(Beyond Pesticides, November 12, 2024) With revelations reported last month by Investigate Midwest and previously by The Guardian showing that Syngenta, the manufacturer and registrant of paraquat, kept secret scientific information on the weed killer’s adverse effects related to Parkinson’s disease, there is increasing concern that endocrine-disrupting properties have not been fully disclosed. Endocrine-disrupting synthetic chemicals, derived from fossil fuels, will be the focus of Session 2 of Beyond Pesticides 41^st National Forum: Imperatives for a Sustainable Future on Thursday, November 14 from 1:00-3:00pm (EST).

Keynote Speaker

The keynote speaker, Tracey Woodruff, PhD, will address the scientific, health, and regulatory issues associated with societal reliance on these chemicals. Dr. Woodruff, a former U.S. Environmental Protection Agency (EPA) senior scientist and policy advisor, is the director of the Program on Reproductive Health and the Environment, and professor in the Department of Obstetrics, Gynecology, and Reproductive Sciences in the School of Medicine at the University of California San Francisco. 

Roundtable Discussion

Dr. Woodruff’s talk will be followed by a roundtable with panelists, including a former senior scientist focusing on ecosystem effects, a breast cancer activist, and a farmworker advocate who will share their experience and insight into both the regulation of hazardous materials (including endocrine disrupting chemicals) and strategies for connecting science (and the power of those adversely affected) to decisions that eliminate hazards—recognizing disproportionate risk to people of color. Tapping the experiences of the panelists, this discussion brings together strategic thinking that supports efforts by individuals and organizations to transition away from petrochemicals from a range of perspectives and a broadening of coalition efforts. The panelists include Les Touart, PhD, senior science and policy advisor, Beyond Pesticides—former senior EPA  biologist and member of EPA’s Endocrine Disruptor Screening and Testing Advisory Committee; Janet Nudelman, director of program and policy, Breast Cancer Prevention Partners (BCPP); Mily Treviño-Sauceda, executive director and co-founder of Alianza Nacional de Campesinas, Inc., the first national grassroots farmworker women’s organization; and her colleague, Amy Tamayo, national policy and advocacy director, Alianza Nacional de Campesinas. Jay Feldman, executive director of Beyond Pesticides, will moderate.

Paraquat.

As Beyond Pesticides argued in a September action alert, EPA has sufficient evidence meeting the standard it established in banning the herbicide Dacthal (or DCPA–dimethyl tetrachloroterephthalate) to ban the highly toxic herbicide paraquat. The new information revealed by Investigate Midwest and The Guardian (linked above) shows that Syngenta has long sought to hide studies showing that paraquat causes Parkinson’s disease in violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).   

>> Tell EPA to ban paraquat. Registrants that hide data should not be allowed to register pesticides or maintain their registrations. Tell EPA’s Office of Inspector General (OIG) to investigate whether registrants are reporting adverse effects as required and whether EPA is taking action based on that information.

Section 6(a)(2) of FIFRA states, “If at any time after the registration of a pesticide the registrant has additional factual information regarding unreasonable adverse effects on the environment of the pesticide, the registrant shall submit such information to the Administrator.” As reported by Investigate Midwest: 

[T]housands of pages of records released in litigation and first reported by The Guardian, show the company’s own scientists determined that paraquat had the potential to damage the brain and nervous system as far back as the 1950s.  

Additional documents, also first reported by The Guardian, showed that as evidence of a connection between paraquat exposure and Parkinson’s disease mounted, Syngenta attempted to discredit critical scientists and limit the spread of information that could threaten paraquat sales. 

“Due possibly to good publicity on our part, very few people here believe that paraquat causes any sort of problem in the field and we have the support of the official side,” a toxicologist at Syngenta’s predecessor company wrote to a Chevron toxicologist in 1975, in response to early concerns about paraquat’s long-term health impacts. 

The articles by Investigate Midwest and The Guardian give a detailed history of the discovery of the link between paraquat and Parkinson’s and Syngenta’s coverup.

*Based on the EPA criteria used in the Dacthal decision, the agency should ban paraquat.

Paraquat poses immediate serious harms to people and the environment. Citing serious health issues associated with its use, including Parkinson’s disease, and inaction by the U.S. Environmental Protection Agency (EPA), the weed killer paraquat would be banned through legislation introduced in the California Assembly (AB 1963). Assemblymember Laura Friedman (D-Burbank), in the Assembly’s leadership, chair of the bicameral Environmental Caucus, and a self-described “steadfast advocate for the environment [and] sustainable communities,” introduced the legislation to phase out and ban the use of paraquat across all uses, including agriculture, by the end of 2025. The introduction of this bill follows a long history of scientific documentation of the pesticide’s hazards, fits and starts in the regulatory process, and previous efforts to ban the herbicide through legislative action. In 2018, U.S. Representative Nydia Velasquez (D-NY) introduced legislation (Protect Against Paraquat Act) to ban paraquat. 

The 6th edition of Recognition and Management of Pesticide Poisonings by James R. Roberts, M.D., M.P.H, and J. Routt Reigart, M.D., says, “When a toxic dose is ingested (see below), paraquat has life-threatening effects on the gastrointestinal tract, kidney, liver, heart, and other organs. The LD50 in humans is approximately 3-5 mg/kg, which translates into as little as 10-15 mL of a 20% solution. . . Although pulmonary toxicity occurs later in paraquat poisoning than other manifestations, it is the most severe and, therefore, mentioned first. Pulmonary effects represent the most lethal and least treatable manifestation of toxicity from this agent. The primary mechanism is through the generation of free radicals with oxidative damage to lung tissue. While acute pulmonary edema and early lung damage may occur within a few hours of severe acute exposures, the delayed toxic damage of pulmonary fibrosis, the usual cause of death, most commonly occurs 7-14 days after the ingestion. In those patients who ingest a very large amount of concentrated solution (20%), some have died more rapidly from circulatory failure (within 48 hours) prior to the onset of pulmonary fibrosis.” 

A 2005 study in Toxicological Sciences was able to “reproduce features of Parkinson’s disease (PD) in experimental animals.” And studies continued to replicate findings associating paraquat with Parkinson’s disease, as EPA continued to reject the need for action. Paraquat was banned in the European Union in 2007, following its prohibition years earlier in 13 countries, including Sweden, Denmark, and Austria. 

In the U.S., paraquat is currently a restricted-use pesticide (meaning it can only be applied by certified applicators or those working under their on- or off-site supervision) and banned on golf courses. There is established and mounting evidence of links between minimal exposure and various adverse health impacts for humans and wildlife. This has mobilized advocates within and outside of California for more robust action by the federal government to serve the public interest. 

Beyond Pesticides continues to track the latest scientific literature on adverse health impacts of paraquat. Within all the single-pollutant models employed in a 2022 study published in Journal of Clinical Endocrinology and Metabolism, researchers found a linkage between paraquat dichloride and thyroid cancer. A different study published that same year in Independent determined the toxic impacts of paraquat on bird embryos, including the Japanese quail, mallards, bobwhite quail, and ring-necked pheasant. Over 60 countries have already banned the use, production, and sale of paraquat, including China, where the pesticide was first developed. 

>> Tell EPA to ban paraquat. Registrants that hide data should not be allowed to register pesticides or maintain their registrations. Tell EPA’s Office of Inspector General (OIG) to investigate whether registrants are reporting adverse effects as required and whether EPA is taking action based on that information. 

EPA’s ecological risk assessment in support of its ID did not consider risks to endangered/threatened species and potential jeopardy to their continued existence. As stated in the assessment: “Given that the agencies are continuing to develop and work toward implementation of the Interim Approaches to assess the potential risks of pesticides to listed species and their designated critical habitat, this ecological risk assessment for paraquat does not contain a complete ESA analysis that includes effects determinations for specific listed species or designated critical habitat.” Considering that the calculated risk quotients (RQs) exceed established levels of concern (LOCs) for most unlisted species, it can be inferred that listed plant and animal species in areas of paraquat use could indisputably be at risk of jeopardy. 

Paraquat was also not fully assessed for potential endocrine disruption. Both the human health and ecological assessments deferred an assessment and provided canned language that endocrine disrupting potential will be further considered under the Endocrine Disruptor Screening Program (EDSP). However, there is evidence available that paraquat has endocrine-disrupting effects. The use of paraquat is significantly associated with hypothyroidism. Paraquat has been reported to decrease testosterone, follicle-stimulating hormone, luteinizing hormone, and prolactin in male rats. In the frog Rana esculenta, paraquat was found to inhibit the production of testosterone in the testis and 17-beta-estradiol in the ovary. More importantly, the endocrine disruption activity of paraquat that causes excessive reactive oxygen species production also links paraquat to Parkinson’s Disease. Though somewhat limited, these data do indicate a potential for unreasonable adverse endocrine disruption in humans and wildlife and should be further investigated as mandated in FIFRA and the Food Quality Protection Act (FQPA). 

Mitigation measures have not eliminated the harm. In 2018, EPA downplayed the connection between exposure to paraquat and the development of Parkinson’s disease in registration review documents released by the agency. But Assemblymember Friedman, in a press release on the day the California legislation was introduced, said, “We cannot afford to ignore decades of mounting evidence linking paraquat exposure to Parkinson’s disease, non-Hodgkin, and childhood leukemia.” She continued: “In 2021, the latest year for which data are publicly available, just over 430,000 pounds were applied in California, primarily in Kern, Kings, Fresno, Merced, and Tulare counties. The herbicide is extremely toxic to humans, with low doses causing death, and it has been linked to increased risk of Parkinson’s Disease.” 

EPA’s actions, or inaction as some would argue, on recognizing the scientific literature on paraquat exposure and Parkinson’s disease represent a failure of EPA to take a proactive approach in ending the continued exposure and health impacts of the toxic herbicide to chemically sensitive populations. According to the EPA’s Office of Pesticide Programs’ guidelines on paraquat and diquat, these ammonium herbicides are life-threatening in toxic doses and hold the potential to “impact GI tract, kidney, lungs liver, heart, and other organs.” Specifically regarding paraquat, “pulmonary fibrosis is the usual cause of death in paraquat poisoning.” 

In 2019, EPA released, “Systematic Review of the Literature to Evaluate the Relationship between Paraquat Dichloride Exposure and Parkinson’s Disease.” Following this ruling, EPA was lambasted for its dismissal of the linkage between Paraquat exposure and Parkinson’s Disease, despite a growing body of literature between 2009 and 2019 and, given that “[a]n EPA environmental review conducted as part of the reregistration process found evidence of significant reproductive harm to small mammals, and determined that songbirds may be exposed to levels well beyond lethal concentrations known to cause death. Threats to mammals and songbirds are particularly concerning considering significant declines in these animal groups.” 

In 2019, Beyond Pesticides submitted comments and concluded: “Since the agency risk assessments are intended to support Agency risk management review, risk management recommendations are not provided in its draft risk assessments. The many risk concerns and uncertainties (lack of data) identified in both the human health and ecological risk assessments make it unconscionable to allow continued use of such a dangerous pesticide as paraquat. A restricted use label will do little to allay the ecological risk concerns enumerated or adequately protect persons in the vicinity of treatments or in harvest and post-harvest activities. Taken together with the clear inability of the agency to preclude the potential for Parkinson’s disease, it is recommended that the use of paraquat should be immediately suspended if not outright cancelled as it is in the EU and several other countries.” 

In late January 2024, EPA released a report, “Preliminary Supplemental Consideration of Certain Issues in Support of its Interim Registration Review Decision for Paraquat.” According to the interim report, “The Agency prepared several documents to support its 2021 interim registration review decision for paraquat and attempted ‘to connect the dots’ of the risk-benefit information contained in its support documents in the Paraquat ID.” The results of this interim report, specifically regarding linkage to Parkinson’s Disease and other health risks associated with chronic exposure to paraquat, highlight the flaws in EPA’s approach to risk assessment and opportunities to incorporate additional sources of sound science in the final report in January 2025. For example, “EPA intends to consider [additional studies] as part of the next steps in this process. First, EPA recognizes that the Michael J. Fox Foundation and Earthjustice submitted letters to EPA on August 4, 2023, along with information that they believe is relevant to EPA’s consideration of paraquat’s health risks. This information consisted of approximately 90 submissions including scientific studies, as well as testimony filed in an ongoing state lawsuit concerning paraquat. EPA has included these documents in the docket for paraquat at EPA-HQ-OPP-2011-0855-0317 and EPA-HQ-OPP2011-0855-0313. While the Agency has started reviewing that material, it was unable to complete that review prior to the issuance of this document. [As a result, this document does not reflect the Agency’s review of any of those materials.] Second, new information on paraquat vapor pressure was submitted on January 18, 2024, which may impact the Agency’s volatilization analysis. Due to the late submission of that data, EPA has not incorporated that information into this document. Therefore, EPA intends to address that material along with any other significant information it receives during the public comment period and incorporate its consideration of those materials into any final document(s) issued by January 17, 2025.” Advocates found it surprising that the EPA was not able to review studies submitted by the Michael J. Fox Foundation and Earthjustice, even though the agency had more than several months for review. Beyond Pesticides will continue to track updates to this upcoming public comment period to insert new studies and data points for the EPA to include in their final report.   

>> Tell EPA to ban paraquat. Registrants that hide data should not be allowed to register pesticides or maintain their registrations. Tell EPA’s Office of Inspector General (OIG) to investigate whether registrants are reporting adverse effects as required and whether EPA is taking action based on that information.

In April 2024, Beyond Pesticides’ comments on the Paraquat Interim Registration Review stated, “EPA failed to assess a common mechanism of toxicity for PQ [paraquat] and any other substance in its review for the ID [interim decision], erroneously concluding that PQ does not have a common mechanism of toxicity or combined toxic action with other substances that may interact and potentiate its action.” The comments address the mandates under FIFRA and FQPA, stating that the agency failed to meet its mandate to obtain proof that paraquat “unequivocally does not cause or contribute to Parkinson’s Disease” and to assess paraquat endocrinological risk through FQPA’s Endocrine Disruptor Screening Program, respectively. Additionally, the comments cite EPA’s failure to adequately review and incorporate the breadth of studies pointing to a relationship between Parkinson’s Disease and paraquat exposure; failure within its ecological risk assessment to consider risks to endangered wildlife and subsequent ecosystem balance concerns; and failure in its risk-benefit analysis to fully consider the risks of paraquat exposure.

The public does not benefit from continued registration of paraquat. Although EPA asserts that there are no direct alternatives to paraquat, however, several alternatives, chemical and non-chemical, are widely available. Given the availability of alternative pest management practices that incorporate alternative cultural practices and/or less toxic products, including other registered pesticides, the agency has a statutory duty to revoke all registrations of the paraquat under its unreasonable adverse effects standard in FIFRA. The risks and uncertainties identified by the agency in its assessments and the independent scientific literature are not reasonable in light of the availability of less toxic alternatives and cultural practices. To refute a rebuttable presumption against paraquat registration, the many data gaps listed previously would need to be fulfilled and reveal opposing evidence to the existing adverse effect data. 

EPA has sufficient information to cancel paraquat. EPA has the information above, which is in the open literature and/or provided in regulatory comments by Beyond Pesticides and others. The failed regulation, and subsequent harm, caused by paraquat is but one representation of a failed regulatory system that can and should do more to eliminate the use of toxic petrochemical-based pesticides. The convergence of crosscutting crises of health threats, biodiversity collapse, and the climate emergency stems from continued reliance on fossil fuels and petrochemical pesticides and fertilizers, which perpetuate the harms of greenhouse gas emissions. These crises are causing ecosystem fragmentation and failure, and public health crises that undermine the nutritional integrity of the food supply and the scientific integrity the public relies on for safety and well-being. After decades of working with farmworkers and farmers who face the brunt of toxic pesticide exposure, Beyond Pesticides echoes the call for advocates across the nation to expand and strengthen organic land management principles to move beyond the existing product substitution framework that leads to the continuous use of toxic pesticides.  

*EPA must not allow companies that hide data to continue to sell pesticides. 

Under FIFRA, EPA relies on data submitted by pesticide manufacturers and registrants. If EPA cannot be sure that it has complete data, then it cannot fulfill its statutory mission to prevent unreasonable adverse effects on humans and the environment.

*EPA’s Office of Inspector General (OIG) should investigate the compliance with FIFRA §6(a)(2). 

The Office of Inspector General is an independent office within EPA whose mission is to: “Conduct independent audits, evaluations and investigations; make evidence-based recommendations to promote economy, efficiency and effectiveness; and prevent and detect fraud, waste, abuse, mismanagement and misconduct for the U.S. Environmental Protection Agency and the U.S. Chemical Safety and Hazard Investigation Board.” Ensuring that EPA has the necessary data to perform its responsibilities is a critical safeguard.

Letter to EPA’s Office of Pesticide Programs
I am renewing my request to ban paraquat. Not only does paraquat meet EPA’s criteria as stated in its decision to ban Dacthal, but new information has shown that the registrant, Syngenta, has withheld information concerning paraquat’s adverse effects. Since under FIFRA EPA depends on data supplied by the registrant in determining unreasonable adverse effects, Syngenta’s duplicity should disqualify it from being allowed to register any pesticide products.  I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. However, paraquat has not been held to the same standard.

In deciding to ban Dacthal, EPA says it considered the seriousness, immediacy, and likelihood of the threatened harm; benefits to the public of continued use; and nature and extent of the information before EPA.

*Paraquat poses immediate serious harms to people and the environment.

The 6th edition of Recognition and Management of Pesticide Poisonings by James R. Roberts, M.D., M.P.H, and J. Routt Reigart, M.D., says, “[P]araquat has life-threatening effects on the gastrointestinal tract, kidney, liver, heart and other organs. The LD50 in humans is approximately 3-5 mg/kg, which translates into as little as 10-15 mL of a 20% solution. . . Although pulmonary toxicity occurs later in paraquat poisoning than other manifestations, it is the most severe and, . . .[p]ulmonary effects represent the most lethal and least treatable manifestation of toxicity from this agent. The primary mechanism is through the generation of free radicals with oxidative damage to lung tissue. While acute pulmonary edema and early lung damage may occur within a few hours of severe acute exposures, the delayed toxic damage of pulmonary fibrosis, the usual cause of death, most commonly occurs 7-14 days after the ingestion. In those patients who ingest a very large amount of concentrated solution (20%), some have died more rapidly from circulatory failure (within 48 hours) prior to the onset of pulmonary fibrosis.”

*Paraquat poses risks to endangered/threatened species and potential jeopardy to their continued existence.

It is an endocrine disruptor. Use of paraquat is significantly associated with hypothyroidism. It has been reported to decrease testosterone, follicle-stimulating hormone, luteinizing hormone and prolactin in male rats. In the frog Rana esculenta, paraquat was found to inhibit the production of testosterone in the testis and 17-beta-estradiol in the ovary. Moreover, the endocrine disruption activity of paraquat that causes excessive reactive oxygen species production also links it to Parkinson’s Disease.

*Mitigation measures have not eliminated harm.

EPA has downplayed the connection between exposure to paraquat and the development of Parkinson’s disease in registration review documents released by the agency, leading California Assemblymember Laura Friedman (D-Burbank), chair of the bicameral Environmental Caucus, to introduce legislation to phase out and ban the use of paraquat across all uses, including agriculture, by the end of 2025.

*The public does not benefit from continued use of paraquat.

Alternative pest management practices that incorporate cultural practices and/or less toxic products are available. Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.” 

*EPA has sufficient information to ban paraquat.

EPA has the information above, which is in the open literature and/or provided in regulatory comments, demonstrating that the agency has a statutory duty to revoke all registrations of the paraquat under its unreasonable adverse effects standard in FIFRA. 

Please apply the criteria EPA used in the Dacthal decision to paraquat. Issue an emergency suspension and prohibit use of existing stocks. Suspend and cancel registrations of all Syngenta products.

Thank you.

Letter to EPA’s Office of Inspector General
I am writing to request that the Office of Inspector General (OIG) investigate the Office of Pesticide Program’s (OPP) compliance with §6(a)(2) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Section 6(a)(2) of FIFRA states, “If at any time after the registration of a pesticide the registrant has additional factual information regarding unreasonable adverse effects on the environment of the pesticide, the registrant shall submit such information to the Administrator.”

Under FIFRA, EPA relies on data submitted by pesticide manufacturers and registrants. If EPA cannot be sure that it has complete data, then it cannot fulfill its statutory mission to prevent unreasonable adverse effects on humans and the environment.

The Office of Inspector General is an independent office within EPA whose mission is to: “Conduct independent audits, evaluations and investigations; make evidence-based recommendations to promote economy, efficiency and effectiveness; and prevent and detect fraud, waste, abuse, mismanagement and misconduct for the U.S. Environmental Protection Agency and the U.S. Chemical Safety and Hazard Investigation Board.” Ensuring that EPA has the necessary data to perform its responsibilities is a critical safeguard.

New information revealed by Investigate Midwest shows that Syngenta, the manufacturer and registrant of paraquat, has long sought to hide studies showing that paraquat causes Parkinson’s disease in violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). As reported by Investigate Midwest:

[T]housands of pages of records released in litigation and first reported by The Guardian, show the company’s own scientists determined that paraquat had the potential to damage the brain and nervous system as far back as the 1950s. 

Additional documents, also first reported by The Guardian, showed that as evidence of a connection between paraquat exposure and Parkinson’s disease mounted, Syngenta attempted to discredit critical scientists and limit the spread of information that could threaten paraquat sales.

“Due possibly to good publicity on our part, very few people here believe that paraquat causes any sort of problem in the field and we have the support of the official side,” a toxicologist at Syngenta’s predecessor company wrote to a Chevron toxicologist in 1975, in response to early concerns about paraquat’s long-term health impacts.

The articles by Investigate Midwest and The Guardian give a detailed history of the discovery of the link between paraquat and Parkinson’s and Syngenta’s coverup. See https://investigatemidwest.org/2024/10/23/herbicide-paraquat-sygenta-legal-troubles-parkinsons-disease-health-claims-lawsuits/; https://amp.theguardian.com/us-news/2022/oct/20/syngenta-weedkiller-pesticide-parkinsons-disease-paraquat-documents; https://amp.theguardian.com/us-news/2023/jun/02/paraquat-parkinsons-disease-research-syngenta-weedkiller.

I urge OIG to investigate whether registrants are reporting adverse health effects data and whether OPP is using the data in evaluating pesticide registrations.

Thank you.

(Beyond Pesticides, November 8-11, 2024) On Veterans Day 2024 we honor those who have served the country and allies. In the 117^th (2021-2022) U.S. Congress, legislators enacted The Sergeant First Class Heath Robinson Honoring Our Promise to Address Comprehensive Toxics Act of 2022 (PACT Act). Since the law passed just over two years ago, there has been just under 1.3 million total approved claims marking a roughly 75% approval rate for PACT Act related claims, according to Department of Veteran Affairs (VA) accounting of progress between August 10, 2022, and October 12, 2024 through its dedicated bimonthly VA PACT Act Performance Dashboard.

The legacy of toxic burn pits (open air areas where the military has burned toxic waste) and other avenues for toxic exposure in military bases oversees, as well as within the United States in Hawai’i (See coverage on asbestos exposure continuously impacting veterans, as reported on by Honolulu Civil Beat) and Puerto Rico (See peer-reviewed literature review here on toxic heavy metals in International Journal of Environmental Research and Public Health), among other areas, comes at a time when the country assesses the ongoing impacts of a history that has been characterized by critics as colonial or imperialist.

Environmental and public health advocates are galvanized by the successful rollout of the PACT Act and view it as a successful model that embodies the precautionary principle, given the “presumptive conditions” that immediately make applicants eligible based on their military service. Advocates have called upon Congress, White House, and the U.S. Environmental Protection Agency (EPA) to apply the criteria it set through “The Dacthal Standard” (See Daily News here) to suspend the registration of toxic pesticides, including atrazine and paraquat, and apply the standard of “presumptive conditions” to expanded funding and support for National Organic Program.

PACT Act Analysis

Environmental, public health, and veterans advocates welcome the impact of PACT Act funds for a systemically neglected subpopulation—veterans.

There are nearly 4.1 million current enrollees in PACT Act Planning Population (a metric used to “identify….the impact of the PACT Act on enrollment in VA health care”), underscoring the popularity of the program. Approximately $6.83 billion in PACT Act benefits have been paid to enrolled veterans between August 10, 2022 and August 6, 2024. VA has engaged in over 5.6 million toxic exposure screenings in that same period, with about one in ten toxic exposure screenings (525,914 screenings) where a veteran identified exposure to more than one toxic substance.

Since the law was enacted, there have been approximately 259,941 “New Enrollees in the PACT ACT Planning Population” (“measur[ing] the number of new enrollees in VA health care that fall within the PACT Act Planning Population to understand the impact of the PACT Act on enrollment.”) See VA Pact Act Anniversary Performance Dashboard here for further information on statistics, metrics, and definitions. Given that 13% of the adult homeless population are veterans according to National Coalition for Homeless Veterans analysis of U.S. Department of Housing and Urban Development (HUD) estimates for 2023 calendar year, advocates welcome the increase in enrolled veterans in their care programs as result of the PACT Act.

The law recognizes the toxic exposure from smoke and fumes generated from open burn pits. In Iraq, Afghanistan, and other areas of the Southwest Asia theater of military operations, open-air combustion of chemicals, tires, plastics, medical equipment, and human waste in burn pits was a common practice, according to VA. The Department of Defense says it has now closed most burn pits and is planning to close the remainder. President Biden has attributed his son’s death from brain cancer in 2015 to his exposure to burn pits in Iraq.

PACT Act has a long list of presumptive conditions for compensation and additional services for exposure to burn pits, as well as contaminated water, Agent Orange, and additional exposure-related presumptive conditions (see Military.com for expansive list here), including but not limited to:

• Cancers of the brain, head, neck, and nervous system
• Brain and nervous system disorders (i.e., Parkinson’s Disease)
• Sarcomas
• Spinal cord cancers
• Gastrointestinal cancers
• Kidney cancers
• Lymphomas
• Melanomas
• Pancreatic cancers
• Reproductive cancers
• Respiratory cancers
• Various non-cancer conditions (High blood pressure/hypertension, chronic obstructive pulmonary disease, pulmonary fibrosis, among others.)

Connection to The Dacthal Standard

Advocates believe that PACT Act’s success lends itself to the design of the legislation in establishing presumptive conditions for eligibility. EPA made history earlier this summer when they made the decision to ban the herbicide Dacthal or DCPA (dimethyl tetrachloroterephthalate) using the “imminent hazard” clause in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). What was already a nearly unprecedented move was the simultaneous accompanying decision to prohibit the continued use of existing stocks of the weed killer Dacthal, a provision that EPA also rarely uses. (See previous Daily News coverage on existing stocks orders for dicamba and chlorpyrifos.) In making its decision, EPA stated that the agency considered:

1. The seriousness of the threatened harm;
2. The immediacy of the threatened harm;
3. The probability that the threatened harm will occur;
4. The benefits to the public of the continued use of the pesticide; and
5. The nature and extent of the information before the Agency at the time it makes a decision.

