03
Mar
Groups Challenge EPA on Allowing Toxic Pesticides that Do Not Even Work and Without Its Review
(Beyond Pesticides, March 2, 2023) On February 22, a group of 65 nonprofit organizations (including Beyond Pesticides) filed a citizen petition with the U.S. Environmental Protection Agency (EPA) that asks the agency to close a gaping — and well exploited — regulatory loophole by revoking a 1984 regulation that waived efficacy data requirements in pesticide evaluations. This means that EPA has, for 39 years, registered pesticides without demonstrated proof of efficacy and benefits. The petition is aimed primarily at the widespread use of neonicotinoid insecticides (neonics), which are so harmful to hundreds of species — and to bees, other pollinators, and birds, in particular — that many advocates have insisted they should be banned altogether. Beyond Pesticides has advocated for a neonics ban because of their extensive harms to pollinators, multiple other organisms (including humans), ecosystems, and natural resources.
The Center for Food Safety, Pesticide Action Network North America, Center for Biological Diversity, Beyond Pesticides, and other advocates have filed lawsuits in recent years to get EPA to act protectively on neonics and other pesticides. The coalition of groups in the subject case seeks to rein in a plethora of harmful impacts of neonics, given EPA’s overall lack of protective action. (For recent developments, see here and here.) Indeed, in the absence of effective neonic regulation, many localities and states (e.g., Maine, Maryland, New York, New Jersey, Massachusetts, Portland and Eugene, Oregon), as well as France and unitary state entities, such as the European Union and the United Kingdom, have taken steps to ban or curb significantly the use of these noxious compounds.
Led by PEER (Public Employees for Environmental Responsibility) and the American Bird Conservancy (ABC), the petition “asks EPA to amend its existing regulation for registrations of all neonicotinoid insecticides and other systemic insecticides so as to require all registration and re-registration applicants to provide performance (efficacy) data to ensure that the benefits of their products actually exceed their costs, including to society and to the environment.” Beyond Pesticides Executive Director Jay Feldman asserts that EPA does not evaluate the efficacy of pesticides, except for those deemed to have public health benefits (such as those used in a public health emergency or for a “special local need”); even then, he says agency action on the latter has hardly been stellar.
According to the Environmental Health Newsletter (EHN), the current, ubiquitous use of neonics has arisen in large part from that 1984 EPA waiver, which said, “rather than require efficacy data, the Agency presumes that benefits exceed risks.” EHN also notes that, “The petition specifically calls for the EPA to reinstate performance data requirements and says if the companies failed to provide such information, the EPA should revoke their product registrations. The rule change would include products currently on the market.”
Neonics are the most widely used class of insecticides globally; they impact roughly 100 million acres annually in the U.S. In a PEER press release subtitled “Neonicotinoid insecticides targeted for wreaking eco-havoc despite lack of economic benefits,” Senior Counsel Peter Jenkins commented, “While EPA should hold all pesticides to a higher standard, for the neonics we have voluminous published evidence on their lack of efficacy, their prophylactic overuse, and the environmental harm they are causing. The threat they pose to long-term ecosystem integrity is especially insidious.”
Launched to market two decades ago, use of neonics increased significantly when the treatment of crop seeds with the compounds took hold. This marked “an unprecedented shift toward large-scale, preemptive insecticide use,” and has contributed to the insect apocalypse underway — as evidenced by a 75% decline in insect abundance.
The impacts on pollinators are of extreme concern, both generally and because these creatures are critical to food production. The U.S. Geological Survey (USGS) recently reported, for example, that the western bumble bee underwent a 57% decline from1998–2020. The use of neonics, and pesticides broadly, threatens not only global ecosystems, but also, food production that depends on pollinators. Neonic seed treatments are commonly used on cotton, soybean, wheat, canola, wheat, sunflower, potato, and many vegetables seeds.
A chief contributor to bee, other pollinator, and bird decline, neonics affect the central nervous systems of organisms. The chemicals impair, for example, bees’ foraging, navigational, and learning behaviors, and immune responses, and often result in paralysis and death. As Beyond Pesticides has written, “These individual impacts are compounded at the level of social colonies, weakening collective resistance to common parasites, pathogens, and other pesticides . . . thus leading to colony losses and mass population declines. In 2018, more than two hundred scientists co-authored a ‘call to restrict neonicotinoids’ on the basis of the bulk of evidence implicating neonicotinoids in mass pollinator and beneficial insect declines.”
Neonics are systemic compounds, meaning that they move throughout a plant’s vascular system, and are present not only in plant tissues, but also, in pollen, nectar, and guttation droplets. Organisms that feed off of treated plants (and those that grow from treated seed) thus ingest the compounds and suffer the risks outlined above; this includes beneficial insects. Any plant remnants left in the field also harbor the compounds, polluting the soils on which they decompose. Neonics can persist for long periods in soil, and are highly water soluble; they can be transported by rain or irrigation systems to surface waters, waterways, and groundwater.
