09
Jan
Calling for Reform of Pesticide Regulation to Address Health, Biodiversity, and Climate Crises
(Beyond Pesticides, January 9, 2023) The Biden EPA still needs a new vision in order to meet the existential crises in public health, climate change, and biodiversity. The Trump Environmental Protection Agency (EPA) reversed in four years much of the progress made by the EPA in decades. Despite a broad new perspective embodied in President Biden’s Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office, the Biden EPA has not adopted a new direction for regulating pesticides.
Tell President Biden, EPA, and Congress to adopt a new direction for pesticide regulation.
Immediately following his inauguration, President Joe Biden issued the EM, which directs the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This EM could reverse the historical trend of status-quo regulatory reviews required by the White House Office of Management and Budget (OMB) that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers). The President’s EM sets the stage for the adoption of agency policy across government to seriously and with urgency confront the existential crises of climate change, biodiversity collapse, and public health threats, including disproportionate harm to people of color communities (environmental racism).
In order for EPA to live up to the vision embodied in the EM, the agency must make systemic changes that incorporate the new direction into every decision. Those systemic changes include:
Challenge so-called “benefits” of pesticides.
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. Claimed “benefits” for toxic pesticides need to be judged in comparison to organic production, which is able to produce all types of food and feed. The Organic Trade Association reports that organic sales now exceed $63 billion per year, and the U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $11.2 billion worth of organic food on 4.9 million acres in 2021. EPA assumes benefits, rather than measuring them, and does not take into account the development of resistance in target insects or plants.
Protect pollinators.
Agriculture relies on insect pollinators to facilitate fertilization and maintain annual crop yield. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet, many agricultural pesticides are killing pollinators outright, making them more susceptible to parasites and disease, and destroying their habitat. Pollinator protection should be a priority of EPA.
Protect workers.
Farmworkers are at greatest risk from pesticide exposure. A blatant example of systemic racism is imbedded in risk assessments in environmental regulation. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. For example, EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—and such exposures routinely occur in fenceline communities, farmworkers, and factory workers.
Protect biodiversity.
Roughly a quarter of the global insect population has been wiped out since 1990, according to research published in the journal Science. Monarchs are near extinction and beekeepers continue to experience declines that are putting them out of business. We continue to lose mayflies, the foundation of so many food chains, and fireflies, the foundation of so many childhood summer memories, for reasons that can be prevented with leadership in regulating pesticides. It is likely that the declines we are seeing in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance, has been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. Amphibians are also particularly at risk.
As if the loss of biodiversity was not bad enough in itself, it combines with the other existential threats to amplify the impacts. A study in the journal Nature finds that, “The interaction between indices of historical climate warming and intensive agricultural land use is associated with reductions of almost 50% in the abundance and 27% in the number of species within insect assemblages relative to those in less-disturbed habitats with lower rates of historical climate warming.” And a study in Environmental Health Perspectives finds that resulting from the loss of pollinators, “3%–5% of fruit, vegetable, and nut production is lost due to inadequate pollination, leading to an estimated 427,000 (95% uncertainty interval: 86,000-691,000) excess deaths annually from lost healthy food consumption and associated diseases.” That study also finds the economic value of crops to be “12%–31% lower than if pollinators were abundant.”
EPA does not factor these impacts into its cost-benefit analysis.
Get rid of endocrine-disrupting pesticides.
Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. In 1998, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 21 years, the Endocrine Disruptor Screening Program (EDSP) has made little progress in reviewing and regulating endocrine-disrupting pesticides. Now the program has stalled entirely.
To ensure appropriate follow-through, Congress gave EPA a timeline to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).
Despite these deadlines, EPA is stalled and ignoring its responsibility. It started a screening program (Tier 1) and reported results in 2009. According to EPA, Tier 1 Screening (which looks at high exposure chemicals) is not sufficient to implicate a chemical as an endocrine disrupting chemical. It is instead a step to define which chemicals must undergo Tier 2 testing – the only stage that can influence regulatory decision making. It is unclear when or how EPA will move forward with Tier 2 testing, and how, if at all, any Tier 2 findings will be used to inform actual regulation.
Only those registrations supported by testing showing a lack of endocrine-disrupting effects should be approved or allowed to continue.
Get rid of neurotoxic pesticides that harm children.
The target of action by which many pesticides kill is the nervous system. It is not surprising, then, that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides (relative to their body weight) than adults, and whose developing organ systems are typically more sensitive to toxic exposures.
The body of evidence in the scientific literature shows that pesticide exposure can adversely affect a child’s neurological, respiratory, immune, and endocrine system, even at low exposure levels. Several pesticide families, such as synthetic pyrethroids, organophosphates, and carbamates, are also known to cause or exacerbate respiratory symptoms like asthma. The American Academy of Pediatrics wrote, “Epidemiologic evidence demonstrates associations between early life exposure to pesticides and pediatric cancers, decreased cognitive function, and behavioral problems.”
