05
Aug
Beyond Pesticides Calls for EPA To Stop Involuntary Exposure to Pesticides from Chemical Trespass
(Beyond Pesticides, August 5, 2024) As the longstanding problem of involuntary pesticide exposure through chemical drift continues unabated, EPA announced “new, earlier protections” that are being criticized by Beyond Pesticides as inadequate. The organization is calling on the public to let EPA and Congress know that it must comprehensively eliminate nontarget chemical trespass. Beyond Pesticides notes that the recent EPA announcement does not stop the movement of pesticides off the target sites restricted by pesticide product labels and therefore does not protect the public and environment in agricultural, rural, suburban, and urban areas from resulting health and ecological threats.
EPA’s July 15, 2024, press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift” states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”
>> Tell EPA and Congress that EPA must protect against all forms of pesticide drift.
Pesticide drift—more properly designated “chemical trespass”—is a threat to people living in agricultural, rural, suburban, and urban areas, as toxic chemicals move off the treated target site. While drift is a major exposure threat wherever pesticides are being used outdoors—from lawns, gardens, parks, playing fields, rights-of-way, to agricultural fields—pesticide drift is a major threat to those living near treated areas, as wind and rain can carry these chemicals miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to anyone in the application area or working and/or living near treated areas.
Included among those at high risk from drift are families of farmworkers who live near agricultural parcels. Schools, playgrounds, recreational fields, and other facilities at which children are frequent visitors, have been affected by pesticide drift—all the more concerning because children have elevated vulnerability to chemicals, given their sizes and developmental stages. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Another study finds that children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia.
Two participants in a Beyond Pesticides’ 2021 National Pesticide Forum session titled “Fighting Chemical Trespass,” were organic farmers who could not sell their then-contaminated crops as organic, and one of them could not sell them at all because the compounds that were sprayed are illegal for use on food crops. That same farmer, formerly in robust health, has suffered serious chronic health consequences, is now legally disabled, and has acquired $100,000 in medical debt as a result of the chemical poisoning she endured across multiple incidents.
One of the farmers summarized that, as an organic producer, he has huge concerns about such chemical trespass—for the safety of the food he produces, for farmworker safety and health, for the health and integrity of pollinators and other organisms, and the surrounding environment, and of course, economic issues of lost production and income. Towering over the immediate financial concerns is that, once contaminated, a USDA (U.S. Department of Agriculture) Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation.
That same farmer contends that reform of drift policy at the state level—currently a kaleidoscope of varying, or no, regulations—is critical. He also suggests that organic farmers, in particular, secure personal liability insurance for any health/medical debt they might incur as the result of a drift or spray incident.
Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency’s efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers’ “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act (ESA) for protecting endangered species and their habitats amid an unprecedented rate of global extinction is called into question.
A major problem with EPA’s efforts to address drift is the agency’s exclusion of vapor drift. Mitigation measures—such as buffer zones—designed to reduce the movement of droplets or dust are inadequate to address pesticides that move much further as vapors after volatilizing from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders.
Furthermore, EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, “The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review.” Why would one assume a lower-than-labeled rate anywhere in the treated area?
When pest management strategies rely on spray and dust pesticide application, drift is inevitable. Aerial pesticide application is of greatest concern, where an estimated 40% of pesticides used are lost to drift. Inert (nondisclosed) ingredients—amines—that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology. Amines are often added to herbicide formulations for glyphosate, dicamba, and 2,4-D products to increase solubility and reduce volatilization. While in theory, amines reduce volatilization by forming herbicide-amine salts that lock the herbicide vapors in place, the researchers found evidence that even new forms of dicamba billed by the agrichemical industry as “low volatility,” and restricted to formulations that include very specific amines, continued to cause drift problems for farmers.
From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming, it is simply ignored or not realistically restricted. These adverse effects are “unreasonable” because of an alternative—an organic production system—that does not harm human health, other species, or ecosystems and, in addition, helps to mitigate climate change. In its registration decisions, EPA must use organic production as a yardstick, denying any use for which organic production and land management is successful.
>> Tell EPA and Congress that EPA must protect against all forms of pesticide drift.
