02
Jan
Commentary: New Year Calls for Transformational Change Starting with Chemical Use Rejection
(Beyond Pesticides, January 2, 2024) [photo credit: Alessandro Marongui, Bhopal Medical Appeal, Bhopal, 2009] The new year begins with numerous critical decisions before the U.S. Environmental Protection Agency (EPA) and its Office of Pesticide Programs, along with other federal agencies and the U.S. Congress, that determine whether the agency will continue to erode its leadership position in meeting the existential crises that threaten health, biodiversity, and climate. Given these crises, EPA under its current authority could take the action necessary to advance a transition away from the use of petrochemical pesticides, since under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) the hazards associated with pesticides are “unreasonableâ€â€”given the availability and viability of organic systems that do not utilize toxic pesticides.
As EPA fails to meet the catastrophic environmental and health challenges of the day, communities and states across the U.S. are increasingly exercising their authority to restrict pesticides more stringently than the federal government. FIFRA, as affirmed by the U.S. Supreme Court in Wisconsin Public Intervenor v. Mortier (1991), does not prohibit or preempt local municipalities from adopting more stringent pesticide restrictions throughout their jurisdictions than the federal government. The U.S. Congress over the next several weeks will continue debating the inclusion in the Farm Bill statutory language that will preempt local authority.
One of the more outrageous proposals now under consideration by EPA is a chemical industry proposal to register the use of the highly neurotoxic, carbamate, insecticide aldicarb on citrus. While the adverse impact of pesticides often remains hidden from public view, especially in communities where pesticides are produced or used, the catastrophic explosion involving the chemical used in aldicarb production cannot be ignored. Forty years ago this year (December 1984), a Union Carbide plant in Bhopal, India released a cloud of highly toxic methyl isocyanate (MIC) gas, the precursor chemical used in carbamate manufacture, in the middle of the night, killing thousands of people immediately—estimates range from 1,754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic disease range up to 95% of the affected population of 531,881. Continuing research released this year (June 2023) has found that fetuses in the womb during the disaster exhibited lower birth weights and remained more susceptible to respiratory problems, cognitive impairments, and other health issues later in life. Moreover, those born just after the gas leak were found to have lower educational attainment and reduced earning potential as adults. (For background on the Bhopal explosion and immediate and long-term effects, see Daily News.)
In 2021, the use of aldicarb on citrus was rejected  by the Florida Department of Agriculture and Consumer Services (April 2021) and the U.S. Court of Appeals (June 2021). Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category. Over 100 countries have banned aldicarb under the Rotterdam Convention, an international agreement on toxic chemicals that the United States has signed but not ratified.   Â
Less than a year after the Bhopal tragedy, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV. This time, at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA. A tank car ruptured, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River. Several hundred people were hospitalized after inhaling fumes. The chemical causes birth defects and fetal death and is a known mutagen, so the total impact on human health is unknown. However, the chemical sterilized a 41-mile stretch of the river, killing over a million fish and thousands of trees. Such events are not in the distant past, as shown by the derailment of about 50 out of 141 cars on the Norfolk Southern train that exploded in a towering fireball over the town of East Palestine, OH in February 2023. Among the compounds on board those cars were “inert†pesticide ingredients (vinyl chloride, ethylhexyl acrylate, and isobutylene), an antimicrobial compound (ethylene glycol monobutyl ether [EGBE]), benzene (a carcinogenic solvent), and butyl acrylate. In 2022, train accidents resulted in releases of hazardous chemicals 11 times.
These examples of injuries to humans and the environment show that the harm caused by pesticides goes far beyond the impacts to consumers, farmworkers, other organisms, air, water, and soil caused by the application of those poisons, which are also extensive. We are all potentially affected. In some cases—including aldicarb—the damages caused by use alone have been shown many times to be, in the words of FIFRA, “unreasonable adverse effects.â€
In fact, no pesticide epitomizes the “cradle-to-grave†dangers of pesticides better than aldicarb. In short, it is a suspected endocrine disruptor and is linked to neurotoxic and reproductive effects, asthma, and learning behavior problems. It has been detected in groundwater, is a potential leacher, and is toxic to birds and fish/aquatic organisms. In use, it has been implicated in poisoning of workers and their children, poisoning deer and other game consuming contaminated seeds, and notably, poisoning food grown in soil treated with the chemical. The effects don’t stop there—aldicarb is also notorious for contaminating groundwater.Â
Aldicarb may persist in groundwater for decades due to its long half-life between 200 to 2,000 days, and ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Furthermore, aldicarb is a systemic pesticide that plant roots and leaves readily uptake, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees. Evidence demonstrates that past use of the aldicarb product Temik 15G on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation.
