08
Jul
Take Action: Elimination of the Insecticide Is Both a Public Health and Ecosystem Issue
(Beyond Pesticides, July 8, 2024) Please submit comments by Wednesday, July 31, 2024. Acephate, an insecticide and member of the highly toxic organophosphate (OP) family, is so toxic that EPA is proposing to ban all uses except the systemic injection into trees. A comment period is open, and EPA is accepting comments through Wednesday, July 31, after extending the earlier July deadline. With this remaining use, EPA is still not recognizing that systemic neonicotinoid pesticides can cause serious environmental harm to the ecosystem through indiscriminate poisoning of organisms.
EPA proposes to cancel all uses of acephate other than tree injection to eliminate all risks of concern it has identified that exceed its level of concern for dietary/drinking water risk, residential and occupational risks, and risks to non-target organisms. As Beyond Pesticides points out, although the tree injection method does not pose excessive dietary or aggregate health risk and does not pose any untoward occupational or post-application human health risks of concern, there are significant ecological risks posed that the agency has neglected. Rather than assessing the ecological risks of tree injection uses, the agency assumes that the use does not pose significant risk to nontarget organisms. On the contrary, the tree injection uses do pose serious risks to pollinator and certain bird species that cannot be mitigated and should therefore be included in the acephate cancellations.
In tree injection, the pesticide is injected directly into a tree trunk where it is taken up quickly by the vascular system and distributed. Because acephate and its degradate methamidophos are very soluble and systemic insecticides, the chemical is transported to all parts of the tree—including pollen, sap, resin, leaves, etc. Honey bees and certain bird species such as hummingbirds, woodpeckers, sapsuckers, tree creepers, nuthatches, chickadees, etc. can be exposed to residues within acephate-injected trees. Honey bees are exposed not only by collecting contaminated pollen, but more so from collecting sap and resins used for producing hive-important propolis. Similarly, birds are exposed to toxic acephate/methamidophos residues when feeding on contaminated tree sap, wood-boring insects/larvae, and leaf-chewing insects/larvae.Â
Although it has limited data, EPA has determined that acephate uses may present risks of concern to honey bees. However, the full suite of pollinator studies has not yet been submitted for acephate or methamidophos; therefore, no adult acute oral, chronic toxicity data or larval toxicity data are available for honey bees. These data gaps represent significant uncertainties for the assessment of the impact of acephate on pollinators as sensitivity may vary according to life stage and length of exposure (adult vs. larval and acute vs. chronic, respectively). Adverse incidents with probable and highly probable causality, including bee kills, have been associated with acephate and/or methamidophos exposure to honey bees. It is reasonable to presume that tree injection application of acephate does not attenuate the risk to honey bees compared to foliar treatment and, given the higher dosage per tree from injection, may actually increase exposure and therefore toxic risk. The agency proposes a pollinator hazard statement for the tree injection uses stating, “This product is highly toxic to bees.†This label statement is totally insufficient to protect bees and other organisms or to communicate the seriousness of the risk.Â
The risks of acephate use and the tree injection method specifically have not yet been fully evaluated for threatened and endangered species. EPA must complete its listed species assessment and any necessary consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service before completing the acephate registration review, paying careful attention to listed avian and insect species using trees subject to injection use for feeding, forage, and nesting.Â
The agency completed a weight-of-evidence endocrine disruptor analysis for acephate in 2015, which concluded that no further data to assess the potential for impacts on the estrogen, androgen, or thyroid pathways are needed for humans or wildlife. However, more recent information suggests the endocrine disrupting potential for acephate and its degradate methamidophos through non-receptor-mediated pathways may be of concern, so EPA should update its assessment on the endocrine disruption risks for acephate.Â
Moreover, EPA concludes in its benefits assessment that the tree injection use of acephate generally provides low pest management benefits because several effective alternatives are available for most insect pests. Therefore, from a risk-benefit standpoint the high risk to bees and birds from acephate tree injection treatments are unreasonable.
Despite prioritizing review of OP pesticides, EPA has failed to take action to protect those most exposed and most vulnerable to their neurotoxic effects—farmworkers and children. In 2021, Earthjustice and others petitioned EPA to cancel the registrations of these highly neurotoxic pesticides. This spring, Consumer Reports’ (CR) most comprehensive investigation ever of pesticides in produce found that exposure to two broad classes of chemicals—organophosphates and carbamates—are the most hazardous, linked to an increased risk of cancer, diabetes and cardiovascular disease. Based on those findings, CR petitioned EPA to “ban these classes of pesticides from use on fruit and vegetables.â€Â
In addition to the issues identified above, EPA fails to consider endocrine disruption. EPA also fails to consider vulnerable population groups, exposure to mixtures, and synergistic interactions in setting allowable food residues. In addition, pesticides contaminate our water and air, hurt biodiversity, harm farmworkers, and kill bees, birds, fish, and other wildlife. Â
Notably, USDA certified organic food products are not permitted to be produced with toxic pesticides. Pesticide residues found in organic products, with rare exception, are a result of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. Not only is the production of organic food better for human health and the environment than chemical-intensive production, but emerging science reveals also what organic advocates have been saying for a long time—in addition to lacking the toxic residues of conventional foods, organic food is more nutritious and it does not poison the people and contaminate the communities where the food is grown. 
A study published by The Organic Center reveals that organic food is higher in certain key areas, such as total antioxidant capacity, total polyphenols, and two key flavonoids, quercetin and kaempferol, all of which are nutritionally beneficial. Another study published in the Journal of Agricultural Food Chemistry looks specifically at the total phenolic content of marionberries, strawberries, and corn, and found that organically grown products contain higher total phenolics. Phenolics are important for plant health (defense against insects and diseases), and human health for their “potent antioxidant activity and wide range of pharmacologic properties, including anticancer, antioxidant, and platelet aggregation inhibition activity.â€â€¯â€¯Â
In view of the advantages of organic production, EPA must use organic production as the yardstick when weighing risks and benefits of pesticides. No pesticide should be allowed to be used if the crop can be produced organically. 
>> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
