(Beyond Pesticides, April 23, 2024) The Office of Inspector General for the U.S. Environmental Protection Agency (EPA) released a report last week finding that the agency has failed to establish “institutional controls” at the American Creosote Works Superfund Site in Pensacola, Florida, leading to continuous groundwater and soil contamination that “leav[es] the public at risk of exposure.” The 1980 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) established the Superfund program, codified under 42 U.S.C. Chapter 103, to clean up contaminated sites with tax money from polluting industries.

The OIG made eight recommendations for the regional EPA administrator and one for the assistant administrator “for Land and Emergency Management to improve the institutional controls at American Creosote Works Superfund Site.” There are three main determinations found in the results section of the OIG report: first, the institutional controls to prevent potential exposure were either “insufficient or unimplemented;” second, the EPA missed its mark in communicating associated risks to the public in areas surrounding this Superfund site; and third, the full administrative record for this site was not available at the time of inspection. This report builds on what advocates argue is the sustained legacy of EPA inaction and failure to protect public health and enforce environmental protections, particularly on the issue of wood preservatives laced with toxic chemicals.

Each determination breaks down as follows: First, the OIG defines institutional controls as “administrative and legal tools that help minimize the potential for human exposure to contamination and protect the integrity of the engineered remedy by limiting land or resource use and guiding human behavior.” EPA failed to achieve the basic definition of institutional controls when it permitted the use of groundwater through the installation of new wells on some nearby private land parcels and “did not conduct well surveys between 2002 and 2013.” When EPA did conduct surveys, “only 61 percent of the properties listed inside the groundwater delineation area” were included despite the remaining residents living in areas of potential contamination. Regarding information sharing on potential exposure via soil contamination, “EPA relied on the community to distribute information and the remedial project manager’s verbal direction to private property owners to guide the owners’ land-use choices,” which is problematic given the turnover of private land over the years can lead to construction that dredges up contaminated soil and leads to potential increased levels of exposure. Compounding the lack of information sharing and administrative hiccups, there was also missing required documents (per CERCLA regulations) between EPA and local/state stakeholders including a memorandum of understanding between EPA and Northwest Florida Water Management District regarding protocols around denying well drilling permits within the zone of potential contamination. Nor was there proof of the creation of an Institutional Control Implementation Assurance Plan for the Superfund site that is designed to establish the parameters and monitoring mechanisms for the institutional controls in question.

Second, EPA failed to adequately and consistently keep the public informed of the associated hazards the Superfund site posed for nearby community members. For example, “EPA’s GIS databse file for the ACW Superfund site does not accurately represent the extent of the site contamination” in terms of contamination spillover beyond the geographical boundaries of the site, which OIG predicts could “mislead interested parties, such as parcel owners, real estate agents, and contractors…to believe that there is no soil contamination” outside of the old site.

Third, the report cites EPA’s failure to maintain a complete copy of the site’s administrative record near or at the site for public access per CERCLA regulations. Both in the office and on the website page, there was a lack of complete, relevant documentation. On the website, as of 2023, “The webpage did contain an electronic repository of documents under the ‘Reports and Documents’ section. However, collectively these documents also do not compose a complete administrative record because they do not include all the Records of Decision or the assessments, investigations, or feasibility studies on which the EPA based its remedial decisions. The EPA’s ACW webpage also did not include an index, and the electronic repository does not include documents demonstrating public involvement in the remedial decisions.”

The report outlines that, out of the nine total recommendations, there are still three left unresolved due to disagreement with the EPA Region 4 lead as signaled in the previous paragraph. Recommendations 3, 4, and 6 unpack how to solve the listed problems above.

• Recommendation 3 recommends that “the EPA work with property owners and appropriate local governments to establish restrictive covenants before remediation began to prevent the disturbance of soil on impacted properties.”
• Recommendation 4 recommends that “[EPA Region 4] establish formal agreements with state and local government stakeholders regarding institutional controls.”
• Recommendation 6 recommends that “the region ensure the existence of a complete physical administrative record.”

The report goes on to assess the regulatory inconsistencies of EPA’s insistence on exclusively maintaining an electronic administrative record, “Given that this site-specific language is used in the final rule [a CERCLA regulation from 2013 called ‘National Contingency Plan’] to address a comment on how the EPA will determine community preferences, the region’s approach to provide an electronic-only administrative record is inconsistent with the assurances provided during the rulemaking process.” (See page 22 of the OIG report for a status update on all 9 recommendations.)

“This report is not an aberration, but it is an indication that the U.S. EPA continues to fall short of its commitment to inform the public in accordance with federal regulations,” says Max Sano, organic program associate at Beyond Pesticides.

Case in point back in 2021, EPA Administrator Michael Regan visited Houston, Texas to tour a petroleum facility owned by Union Pacific Railroad Company as thousands of surrounding community members sued the corporation for adverse health effects allegedly caused by creosote contamination. The city of Houston was sued in the aftermath of a 13-year-old boy living near the facility who died of leukemia after a five-year battle with the disease. Yet, Administrator Regan failed to see the connection between lived experiences of frontline communities impacted by creosote wood preservatives since the EPA moved forward with its decision to reauthorize creosote use for another 15 years. Beyond Pesticides engaged with grassroots advocates for the EPA to acknowledge this fundamental disconnect through a previous Action of the Week (You can still engage on this issue as well!)

Creosote-induced health problems have emerged in communities across the country, such as Springfield, Missouri where a retired Kerr-McGee Treatment Facility continues to threaten community members. Creosote-laced wood in railroad tracks has also been of considerable alarm for community members living alongside railroad tracks dotted across the nation, including concerns from residents in Great Barrington, Massachusetts.

Federal inaction on toxic chemicals in wood products has been a longstanding problem. Beyond Pesticides released a report on the lasting effects of toxic chemicals in traditional utility poles, “Poison Poles – A Report About Their Toxic Trail and Safer Alternatives.” The problem of public exposure to creosote and toxic chemicals in wood goes beyond Superfund sites. “Using a pole distribution formula…there are well over 116 million mini-waste sites in backyards, school yards, along rivers and lakes, and up and down roadsides across the country. Out of the over 3,000 electric utilities in the U.S., over one-half of these toxic poles are put in place by the 100 largest utilities. That translates to more than one toxic pole per household.” In May, King 5 News in Seattle, WA, sampled soil near pentachlorophenol-treated utility poles and found that in every case pentachlorophenol had leached out of the wood.” Beyond Pesticides found the following as far back as the late 1990’s: Wood preservative treatment facilities have contributed greatly to the ranks of Superfund cleanup sites. On the National Priority List (NPL) of sites identified by EPA: (i) Arsenic has been found in at least 781 NPL sites; (ii) Penta had been found at least 314 NPL sites; (iii) Chromium has been found in at least 386 hazardous waste sites on the NPL; (iv) Copper has been found at least 210 NPL sites; and (v) Creosote has been found at least 38 of NPL sites. Based on data from the EPA’s Superfund Enterprise Management System, there are 63 current and proposed Superfund sites based on former facilities in “Lumber and wood products/wood preserving/treatment” with creosote and pentachlorophenol that fall on the National Priorities list as of 2024. If you zoom out beyond those two contaminants, there are 76 current and proposed Superfund sites on former wood product facilities that fall on the National Priorities List. If you zoom out further, former wood product facilities make up over 139 across all different site types (NPL, Superfund Alternative Approach, or not NPL) .

