29
Jul
Public Asked To Support Petition To Stop EPA from Allowing “Forever Chemicals” (PFAS) Use in Pesticides
(Beyond Pesticides, July 29, 2024) Beyond Pesticides is asking the public to support a petition to the U.S. Environmental Protection Agency (EPA), filed by environmental and farm groups, to require the agency’s pesticide registration program to ban PFAS (so-called “forever chemicals”) as pesticide ingredients and all their uses that result in contamination of pesticide products. The petition, submitted by the Center for Food Safety (CFS) on behalf of 12 other petitioners, asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.” PFAS—per- and polyfluorinated substances—is a group of nearly 10,000 highly persistent, human-made toxic chemicals. A commentary released last week in Environmental Health Perspectives, Forever Pesticides: A Growing Source of PFAS Contamination in the Environment, “explore[s] different ways that PFAS can be introduced into pesticide products, the extent of PFAS contamination of pesticide products, and the implications this could have for human and environmental health.”
The petition addresses the fact that EPA continues to register hundreds of PFAS pesticide ingredients. In addition, the agency has allowed the ongoing use of pesticide storage containers treated with PFAS, despite its own findings that these containers leach the chemicals into pesticide products—which are then dispersed into the air, water, and soil. PFAS persistence is due to a fluorine–carbon atom bond being among the strongest ever created.
PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply, among other resources, is a ubiquitous and concerning contaminant across the globe. The use and associated public and environmental exposure to PFAS as active ingredients represent a grave threat as a result of their application in homes, emergency rooms, health care facilities, schools, and lawn care. The contamination extends to structures, gardens, food, soil, and water, including as a contaminant in drinking water. Among the wide variety of sources, contamination is attributed to the use of fertilizers made from so-called “biosludge” (biosolids) from local waste treatment plants where PFAS active ingredients can end up. In addition, run-off from land treated with PFAS active ingredients, these treatment plants may discharge millions of gallons of wastewater into waterways, contaminating them; current waste and water treatment generally does not eliminate PFAS compounds from the treated effluent water.
Among the wide use of PFAS in pest management products is the mosquito insecticide Anvil 10+10. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—as the plastic containers leach PFAS. PFAS have been linked to various health threats, including cancer, reproductive problems, and immune system dysfunction.
As PEER notes, PFOA and twelve other PFAS chemicals are formed during the fluorination of high-density polyethylene (HDPE) plastic containers by Inhance Technologies, LLC of Houston, Texas. Inhance is the sole U.S. company conducting this type of fluorination. Studies by EPA, independent researchers, and Inhance itself show that PFAS leaches from the walls of containers into their contents, thus exposing millions of people to PFAS without their knowledge. In February 2024, EPA announced new methodology for detecting dangerous low levels of PFAS in plastic containers. The leaching of PFAS from plastic containers into various products, including pesticides, food, cosmetics, and cleaning supplies, poses a significant risk to millions of Americans through exposure via ingestion, inhalation, and dermal contact.
The number of pesticide ingredients classified as PFAS in the U.S. heavily depends on EPA’s definitions. Many experts describe EPA’s initial definition as significantly underinclusive compared to state and international definitions. EPA took a further step away from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas.
In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states, including Colorado, Washington, Maine, Maryland, New York, and California, encompasses a broader range of compounds.
In the context of pesticide ingredients, the “one fully fluorinated carbon” definition encompasses up to 200 pesticide ingredients. Maine will prohibit these starting in 2030, following its ban on pesticides that include intentionally added PFAS and pesticides contaminated with PFAS. This definition covers bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, and the main ingredient in over 600 pesticide formulations today, which recent testing has found elevated amounts of bifenthrin in numerous agricultural crops, exceeding the agency’s safety levels.
Concerns about safety in the use of fluorinated plastic containers used for packaging are based on exposure to PFAS not just from leaching into the contents of the plastic containers, but also from handling the exterior of the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, from pregnant women through children and the elderly, experience disproportionate risks of exposure. (See here, and here). The chemicals have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. As new drinking water health advisories issued by EPA show, PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.