Advocates acknowledge criteria set in “The Dacthal Standard,” as determined by EPA actions this year, demonstrate the agency’s potential to establish presumptive conditions for preventing further exposure to toxic pesticides to vulnerable subpopulations in the U.S. For example, EPA identified serious concerns about fetal hormone disruption and resulting “low birth weight and irreversible and life-long impacts to children [impaired brain development, decreased IQ, and impaired motor skills] exposed in-utero” and finds that there are no “practicable mitigation measures” to protect against these hazards. (See EPA Federal Register notice here.)

EPA has issued this emergency action just once before in its history. This was in 1979 when the agency acknowledged miscarriages associated with the forestry use of the herbicide 2,4,5-T—one-half of the chemical weed killer Agent Orange, which is one of the toxic substances covered under PACT Act for Vietnam War veterans.

Call to Action

THIS WEEK – Talk with Beyond Pesticides about creating a livable future: Attend Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency. The Forum launched on October 30 at 2-4pm (EDT) and will continue on November 14 at 1pm (EST). Tracey Woodruff, PhD, will be discussing the impact of petrochemical pesticides, fertilizers, and plastic linked to severe health consequences, including endocrine disruption. (See Daily News here.) 

The conversation will continue after Dr. Woodruff’s talk with a roundtable of remarkable people with a wealth of experience and insights into both the regulation of hazardous materials (including endocrine-disrupting chemicals) and strategies for connecting science (and the power of those adversely affected) to decisions that eliminate hazards—recognizing disproportionate risk to people of color. Tapping the experiences of the panelists, this discussion brings together strategic thinking that supports efforts by individuals and organizations to transition away from petrochemicals from a range of perspectives and a broadening of coalition efforts. 

The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the U.S., both (i) the hazards that define the urgency of threats associated with petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.  

Registration is complimentary, with contributions appreciated, and valid for all sessions of the Forum!   

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Department of Veterans Affairs

(Beyond Pesticides, November 7, 2024) Organic banana production is significantly more conducive to microbial decomposition than its chemical-intensive counterparts in the Caribbean nation of Martinique, according to a recent study published in Applied Soil Ecology. “Macrofaunal decomposition was increased more (55%) than microbial decomposition (20%), indicating that organic farming removes a constraint of conventional farming especially affecting macrofauna.” Biological activity in the soil is foundational to organic land management and critical to the cycling of nutrients that feed plant life while contributing to resiliency and soil water retention.

Bananas are one of the most highly consumed fresh fruits in the U.S. marketplace. A consumer survey conducted by the International Fresh Produce Association in 2023 identified 84% of households purchasing bananas that year. The U.S. Department of Agriculture (USDA) Economic Research Service identifies bananas as the third most consumed fruit product in the United States, with the average person eating 13.2 pounds that year.

Since bananas require specific bioclimatic conditions for commercial production that meets ongoing consumer demand, the proliferation of industrial-scale monoculture banana plantations in various Central and South American countries and territories has and continues to devastate local and Indigenous communities for generations. Environmental justice and public health advocates are invested in pushing for organic agricultural production to move beyond extractive systems that leverage toxic pesticide products at the expense of public health, biodiversity, and community well-being.

Study Analysis

Background and Goals

“Our study aims at improving knowledge on how organic farming affects litter decomposition in a tropical agroecosystem focusing on banana cropping systems in Martinique (Lesser Antilles),” says the study authors.

The authors hope to address an apparent gap in research surrounding the potential impact of organic farming on litter decomposition. In tropical areas with ideal bioclimatic conditions for banana production such as Martinique, “biological activity is supposed to be the driving force of decomposition process.” Therefore, the researchers focus on the impact of organic farming on microbial decomposers (i.e. fungi and bacteria) as well as macrofaunal decomposers (i.e. earthworms, isopods, gastropods, and diplopods).

As an extension of the main goal, researchers proposed two guiding questions to direct this study:

1. Does organic farming enhance litter decomposition in the banana cropping systems of Martinique?
2. Does glyphosate contamination of banana litter affect its decomposition in situ (in the original place)?

The study authors are researchers at the French Agricultural Research Centre for International Development, or Centre de coopération internationale en recherche agronomique pour le développement (CIRAD), a self-described “French agricultural research and cooperation organization working for the sustainable development of tropical and Mediterranean regions.” The authors received joint funding from the European Regional Development Fund and the Territorial Collectivity of Martinique for this study.

Methodology

The researchers gathered leaf litter samples from banana fields in two distinct bioclimatic zones in Martinique, “the South of Martinique” (South zone) and “central Martinique” (Central zone).

The South zone is known for a relatively dryer climate, Vertisol soil type, and lower mean average annual rainfall; the Central zone, meanwhile, is relatively more humid, Nitisol soil type, and higher average annual rainfall. To ensure uniformity in the data analysis and avoid confounding factors such as soil type in the South zone, the authors “restricted [the] study area to a plain sector with the same soil type, where we interviewed different farmers about their crop management, where [the researchers] interviewed different farmers about their crop management, [the researchers] selected three organic banana fields and three conventional banana fields having the same planting date, similar slope, soil tillage and field area (1.5 hectares/3.7 acres on average).”

Meanwhile, in the Central zone, “three organic banana fields and three conventional banana fields were selected on an experimental station managed like a farm within the BANABIO project [another CIRAD research initiative].” The fields in the Central zone were smaller than those in the South zone, with a mean area of 500 square meters per field. The authors note that “all fields were banana monocultures” of the Cavendish subgroup of the AAA banana cultivator group (Musa acuminata), the most commonly produced species available to consumers in the global marketplace.

To address the first research question, researchers considered various variables, including field shading by banana canopy, weed soil cover, plant species richness, and macrofaunal decomposer abundance and richness. Five sampling units were established for the South and three for the Central fields due to discrepancies in field size between the two zones. Earthworms (the indicator for macrofaunal decomposition) were hand-sorted and placed in three sampling units on each field. To address the second research question, the authors collected two batches of banana leaf litter samples from randomly selected plants in each field. The first batch was collected from plants injected with glyphosate, and the second batch was destroyed without the use of the pesticide. The leaves were dried outdoors for a week before falling to the ground and transported to the laboratory to quantify glyphosate and one of its degradation products, as well as carbon, nitrogen, and other mineral concentrations.

To test for leaf decomposition and compare rates between organic and conventional fields (as well as glyphosate and glyphosate-free leaf litter), the litter was gathered from randomly selected plants and placed into 264 litter bags on the soil surface of the 12 selected field sites. Seven control bags were placed in a banana field near the laboratory to best monitor the decomposition rates across both the Central and South zones. The bags had large and small mesh sizes to test the microbial versus macrofaunal contributions to decomposition. The “ash-free decomposition rate” was calculated for each bag to “correct this final dry mass for potential soil contamination in the litter.”

For further details, see the “Materials and Methods” section.

Main Conclusions

The authors arrived at the conclusion that there were notable differences in biological activity and soil health in organic versus non-organic fields. “Mean plant species richness was 55% significantly higher in organic fields and soil weed cover was 79% significantly higher in organic fields than in conventional fields,” says the researchers. The presence of earthworms, macrofauna, and other decomposers was far higher in organic fields. The nitrogen, calcium, and magnesium concentrations “were significantly higher” in glyphosate-free samples.

The type of farming practices and decomposition rate had a significant influence. “Overall litter mass loss was 24% significantly higher in organic compared to conventional fields,” says the researchers. Microbial decomposition was 20% higher in organic fields, with macrofaunal contribution 55% higher in organic fields relative to conventionally grown banana fields. This top-level finding is in alignment with other comparative analyses of decomposition rates of organic and conventional fields in the Netherlands and Ghana.

The researchers hypothesize the three main mechanisms contributing to greater litter decomposition in organic fields:

1. “[T]he toxicity of herbicides (especially glyphosate) on macrofauna decomposers in conventional fields.”
2. “[T]he stimulated microbial and macrofaunal activity due to organic fertilization in organic fields ().”
3. “[T]he beneficial effect of vegetation providing more microhabitats and favourable microclimate for both microorganisms and macrofauna, ().”

Toxic Legacy of Monoculture Banana Plantations

Human rights and environmental advocates consider the continuation of monoculture banana farms a matter of environmental injustice and racism that will also cause lasting public health and biodiversity damage.

In 2019, Central American agricultural workers exposed to the toxic pesticide Nemagon brought back lawsuits in French courts after previously failed attempts back in the 1980s. (See Daily News here). Those lawsuits were prevented from moving forward again in 2022 after the lawyer representing the affected workers shared that the courts “denied our claim because the judges had no jurisdiction over the [pesticide] companies.” This decision follows a precedent in which multinational companies do not face legal consequences for their actions due to arguments of jurisdiction. In 2009, U.S. District Judge Paul Huck said a multimillion-dollar judgment against U.S. food giant Dole and the Dow Chemical Company cannot be enforced because, “[T]he judgment was rendered under a system which does not provide impartial tribunal or procedures compatible with the requirements of due process of law, and the rendering court did not have jurisdiction over Defendants.” (See Daily News here.) Meanwhile, biodiversity and human health are impacted by chemical-intensive banana production as documented by previous Daily News here and here.

Call to Action

Demand for organic bananas is increasing significantly. According to data gathered by the International Federation of Organic Agriculture Movements (IFOAM) and Research Institute of Organic Agriculture (FiBL), bananas, soybeans, and sugar are the topmost imported organic products in the United States. “With more than 1.2 million metric tons and almost 44 percent of the Latin American and Caribbean organic exports, bananas are the most important product group,” says the report (See here.)

Session 1 of Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency, from October 30, can be viewed here. Session 2 of the Forum continues on November 14 at 1pm (EST). The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated with petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Applied Soil Ecology

(Beyond Pesticides, November 6, 2024) An analysis in the International Journal of Research Publication and Reviews emphasizes the role of biodiversity in agriculture, adding to a wide body of science on its importance. The authors, from Western Illinois University in the United States and Rome Business School in Italy, find that biodiversity supports critical ecosystems and organisms needed for sustainable food production. Through literature reviews and case studies, the interconnectedness of agriculture with plant and animal diversity, beneficial insects, soil health, and climate change is highlighted, as well as the need to manage land organically to support biodiversity.

Plant and Animal Diversity

As the researchers note, “A diverse agricultural system can better absorb shocks and maintain productivity, ensuring food security in the face of uncertainty.” A wide range of species present within ecosystems protects from changing environmental conditions and improves resilience. When farmers use monocultures for their crops, this leads to reduced ecosystem services from beneficial insects and increased vulnerability to pests and diseases. “By contrast, diverse cropping systems can enhance resilience, providing a buffer against environmental changes and fostering sustainable food production,” the authors say.

Research shows that higher plant diversity disrupts pest life cycles and promotes beneficial insects, which prevents farmers from relying on chemical inputs. Crop diversity also improves soil health. By having healthy soils, this “reduce[s] the need for chemical inputs while also providing habitats for beneficial organisms that help control pests and diseases.” Having a diverse range of crops, such as with polycultures and crop rotation, improves yield stability and creates a system with natural defenses against pests. This biodiversity also contributes to ecosystem services, such as pollination, nutrient cycling, and soil fertility, that are essential for agriculture.

The authors note that, “[I]n countries like Ethiopia and Kenya, smallholder farmers have integrated legumes and cover crops into their rotations. This not only enhances soil fertility through nitrogen fixation but also contributes to improved food security by providing multiple harvests throughout the year.” This promotes soil health while also supporting farmers and consumers.

A genetically varied population, for both crops and livestock, is “less susceptible to epidemics and can better withstand environmental stresses, such as extreme temperatures or feed shortages,” the researchers report. They continue, “Studies have shown that mixed-species cropping systems often yield higher overall productivity compared to monocultures, as different species can utilize resources (such as light, water, and nutrients) more efficiently. Additionally, diverse plantings can provide habitats for beneficial organisms, fostering a balanced ecosystem.”

Having plant diversity within a landscape also provides root mass and structure in the soil, which allows for greater water absorption and retention that helps both during periods of drought and in mitigating flooding during heavy rainfall. The authors share additional benefits in saying, “Diverse plant communities act as natural filters, capturing pollutants and nutrients before they can reach water bodies. For instance, buffer strips and cover crops can absorb excess nitrogen and phosphorus, thereby reducing nutrient runoff into rivers and lakes, which helps to prevent eutrophication.”

The researchers also find that the practice of integrating trees and shrubs into agricultural landscapes, known as agroforestry, enhances biodiversity, protects water resources, and improves soil structure. “In Brazil, agroforestry practices such as the integration of native trees with crops and livestock have been instrumental in restoring degraded lands and improving ecosystem health. For example, the ‘Sistema Agroflorestal’ (SAF) involves planting diverse species of trees alongside cash crops, which not only diversifies income sources but also enhances soil fertility and resilience against climate extremes,” the authors share.

Another case study in Costa Rica, which practices agroforestry through its Payment for Ecosystem Services (PES) program, “incentivizes farmers to maintain and enhance biodiversity on their lands. This program encourages practices that incorporate native tree species into agricultural landscapes, promoting habitat for wildlife and increasing carbon sequestration,” the researchers state.

Integrating several types of livestock can additionally improve land use. By having cattle, sheep, and poultry, nutrient management increases, and the various livestock, can graze and forage on the land, which supports carbon sequestration. “A diverse array of species within agroecosystems, from crops and livestock to soil organisms and pollinators, contributes to the stability, productivity, and adaptability of farming systems,” the authors say. By creating diverse populations on their land, farmers can increase the resilience and productivity of their farms.

Predatory Insects Crucial for Ecological Balance

An increase in natural predators, such as ladybugs, is seen in diverse ecosystems, which help control pest populations. These insects are better able to adapt to changing conditions and bring many benefits to landscapes. “For instance, ladybugs can consume thousands of aphids in their lifetime, providing significant pest control without the harmful side effects associated with chemical treatments,” the researchers note.

Pollinators are necessary for the reproduction of many crops and are drawn to landscapes with a variety of plants. The use of pesticides, such as neonicotinoids, endangers these critical species. (See Daily News here, here, and here.) As the authors share, “The loss of pollinators not only affects crop yields but also threatens the reproduction of many wild plant species, further exacerbating biodiversity loss.”

Populations of pollinators and other beneficial insects are facing what is known as the “insect apocalypse” as they are threatened with habitat loss, pesticide use, climate change, and diseases. This has led to a “decline in biodiversity, particularly in agricultural landscapes, [that] can exacerbate these threats by reducing the availability of food and nesting sites for pollinators. Restoring habitats and implementing practices that promote biodiversity, such as planting cover crops and creating wildflower strips, can enhance pollinator populations and, consequently, crop yields,” the researchers state. See more coverage on insect biodiversity here and here.

Soil Health

The foundation of sustainable agriculture begins with healthy soil. The soil microbes, including bacteria and fungi, underfoot provide essential functions in nutrient cycling, organic matter decomposition, and disease suppression, among others. Diversity in soil microorganisms helps maintain soil structure and fertility, which promotes healthy and resilient crops.

“Different microbial species have specialized roles in breaking down organic matter and transforming nutrients into plant available forms. For instance, nitrogen-fixing bacteria can convert atmospheric nitrogen into forms usable by plants, thereby reducing the need for synthetic fertilizers,” the authors write. “Feed the Soil, Not the Plant” is the mantra of organic land management. By focusing on soil health, other issues, such as pests and climate change, are also mitigated.

Climate Change

One of the major crises species are facing today is climate change. There is a vicious cycle of anthropogenic activities that exacerbate climate change, creating conditions that can further these activities even more. With climate change comes severe weather, such as droughts, floods, and heatwaves, that puts stress on food production. In these unfavorable conditions, a shift toward monocultures, as well as increased usage of pesticides and synthetic fertilizers, can occur as farmers struggle to maintain productivity, thus creating a treadmill effect.

Farmers with diverse ecosystems, however, “can buffer the impacts of climate change by providing microclimates that protect crops from extreme weather events,” the researchers share. “Resilient agricultural systems are characterized by diversity, adaptability, and efficient resource use, allowing them to maintain productivity and ecosystem services even under adverse conditions.”

Mitigation of climate change occurs through “enhancing soil health, conserving water, and fostering biodiversity, which collectively contributes to improved productivity and sustainability. Furthermore, resilient agriculture promotes economic stability for farmers and communities. By diversifying crops and employing sustainable practices, farmers can reduce their dependence on external inputs and navigate market fluctuations more effectively,” the authors state. See more on climate change here and here.

Farmers and Food Security

Farmers and farmworkers, who are pivotal in food production, also play a crucial role in biodiversity. Through the way they manage their land, farmers directly impact the health and resilience of ecosystems and act as stewards of biodiversity. Through their daily practices, farmers can either enhance or hinder the sustainability and resilience of agricultural landscapes. Agriculture has the ability to contribute to global food security in a changing climate in a positive way by integrating ecological principles into farming practices or creating a failing food system and barren environment.

Fostering biodiversity both above and below ground is vital for the longevity and health of both farming systems and the environment. The researchers postulate, “As agriculture faces increasing pressures from climate change and environmental degradation, prioritizing the conservation of biodiversity will be essential for securing the future of food systems worldwide.”

Organic Solution

Supporting biodiversity and mitigating climate change can be accomplished through organic land management. As part of a case study, the authors find that countries including Sweden, Germany, and France have already implemented extensive organic farming initiatives with success. As a result, these farms have improved soil health, increased species diversity, and greater ecosystem stability that supports food production.

The researchers say, “[B]iodiversity-driven resilience is essential for mitigating the impacts of climate change, pests, diseases, and resource scarcity, which pose significant threats to global food security. Agricultural systems rich in biodiversity benefit from improved soil fertility, enhanced pollination, natural pest control, and water regulation, all of which reduce dependence on external inputs such as chemical fertilizers and pesticides.”

Research also “indicates that organic farms typically support higher levels of biodiversity compared to conventional farms, with greater abundance and variety of species, particularly in wild plants and insects.” In another case study, organic vineyards in France show more resilience to drought conditions due to better water retention and improved soil health. See more on higher production in organic systems here.

“In summary, the path toward sustainable food production hinges on recognizing the vital role of biodiversity in agriculture. By adopting holistic and integrated approaches that prioritize biodiversity, we can build resilient agricultural systems capable of meeting the challenges posed by a changing world,” the authors conclude. “The future of food security, environmental health, and sustainable agriculture is intertwined with our commitment to preserving and enhancing biodiversity in all its forms. It is imperative that we act now to protect these vital resources for generations to come.”

Take action to ensure that organic programs, and their funding, do not lapse this fall and sign up to receive Beyond Pesticides’ Action of the Week and Weekly News Updates delivered right to your inbox. Encourage your community to transition to organic land management by becoming a Parks Advocate through the Parks for a Sustainable Future program and stay apprised of the latest pesticide science and policy through the Daily News Blog.

Plan to attend Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future! Thank you to all who attended our launch on October 30—the recording is LIVE on our website as of November 5, 2024! The second session will continue on Thursday, November 14, 2024, at 1 PM (EST) with Tracey Woodruff, PhD, MPH, the director of the Program on Reproductive Health and the Environment (UCSF). Dr. Woodruff’s work focuses on uncovering and addressing environmental determinants of disease and health inequities and has written groundbreaking material on endocrine-disrupting chemicals. Registration is complimentary, with contributions appreciated, and is valid for all sessions of the 2024 National Forum! 

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source:

Christianah, D. and Folarin, I. (2024) The Role of Biodiversity in Agricultural Resilience: Protecting Ecosystem Services for Sustainable Food Production, International Journal of Research Publication and Reviews. Available at: https://www.researchgate.net/publication/384848907_The_Role_of_Biodiversity_in_Agricultural_Resilience_Protecting_Ecosystem_Services_for_Sustainable_Food_Production.

(Beyond Pesticides, November 5, 2024) Published in the journal Frontiers in Toxicology, a recent study uncovers serious flaws in the pesticide registration process at the U.S. Environmental Protection Agency (EPA) with an in-depth evaluation of the agency’s failure to protect the public from the harmful effects of five neonicotinoid (neonic) insecticides—as mandated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and amendments, including Food Quality Protection Act (FQPA) of 1996. This coincides with EPA’s ongoing review to renew their approval for the next 15 years (set to be announced in 2025). The report is based on the first comprehensive assessment of unpublished rodent-based Developmental Neurotoxicity (DNT) studies, conducted between 2000-2003 and submitted by pesticide manufacturers as part of the registration process.

All five neonicotinoids evaluated—acetamiprid, clothianidin, imidacloprid, thiacloprid, and thiamethoxam—are associated with significant shrinkage of brain tissue at the highest dosage, according to EPA data reports (see acetamiprid, clothianidin, imidacloprid, thiacloprid, and thiamethoxam). However, with little or no data regarding the chemicals’ impacts at low and mid-level dosages, EPA has either failed to find a “No Observed Adverse Effect Level” (NOAEL) or, seemingly at random, set the NOAEL at the mid-level dosage. The evaluation suggests that perinatal exposure to neonicotinoids and their metabolites results in nicotine-like neurotoxic effects in rodent studies, concluding that, “… the exposure limits set by EPA for human exposure are either not protective or not supported by available neurotoxicity data.” The study also finds that the agency ignored significant adverse effects, allowed DNT studies that did not conform with scientific protocols, and permitted “neonicotinoid registrants to unduly influence agency decision-making.” 

[The research was conducted by Jennifer Sass, PhD, senior scientist at Natural Resources Defense Council; Nathan Donley, PhD, environmental health science director at the Center for Biological Diversity; and, Bill Freese, science director at the Center for Food Safety. A press release on the evaluations notes, “Our study contributes to the growing body of evidence suggesting that neonicotinoids are hazardous to the developing human nervous system and should be avoided just as mothers abstain from smoking during pregnancy. EPA must act to reduce the use of and human exposure to these toxic insecticides.”]

While the authors conclude that EPA regulatory changes are needed to better protect public health from developmental neurotoxic neonicotinoids, many public health and environmental advocates interpret the results as a signal—a need for a major shift that questions the registration of harmful pesticides, which can be replaced by organic management practices and organic-compatible production inputs. These advocates point to the study’s findings as identifying a fundamentally broken regulatory system in the face of the existential health, biodiversity, and climate crises stemming from petrochemical pesticide use, including highly toxic neonicotinoid insecticides. [Additionally, read more about recent U.S. Supreme Court decisions impacting environmental regulatory authority here: Daily News on Chevron decision, Daily News on Sackett decision, and the Clean Water Act here].

Background

Neonics are among the most widely used insecticides in the world, with the most common form of application as a treatment of seeds before dispersal. According to the report, at least 150 million acres were planted with neonic-treated seeds in 2012, which is six times the amount of land treated with the top ten insecticides combined in 2001. Outside of agricultural applications, neonics are commonly applied to parks and gardens, to pets as a flea treatment, and to control bed bug infestations. The result of such widespread use has led to rampant contamination in the food supply, human breast milk, and amniotic and cerebrospinal fluids. (See here, here, and here). Neonicotinoids have been linked to breast cancer by stimulating excess estrogen production, known to occur during the development of progressive hormone-dependent breast cancer. Due to their widespread use, neonicotinoids commonly contaminate water sources, including rivers and groundwater. This cumulative presence suggests, according to the authors, that children may be exposed at multiple developmental stages, including prenatally, through breastfeeding or formula mixed with contaminated tap water, and during childhood through food and water consumption. Given the likelihood of exposure, the authors argue that it is essential to sustain and enhance monitoring programs that identify pesticide residues in food, water, and biological samples. Furthermore, to address regular exposure to neonicotinoids, especially during critical early life stages, the study results suggest that risk assessments and regulatory decisions must adhere to (and ideally surpass) the safety standards established by current federal pesticide regulations.

EPA employs DNT studies with rodents under established guidelines (see here and here) to evaluate the risks that pesticides may pose during the early development of the brain and nervous system, determine dose-response relationships, and set regulatory exposure limits. The agency then, based on the data provided, sets acute (short-term) and chronic (long-term) exposure limits by identifying a No Observed Adverse Effect Level (NOAEL). A 100-fold uncertainty factor is then applied to the NOAEL to account for differences between animals and humans and the uncertainty associated with individual variability in humans. However, this approach does not fully consider the increased vulnerability of the developing brain when exposure occurs during fetal growth or infancy. These stages are critical periods when the brain’s structure is being formed via cell growth, differentiation, axon and synapse development, and cell migration. This damage is often irreversible due to the limited capacity for repair during these complex and fragile developmental processes.

FQPA mandates that EPA consider the increased susceptibility of infants and children, including differences in neurological development and potential in-utero exposure to pesticides, to ensure “reasonable certainty of no harm” from all forms of pesticide exposure, including dietary and other known sources. A protective, although arbitrary, measure of FQPA is the 10X-fold child safety factor, which aims to reduce permissible exposure levels to account for children’s vulnerability to developmental toxins. Additionally, FQPA requires cumulative risk assessments for pesticides with shared mechanisms of toxicity. By law, EPA can reduce or eliminate this safety factor only if reliable data demonstrate that doing so would not compromise the safety of infants and children. Despite this mandate, EPA has often reduced or removed the child safety factor in its pesticide evaluations, including for neonicotinoids. (See here, here, and see Daily News for one recent example of EPA failure to apply children’s safety factor here, specific to acephate).

Study Methodology

The report evaluates EPA’s Data Evaluation Records, in which data for five unpublished DNT studies with highly defined protocols were previously analyzed by EPA staff. (After feeding female rats different doses of pesticides during pregnancy and lactation, labs contracted by pesticide manufacturers administer a variety of morphological, neurological, and behavioral tests from birth to 60 days old).

Among the many irregularities that the report identifies:

• Contrary to DNT guidelines, the agency received no or partial data related to mid- and low-dosage groups. Despite the lack of evidence, EPA concluded that the five neonics only offered negative effects at the high-dose level.
• When presented with highly variable data from Nippon Soda in 2003 regarding impacts from acetamiprid, EPA at first rejected the application. However, after a secondary appeal by the manufacturer, the agency overruled its own conclusions. In 2008 and again in 2017, EPA raised the NOAEL, eventually reaching 40 times the level proposed by the European Food Safety Authority.
• In a 2000 DNT by Takeda Chemical Industries for clothianidin, EPA found the application to be missing data for low- and mid-dose tests. Even though the data was never submitted, and the study remains classified as “deficient,” EPA set the NOAEL at the mid-dose level.
• Similarly in 2001, Bayer conducted a DNT for imidacloprid where no information was provided for the mid- and low-dose categories. Nevertheless, EPA set the NOAEL at the mid-dose level.
• In 2001, Bayer’s DNT study of thiacloprid identified a reduction in brain weight significantly at the high- and mid-doses, while the age of male sexual maturation was delayed at all dose levels. However, EPA determined that only the high-dose effects were related to pesticide exposure and set the NOAEL at the mid-dose level.