In 2022, EPA announced the cancellation of pentachlorophenol, which is still used on utility poles and railroad ties, as well as other industrial uses. The agency announced that registrants (chemical manufacturers) were to voluntarily cancel their penta products by February 29, 2024. EPA is then providing another 3 years for registrants to utilize their left-over stocks of penta, placing a hard end date on February 29, 2027. Despite highly elevated risk factors, EPA did not act until the last manufacturer shut down their operations in Mexico under the Stockholm Convention on Persistent Organic Pollutants, (See also Environmental Racism Strikes South Carolina Community—with the siting of a pentachlorophenol wood preservative plant.) Regarding creosote, the European Union begun a review of its environmental health impacts in 2011. Fast forward to 2022, the majority of EU states voted in favor of restricting its further authorization. Then, beginning at the end of April 2023, creosote was banned for treatment on fenceposts. However, the pesticide continues to be authorized for railroad tracks and utility poles.

Consumers and children, who are particularly susceptible to deadly and chronic health problems compared to the general population, have the right to avoid exposure to toxic chemicals in and surrounding their homes. See Tools for Change to learn how to organize in your community toward policies that align with Beyond Pesticides’ mission to eliminate toxic petrochemical substances and pesticides within the decade. See Gateway on Pesticide Hazards and Safe Pest Management to identify particular toxic pesticides and substances of concern linked with relevant reports, fact sheets, and studies.

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

Source: Office of Inspector General U.S. Environmental Protection Agency

(Beyond Pesticides, April 22, 2024) Today, on Earth Day, the future of the planet and the health of all its inhabitants come into focus from numerous human and ecosystem health perspectives, with particular concern for the health of the next generation—as childhood cancer continues to be a leading cause of death from disease among children. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring.

Taking Action in Your Community: On Earth Day, Beyond Pesticides invites communities to join together in its nationwide campaign to convert parks to organic land management practices through the Parks for a Sustainable Future program. Through this program, Beyond Pesticides works with park managers, bringing hands-on horticultural support to eliminate petrochemical pesticides and fertilizers and instead nurture soil organisms to cycle nutrients naturally while creating resilient landscapes that resist weeds, insects, and disease. This program outlines the steps to become a parks advocate and how Beyond Pesticides works with communities committed to safe parks and playing fields for communities, children, and pets.

One major impetus for the Parks program are the many studies that find prenatal and early-life exposure to environmental toxicants increases disease susceptibility. For decades, studies have long demonstrated that childhood and in-utero exposure to the U.S.-banned insecticide DDT increases the risk of developing breast cancer later in life. Risks from exposure to pesticides and other toxic chemicals during pregnancy include: pesticides and children’s sleep disorders; prenatal exposures to a multitude of chemicals; insecticides and childhood leukemia; insecticides and Attention Deficit/Hyperactivity Disorder.

Taking Action on Policy:
Tell EPA to ban carcinogenic pesticides. Tell your Congressional Representative and Senators to support S. 269 and H.R. 5085, the Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA).

A study published in Environmental Research suggests occupational (work-related) exposure to pesticides among nonpregnant women and men may increase childhood cancer risk for offspring. Low levels of pesticide exposure during pregnancy or childhood cause adverse health effects from metabolic disorders to mental and physical disabilities. Moreover, several studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer, specifically focusing on leukemia. Acute leukemia is the most common type of childhood cancer, accounting for one of three cancer cases in children ages 0 to 14. Although the disease is rare, incidents have been steadily increasing among adolescents over the last 30 years.

Researchers at the National Institute of Pediatrics and National Polytechnic Institute found positive associations between pesticide exposure and heightened risk of certain childhood cancers. The finding is derived from a meta-analysis of 174 studies published between 2013 and 2023 and reported in the International Journal of Molecular Science. The authors note, “Although [pesticide exposure] association with childhood cancer has not been fully demonstrated, we found that more than 80% of the epidemiological studies show positive associations [with forms of childhood cancer].”

Even household cleaners, many of which are pesticides, can increase nephroblastoma (kidney cancer) and brain tumor risk in children. Furthermore, long-term exposure to organophosphate (OP) pesticides increases adverse health and cancer risks, specifically among women. Since DDT and its metabolite DDE residues, current-use pesticides, and other chemical pollutants contaminate the environment, exposure to these chemical mixtures can synergize to increase toxicity and disease effects.

A literature review published in Ciência & Saúde Coletiva finds environmental exposure to all classes of pesticides (fungicides, herbicides, insecticides) has an association with childhood astrocytoma (brain/central nervous system [CNS] tumor). CNS tumors represent half of all malignant neoplasms (tumors) in children.

A 2024 Environmental Research study found an association between adverse neurodevelopment (brain function and development) among infants and exposure to the herbicide glyphosate during pregnancy, which becomes more pronounced at 24 months. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure, leading to reduced melatonin levels that ultimately disrupt circadian rhythm and lead to sleep disorders later in life, according to a 2023 study in Antioxidants.

In addition to maternal/prenatal exposure to herbicides, children experience exposure to pyrethroid insecticides early in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life, according to a study published in Frontiers in Public Health in 2023. Moreover, pediatricians strongly agree that pregnant mothers and young children should avoid pesticide exposure during critical development periods.

The state of pesticide regulation and of research into pesticide impacts is inadequate and like nothing so much as a game of “whack-a-mole.” A single pesticide or class of pesticides is studied, a paper is written, and policy makers and regulators may or may not pay attention. Then another one happens, and another, and another, ad infinitum. The pattern of “progress” is similar on the regulation side: individual pesticides registered (aka, approved) by the U.S. Environmental Protection Agency (EPA) are reviewed “on the regular” — but only every 15 years, barring an emergent and urgent concern. Given the cascade of discovery of harmful impacts over the past couple of decades, 15 years has become a very long window in which to allow continued use without review.

When EPA undertakes more timely review due to an urgent concern, it still considers one chemical at a time. Even more fundamentally, its approach to regulation, in the face of evidence of harm, is often characterized by tweaking the use of toxic pesticides “at the margins” — requiring a change to the text on a pesticide label, reducing the time frame in which a compound can be used, restricting application to trained applicators, or other piecemeal actions that are generally wholly inadequate to reducing the health and environmental harms of these compounds being unleashed into the environment.

EPA also continues to fall short on multiple research and regulatory fronts, failing to consider synergistic impacts, multiple exposure vectors, and endocrine disruption effects, among others. In addition, the agency is far too dependent on industry-generated research, influenced by agrochemical industry lobbying, and sometimes, in downright collusion with industry.

It is unconscionable to continue tweaking restrictions on pesticides with known hazards and broad uncertainties about the effect of mixtures, synergistic effects, and cumulative risk, given the availability of organic systems that eliminate those hazards economically and solve the looming environmental threats. Buying, growing, and supporting organic land management can reduce human and environmental contamination from pesticides. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices. Numerous studies find that pesticide metabolite levels in urine significantly decrease when switching to an all-organic diet.

Globally, cancer is one of the leading causes of death, with over eight million people succumbing to the disease every year. Notably, the International Agency for Cancer Research (IARC) predicts a 67.4 percent rise in new cancer cases by 2030. Thus, it is critical that both government officials and the public understand the health implications of pesticide use and exposure on humans, especially when pesticides increase chronic disease risk.

Some elected officials are attempting to take action. The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S. 269 and H.R. 5085, addresses many of the controversial issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S.

Tell EPA to ban carcinogenic pesticides. Tell your Congressional Representative and Senators to support S. 269 and H.R. 5085, the Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA).

Letter to EPA:

I am writing out of concern that EPA is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects.

Occupational exposure to pesticides among nonpregnant women and men may increase childhood cancer risk for offspring. Studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer, specifically leukemia. Acute leukemia is the most common type of childhood cancer, accounting for one of three cancer cases in children ages 0 to 14, and incidence has been steadily increasing among adolescents over the last 30 years.

