09
Sep
Increased Pesticide Use and Infant Deaths Tied to Decline of Bats; Importance of Organic Cited
(Beyond Pesticides, September 9, 2024) Comments are due by 11:59 PM EDT on September 30, 2024.
With the opening of the public comment period on organic standards that determine the integrity, strength, and growth of the organic agricultural sector, a study was released last week that shows degradation of the ecosystem linked to increased infant mortality associated with higher pesticide use by chemical-intensive farmers compensating for losses in bat populations. It is well known that bats, among other wildlife including birds and bees, provide important ecosystem services to farmers by helping to manage pest populations and increase plant resilience and productivity. While degradation of ecosystems is attributable to many factors, pesticide use accounts for an important element in harm to bats and biodiversity. The study, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes with a finding that “insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.” Daily News will cover this study in depth in an upcoming edition. According to research published in the Journal of the Association of Environmental and Resource Economists (2022), bat population declines cost American farmers as much as $495 million annually.
Why organic matters. A major tenet of organic land management is the protection and enhancement of biodiversity. Organic as a systemic approach to environmental and human health protection is well-documented to be a productive and profitable path to averting biodiversity collapse, eliminating toxic pesticide use, and creating a sustainable future. Organic advocates stress the importance of public involvement in the deliberations of the National Organic Standards Board during the current public comment period ending September 30 to ensure that the standards are upheld and strengthened, as big agricultural interests and some within the U.S. Department of Agriculture (USDA) seek to reduce the rigor associated with the USDA organic food label. There is no other system of agricultural production that is subject to as rigorous a public standard-setting process, labeling, certification, and enforcement—while being governed by a stakeholder board composed of a majority of organic farmers, consumers, and conservationists/environmentalists. Beyond Pesticides says that the label and governing standards are only as strong as the level of public participation by those who eat organic food, practice organic land management, and/or are concerned about the elimination of all the petrochemical pesticides that contribute to existential climate, biodiversity, and health threats.
How to participate in growing the shift to organic and protecting its integrity. The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by 11:59 PM EDT on September 30, 2024. This precedes the upcoming public comment webinar on October 15 and 17 and a deliberative board hearing on October 22-24—concerning how organic food is produced.
📌 Sign up to speak at the webinar by 11:59 pm EDT on September 30. (Speaking slots are generally filled early.)
📌 Written comments can be submitted via our form below or directly through Regulations.gov.
📌 Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October.
The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials (substances) allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health.
>> Click here to submit your comments to the National Organic Standard Board by September 30, 11:59 pm EDT. [In addition to the issues identified, Beyond Pesticides will issue another action before the comment deadline with comments on all the issues before the board.]
The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and stay tuned for updates to our Fall 2024 issues page!
Some priority issues for Beyond Pesticides at this meeting are:
“Inert” ingredients used in organic production. USDA’s National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection Agency (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA.
The Materials Subcommittee has proposed two options for addressing this problem.
- The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling.
- The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food and not adverse effects to the environment and workers, falling short of the holistic assessment required by the organic law.
Compost regulations. The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. Beyond Pesticides supports the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a ‘de minimis’ doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.”
Meloxicam in organic livestock. The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes to list the drug without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.”
Beyond Pesticides opposes the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.
>> Click here to submit your comments to the National Organic Standard Board by September 30, 11:59 pm EDT. [Beyond Pesticides will issue another action before the comment deadline with comments on all the issues before the board.]
Beyond Pesticides urges the submission of public comments to the docket on the above issues and to add a sentence or two at the beginning of the comments explaining why organic is important to each person submitting a comment! As an alternative to using the above link, for those who prefer to copy and paste comments directly to Regulations.gov, please see a copy of our comments included on Beyond Pesticides’ archive page.