Organic growers know that soil biology and soil health is important to protection from diseases like citrus greening. The use of aldicarb, on the other hand, destroys healthy soil biota.
This revival of consideration of aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions. See the Daily News of December 14, 2023 for more about aldicarb.
EPA must not revive the use of aldicarb, which is responsible for so much death and destruction, beginning with its manufacture and continuing through its use.
Letter to EPA:
Thirty-nine years ago last month, a Union Carbide plant in Bhopal, India released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic disease range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. In spite of this history and the many adverse effects of aldicarb, EPA is now considering reviving the pesticide’s use.
Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert†pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate.
Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. In fact, no pesticide epitomizes the “cradle-to-grave†dangers of pesticides better than aldicarb. It is a suspected endocrine disruptor, linked to neurotoxic and reproductive effects, asthma, and learning behavior problems. It has been detected in groundwater, is a potential leacher, and is toxic to birds and fish/aquatic organisms. It is a systemic pesticide readily taken up by plant roots and leaves, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees.
It has been implicated in poisoning of workers and their children, game consuming contaminated seeds, and notably, food grown in soil treated with the chemical. Aldicarb is also notorious for contaminating groundwater, where it may persist for decades due to its long half-life between 200 to 2,000 days. Ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Aldicarb is a highly toxic, systemic carbamate insecticide banned by over 100 countries under the Rotterdam Convention. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category.
Evidence demonstrates that past use of aldicarb on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. In 2017 and 2018, the Florida Department of Agriculture denied “Special Local Needs†approval for use on Florida citrus because the registrant was unable to demonstrate that aldicarb is safer than alternatives.
Organic growers know that soil biology and soil health are important to protection from diseases like citrus greening. The use of aldicarb, on the other hand, destroys healthy soil biota.
I am appalled that despite previous cancellations due to unreasonable adverse effects, particularly on the health of children, EPA is now considering approving the use of aldicarb for use on Florida oranges and grapefruits. This reconsideration of aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.
EPA must not revive the use of aldicarb, which is responsible for so much death and destruction, beginning with its manufacture and continuing through its use.
Thank you.
Letter to U.S. Senators and Representative:
Thirty-nine years ago last month, a Union Carbide plant in Bhopal, India released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic disease range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. In spite of this history and the many adverse effects of aldicarb, the Environmental Protection Agency (EPA) is now considering reviving the pesticide’s use.
Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert†pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate.
Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. In fact, no pesticide epitomizes the “cradle-to-grave†dangers of pesticides better than aldicarb. It is a suspected endocrine disruptor, linked to neurotoxic and reproductive effects, asthma, and learning behavior problems. It has been detected in groundwater, is a potential leacher, and is toxic to birds and fish/aquatic organisms. It is a systemic pesticide readily taken up by plant roots and leaves, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees.
Aldicarb has been implicated in poisoning of workers and their children, game consuming contaminated seeds, and notably, food grown in soil treated with the chemical. It is also notorious for contaminating groundwater, where it may persist for decades due to its long half-life between 200 to 2,000 days. Ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Aldicarb is a highly toxic, systemic insecticide banned by over 100 countries under the Rotterdam Convention. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category.
Evidence demonstrates that past use of aldicarb on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. In 2017 and 2018, the Florida Department of Agriculture denied “Special Local Needs†approval for use on Florida citrus because the registrant was unable to demonstrate that aldicarb is safer than alternatives.
Organic growers know that soil biology and soil health are important to protection from diseases like citrus greening. The use of aldicarb, on the other hand, destroys healthy soil biota.
I am appalled that despite previous cancellations due to unreasonable adverse effects, particularly on the health of children, EPA is now considering approving the use of aldicarb for use on Florida oranges and grapefruits. This reconsideration of aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.
Please ensure that EPA does not revive the use of aldicarb, which is responsible for so much death and destruction, beginning with its manufacture and continuing through its use.
Thank you.