Even household cleaners, many of which are pesticides, can increase kidney and brain cancer risk in children. Long-term exposure to organophosphate pesticides increases adverse health and cancer risks. A literature review published found environmental exposure to all classes of pesticides is associated with childhood brain/central nervous system tumors, representing half of all malignant tumors in children.

Adverse neurodevelopment among infants is associated with exposure to glyphosate during pregnancy. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure. In addition to maternal/prenatal exposure to herbicides, children experience exposure to pyrethroid insecticides early in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life.

Moreover, pediatricians strongly agree that pregnant mothers and young children should avoid pesticide exposure during critical development periods.

The state of pesticide regulation and of research into pesticide impacts is inadequate and resembles a game of “whack-a-mole”—in which single pesticides or a class of pesticides are studied for specific effects. And EPA only considers one chemical at a time, ignoring research showing that the synergy of exposure to multiple chemicals in the environment that increases toxicity and disease effects. All of these effects have environmental justice implications since farmworkers are most exposed.

More fundamentally, the approach to regulation in the face of evidence of harm, characterized by tweaking the use of toxic pesticides—requiring a change to the text on a pesticide label, reducing the time frame in which a compound can be used, restricting application to trained applicators, or other piecemeal actions—is wholly inadequate to reduce the health and environmental harms of these compounds being unleashed into the environment.

It is unconscionable to continue tweaking restrictions on pesticides with known hazards and broad uncertainties about the effect of mixtures, synergistic effects, and cumulative risk, given the availability of organic systems that eliminate those hazards economically and solve the looming environmental threats. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices.

Our children’s health requires elimination of cancer-causing pesticides.

Thank you.

Letter to U.S. Representative and Senators who are co-sponsors of PACTPA:

I am writing out of concern that our pesticide law is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects.

The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269 and H.R 5085, addresses many of the issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S. I am happy to see that you have joined this effort to protect our nation’s children. In addition to thanking you for your co-sponsorship of the legislation, I’m writing to ask you to also seek broader protections, especially necessary to protect children.

Despite an impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, please consider amending the legislation to:

* Prohibit the registration and use of pesticides that do not meet these criteria:

– Necessary to prevent harm to humans and the environment based on an analysis of all alternatives;

– Cause no harm to humans and the environment; and

– Protect against the existential crises of biodiversity collapse, runaway climate change, and chronic and acute health threats.

* Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration).

* Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects.

* Deny and cancel registrations of all pesticides posing a threat to life in the soil—and hence threatening the climate.

* Deny and cancel registrations of all pesticides posing a threat to any endangered species.

Thank you.

Letter to U.S. Representative and Senators who are NOT co-sponsors of PACTPA:

I am writing out of concern that our pesticide law is failing to protect children from cancer caused by exposure to pesticides. While medical advancements have resulted in greater survival, childhood cancer remains the leading cause of death from disease among children. Furthermore, childhood cancer survivors can suffer from chronic or long-term health complications that may be life-threatening. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring, as well as greater disease susceptibility and neurological effects.

The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269 and H.R 5085, addresses many of the problems with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S.

PACTPA would provide some desperately-needed improvements to FIFRA to better protect people and the environment, including:

* Bans some of the most damaging pesticides scientifically known to cause significant harm to people and the environment:

– Organophosphate insecticides, which have been linked to neurodevelopmental damage in children;

– Neonicotinoid insecticides, which been shown to cause developmental defects, heart deformations, and muscle tremors in unborn children;

– Paraquat, which is one of the most acutely toxic herbicides in the world—already banned in 32 countries, including the European Union.

* Removes dangerous pesticides from the market by:

– Creating a petition process to enable individual citizens to petition the EPA to identify dangerous pesticides so that dangerous pesticides would not remain on the market indefinitely;

– Closing loopholes that have allowed the EPA to issue emergency exemptions and conditional registrations to use pesticides before they have gone through full health and safety review;

– Enabling local communities to enact protective legislation and other policies without being vetoed or preempted by state law;

– Suspending the use of pesticides deemed unsafe by the E.U. or Canada until they are thoroughly reviewed by the EPA.

* Provides protections for frontline communities that bear the burden of pesticide exposure by:

– Requiring employers of farmworkers to report all pesticide-caused injuries to the EPA, with strong penalties for failure to report injuries or retaliating against workers;

– Directing the EPA to review pesticide injury reports and work with pesticide manufacturers to prevent future injury;

– Requiring that all pesticide label instructions be written in Spanish and in any language spoken by more than 500 pesticide applicators.

Despite this impressive list of corrections, PACTPA does not touch the toxic core of FIFRA, which permits the unnecessary dispersal of toxic chemicals in the environment. To eliminate this toxic core, please support legislation to:

* Prohibit the registration and use of pesticides that do not meet these criteria:

– Necessary to prevent harm to humans and the environment based on an analysis of all alternatives;

– Cause no harm to humans and the environment; and

– Protect against the existential crises of biodiversity collapse, runaway climate change, and chronic and acute health threats.

* Require all supporting data to be submitted and examined by the public before registration (including the elimination of conditional registration).

* Deny and cancel all pesticide registrations not supported by studies demonstrating a lack of endocrine-disrupting effects.

* Deny and cancel registrations of all pesticides posing a threat to life in the soil—hence threatening the climate.

* Deny and cancel registrations of all pesticides posing a threat to any endangered species.

Thank you.

(Beyond Pesticides, April 19, 2024) Parkinson’s disease (PD) and certain forms of dementia have been associated with exposure to pesticides, industrial chemicals, and air pollution for decades. But the mechanisms of disease progression have been unclear, and U.S. regulators have been reluctant to recognize the risks. Now neurologist E. Ray Dorsey, MD of the University of Rochester and researchers from the University of Alabama at Birmingham and Aarhus University in Denmark propose a new research paradigm based on tracking how toxicants cause neurodegeneration through inhalation and ingestion pathways.

The paradigm, the authors believe, can be used to gain insight into how PD and a form of dementia known as Lewy body disease (LBD) are initiated as many as 50 years before the onset of symptoms. Dorsey and colleagues build on a recent theory that PD and LBD may be two versions of the same basic disease, both involving Lewy bodies in the nervous system.

The group’s proposal was published in the Journal of Parkinson’s Disease in April. If its recommended research agenda produces the anticipated empirical support, the new paradigm will demand integration of many interdisciplinary lines of evidence showing that environmental exposures to synthetic chemicals may be the primary cause of the worldwide epidemic of neurodegenerative disease. Regulatory capture by industry and spineless policy responses to it will no longer suffice to prevent reimagining chemicals policy at a most basic level.

A symposium to discuss the proposed paradigm will occur on Monday, May 20 from 9:00 a.m. to 5:30 p.m. at the Phillips Collection, 1600 21st Street NW, Washington, D.C. Sessions will be moderated by journalists Katie Couric, Jake Tapper, and others. The Michael J. Fox Foundation is a major conference funder.

Dorsey and colleagues review the mounting evidence that PD and LBD have two principal routes to their ultimate neurological harms. One, known as “brain-first,” is quite direct: inhaled through the nose, a toxicant can travel to the olfactory bulb in the brain, from which it spreads to many other brain structures. The second route, through ingestion, called “body-first,” takes the toxicant to the gut, where it initiates the Lewy body disorder in the enteric nervous system (ENS or digestive system’s nervous system). Lewy bodies then propagate into the parasympathetic nervous system, the central nervous system and the brain. Thus, according to this paradigm, the dysfunctions associated with PD and LBD affect the entire neurological network of the body, not just the brain.

