08
Jan
Commentary: We Can and Must Stop Antibiotic Pesticide Use in the Interest of Public Health Worldwide
(Beyond Pesticides, January 8, 2024) Despite successful litigation that stopped the unnecessary use of an antibiotic (streptomycin) in citrus production in December 2023, the court’s reasoning fails to grasp the science behind the biggest emerging threat to U.S. and global health—antibiotic resistance. What is most disturbing and challenging is that the U.S. Environmental Protection Agency (EPA), responsible for applying science in the protection of the public’s health, misled the court on the overwhelming worldwide scientific consensus on the contribution of agricultural antibiotic use to the human death and disability rate linked to antibiotic resistance. On this subject, Beyond Pesticides has written extensively about horizontal gene transfer, which explains the movement of antibiotic resistant bacteria throughout the environment, ultimately making their way to people, as medically necessary drugs become ineffective. As we’ve written, “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.”
[Regarding the reliance of the court on EPA’s misrepresentation of the science, the court found, ”EPA emphasized that ‘there is no data that antibiotic use in agriculture leads to the presence of antibiotic resistance in bacteria of human health concern,’ and that ‘[a]t the present time, there is little evidence for or against the presence of microbes of human health concern in the plant agricultural environment.'” And yet, on May 19, 2019, The New York Times reported, “The agency [EPA] approved the expanded use [of streptomycin] despite strenuous objections from the Food and Drug Administration and the Centers for Disease Control and Prevention, which warn that the heavy use of antimicrobial drugs in agriculture could spur germs to mutate so they become resistant to the drugs, threatening the lives of millions of people.”]
Tell EPA and Congress that antibiotic pesticides must be eliminated.
We like victories, so let’s soak up the victory of the court decision and the protection it affords farmworkers in the short-term. Of note is the court finding, for procedural reasons, that EPA review of direct streptomycin exposure to pollinators “does not pass muster.” We have always said that when we protect pollinators and ecosystems, we protect people. But, now we must urgently zero in on how the nation’s pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), and the chemical-intensive agricultural practices it effectively promotes, is contributing to what can already be considered a worldwide pandemic. Yes, antibiotic resistance is another pandemic that some call the “silent pandemic,” but the numbers belie that characterization.
Let’s look at the numbers and the threat and then ask ourselves whether our federal agencies should be doing everything they can, from every perspective, to take action. It certainly is true that there is a confluence of factors that contribute to this worldwide pandemic, which will be the focus of a United Nations General Assembly (UNGA) High-Level meeting on antimicrobial (e.g. bacterial and fungal) resistance (AMR) in September, 2024 in New York. However, we cannot afford to ignore any cause of resistance, given the health implications of ineffective treatments for bacterial and fungal diseases. While there are many statistics with a range of numbers that we cite, according to the Centers for Disease Control and Prevention (CDC), “More than 2.8 million antimicrobial-resistant infections occur in the U.S. each year, and more than 35,000 people die as a result. When Clostridioides difficile—a bacterium that is not typically resistant but can cause deadly diarrhea is associated with antibiotic use—is added to these, the U.S. toll of all the threats in the report exceeds 3 million infections and 48,000 deaths.” According to a 2021 article in Current Research in Microbial Sciences, “Antibiotic resistance in agriculture: Perspectives on upcoming strategies to overcome upsurge in resistance,” the leading consumers of antibiotics in developed countries are U.S. consumers. So, it would appear that the U.S. population may have the most to lose from antibiotic resistance.
A report evaluating 204 countries published by the University of Washington’s Institute of Health Metrics and Evaluation, “Global burden of bacterial antimicrobial resistance in 2019: a systematic analysis,” generated the following statistics:
13.66 million people who died globally had sepsis as an immediate cause of death or in the chain of events leading to their death (intermediate cause).
4.95 million people who died in 2019 suffered from drug-resistant infections, such as lower respiratory, bloodstream, and intra-abdominal infections.
1.27 million deaths in 2019 were directly caused by AMR [antimicrobial resistance].
1 in 5 people who died from AMR was a child under 5 years old, often from previously treatable infections.
For those who prefer to talk about public health in economic terms, according to the Food and Agriculture Organization of the U.N., the Global Research on Antimicrobial Resistance study found, “If action is not taken, the rise of AMR cumulatively may result in over 3.4 trillion USD loss in the world’s annual gross domestic product (GDP) in ten short years.
ReAct, an independent worldwide network focused on antibiotic resistance, founded in 2005, has characterized the problem from perspectives around the world.
ReAct Africa Director Mirfin Mpundu says:
“Addressing antibiotic resistance effectively will require big changes – to governance, financing, systems transformation and the change of behaviors and practices. But at the end of the day the end goal must be to ensure that everyone who has a resistant infection, or requires surgery, or needs cancer treatment, or is born premature can in fact access effective antibiotics in the future – this is the expectation that we should all voice to governments from now to September next year.”
ReAct Europe Director Anna Sjöblom says:
“The UNGA High-level meeting must be a turning point in the global response to AMR – and more specifically to antibiotic resistance. Enough with the talk of ‘a silent pandemic’ – antibiotic resistance is here now and is a global leading cause of suffering and unnecessary loss of lives across the world. The global response must finally start to reflect this fact.”