Yet another vector for exposures is the neonic dust that becomes airborne when treated seeds are planted. Together, these paths account for much of the contamination of drinking water by neonics. Neonic impacts on health, via compromise of the central nervous system, is not limited to the insect and bird world. Humans are also at risk, with established associations between neonic exposures and neurotoxicity, reproductive anomalies, hepatic and renal damage, and an increase in gene expression linked to hormone-dependent breast cancer.
Acting director of the pollinator initiative at the Natural Resources Defense Council, Daniel Raichel, commented: “The failure to regulate treated seeds creates a gigantic regulatory blind-spot — allowing one of the largest and most widespread uses of pesticides to go almost completely untracked and unregulated.”
Research published in the Proceedings of the National Academy of Sciences Journal in 2020 adds to the arguments against this class of insecticides: “[N]eonicotinoid exposure is far higher than necessary to achieve plant protection and yield objectives. Neonicotinoid seed coatings rarely improve crop yield, and neonicotinoids are applied preventively to vast areas of turf, which cover more land in the United States than any other irrigated crop, even when pests are absent or below thresholds. . . . Risks to many terrestrial, aquatic, and detrital organisms and ecosystems have been documented. Considering these risks, advocacy groups have frequently promoted outright bans on all neonicotinoids in all circumstances, and this stance seems easy to justify.”
Efficacy facts belie the intensive use of neonics as seed treatments. EPA itself (in 2014) reported that “seed treatments with neonicotinoid insecticides provide little or no overall benefit in controlling insects or improving yield or quality in soybean production.” (See the detailed EPA letter on the underlying research here.) Research in 2019, as reported by Beyond Pesticides, found that neonic-treated soybeans provide negligible benefits to farmers in terms of yield and overall economic benefit. EPA ought, in its neonic registrations and re-registrations, be evaluating whether pesticide compounds — especially those with such demonstrated harms as neonics cause — are necessary and effective before introducing them into the environment or allowing their continued deployment.
It is instructive, in discussion of the petition’s attention to efficacy, to note that under the Organic Foods Production Act (OFPA), the U.S. Department of Agriculture’s (USDA’s) National Organic Program (NOP) operates with attention to the necessity of a substance: “NOSB members use specific criteria when voting on substances, including the essentiality for the substance and its impacts on human health and the environment.” EPA should take a page from NOP: if a neonic does not work, it is entirely unnecessary.
Beyond Pesticides Executive Director Jay Feldman comments, “The justification EPA has used about efficacy of pesticides is that ‘the marketplace determines efficacy,’ and that ‘farmers and consumers wouldn’t buy them if didn’t work.’ When we’re talking about toxic substances and acknowledged hazards and risks, it is inappropriate for an agency to allow harm, especially if the product doesn’t work or perform as intended.” In 2021, a coalition of groups, including PEER and Beyond Pesticides, issued a scathing critique of the performance of EPA’s Office of Pesticide Programs — embedded in the groups’ advocacy for a series of 25 reforms.
The subject petition is the most recent strategy used by advocates to pressure EPA to curb the use of neonics by altering its registration (and re-registration) process for them (and all pesticides) to take into account their efficacy. The petition tackles one specific aspect of EPA’s process on one class of insecticides. The agency’s track record, on so many pesticides, is to deal with one compound (under a narrow range of circumstances and/or narrow time frame and/or specific exposure levels) at a time. Beyond Pesticides has dubbed this the “whack-a-mole” struggle on pesticides.
Each regulatory baby step at EPA, each judicial settlement or knock-down of a particular pesticide, each bit of research demonstrating harms — these represent small, incremental advances on a pesticide problem that is vast in scope. But this approach is wholly inadequate to the devastation that toxic pesticides are causing, and it continues the “collision course” we are on re: human health and well-being, biodiversity collapse, and the climate crisis. A precautionary approach — captured in organic, regenerative agriculture and land management protocols — is far more suited to the task of genuinely protecting public health and the environment than EPA’s current, industry friendly, piecemeal approach.
The availability of alternative materials and practices that prevent (or vastly reduce) toxic hazards, as are used in organic management, makes the dependence on synthetic chemical pesticides even more reprehensible. As consistent readers of the Daily News Blog are aware, Beyond Pesticides pursues a vision of a genuinely protective approach to pests (floral or faunal) in agriculture and land management, via a transition from chemical dependency to organic land management in food production, and in parks, playing fields, and all recreational and public spaces. In the meantime, efforts to push EPA will continue to move the needle, however slowly and haltingly. EPA should take seriously its mission: to protect human health and the environment.
Source: https://www.ehn.org/neonics-pollinators-2659453225.html
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
