hundreds of pesticides), these four compounds share several features, chief among which is their toxicity to fish and aquatic organisms. In addition, three of the four are potentially carcinogenic; three likely cause endocrine disruption; all are sensitizers/irritants; three are detected in groundwater (metalochlor, frequently); and Beyond Pesticides rates all but prometryn as toxic.
Agricultural runoff and drift from pesticide applications — the two primary vectors for contamination of Northwest rivers and streams, and the coastal Pacific — are the central targets of the new EPA constraints on the use of the subject pesticides. Beyond Pesticides notes that the drift of pesticides from target application sites — even when applied according to label instructions — can travel significant distances and end up in waterways (as well as on nontarget soils, plants, and organisms). Pacific salmon species are exposed to the compounds in the fresh water ways where they hatch and develop, and to which — after maturing in ocean waters that may also harbor some of these chemical pollutants — they return to reproduce and then die. Not insignificantly for the food web, their decaying carcasses furnish nutrients back to the ecosystem, providing food for other members.
Studies have shown that well more than 100 wildlife species depend on salmon as food, according to the organization, American Rivers. In 2021, it wrote, “Let the salmon disappear, and you threaten the existence of all life up and down the food chain, including people, economies, and the Indigenous cultures that orbit these irreplaceable fish.” Many experts have noted a particular “food chain” threat represented by pesticide impacts on salmon — endangered salmon are the central prey of the iconic orca whales, found from Alaska to Washington to Oregon, and even sometimes off California. Dwindling salmon populations spell trouble for the orcas.
Yet some salmon species have been brought to the edge of extinction for want of effective and timely action on their exposures to a large menu of pesticides. Just last March, EPA finally — after a series of flip-flops and failures on regulating several organophosphate pesticides — released findings that reflected to some extent the risks of malathion, chlorpyrifos, and diazinon, and the need to ramp up protections. A revised EPA–NMFS biological opinion found that use of those compounds is likely to jeopardize some listed species and adversely modify some critical habitats, and recommended protective measures similar to those in the new rules on the subject pesticides.
Yes, this is welcome news. But, these mitigation measures will presumably be enacted under the assumption that they will manage sufficiently the exposures of salmon species to these toxic chemicals. Whether that proves true is, clearly, to be determined. Salmon populations through the coastal West will require critical monitoring in coming years to determine whether the measures are having protective effects; whether that happens also remains to be seen.
Beyond the specifics of these salmon species and these particular synthetic pesticides lies the central issue: EPA continues to allow, and non-organic producers and land managers continue to use aplenty, toxic chemicals that harm people, other organisms, and the environment. This decades-long deluge of the planet with pesticide (and other chemical) compounds represents — apart from the contributions of fossil fuels to the climate crisis — arguably the most extensive experiment ever conducted on Planet Earth. And it happens generally without participants’ knowledge, and virtually never with their permission. By any definition of “valuing life,” this is unconscionable.
Beyond Pesticide Executive Director Jay Feldman notes, “Again, EPA operates with the assumption that these chemicals are needed to achieve pest management goals. But, the agency has not asked the most basic question: is there another way to achieve pest management goals without toxic pesticides? Of course, the answer is ‘yes.’”
The solution is the broad transition to organic agricultural and land management systems that respect, mimic, and cooperate with natural systems. The shift to organic approaches would end the worldwide chemical experiment, and pull land management out of its current, entropic pattern, which is the antithesis of regenerative, organic approaches.
In December 2022, Beyond Pesticides wrote that its “bold goal is to transition off of synthetic, petroleum-based pesticides and fertilizers within the next decade, and transition to a society and world committed to organic practices. This will require massive public engagement — and, as Executive Director Jay Feldman says, ‘outrage’ — that we are not moving fast enough to embrace that goal. . . . Everyone — consumers, producers, advocates, legislative and executive government branches, federal and state agencies businesses, and others — has a part to play. We must advance, rapidly, on-the-ground work to make the transition to organic regenerative practices a mainstream expectation” — and a reality.
Please join this effort by becoming a member, signing up for action alerts, supporting this work, and/or organizing at the local or state level to advance organic. Contact us with questions, thoughts, or needs for assistance: [email protected] or 1.202.543.5450.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