The researchers estimate that the majority of LBD cases and about a third of PD cases result from the body-first route. The timing of onset of various symptoms such as loss of motor control, sleep disorders and dementia varies according to the route.

One of the pesticides associated with PD is paraquat, a powerful herbicide currently registered by EPA for application only by licensed operators. Our April 16 Daily News Brief delineates the reasons paraquat should be taken off the market entirely.

Paraquat presents myriad health hazards—EPA itself says, “One small sip can be fatal and there is no antidote.” Beyond this direct lethality to humans and many other organisms, paraquat is linked to thyroid cancer, lung fibrosis, endocrine disruption and liver tumors. It was banned in the European Union in 2007; currently more than 60 countries prohibit its use. But EPA refused to accept the mounting evidence that paraquat is implicated in PD, stating in a 2019 human health risk assessment that for both occupational and non-occupational exposures, there is “insufficient epidemiologic evidence of a clear associative or causal relationship.” This echoes paraquat manufacturer Syngenta’s position in class action litigation brought by PD victims. One bright spot is that the California Assembly is currently considering phasing out paraquat from all uses by the end of 2025.

Only 15 percent of PD victims have a family history of the disease, which implies that environmental factors—and likely multiple simultaneous insults—are involved. Toxicants linked to PD and LBD include not just paraquat but also organochlorine pesticides, trichloroethylene and perchloroethylene (largely responsible, along with benzene and vinyl chloride, for the severe water contamination at Camp Lejeune in California), and particulates from fossil fuel air pollution and wildfires. Dorsey and colleagues’ literature review includes many studies demonstrating PD’s and LBD’s association with environmental toxicants. “In rural areas,” they write, “the prevalence of PD is almost perfectly correlated with pesticide use.” Just drinking well water and working in agriculture are strongly associated with PD prevalence.

The exact processes by which degenerative brain diseases progress remain complex and confusing. PD and LBD resemble Alzheimer’s disease and have some commonality with transmissible spongiform encephalopathies such as Creutzfeldt-Jakob disease, “mad cow,” and the sheep disease scrapie. In PD and LBD, a protein called alpha-synuclein (α-Syn) is important to neuronal signaling. It is something of an oddity, being able to fold itself into multiple configurations even in healthy brains, but is also prone to misfold in ways that interfere with neurotransmitters. During development of PD and LBD, clumps of α-Syn called Lewy bodies form. Once this happens, neurons die and various neurological processes affecting motor coordination, sleep, memory and many other functions begin to fail. Dorsey’s team suggest that α-Syn behaves something like the prions that misfold to induce the transmissible encephalopathies. One misfolded protein can trigger another to copy it, propagating the problem throughout a nervous system.

The authors emphasize that not everyone exposed to environmental toxicants develops PD or LBD. Age at exposure, length of exposure, the involvement of multiple toxicants, and other factors influence the outcome. While a family history of PD and LBD accounts for a small percentage of cases, it does raise the risk of contracting the diseases, and several genes are known to be involved. Little of their influence is understood. At the same time, however, Dorsey and colleagues write that despite having known for a generation about environmental factors, “[We] have fundamentally underinvested in and under-investigated the role environmental toxicants are playing.”

Much research remains to determine the validity of the double-route toxicant paradigm. Clearly there must be research into enteric Lewy bodies and their propagation throughout the whole body nervous system. Dorsey and colleagues suggest approaches for further investigation of exposure scenarios, including comparative analysis of environmental samples such as air, water, and food, as well as biomonitoring samples such as breast milk, urine and blood; and geospatial mapping of PD/LBD prevalence in areas where pesticides and industrial chemicals are present. They also find reason to hope that the severity of these incurable, devastating and fatal diseases can be reduced if exposures are reduced even after disease onset.

Proving the principle will require interdisciplinary studies and synthesis of results from numerous research specialties. If it pans out, it will throw open the gates of inquiry and destabilize chemicals policy, because if PD, LBD and other neurodegenerative diseases are initiated by environmental exposures through the gut and olfactory pathways to the nervous system, the causes of these diseases can no longer be considered in piecemeal fashion. They cannot be entirely explained as mysterious ailments that randomly strike unfortunate people, or are determined by genes. They must be considered as manifestations of the fossil fuel system that is destroying the health of humans and ecosystems and dealt with at the scale of the problem.

For more information on the adverse health impacts of paraquat, see its entries in Beyond Pesticides’ Gateway on Pesticide Hazards and Safe Pest Management and Pesticide-Induced Disease Database.

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

Sources:

The Body, the Brain, the Environment, and Parkinson’s Disease
Dorsey, E. Ray et al.
Journal of Parkinson’s Disease
1 Jan. 2024: 1 – 19.
https://content.iospress.com/articles/journal-of-parkinsons-disease/jpd240019

Risk of Parkinson Disease Among Service Members at Marine Corps Base Camp Lejeune
Samuel M. Goldman et al.
JAMA Neurol. 2023;80(7):673-681. doi:10.1001/jamaneurol.2023.1168
https://jamanetwork.com/journals/jamaneurology/article-abstract/2805037

Brain and Environment Symposium: A day-long symposium to uncover the influence of environmental toxicants on brain disorders
https://brainandenvironment.org/

Comment submitted by Beyond Pesticides
Paraquat Interim Registration Review
March 29, 2024
EPA-HQ-OPP-2011-0855
https://downloads.regulations.gov/EPA-HQ-OPP-2011-0855-0339/attachment_1.pdf

Secret files suggest chemical giant feared weedkiller’s link to Parkinson’s disease
Documents seen by Guardian detail effort to refute scientific research into paraquat and derail nomination of key EPA adviser
by Carey Gillam and Aliya Uteuova
https://www.theguardian.com/us-news/2022/oct/20/syngenta-weedkiller-pesticide-parkinsons-disease-paraquat-documents

(Beyond Pesticides, April 18, 2024) University of Michigan researchers have found a statistically significant relationship between heightened risk of amyotrophic lateral sclerosis (ALS) and household exposure to lawn care products and pesticides. The study results were published earlier this month in Amyotrophic Lateral Sclerosis and Frontotemporal Degeneration. The interdisciplinary research team concludes that modifying residential exposure to toxic substances, including pesticides, can play an important role in ALS susceptibility and prognosis. The results build on a substantial body of scientific literature identifying pesticide exposure in various ALS cohort studies. Advocates say that these adverse effects, along with other numerous health and environmental effects, inform their call for the phaseout of toxic pesticide use and the adoption of alternative practices and eco-compatible products.

All participants in this study are patients at the University of Michigan Pranger ALS Clinic with Gold Coast ALS diagnosis, which according to a Muscle & Nerve study refers to the identification of two factors: “progressive motor impairment documented by history or repeated clinical assessment” and “the presence of upper and lower motor neuron dysfunction in a least one body region.” All 367 ALS and 255 control patients were tasked with completing a survey in which they self-reported their exposure to a list of toxic substances at four households over their lives: current home, birth home, and two other homes where they had lived the longest. The researchers split up the patients into three “latent profile” groups. The first group consisted of participants with “high storage of chemicals in a detached garage;” the second group consisted of participants “who had high storage of chemicals in an attached garage;” and the third group consisted of participants “who had low storage of chemicals in a garage.” Generally, group three participants had a higher proportion of participants without ALS than the other two groups with detached and attached garages with higher proportions of chemicals.

The researchers in this study find that pesticide storage, lawn care product storage, and woodworking supplies storage indoors have a statistically significant relationship with poorer ALS survival.