Together, the report highlights a pattern of poor scientific practices and unjustified conclusions, with EPA making determinations contrary to the recommendations of the agency’s own scientists. For four of the five studies included in this analysis, appropriate data was either not received or not fully evaluated by EPA. EPA also identified study deficiencies including inadequate testing and reporting but failed to require any follow-up studies or data.

Meanwhile, pesticide registrants (manufacturers) face no consequences for failing to supply missing or inadequate data. “These are extremely disturbing findings that expose an agency strong-armed by pesticide makers into ignoring glaring problems with critical safety assessments,” notes Dr. Donley in a press release. “When the agency charged with protecting us all from harmful poisons doesn’t even require the necessary data to determine significant health risks, its pesticide approvals simply can’t be trusted as scientifically valid.”

Developmental Neurotoxicity Studies: Future Approaches

While DNT studies allow for evaluating potential risks to brain development, the studies require proper design and oversight, as well as improvements to enhance their sensitivity, particularly in cognitive function assessments. The authors’ review of positive control studies (tests using chemicals known to affect neurological development) found significant deficiencies. For example, in four of the five DNT studies reviewed (excluding clothianidin), positive control data was missing or not fully evaluated by EPA. For thiacloprid, EPA noted that no study adequately demonstrated the lab’s capability to detect key neurotoxic effects.

Rather than updating rodent DNT methods to enhance their rigor and sensitivity, EPA’s Office of Pesticide Programs is moving toward using New Approach Methodologies (NAMs), like in vitro assays and in silico models. This approach uses a lack of bioactivity in NAMs as proof of safety, leading to less protective risk assessments for some pesticides. These methods are favored for their cost-effectiveness, faster results, and reduced animal use; however, in vivo DNT studies currently have no equivalent substitutes. Critics, including health experts and regulatory scientists, argue that this new methodology undermines public health. (See here and here).

The Organisation for Economic Co-operation and Development (OECD) recently reviewed in vitro DNT tests (using NAMs) and highlighted significant gaps in assessing neurodevelopmental processes, such as neuroectoderm formation, peripheral nervous system processes, and astrocyte maturation, among others. Similarly, the European Partnership for the Assessment of Risks from Chemicals (PARC) concludes that existing NAMs do not adequately assess cognitive and neurobehavioral outcomes or learning and memory.

Recommendations for Regulatory Improvement

The study recommends that to enhance the quality of rodent DNT and other toxicology studies, EPA should reject severely flawed studies, enforce data submissions, and suspend or deny approvals of pesticides when data is insufficient or unreliable.

• Require DNT Studies: EPA should mandate DNT studies for pesticide registrations, as recommended in 1999, reversing the trend of granting study waivers.
• Lower Exposure Limits for Neonicotinoids: Given their established neurotoxicity, neonicotinoids’ exposure limits should be reduced tenfold to protect developing nervous systems, per FQPA.
• Conduct Cumulative Risk Assessments: Since neonicotinoids share toxic mechanisms with nicotine, EPA should assess cumulative risks and assign relative potency factors for each compound.
• Retain the FQPA 10X Child Safety Factor: EPA should only reduce this safety factor when supported by reliable data, especially given NAMs’ limitations and existing uncertainties.

Unpublished, manufacturer-submitted rodent-based studies show, via the report, that neonics can disrupt mammalian brain development, like nicotine. Early exposure reduced brain region sizes, implying neuronal cell loss and diminished neurogenesis. Affected regions like the corpus callosum and caudate putamen may also be linked to attention-deficit/hyperactivity disorder (ADHD). The analysis also shows impaired auditory startle responses and possible effects on learning and memory. The authors conclude that further research is needed on neonics and their nicotine-like metabolites, given their widespread use and potential for lasting harm. While NAMs offer insights into cellular mechanisms, they cannot currently replace the value of well-designed in vivo studies for understanding complex neurodevelopmental impacts.

As a principle, Beyond Pesticides urges a systemic move toward the adoption of proven organic systems that do not use neonicotinoids and other toxic synthetic pesticides. Organic practices and products also address current existential crises, including microbial support for ecosystem health, and biodiversity. To stay informed on upcoming pesticide regulatory decisions and take action, click here to sign up for updates from Beyond Pesticides via our listserv.

***
Plan to attend Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future! Thank you to all who attended our launch on October 30—the recording is LIVE on our website as of November 5, 2024! The second session will continue on Thursday, November 14, 2024, at 1 PM (EST) with Tracey Woodruff, PhD, MPH, the director of the Program on Reproductive Health and the Environment (UCSF). Dr. Woodruff’s work focuses on uncovering and addressing environmental determinants of disease and health inequities and has written groundbreaking material on endocrine-disrupting chemicals. Registration is complimentary, with contributions appreciated, and is valid for all sessions of the 2024 National Forum! 

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Sources:

Neonicotinoid pesticides: evidence of developmental neurotoxicity from regulatory rodent studies, Frontiers in Toxicology, October 1, 2024

EPA Set to Greenlight Widely Used Neonicotinoid Pesticides, Overlooking Evidence of Harms to Brain, Nervous System, Press release, Center for Biological Diversity, Center for Food Safety, October 22, 2024

Poisoned Waterways: The Same Pesticide that Is Killing Bees Is Destroying Life in the Nation’s Streams, Rivers, and Lakes, Beyond Pesticides, Pesticides and You, Spring 2017

Sowing Uncertainty: What We Do and Don’t Know about the Planting of Pesticide-Treated Seed, BioScience, March 18, 2020

Schedule for Review of Neonicotinoid Pesticides, EPA website

Initial Recommendations on Evaluation of Data from the Developmental Neurotoxicity (DNT) In-Vitro Testing Battery, OECD Environment, Health and Safety Publications Series on Testing & Assessment No. 377, Organisation for Economic Co-operation and Development, November 3, 2023

New Approach Methodologies (NAMs): Scientific Challenges and Potential Solutions, presentation by Dr. Raashmi Joklekar, UCSF, and Dr, Jennifer Sass, NRDC, EPA documents, February 14, 2024

(Beyond Pesticides, November 4, 2024) The U.S. Environmental Protection Agency (EPA) last week opened a public comment period on the regulation of endocrine-disrupting pesticides, a proposal that lays out a drawn-out 10-year process that is narrow in evaluating the underlying mechanism that causes endocrine disruption. The proposal, published in the Federal Register as a partial settlement agreement and consent decree, responds to a lawsuit filed by farmworker and health groups challenging the agency’s failure to test and regulate endocrine-disrupting pesticides. Earlier in the year, after over 25 years of delay following the 1996 Congressional mandate to determine whether pesticides disrupt the endocrine system of humans and other organisms, EPA issued a proposal for modifying its approach to the implementation of the Endocrine Disruptor Screening Program (EDSP). 

The National Institutes of Environmental Health Sciences explains endocrine disruptors this way: “Endocrine-disrupting chemicals (EDCs) are natural or human-made chemicals that may mimic, block, or interfere with the body’s hormones, which are part of the endocrine system. These chemicals are associated with a wide array of health issues. . . Endocrine glands, distributed throughout the body, produce the hormones that act as signaling molecules after release into the circulatory system. The human body is dependent on hormones for a healthy endocrine system, which controls many biological processes like normal growth, fertility, and reproduction. Hormones act in extremely small amounts, and minor disruptions in those levels may cause significant developmental and biological effects.” The Endocrine Society has written, “Many pesticides are designed to be toxic to pests’ nervous or reproductive systems and may act by disrupting endocrine systems. Such chemicals are also EDCs because of the similarities between insect and animal endocrine systems.” The data is available to regulators, who have allowed endocrine-disrupting pesticide exposure for decades to people and families whose lives have been upended and often destroyed by deadly diseases that are preventable and chemicals that can be replaced by alternative practices and products, according to health and environmental advocates. A 2011 article, Effect of Endocrine Disruptor Pesticides: A Review (2011), found: “Many chemicals that have been identified as endocrine disruptors are pesticides. About 105 substances can be listed, and most of them are shown in Table 1. Of these, 46% are insecticides, 21% herbicides, and 31% fungicides; some of them were withdrawn from general use many years ago but are still found in the environment (ex. DDT and atrazine in several countries).” Meanwhile, it is estimated that 90% of breast cancer, the most common form of cancer for women worldwide, is due to nongenetic factors including endocrine-disrupting pesticides. (See Daily News.) 

EPA’s February 2024 proposal, according to Beyond Pesticides, is an abrogation of the agency’s responsibilities under the 1996 Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA) as well as the underlying statute, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the Safe Drinking Water Act (SDWA). Limiting the scope of the EDSP to humans, certain pesticide active ingredients only, and limiting the types of data to assess endocrine disruption (ED) effects runs counter to the Congressional intent and requirements in these statutes. It is also a reversal of the Endocrine Disruptor Screening and Testing Advisory Committee’s (EDSTAC) advice and the agency’s original EDSP implementation policy and science decisions.

EPA’s October proposal sets deadlines by which EPA will implement EDSP requirements and assess some of the endocrine-disrupting effects of pesticides. CFS, which serves as counsel for the plaintiffs, including Alianza Nacional de Campesinas, Pesticide Action Network North America, Rural Coalition, Center for Environmental Health, and Organización en California de Líderes Campesinas, says, “Under the terms of the proposed agreement, over the next five years, EPA will collect data on and assess the effects of endocrine-disrupting pesticides, either as part of the agency’s registration review of registered pesticides or as a part of new pesticide approvals. To maximize protection of farmworker and public health, the proposed agreement provides opportunities for farmworker input on prioritizing certain pesticides and requires EPA to provide regular public updates on the status of their ongoing assessment. Per the agreement, EPA will complete endocrine-disrupting assessment for 86 pesticides over the next 10 years.”

While it can be argued that this is the best that can be done under existing federal law, the settlement represents another generation of exposure to endocrine disruptors in air, water, landscapes, and food—chemicals that cause breast cancer, neurological, immunological and reproductive effects, developmental effects, learning disabilities, and a range of effects (many multigenerational) that adversely affect most organ systems. The agreement affirms that the public is not protected and should urgently shift away from a reliance on synthetic pesticides in food production, gardening, and landscape management. For more background, see here, here, here, and here. Also, see the Pesticide-Induced Diseases Database (PIDD) section on endocrine disruptors.

While the consent decree does commit EPA to test for estrogenic effects in conventional pesticide active ingredients, it falls far short of addressing the full range of endocrine disrupting effects of all pesticide ingredients, as is required to protect human health and the environment. The February 2024 comments of Beyond Pesticides detail these requirements. In addition, the only recourse it gives the plaintiffs is to resume the litigation if EPA fails to deliver on its agreement.

Under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk.

OPPORTUNITY FOR TWO ACTIONS
1. Tell EPA that it must consider complete all data concerning endocrine disruption and must not register pesticides without sufficient data to demonstrate no unreasonable adverse endocrine risk.
AND
2. Tell Congress to ensure that EPA follows through! EPA must not register pesticides without sufficient data demonstrating no endocrine disruption.

EPA cannot develop a strategy for evaluating pesticides without understanding the history and status of endocrine disruption research, which are summarized in Beyond Pesticides’ comments and the October 29, 2024 Daily News. Evidence that synthetic chemicals can mimic or otherwise interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it soon became apparent that the homeostatic function of the endocrine system—which regulates and balances physiological functions—can be disrupted at many sites and hormone systems.

Endocrine disruption as a phenomenon affecting humans and other species has been critically reviewed by several authors. A common thread weaving across these reviews is the understanding that chemicals that may disrupt the endocrine systems of humans and wildlife may be pervasive in contaminating their habitats. A pandemic of endocrine-related disorders from attention deficit and hyperactivity disorder (ADHD), autism, diabetes, obesity, childhood and breast cancers, testicular cancer in young men, infertility, male dysgenesis syndrome, hypospadias, low sperm count, loss of semen volume and sperm quality, and increased risk of testicular and prostate cancer can be connected with endocrine-disrupting chemicals (EDCs). All these disorders have been increasing in incidence and can be traced back to prenatal exposure to EDCs.

Endocrine pathways are largely conserved across species and, thus, are not species- or taxa- specific. It is well known that thyroid endocrinology in particular is well conserved across vertebrate taxa. This includes aspects of thyroid hormone synthesis, metabolism, and mechanisms of action. Thyroid hormones are derived from the thyroid gland through regulation of the HPT axis, which is controlled through a complex mechanism of positive and negative feedback regulation. Multiple pathways contribute to the synthesis of thyroid-releasing hormone, including thyroid hormone signaling through feedback mechanisms; leptin and melanocortin signaling; body temperature regulation; and cardiovascular physiology. Each pathway directly targets thyroid-releasing hormone neurons. Based on the conservation of endocrine pathways, it is well understood that the ecological assays (the frog assay in particular) are often more sensitive and equally relevant to mammalian assays in informing risk assessors of whether a chemical can perturb and cause adverse endocrine outcomes in the human population and vice versa.

FQPA essentially amends FIFRA and FFDCA to ensure potential endocrine-disrupting effects are considered in EPA risk assessments to fulfill the FIFRA mandate that a pesticide registration will not cause unreasonable adverse effects. This applies to humans, wildlife, and all pesticide chemicals as defined in FIFRA, including “all active and pesticide inert ingredients of such pesticide” (21 U.S.C. 231(q)(1)). SDWA adds drinking water contaminants as well.

In summary, the agency cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements enumerated in FIFRA, FQPA, and SDWA. EPA should make use of all available scientifically relevant endocrine disruption research findings and also be wary of deviating from established international efforts for screening/testing endocrine disruptors that incorporate human and wildlife-relevant studies. Recognizing that mammalian data inform potential endocrine disruption in other vertebrate taxa (avian, amphibian, fish) and vice versa, the agency should not decouple the mammalian from other vertebrate assays in EDSP screening. There are more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development (OECD) Conceptual Framework for screening/testing endocrine disrupting effects, and there are additional assays being developed for consideration as well. So, the agency should not limit the range or types of data to be used, but as FQPA prescribes use “appropriate validated test systems and other scientifically relevant information.”

Even if currently required data—including the limited data required under this proposed partial settlement—meet the needs of human risk assessment, they are inadequate to evaluate endocrine effects on wildlife species. It should also be understood that under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk per the mandate in FIFRA. Further, it is not the agency but pesticide registrants that have the burden to demonstrate with adequate data that their products will not pose unreasonable adverse effects, including the inherently presumed endocrine-disrupting effects.

***
With a focus on endocrine disruption, plan now to attend Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future! Thank you to all who attended our launch on October 30—stay tuned for a recording! The second session will continue on Thursday, November 14, 2024, at 1 PM (EST) with Tracey Woodruff, PhD, MPH, the director of the Program on Reproductive Health and the Environment, University of California, San Franisco (UCSF). Dr. Woodruff’s work focuses on uncovering and addressing environmental determinants of disease and health inequities and has written groundbreaking material on endocrine-disrupting chemicals. Registration is complimentary, with contributions appreciated, and is valid for all sessions of the 2024 National Forum!

>> Tell EPA that it must consider complete all data concerning endocrine disruption and must not register pesticides without sufficient data to demonstrate no unreasonable adverse endocrine risk.

Letter to the U.S. Environmental Protection Agency
The endocrine disruptor strategy (EDSP) proposed under the consent decree abrogates EPA’s responsibilities under the Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and Safe Drinking Water Act (SDWA). While the proposed consent decree commits EPA to test for estrogenic effects in conventional pesticide active ingredients, it falls far short of addressing the full range of endocrine-disrupting effects of all pesticide ingredients, as is required by FIFRA to protect human health and the environment. Limiting the scope of the EDSP to humans, certain pesticide active ingredients only, and limiting the types of data to assess endocrine disruption (ED) effects is contrary to the Congressional intent and requirements in these statutes and reverses Endocrine Disruptor Screening and Testing Advisory Committee advice and EPA’s original EDSP implementation policy and science decisions.

Evidence that synthetic chemicals can interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it was soon apparent that the homeostatic function of the endocrine system can be disrupted at many sites and hormone systems.

Many authors have documented the pervasiveness of endocrine-disrupting chemicals (EDCs) in the ecosphere. A pandemic of endocrine-related disorders—ADHD, autism, diabetes, obesity, childhood and breast cancers, testicular cancer in young men, infertility, male dysgenesis syndrome, hypospadias, low sperm count, loss of semen volume and sperm quality, and increased risk of testicular and prostate cancer—may be related to EDCs.

Endocrine pathways are largely conserved across species and thus are not species- or taxa-specific. It is well understood that the ecological assays (e.g., the frog assay) are often more sensitive and equally relevant to mammalian assays in determining whether a chemical can perturb and cause adverse endocrine outcomes in the human population and vice versa.

Thus, EPA cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements of FIFRA, FQPA, and SDWA. EPA must use all available scientifically relevant endocrine disruption research findings and avoid deviating from established international efforts that incorporate human and wildlife studies. Recognizing that mammalian data inform potential endocrine disruption in other vertebrates (avian, amphibian, fish) and vice versa, the agency must not decouple the mammalian from other vertebrate assays in EDSP screening. With more than 50 different ecological and mammalian assays included in the Organization of Economic Cooperation and Development Conceptual Framework for screening/testing endocrine disrupting effects and additional assays in development, EPA must not limit the range or types of data to be used, but as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” Even if currently required data—including the limited data required under this proposed partial settlement—meet the needs of human risk assessment, they are inadequate to evaluate endocrine effects on wildlife species.

FQPA amends FIFRA to ensure potential endocrine-disrupting effects are considered in risk assessments to fulfill the FIFRA mandate that pesticide use will not cause unreasonable adverse effects. This applies to humans and wildlife and to all pesticide chemicals as defined in FIFRA including all active and inert ingredients. Under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If EPA is unable to fully evaluate endocrine risks to human health and wildlife, then the agency must suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk.

Thank you.

>> Tell Congress to ensure that EPA follows through! EPA must not register pesticides without sufficient data demonstrating no endocrine disruption.

Letter to Congress
Plaintiffs and the Environmental Protection Agency have tentatively agreed on a consent decree describing an endocrine disruptor strategy (EDSP) to meet EPA’s responsibilities under the Food Quality Protection Act/Federal Food, Drug, and Cosmetic Act (FQPA/FFDCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and Safe Drinking Water Act (SDWA). While the proposed consent decree commits EPA to testing for estrogenic effects in conventional pesticide active ingredients, it falls far short of addressing the full range of endocrine disrupting effects of all pesticide ingredients, as is required by FIFRA to protect human health and the environment. Limiting the scope of the EDSP to humans, certain pesticide active ingredients only, and limiting the types of data to assess endocrine disruption (ED) effects is contrary to the Congressional intent and requirements in these statutes and reverses Endocrine Disruptor Screening and Testing Advisory Committee advice and EPA’s original EDSP implementation policy and science decisions.

Evidence that synthetic chemicals can interfere with natural hormones has existed for over half a century. Although early attention was given to estrogen mimics, it was soon apparent that the homeostatic function of the endocrine system can be disrupted at many sites and hormone systems.

Many authors have documented the pervasiveness of endocrine-disrupting chemicals (EDCs) in the ecosphere. A pandemic of endocrine-related disorders—attention deficit and hyperactivity disorder (ADHD), autism, diabetes, obesity, childhood and breast cancers, testicular cancer in young men, infertility, male dysgenesis syndrome, hypospadias, low sperm count, loss of semen volume and sperm quality, and increased risk of testicular and prostate cancer—may be related to EDCs.

Endocrine pathways are largely conserved across species and thus are not species- or taxa- specific. It is well understood that the ecological assays (e.g., the frog assay) are often more sensitive and equally relevant to mammalian assays in determining whether a chemical can perturb and cause adverse endocrine outcomes in the human population and vice versa.

Thus, EPA cannot limit EDSP to only humans and conventional pesticide active ingredients without violating the statutory requirements of FIFRA, FQPA, and SDWA. EPA must use all available scientifically relevant endocrine disruption research findings and avoid deviating from established international efforts that incorporate human and wildlife studies. More than 50 different ecological and mammalian assays are included in the Organization of Economic Cooperation and Development Conceptual Framework for screening/testing endocrine disrupting effects and additional assays in development, so EPA must not limit the range or types of data to be used, but as FQPA prescribes, use “appropriate validated test systems and other scientifically relevant information.” They must be adequate to evaluate endocrine effects on wildlife species as well as humans.

FQPA amends FIFRA to ensure potential endocrine-disrupting effects are considered in risk assessments to fulfill the FIFRA mandate that pesticide use will not cause unreasonable adverse effects. This applies to humans and wildlife and to all pesticide chemicals as defined in FIFRA including all active and inert ingredients. Under FIFRA, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If EPA is unable to fully evaluate endocrine risks to human health and wildlife, then the agency must suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk.

Please ensure that EPA carries out its statutory responsibilities.

Thank you.

(Beyond Pesticides, November 1, 2024) In a study published earlier this year in Soil Science Society of America Journal, researchers at Kansas State University document direct evidence that organic amendments (e.g., manure and compost) in a no-till agricultural system “facilitat[e] microbial diversity” that cycles plant-available nutrients.

The study was published just as farmers are looking for less expensive practices that support the economic vitality of their farms amid surging prices for petrochemical pesticides and fertilizers and as agricultural support programs are threatened by unresolved issues in Farm Bill talks on Capitol Hill. [See the recent Action of the Week calling on Congress to take action.] Simultaneously, awareness is growing among environmental and public health advocates about the importance of soil health to ecosystem stability in combatting climate change-induced natural disasters and stopping plummeting biodiversity. Demands for new systems rooted in organic principles and land management practices continue to become more widely recognized by farmers, environmentalists, and the broad public. The study adds to earlier findings and contributes to the body of scientific literature on soil health and its importance to ecosystem and human health.

Methodology and Results

The study was led by researchers at Kansas State University specializing in agronomy and chemistry. “The primary aim of this study was to determine soil carbon stabilization mechanisms (in situ) in free soil microaggregates (), collected from a differently managed temperate agroecosystem (no till with N [nitrogen] treatments: manure/compost, urea, and zero fertilizer) by gathering direct evidence using STXM-NEXAFS [near-edge X-ray absorption fine structure spectrometry], while incurring minimal disturbance to the original aggregate microstructure,” say the researchers.

Researchers used STXM-NEXAFS and chemical analysis to aggregate a holistic view of soil health based on soil biology and chemistry. The soil samples were collected in February 2012 from a corn farm established in 1990. [To preserve microbial life in soil samples, researchers confirmed the samples were refrigerated as soon as they were brought in for eventual testing at the Advanced Light Source, Lawrence Berkeley Laboratory, as consistent with other soil health studies led by Professor Ganga M. Hettiarachchi, Ph.D, Professor of Soil and Environmental chemistry at Kansas State University. See here and here.]

Before this, the site was cultivated for grain production (e.g., wheat, oats) for over sixty years. Each sample was gathered at a depth of 0-5 centimeters in 15-20 locations across each plot. “This experiment was established as a split-plot randomized complete block design with four blocks. Main plots represented tillage (conventional till [] and no-till [NT]), and sub plots () were control (no external input), organic amendments/fertilizer (manure/compost), and inorganic fertilizers (urea),” the researchers go on to describe the parameters of the experiment. “In this study, we focused on no-till control, no-till organic amendments/fertilizer, and no-till inorganic fertilizer treatment combinations.”  

The researchers analyzed the carbon, calcium, iron, aluminum, and silicon clusters in the soil samples at a microscopic level. They arrived at the following four main conclusions after analyzing the three soil microaggregates:

1. Direct evidence provided the positive impact of organic amendments on carbon stabilization in free soil microaggregates;
2. Microbial-derived carbon was found in microaggregates from manure-/compost-added soils;
3. Continuous addition of organic amendments enhances organic carbon (OC) stabilization in soil microaggregates; and
4. Integrated approach of STXM-NEXAFS, C-NMR [Carbon-13 nuclear magnetic resonance], and wet chemistry improved our mechanistic understanding.

The investigation of chemical, biological, and environmental impacts of organic amendments, such as manure and compost, resonates with organic advocates who are dedicated to moving beyond synthetic fertilizer products as an immediate fix to mineral deficiencies on their farmland. Carbon stabilization is only sustainable in a healthy soil system. Therefore, the presence of microbial life is an indication that the necessary checks and balances are in place to draw down atmospheric carbon further into the soil ecosystem, rather than leaching into the atmosphere. Organic matter, including compost and manure, is a powerful carbon stabilizer that provides a binding material for other necessary minerals to remain in the soil for crop and plant intake. 

Soil Health Benefits of Organic Agriculture

Organic advocates acknowledge the surge in academic, popular, and farmer interest in organic land management practices and principles as an important expansion to existing research identifying the soil health impacts of agrochemical products.

For example, peer-reviewed scientific research going back to 2004 establishes a direct relationship between deleterious glyphosate-based herbicides and soil health conditions. A 2022 paper published in Trends in Ecology & Evolution asserts the widespread environmental contamination with these herbicide compounds is influencing soil, plant, and animal microbiomes in ways that are not only not well understood, but also can have significant impacts on the functioning of organisms and their ecosystems—with evolutionary implications. Impacts of herbicides on soil microbiota include disruption to nutrient cycling, as well as altered organism and plant performance, which can affect pollination and animal consumption of plants. This builds on a 2021 study published in Frontiers in Environmental Science by a team of international researchers on the destructive impact of glyphosate on microbial communities, particularly against beneficial microorganisms. Glyphosate acts on the shikimate pathway, present in plants, fungi, bacteria, archaea, and protozoa. Thus, many taxonomic groups of microorganisms are sensitive to glyphosate.

Glyphosate is just one example of an array of pesticide products and agricultural practices that undermine soil microbial activity, which many scientists, farmers, and the pesticide industry itself, acknowledge as a fundamental building block of long-term food system stability. A study published in Nature Ecology and Evolution found various fungicides harm the soil and jeopardize crop yields by reducing the prevalence of beneficial fungi, specifically arbuscular mycorrhizal fungi (AMF). Monoculture agriculture is a form of industrial agriculture that inevitably leads to poor soil health relative to diverse farming systems, based on a 2021 study published in Agrosystems, Geosciences and Environment. Researchers note that the U.S. Corn Belt, which is defined by monoculture farming of genetically engineered corn, has lost 35% of its topsoil. The impact of toxic pesticides on beneficial organisms and nontarget species has contributed to the dramatic loss in insect populations (up to one-quarter of the global population) since 1990, based on a 2024 study published in Environments. A 2020 study published In Communications Biology by scientists at the University of Bern, Switzerland found that beneficial black garden ants (Lasius niger) are adversely impacted by neonicotinoid insecticides.

On this year’s International Microorganism Day, a Daily News reviewed the continuous impact of pesticide residues (glyphosate, paraquat, endosulfan, and diazinon) on the microbial health of farming systems in Nigeria and what it represents for pesticide-dependent farming systems globally.

