04
Dec
Ubiquitous Herbicide Glyphosate/Roundup Threatens Nearly All Endangered Species, Says EPA
(Beyond Pesticides, December 4, 2020) Amid the maelstrom of national political news related to the recent election, and the Trump administration’s upcoming exit, comes a release of the Environmental Protection Agency’s (EPA’s) draft biological evaluation (BE) of glyphosate. The assessment indicates that use of this ubiquitous herbicide likely threatens nearly every animal and plant species on the U.S. list of threatened and endangered species — 93% of them, in fact. Chemical and Engineering News reports that the EPA announcement was made public only a few days after the agency also reported that atrazine (another commonly used and toxic herbicide) probably harms more than half of those species. Given the Trump EPA’s eagerness, during the past four years, to serve industry interests rather than protect human health, biodiversity, and functional ecosystems, the timing of this released evaluation during the so-called “lame duck” period is puzzling.
Glyphosate is the active ingredient in many herbicides, including RoundupTM, Monsanto’s (now Bayer’s) ubiquitous and widely used weed killer; it is very commonly used with genetically modified companion seeds for a variety of staple crops, as well as for weed control on managed landscapes. These seeds are genetically engineered to be glyphosate tolerant. Glyphosate-based herbicides are the most widely used pesticides worldwide, and deliver human, biotic, and ecosystem harms.
The regulatory context for this biological evaluation is this: EPA is legally bound to review each registered pesticide every 15 years to see whether it continues to meet the FIFRA (The Federal Insecticide, Fungicide, and Rodenticide Act) standard for registration. Somewhat unbelievably, the re-registration review of glyphosate has been under way since 2009. During these 11 years, the herbicide has been the subject of massive public, advocacy, and regulator attention, much of it subsequent to both the 2015 declaration by the IARC (International Agency for Research on Cancer) that the compound is a likely human carcinogen, and several subsequent high-profile lawsuits against glyphosate’s makers when exposures caused non-Hodgkin lymphoma.
EPA has issued proposed interim decisions on glyphosate’s re-registration that have allowed these herbicides to remain on the market. In May 2019 the agency declared, ignoring broad scientific consensus, that glyphosate is “not likely to be carcinogenic to humans.” In January 2020, EPA issued a favorable interim review decision on reregistration, stating, “After a thorough review of the best available science, as required under the Federal Insecticide, Fungicide, and Rodenticide Act, EPA has concluded that there are no risks of concern to human health when glyphosate is used according to the label.”
Beyond Pesticides and other public health, conservation, and farmworker advocacy organizations brought suit against EPA in March 2020 for that interim approval. Common Dreams reported at the time on the top-level justification for the suit: “After a registration review process spanning over a decade, EPA allowed the continued marketing of the pesticide despite the agency’s failure to fully assess glyphosate’s hormone-disrupting potential or its effects on threatened and endangered species. The review began in 2009, has already taken 11 years, without a full assessment of the widespread harmful impacts on people and the environment in that time period.” More specifically, plaintiffs charged EPA with bias, ignoring and using incomplete scientific data, and delay in finishing “any assessment of [glyphosate’s] impacts on thousands of potentially harmed endangered species, delaying it until a future decision.”
Science policy analyst at the Center for Food Safety (one of the plaintiffs in the case), Bill Freese, said at the time: “Contrary to the Trump EPA’s claims, both regulatory and independent scientific studies demonstrate that glyphosate herbicides are carcinogenic and have adverse effects on internal organs. Far from consulting the ‘best available science,’ as EPA claims, the agency has relied almost entirely on Monsanto studies, cherry-picking the data that suits its purpose and dismissing the rest. EPA’s [interim] glyphosate decision shows the same hostility to science that we’ve come to expect from this administration, whether the issue is climate change or environmental health.” “EPA failed to consider if Roundup disrupts the balance of nature and ecosystem health, critical to the survival of a vast number of organisms on which life depends – from beneficial insects, such as parasitoid wasps, lacewings, ladybugs, and endangered bumblebees, monarch butterflies, to fish, small mammals, and amphibians,” said Jay Feldman, executive director of Beyond Pesticides, another plaintiff in the case.