Ultimately, EPA must get out in front and start thinking and acting holistically in its analyses and restrictions of pesticides. The challenge of antimicrobial resistance is an example of the agency moving along with a limited focus that undermines the protection of the environment and people, as existential crises continue to emerge—whether it’s the chemical-induced or exacerbated human health crises, biodiversity collapse, or the climate emergency. Even under existing law, EPA has the opportunity and responsibility to deem the adverse effects associated with petrochemical pesticide use related to these existential crises “unreasonable” (the statutory standard under FIFRA), given the availability of alternative practices, principally organic land management, that are viable, accessible, productive, profitable, and, most importantly, enabling of a livable future.
Tell EPA and Congress that antibiotic pesticides must be eliminated.
Letter to EPA:
Antimicrobial resistance is rising to dangerously high levels. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” They continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”
A federal district court decision blocked EPA’s decision to register the antibiotic streptomycin for use in Florida citrus to control Huanglongbing (HLB), also known as “citrus greening,” a plant disease spread by the Asian citrus psyllid, finding, “[EPA] admits it did not comply with the ESA.” The court also found that EPA failed to show that streptomycin would achieve benefits in preventing the disease. However, the court was not convinced that EPA fails to protect against the spread of antibiotic resistance and assumed that the restrictions that EPA required for personal protective equipment (PPE) and drift control would adequately mitigate risks.
When antimicrobial pesticides are sprayed on a crop, they induce resistance in bacteria that are present by killing susceptible bacteria—which may or may not be pathogenic—allowing resistant bacteria to proliferate. The resistant bacteria move off the site on crops, workers, and the wind. Prevention of chemical drift is thus inadequate to protect against the spread of antibiotic resistant bacteria. The fact of horizontal gene transfer means that antibiotic resistance genes in those (possibly harmless) bacteria can move to pathogens.
In 2017, EPA permitted use of these antibiotics in Florida citrus crops. In January 2019, EPA moved to make the authorization permanent, despite, according to the New York Times, “strenuous objections from the Food and Drug Administration and the Centers for Disease Control and Prevention, which warn that the heavy use of antimicrobial drugs in agriculture could spur germs to mutate so they become resistant to the drugs, threatening the lives of millions of people.” Two years prior oxytetracycline was approved for use on the same citrus crops.
In addition to crops, antimicrobials are used to manage synthetic turf. A builder of sports facilities, American Athletic, states, “Beyond surface cleaning, the artificial turf should be sanitized weekly or monthly to protect the players’ and coaches’ health. This disinfection requires special solvents, cleansers, and antimicrobial products to remove invisible particles and bacterial growth. You should strive to sanitize the field after every game and throughout the school day if it’s used for physical education classes.”
Finally, focusing on materials sold as antibiotics or antimicrobials is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens. Thus, we must stop broadcasting pesticides in the environment. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides had been disseminated in the environment for decades.
EPA must not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and must cancel the registration of those that do.
Thank you.
Letter to U.S. Representative and Senators:
Antibiotic resistance is rising to dangerously high levels. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” They continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”
A federal district court decision blocked EPA’s decision to register the antibiotic streptomycin for use in Florida citrus to control Huanglongbing (HLB), also known as “citrus greening,” a plant disease spread by the Asian citrus psyllid, citing failure to comply with the ESA and to show benefits. However, the court was not convinced that EPA fails to protect against the spread of antibiotic resistance and assumed that the restrictions that EPA required for personal protective equipment (PPE) and drift control would adequately mitigate risks.
When antimicrobial pesticides are sprayed on a crop, they induce antimicrobial resistance in bacteria that are present by killing susceptible bacteria—which may or may not be pathogenic—allowing resistant bacteria to proliferate. The resistant bacteria move off the site on crops, workers, and the wind. Prevention of chemical drift is thus inadequate to protect against the spread of antibiotic resistant bacteria. The fact of horizontal gene transfer means that antibiotic resistance genes in those (possibly harmless) bacteria can move to pathogens.
In 2017, EPA permitted expanding use of these antibiotics in Florida citrus crops. In January 2019, EPA moved to make the authorization permanent, despite, according to the New York Times, “strenuous objections from the Food and Drug Administration and the Centers for Disease Control and Prevention, which warn that the heavy use of antimicrobial drugs in agriculture could spur germs to mutate so they become resistant to the drugs, threatening the lives of millions of people.” Two years prior oxytetracycline was approved for use on the same citrus crops.
In addition to crops, antimicrobials are used to manage synthetic turf. A builder of sports facilities, American Athletic, states, “Beyond surface cleaning, the artificial turf should be sanitized weekly or monthly to protect the players’ and coaches’ health. This disinfection requires special solvents, cleansers, and anti-microbial products to remove invisible particles and bacterial growth. You should strive to sanitize the field after every game and throughout the school day if it’s used for physical education classes.”
Finally, focusing on materials sold as antibiotics or antimicrobials is too shortsighted. First, science shows that use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens. Thus, we must stop broadcasting pesticides in the environment. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides had been disseminated in the environment for decades.
Please ensure EPA does not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and cancels the registration of those that do.
Thank you.
