21
Aug
Advocates Urge EPA Integration of Safer Chemicals and Organic Practices in Pesticide Assessments
(Beyond Pesticides, August 21, 2023) As the U.S. Environmental Protection Agency’s (EPA) Safer Choice program asks for public input into the expansion of its work to label green chemicals, the need to recognize the importance of holistic management systems in sync with nature looms large. Will simple chemical substitution ignore the value of natural processes that require nurturing for sustainable future? EPA’s Safer Choice is a non-regulatory program that identifies alternative chemicals for a number of uses that meet expanded safety criteria.
For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers can look for products with the Safer Choice label, which requires that EPA review all chemical ingredients that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/Design for the Environment (DfE) program performs alternatives analyses on chemicals and identifies chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods. [For pesticidal uses, the program is called Design for the Environment (DfE), which has so far been limited to disinfectants.]
Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA), is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural (nonsynthetic) or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food.
The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by available organic methods.
Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.†There are two ways that the Safer Choice program could improve CWA implementation. First, the chemical and toxicological analyses required by Safer Choice could identify priorities for elimination. Second, the Safer Choice alternatives analyses could identify alternative processes that could eliminate those substances and create a list of substances for which NPDES permits might be allowed for specified uses—analogous to the National List in NOP.
In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program.
These applications are consistent with policies of EPA and the Biden administration. EPA characterizes Safer Choice as being part of the agency’s pollution prevention (P2) program, which EPA defines as “any practice that reduces, eliminates, or prevents pollution at its source prior to recycling, treatment, or disposal.†EPA says, ““Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer and industrial sectors. Prevention practices are essential for preserving wetlands, groundwater sources and other critical ecosystems – areas in which we especially want to stop pollution before it begins.†P2, in concert with President Biden’s Executive Order 14057 on catalyzing American clean energy industries and jobs through Federal sustainability and accompanying Federal Sustainability Plan, establishes a framework for applying Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.
Note: Beyond Pesticides will continue the discussion on Safer Choice in future postings, both in the context of suggesting an expansion of the program, as well as in the context of what is needed to meet the challenges of severe health threats, biodiversity collapse, and the climate emergency—systemic change in the way synthetic chemicals are regulated.
Letter to U.S. Representative and Senators:
EPA is considering expanding its Safer Choice program—a non-regulatory program that identifies alternative chemicals that meet expanded safety criteria for specified uses. Substituting chemicals alone is not the safer choice. Safer Choice should be expanded and used to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.
For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, which must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice program does an admirable job of performing alternatives analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods.
Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA) is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food.
The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by organic methods.
Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.†The Safer Choice program could improve CWA implementation by identifying priorities for elimination and identifying alternative processes that could eliminate those substances. Analogous to the National List in NOP, a list of allowable discharges could be created.
In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program.
These applications are consistent with current policies. EPA characterizes Safer Choice as being part of the agency’s pollution prevention (P2) program. EPA says, “Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer and industrial sectors.â€
Please encourage EPA to use P2, in concert with President Biden’s Executive Order 14057 and Federal Sustainability Plan, to apply Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.
Thank you.
Suggested comment for EPA, which can be submitted at Regulation.gov through EPA’s docket: Please consider copying and pasting the following into your comment here:
For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, which must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternatives analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to organic methods.
Like Safer Choice, the National Organic Program (NOP) established by the Organic Foods Production Act (OFPA) is a label-centered program. Relying on consumer demand for food without pesticides or other chemical additives, produced in a way that benefits health, ecology, and biodiversity, NOP establishes standards for producers to use the organic label. OFPA does not require organic producers to use safer inputs. Rather, it requires them to adopt a system consistent with organic principles—building soil, increasing biodiversity, and producing healthy food—using only inputs that are natural (nonsynthetic) or are approved for a specific use by the National Organic Standards Board and placed into regulations on the National List. The growth of organic food sales in the U.S.—exceeding $60 billion in 2022—is based on consumer recognition of the value of organic food.
The organic program could have a larger impact if EPA, in its pesticide registration program, recognized that pesticide uses are unreasonable if the goals of the use could be met by organic methods.
Similarly, Safer Choice would have a larger impact if expanded and incorporated into regulatory programs, as part of a system. The heart of the Clean Water Act (CWA) program, for example, is the National Pollution Discharge Elimination System permit. EPA has largely ignored the elimination part of this program. Instead, EPA says, “An NPDES permit will generally specify an acceptable level of a pollutant or pollutant parameter in a discharge.†There are two ways that the Safer Choice program could improve CWA implementation. First, the chemical and toxicological analyses required by Safer Choice could identify priorities for elimination. Second, the Safer Choice alternatives analyses could identify alternative processes that could eliminate those substances and create a list of substances for which NPDES permits might be allowed for specified uses—analogous to the National List in NOP.
In the arena of pesticide regulation, EPA could determine that the registration of a toxic substance is unreasonable in light of the availability of alternative practices and products identified by the Safe Choice program.
These applications are consistent with policies of EPA and the Biden administration. EPA characterizes Safer Choice as being part of the agency’s pollution prevention (P2) program, which EPA defines as “any practice that reduces, eliminates, or prevents pollution at its source prior to recycling, treatment, or disposal.†EPA says, ““Pollution prevention approaches can be applied to all potential and actual pollution-generating activities, including those found in the energy, agriculture, federal, consumer and industrial sectors. Prevention practices are essential for preserving wetlands, groundwater sources and other critical ecosystems – areas in which we especially want to stop pollution before it begins.†P2, in concert with President Biden’s Executive Order 14057 on catalyzing American clean energy industries and jobs through Federal sustainability and accompanying Federal Sustainability Plan, establishes a framework for applying Safer Choice to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.
Please expand Safer Choice and use it to eliminate harmful practices and emissions by compelling a transition to practices that build a climate- and sustainability-focused economy.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
Note: Beyond Pesticides began its Safer Choice program prior to EPA’s.
This def sheds light on how programs like EPA’s Safer Choice and the National Organic Program are beneficial but still have room for meaningful improvements. I especially agree with the point that Safer Choice should not just identify less hazardous alternatives but should push for systems that make hazardous inputs completely unnecessary. The idea to integrate Safer Choice into the Clean Water Act’s NPDES program is a novel approach and could be a real game-changer in pollution prevention. It’s time to move beyond merely substituting one chemical for another; we need to rethink our systems entirely for a sustainable future. Thank you for this thorough analysis!
August 21st, 2023 at 7:49 pmPlease ban unsafe chemicals in pesticides and integrate safer ones in. We are poisoning our world, and losing many other species, in part due to these poisons. This is not sustainable.
August 23rd, 2023 at 10:16 pmWe expect EPA thinking about prevention of exportation HHPs to developing countries.
August 24th, 2023 at 1:49 am