Letter to EPA:
EPA’s press release says, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift.” Yet EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”
Pesticide drift (chemical trespass) is a major threat to those living in agricultural, rural, suburban, and urban areas, as chemicals are carried by air and water miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to anyone working or living nearby. Among those at highest risk are farmworker families who live near farms. Children, who are more vulnerable to chemicals, use schools, playgrounds, and recreational fields that are subject to drift. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Additionally, children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia.
Also affected are organic farmers who cannot sell their contaminated crops as organic or cannot not sell them at all because the compounds that were sprayed are illegal for use on food crops. Organic farmers have huge concerns about such chemical trespass—for the safety of the food they produce, farmworker safety and health, the health and integrity of pollinators and biodiversity, and lost production and income. Once contaminated, a USDA Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation.
Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to its Draft Herbicide Strategy Framework, weakening ”protections” for endangered species from herbicide use. By reducing the stringency of the strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act amid an unprecedented rate of global extinction is called into question.
EPA’s failure to consider vapor drift is a major problem. Measures—such as buffer zones—designed to reduce movement of droplets or dust are inadequate in controlling vapors that move far from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders.
EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, “The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review.” Why would one assume a lower than labeled rate anywhere in the treated area?
When pest management strategies rely on spray and dust pesticide application, drift is inevitable. An estimated 40% of pesticides applied by air are lost to drift. Amines that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology.
From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming. The harm from drift is unreasonable given the alternative—an organic production system—that does not harm human health, other species, or ecosystems and helps to mitigate climate change. In the registration of toxic pesticides, EPA must recognize that successful organic land management eliminates the harm and uncertainties associated with drift.
Thank you.
Letter to U.S. Representative and Senators:
EPA issued a press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift.” Yet it states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.”
Pesticide drift (chemical trespass) is a major threat to those living near in agricultural, rural, suburban, and urban areas, as chemicals are carried by air and water miles from the application site. Pesticide drift can cause acute poisoning and/or chronic health impacts to those living or working nearby. Among those at highest risk are farmworker families who live near farms. Children, who are more vulnerable to chemicals, use schools, playgrounds, and recreational fields that are subject to drift. A National Cancer Institute study shows that pregnant women living within nine miles of farms where pesticides are used have an increased risk of losing an unborn baby to birth defects. Additionally, children living near agricultural areas have twice the risk of developing acute lymphoblastic leukemia.
Also affected are organic farmers who cannot sell their contaminated crops as organic or cannot not sell them at all because the compounds that were sprayed are illegal for use on food crops. Organic farmers have huge concerns about such chemical trespass—for the safety of the food they produce, farmworker safety and health, the health and integrity of pollinators and biodiversity, and lost production and income. Once contaminated, a USDA Certified Organic farm (or at least the affected parts) must exit the certification program for three years—a huge blow to a modest organic operation.
Pesticide drift also threatens biodiversity, and on April 16, 2024, EPA posted an “update” to its Draft Herbicide Strategy Framework, weakening ”protections” for endangered species from herbicide use. By reducing the stringency of the strategy, EPA’s commitment to fulfilling legal requirements under the Endangered Species Act amid an unprecedented rate of global extinction is called into question.
EPA’s failure to consider vapor drift is a major problem. Measures—such as buffer zones—designed to reduce movement of droplets or dust are inadequate n controlling vapors that move far from the target area. Furthermore, as gases, the vapors can be inhaled more deeply into the lungs of bystanders.
EPA’s assessment of drift hazard has been flawed by unwarranted assumptions, such as, “The highest residue expected at the edge of a treated area as a result of drift is the determined by multiplying 0.26 by the application rate for the scenario under review.” Why would one assume a lower than labeled rate anywhere in the treated area?
When pest management strategies rely on spray and dust pesticide application, drift is inevitable. An estimated 40% of pesticides applied by air are lost to drift. Amines that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research in Environmental Science and Technology.
From an economic perspective, drift—like other contamination—is an externality that is never calculated in the true cost of chemical-intensive farming. The harm from drift is unreasonable given thealternative—an organic production system—that does not harm human health, other species, or ecosystems and helps to mitigate climate change.
Please ensure that in its registration decisions, EPA recognizes that successful organic land management eliminates the harm and uncertainties associated with drift.
Thank you.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