Researchers used a descriptive statistical analysis for their study cohort, using logistic regression models “to estimate one-at-a-time association[s] between residential exposures and case/control status.” The researchers describe their analytical approach as follows: “[M]ultinomial [more than two categories] regression models estimated associations between residential exposures and three onset segments (bulbar, cervical, lumbar); and Cox proportional hazards models estimated associations between residential exposures and post-diagnosis survival.” Onset segments refer to the parts of the body in which patients noticed early indications of motor disfunction consistent with ALS. “Logistic and multinomial regression models were adjusted for military service, sex, education, life-years covered by self-reported residences, and life-years not covered by self-reported residences. The hazards models were adjusted for military service, sex, age at diagnosis, education, log-transformed time between symptom onset and diagnosis, El Escorial criteria [for ALS classification], onset segment, family history of ALS, life-years covered by the self-reported residences, and life-years not covered by the self-reported residences.” The use of logistic and multinomial regression is helpful in determining patient demographics not otherwise covered in the self-reported survey component of the study.        

A team of researchers at Michigan Medicine reached similar conclusions in a 2022 study published in International Archives of Occupational and Environmental Health, which indicated that ALS patients working in manufacturing, welding, and chemical jobs “reported higher occupational exposure to metals, particulate matter, volatile organic compounds and combustion pollutants prior to diagnosis.”

While there is no confirmed treatment or cure for ALS, scientists have engaged in studies to better understand the triggers for this neurodegenerative condition since it was discovered in 1869 by French neurologist Jean-Martin Charcot. Approximately 5,000 new cases of ALS are documented annually in the United States, according to the Centers for Disease Control and Prevention. There is sporadic ALS and familial ALS, with the former making up more than 9 in 10 of all ALS cases. Sporadic ALS means that the condition is not necessarily onset by a particular risk factor or familial history. Cohort studies on sporadic ALS are important to follow because studies such as the one conducted by Michigan Medicine indicate the associated risks that pesticide applicators face with heightened risk of debilitating chronic illnesses such as ALS. Otherwise regarding familial history cases, according to National Institute of Neurological Disorders and Stroke, 25-40 percent of all cases are a result of a defect in the C9orf72 gene and another 12-20 percent of all cases are from a genetic mutation in the SOD1 gene.

Beyond Pesticides tracks the latest scientific literature on adverse health effects of toxic pesticide exposure, including ALS. A 2021 study published in Toxicology, for example, found individuals working or living in areas with frequent neurotoxic herbicide, insecticide, and fungicide (i.e. 2,4-D, glyphosate, carbaryl, and chlorpyrifos) use experience more ALS incidences than the general population. An earlier study published in International Journal of Environmental Research and Public Health in 2020 determined that exposure to agricultural and industrial pesticides, solvents (thinners), electromagnetic fields, and heavy metals predispose humans to ALS. For more studies and analysis, see the Daily News Blog section on ALS.

Advocates, scientists, community leaders, and physicians have engaged with Beyond Pesticides resources to mobilize their communities and institutions to address the longstanding adverse health effects of pesticide exposure. After tracking the latest scientific literature, synthetizing breaking developments and studies through the Daily News Blog, and submitting public comments and testimony at local, state and national levels for over four decades, advocates look to Beyond Pesticides to meet the mission of eliminating toxic petrochemical pesticide use by 2032. See Gateway on Pesticide Hazards and Safe Pest Management to learn about specific pesticide ingredients and the various adverse health impacts they impose on wildlife, ecosystems, and humans. See Pesticide-Induced Disease Database to learn about the impacts of toxic pesticides in contributing to chronic diseases, including ALS. See Non-Toxic Lawns and Landscapes to learn about strategies and access resources to move beyond the use of toxic petrochemicals in lawncare throughout your community.

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

Source: Amyotrophic Lateral Sclerosis and Frontotemporal Degeneration

(Beyond Pesticides, April 17, 2024) With headlines drawing public attention to the contamination of drinking water after years of federal government neglect, the U.S. Environmental Protection Agency (EPA) announced on April 10 new standards to reduce public exposure to PFAS, or per- and polyfluoroalkyl substances, commonly referred to as “forever chemicals” because of their persistence. EPA has finalized a National Primary Drinking Water Regulation (NPDWR) for six PFAS, including PFOA and PFOS, which EPA has recognized have no safe level of exposure, regulating new chemicals for the first time since the 1996 amendments to the Safe Drinking Water Act (SDWA). PFAS persistence and bioaccumulation in humans, wildlife, and the environment is due to the strength of a resulting fluorine–carbon atom bond. PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply—among other resources—is ubiquitous worldwide. PFAS is used in everyday products, including cookware, clothes, carpets, as an anti-sticking and anti-stain agent, in plastics, machinery, and as a pesticide. The action was welcomed by environmentalists and public health advocates as an important step but left many concerned that any level of exposure to these chemicals is unacceptable and critical of EPA’s ongoing failure to act despite years of overwhelming scientific evidence of harm and the availability of safer alternative materials and practices.

PFAS or related compounds are included in 70% of pesticides introduced to the global market from 2015 to 2020, according to a review paper published in January 2022 in Environmental Pollution. And the surge in their use has come without a full understanding of their potential impact on the environment and human health. PFAS health risks include developmental, metabolic, cardiovascular, and reproductive harm, cancer, damage to the liver, kidneys, and respiratory system, as well as the potential to increase the chance of disease infection and severity. Gestational (during pregnancy) and childhood exposure to PFAS increases cardiometabolic risk, or the risk of heart diseases and metabolic disorders, later in life, according to a Brown University study published in Environment International in 2021.  In light of the adverse effects, Beyond Pesticides has urged EPA and other federal agencies to advance alternatives to PFAS, rather than establish levels of harm with acceptable residues, issuing a nationwide action in March calling for the federal government to facilitate a transition away from plastics in farming, food, and water.

PFAS Solution Must Be Comprehensive: Stop Use of PFAS, Prevent “New” PFAS Replacements

The PFAS contamination problem, according to advocates, calls for a comprehensive policy rather than the “whack-a-mole” approach to chasing individual contamination crises after they have occurred and inflicted serious harm to people’s health. With a holistic strategy, like that contained in organic land management under the Organic Foods Production Act (OFPA), the government must consider “cradle-to-grave,” from production through use to disposal, and require that systems are put in place to prevent the need for use of synthetic materials. In this context, the goal is to eliminate the use of petrochemical substances that are contributing to daily health threats, biodiversity collapse, and the climate emergency.

EPA PFAS Drinking Water Regulation

The NPDWR establishes maximum contamination limits (MCLs) for PFOA and PFOS at 4 parts per trillion (ppt) (the limit of detection), two among the roughly 14,000 known PFAS. Additionally, the rule imposes a 10 parts10 parts per trillion (ppt) limit for three other PFAS—PFHxS, PFNA, and HFPO-DA (commonly referred to as GenX), while introducing a combined limit for four PFAS, calculated using a Hazard Index method. The Hazard Index calculates a compliance value from the detected PFAS levels—if the total ratio of these levels reaches or exceeds 1.0, water systems are required to lower these PFAS levels. Actions might be necessary even if only one of these four chemicals is detected at significant levels. EPA plans to provide an online calculator to help water systems determine their Hazard Index compliance. In addition, regulated public water systems have three years to complete their initial monitoring. Systems must include their results in their Annual Water Quality reports to customers, and PFAS detected above the new standards triggers a requirement to reduce if levels exceed the new limits within five years. EPA estimates that six to ten percent of water systems will be affected. These rules will be implemented by and will require state, tribal, and other public water systems to implement testing and treatment to remove these chemicals.