Action taken by this administration to ban food uses of the extremely neurotoxic insecticide chlorpyrifos is an important first step in eliminating neurotoxic pesticides, but a small one. Even the uses of chlorpyrifos that remain allow continued exposure to workers and children. In addition, many other neurotoxic pesticides continue to be used and threaten public health.
Tell President Biden, EPA, and Congress to adopt a new direction for pesticide regulation.
Letter to the Biden Administration (Council on Environmental Quality Chair Barbara Mallory and EPA Administrator Michael Regan):
Pesticide regulation needs a change of direction in order to meet the existential crises in public health, climate change, and biodiversity. Despite a broad new perspective embodied in President Joe Biden’s Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office, the Biden EPA has not adopted a new direction for regulating pesticides. A program consistent with the EM requires EPA to:
- Challenge so-called “benefits” of pesticides. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. The standard for claimed “benefits” for toxic pesticides organic production. The U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $11.2 billion worth of organic food in 2021. EPA assumes benefits, rather than measuring them, and does not take into account the development of resistance in target insects or plants.
- Protect pollinators. Agriculture relies on insect pollinators to facilitate fertilization and maintain annual crop yield. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet, many agricultural pesticides kill pollinators outright, make them more susceptible to parasites and disease, and destroy their habitat.
- Protect workers. Farmworkers are at greatest risk from pesticide exposure. Systemic racism is imbedded in risk assessments in environmental regulation. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—that routinely occur in fenceline communities, farmworkers, and factory workers.
- Protect biodiversity. Roughly a quarter of the global insect population has been wiped out since 1990. It is likely that declines in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance has been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. A study in the journal Nature finds reductions of almost 50% in the abundance and 27% in the number of species due to interaction with climate change. A study in Environmental Health Perspectives calculates an estimated 427,000 (95% uncertainty interval: 86,000-691,000) excess deaths annually from lost healthy food consumption and associated diseases resulting from the loss of pollinators and subsequent loss of production, as well as reduction in economic value of crops of 12%–31%. EPA does not factor these impacts into its cost-benefit analysis.
- Get rid of endocrine-disrupting pesticides. Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. EPA is stalled and ignoring its responsibility.
- Get rid of neurotoxic pesticides that harm children. The target of action by which many pesticides kill is the nervous system. It is not surprising, then, that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides (relative to their body weight) than adults, and whose developing organ systems are typically more sensitive to toxic exposures.
Please ensure that EPA acts on these existential threats.
Thank you.
Letter to U.S. Representative and Senators:
Pesticide regulation needs a change of direction in order to meet the existential crises in public health, climate change, and biodiversity. Despite a broad new perspective embodied in President Joe Biden’s Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office, the Biden EPA has not adopted a new direction for regulating pesticides. A program consistent with the EM requires EPA to:
- Challenge so-called “benefits” of pesticides. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires EPA to weigh risks against benefits when registering pesticides. The standard for claimed “benefits” for toxic pesticides organic production. The U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $11.2 billion worth of organic food in 2021. EPA assumes benefits, rather than measuring them, and does not take into account the development of resistance in target insects or plants.
- Protect pollinators. Agriculture relies on insect pollinators to facilitate fertilization and maintain annual crop yield. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Yet, many agricultural pesticides kill pollinators outright, make them more susceptible to parasites and disease, and destroy their habitat.
- Protect workers. Farmworkers are at greatest risk from pesticide exposure. Systemic racism is imbedded in risk assessments in environmental regulation. In deciding on “acceptable” risks, exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—that routinely occur in fenceline communities, farmworkers, and factory workers.
- Protect biodiversity. Roughly a quarter of the global insect population has been wiped out since 1990. It is likely that declines in many bird species are closely linked to insect declines. Recent research finds that three billion birds, or 29% of bird abundance has been lost since the 1970s. Pesticides cause biodiversity loss in aquatic ecosystems as well. A study in the journal Nature finds reductions of almost 50% in the abundance and 27% in the number of species due to interaction with climate change. A study in Environmental Health Perspectives calculates an estimated 427,000 (95% uncertainty interval: 86,000-691,000) excess deaths annually from lost healthy food consumption and associated diseases resulting from the loss of pollinators and subsequent loss of production, as well as reduction in economic value of crops of 12%–31%. EPA does not factor these impacts into its cost-benefit analysis.
- Get rid of endocrine-disrupting pesticides. Despite the Congressional mandate in the Food Quality Protection Act of 1996 (FQPA), EPA is not acting on endocrine disruptors linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. EPA is stalled and ignoring its responsibility.
- Get rid of neurotoxic pesticides that harm children. The target of action by which many pesticides kill is the nervous system. It is not surprising, then, that pesticides also target the nervous system in humans. They are particularly hazardous to children, who take in greater amounts of pesticides (relative to their body weight) than adults, and whose developing organ systems are typically more sensitive to toxic exposures.
Please ensure that EPA acts on these existential threats.
Thank you.