Meanwhile, various studies identify the significance of organic farming systems in advancing soil health in comparison to chemical-intensive agriculture. In 2022, the Rodale Institute released the findings of its forty-year-long comparative analysis of organic and conventional grain production, finding that:

1. Organic systems achieve 3-6 times the profit of conventional farms.
2. Yields for the organic approach are competitive with those of conventional systems after a five-year transition period.
3. Organic yields during stressful drought periods are 40% higher than conventional fields.
4. Organic systems leach no toxic compounds into nearby waterways.
5. Organic systems use 45% less energy than conventional farming systems.
6. Organic systems emit 40% less carbon into the atmosphere.

A 2024 study published in Biology and Fertility of Soils confirms the soil health benefits of organic agriculture in its ability to improve ecological functions damaged by chemical-intensive farming practices. There are various agroecological practices that demonstrate the growing obsolescence of toxic pesticide products. For example, a 2023 study published in Agriculture, Ecosystems & Environment identifies black soldier fly exoskeletons as a potentially effective organic fertilizer in terms of positive impacts on plant size, flower count, seed production, and pollinator appeal, among other factors, as a soil supplement. Additionally, a 2024 study published in the International Journal of Molecular Sciences demonstrates that biofungicides act as a “sustainable and economically viable alternative” to synthetic fungicides. As chemical-intensive practices impair certain production sectors such as citrus orchards in Florida, scientists are moving forward to establish agroecological, organic-aligned practices through a “push-pull” pest management system. (See Daily News here.)

Call to Action

The proliferation of research and scalable solutions in organic farming is viewed by farmers, retailers, policy advocates, and community leaders as a transformational solution.

Talk with Beyond Pesticides about creating a livable future: Attend Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency. The Forum launched on October 30 at 2-4pm (EDT) and will continue on November 14 at 1pm (EST). The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated with petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time. Registration is complimentary, with contributions appreciated, and valid for all sessions of the Forum! 

All unattributed positions and opinions in this piece are those of Beyond Pesticides. 

Source: Soil Science Society of America Journal  

(Beyond Pesticides, October 31, 2024) Approximately four in ten private wells in the state of Wisconsin contain toxic pesticides and pesticide metabolites, according to findings released earlier this year from a 2023 survey, entitled Wisconsin Agricultural Chemicals in Wisconsin Groundwater, conducted by the Wisconsin Department of Agriculture, Trade, and Consumer Protection (DATCP) in partnership with U.S. Department of Agriculture’s (USDA) National Agricultural Statistics Service (NASS). An analysis of the survey findings from Wisconsin Public Radio determined that “more than half of 29 pesticide compounds detected are unregulated in groundwater.” Pesticides detected in this study include toxic herbicides atrazine, dacthal, metolachlor, and alachlor, commonly used by chemical-intensive corn and soybean growers throughout the United States, but they are particularly concentrated for use in Corn Belt states such as Wisconsin. Various neonicotinoid insecticides were also detected. Pesticide leaching into both surface water and groundwater continues to impose adverse health and environmental impacts on communities across the nation, leading to advocates pushing for organic land management principles and practices to avoid the continuous use of toxic pesticides.

Methods and Findings

“Of the 29 compounds detected, [Carla] Romano [groundwater specialist at DATCP] said 13 have established groundwater standards,” based on an interview conducted by Wisconsin Public Radio. “Nine pesticide compounds lacked any groundwater limits or health advisory levels. Seven only have health advisory levels.” A primary obstacle to establishing standards that state officials pinpoint is an insufficient amount of peer-reviewed research on the health and ecological impacts of various specific pesticides.

This survey is conducted on a five-year rotation basis, beginning in 1996, and has resulted in surveys in 1996, 2001, 2007, 2016, and 2023 to “assess the presence of agrichemicals in Wisconsin’s groundwater.” In each survey following the initial study, 50% of wells surveyed were already tested in the previous cycle with the other 50% newly selected, with state and national officials reporting that “[t]his rotation strategy enabled the identification of new areas with agricultural chemical presence within the state and allowed for tracking changes in pesticide concentrations over time.” The researchers used “a stratified random sampling” including NASS Land Use Strata for previously untested wells, providing data on the intensity of agricultural production on targeted land areas. Researchers describe the benefits of this research strategy as twofold:

1. “First, samples were allocated proportional to agricultural intensity throughout the state.
2. “Second, the current method allows for comparisons of water quality to agricultural intensity in addition to location within the state.”

The topline statistic worrying public health and environmental advocates, as well as regenerative organic and organic farmers and landowners in the state, is that the “percentage of wells that contained a detectable concentration of a pesticide or pesticide metabolite was 43.1%, up from 41.7% of 2016 and 33.5% in 2007.” When comparing pesticide levels in waterways across different assessment years, DATCP arrives at some of the following additional conclusions:

• “Alachlor ESA [ethane sulfonic acid], a metabolite of alachlor — an active ingredient historically employed in herbicides targeting grass and broadleaf control — was identified in 97 samples from the same survey, despite the absence of currently registered alachlor products in Wisconsin.”
• “The increase in the estimated detection rates for metolachlor ESA and atrazine TCR since 2007 may be partially attributed to the reduction of laboratory reporting limits, initiated in 2016, for a range of tested compounds, including metolachlor ESA, atrazine, and atrazine metabolites.”
• “Between 2016 and 2023, the statewide detection rate for neonicotinoids increased by approximately 5%.”

Regarding the detectability of pesticides and pesticide metabolites, a concentration is considered detected if it is reported as greater than the “respective reporting limit,” which is set by Wisconsin regulators. More than half of the detected pesticides do not have groundwater or health advisory levels, which demonstrates the pervasiveness of pesticide use and the lack of data tracking to assess short- and long-term health impacts.

The framing of these surveys regarding the statistical insignificance of changes in pesticide levels found in private waterways is viewed by advocates as an implicit acceptance by state and federal government officials of contamination and a failure to address the problem at its source: the continuous registration and use of toxic pesticides that ultimately breakdown in, and spread widely throughout waterways.

Pesticides, Waterways, and SCOTUS

Wisconsinites, as well as researchers, farmers, and advocates across the country, have spoken out against state inaction on pesticide contamination in groundwater.

In 2016, a Wisconsin family spoke out against groundwater contamination after their son was diagnosed with juvenile dermatomyositis, a rare inflammatory skin disease with unknown causes. Test results from the Wisconsin State Laboratory of Hygiene showed that their well-contained atrazine levels at twice the state and federal drinking water health standards; follow-up testing by DATCP found it was closer to triple the state health standard. While there are no conclusive studies linking pesticide exposure to this rare disease, atrazine exposure has been linked to serious respiratory and skin diseases. (See here for Daily News.)

During the Trump Administration, the U.S. Environmental Protection Agency (EPA) waived its requirement for Syngenta to monitor Midwest waterways for atrazine presence, alarming public health and environmental advocates across the region. This weakening of policies was consistent with the establishment of Navigable Waters Protection Rule in the Trump Administration, a precursor to the eventual SCOTUS decision in Sackett v. EPA (2023) in which Clean Water Act protections are only applied to contiguous “Waters of the United States” (WOTUS), excluding groundwater, ephemeral streams, and critical wetland ecosystems that do not connect directly to waterbodies that are not clearly defined under the WOTUS definition.

Recent research conducted by Yale University and the University of Massachusetts determined that the Sackett decision “endangered the drinking water sources of at least 117 million Americans by stripping protections from over half of the nation’s wetlands, as well as up to nearly 5 million miles of rain-dependent and seasonal streams that feed into rivers, lakes, and estuaries.”

Further analysis of allowable groundwater levels for herbicides in Wisconsin specifically can be found in this Daily News here.

Pesticide Contamination, Biodiversity, and Public Health

Pesticide movement into waterways is a national and international reality for which there has been testing and numerous research efforts.

In 2021, a study published by the U.S. Geological Survey (USGS) determined that millions of people are drinking from groundwater reserves riddled with pesticide and pesticide metabolites or breakdown chemicals. More specifically, USGS researchers found that 41% of public drinking water supply wells are contaminated with pesticides. USGS, in a 2023 study published in Environment International, found that nearly half (45%) of U.S. tap water is contaminated with PFAS chemicals. Researchers note that USGS can only detect 32 of the more than 12,000 different types of PFAS and PFAS breakdown chemicals, thus indicating the number is most likely higher.

According to a Portland State University study in 2021, pesticide contamination is a threat to biodiversity considering the continuous use of pesticides in forest management practices on public lands threatens marine organisms along the West Coast of the United States, including indicator species such as clams, mussels, and bivalves (oysters). A 2024 study published in Aquatic Toxicology reviewed over 150 peer-reviewed studies that found pesticide contamination (including glyphosate, atrazine, bifenthrin, and imidacloprid) in algae populations disrupts the aquatic food web. In a study published in Science of the Total Environment, chemicals of concern, including pesticides, were identified as leaching into groundwater reserves in the Grombalia shallow aquifer feeding into the Wadi El Bay watershed in northeast Tunisia. The researchers determine their findings to be relevant for watershed management beyond this specific regional context, including relevance in areas with “high population density [with] intensive agricultural activity.”

What are states doing to respond to pesticide movement and subsequent contamination? In Arizona, the state’s Auditor General reported the systemic failure of Arizona’s Department of Environmental Quality (ADEQ) to monitor groundwater reserves and soil for pesticides and other environmental contaminants in a 2021 investigation. Between 2013 and 2021, ADEQ failed to monitor groundwater and soil for agricultural pesticide contamination. Furthermore, the agency did not implement key groundwater monitoring processes over four years, despite law requirements. There have been some instances of government leadership, including in 2018 when the Vermont Department of Environmental Conservation denied a permit to apply toxic pesticides (Fluridone) to Lake Iroquois, a 237-acre spring-fed body of water used for public recreation.

This problem of pesticide contamination and government inaction is not limited to the state level but is a broader national regulatory system issue. On the topic of EPA regulation of PFAS, Public Employees for Environmental Responsibility (PEER) filed a lawsuit against EPA in June 2024 on behalf of Texas farmers impacted by PFAS-contaminated biosolid fertilizers, alleging EPA’s failure to live up to its statutory obligation under Clean Water Act Section 405(d) and 40 CFR Part 504 to identify and regulate toxic pollutants. (See Daily News here.) Beyond Pesticides joined a petition submitted by the Center for Food Safety and numerous other environmental, farmer, and grassroots organizations to hold EPA accountable in updating their regulatory approach to PFAS contamination. (See Daily News here.) On October 9, EPA issued the fifth Test Order pursuant to the Toxic Substances Control Act requiring Innovative Chemical Technologies, The Chemours Company, Daikin America, Inc., Sumitomo Corporation of Americas, and E.I. Du Pont de Nemours and Company to conduct testing on certain PFAS chemicals in their products as a part of the National PFAS Testing Strategy.

Considering recent major settlements—including a $1.185 billion dollar settlement in 2023 from pesticide manufacturers DuPont, Chemours, and Corteva to major cities across the U.S. for PFAS remediation and monitoring in public drinking water systems—advocates continue to mount public pressure for the federal government to take action.

Call to Action

Public health and environmental advocates see the persistent infiltration of toxic pesticides into common areas, including public drinking wells and waterways, as a failure of local, state, and national governments to adequately address the ongoing biodiversity and health crises compounded by the climate crisis. The National Organic Program prevents the use of toxic pesticides on certified land; however, advocates, farmworkers, and farmers acknowledge that the movement of pesticides off their target site poses an existential threat to safeguarding agroecological food systems.

See Actions of the Week for opportunities to pressure EPA to suspend the registration of atrazine and paraquat using the criteria established under The Dacthal Standard. See Beyond Pesticides’ ongoing campaign, Keeping Organic Strong, to ensure the integrity of organic standards and enforcement.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Sources: Wisconsin Public Radio, Wisconsin Department of Agriculture, Trade, and Consumer Protection

(Beyond Pesticides, October 30, 2024) STARTS TODAY at 2 PM EDT—NATIONAL FORUM: IMPERATIVES FOR A SUSTAINABLE FUTURE. Beyond Pesticides has filed suit against The Scotts Miracle-Gro Company and GreenTechnologies, LLC for allegedly misleading consumers on the hazardous nature of their fertilizer products, which contain sewage sludge (often referred to as biosolids) contaminated with per- and polyfluoroalkyl substances (PFAS). The group filed two cases, Beyond Pesticides v. Miracle-Gro Co. and Beyond Pesticides v. GreenTechnologies, LLC, in D.C. Superior Court on October 25, 2024. The complaint alleges that, as part of their marketing, these companies tell consumers that their fertilizers are “eco-friendly” and “sustainable,” when, in fact, the products contain hazardous substances. The complaint cites test results showing PFAS residues in the companies’ fertilizers and numerous scientific studies on the adverse effects of PFAS to public health, wildlife, and pollinators.  

PFAS, known as “forever chemicals” due to their ability to persist in the environment, are endocrine disruptors linked to developmental issues, cancers, metabolic, cardiovascular and reproductive harm, damage to the liver, kidneys, and the respiratory system, as well increased chances of disease infection and severity. The chemicals’ immunotoxic effects threaten human health. 

Beyond Pesticides alleges that consumers are, thus, misled by advertising in which Scotts Miracle-Gro describes its product ingredients as “organic matter and recycled nutrients,” despite the presence of PFAS. Similarly, Beyond Pesticides alleges that consumers are misled by GreenTechnologies’ representations that its product is “a sustainable fertilizer that enhances environmental quality.” 

“Companies that market hazardous substances while claiming environmental and health benefits are misleading consumers who seek out products to protect themselves, their families, and the ecosystems in which they live,” said Jay Feldman, executive director of Beyond Pesticides. “Our litigation seeks to put a stop to this deceptive practice in the marketplace, where there are products and practices that are truly healthful and protective of nature,” Mr. Feldman continued. 

Please see Beyond Pesticides’ Daily News and Action archive.

Beyond Pesticides is seeking injunctive relief under the District of Columbia Consumer Protection Procedures Act, D.C. Code §§ 28-3901-13. Beyond Pesticides is represented by Richman Law & Policy. 

***

Don’t miss it! Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency, starts TODAY, October 30 at 2-4pm (EDT) and then continues on November 14 at 1pm (EST). The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time. It is not too late to register—Click here!

(Beyond Pesticides, October 29, 2024) STARTS TOMORROW—NATIONAL FORUM: IMPERATIVES FOR A SUSTAINABLE FUTURE. A legal victory in federal court is the latest in a series of attempts to force the U.S. Environmental Protection Agency (EPA) to fulfill the mandate given to it by Congress in 1996 to test all pesticides for their endocrine disrupting effects and regulate them accordingly. The case in the U.S. District Court for the Northern District of California was brought by the Center for Food Safety (CFS) and a collection of agricultural workers’ organizations, farmers’ groups, and pesticide activists.

Beyond Pesticides wrote in 2019, EPA’s “Endocrine Disruptor Screening Program (EDSP) began, then virtually stopped, its review and regulation of endocrine disrupting pesticides, despite [its 1996 Congressional mandate] to develop a screening program within two years and then begin regulating.” (See timeline, Figure 2, p11.) After the release of a  a damning 2021 Office of Inspector General (OIG) report (see Beyond Pesticides’ reporting) on the agency’s lack of progress in protecting the population from potentially damaging endocrine disruption impacts of exposures to synthetic chemical pesticides (and other chemicals of concern), CFS wrote: “The 2021 [OIG] report included the shocking revelation that some EPA staff were instructed to function as if the screening program had been eliminated from EPA’s budget, despite a $7.5 million allocation that same year — raising the prospect of EPA’s intentional violation of its statutory duty.”

CFS’ most recent litigation closed with a tentative legal settlement, rather than a judge’s ruling, as did a similar 1999 Natural Resources Defense Council suit. According to the CFS press release, the agreement includes “deadlines by which EPA will implement the EDSP and assess pesticides’ endocrine-disrupting effects. Under the terms of the proposed agreement, over the next five years, EPA will collect data on and assess the effects of endocrine-disrupting pesticides, either as part of the agency’s registration review of registered pesticides or as a part of new pesticide approvals.” EPA also promises to listen to farmworkers’ input on specific pesticides, and to complete assessment of 86 pesticides by 2034.

The case details EPA’s behavior for more than 25 years: a combination of stubborn inaction and a succession of failed promises to do better. In the words of Maricel Maffini, PhD and Laura  Vandenberg, PhD, in Failure to Launch: the Endocrine Disruptor Screening Program at the U.S. Environmental Protection Agency (2022), “[N]ot a single pesticide chemical has been determined to be an endocrine disruptor, and no regulatory actions have been taken.”

The reasoning for EPA’s inaction has been murky and illogical. It has spent most of that time stalled, under chemical industry pressure, on the appropriate testing methods for determining whether a pesticide is an endocrine disruptor (ED), even though there are mountains of academic research demonstrating exactly that for numerous pesticides still in heavy use in the U.S. Currently the agency uses a two-tier system in which, if a chemical meets certain initial criteria in test tube assays, rats, amphibians and fish, it will then be bumped up to a second, more rigorous set of in vivo experiments using a few more species tested over two generations. Other proposed testing protocols have remained under discussion, but not put into practice.

The original legislation mandating establishment of EPA’s Endocrine Disruption Screening Program (EDSP) took effect in 1998 as part of the Food Quality Protection Act of 1996, itself an amendment of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The legislation instructed EPA to implement the EDSP no later than August 1999 and test all registered pesticides. According to the CFS complaint, to date, EPA has begun testing only four percent of those pesticides. Of those, only half are finished and even that remnant requires more testing. EPA published one list of 52 candidate chemicals and a second list of 109 candidates, acknowledging that at least some of them were likely to disrupt hormones. It got through Tier 1 testing for the first 52 chemicals and then stopped. It has completed no testing for the second list. Yet during this same period EPA registered 425 new pesticides without considering their potential endocrine effects. EPA has also acknowledged that more than 87,000 chemicals—not just pesticides—are eligible for EDSP evaluation. There is no way that EPA can ever fulfill the requirements of the enabling legislation with this kind of desultory inaction.

One egregious example is atrazine, which EPA put through Tier 1 tests and found both male and female hormone effects, yet declined to move it up to Tier 2. In its 2015 EDSP Weight of Evidence Conclusions for atrazine, EPA stated, “EDSP Tier 2 testing with mammals, fish, amphibians or birds is not recommended for atrazine at this time because it is not expected to impact current EPA-established regulatory endpoints for human health or ecological risk assessment.” Atrazine, an unambiguous endocrine disrupter, remains on the market in the U.S.

Beyond Pesticides submitted a detailed comment to EPA regarding the agency’s latest proposal to modify its implementation of the EDSP, which would narrow the scope to humans, limit testing to some active ingredients, and limit the data types considered. A Daily News of February 5 details the proposal’s weaknesses. Beyond Pesticides points out that EPA’s mandate is to protect both the environment and humans, and that the elucidation of endocrine disruption came about through observation of chemicals’ effects on animals as much as humans. The thinning of eagles’ eggshells from DDT exposure is an iconic example, which the public became aware of in Rachel Carson’s foundational book, Silent Spring, in 1962—six decades ago. The term “endocrine disruption” emerged from work by the late Theo Colborn, PhD and her 1996 book Our Stolen Future. (See Dr. Colborn’s talk to Beyond Pesticides’ 29^th National Pesticide Forum (2011) It soon became apparent that entire ecosystems are affected by chemicals that alter hormonal balances in mammals, birds, fish, reptiles, insects, and even plants. There is no divorcing humans from the rest of the biosphere. It is Beyond Pesticides’ position that “mammalian data inform potential endocrine disruption in other vertebrate taxa (avian, amphibian, fish) and vice versa” and therefore EDSP testing should not “decouple” data on mammals from other vertebrates.

[For a riveting talk by Tyrone Hayes, PhD, professor of Integrative Biology at University of California Berkeley and ground-breaking researcher on endocrine disruptors, see Protecting Life, From Frogs to the Human Family—delivered at Beyond Pesticides’ 36th National Pesticides (2018).]

Beyond Pesticides has further noted that under FIFRA, “[T]here is an inherent presumption of risk, a pesticide is presumed to pose an unreasonable risk until reliable data demonstrate otherwise. If the agency lacks the data and/or resources to fully evaluate endocrine risks to human health and wildlife, then the agency is obliged to suspend or deny any pesticide registration until the agency has sufficient data to demonstrate no unreasonable adverse endocrine risk per the mandate in FIFRA.” This means EPA must assume pesticides are EDs and the companies selling them must prove otherwise to be registered.

EPA has taken the opposite approach all along. It has done very little to protect the public, farmworkers, and wildlife from endocrine-disrupting chemicals despite three lawsuits, at least two sharp admonitions from Congress, and three scathing inspector general reports. The CFS complaint cites the 2021 OIG report, which included interviews with EPA employees from the EDSP who were “ready to go…but EPA lacked the institutional will to follow through with issuing test orders.” In a 2011 report, the Inspector General (IG) attributed EPA’s lack of progress to “lack of management.” And the 2021 IG document reported that EPA instructed some staff to act as if the EDSP did not appear in the agency budget “even though we were fully funded by Congress,” according to one employee.

EPA’s behavior is largely inexplicable to the uninitiated, but it is shaped by the shadowy influence of the pesticide industry, which is like an invisible planet whose existence must be deduced by the behavior of visible objects. In the CFS litigation, CropLife International intervened as a defendant. This gave it status as a party to the litigation, including the right to appeal. CropLife’s filings served to distract the process from the main issue, which was the utter failure of the EDSP. CropLife’s documents contained such ludicrous statements as:

• “[E]ach of CropLife’s members’ registered pesticide products has been found by EPA, after a rigorous evaluation process, to perform its intended function without “unreasonable risk to man or the environment” or “human dietary risk.”
• “CropLife has maintained that EPA must take the time to develop validated methods for conducting testing….Rushing through the processes without properly validated methods and protocols risks creating public misperceptions about the chemicals undergoing testing and could result in needless fear and distrust of pesticides.”

But overall, CropLife’s argument starkly pitted property and economic rights against the continued viability of human life and the environment without which life cannot exist. The judge accepted CropLife’s assertion that its interests should be given considerable weight in the process.

It is always worth pushing back on egregious environmental failures and it is encouraging to see the CFS settlement set out very worthy goals in writing. But EPA’s history does not bode well for real change. That will likely require agency restructuring and stronger pressure from Congress. You can help bring this about by voting in the most consequential election of our lifetimes and by telling your elected representatives to support effective reform, realistic funding, and EPA’s forward momentum toward fulfilling its statutory mandates.

Don’t Miss This!: Hear from world renowned researcher on endocrine disruptors and their connection to petrochemical pesticide exposure, Tracey Woodruff, PhD (Director of the Program on Reproductive Health and the Environment, and Professor in the Department of Obstetrics, Gynecology, and Reproductive Sciences, School of Medicine, University of California San Francisco) at Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency. The Forum begins on October 30 at 2-4pm (EDT) and then continues on November 14 at 1pm (EST). The Forum provides an opportunity to discuss with scientists from Germany and the United States, both (i) the hazards that define the urgency of threats associated petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Sources:

Alianza Nacional de Campesinas, Pesticide Action Network North America, Rural Coalition, Center for Environmental Health, Organición en California de Líderes Campesinas, and Center for Food Safety v. USEPA
United States District Court for the Northern District of California
December 20, 2022
Case No. 22-cv-9030, Complaint for Declaratory and Injunctive Relief
http://www.centerforfoodsafety.org/files/2022-12-20-doc-01–pltf-complaint_89752.pdf

Victory! EPA Ends Decades of Inaction on Assessing Endocrine-Disrupting Harms of Pesticides Pursuant to Legal Settlement with Farmworker and Environmental Health Groups
Center for Food Safety
October 15, 2024
https://www.centerforfoodsafety.org/andrew-kimbrell/2440/andrew-kimbrell/press-releases/6963/victory-epa-ends-decades-of-inaction-on-assessing-endocrine-disrupting-harms-of-pesticides-pursuant-to-legal-settlement-with-farmworker-and-environmental-health-groups

Failure to Launch: The Endocrine Disruptor Screening Program at the U.S. Environmental Protection Agency
Maricel V. Maffini and Laura N. Vandenberg
Front. Toxicol., 29 May 2022
https://www.frontiersin.org/journals/toxicology/articles/10.3389/ftox.2022.908439/full

EPA Proposal for Endocrine Disruption Testing of Pesticides Is Too Narrow in Scope
https://www.beyondpesticides.org/action-of-the-week/epa-proposal-for-endocrine-disruption-testing-of-pesticides-is-too-narrow-in-scope

While France Bans a Common Endocrine Disrupting Pesticide, EPA Goes Silent: U.S. ignores statutory mandate to review pesticides that cause deadly illnesses at minute doses, defying classical toxicology
Pesticides and You, Summer 2019
https://www.beyondpesticides.org/assets/media/documents/Feature%20–%20Endocrine%20disruptor%20review%2039.2.pdf

Inspector General Rips EPA for Failure to Test Pesticides for Endocrine Disruption
Beyond Pesticides, August 20, 2021
https://beyondpesticides.org/dailynewsblog/2021/08/inspector-general-rips-epa-for-failure-to-test-pesticides-for-endocrine-disruption/

EPA’s Failure to Regulate Endocrine-Disrupting Pesticides before a Federal Court. . . Again
Beyond Pesticides, January 6, 2023
https://beyondpesticides.org/dailynewsblog/2023/01/epas-failure-to-regulate-endocrine-disrupting-pesticides-before-a-federal-court-again/

Take Action: Male Fertility Harmed by Pesticides and EPA Dysfunction
Beyond Pesticides, July 18, 2022

Take Action: Male Fertility Harmed by Pesticides and EPA Dysfunction

(Beyond Pesticides, October 28, 2024) STARTS WEDNESDAY—NATIONAL FORUM: IMPERATIVES FOR A SUSTAINABLE FUTURE. As scientific articles and regulatory reviews by the U.S. Environmental Protection Agency (EPA) focus on individual pesticides or families of pesticides and specific health outcomes associated with exposure, legislation introduced by U.S. Senator Cory Booker (D-NJ), S. 5084, Safe School Meals Act (SSMA), proposes a holistic response to the protection of children by banning pesticides in school lunches. While focused on the elimination of certain individual pesticides and other chemicals of known concern, the bill unilaterally allows children to be served food from certified organic farms.

The overwhelmingly large body of scientific findings on the adverse effects of pesticides in the food that children eat in schools and generally. For example, last week Beyond Pesticides commented on EPA’s Draft Human Health and/or Ecological Risk Assessments for Several Pesticides, citing scientific findings that, “Neonicotinoids . . .have been found to affect mammalian nicotinic acetylcholine receptors (nAChRs) [which] are of critical importance to human brain function, especially during development and for memory, cognition, and behavior.” (See more here.) This month, Jennifer Sass, PhD, et al., in Frontiers in Toxicology, published a review of  unpublished rodent developmental neurotoxicity (DNT) studies on five neonicotinoid insecticides—submitted to EPA by their manufacturers to support the chemicals’ registration—that exhibit evidence of developmental neurotoxicity. The authors report that in reviewing this data, “EPA dismissed statistically significant adverse effects, accepted substandard DNT studies despite lack of valid positive control data, and allowed neonicotinoid registrants to unduly influence agency decision-making.” The range of adverse health outcomes associated with pesticide exposure extends well beyond neurotoxic effects to cancer, immune system and respiratory effects, diabetes, endocrine disrupting effects that affect organ function, and more. For a catalog of the range of adverse effects, see Pesticide-Induced Disease Database.