Additionally, EPA has set Maximum Contaminant Level Goals (MCLGs), which are non-enforceable health goals indicating safe levels without any health risks. These goals are not legally enforceable, focusing purely on health impacts without considering economic or technical feasibility—unlike MCLs, which are legally enforceable under SDWA and require a cost-benefit analysis. EPA has set MCLGs at zero for PFOA and PFOS, recognizing no level of exposure is safe, and 10 parts per trillion ppt for the remaining PFAS. Given that EPA itself has set health advisory levels for certain PFAS at zero, or in the parts per quadrillion, advocates continue to raise alarm at the inability of the regulatory framework to impact the enormity of the crises PFAS represents.

Through the Bipartisan Infrastructure Law, EPA has $21 billion allocated to strengthen U.S. drinking water systems, with $9 billion targeted toward addressing PFAS and emerging contaminants. The financing programs are part of President Biden’s Justice40 Initiative, seeking to have 40% of the overall benefits of certain federal investments flow to disadvantaged communities historically marginalized by underinvestment and overburdened by pollution. With this funding, EPA commits to assisting water systems with the adoption of technologies like granular activated carbon and reverse osmosis to meet the new standards.

After years of advocate pressure, EPA began to take action under its PFAS Strategic Roadmap—including “designat[ing] two of the most widely used PFAS [PFOA and PFOS] as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),” issuing interim updated drinking water health advisories for PFOA and PFOS, and issuing final health advisories on two others that had been considered “replacement” chemicals for manufacturing uses—perfluorobutane sulfonic acid and its potassium salt (PFBS), and hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (the so-called “GenX chemicals”). And yet, amid the public outcry, the number of PFAS compounds continues to grow. Since the phase-out of PFOA and PFOS, companies have shifted to “short-chain” PFAS such as GenX, which is now a significant concern, for example, in the Cape Fear Watershed downstream of a Chemours manufacturing plant in North Carolina,

Despite these new drinking water standards and progress, EPA’s steps are seen as incremental in confronting the pervasive threat of PFAS. This suggests a need for more aggressive and comprehensive regulations that preemptively curb the production and widespread use of PFAS rather than just managing their consequences. While setting a floor, advocates note that only six PFAS chemicals in use and production are covered by the new regulations.

In the absence of viable solutions at the federal level, a 2022 Safer States’ analysis of state-level legislation on PFAS demonstrates the extent of the problem that 22 states have taken steps to protect their residents. Eleven states (ME, MA, MI, NH, NJ, NY, PA, RI, VT, WA, WI) have implemented standards like Maximum Contaminant Levels (MCLs) for specific PFAS in drinking water. As of January, Maine currently enforces an interim standard during its rule-making process to set final PFAS MCLs, with a phase out by 2030, except for “currently unavoidable use.” Delaware and Virginia are also in the process of setting their own PFAS standards. Additionally, twelve states (AK, CA, CT, CO, HI, IL, MD, MN, NC, NM, OH, OR) have established guidance, health advisories, or notification levels for various PFAS chemicals to protect their residents. A handful of state legislatures are considering banning pesticides containing PFAS entirely—as the Maryland General Assembly considers HB 1190, prohibiting the sale and use of pesticides with PFAS as an active ingredient by 2025. (See Beyond Pesticides’ statement in support here and call to action here). Furthermore, recognizing the impacts on the agricultural sector from PFAS, the state of Maine has taken the lead in both state and federal efforts to support farmers who have been affected by PFAS contamination, including the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act. 

PFAS Contamination Vectors

As Beyond Pesticides reported in July 2023, a study by the United States Geological Survey (USGS) finds that almost half of U.S. tap water is contaminated with PFAS chemicals, with measured concentrations in both private wells and public water sources. Authors of the study “estimate that at least one PFAS could be detected in about 45% of U.S. drinking-water samples,” likely a low estimate as only 32 are detectable by USGS lab tests. Advocates note that while PFOA and PFOS are the most studied, it should not be implied that other legacy contaminants are safe or safer—the absence of knowledge does not translate to an absence of harm.

A known source of soil and drinking water contamination is PFAS added as ‘inert’ ingredients to pesticides and fertilizers. As Beyond Pesticides has noted, “Why would PFAS be found in a pesticide formulation? The chemicals are included as dispersants, surfactants, anti-foaming agents, or other pesticide adjuvants intended to increase the effect of the active ingredient. EPA includes PFAS chemicals in its “Inert Finder” database, and according to a PEER [Public Employees for Environmental Responsibility] press release, many companies have patents on file for pesticide formulations containing PFAS, shrouded behind claims of trade secret formulation and do not disclose PFAS ingredients. PFAS soil contamination is also likely from PFAS as an undisclosed ingredient in pesticide and/or fertilizer formulations.  pesticides with PFAS active ingredients will not cause disruptions to the pest management industry. Pest problems in agriculture and landscaped areas can be prevented through practices that improve soil health and promote biodiversity and habitat for pest predators. If pest problems do become an issue, a wide range of insecticidal soaps and essential oils, classified either as certified organic, or minimum risk, are available and represent a least-toxic option. See Beyond Pesticides resources on Organic and Organic Compatible Products, what individuals can do organically in yards and gardens, and the benefits of organic agriculture and choosing organic food.

Secondly, PFAS contamination results from leaching out of plastic containers and contaminating food products. As reported by Beyond Pesticides in 2023, research published in Environment Technology and Letters confirm the propensity of PFAS to contaminate various pesticide products through storage containers. Testing done by PEER in 2020 initiated testing done separately by the Massachusetts Department of Environmental Protection and the EPA, all of which found high levels of PFAS in several mosquito insecticide products sprayed throughout states like Massachusetts, Florida, and New York. Ultimately, EPA traced significant PFAS contamination to the manufacturing process used since 1983 by one manufacturer, Inhance Technologies, which produces 200 million HDPE containers a year. Multiple lawsuits and EPA stop use orders have been ineffective at ending this manufacturing process, used only by Inhance, although some other plastic containers have been shown to leach PFAS at lower levels.

Finally, PFAS compounds have been found to contaminate water and irrigation sources, and soils themselves — often using fertilizers made from so-called “biosludge” (biosolids) from local waste treatment plants. In addition, these plants may discharge millions of gallons of wastewater into waterways, contaminating them; current waste and water treatment generally does not eliminate PFAS compounds from the treated effluent water. Biosolids and wastewater have long been sources of exposure concerns related to pesticides, industrial chemicals, pharmaceuticals, personal care products, and household chemicals; PFAS contamination is now rising as a specific and concerning addition to that nasty list. These forever (and perhaps “everywhere”) compounds may be contaminating nearly 20 million acres of productive agricultural land in the U.S. A significant portion of farmers, perhaps 5%, is using biosludge from local treatment plants as fertilizer on their acreage. The use of biosludge was thought by many, a decade ago, to be a sensible use of the waste products from treatment; it was even encouraged by many state agricultural department programs, but now it is recognized that these products present threats when spread on fields that produce food—or anywhere that presents the possibility of living or environmental exposures to PFAS compounds. Notably, there are currently no federal requirements to test such sludge “fertilizers” for the presence of PFAS.  (See Beyond Pesticides reporting from 2022 on Maine laws against biosludge).

Biosludge products are not only sold to farmers; they also show up on the shelves of retailers as fertilizers for consumer home and garden use. The organization wrote in 2021 that these products not only often contain PFAS but also harbor “hazardous pesticides, heavy metals, antibiotics, and other pharmaceuticals, personal care products, and a range of other toxicants… None of these risks [are] relayed to consumers on fertilizer packages. With fertilizer regulations failing the American consumer, it becomes more important than ever to seek out certified organic fertilizer products.” (See here, here, and here for Beyond Pesticides list of organic and organic-compatible products).

