28
Aug
Study Finds Pesticide Product Labels Fail to Convey Toxic Effects to Consumers
(Beyond Pesticides, August 28, 2024) The U.S. Environmental Protection Agency’s (EPA) pesticide labeling requirements fail to adequately communicate acute toxicity levels to the public, as evidenced in a recent study of consumers published last month in the journal Nature. After evaluating whether the current three “signal” words (CAUTION, WARNING, DANGER) on pesticide products adequately convey pesticide toxicity, the authors conclude that current labeling may result in “unintended adverse effects” because it does not “effectively communicate toxicity risks to consumers.” The signal words on pesticide labels, based on laboratory animal testing for determining lethal doses, are intended to protect users of the product from exposure that can kill through inhalation, skin absorption, and ingestion of the pesticide. However, the signal words do not warn about long-effects like cancer, neurological diseases, reproductive harm, as well as other adverse effects associated with pesticide exposure. (See Pesticide-Induced Diseases Database.)
The study tests two prototype labels to evaluate the effectiveness of visual elements in communicating toxicity information, citing research in cognitive psychology that indicates visual elements, like images and graphics, are more effective for conveying information than text alone. This is particularly crucial for pesticide labels, where complex toxicity details need to be communicated quickly and clearly. The authors note that consumers are highly responsive to visual cues like colors and symbols, which capture their attention and influence purchasing decisions, especially regarding environmental and health concerns.
Methodology and Results.
To examine the efficacy of EPA’s label in conveying toxicity information to potential consumers, the researchers conduct an incentivized field experiment with eye tracking to evaluate the effectiveness of pesticide labels using signal words as compared to two alternative visual designs: traffic light colors and skull intensity symbols. Using a “between-subjects” design primarily examining the format of the label display, the study recruited 180 participants from the Southwest region of the United States through local newspaper ads and recruitment emails.
Participants in the study are presented with three tasks, each involving a series of 12 choices between two pesticides that differed only in their toxicity levels (HIGH, MEDIUM, LOW), but were otherwise identical. The price of the more toxic pesticide was fixed, while the price of the less toxic options decreased incrementally across the choices. This setup allowed the authors to estimate how much more participants were willing to pay to avoid higher toxicity.
The authors cite previous research that indicates that consumers’ awareness and understanding of pesticide risks significantly influences their behavior. In addition, the results support the notion that consumers are willing to pay a premium for less toxic alternatives when they understand the choice. For example, under the current “three-word system,” only 21% of participants indicate a willingness to pay an extra dollar for a “less toxic pesticide,” while under the traffic light system, 60% of consumers will choose to pay more. When the price of two pesticides is the same, 60% opt for the less toxic pesticide under the three-word system, as compared to 80% under the traffic signal system.
These results demonstrate that even a simple modification to EPA’s labeling requirements would lead to a significant change in consumer behavior. The authors conclude that incorporating graphic representations of toxicity in labeling can significantly assist in empowering consumers to make “more discerning decisions and minimize exposure to potentially hazardous chemicals in pesticides.” Advocates argue that the most effective way to protect themselves, their families, and the environment from the hazards posed by toxic pesticides is to eliminate their use, especially petrochemical pesticides, and fertilizers, in favor of organic methods.
However, perhaps of greater concern than the ineffectiveness of the label on safety is the highly criticized underlying statutory and regulatory standards that allow pesticides on the market. As Beyond Pesticides has noted, pesticides are registered and labeled based on data submitted by the manufacturer—not studies conducted or commissioned by EPA or discussed in the independent peer-reviewed scientific literature. The data submitted by the manufacturer, and not released to the public before initial product registration, is used by the agency to assess adverse effects of the pesticide, including impacts such as those on farmers and farmworkers, and to set allowable human dietary and non-dietary exposures.