S. 5084, Safe School Meals Act (SSMA) identifies four objectives:

• Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals. The limits will be based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure.
• Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement.
• Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals.
• Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA’s analysis.

According to Senator Booker, “School meals should be a child’s safest source of nourishment, not another source of toxic exposure.” Although S. 5084 does not require organic school meals, the only way for a school to meet these objectives without bearing a large expense for testing is to buy organic food. Unfortunately, as pointed out by Kate Mendenhall, executive director of the Organic Farmers Association, “Most organic and small farms have not traditionally had access to school food purchasing programs.” S. 5084 will provide a strong incentive for schools to buy organic food for school lunches and thus, according to Mendenhall, will “open new markets for organic foods and help make organic certification affordable for small farmers.”

>> Tell your U.S. Representative and Senators to cosponsor S. 5084, which increases the funding available for schools to purchase safe school meals and expands funding for the Organic Certification Cost-Share Program to compensate organic farmers.

The Food Quality Protection Act, passed in 1996 as an amendment to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Food, Drug, and Cosmetic Act (FDCA) requires regulation of endocrine-disrupting impacts of pesticides. Almost two decades later, EPA has failed to regulate endocrine-disrupting pesticides.

The review process in S. 5084 mandates that at least every five years the Commissioner of Food and Drugs must “determine potential adjustments to the maximum permissible levels of heavy metals and toxic metalloids.” Similar provisions exist for other toxic materials that this legislation is intended to regulate. Permissible levels of toxic substances—including PFAS, heavy metals, industrial chemicals, and pesticides—are now calculated without consideration given to the cumulative impacts (or toxic burden) across all exposures. In 2020, FDA acknowledged that half of food samples tested by the agency have toxic pesticide residues and one in ten samples have levels that violate legal limits established by EPA, according to the Pesticide Residue Monitoring Report. Consumer Reports recently updated its analysis of pesticide residues in various common grocery store products, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day.

There are serious long-term health implications for children and youth exposed to the toxic soup of pesticide and chemical residues found in conventionally grown food. Research published in Environmental Pollution in 2022 identified children with higher levels of certain pesticide metabolites are more likely to go through early puberty. The American Academy of Pediatrics identified in a study published this year the proliferation of anti-microbial resistant infections resulting from overreliance on antibiotics in animal agriculture and resulting in potentially severe health risks for infants and children. Additionally, a 2024 study published in Environment International finds 60 biomarkers of pollutants and pesticides in hair analyses of children throughout France, which highlights the global crisis resulting from inadequate regulation of toxic chemicals. Despite the known health impacts of pesticide exposure, Congress may end up removing two-hundred-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields depending on how Farm Bill negotiations move forward, according to an analysis by Environmental Working Group.

There are additional associated benefits for children who consume organic food. Sticking to an organic diet has reduced toxic pesticide residues in the bodies of U.S. children and adults, based on several studies published in 2019 in Environmental Health, and in two 2015 studies published in Environmental Health Perspectives and by the Center for Environmental Research and Children’s Health. A particularly noteworthy study published in 2014 in Environmental Research found that organophosphate pesticide metabolites in the urine of adults were reduced after just a week-long organic diet. A 2019 study published in Environmental Health, led by Barcelona Institute for Global Health, found that organic food consumption among children is directly associated with higher test scores, after measuring for fluid intelligence and working memory. Conversely, lower scores on fluid intelligence tests were associated with, among other factors, children’s fast-food intake.

The transition to organic food in school cafeterias is not a new policy concern. In a 2004 article published in Pesticides and You, School Lunches Go Organic: Science supports growing movement, numerous examples across the nation demonstrate a pathway forward for broader adoption of organic mandates. “Stonyfield Farm has sponsored organic programs at schools in Rhode Island, California, Massachusetts, New York, New Hampshire, and Connecticut,” according to the article. Additionally, the authors wrote, “An organic salad bar started at Lincoln Elementary School in Olympia, Washington has proven so popular and economically feasible, all grade schools in Olympia now have one. California school districts in Berkeley, Santa Monica, and Palo Alto also have organic food programs. In 2004, the Seattle school district adopted H61.01, Breakfast and Lunch Program Procedure, a policy banning junk food and encouraging organic food in school cafeterias.” More recently, Beyond Pesticides called for requiring organic school lunches in order to eliminate obesogenic pesticide residues.

S. 5084 also establishes a pathway forward for acknowledging organic food production as a public good and service by expanding funding for the Organic Certification Cost-Share Program to fully compensate farmers for certification costs, a long-term policy goal for organic advocates nationwide. It increases the funding available for schools to purchase safe school meals. Supporters of the bill include a broad spectrum of educational, health, environmental, and organic advocates, who welcome the continued leadership of Senator Booker in pushing forward legislation that eliminates a number of toxic residues from the National School Lunch Program and the elevation of organic food production on the national stage.

>> Tell your U.S. Representative and Senators to cosponsor S. 5084, which increases the funding available for schools to purchase safe school meals and expands funding for the Organic Certification Cost-Share Program to compensate organic farmers.

Letter to U.S. Representative and Senators:

I am writing to ask you to cosponsor S. 5084, Safe School Meals Act, introduced by Senator Cory Booker in September, which has four objectives:

*Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals, based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure.

*Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement.

*Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals.

*Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA’s analysis.

School meals should be a child’s safest source of nourishment, not another source of toxic exposure. Although S. 5084 does not require organic school meals, buying organic food is a cost-effective way for schools to meet the bill’s requirements. EPA has still failed to advance the protections for children mandated by the Food Quality Protection Act, passed in 1996. In 2020, FDA acknowledged that half of food samples tested by the agency have toxic pesticide residues and one in ten samples have levels that violate legal limits established by EPA. Consumer Reports recently updated its analysis of pesticide residues in various common grocery store products, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day.

There are serious long-term health implications for children and youth exposed to pesticide and chemical residues found in food grown in chemical-intensive agriculture. Research published in Environmental Pollution in 2022 identified children with higher levels of certain pesticide metabolites are more likely to go through early puberty. The American Academy of Pediatrics identified the proliferation of anti-microbial resistant infections resulting from overreliance on antibiotics in animal agriculture and resulting in potentially severe health risks for infants and children. A 2024 study published in Environment International finds 60 biomarkers of pollutants and pesticides in hair analyses of children throughout France.

Children benefit from organic food. An organic diet reduces toxic pesticide residues in the bodies of U.S. children and adults, based on several studies published in 2019 in Environmental Health, and in two 2015 studies published in Environmental Health Perspectives, and by Center for Environmental Research and Children’s Health. A study published in 2014 in Environmental Research found that organophosphate pesticide metabolites in the urine of adults declined after just a week-long organic diet. A 2019 study published in Environmental Health, led by Barcelona Institute for Global Health, found that organic food consumption among children is directly associated with higher test scores. Conversely, lower scores on fluid intelligence tests were associated with, among other factors, children’s fast-food intake.

S. 5084 also expands funding for the Organic Certification Cost-Share Program to fully compensate farmers for certification costs, a long-term policy goal for organic advocates across the nation, and increases the funding available for schools to purchase safe school meals. Supporters of the bill include a broad spectrum of educational, health, environmental, and organic advocates.

Please cosponsor S. 5084.

Thank you.

***
Don’t miss it! Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency, begins on October 30 at 2-4pm (EDT) and then continues on November 14 at 1pm (EST). The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.

(Beyond Pesticides, October 25, 2024) To better understand synergistic interactions between multiple stressors, researchers from the Helmholtz Centre for Environmental Research in Leipzig, Germany, analyze exposure to the pyrethroid insecticide esfenvalerate with two nonchemical environmental factors: elevated temperature and food limitation. In their recent publication in Environmental Pollution, the authors find the greatest synergistic effects when Daphnia magna (D. magna) are subjected to esfenvalerate under conditions experienced with climate change including lower food availability and increased temperature.

D. magna, also known as daphnids or water fleas, are small planktonic crustaceans that represent an essential part of the food web in lakes and ponds. Impacts on populations of daphnids can lead to effects throughout multiple trophic levels that impact overall biodiversity. As the researchers state, “Global biodiversity is declining at an unprecedented rate in response to multiple environmental stressors… A key challenge is understanding synergistic interactions between multiple stressors and predicting their combined effects.”

To study this, a Stress Addition Model (SAM), which predicts the cumulative effects of interacting stressors, was utilized and compared to laboratory data using 24-hour-old neonates of D. magna. The organisms were subjected to various conditions, singularly and in combination, including increased temperature, lower quantities of food, and different concentrations of esfenvalerate. The study encompasses “eight esfenvalerate concentrations (0, 0.001, 0.01, 0.0316, 0.1, 0.316, 1.0 and 3.16 μg/L) × two temperature levels (20 and 25 °C) × two food conditions (high and low food), resulting in 32 treatments. In each treatment, we used 15 replicates, and the experiment was repeated 3 times,” the authors note.   

The low food treatments received 100 times less food, and the increase to 25 °C was chosen as it represents the upper threshold of D. magna’s thermal tolerance. Both of these conditions represent a stress that the researchers hypothesized would exacerbate the effects of pesticide exposure. “We selected esfenvalerate because it has frequently been detected in agricultural streams and is allowed for agricultural practices in the EU [European Union] until May 2026,” the researchers share. The varying concentrations reflect those commonly found in the field and represent real-life exposure levels for aquatic organisms.

Esfenvalerate is a suspected endocrine disruptor and has documented effects of neurotoxicity, irritation, and kidney/liver damage, as well as reported toxicity to fish/aquatic organisms and bees. See more on the health effects of esfenvalerate and pyrethroids here and here.

The test groups in this study are used to predict “the combined effects of (i) elevated temperature and food limitation, (ii) elevated temperature and esfenvalerate, (iii) esfenvalerate and food limitation, and (iv) all stressors together.” In assessing the nonchemical environmental stressors, the authors find, “[E]levated temperature alone caused 12% mortality, while starvation alone caused 20% mortality. However, when both stressors were combined, the mortality rate increased to approximately 29%, indicating the additive effects of both stressors.”

When factoring in exposure to esfenvalerate under each of these conditions individually, stronger interactions are observed with food stress. The results demonstrate that limitation of food decreases the tolerance of D. magna to esfenvalerate and causes synergism. When analyzing all three stressors together, the interactions between esfenvalerate and food limitation show even stronger effects at elevated temperatures. The researchers report, “[T]he synergistic interaction between food limitation and esfenvalerate at elevated temperature (25 °C) was 3.6-fold stronger as compared to synergism at reference temperature (20 °C).”

The increased effects of pesticide exposure under food limitation “can be attributed to metabolic depression resulting in limited energy budget for physiological defences against stress,” the authors say. When organisms experience starvation, their metabolic activity is lowered as a strategy to survive until food is available. Additional studies reveal that food limitation increases the toxicity of pesticides in invertebrates. (See here and here.)

When temperatures are elevated, it increases metabolic rates within organisms that creates greater energy demands, and compromises the organism’s ability to detoxify chemicals. With the depletion of energy that comes with limited food availability, this leaves the organisms particularly vulnerable. “Additionally, temperature stress might weaken the immune system, making daphnids more vulnerable to toxicant exposure. Thus, cumulative effects likely disrupt homeostasis, leading to synergistic rather than additive response… Each stressor diminished the general stress capacity of individuals, thereby increasing synergism with increasing total general stress,” the researchers state.

To summarize the study data, the authors say, “Our results indicate that, compared to high food and reference temperature, the combination of food limitation and elevated temperature substantially increased the sensitivity of D. magna to esfenvalerate.” With the current crises of climate change and biodiversity, food scarcity and warming are already individually impacting organisms. In finding that these stressors have a greater cumulative impact, without even factoring in chemical exposure, places a huge threat over the stability of aquatic and terrestrial food webs. Adding in the harmful effects of pesticides, which are further exacerbated under these environmental conditions, puts the entire ecosystem at risk.

Synergistic effects of pesticides have been well documented by Beyond Pesticides (see here, here, and here) and highlight the heightened risks of chemicals with additional stressors. The interaction of multiple stressors and pesticides is overlooked in ecological risk assessments. When pesticides are reviewed by the U.S. Environmental Protection Agency (EPA) to determine if they create unreasonable adverse effects on human health and the environment, the toxicity of the individual compounds is assessed without factoring in the real-life scenarios of pesticide mixtures and environmental stressors that create synergy.

Current regulatory review protocols do not adequately capture the complex interactions that occur in nature with pesticide exposure, which threatens the health of all organisms and the environment. As the researchers note, “[T]he combined impacts of climate change, chemical pollution, and other physical stressors are reshaping ecosystems by altering the composition of natural communities and affecting ecosystem services.”

As Beyond Pesticides previously reported on biodiversity, the mix of diverse and intricate relationships of organisms in nature are essential for sustaining life. Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. Biodiversity is critical for many goods and services essential to life on earth, supports human and societal needs, influences human health and well-being, and protects against exposure to zoonotic diseases. Biodiversity loss harms our health and threatens the ecological cycles that support life.

The entire food web, including both aquatic and terrestrial organisms, relies on balance. When stressors, such as climate change and pollution, threaten that balance, all organisms including humans are at risk. D. magna represents an important foundation in the aquatic ecosystem, and its effects on these organisms highlight the wider threat to all wildlife. “Maintaining biodiversity of surface water ecosystems is paramount for providing essential ecosystem services,” the authors conclude. “However, these ecosystems are increasingly subjected to multiple anthropogenic stressors that compromise their ecological status.”

Protecting biodiversity through the elimination of harmful chemicals is the path forward. By adopting organic land management practices, the effects on human health and the environment, as well as climate change, can be mitigated. Organic agriculture focuses on soil health, which leads to improved health of all organisms and the environment.

A study in the Journal of Environmental Science and Public Health, as previously reported by Beyond Pesticides, shares that, “The three most important environmental problems affecting the globe now are pollution, climate change, and biodiversity loss.” Based on the science, petrochemical pesticides, and synthetic fertilizers, central to conventional chemical-intensive systems, are contributors to these problems. There is an abundance of scientific, peer-reviewed evidence that shows these chemicals disrupt ecosystems that support and sustain life in addition to negatively influencing human health both directly and indirectly as well as acutely and chronically.

To solve the existential crises of climate change, biodiversity loss, and human disease, it is critical that we transition away from this reliance on chemicals and adopt organic agriculture as a standard. Take action to tell Congress to ensure that organic programs, and their funding, do not lapse this fall and encourage your community to transition to organic with the Parks for a Sustainable Future program. Add your voice to the urgent movement to help Beyond Pesticides accomplish the mission of eliminating fossil fuel-based pesticide use by 2032 by joining as a member today.

On the necessity, viability, productivity, and profitability of organic land management, attend the 41st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source:

Shahid, N., Siddique, A. and Liess, M. (2024) Synergistic interaction between a toxicant and food stress is further exacerbated by temperature, Environmental Pollution. Available at: https://www.sciencedirect.com/science/article/pii/S0269749124018268.

(Beyond Pesticides, October 24, 2024) When U.S. Senator Cory Booker (D-NJ) introduced S. 5084, Safe School Meals Act (SSMA) in September, he identified four objectives:

1. Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals. The limits will be based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure.
2. Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement.
3. Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals.
4. Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA’s analysis.

While groups like Beyond Pesticides applaud Senator Booker’s initiative to restrict exposure to some of the most hazardous toxicants, especially the most vulnerable subpopulation of children, their goal is to provide organic food to school children. In this spirit, groups have advocated that the U.S. Department of Agriculture’s National School Lunch Program procure certified organic food (see Daily News and Action of the Week). There are concerns regarding the imposition of costly monitoring and testing components that may be unfeasible and unrealistic given previous and existing failures of the U.S. Environmental Protection Agency (EPA) and FDA to fulfill their mandates. (See Daily News here, here, and here.)

Breaking Down the Bill

Advocates are concerned that legislation requiring additional monitoring and risk assessment reviews of individual classes of pesticides or individual active ingredients will run into challenges given the already glacial pace at which EPA’s Office of Pesticide Programs moves to review the latest peer-reviewed, independent scientific analysis of toxicity. For example, the Food Quality Protection Act was passed in 1996 as an amendment to both Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Food, Drug, and Cosmetic Act (FDCA) with one of the goals to regulate and review endocrine-disrupting impacts of registered and pending pesticides. Almost two decades later, EPA has failed to review and regulate, leading to public confusion over the true health impacts of pesticide exposure. See the following Action of the Week, Tell EPA That the Failed Pesticide Program Needs a New Start, for additional context.

The review process in S. 5084 would mandate that at least every five years, the Commissioner of Food and Drugs must “determine potential adjustments to the maximum permissible levels of heavy metals and toxic metalloids” in the National School Lunch Program. Similar provisions exist for other toxic materials that this legislation is intended to regulate. Permissible levels of toxic substances, be it PFAS, heavy metals, industrial chemicals, pesticides, are now calculated without consideration given to the cumulative impacts (or toxic burden) across all exposures. Ultimately, environmental and health advocates maintain that action is needed to end the “chemical soup” that defines daily exposure. In 2020, FDA acknowledged that half of food samples tested by the agency have toxic pesticide residues and one in ten samples have levels that violate legal limits established by EPA, according to the Pesticide Residue Monitoring Report. See Daily News here for an in-depth Consumer Reports analysis of pesticide residues in various common grocery store products.

S. 5084 establishes a pathway forward for acknowledging organic food production as a public good and service by expanding funding for the Organic Cost-Share Program to fully compensate farmers for certification costs, a long-term policy goal for organic advocates across the nation. However, the legislation’s creation of a category of “clean suppliers” will compete with certified organic farmers and wholesalers who now receive just a fraction of the support from the federal government relative to chemical-intensive growers, and would more likely divert federal funds spent by school districts that would otherwise source organic food.

Given the increased public interest and demand for organic, and concern over toxic pesticide exposure, advocates call for organic certified food to be the baseline criterion for eligibility under the National School Lunch Program—which is where this bill unfortunately falls short, given the urgent need to eliminate toxic petrochemical pesticide production, manufacturing, sales, and use.

Health Benefits of Organic

There are serious long-term health implications for children and youth exposed to the toxic soup of pesticide and chemical residues found in conventionally grown food. Research published in Environmental Pollution in 2022 identified children with higher levels of certain pesticide metabolites are more likely to go through early puberty. The American Academy of Pediatrics identified in a study published this year the proliferation of anti-microbial resistant infections resulting from overreliance on antibiotics in animal agriculture and how this poses potentially severe health risks for infants and children. Additionally, a 2024 study published in Environment International finds 60 biomarkers of pollutants and pesticides in hair analyses of children throughout France, which highlights the global crisis resulting from the inadequate regulation of toxic chemicals. Despite the known health impacts of pesticide exposure, Congress may end up removing two-hundred-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields depending on how Farm Bill negotiations move forward, according to an analysis by Environmental Working Group.

There are additional associated benefits for children who consume organic food. Sticking to an organic diet has reduced toxic pesticide residues in the bodies of U.S. children and adults, based on several studies published in 2019 in Environmental Health, and in two 2015 studies published in Environmental Health Perspectives and by the Center for Environmental Research and Children’s Health. A particularly noteworthy study published in 2014 in Environmental Research found that organophosphate pesticide metabolites in the urine of adults were reduced after just a week-long organic diet. A 2019 study published in Environmental Health, led by Barcelona Institute for Global Health, found that organic food consumption among children is directly associated with higher test scores, after measuring for fluid intelligence and working memory. Conversely, lower scores on fluid intelligence tests were associated with, among other factors, children’s fast-food intake.

The transition to organic food in school cafeterias is not a new topic and policy concern. In a 2004 article published in Pesticides and You, School Lunches Go Organic: Science supports growing movement, numerous examples across the nation demonstrate a pathway forward for broader adoption of organic mandates. “Stonyfield Farm has sponsored organic programs at schools in Rhode Island, California, Massachusetts, New York, New Hampshire and Connecticut,” according to the article. Additionally, the authors wrote, “An organic salad bar started at Lincoln Elementary School in Olympia, Washington has proven so popular and economically feasible, all grade schools in Olympia now have one. California school districts in Berkeley, Santa Monica, and Palo Alto also have organic food programs. In 2004, the Seattle school district adopted H61.01, Breakfast and Lunch Program Procedure, a policy banning junk food and encouraging organic food in school cafeterias.”

Call to Action

Advocates welcome the leadership of Senator Booker in pushing forward legislation that eliminates glyphosate, paraquat, and organophosphate pesticides from the National School Lunch Program, as well as the elevation of organic food production on the national stage. This is not a surprise given the Senator’s leadership in pushing forward the Protect America’s Children from Toxic Pesticides Act (PACTPA) in 2023, which also aims to address gaps in national pesticide regulation. (See here and here for Daily News articles on PACTPA). To strengthen the objectives of this proposed legislation, see this Action of the Week to tell USDA’s Food and Nutrition Service to require organic school lunches in public schools to combat the obesity and nutrition crises facing children.

Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency, begins on October 30 at 2-4pm (EDT) and then continues on November 14 at 1pm (EST). The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source: Office of Senator Cory Booker

(Beyond Pesticides, October 23, 2024) The stark contrast of two political parties emerged around this summer’s reporting of the Project 2025 blueprint—created by extreme right-wing conservatives—that proposes the gutting of environmental and public health policy and implementation. Many political observers say “Project 2025 Presidential Transition Project,” formally titled “Mandate for Leadership: The Conservative Promise,” will be embraced by a second Trump Administration, despite denials that are challenged by insiders as outright lies. While the public became aware of Project 2025 plans to gut the U.S. Environmental Protection Agency (EPA) and many other agencies, the Biden Administration was announcing the emergency ban (see also August 6 announcement), finalized yesterday, of the weed killer Dacthal, exercising an EPA authority that has not been used in 45 years since the banning of 2,4,5-T (50% of the mixture of Agent Orange). With this decision, EPA set an important precedent for proclaiming (i) an unacceptable harm, (ii) its inability to mitigate the pesticide’s hazards with typical risk mitigation measures, and (iii) the availability of alternatives that made the chemical unnecessary. In dramatic contrast, the Trump supporters behind Project 2025 are intent on politicizing science to undermine governmental structures and laws established to protect public health and the environment. The blueprint, if followed, will surely allow the existential health, biodiversity, and climate crises to spiral out of control—ensuring that a sustainable future will suffer a deadly setback, given the urgency of the crises.

Published by the conservative Heritage Foundation and 140 former Trump administration staffers, Project 2025 lays out a plan for a hypothetical second Trump administration on a range of environmental, public health, and social issues. The document has sections devoted to EPA, the U.S. Department of Agriculture (USDA), and the Department of the Interior (DOI).

If all the plans detailed in the document were to become policy, any control over pesticides, fossil fuels, industrial chemicals, metals like lead and arsenic, and carbon dioxide emissions would evaporate like volatile gases. This is not an exaggeration. Every brake on agricultural chemicals, resource extraction, and industrial pollution, including oil, gas and coal, will be removed. The document is unapologetic and deeply radical in intent. The New York Times reported that the head of the Heritage Foundation, Kevin Roberts, said, “We are in the process of the second American Revolution.”

Project 2025 alternates between aggressively hostile terms for civil servants and environmental advocates on the one hand and insincere, benevolent-sounding statements that say one thing and mean something else. The document’s overall polemic tone makes it sound as if EPA is riddled with crazy “Leftists” who have been imposing their distorted vision on the nation by wrapping all economic activity in choking ribbons of red tape and illegally incorporating attempts to cope with climate change into every policy. To anyone who has tried to convince EPA to take urgent steps to prevent and eliminate exposures to harmful chemicals—glyphosate, for example, or dicamba, chlorpyrifos, or DDT (Dacthal, for sure)—this line of rhetoric is laughable.

Project 2025 will change the definition of pollutants and hazardous chemicals, which will likely dilute actions to control, for example, perfluoroalkyl and polyfluoroalkyl compounds (PFAS), the “forever chemicals” often contained in pesticides and as flame retardants in almost everything else. See Beyond Pesticides’ analysis of a recent Environmental Health Perspectives commentary on PFAS present in the active ingredients of pesticides.  

Project 2025’s supposed concern for safe food and Americans’ health includes a call for “reform for pesticides. . .When approving pesticides, FIFRA [the Federal Insecticide, Fungicide and Rodenticide Act] allows for cost-benefit balancing, recognizing that pesticides are effective precisely because they harm pests. However, the ESA [Endangered Species Act] does not allow for any consideration of the beneficial effects of pesticides.”

In a statement regarding EPA’s Office of Pesticide Programs that George Orwell would single out as perfect Newspeak, or purposefully ambiguous and confusing language, Project 2025 asserts that pesticide manufacturers feel the program is underfunded:

Manufacturers are also willing to pay higher fees to the fee-based portion of the program. However, grower groups have been disappointed by EPA’s actions and have significant concerns about EPA’s ability to conduct science-based risk assessments and take risk management actions that appropriately balance benefits and risks as required by FIFRA.

Project 2025’s real opinion is nowhere more evident than in its treatment of science, for example in its proposal to “[s]hift responsibility for evaluating misconduct away from its Office of Scientific Integrity, which has been overseen by environmental activists, and toward an independent body.” It says EPA’s “scientific enterprise, including the ORD [Office of Research and Development], has rightly been criticized for decades as precautionary, bloated, unaccountable, closed, outcome-driven, hostile to public and legislative input, and inclined to pursue political rather than purely scientific goals.”

One of the most bizarre aspects of Project 2025’s approach to pesticides is its use of the word “transparency” regarding scientific data. Rather cryptically, the document states:

“[W]hen pesticides undergo registration review every 15 years, EPA relies on publicly available data with differing levels of quality and transparency. Data standards are needed to ensure that information relied on by EPA is made available to the agency at a similar level as the original testing data conducted by registrants to ensure that EPA can conduct a robust review and analysis of the data.”

This is code for a return to what critics call the “Censoring Science” rule, or EPA’s “Strengthening Transparency in Pivotal Science” policy proposed by then-EPA administrator Scott Pruitt in 2018 during the Trump administration. The rule was both finalized by EPA and vacated by a Montana federal judge in 2021.

The rule was an attempt by the chemical industry to repeat the ploys used by the tobacco industry, which “attacked the methodology of underlying epidemiologic research and called for the inclusion of non-peer-reviewed and industry-sponsored literature into the final assessment,” according to a powerful analysis in the Annals of the American Thoracic Society. This rule was scathingly criticized by all kinds of scientists; its effects would have been to allow non-peer reviewed literature into final reviews and bar any science that did not make its raw data public, posing severe threats to the privacy of individuals in epidemiological studies and pollution exposure surveys.  The Washington Post explains that the rule would “actually restrict the EPA from using some of the most consequential research on human subjects because it often includes confidential medical records and other proprietary data that cannot be released because of privacy concerns.” Restoration of the policy is the real goal of the “transparency” language.