As of the January 2020 interim decision, what remained to be completed before a final reregistration decision were evaluations of (1) the risks of glyphosate exposure to endangered species, and (2) screenings for endocrine system impacts. This biological evaluation goes to the first of those outstanding items. A BE is supposed to assess the potential risks to any listed species (as well as species that are proposed and candidates for listing) and to any critical habitat. The BE (1) assesses whether an individual of a listed species is reasonably expected to be exposed to a pesticide at a level that results in a discernable effect, and if so, (2) distinguishes effects that are likely to affect an individual of a species adversely from those that are not likely to do so. The categories of allowed determinations for (1) include NE (No Effect) and MA (May Affect). For species and habitats that receive an MA finding, EPA then assigns either a Not Likely to Adversely Affect (NLAA) or a Likely to Adversely Affect (LAA) designation to each individual species or critical habitat. Finally, for each LAA determination, evidence is characterized by its “strength” — strongest, moderate, or weakest.
This recently announced BE made determinations for 1,795 animal and plant species and 792 designated critical habitats. The executive summary for the BE cuts to the chase: “No NE determinations were made for any species or designated critical habitats; therefore, all species received a MA determination.” Thus, all species and habitats underwent the second step: NLAA determinations were made for 119 species and 33 species’ critical habitats, and LAA determinations were made for 1,676 species and 759 critical habitats. For the LAAs, 96% of species and 97% of habitats had moderate evidence; strongest evidence was found for less than 1% of both species and habitats; and weakest evidence was found for 4% of species and 3% of critical habitats.
In addition, the evaluation indicates that, though glyphosate is not acutely toxic to animals, some herbicide formulations that include adjuvant “inert” ingredients can be up to two orders of magnitude more toxic than glyphosate alone, about which issue Beyond Pesticides has written. The BE asserts that persistent exposures to glyphosate herbicides can have impacts on plants’ and animals’ growth and reproduction, in particular. One of the many failures of FIFRA, the primary federal pesticide law, is that it distinguishes between active and “inert” ingredients, the latter of which receive minimal attention, e.g., to establish tolerances. In addition, manufacturers are not required to disclose those ingredients, on the product label or elsewhere, under the guise of “proprietary information.”
Examples of the Trump EPA’s fealty to industry interests rather than to enactment of its mission — “to protect human health and the environment” — are legion. With the transition to a new administration under way, EPA’s behavior is a tad perplexing. With one hand, it has released this important and mandated biological evaluation of impacts of glyphosate on species protected by the Endangered Species Act. Roughly a week after the BE was made public, and with the other hand, EPA is full-speed-ahead on advancing two toxic compounds: a bee-toxic pesticide and an acutely and chronically toxic disinfectant.
One might wonder, “why this BE now”? Perhaps, given that the requisite screenings for endocrine system impacts still lie ahead (for a final reregistration decision on glyphosate), the agency is kicking the can down the road to the next EPA. (It is extremely unlikely that this EPA will, in the remaining weeks of this administration, take any regulatory action as a result of the terrible data in this BE.) Perhaps, with tens of thousands of glyphosate lawsuits in queue, the agency sees the writing on the wall. Perhaps, with the waning of the Trump administration, career officials at EPA are feeling more emboldened. In any case, the results of this BE on glyphosate — a compound the agency has bent over backwards to keep registered — are damning.
EPA is accepting public comment on the Draft Biological Evaluation for Glyphosate (released on November 25) for a 60-day period, after which it will be finalized, though it should be noted that 60 days from November 25 is January 24 — four days after Vice President Joe Biden is inaugurated as the next President. Comments can be made (via docket EPA-HQ-OPP-2020-0585) at www.regulations.gov.
Sources: https://cen.acs.org/environment/pesticides/Glyphosate-likely-harms-nearly-endangered/98/web/2020/11 and https://www.epa.gov/endangered-species/draft-national-level-listed-species-biological-evaluation-glyphosate#chap4
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