Pesticide manufacturers are not required to provide toxicity data for all pesticide formulation ingredients. Additionally, EPA does not require manufacturers to disclose so-called “inert” (those not claimed to attack the target pest) or “other” ingredients, which are classified as “proprietary information” under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). FIFRA requires all pesticides distributed or sold in the U.S. to be registered by the EPA. Section 10(d)(1) [7 USC 126h], Protection of Trade Secrets and Other Information, of FIFRA states that it “does not authorize the disclosure of any information that—(C) discloses the identity or percentage quantity of any deliberately added inert ingredient of a pesticide, unless the Administrator has first determined that disclosure is necessary to protect against an unreasonable risk of injury to health or the environment.” Many of these “inert” ingredients that have been classified as hazardous under various laws, including the Clean Air Act, the Clean Water Act, and the Emergency Planning and Community Right to Know Act (EPCRA under Superfund Act) and the agency does not require testing data on the full formulation of a pesticide product, including inert ingredients (see here, here and here). Thus, data on the human health and environmental effects of the actual product on the market is entirely lacking—and not included on labels.
Beyond Pesticides previously reported on a 2000 report, The Secret Ingredients in Pesticides: Reducing the Risk, produced by the New York State Attorney General, that found 72 percent of pesticide products available to consumers contain over 95 percent inert ingredients and fewer than 10 percent of pesticide products list any inert ingredients on their labels. The report also found that more than 200 chemicals used as inert ingredients are hazardous pollutants in federal environmental statutes governing air and water quality, and, from a 1995 list of inert ingredients, 394 chemicals were listed as active ingredients in other pesticide products. For example, naphthalene is an inert ingredient in some products and listed as an active ingredient in others. See 2006 petition seeking disclosure of “inert” ingredients on pesticide product labels.
In evaluating allowed exposure and labeling of pesticides, EPA’s decisions rely on risk assessments that often adopt questionable exposure assumptions and overlook vulnerable groups, such as children and individuals with preexisting health conditions, including cancer, disruption of the endocrine system, and neurological disorders, which can be exacerbated by pesticide exposure. Amendments to FIFRA adopted in the 1996 Food Quality Protection Act, while creating requirements for evaluating cumulative dietary and nondietary exposure in determining label restrictions, have done little to curb overall reliance on toxic chemicals in agriculture and land management. It should be noted that the law does not include occupational exposure when determining acceptable cumulative exposure. Despite the rise of the $70 billion organic industry with third-party organic certification that proves food crops are successfully grown without reliance on synthetic pesticides and fertilizers, EPA still does not consider organic practices as a viable alternative when assessing the “reasonableness” or “acceptability” of pesticide risks, instead focusing on the acceptability of chemical risks in relation to other chemical alternatives.
The study authors’ recommendation that policymakers could impact consumer safety through ”a comprehensive shift” in labeling policies while addressing an important issue of EPA requirements for effective communication with consumers, does not address the inherent adverse impacts of toxic pesticides and the availability of nontoxic alternatives. A continued reliance on petrochemical pesticides perpetuates the trifecta of existential crises of human health threats, biodiversity collapse, and the climate emergency. In contrast is a precautionary approach—embodied in organic and regenerative organic land management practices. The existence, availability, and economic feasibility of alternative materials and practices, as demonstrated in organic management, is challenging the continued reliance on synthetic chemical pesticides. Environmental and health advocates argue that a truly protective strategy requires a transition from this chemical dependency to organic practices across food production, parks, playing fields, and all public spaces.
Beyond Pesticides aims to facilitate through our resources educating the public on pesticides’ adverse effects on human health, including through the Pesticide Illness and Disease Database (PIDD). For consumer resources on safer management of pests, including weeds and insects, see the Safer Choice page. See Tools for Change for a range of strategies, resources, and tips to initiate grassroots advocacy in your community, town, city, or state against pesticide use on lawns, public land, and agricultural lands. Beyond Pesticides established the Parks for a Sustainable Future program to assist with the transition to organic land management in communities across the U.S. The organization also strives to maintain the integrity of organic standards through Keeping Organic Strong campaign and historical work to transition agriculture to organic practices.
[For more information on the importance of eating organic food for you, farmworkers, and the environment, please see Beyond Pesticides’ Eating with a Conscience and Organic Agriculture webpages. For more background on deficiencies in farmworker protection, see Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety.]
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
Sources:
Improving consumer understanding of pesticide toxicity labels: experimental evidence, Nature Scientific Reports, July 27, 2024
Implementation of PRIA 5 Bilingual Labeling Requirements To Make Bilingual Pesticide Labeling Accessible to Farmworkers; Request for Comments, EPA Notice, June 20, 2023