Project 2025’s hypocrisy is staggering. The document attacks the present policies and staff of EPA and USDA. It claims EPA is riddled with “politically connected” and “embedded” activists, pushing “vendetta-driven enforcement,” using “fear-based rhetoric” about climate change, which is a “favored tool that the Left uses to scare the American public into accepting their ineffective, liberty-crushing regulations, diminished private property rights, and exorbitant costs.”

The document repeatedly complains about bureaucratic delays, too many confusing and far-flung offices, and the injection of political motives into what it says it values—pure science. Yet Project 2025 recommends placing political appointees in almost every office of EPA. As to the agency’s risk management policy, Project 2025 states that “each office will need a political chief of staff, senior advisers designated to run suboffices, and energized assistants. Teams should be balanced with technical knowledge, legal expertise, and political exposure.”

It further proposes to centralize authority in such a way as to give all control to appointees with explicit political skills rather than to experienced technical and scientific experts. It will:

“Appoint and empower a Science Adviser reporting directly to the Administrator in addition to a substantial investment (no fewer than six senior political appointees) charged with overseeing and reforming EPA research and science activities. Qualifications for these positions should emphasize management, oversight, and execution skills (including in leading state environmental agencies) as opposed to personal scientific output.”

In other words, Project 2025 will make EPA even more politicized and less scientifically sound than it is now.

Regarding USDA, Project 2025 has less to say about specific chemical or pesticide policies, but advocates shrinking the agency and removing its authority to regulate wetlands associated with farmland. It accuses USDA of trying to force farmers to adopt organic practices and of placing “ancillary issues like climate change ahead of food productivity and affordability.” It will eliminate USDA dietary guidelines. Regarding genetic engineering, Project 2025 will repeal the federal labeling law.

In the Department of the Interior (DOI), Project 2025’s environmental agenda is to open up all land everywhere to fossil fuel exploitation: “[N]o other initiative is as important for the DOI under a conservative President than the restoration of the department’s historic role managing the nation’s vast storehouse of hydrocarbons, much of which is yet to be discovered.” The document also takes aim at the Endangered Species Act and calls the National Environmental Policy Act (NEPA) a “tree-killing, project-dooming, decade-spanning monstrosity.” Project 2025 will eliminate NEPA’s authority to consider the cumulative impacts of multiple stressors from weather disasters to chemical exposures to social determinants of health, roll back lead regulations, and gut numerous other helpful EPA programs. 

The problem with this sweeping, agency-by-agency approach is that issues like health effects from exposure to pesticides, industrial chemicals, toxic metals, and their legacy residues permeate all life, and have relevance in every activity from the military to fish farming. Acknowledging their harms and eliminating their use to the greatest extent possible with replacement practices and products would be the fastest way to accomplish true health and safety for everyone. Instead, Project 2025 proposes to simply open the floodgates to an expansion of all these kinds of pollution beyond anything previously experienced.

There are many aspects of environmental regulation in the U.S. that are far from perfect, but EPA, USDA, DOI, and other agencies beat the alternative of no regulation whatsoever. Some of the “reforms” in Project 2025 could actually improve regulatory function by reducing the time it takes for an agency to make a decision, to clarify murky rules, arrive at equitable specifics, and so on. But much of the delay and murkiness result from industry influence in the decision-making process, not from “radical” environmentalists. See Beyond Pesticides’ 2023 Daily News  for further analysis of conflicts of interest in chemicals regulation and our 2021 Daily News regarding 37 environmental groups’ letter to EPA demanding reform of the Office of Pesticide Programs. An award-winning 2021 report by Sharon Lerner in The Intercept, “The Department of Yes: How Pesticide Companies Corrupted the EPA and Poisoned America” reveals industry’s meddling in granular detail.

In another ironic twist, there is good evidence that most Americans actually approve of environmental regulations; Mongabay reports on a new survey showing that support for wildlife conservation and the environment among American adults has risen from 80 percent in 2020 to 87 percent this year. In particular, 82 percent of Republicans say this value is part of their voting decision this year compared to 68 percent in 2020—a 14-point jump in four years. This suggests that Project 2025’s obsession with dismantling environmental protections is misplaced and out of sync with the public, since the document proposes to remove conservation protections—one of conservatives’ favorite environmental values—by delisting the grizzly bear and the gray wolf under the Endangered Species Act and giving states control over the greater sage grouse.

The environmental sections of Project 2025 constitute a very clear authoritarian agenda laying out the intention to entirely dismantle environmental policy in the United States. In a most-likely insincere rhetorical ploy, the document claims to want to preserve the federal agencies most involved with environmental health, agriculture and conservation. But this is disingenuous. The intended method is to impose something like the process of fossilization: when an organism fossilizes, its biological tissues are replaced by minerals in the exact configuration of the original, so the structure looks the same, but the function is destroyed. This is what Project 2025 aims to do: not to “drown [the government] in the bathtub” and totally dismantle the agencies, but to keep their shells visible while it hands our entire environment over to industry and corrupt politicians.

Throughout the document, Project 2025 pits private property and states’ rights against all the federal agencies’ efforts to clean up past environmental degradation caused by economic activities and to protect the health of American citizens from ongoing and combined threats. While property ownership is a basic right guaranteed by the U.S. Constitution, it is not an appropriate standard by which environmental issues should be assessed, because it completely disregards the basic facts of how ecosystems work. The truth is that Earth’s surface is mostly fluid—air and water—and anything that gets into either can and often does move far beyond political boundaries, following instead wind patterns, river drainages, temperature gradients, and many other dynamics of Earth’s systems.

The most striking proof of this is climate change, mitigation of which Project 2025 means to abandon altogether. The integration of the biosphere means that what happens in a field in Iowa, or a mine in Nevada, or a pesticide plant in Louisiana, does not necessarily stay there, so leaving environmental decisions entirely to individuals, states, or a second Trump administration will result in exactly the kind of devastation the nation experienced before there were any regulations at all. This would be a tragedy—just when we are attempting to correct our previous mistakes in time to save ourselves.

Sources:

Mandate for Leadership: The Conservative Promise (Project 2025)
The Heritage Foundation 2023
https://static.project2025.org/2025_MandateForLeadership_FULL.pdf

Science on “Forever Chemicals” (PFAS) as Pesticide Ingredients and Contaminants Documented
Beyond Pesticides, July 31, 2024
https://beyondpesticides.org/dailynewsblog/2024/07/science-on-forever-chemicals-pfas-as-pesticide-ingredients-and-contaminants-supports-need-for-immediate-action-to-end-their-use/

Int’l Group of Scientists Calls for Restraints on Conflicts of Interest in Publications and Regulation
Beyond Pesticides
December 15, 2023

Int’l Group of Scientists Calls for Restraints on Conflicts of Interest in Publications and Regulation

Groups Tell EPA’s Pesticide Program It’s a Failure, Call for Immediate Reforms
Beyond Pesticides, October 26, 2021
https://beyondpesticides.org/dailynewsblog/2021/10/groups-tell-epas-pesticide-program-its-a-failure-calls-for-immediate-reforms/

Project 2025 Means More Toxic Chemicals. We’ll Fight Back.
Earthjustice
September 24, 2024
https://earthjustice.org/article/project-2025-means-more-toxic-chemicals-well-fight-back

Project 2025 Would Make It Easier for Big Corporations To Dump Dangerous Toxins That Poison Americans
Center for American Progress
August 7, 2024
https://www.americanprogress.org/article/project-2025-would-make-it-easier-for-big-corporations-to-dump-dangerous-toxins-that-poison-americans/

Project 2025 Plan for Trump Presidency Has Far-Reaching Threats to Science
Scientific American
July 19, 2024
https://www.scientificamerican.com/article/project-2025-plan-for-trump-presidency-has-far-reaching-threats-to-science/

(Beyond Pesticides, October 22, 2024) A recent study, published through the American Chemical Society, analyzes pesticide contamination in riparian soil and plants as a result of flooding from streams in Germany. The authors hypothesize, and then prove, that frequently flooded sites have higher levels of pesticides present due to the pesticides in surface waters contaminating the soil. Results show that the plant vegetation in the contaminated soil then takes up the pesticides, which bioaccumulate and lead to higher contamination that can further cascade throughout the ecosystem and affect terrestrial food webs.

“[O]ur study provides evidence from the field that nontarget plant species typical for riparian stream sites receive considerable pesticide exposure via flooding events,” the authors share. This exposure, and subsequent bioaccumulation in plants, threatens the food web, as many riparian plants are a vital food source for insects.

According to the authors, flooding events, and their impact on pesticide contamination within soil and plants, are rarely investigated. This study, “measur[ing] 98 pesticides and metabolites in plants and root-zone soils sampled at five streams situated in an area in Southwest Germany characterized by intensive agricultural land use,” highlights the differences in contamination between frequently flooded and rarely flooded areas and the greater impacts on the environment and resident organisms.

At each of the five streams in the Upper Rhine Valley, samples were collected from paired sites with different flooding frequencies. Regularly flooded sites are closer to each stream’s usual water level while rarely flooded sites are more elevated. Samples of the plant vegetation and soil were collected during October 2022, while the water-level data utilized was for the year prior to sampling (October 2021 – October 2022). The water-level data, from the Agency for the Environment in Rhineland-Palatinate, provides data on the frequency of site flooding, permitting the authors to calculate the average flooded days per year for each sampling site.

The vegetation collected at each site includes “five plant species typical for riparian sites, namely, stinging nettle (Urtica dioica), blackberry (Rubus sect. Rubus), ivy (Hedera helix), ground ivy (Glechoma hederacea), and alder (Alnus glutinosa),” the authors state. The soil attached to the roots of the collected plants was also used as root-zone soil samples. All samples of plant material and soil were freeze-dried before being filtered and analyzed using liquid chromatography and mass spectrometry techniques.

In analyzing the amount of pesticide contamination within the samples, the authors find that the regularly flooded sites were flooded at a frequency that was 10 times higher than the rarely flooded sites and exhibit not only higher concentrations of individual pesticides but also a higher number of pesticides present.   

Of the 98 pesticides and metabolites screened, 33 are quantified in plant material from regularly flooded sites while 27 pesticides are detected in the rarely flooded site samples. At the regularly flooded site, up to 17 individual pesticides are found in a single plant sample. Within the soil from the regularly flooded sites, 39 pesticides are detected while the soil from rarely flooded sites shows only 25 pesticides present.

“The average pesticide concentration over all 98 compounds was up to 3 times higher at regularly flooded sites compared to rarely flooded sites in both soil and plants,” the authors report. In just the soil of the regularly flooded sites, about 10 times higher average pesticide concentrations are seen than in the soil of the rarely flooded sites. “Our results suggest a pathway for pesticides via flooding from the aquatic system to the terrestrial soil,” the authors conclude.

Nine pesticides are detected at high frequencies in both the soil and plants of the regularly flooded sites, including the fungicides cyflufenamid, fluopyram, metrafenone, spiroxamine, boscalid, and azoxystrobin, and the herbicides prosulfocarb, flufenacet, and pendimethalin. Of the nine pesticides, the six fungicides are detected more frequently and with higher concentrations in the soil than the three herbicides while the opposite is seen in plant material. “All of these pesticides are regularly detected in surface waters of the area,” the authors say, which “represent a usual contamination profile driven by flooding events.”

Within the plants from the regularly flooded sites, pesticide concentrations are more than twice as high as those in rarely flooded sites. According to the authors, “Four out of the nine pesticides (cyflufenamid, prosulfocarb, flufenacet, and pendimethalin) were generally detected at higher mean concentrations in plant material compared to soil material,” which highlights bioaccumulation within plant tissue.

In analyzing the different parts of the plants, the study finds that the leaves contain the highest average pesticide concentration. Higher levels are also observed in woody plants, such as the alder and blackberry, when compared to herbaceous plants. To explain these differences, the authors state, “It has been suggested that the lipid content of the roots, evapotranspiration rates, and other physiological factors influence the species-specific contamination profile.” This indicates that some species, and even parts of the plants within all species, are more likely to have contaminants present. (See studies here, here, and here.)   

Contamination of nontarget plants through flooding can greatly impact the species present, but also threaten the herbivores that feed on them as well. The five species included in this study provide a food source for many organisms, such as various butterflies, moths, and beetles. “The results of the present study indicate that different ecological niches within the same (micro)habitat are exposed to different concentrations of the same compound, posing different threats to taxa occupying these different ecological niches,” the authors highlight.

With the pattern of higher frequency and concentrations of pesticides at the regularly flooded sites, present in both plants and root-zone soil, it suggests that flooding is a vector for the aquatic−terrestrial transport of contamination in small streams. “Our study provides evidence from the field that flooding events, which may increase due to climate change, can transport pesticides to riparian soils and plants with potential cascading effects on terrestrial food webs,” the authors state.

Bioaccumulation and biomagnification of pesticides has been documented as a threat to biodiversity. As the authors point out, “[E]ven low pesticide concentrations at the base of the food web may translate via biomagnification to increased levels at higher trophic levels of the food chain, leading to cascading effects.” They continue in summarizing, “The transfer of flood-driven contaminants from water to land can result in their accumulation in the soil, and thus enter the food web via plant absorption potentially triggering bottom-up effects at higher trophic levels of the terrestrial food web.”

The authors demonstrate how surface waters, which are often polluted with chemicals such as those used in agriculture, can transport contamination back into adjacent terrestrial ecosystems. One study, that followed the extreme flooding of the rivers Elbe and Vltava in August 2002, finds similar results of a 10-fold increase in concentration of pesticides in flooded soil compared to that in nonflooded soil. Another study corroborates the higher concentrations of pesticides within plants due to the soil-to-plant uptake for various nontarget plant species, including the stinging nettle.

Riparian soil can act as a pesticide sink and is a potential source for contaminated plants in those areas that can lead to implications for the entire terrestrial food web. This study highlights the importance of the “widespread distribution of small surface waters in agriculturally dominated areas and the predicted increases in flooding events due to climate change” that can impact riparian zones but also calls for additional studies and analyses on the widespread impacts of flooding.

The runoff of pesticides from agricultural land into surface waters is well documented and continues to be a concern not only in Germany but across the globe. (See previous coverage of pesticides in rivers and streams in the United States here.) This contamination not only threatens aquatic life but terrestrial organisms, as shown by the authors’ results. The only solution to prevention of this harmful contamination that can impact all species including humans is the elimination of the source pesticides, according to environmental and public advocates. Chemical-intensive agriculture relies on petrochemical pesticides and synthetic fertilizers, but a safer alternative via organic agriculture exists.

With organic land management, the threats to biodiversity and climate change are mitigated. In adopting organic standards, which are continuously improved upon through the National Organic Standards Board (NOSB), less harmful chemicals will pollute waterways and be able to impact not only human health but the health of all organisms and the environment.

Learn more about transitioning your community to organic land management, as well as how to make The Safer Choice within your home. The Daily News Blog provides the latest information on pesticide policies and science, and you can sign up for Action of the Week and Weekly News Updates here to stay engaged and informed. Play a part in the organic solution and join Beyond Pesticides as a member today.

On the necessity, viability, productivity, and profitability of organic land management, attend the 41^st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source:

Fiolka, F. et al. (2024) Flooding as a Vector for the Transport of Pesticides from Streams to Riparian Plants, American Chemical Society ES&T Water. Available at: https://pubs.acs.org/doi/abs/10.1021/acsestwater.4c00571.

(Beyond Pesticides, October 21, 2024) To solve the existential crises of climate change, biodiversity loss, and human disease, Beyond Pesticides is urging that organic agriculture grows—over the next decade becoming universally adopted for all agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic.

The OCCSP will disappear in 2025 unless Congress passes a five-year Farm Bill with funding or includes sufficient funding in a stopgap bill this fall.

Chemical-intensive agriculture, with its dependence on petrochemical pesticides and fertilizers, is a major contributor to the existential health and environmental crises and contamination of air, land, and water. Organic agriculture, certified and labeled in compliance with the Organic Foods Production Act (OFPA) provides:

• A definition of organic agriculture that defines health-biodiversity-climate friendly practices;
• A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests;
• A rigorous process for an allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
• A third-party certification and enforcement system;
• A process for public participation to ensure a feedback loop for continuous improvement; and,
• Funding to ensure elements are carried out in a robust way.

>> Tell Congress to ensure that organic programs, and their funding, do not lapse this fall.

While environmental and public health advocates say it is essential for organic to grow to solve the existential health, biodiversity, and climate crises, Beyond Pesticides, at the same time, advocates for continuous improvement of organic standards. Both statements before the National Organic Standards Board (NOSB), October 15, 2024, of Jay Feldman, executive director, and Terry Shistar, PhD, board member, of Beyond Pesticides are below.

[Beyond Pesticides thanks all those who participated in the public comment period before the NOSB by submitting comments through Beyond Pesticides’ Keep Organic Strong program.]

Statement of Jay Feldman:
The NOSB was established to protect and enhance the integrity of the organic label. integrity is operationalized through continuous improvement, which is key to the sunset process for synthetic materials on the National List of Allowed and Prohibited Substances AND through your oversight of USDA’s National Organic Program.

It is in this spirit that we offer our extensive written comments.

We look to organic to lead the shift away from petrochemical pesticides and fertilizers with urgency—to confront the existential health, biodiversity, and climate crises of the day. We don’t want cancer in our families or the long list of pesticide-induced illnesses associated with chemicals used in chemical-intensive agriculture—chemicals that end up in our air, water, soil, and food.

However, this shift will only happen if we as an organic community and an organic marketplace move quickly and forcefully to differentiate organic from all the destructive agricultural practices that contribute to the existential crises.

It wasn’t hard to predict that PFAS would end up contaminating farmland. Same for DDT. Contaminated biosolid fertilizer is a cheap waste product, but the externalities of cleanup and remediation, if that is even possible, are certainly not cheap. Neither is the treatment of resulting illnesses and environmental disasters. We had the foresight to prohibit biosolids in organic production.

Of course, the problem extends beyond biosolids to compost. We urge the NOSB to reopen the workplan item on contaminated inputs that is currently on hold after the issuance of a 2014 document on the issue—when I was on the NOSB.

But first, we must not further weaken the standard or exacerbate the problem. As important as compost is to organic, only synthetic materials that are specifically added to the National List should be allowed in compost. More persistent contaminants in “compost feedstocks” will certainly be found. The petition from BPI should be denied. Thank you Crops Subcommittee for recommending against and rejecting some notion of a de minimis or negligible risk assumption foreign to OFPA.

With this same thinking, organic must lead on eliminating plastics. Plastic Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. Make the elimination of plastic in organic a research priority.

And, we must push harder to replace nonorganic ingredients more broadly like the proposals to delist dried orange pulp, which is available in organic form.

And, Organic seeds and starts must become a priority, given their limited availability. 

Thank you.

Statement of Terry Shistar, PhD:
We are focused on three intertwined existential crises in which pesticides play a role:[1] Climate change, human illness, and biodiversity decline.

I will make six points:

1. Organic practices can and should play a major role in addressing all of these:

• Organic practices can mitigate climate change.
• The Organic Foods Production Act (OFPA) provides a framework for eliminating toxic chemicals in organic production and processing.
• Protecting biodiversity is central to the NOP definition of “organic production.”

Some challenges remain before organic can be the answer.

2. Organic production can mitigate climate change only if it is soil-based because soil-building practices help sequester carbon in the soil. The NOSB must take a strong stance against hydroponic and container systems that do not build soil biology.[2]

3. Although the NOSB does a good job of keeping toxic active ingredients out of organic production, the so-called “inert” ingredients make up the largest part of formulations and pose greater risks.

4. The Materials Subcommittee has proposed two alternatives [at link, search on “inert ingredients”]—one of which would address this problem and another that would not. The NOSB should recommend only Option 1, which meets the requirements of OFPA, and not forward the recommendation for Option 2 to NOP. Option 1 relies on EPA’s decision that residues in food do not pose a risk and ignores risks to farmworkers and the environment. [See “Inert” Ingredients Used in Organic Production.]

5. Another avenue through which toxic chemicals can enter organic food—and by which organic processing fails to promote the health and environmental precepts of organic—is the allowance of non-organic ingredients through listing on §606. There is no reason that organic production cannot meet the needs for these ingredients—if processors are not allowed to use cheaper nonorganic ingredients. Besides removing potential toxic exposures to consumers, elimination of these nonorganic ingredients would avoid the support of chemical-intensive agriculture through their use in organic products.

The NOSB should also work towards elimination of toxic chemicals—such as plastics, PFAS, and bisphenols—in food packaging.

6. The NOSB has made strides towards protecting biodiversity in materials reviews and policies, but needs to address:

• Implementation of biodiversity and marine materials policies
• Phasing out the use of plastics

Thank you.

Letter to the U.S. Congress:
Now that the Farm Bill and its extension have expired on September 30, I am reaching out because I am concerned about gaps in funding for programs that are essential for organic farms and businesses.

To solve the existential crises of climate change, biodiversity loss, and human disease, it is critical that organic agriculture grow—eventually becoming the standard for agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic.

Organic agriculture also promotes economic growth by creating market opportunities for farmers, while supporting rural development through practices that protect natural resources and boost community resilience. I am writing to urge you to pass a five-year Farm Bill before the end of this year. I support the Farm Bill framework put forward by Senate Agriculture Committee Chairwoman Stabenow, which provides funding for essential organic programs and provides a foundation so organic agriculture can thrive. However, as this proposal moves forward, do not accept any legislative language that limit pesticide restrictions and the right to sue chemical manufacturers and allied users of pesticides when harmed.

If Congress does not renew the five-year Farm Bill, it is imperative that the Farm Bill extension include funding for the Organic Certification Cost Share Program (OCCSP). This essential program provides a partial reimbursement to defray the cost of organic certification. 

The cost of certification is one of the biggest challenges faced by organic farmers. Without Congressional action, this program will expire, leaving thousands of organic farmers with a huge net increase in their annual certification costs. A lapse or reduction in funding, will have a big impact on farmers’ ability to stay certified, and would come at a time when most operations are seeing significant increases in certification costs to keep up with inflation and new requirements to strengthen enforcement of organic rules.

Level funding of $8 million, as was provided last year, is no longer enough funding and would result in cuts to this essential program! The cost of the program has risen due to increasing certification costs and as more operations are getting certified. Congress needs to provide at least $11 million for the OCCSP in the Farm Bill extension (or through an ad hoc emergency assistance package).

In addition to the Organic Certification Cost Share Program, please include provisions to reauthorize the Organic Agriculture Research and Extension Program (OREI), and fund the Organic Data Initiative and the Organic Certification Trade and Tracking Program (OCTT), which is necessary for organic fraud prevention activities. Like the OCCSP, the Organic Data Initiative and the Organic Certification Trade and Tracking Program are ‘orphan’ programs. Essential funding for these programs will lapse with devastating consequences unless there is Congressional action.

Please make sure organic programs do not lapse this fall.

Thank you.

On the necessity, viability, productivity, and profitability of organic land management, click here to register to attend the 41^st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.

[1] Graphs from: https://www.climate.gov/news-features/understanding-climate/climate-change-global-temperature; https://gco.iarc.fr/overtime/en/dataviz/trends?populations=840&sexes=1_2&types=0&multiple_populations=0&cancers=0_14&mode=cancer&multiple_cancers=1; https://www.ipbes.net/news/global-assessment-summary-policymakers-final-version-now-available

[2] Picture from: https://beyondpesticides.org/dailynewsblog/2024/08/study-documents-value-of-soil-microbiome-nurtured-in-organic-farming-harmed-by-chemical-intensive-ag/

(Beyond Pesticides, October 18, 2024) On October 30 at 2:00pm (eastern time, U.S.), Beyond Pesticides convenes the first session (virtual) of its 41^st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency. The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.

What’s Happening on October 30 at 2:00pm (eastern time US)?

An opportunity: Meet Felix Löwenstein, PhD, author of Food Crash: Why Organic Is the Only Way Forward, just released in the United States. 

• Focus: Adopt a holistic worldwide strategy to reverse the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.
   
• Vision: Explore Dr. Löwenstein’s passion, grown from his life as an agricultural scientist, farmer, international agricultural aid worker, and leader in Germany’s association of organic food producers and organic research. 

• Mandate: Delve into the compelling facts about the adverse impacts of chemical-intensive agriculture on ecological and human health, food sovereignty, and animal welfare—and the viability, productivity, and profitability of the sustainable alternative now! 

. . . And on November 14, at 1:00pm (eastern time US)?

An opportunity: Meet Tracey Woodruff, PhD, MPH, director of the Program on Reproductive Health and the Environment, School of Medicine, at the University of California San Francisco.

• Focus: Elevate understanding that links the deadly and debilitating effects of endocrine disrupting toxicants, including pesticides, plastics, and a wide range of manufactured products, to fossil fuels and the compelling science to support action. 

• Vision: Explore the clinical effects and inequities associated with dependency on the range of endocrine disruptors, as Dr. Woodruff calls for decarbonizing the economy with a precautionary standard. 

• Mandate: Apply scientific findings and uncertainties to policies and practices to address threats associated with serious health effects, biodiversity decline, and the climate crisis. 

ABOUT THE PROGRAM
The Forum will address the increasing understanding that the world faces existential threats to health, biodiversity, and climate for which petrochemical-based pesticides and fertilizers, among other products, are major contributors—at the same time that solutions are currently available and operational. The threats are real and scientifically defined, and so are the solutions. The goal of the Forum is to contribute to the adoption of a holistic worldwide strategy to reverse the existential crises in the production of our food and the management of land and ecosystems.

The convenors explain that the 41st National Forum, Imperatives for a Sustainable Future, offers us an opportunity to elevate our understanding of the petrochemical threats and the critical need to adopt practices and policies that eliminate one of the major sources of the problem, petrochemical pesticides and fertilizers. Among the significant changes that will be discussed is the need for an accelerated transition to organic land management, from agriculture, landscapes to playing fields, as part of a holistic strategy that recognizes the multidimensional nature of the problem and solution.

A focus of the Forum is what Beyond Pesticides describes as two major imperatives for sustainability and a livable future that require community and decision maker understanding of and action on:

1. The threats to human health and ecosystems and the dire consequences of inaction or measures that fall far short of what is necessary; and
2. The path forward to eliminate reliance on petrochemical-based products, including the constellation of toxic materials associated with chemical-intensive practices—from food production to the management of homes, gardens, parks, and schools.

Session 1: October 30, 2024, 2:00 PM (Eastern time US)  

Felix zu Löwenstein, PhD
The Forum Series begins with an agronomist who has been farming organically on his family farm in Germany since the 1990’s, bringing a wealth of hands-on experience that informs the technical information that transformational change requires. In Dr. Löwenstein’s book, Food Crash: Why Organic Is the Only Way Forward, just released in the United States, the case is made that organic land management with “ecological intensification” provides society with a social good, as opposed to chemical-intensive (conventional) practices that have externalized health and environmental costs. The book’s thesis on the organic imperative is rooted in the facts about the adverse impacts of chemical-intensive industrial agriculture on human health, food sovereignty, the environment, animal welfare, soil erosion, and soil health.  