Organic agriculture and land care

These new drinking water regulations from EPA would not happen without pressure from advocates, non-profit groups, and independent science, however, the solution does not go far enough. Transition, of course, requires time and effort, and should be supported by the state (and federal) governments, but getting off the toxic chemical treadmill in agriculture resolves multiple environmental and health problems simultaneously — including that of PFAS in pesticides and fertilizers and related contamination of soils, groundwater, and drinking water. EPA’s latest attempt underscores federal failures in regulation and the gravity of realigning federal and state agencies so that precaution becomes the guiding watchword. Legacy or “forever” chemical contamination is a dramatic demonstration of how a historically non-precautionary ethic in the U.S. can cause egregious harm — even years and decades hence. 

And the viable solution available to all producers? Organic regenerative agriculture.

Certified organic production and food labeled “USDA Organic” may not be produced with biosolids or fertilizers containing biosolids, and the National Organic Program proscribes the use of toxic pesticides.  For more on Beyond Pesticides’ work with grassroots support across the U.S. to “Keeping Organic Strong” through the robust organic certification process, overseen by the National Organic Standards Board (NOSB).  The strength of the Organic Certification label rests on the independent system established by the 1990 Organic Food Production Act and, despite industry pressure to weaken organic certification standards (see most recent Beyond Pesticides March 18, 2024, comments to the NOSB on Compost), consumers and organic producers alike can have confidence in the integrity of organic certification.

Beyond Pesticides offers a variety of articles in the archives detailing the dangers and prevalence of PFAS in pesticides. Check out “Threatened Waters: Turning the Tide on Pesticide Contamination” to learn more about the health and safety of water sources. Click here to sign up for action alerts from Beyond Pesticides to take action on PFAS contamination and other environmental issues, and please take a moment to explore Beyond Pesticides’ Tools for Change webpage to begin your journey in advocacy. 

Another important place to eliminate exposure to the harmful impacts of synthetic pesticide/fertilizer use is in our local public parks, playgrounds, and open spaces managed by municipalities, school districts, and colleges. Beyond Pesticides established the Parks for a Sustainable Future program to assist with the transition to organic land management in communities across the U.S. This holistic approach provides a 2-year pilot program with free technical training and transition to organic management guidance for two sites. See here for more information. 

The organization also strives to maintain the integrity of organic standards through the Keeping Organic Strong campaign and historical work to transition agriculture to organic practices. In 2022, Beyond Pesticides sponsored a Climate Change Calls for Phase Out of Fossil Fuels Linked to Petrochemical Pesticides and Fertilizer series of national virtual seminars (with archived videos) covering health, biodiversity, and climate. For more on climate-friendly organic agriculture, see Daily News and the groundbreaking work of the Rodale Institute, as captured in its Farming Systems Trial — 40-Year Report, which shows the efficacy and benefits of organic agriculture. California Certified Organic Farmers Association’s Roadmap to an Organic California provides a policy framework for advancing agricultural programs that eliminate the use of petrochemical PFAS containing pesticides and fertilizers while combating climate change.  

To raise your voice in support of two Congressional bills to fight PFAS contamination, see Beyond Pesticides’ Action:

Tell Congress to Take Action: The Farm Bill must include the Relief for Farmers Hit with PFAS Act and support the Healthy H2O Act to protect farmers and rural communities from PFAS contamination. Led by Chellie Pingree (D-ME), U.S. Senators Tammy Baldwin (D-WI), and Susan Collins (R-ME), a bipartisan and bicameral bill—the Relief for Farmers Hit with PFAS Act—has been introduced to provide assistance and relief to those affected by PFAS. A second bill, the Healthy H2O Act, introduced by Representatives Pingree and David Rouzer (R-NC) and Senators Baldwin and Collins, provides grants for water testing and treatment technology directly to individuals and non-profits in rural communities. Click here to tell your Congress member to act now.

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

Sources

Biden-Harris Administration Finalizes First-Ever National Drinking Water Standard to Protect 100M People from PFAS Pollution, EPA announcement, April 10, 2024.

Why is the EPA regulating PFAS and what are these ‘forever chemicals’? The Washington Post, April 10, 2024.

Meaningful and Achievable Steps You Can Take to Reduce Your Risk, EPA website

Reducing PFAS in Drinking Water with Treatment Technologies, EPA website

Pesticides Are Spreading Toxic ‘Forever Chemicals,’ Scientists Warn, Scientific American, June 2022.

Revisiting pesticide pollution: The case of fluorinated pesticides, Environmental Pollution, January 2022.

PFAS Interactive Map: PFAS Contamination Crisis, Environmental Working Group (EWG) website 

Fertilizers Compatible with Organic Landscape Management, Beyond Pesticides Fact Sheet

Pesticides in My Drinking Water? Beyond Pesticides Fact Sheet

Per- and Polyfluorinated Substances (PFAS) Factsheet, National Biomonitoring Program, U.S. Centers for Disease Control and Prevention

EPA Announces New Drinking Water Health Advisories for PFAS Chemicals, $1 Billion in Bipartisan Infrastructure Law Funding to Strengthen Health Protections, EPA Announcement, June 15, 2022.

PFAS-FREE PROCUREMENT ACT OF 2023 Report by The Committee on Homeland Security and Governmental Affairs, United States Senate, November 30, 2023.

(Beyond Pesticides, April 16, 2024) 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.

In a 1986 factsheet, Beyond Pesticides wrote, “In mammals, paraquat attacks the epithelial tissues (the skin, nails, the cornea of the eye, and the linings of the respiratory and gastrointestinal tract). There have also been reports of damage to the heart muscle and to nerves. It is easily absorbed through the skin as well as orally [and through inhalation]. Paraquat causes specific damage to the lungs, where residues concentrate in a particular lung cell, the pneumonocyte. This leads to the formation of large amounts of non-functional scar tissue so that poisoning victims suffocate to death. Paraquat is a lung carcinogen in rats.” 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 the U.S. Environmental Protection Agency (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.

In 2018, EPA downplayed the connection between exposure to paraquat and the development of Parkinson’s disease, per registration review documents released by the agency. But, Assemblymember Friedman, in a press release on the day the 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.”

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. EPA’s actions, or inaction as some advocates 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.” Advocates, following this ruling, lambasted the EPA 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.”

At that time, 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 makes 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 vicinity of treatments or in harvest and post-harvest activities. Taken together with the clear inability of the agency to preclude 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.”

On alternatives to paraquat, Beyond Pesticides stated, “The agency 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.”

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.  

In April 2024, Beyond Pesticides’ comments on the Paraquat Interim Registration Review stated, “EPA failed to assess a common mechanism of toxicity for PQ and any other substance in its review for the ID, 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 the Federal Insecticide, Fungicide, and Rodenticide Act and Food Quality Protection Act (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

Beyond Pesticides and advocates around the nation take the position that 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. We have engaged our members with actions to call for EPA to improve its scientific integrity after criticism by the Inspector General and whistleblowers. For more information on the adverse health impacts of paraquat, see its entries in the Gateway on Pesticide Hazards and Safe Pest Management and Pesticide-Induced Disease Database.