Certified organic agriculture can play a crucial role in addressing the widespread contamination of PFAS as the only viable solution in the long run. Organic agriculture prohibits the use of petrochemical pesticides and fertilizers under a robust regulatory system created by the Organic Food Production Act (OFPA) and overseen by the National Organic Standards Board (NOSB), which reports directly to the U.S. Secretary of Agriculture. As the only agricultural system with public input and standards as defined by federal law, organic promotes sustainable farming practices that prioritize soil health and biodiversity. As the governing body responsible for setting organic standards, the NOSB must take a leadership role in developing a comprehensive strategy for eliminating plastics and PFAS from organic production and packaging, ensuring that organic agriculture remains a safe and sustainable alternative to conventional farming.
Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. For more information on why organic is the healthy choice, see Beyond Pesticides’ webpage, Health Benefits of Organic Agriculture.
Letter to EPA:
Numerous studies document the devastating impacts on public health, wildlife, and pollinators caused by the broad use of PFAS chemicals and the resulting environmental contamination. While acknowledging PFAS as an urgent public health and environmental issue, EPA continues to register hundreds of PFAS pesticide ingredients and allows the ongoing use of fluorinated pesticide storage containers, despite its own findings that these containers leach PFAS chemicals into pesticide products—which are then dispersed into the air, water, and soil.
The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products raises alarm about the extent of PFAS contamination and its potential impact on public health. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—plastic containers that leached PFAS. Studies by EPA, independent researchers, and manufacturers show that PFAS leaches from the walls of containers into the contents, thus exposing millions of people to PFAS without their knowledge. Exposure to PFAS also results from handling the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, including pregnant women, children, and the elderly, experience disproportionate risk. PFAS have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. EPA’s drinking water health advisories find PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.
The number of pesticide ingredients classified as PFAS in the U.S. depends on EPA’s definitions. EPA retreated from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas. In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states, encompasses a broad range of compounds, among them up to 200 pesticide ingredients, such as bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, a main ingredient in over 600 pesticide formulations, which tests have found to exceed EPA safety levels in numerous agricultural crops.
A petition submitted by the Center for Food Safety (CFS) on behalf of CFS and twelve other petitioners asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.”
Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals.
Please approve the Center for Food Safety petition filed on July 23, 2024 on behalf of itself and 12 environmental and farm petitioners to eliminate the distribution of PFAS chemicals through pesticides.
Thank you.
Letter to U.S. Representative and Senators:
Numerous studies have document the devastating impacts on public health, wildlife, and pollinators caused by the broad use of PFAS chemicals and the resulting environmental contamination. While acknowledging PFAS as an urgent public health and environmental issue, EPA continues to register hundreds of PFAS pesticide ingredients and allows the ongoing use of fluorinated pesticide storage containers, despite its own findings that these containers leach PFAS chemicals into pesticide products—which are then dispersed into the air, water, and soil.
The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products raises alarm about the extent of PFAS contamination and its potential impact on public health. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—plastic containers that leach PFAS. Studies by EPA, independent researchers, and manufacturers show that PFAS leaches from the walls of containers into the contents, thus exposing millions of people to PFAS without their knowledge. Exposure to PFAS also results from handling the containers. Factory workers and farmworkers have higher cumulative exposures, while vulnerable people, including pregnant women, children, and the elderly, experience disproportionate risk. PFAS have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. EPA’s drinking water health advisories find PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.
The number of pesticide ingredients classified as PFAS in the U.S. depends on EPA’s definitions. EPA retreated from managing the entire PFAS class in August 2023 when it decided to define PFAS on a “case-by-case” basis during rulemakings and agency actions, instead of using one definition for all program areas. In contrast, the definition of PFAS as a compound with at least “one fully fluorinated carbon,” which has been adopted by other authorities, including the U.S. Geological Survey, the U.S. National Defense Authorization Act (NDAA), and many states, encompasses a broad range of compounds, among them up to 200 pesticide ingredients, such as bifenthrin, a highly stable, fluorinated insecticide with a half-life ranging from 97 to 345 days, a main ingredient in over 600 pesticide formulations, which tests have found to exceed EPA safety levels in numerous agricultural crops.
A petition submitted by the Center for Food Safety (CFS) on behalf of CFS and twelve other petitioners asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.”
Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals.
Please urge EPA to approve the Center for Food Safety petition filed on July 23, 2024 on behalf of itself and 12 environmental and farm petitioners and eliminate the distribution of PFAS chemicals through pesticides.
Thank you.