With it being widely understood that reducing greenhouse gases must be accompanied by the drawdown of atmospheric carbon, the author explains the importance of eliminating petrochemical pesticides and fertilizers, and the essential role of soil in sequestering carbon. The history of the failed Green Revolution and continuing efforts of multinational chemical/seed companies to advance monoculture farming systems, genetically engineered seeds, and dependency on synthetic fertilizers is juxtaposed with the success of diversified organic production practices, which utilize on-farm composting, the natural cycling of nutrients, and rotations with leguminous plants such as clover, alfalfa, and beans. Most importantly, Dr. Löwenstein is focused on “What To Do,” taking urgent action with at least three objectives: (1) require cost of harm to be internalized to the polluter, (2) incentivize organic production and consumption with tax policy, and (3) elevate consumer knowledge and awareness about the personal and societal benefits of organic. 

Dr. Löwenstein’s passion for organic transition has grown from his life as an agricultural scientist, farmer, international agricultural aid worker, and leader in Germany’s association of organic food producers and organic research. 

Session 2: November 14, 2024, 1:00 PM (Eastern time US)

Tracey Woodruff, PhD, MPH 
The conversation continues with the Alison S. Carlson Endowed Professor in the Department of Obstetrics, Gynecology, and Reproductive Sciences and the director of the Program on Reproductive Health and the Environment, School of Medicine, at the University of California San Francisco. Dr. Woodruff’s work focuses on uncovering and addressing environmental determinants of disease and health inequities and has written groundbreaking material on endocrine disrupting chemicals. 

Dr. Woodruff’s research studies the harmful effects of chemicals and pollutants on health, pregnancy, and child development. She leads efforts to translate scientific information into actionable change in the clinic environment and through public policy. Previously, she has served as a senior scientist and policy advisor for the U.S. Environmental Protection Agency’s Office of Policy.  

In a recent piece in The New England Journal of Medicine, Health Effects of Fossil Fuel–Derived Endocrine Disruptors, Dr. Woodruff highlights the urgent need to address the widespread chemical pollution stemming from the petrochemical industry, underscoring the dire implications for public health. She emphatically states, “We need to recognize the very real harm that petrochemicals are having on people’s health. Many of these fossil-fuel-based chemicals are endocrine disruptors, meaning they interfere with hormonal systems, and they are part of the disturbing rise in disease.”   

Petrochemical exposure through air, water, food, and land is increasing and the health problems induced by endocrine disruptors require broader understanding among health care professionals and a more robust regulatory response, with recognition of disproportionate harm to people of color communities. In raising these issues, Dr. Woodruff is sounding the alarm to decarbonize and detoxify our economy with a precautionary approach.

To register for the Forum, Click here or go to bp-dc.org/2024-national-forum. Click here to access last year’s Forum webpage (and Daily News post)!

Beyond Pesticides (October 17, 2024) On September 30, 2024, the U.S. Environmental Protection Agency (EPA) opened a public comment period about production of specific per- and polyfluoroalkyl substances (PFAS, also known as ‘forever chemicals’)—including perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), and perfluorodecanoic acid (PFDA). EPA is collecting information on the fluorination process of high-density polyethylene (HDPE) and other plastic containers to inform possible regulatory action under the Toxic Substances Control Act (TSCA). The deadline for submitting comments is November 29, 2024.

PFOA and twelve other PFAS compounds are created during the fluorination of HDPE plastic containers by Inhance Technologies, LLC, the only U.S. company manufacturing containers using this fluorination technique (see here). Studies by EPA, independent researchers, and the company itself demonstrate that PFAS leaches from container walls into contents, exposing millions to these toxic chemicals without their knowledge. EPA notes, “Long-chain PFAS like PFOA, PFNA, and PFDA build up in our bodies and the environment over time. Even small amounts can significantly contribute to people’s long-term exposure and health risk for cancers, impacts to the liver and heart, and immune and developmental damage to infants and children.”

The adverse effects of PFAS exposure are linked to serious health issues, including cancer, reproductive disorders, and immune system dysfunction. Factory and farmworkers, due to cumulative exposure, and vulnerable groups exposed to HDPE products, face heightened risks. Leaching affects a broad range of household and daily-use products, from pesticides to food, cosmetics, and cleaning supplies, presenting risks through ingestion, inhalation, and skin contact. In addition, cumulative exposure to PFAS emerges from multiple sources in daily life. In recent years, EPA has acknowledged this critical issue; in April 2024, the agency’s first-ever enforceable drinking water standards for PFAS, “National Primary Drinking Water Regulation” (NPDWR) included PFOA and PFNA and designated PFOA as one of the first two hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as Superfund). 

PFAS contamination from Inhance Technologies manufactured plastic containers

 EPA has been involved in the PFAS tragedy revolving around Inhance Technologies’ plastic container manufacturing process since the agency was notified by Public Employees for Environmental Responsibility (PEER) in September 2020. In April 2024, a coalition of environmental and public health organizations, including PEER, filed a TSCA Section 21 petition, urging EPA to immediately halt the production of plastic containers with PFAS levels that leach into consumer products and the environment. The petition calls on the agency to use its TSCA Section 6 authority to ban the production of PFOA, PFNA, and PFDA produced as a result of Inhance’s fluorination process. EPA approved this petition on July 10, 2024, and is now calling for public comments to inform EPA’s response.

In the petition, PEER highlights that the U.S. Court of Appeals for the Fifth Circuit, as referenced later in this post, acknowledges EPA’s authority to regulate the fluorination process that generates PFAS under TSCA’s Section 6. This provision mandates that when EPA identifies a chemical as posing an “unreasonable risk of injury to health or the environment,” it must take necessary measures to mitigate that risk. This is precisely the action sought by the petitioners.

“The Toxic Substances Control Act allows EPA to issue an immediately effective rule to prohibit or limit any chemical process determined to present an unreasonable risk of injury if serious or widespread injury is likely before completion of the rulemaking process,” said Bob Sussman, principal in Sussman and Associates, former senior EPA official in the Obama Administration, and legal advisor to the Center for Environmental Health, one of the petitioners with PEER. “EPA has all the evidence it needs to justify this action and should not allow Inhance to continue to expose Americans to dangerous PFAS one day longer than necessary,” Mr. Sussman continued.

In fact, EPA did previously take such decisive action, however, the decision was consequently reversed by the judiciary. On December 1, 2023, EPA issued stop orders to Inhance Technologies, LLC, mandating the cessation of PFAS production, which occurs during the fluorination process of the company’s HDPE plastic containers. In December 2022, Inhance submitted Significant New Use Notices (SNUN) for nine PFAS chemicals, including PFOA, PFNA, and PFDA. Following its review, EPA determined that these three PFAS chemicals pose serious health risks, requiring prohibition to prevent harm. Consequently, under TSCA Section 5(f), the agency banned further production of PFOA, PFNA, and PFDA resulting from HDPE fluorination.

In response, Inhance challenged EPA’s orders, resulting in a March 21, 2024, ruling by the U.S. Court of Appeals for the Fifth Circuit to vacate the agency’s decision. The court found that EPA had exceeded its authority by using TSCA Section 5 instead of Section 6, as Inhance’s decades-old fluorination process does not constitute a “significant new use.” Inhance argued that the process was not new due to its long-standing implementation, while the EPA contended that the lack of prior disclosure rendered it a significant new use. The court emphasized that this ruling does not restrict the EPA from regulating Inhance’s fluorination process under TSCA Section 6, provided it follows the procedural guidelines. The Fifth Circuit decision did note that if EPA were to pursue another approach (Section 6) under TSCA, the agency must “weigh the costs to businesses and the overall economy before shutting down an ongoing manufacturing process.” Public health advocates say that this starkly underscores the limitations of federal law in protecting public health in the face of corporate interests and profits. (See here).

PFAS contamination also found in pesticides

The Center for Food Safety—joined by environmental, farm, and grassroots organizations including Beyond Pesticides—submitted a groundbreaking petition to EPA in July 2024, urging immediate action to address PFAS in pesticides and pesticide containers. Numerous studies have shown that the broad use of PFAS chemicals, and the resulting environmental contamination, has devastating impacts on public health, wildlife, and pollinators. Despite acknowledging PFAS as an urgent public health and environmental issue, EPA has upheld hundreds of registrations of pesticide ingredients that fall into the PFAS category. (See here to take action).

As the situation evolves, environmental and public health advocates are continuing to pay close attention, given EPA’s recent history of testing for PFAS in pesticides from HDPE container contamination. In May 2024, PEER filed a complaint asserting that EPA issued misleading statements in falsely claiming that recent tests found no detectable per- and polyfluoroalkyl substances (PFAS) in pesticides (see here). PEER’s administrative complaint calls for the EPA to retract a 2023 research memo and press release, alleging these publications violated the agency’s standards for scientific quality and accuracy. In late 2022, research published in the Journal of Hazardous Materials Letters identified significant PFAS levels in widely used pesticides, contradicting EPA’s previous assurances that registered pesticides do not contain PFAS (see here). However, in the aforementioned  press release, EPA issued a non-peer reviewed memo stating the agency “did not find any PFAS in the tested pesticide products.”

PEER alleges that EPA omitted critical details, including:

• Detection of PFAS in samples it both received and independently collected;
• Failure to report high PFAS levels, as revealed by documents obtained via the Freedom of Information Act; and
• EPA’s failure to disclose that test samples were spiked intentionally with PFAS—a standard quality control method—which EPA’s tests failed to detect, raising concerns over test reliability.

“This memo represents some of the poorest science I’ve seen from the agency,” said Kyla Bennett, PhD, PEER’s science policy director and former EPA scientist, emphasizing that failure to detect spiked PFAS is particularly concerning. Filed under the Information Quality Act (IQA), PEER’s complaint requires EPA to address any inaccurate scientific information it has published. The complaint further alleges that EPA ignored its own standards for peer review and quality control before publication.

As a note, in February 2024, EPA introduced a new testing method capable of detecting 32 PFAS directly from HDPE container walls, enabling HDPE container users and manufacturers to assess containers prior to use and assist in preventing contamination from stored products. [It can also be adapted for broader applications, including testing PFAS in other solid materials such as fabric and packaging paper.] However, the focus of the PEER petition is not to shift the burden of testing to food producers to keep their products safe from fluorinated PFAS-contaminated plastic containers; rather, it is to require EPA to carry out its legal responsibility to regulate PFAS under TSCA.

Organic certification system poised to act more quickly and effectively

Organic agriculture offers a long-term solution to PFAS contamination. Under the Organic Food Production Act (OFPA), organic producers are prohibited from using petrochemical pesticides and fertilizers, as well as biosolids often contaminated with PFAS, operating under a regulatory framework overseen by the National Organic Standards Board (NOSB). As the only agricultural system with a requirement for a farm plan, inspections and certification for compliance with organic standards, and rigorous public oversight, organic farming promotes sustainable practices that enhance soil health and biodiversity. Organic is attempting to reverse the escalating public health, environmental, and climate crises as EPA fails to prevent long-chain PFAS contamination throughout the country. Additionally, as there are organic certified foods that are stored in HDPE Inhance manufactured containers—and thus may introduce PFAS contamination into organic foods—the organic food certification system could more rapidly and effectively address the issue in comparison to relying on EPA regulatory authority, which is untenable to rely on given the recent reversal by court order.

Organic land management practices and certified organic agriculture are critical to the systemic shift to prevent further PFAS contamination, as Beyond Pesticides continues to call on the NOSB to develop a strategy for eliminating plastics and PFAS from organic as a priority issue. For more information, please see comments by Beyond Pesticides here calling for research into the elimination of plastic—in all aspects of organic production and handling—to be made a priority for the NOSB Fall 2024 meeting from Thursday, October 22 – Saturday, October 24, 2024, in Portland, Oregon.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Sources:

Certain Per- and Polyfluoroalkyl Substances (PFAS) Risk Management Under the Toxic Substances Control Act (TSCA); Request for Comment, EPA notice, Federal Register website

Public Health Groups File Petition to Compel EPA to Remove PFAS Immediately from Fluorinated Plastic Containers, PEER petition, April 11, 2024

EPA Grants Petition on Three PFAS Found in Fluorinated Plastic Containers, EPA website

EPA Must Retract Fraudulent PFAS Report, PEER press release, May 28, 2024

PEER Demand for Correction under the Information Quality Act (IQA), PEER filing, May 28, 2024

EPA Completes Scientific Testing of Pesticide Products for PFAS, EPA website, May 30, 2023

(Beyond Pesticides, October 16, 2024) In a study published in the Journal of Agriculture, Food Systems, and Community Development (JAFSCD), researchers from New York University (NYU) identify gaps in various federal agricultural support systems for organic farmers in a sweeping analysis. The research was spearheaded by Carolyn Dimitri, PhD, chair of the Nutrition and Food Studies program at NYU and a current member of the National Organics Standard Board (NOSB) as a public interest/consumer interest representative serving through January 2026.

According to this study, there is a deficiency in institutionalized knowledge of national organic standards among existing U.S. Department of Agriculture (USDA) agents and staff working in various agencies, including Risk Management Agency (RMA), Natural Resources Conservation Service (NRCS), and Farming Service Agency (FSA). “A key recommendation from this study is the creation of specialized, highly trained crop insurance and conservation agents with expertise in organic farming systems to facilitate the application process and program use for conservation programs and crop insurance,” according to the researchers. The authors continue by echoing the sentiments of organic advocates and farmers across the nation on building organic integrity, saying, “The Organic Cost Share Program [a program of USDA’s FSA] would have more impact if its funds were used to support beginning organic farmers in addition to small-scale farm operators.”

Key Findings from the Study

The researchers identify barriers preventing organic farmers from engaging in top federal agricultural support programs—crop insurance (administered by RMA), Environmental Quality Incentives Program (EQIP) and Conservation Stewardship Program (CSP) (administered by NRCS), and Organic Certification Cost Share Program (OCCSP) /Organic Cost Share (administered by FSA or certain state departments of agriculture).

34 individual farmers and organic advocates were interviewed for this study: 23 were conducted with certified organic farmers engaged in diversified, specialty crop, fruit, and grain production; 11 were organic advocates engaged in technical assistance, policy analysis, and research. The farmers operate in 13 states across the United States with farm sizes ranging from a 3-acre diversified farm to a 12,500-acre grain production farm. The goal of this study is to “understand organic farmer perceptions of these programs, their decisions to participate, experiences with the application process, and how the programs worked for their operations” and provide potential policy solutions.

“Farm programs that target risk management and farmland conservation are important for the economic and environmental health of farms, yet they fail to meet the needs of organic producers,” said Dr. Dimitri. “Our work suggests that inserting organic farms into programs that were designed for non-organic farms has not been widely successful, because they fail to consider differences between organic and non-organic farms.”

EQIP and CSP

The goals of EQIP and CSP are to provide funding incentives for farmers already engaged in eligible practices, such as cover cropping, that support ecosystem services and biodiversity.

Even though organic farmers engage in eligible practices for both programs, recent USDA data demonstrate significantly lower organic farmer participation relative to overall chemical-intensive or conventional farmer engagement with EQIP:

• “In total, only 0.2% of EQIP contracts administered in 2022 went to organic operations. []”
• “In 2019, organic producers had approximately 74% fewer EQIP contracts per organic farm compared to all farms.”

CSP engagement has historically remained higher among organic farms compared to total farm participation, with organic farms “maintain[ing] twice as many CSP contracts… as compared to all farms.” 17 farmers participated in EQIP and six enrolled in CSP. There were several key themes that emerged regarding participation in conservation programs:

1. The knowledge of USDA agents influenced farmer perception of CSP and EQIP;
2. EQIP-eligible practices may vary based on regional/local contexts, thus if there is not a robust organic farming sector there may be intense competition with chemically intensive growers; and
3. Funding levels offered in EQIP and CSP “were not high enough [for some organic farmers] to bother with the lengthy and cumbersome application process.”

Crop Insurance

Just 10 of the 23 farms purchased crop insurance, with organic grain producers making up the vast majority. “Many of the farmers who had diversified operations did not purchase crop insurance and expressed little to no interest in doing so in the future,” according to the study. For the handful of farmers who did participate in insurance, they were disappointed in the benefits.

For example, one diversified farmer was only paid $140 after losing $7,000 in revenue from a surprise overnight drop in temperature, while another farmer was disqualified from payment because an inspector “saw evidence of pests and crop disease.” Another diversified farmer, even after going through what was described as a “stressful” paperwork process, indicated that the inspector “could not figure out how much the crop was worth.” The result: no payout. Organic grain farmers, meanwhile, laud insurance as an essential component of their operations, given climate change-fueled natural disasters that could disrupt their production. This is consistent with general trends in crop insurance enrollment in nonorganic farms, according to the research.

Whether organic farms spoke highly or disparagingly about crop insurance enrollment and procedures, reforms were suggested in the report, including the creation of consistent best management practices across insurance and conservation programs.

“Farmers must follow the RMA good farming practices to be eligible for crop insurance payments, but competing priorities for organic or conservation programming might put them at fault with RMA.” An example of this was an organic grain farmer losing access to insurance for 120 acres of wheat fields in their portfolio after engaging in no-till and cover cropping.

The researchers emphasize that there is “a large potential payoff from additional research into best practices and the development of organic system-specific seed varieties.” This is consistent with advocates’ calls to establish whole-of-government coordination akin to the European Union’s Farm to Fork Strategy (See Daily News here and here) within and among relevant agencies to consider organic food production targets in national programs such as the National School Lunch Program. (See Daily News here.)

The authors did identify RMA efforts to update its rules on insurance policies for organic farmers, as reflected in an updated rule from the Federal Crop Insurance Corporation that went into effect in July this year. See here for more information.

Organic Cost Share

OCCSP, commonly referred to as Organic Cost Share, is the most popular program among surveyed organic farmers, which is not surprising given that the total per-year certification costs can range from $2,000 to $9,000, depending on the variety of production scopes.

This does not include the annual inspection costs to verify farm compliance with the organic standards, with certification prices based on a range of factors.

Small-scale and diversified operations tend to benefit more from OCCSP, whereas large-scale grain producers “can absorb that [certification] cost very easily.” Across the board, there were a variety of recommendations proposed by the surveyed farmers, including:

• Free certification for beginning farmers with less than 10 years’ experience and beginning farmers who are under the age of 35.
• Certification payment coverage based on farm income, with farmers yielding less than $75,000 to $100,000 per year receiving 100% reimbursement.
• Complete coverage for farmers transitioning to organic with existing certified farms paying no more than 10% to 15% total certification costs per year.
• Free certification for farmers grossing less than $250,000 per year.

The survey contains calls to streamline the administrative side of OCCSP. Recommendations include shifting the administration of the cost share (e.g. sharing of invoices and proof of certification) to the certifying body rather than a separate USDA administrative agency to minimize potential communication hardships for farmers.

One of the final recommendations from the authors of this report is the creation of an “Organic Agent Corps.” This would establish permanent positions for experts in various states or regions who are familiar with crop insurance, EQIP, CSP, and related programs, as well as organic certification. Given that there are only 17,000 organic certified farmers compared to the over two million total farm operations in the United States (2021 USDA data), researchers see more targeted expertise and resources as a potential pathway to expanding capacity for the thousands of farmers who may wish to transition to organic but do not know where to begin.

Organic Integrity and Policy

With Farm Bill negotiations in the U.S. Congress in a potential holding pattern until after the presidential election, advocates from the National Organic Coalition are sounding the alarm on the expiration (as of September 30) of funds for programs including Organic Cost Share that directly impacts organic and transitional organic farmers. (See here for this week’s Action of the Week to act now!)

This week, for its fall 2024 meeting, the NOSB convenes to take public comments virtually and will meet in person on October 22-24 in Portland, Oregon. See Keeping Organic Strong for a full list of NOSB recommendations and Beyond Pesticides comments. For more information on the benefits of, and threats to, organic agriculture, see its dedicated Daily News section here.

All unattributed positions and opinions in this piece are those of Beyond Pesticides. 

Source: JAFSCD

(Beyond Pesticides, October 15, 2024) In Environmental Epidemiology, researchers from Columbia University and the University of Southern California, along with representatives from the nonprofit Comite Civico del Valle in Brawley, California, report the heightened risk of wheezing for five- to twelve-year-olds in the rural communities of California’s Imperial Valley. Through a school-based survey, the authors find associations between living near pesticide applications and more wheeze symptoms among the children.

According to the authors, residents of the Imperial Valley, which is located near the border between the United States (U.S.) and Mexico, “are primarily Latino, 1 in 3 children live in poverty, and there is a 20% unemployment rate. The county faces poor air quality and excess particulate matter levels. Further, one in five children is diagnosed with asthma and the rate of asthma-related pediatric emergency room visits and hospitalizations is two times the CA state average.” This highlights the disproportionate risk for residents in this area regarding environmental exposure to harmful chemicals.

Children are already more susceptible to health complications following pesticide exposure, as they take in greater amounts of toxic chemicals relative to their body weight and have still-developing organ systems. Young children in environments with higher levels of pesticide usage and pesticide drift face an even greater threat, such as in the Imperial Valley. The authors note, “Industrial agriculture in the region results in one of the highest amounts of pesticide applications in the state, with Imperial County ranking in the top 12 (of 58 counties) since 2017.”

The purpose of this study, the authors share, is to “assess the respiratory health impacts of pesticide usage in a rural, structurally marginalized population of school-aged children.” This is of particular importance, as the respiratory health of children can lead to long-term consequences into adulthood. The Assessing Imperial Valley Respiratory Health and the Environment (AIRE) study was initiated as a result of the concern among residents and community organizations about cumulative effects and body burden from the copious amounts of pesticides used in the Imperial Valley.

“In this intensively farmed community, fields are planted and harvested several times a year. There are over 100 different types of crops cultivated and over 50 pesticides (differentiated by active ingredient) used in Imperial Valley amounting to over five million pounds of pesticides applied annually,” the authors state. “As schools and homes are located in close proximity to agricultural fields, exposure to pesticides is of great concern.” To address this, the AIRE study provides an analysis of pesticide usage from 2016-2020 within 400 meters (m) of the homes of over 700 children.

Elementary school-aged children from five schools across five communities throughout the Imperial Valley were considered in the voluntary study. With a parent or guardian’s consent, eligible students received questionnaires. These consisted of demographic and lifestyle questions, as well as an inquiry of respiratory symptoms based on questions adapted from the International Study of Asthma and Allergies in Childhood (ISAAC). After which, 708 children participated in the questionnaire and were enrolled in the AIRE study.

In describing their methodology, the authors say, “For each child, we computed the total pesticides applied within a 400-m buffer distance of their home, using a reported address from the questionnaire, for the 12 months before the date of the baseline survey using the following pesticide groups: all pesticides, all pesticides except sulfur, sulfur only, chlorpyrifos only, and glyphosate only.”

In choosing the 400 m buffer parameter, the authors consider that there are “(1) previous studies identifying an association between a 500-m buffer correlation with pesticides measured in homes located near agricultural fields and (2) a 2018 law in California that limits the application of pesticides within 402 m (1/4 mile) of schools.” This provides 400 m as “a buffer with both scientific and policy implications,” the authors note. While this law recognizes concerns in California about children’s exposure to pesticides, it is limited to contiguous areas around schools and does not consider the amount of residential exposure, especially in rural areas, that many children face.

With information from the questionnaires, along with data from the California Pesticide Use Registry in the areas surrounding the children’s homes, the authors are able to assess links between reported respiratory symptoms and pesticide exposure. The exposure levels for each child are categorized into one of three groupings: none, low, and high.

Important statistics the authors share from the study results include: 

• “Approximately 62% of the 708 children (aged 5–12 years) lived within 400 m of at least one pesticide application within 12 months prior to survey administration.”
• “There were 130 children (18%) with wheezing in the 12 months prior to the survey.”
• “Within 400 m of child residences, there were 150 different pesticides applied over a 12-month period. This amounted to a total of 56,824 kg of pesticides applied to agricultural fields in our Imperial Valley study area.”
• “Applications of sulfur only were the main contributor with a total of 28,060 kg, followed by all pesticides except sulfur (28,763 kg), glyphosate (3319 kg), and chlorpyrifos (523 kg).”

Of the 708 participants that were enrolled in the study, 658 are included in minimally adjusted models. These participants submitted questionnaires with complete information and a geocoded address that allows for a full assessment. The authors report, “In minimally adjusted models, children in the ‘high’ total pesticide exposure group had a prevalence of 12-month prior wheeze that was 10 percentage points higher than that of children not exposed to any pesticides. Similarly, the difference in the prevalence of 12-month prior wheeze in the ‘high’ exposure group to sulfur compared to the ‘no’ exposure group was 12 percentage points higher.”

Additional results show higher prevalence in the “high” exposure groups, such as for chlorpyrifos (15%) and glyphosate (9%) when compared to the unexposed groups. An association is also noted for pesticide exposure and respiratory symptoms in children with a history of asthma. Wheezing in these children is, on average, 18.6% greater within the “high” exposure groups for all categories. In children without asthma, the “high” exposure groups are 6% and 10% higher than that among unexposed children in the categories of all pesticides, except sulfur and chlorpyrifos, respectively.

To summarize the results, the authors say, “We observed consistent cross-sectional associations between exposure to pesticides applied within 400 m of children’s residences within the past 12 months and reported wheeze during this time. Those in the highest exposure group experienced a higher prevalence of wheeze compared to unexposed children for all pesticides groups we examined: all pesticides, sulfur only, all pesticides except sulfur, chlorpyrifos, and glyphosate, respectively.”

They continue, “Associations between exposure to pesticides and respiratory symptoms appear to be higher in children with asthma, but positive, albeit weaker trends, also were observed among nonasthmatic children.” This study shows how detrimental the pesticide drift exposure pathway can be, particularly for rural communities, as living in areas with pesticide applications increases the risk of health effects. The results indicate that individuals with already documented health effects are more susceptible to additional respiratory implications, but all exposed children are still in jeopardy.

The authors also highlight the role of environmental justice, saying, “Disparities in pesticide exposures by race/ethnicity also persist, with higher exposures concentrated in structurally marginalized communities.” The AIRE cohort consists primarily of children from under-resourced Latino families, the authors note. “[P]esticide use is disproportionately located in communities experiencing the highest levels of poverty, and communities of color. Rural communities such as Imperial Valley continue to rank among the top communities most burdened by toxic pollution, including pesticides.” See additional coverage on environmental justice here, here, and here.

Concerns from residents of the Imperial County, which led to the initiation of the AIRE study, are due to many of the pesticides sprayed in the area being classified as respiratory irritants (e.g., chlorpyrifos, glyphosate, and sulfur). While each of these pesticides has a different mode of action, they are all considered irritants when inhaled. Previous studies link these pesticides to an increase in respiratory symptoms in both children and adults. One study finds that sulfur, used as a fumigant, is associated with an increase in respiratory symptoms and a decrease in pulmonary function in children, while another finds the weed killer glyphosate is associated with atopic asthma. Chlorpyrifos, in addition to pendimethalin and trifluralin, is associated with wheezing in farmers.

The authors note a limited but growing number of studies focused on the association between various types of pesticides and wheezing in children. Such studies (here and here) report increased wheezing in young children with pesticide exposure, particularly pyrethroids. Another California-based study finds decreased lung function with a 10-fold increase in exposure to sulfur within 1000 m of a child’s residence. See more coverage on respiratory implications here and here.

While the escalated health risks to farmworkers and their children have been documented, the AIRE study highlights how “pesticide drift and inhalation may be of greater concern than the take-home exposure pathway” that farmworker families face since the majority of children in the AIRE cohort are not from a household with a farmworker parent or guardian. This calls to attention the proximity of residences to agriculture and how prevalent pesticide drift is, especially in posing a threat to children’s health, as compared to the risk for farmworker children with pesticide residues brought into the house on a parent’s clothing.

The authors conclude, “Pesticide exposures have long been identified by researchers and community voices as an important environmental justice issue impacting not only agricultural workers but also nearby residents. In the United States alone, the agricultural sector accounts for nearly 90% of the total pesticide usage, making agricultural farmworkers, their families, and nearby residents particularly vulnerable to the effects of pesticides.”

To protect children’s health and mitigate respiratory effects, pesticide applications near residential homes should be eliminated. Chemical-intensive agriculture, as well as the use of household pesticides on lawns and gardens, threatens not only the health and development of growing children but all humans, pets, wildlife, and ecosystems. The Safer Choice to protect human health, biodiversity, and the environment is in organic land management.

Take action to protect the health of infants and children, as well as advocate for the removal of harmful pesticides such as paraquat, to help further Beyond Pesticides’ mission of phasing out all petrochemical pesticides and synthetic fertilizers by 2032. The path forward for a livable future is organic, which focuses on healthy soil as the foundation for land management. Organic methods promote soil health, biodiversity of microorganisms, and ecological functions as a whole. (See more here, here, and here.)

Stayed informed with Beyond Pesticides’ Daily News, which shares the latest news on the health and environmental hazards of pesticides, pesticide regulation and policy, pesticide alternatives, and cutting-edge science. Become a Parks Advocate to encourage your community to transition to organic and join Beyond Pesticides as a member today to support the movement of eliminating fossil fuel-based pesticide use and adopting the organic solution.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.

Source:

Ornelas Van Horne, Y. et al. (2024) Exposure to agricultural pesticides and wheezing among 5–12-year-old children in the Imperial Valley, CA, USA, Environmental Epidemiology. Available at: https://journals.lww.com/environepidem/fulltext/2024/10000/exposure_to_agricultural_pesticides_and_wheezing.2.aspx.

(Beyond Pesticides, October 11-14, 2024) Indigenous Peoples’ Day is celebrated this year on Monday, October 14, 2024 and has been described as follows: “[T]hroughout our Nation’s history, Indigenous peoples have faced violence and devastation that has tested their limits. . . Today, Indigenous peoples are a beacon of resilience, strength, and perseverance as well as a source of incredible contributions. . . They challenge all of us to celebrate the good, confront the bad, and tell the whole truth of our history.  And as innovators, educators, engineers, scientists, artists, and leaders in every sector of society, Indigenous peoples contribute to our shared prosperity.  Their diverse cultures and communities today are a testament to the unshakable and unbreakable commitment of many generations to preserve their cultures, identities, and rights to self-governance.  That is why, despite centuries of devastation and turmoil, Tribal Nations continue to thrive and lead in countless ways.” This language is taken from a Proclamation issued by President Biden (2023), first issued in 2021 and then again last year.

This year’s Proclamation states: “On Indigenous Peoples’ Day, we honor Indigenous peoples’ strength, courage, and resilience.  We celebrate the vast contributions of Indigenous communities to the world.  And we recommit to respecting Tribal sovereignty and self-determination and working to usher in a new era of our Nation-to-Nation relationships.” (See 2024 Proclamation.)

The federal holiday on October 14, known as Columbus Day, has for many been reoriented to recognize that the “discovery” of America was, in fact, an invasion of the Western hemisphere by Europeans who took unceded land and undermined culture, self-governance, and a way of life. In fact, the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), adopted in 2007, found that:

“[I]ndigenous peoples have suffered from historic injustices as a result of, inter alia, their colonization and dispossession of their lands, territories and resources, thus preventing them from exercising, in particular, their right to development in accordance with their own needs and interests.”

In explaining why the United States has never “endorsed” the Declaration, the U.S. Agency for International Development (USAID) wrote: “The UNDRIP is not legally binding on States and does not impose legal obligations on governments, but like all human rights instruments, it carries moral force. While not endorsing the UNDRIP, the United States has agreed to support the Declaration.”

Indigenous Peoples’ Day has increasingly become a day to remember the people of those nations indigenous to their country. Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. As Kaipo Kekona shared with the Beyond Pesticides 39^th Pesticide Forum, it is critical for us to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

In Indigenous Peoples in North America: An Overview of Progress and Report of the Regional Dialogues for the United Nations Permanent Forum on Indigenous Issues, the author writes: “Numbering over 370 million people in over 70 countries around the world on every continent, Indigenous Peoples are practitioners and knowledge-bearers of distinct cultural, ecological, spiritual, health and healing practices, as well as systems of governance. Yet tragically, the rights of Indigenous Peoples have been violated worldwide through processes of colonization involving forced relocation as well as removal of children from their families. Large numbers of children were often placed in residential schools, where they suffered severe psychological and physical abuse.”

>> Tell EPA to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. Tell EPA that when needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment.”

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those in the Great Plains, Eastern North America, or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the Indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our well-being and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

According to A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “There are stark differences between agricultural systems in Indigenous communities and agricultural systems in contemporary communities. The first being the idea of collective resources. In an Indigenous community, there are some things that just cannot be commodified – land, water, air, animals, even the health of the people, all of which are considered collective resources. Collective resources require collective and community management. Contemporary agriculture doesn’t have the same base. In contemporary agriculture, there are individualized, commodified resources like land, you can buy water, at one point in our history you could even buy somebody’s body and health.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although Indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency that although it “adhered to applicable tribal consultation policies when it conducted consultations for the three RUP [restricted use pesticide] actions that we reviewed, the EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The investigation was specifically directed toward RUP actions, but the OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate.

>> Tell EPA to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment.”

Letter to EPA
On Indigenous Peoples’ Day, I urge the U.S. Environmental Protection Agency (EPA) to recognize that indigenous agriculture and landcare provide a model for a truly sustainable relationship with the land. These practices must be integrated into the agency’s decision making that now allows unreasonable levels of harm to health and the environment despite the availability of alternative practices and products. By ignoring this fact in registering pesticides, EPA promotes unsustainable practices, increasing crises with health, biodiversity, and climate—and undermines the opportunity for humans to live sustainably on Earth.

Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for EPA to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those Great Plains or Eastern North America or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the Indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our well-being and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although Indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency, “EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how Indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate. A starting place is the understanding that, in the words of A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “In an Indigenous community, there are some things that just cannot be commodified—land, water, air, animals, even the health of the people, all of which are considered collective resources.”

I urge you to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment”—the statutory standard for regulating pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act—and should result in the cancellation of the pesticide use.

Thank you.

Letter to U.S. Senators and Representative
Indigenous agriculture and landcare provide a model for a truly sustainable relationship with the land. By ignoring this fact in registering pesticides, EPA promotes the opposite, increasing problems with health, biodiversity, and climate–not to mention the possibility of humans living sustainably on Earth.

On Indigenous Peoples’ Day, I urge you to require the U.S. Environmental Protection Agency (EPA) to engage in constructive dialogue with Native American Tribes to incorporate Indigenous agriculture and landcare practices in its assessment of pesticide registrations that allow unreasonable harm to people and the environment, despite the viability of truly sustainable Indigenous methods. These Indigenous practices must be integrated into the agency’s decision making. By ignoring these practices in registering pesticides, EPA promotes unsustainable practices, increasing crises with health, biodiversity, and climate—and undermines the opportunity for humans to live sustainably on Earth.

Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for EPA to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those Great Plains, Eastern North America, or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the Indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our wellbeing and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although Indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency, “EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how Indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate. A starting place is the understanding that, in the words of A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “In an Indigenous community, there are some things that just cannot be commodified—land, water, air, animals, even the health of the people, all of which are considered collective resources.”

Please urge EPA to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment”—the statutory standard for regulating pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act— and should result in the cancellation of the pesticide use.

Thank you.

(Beyond Pesticides, October 10, 2024) On September 16, 2024, the U.S. Environmental Protection Agency (EPA) announced an order allowing Kaizen Technologies LLC to sell off its chlorpyrifos-based insecticide product—Bifenchlor, a known neurotoxicant. This reverses an existing stocks agreement that Kaizen voluntarily negotiated with EPA in August 2022 when the company withdrew Bifenchlor from use. The agency attributes this new order to a November 2023 Eighth Circuit Court of Appeals decision, which vacated EPA’s prior 2021 chlorpyrifos ban on food crops (see here). EPA’s practice of permitting the sale and use of existing stocks of canceled pesticides has been a longstanding concern for public health and environmental advocates, as it enables the continued use of petrochemical pesticides that the agency has found to be dangerous. Chlorpyrifos, an organophosphate with adverse health effects on children (see here and here), is now the latest example. 

In reporting on the almost unprecedented decision on August 7, 2024, to use its emergency authority to ban Dacthal/DCPA, Beyond Pesticides argues that the “Dacthal Standard” is a positive precedent, a step forward in modern regulatory history; however, EPA’s continued approval of chlorpyrifos’s existing stock, complicated by the 2023 court decision, may suggest otherwise.  

As demonstrated historically with chlordane, dicamba, methyl iodide, atrazine, and other pesticides, EPA’s decision making, delay tactics, and contradictory policies are not confined to chlorpyrifos. In fact, when EPA negotiated in 2000 a withdrawal from the market residential uses of chlorpyrifos, based on the neurotoxic impacts on children, it allowed Dow Chemical to sell off all its existing stocks over a one-year period.  “Chlorpyrifos, glyphosate, 2,4-D, atrazine, and many others are poster children for a failed regulatory system that props up chemical-intensive agriculture despite the availability of alternative organic practices not reliant on these toxic chemicals,” says Jay Feldman, executive director of Beyond Pesticides. 

Ironically, as in the short interval between EPA’s rule banning agricultural uses of chlorpyrifos and the Eighth Circuit’s intervention, “the need for any use of chlorpyrifos has been refuted,” as Earthjustice Senior Attorney Patti Goldman noted in a press release. “Crops have been successfully grown in the two years since chlorpyrifos has been banned,” Ms. Goldman said. Despite the growth of the $70 billion organic industry, organic agricultural methods and materials are still not considered by EPA to be a legitimate alternative to chemicals when determining the “reasonableness” or “acceptability” of adverse pesticide effects under federal pesticide law.  

This most recent “chlorpyrifos existing stock order notice” by the agency is another footnote in an ongoing chapter of what environmental and health advocates see as regulatory failure by EPA under a weak federal statute, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The current 2024 growing season allowed the use of chlorpyrifos pesticides on most food crops [except for five states that have stepped up, independent of EPA, to ban the insecticide to protect children: Hawaii, Maryland, New York, Oregon, and California]. (See here and here.) In 2000, EPA discontinued all uses of chlorpyrifos on tomatoes, restricting use on apples, and lowering the grape tolerances. 

Background  

In 2021, EPA issued a rule that revoked food tolerances for chlorpyrifos, effectively banning its use on food crops. This decision, however, faced legal challenges from a chlorpyrifos manufacturer and several agricultural groups, which filed a lawsuit in the U.S. Court of Appeals for the Eighth Circuit. On November 2, 2023, the Eighth Circuit vacated EPA’s 2021 rule revoking all tolerances in Red River Valley Sugarbeet Growers Associations, et al. v. Regan, 85 F.4th 881 (8th Cir. 2023) and directed the agency to reconsider.  

In response to this legal development, EPA published a notice in the Federal Register on February 5, 2024. This notice served as a technical correction to the Code of Federal Regulations, formally acknowledging the Eighth Circuit’s reinstatement of chlorpyrifos tolerances, and allowing its use for the 2024 growing season on all crops effective February 5, 2024. The Eighth Circuit’s decision also referenced EPA’s 2020 Proposed Interim Registration (PID) Review Decision for chlorpyrifos, which identified eleven specific crops for potential continued use of the pesticide. The crops include alfalfa, apples, asparagus, cherries, citrus, cotton, peaches, soybeans, strawberries, sugar beets, and wheat. As discussed below, EPA is now in discussions with chlorpyrifos registrants to cancel its use on all food crops, except for the eleven identified in the 2020 Proposed Interim Registration Review Decision (PID). 

Door opens to chlorpyrifos’ expanded use and toxic exposure—‘Existing stocks’ orders 

“Since the Final Rule has been vacated—and the tolerances are again in effect—growers can use currently registered chlorpyrifos products on crops consistent with label directions. Products that were cancelled or amended may be able to be used if use is consistent with the existing stocks provisions…”—Chlorpyrifos; Amendment to Existing Stocks Provisions in Kaizen Product Cancellation Orders, A Notice by the U.S. Environmental Protection Agency on September 16, 2024. 

When courts defer to EPA’s interpretation of the existing stock provision in the federal pesticide law, a pattern of “existing stock” allowances permit hazards to continue well after a finding of harm or noncompliance. This process contrasts with the issuance of a product recall, which is typically done when pharmaceuticals are found to violate safety standards. In addition to chlorpyrifos, Beyond Pesticides has previously objected to the agency’s expansion of existing stock use for dicamba, dacthal, and paraquat. As this latest example shows, manufacturers have found a short-term workaround to quickly return to selling and distributing chlorpyrifos. Their solution—petitioning EPA for new or amended existing stock orders.  

As of September 16, chlorpyrifos can be used on all food crops that were previously subject to the formal revocation of tolerances. According to EPA’s Frequently Asked Questions about the Current Status of Chlorpyrifos and Anticipated Path Forward, the agency intends to issue a new rule to revoke the tolerances for all food commodities except for the 11 uses cited in the December 2020 PID. After providing an opportunity for public comments on PID-referenced crops——anticipated updates are tentatively proposed for 2025. However, this will only apply to specific states under agency review with limits on application rates and methods. 

Meanwhile, in an analogous decision despite the finding of harm and EPA’s violation of law in allowing harm associated with the herbicide dicamba’s registration, the continued use of the weed killer through the 2024 growing season is also effectively authorized by the U.S. District Court of Arizona (which vacates EPA’s 2021 authorization for three over-the-top uses of dicamba-based herbicide products). In response, EPA issued an existing stocks order, which means that dicamba will continue to be sold and used through 2024—although it has been linked to environmental and health adverse effects.  

As the agency continues to prioritize commercial interests and agricultural continuity over public safety and environmental protection by expanding existing stocks, Beyond Pesticides advocates for immediate discontinuation of pesticide use when risks are identified and emphasizes the availability of safer, profitable alternatives, such as USDA-certified organic farming practices. They advocate for these organic principles to be adopted more broadly to replace the reliance on harmful chemical pesticides like dicamba and chlorpyrifos. 

As clearly indicated by the evidence at hand, individual chemical bans are not the strategy for systemic change, nor are they an effective methodology for cultivating a livable future for ourselves and future generations. Given the proven viability and profitability of cost-effective organic production practices, the solution must be the urgent adoption of organic agriculture and land care that eliminates not just chlorpyrifos, but the pesticide treadmill that chemical manufacturers and chemical-intensive agriculture fuels.  

Organic management practices build soil health, cycle nutrients naturally, enhance plant resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers. The organic alternative is central to a commitment to both the elimination of practices and products that are petrochemical-based and the ability of organically managed soils to draw down (sequester) atmospheric carbon, which contributes to mitigating global warming and erratic temperatures.  

For a detailed analysis, see Beyond Pesticides’ article “Abandoning Science: A look back at the failure to regulate the neurotoxic insecticide chlorpyrifos,” featured in a special edition of Pesticides and You, where the clarion call to action notes that “… states should ban chlorpyrifos compounds . . . should undertake organic management on state-owned lands, and should support producers in transitioning away from chemical agriculture and to organic, regenerative, and sustainable practices.” 

As we emerge from a celebration of National Organic Month in September, please continue to take action to strengthen organic locally! >> Tell your governor and mayor to adopt policies that support organic land management. 

All unattributed positions and opinions in this piece are those of Beyond Pesticides. 

Sources: 

EPA’s Momentous Decision to Ban the Weed Killer Dacthal/DCPA: An Anomaly or a Precedent? Beyond Pesticides Daily News, August 8, 2024 

EPA and Court Allow Violations and Hazards of Weed Killer Dicamba Under Existing Stock Order, Beyond Pesticides Daily News, March 5, 2024  

Oregon Is the Latest State to Step In and Ban Widely Used Neurotoxic Pesticide, Chlorpyrifos, as EPA Stalls, Beyond Pesticides Daily News, February 29, 2024  

Celebrated 2021 Ag Ban of Deadly Pesticide, Chlorpyrifos, Reversed by Court Despite Decades of Review and Litigation, Beyond Pesticides Daily News, November 14, 2023 

Commentary: Are Children, Agricultural Workers, and the Food Supply Safe with EPA’s Chlorpyrifos Decision? Beyond Pesticides Daily News, August 19, 2021 

Abandoning Science: A look back at the failure to regulate the neurotoxic insecticide chlorpyrifos, Beyond Pesticides, Pesticides and You, Special Edition 2020  

Widely Used Pesticide in Food Production Damages Children’s Brains—EPA Science on Chlorpyrifos Ignored as Agency Reverses Decision to Stop Insecticide’s Agricultural Use, Beyond Pesticides, Pesticides and You, Winter 2017-2018 

What You Need To Know About Chlorpyrifos, Earthjustice, April 9, 2024 

Frequently Asked Questions about the Current Status of Chlorpyrifos and Anticipated Path Forward, EPA website 

(Beyond Pesticides, October 9, 2024) An agrichemical industry-funded study published in International Journal of Agricultural Sustainability dissects the development of national organic standards and opportunities that can be applied in expanding the use of “regenerative” agriculture. Not surprisingly, the study authors offer support for integrated pest management (IPM) and reassurance of a rigorous pesticide registration review process before the chemicals are marketed. The study included a survey of five farmers, who farm a total of 100,000 acres, but do not have extensive experience farming organically.

For those practicing regenerative organic practices and organic advocates, the bottom line is that the study concludes that a list of criteria that would be needed for regenerative agriculture criteria (e.g., list of allowed substances) already exists within the standards and requirements of the 1990 Organic Foods Production Act (OFPA) and the National Organic Program.

Environmental and public health advocates are concerned about this piece representing an industry position being cloaked in an academic journal serving as an obstacle to the widespread adoption and improvement of organic principles and practices. The study was written by four authors with varying levels of connections to CropLife America (the major agrichemical industry trade group), including academic researchers with funding from the pesticide lobbying group or direct employment. In the disclosure statement at the end of the article in the International Journal of Agricultural Sustainability, the authors indicate that the work was supported by CropLife and then say, “No potential conflict of interest was reported by the author(s).” In fact, one author, Katie Stump, indicates that she is currently a science and policy manager at CropLife America.

The surveyed farmland represents a limited number of organically managed land within the farmers’ total land portfolio. According to the study, “Two operations were growing 7-20% of their acres as certified organic. One of the growers had not entered organic production and two growers had recently exited certified organic due to barriers they encountered. Growers not currently growing organic discussed the barriers to entry and reasons they exited organic agriculture.” While the authors do acknowledge that they must consider farms of varying sizes, they fail to consider farms such as those affiliated with the Real Organic Project—a network of over 1,000 certified organic farms that have adopted practices that exceed USDA organic standards by rejecting hydroponic practices and only raise livestock on pasture.

“For a new paradigm to be successful, it will require flexibility and options to pick from in management practices that achieve the desired outcome, acknowledgment on a regional level of varying needs and practices, a clear list of certification requirements, a third-party verification system, and should be tied to a premium to reward the grower for the practices,” according to the authors. OFPA is designed to include flexibility in the adoption and continuous review of standards, and the rules require public meetings facilitated by the National Organic Standards Board (NOSB) twice a year with a sunset review of allowed substances to facilitate additions or subtractions to the National List of Allowed and Prohibited Substances (which is a foundational feature that establishes a clear list of inputs allowed in certified organic production).

For example, the requirement that beer labeled organic contain only organic hops, typically a small fraction of the beer by weight and volume, was advanced by organic hops growers who showed that the organic crop was commercially available. OFPA contains an allowance for conventional inputs in organic-labeled processed commodities if they make up less than 5% of the products that are not commercially available as organic, incentivizing the adoption of organic production practices or “continuous improvement.” With the continuous improvement of national organic standards ongoing, the organic sector has cultivated regional production hubs for various products such as cotton. Moreover, as the farmers interviewed in this study indicate, two of the main drivers to attain organic certification are “profitability” and “meeting consumer demand,” underscoring the underlying economic viability of certified organic.

The authors take the position that IPM is the most viable systems approach. They state: “This approach [IPM] does not put process limits on the use of pesticides. In fact, The Weed Science Society of America, the American Phytopathological Society, and the Plant-Insect Ecosystems Section of the Entomological Society of America issued a statement that pesticides are an important part of IPM and that restricting their use by considering them a ‘last resort’ or selecting only the ‘least toxic pesticide’ can result in a build-up of pests and reduce the overall options for control.” Advocates find it notable, and unsurprising, that the Entomological Society of America (ESA) issued support of pesticide use as a feature of IPM, given recent instances of corruption alleged by scientists attending ESA’s 2023 annual meeting. See here for the Daily News analysis of U.S. Right to Know’s report on ESA. See an additional Daily News article, IPM (Integrated Pest Management) Fails to Stop Toxic Pesticide Use, to learn more about the structural failures of IPM to address moving beyond the chemical treadmill.

The authors continue by blurring the difference between the safety of food grown with chemical-intensive and organic practices. They say, “Consumers should have confidence in the safety of their food regardless of type of pesticides used given the robust nature of the pesticide review and registration process in the U.S. for organic and conventional pesticides.”

Numerous Office of Inspector General (OIG) reports have documented the inability of the Office of Pesticide Programs to fulfill its mandate of protecting the public from toxic pesticide exposure. For example, a recent investigation by Inside Climate News found that EPA failed to adequately assess the cancer effects of 1,3-D or Telone by, among other deficiencies, relying on industry-funded scientific studies that downplayed the carcinogenic potential of this pesticide. EPA’s failure to consider the independent scientific literature extends to other areas, including failure to complete the protocol for testing the endocrine-disrupting potential of registered pesticides.

In 2023, six years after the filing, EPA rejected a public petition to request an evaluation of complete formulations of pesticide products to include toxicological analysis of both active ingredients and inerts (or other ingredients, which pesticide manufacturers do not have to disclose on labels or to the public). In a recent analysis published in Frontiers in Toxicology, researchers identified a number of pitfalls in the broader U.S. regulatory system in terms of its failure to regulate toxic chemicals that threaten public health. Beyond the failure of the scientific and risk assessment process, the U.S. Department of Agriculture continues to mislead the public about its findings related to pesticide residues. (See here for an analysis of the 2024 data.) Meanwhile, with ongoing public criticism of its failure to adequately assess its risk assessment process, EPA solicited public comments earlier this year to update its scientific integrity guidelines.

According to the study authors, “Growers believe that for the foreseeable future, both process-based organic and development of outcome-based programs [soil health, biodiversity, and other environmental and social parameters] will continue to co-exist.” Among the categories of agricultural practices that the authors identify as needing definition is regenerative agriculture. “Whether [issues of soil health and biodiversity] will develop into a cohesive definition of regenerative agriculture remains to be seen,” the authors say. Regenerative can be put in the category of greenwashing, as documented in previous Daily News articles. (See here.) The authors rest heavily on the need for “flexibility” in the use of pesticides. According to the researchers, “A key production challenge is management of pests. Growers could benefit from more flexibility such as the development of additional tools to combat difficult pests, ensuring multiple modes of action to prevent resistance and exploration of the use of derogations in concert with an IPM plan to deal with emergency situations.” Significantly, the use of petrochemical pesticides and fertilizers have been found to undermine the benefits of healthy soil systems with microbial life, nutrient cycling, and biodiversity. (See here.)

Earlier this year, the California Department of Food and Agriculture held public listening sessions, as officials entertained the adoption of a state definition of regenerative agriculture. Farmers, consumers, and advocates in California and nationwide provided statements in opposition to the state proposal, given the absence of a proposed requirement that organic standards become a baseline in the definition of regenerative. (See here.)

One of the biggest takeaways from organic farmers and advocates is the lack of definition for what substances are allowed and prohibited in regenerative agriculture, which has resulted in a continued reliance on toxic pesticides such as glyphosate. Advocates point out that agricultural systems reliant on pesticides are antithetical to supporting ecosystem services and agroecological food production. See here, here, here, and here for numerous peer-reviewed articles and commentary on the climate resilience, soil health, carbon sequestration, and economic benefits of certified organic agriculture.

As the debate on regenerative agriculture heats up, chemical industry lobbyists are hitting Capitol Hill on the Farm Bill to establish a national policy to take away local and state authority to restrict pesticides and, at the same time, fanning out across the country to pressure state legislatures to prohibit people’s right to sue for the failure to warn on the hazards of their products. (See Daily News here for more analysis.) Beyond Pesticides has called these industry campaigns an attack on democratic institutions and principles in the United States in the Daily News article, This Independence Day, Protect Democracy.

Millions of dollars are being spent by pesticide manufacturers on lobbying efforts to support these policies that restrict basic rights. According to Open Secrets, Bayer spent 7.45 million in total lobbying expenditures for 2023, CropLife America spent over 1.5 million in 2023, and BASF spent 1.5 million in 2024. A previous Daily News addresses the legacy of CropLife America’s and pesticide manufacturers’ efforts to influence national and international frameworks for pesticide and agricultural policy. (See here.)

As a growing intersectional movement of advocates continues to push for reform, the industry is seeking to undermine the credibility of advocates through doxing of information and smear campaigns, allegedly funded by the U.S. government, as reported recently by The Guardian. The critical need identified by health and environmental advocates for broader EPA regulatory action to ban pesticides was exemplified by a landmark EPA decision in August to suspend the use of the herbicide Dacthal/DCPA without allowing continued use of existing stocks—the second time in agency history that it took this action, despite its authority clearly defined in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Beyond Pesticides has since called for the banning of weedkillers atrazine and paraquat under what it calls the Dacthal Standard.

Consider subscribing to Action of the Week to learn how to support the growth of policies and decision-making that hold the agrochemical industry accountable while supporting organic and regenerative organic food systems.

All unattributed positions and opinions in this piece are those of Beyond Pesticides. 

Source: International Journal of Agricultural Sustainability