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

Source: Mother Jones

(Beyond Pesticides, April 15, 2024) At first, some thought this was an April Fools’ announcement by pranksters like the YES men. Put out an announcement pretending to be the U.S. Environmental Protection (EPA) with a warning to farmworkers that they are being exposed to a highly hazardous weed killer, dacthal (dimethyl tetrachloroterephthalate or DCPA), offering no protection. The announcement says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA” and notes that the agency will be “pursuing” further action at some unspecified time in the future. But, this was no joke, especially for farmworkers. The agency somehow believed it was fulfilling its statutory duty to protect farmworkers and their families with a warning that a chemical they may be exposed in their workplace and possibly their homes and schools is harming them and, for those pregnant, destroying the health of their fetus. “In light of the workplace reality for farmworkers, the lack of labor protections, and the documented deficiencies in the existing worker protection standards, it is difficult to conceive of how EPA officials think this warning is protective in any way. And in light of what agency officials know, or should know, about the reality for farmworkers in their agricultural workplace, why are they not exercising the imminent hazard authority to suspend the chemical that Congress gave them,” said Jay Feldman, executive director of Beyond Pesticides. Mr. Feldman continued, “It’s not even clear in EPA’s press release how this warning will reach farmworkers.”

Beyond label warnings, EPA does not typically issue public warnings, as it has done in this case, with the determination that the agency’s mitigation measures (requirements for personal protective equipment) under a product’s existing registration is not protective of farmworkers, and specifically pregnant farmworkers and their fetuses. In its release and announcement on its website, the agency says “EPA is taking this rare step of warning farmworkers about these concerns while it works on actions to protect workers because of the significant risks the agency has identified.”

Quoting from the agency, “In May 2023, EPA released its assessment on the risks of occupational and residential exposure to products containing DCPA, after the agency reviewed data that it compelled AMVAC [the product’s manufacturer] to submit, which had been overdue for almost 10 years. The assessment found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.” 

The delays associated with this one pesticide exemplifies concerns that advocates have raised as endemic to EPA’s pesticide registration process, resulting in serious harm that is not adequately prevented or managed by the agency. Beyond Pesticides has pointed to this historical and ongoing failure as one of the many reasons to shift to organic management practices that, under the Organic Foods Production Act, do not allow the use of hazardous substances like dacthal.

Tell EPA to immediately suspend the registration of dacthal, while Congress must urge the agency to take immediate action.

Although it suggests several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, acknowledging that DCPA use on turf was voluntarily canceled in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include “non-golf turf uses; sod farms, commercial turf, and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism. 

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. EPA does have imminent hazard authority, which it can use to remove pesticides from use while it works through the legal process. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.  

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, “US pesticide regulation is failing the hardest-hit communities. It’s time to fix it,” finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others (see earlier coverage) on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. In a piece posted earlier this year by Beyond Pesticides, the serious weaknesses in the worker protection standard for farmworkers are documented.   

In view of the serious health risks acknowledged by EPA, the agency must immediately suspend the registration of dacthal, pending any other actions. 

Tell EPA to immediately suspend the registration of dacthal, while Congress must urge the agency to take immediate action.

Letter to EPA:

In a move that defies the most basic principles of worker and public health protection, EPA has warned farmworkers of the risks of dacthal (dimethyl tetrachloroterephthalate or DCPA), instead of taking steps to eliminate the risks. EPA’s press release says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA and will be pursuing action to address the serious, permanent, and irreversible health risks associated with the pesticide as quickly as possible.”

EPA states that it “found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.”

Despite suggesting several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, admitting that DCPA use on turf was voluntarily canceled by in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include “non-golf turf uses; sod farms, commercial turf and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism.

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, US pesticide regulation is failing the hardest-hit communities: It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. The serious weaknesses in the worker protection standard for farmworkers have also been documented.  

In view of the serious health risks acknowledged by EPA, the agency must immediately suspend the registration of dacthal pending any other actions.

Thank you for considering these comments.

Letter to Congress:

In a move that defies the most basic principles of worker and public health protection, EPA has warned farmworkers of the risks of the weed killer dacthal (dimethyl tetrachloroterephthalate or DCPA), instead of taking steps to eliminate the risks. EPA’s press release says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA and will be pursuing action to address the serious, permanent, and irreversible health risks associated with the pesticide as quickly as possible.” In view of the serious health risks acknowledged by EPA, please urge EPA to immediately suspend the registration of dacthal, pending any other actions.

EPA states that it “found concerning evidence of health risks associated with DCPA use and application, even when personal protective equipment and engineering controls are used. The most serious risks extend to the developing babies of pregnant individuals. EPA estimates that some pregnant individuals handling DCPA products could be subjected to exposures from four to 20 times greater than what current DCPA product label use instructions indicate is considered safe. EPA is concerned that pregnant women exposed to DCPA could experience changes to fetal thyroid hormone levels, and these changes are generally linked to low birth weight, impaired brain development, decreased IQ, and impaired motor skills later in life.”

Despite suggesting several measures that it might take—including an immediate suspension order—EPA says it is “considering these tools as it moves forward with the DCPA registration review, but in light of the serious risks posed by DCPA, chose to warn the public of them at this time as it continues its work.” EPA’s press release gives an astonishing history of the agency’s failure to act, admitting that DCPA use on turf was voluntarily canceled by in December 2023, while “unacceptable risks from agricultural use remained.” The uses voluntarily cancelled include “non-golf turf uses; sod farms, commercial turf and golf course roughs.” Continued use allowances, like those retained under the voluntary action, cause disproportionate harm to farmworkers who work around or apply the pesticides in agriculture as well as their families living nearby—making this an act of environmental racism.

EPA’s reliance on voluntary cancellations—which arises because of the cumbersome cancellation process established in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)—has been identified as a major problem in eliminating problem chemicals. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.

Although it has not yet acted, EPA accepted comments on its dacthal pesticide registration review last year, particularly soliciting comments on the environmental justice implications. A report released in January, US pesticide regulation is failing the hardest-hit communities: It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. The serious weaknesses in the worker protection standard for farmworkers have also been documented.  

Thank you for consideration of my request.

(Beyond Pesticides, April 12, 2024) In honor of Earth Month, Natural Grocers® is partnering with Beyond Pesticides for its seventh annual Ladybug Love^SM campaign. Natural Grocers, a longtime leader of the organic movement through national advocacy efforts and rigorous product standards, encourages its communities to pledge to protect beneficial insects and further Beyond Pesticides’ critical mission of converting local parks and playing fields to organic landscape management practices.  

Natural Grocers’ annual Earth Month fundraising efforts benefit the nonprofit organization, Beyond Pesticides and its Parks for a Sustainable Future program. Cleaner air, water, and land make for a healthier food supply – a principle Natural Grocers has championed since 1955. Click here to see the campaign from last year.

April shoppers at Natural Grocers’ 168 stores are also invited to donate to Beyond Pesticides at checkout. Ladybug Love also features in-store promotions!

LADYBUG LOVE & BEYOND PESTICIDES
Natural Grocers’ Ladybug Love campaign aims to bring awareness to the precious insects that play a crucial role in the stability of our food supply and regenerative farming. The annual Earth Month fundraising efforts benefit Beyond Pesticides and its Parks for a Sustainable Future program, designed to assist communities in transitioning away from pesticide use at local parks and public areas by providing the education, training, and practical assistance needed to move toward organic land care.

Beyond Pesticides envisions a future where local parks, playing fields, and greenways are managed without unnecessary toxic pesticides. Where children and pets are safe to run around on the grass, and bees and other pollinators are safeguarded from toxic chemicals.  

Raquel Isely, vice president of marketing for Natural Grocers, states, “Natural Grocers, in partnership with Beyond Pesticides, is pleased to support Parks for a Sustainable Future with our seventh annual Ladybug Love campaign. Through this program and the generosity of our customers, we are underwriting the cost of horticultural services to transition parks and playing fields to organic land management. Cleaner air, water, and land make for a healthier food supply – a principle Natural Grocers has championed for almost 70 years. We are thankful for our generous customers who share our passion to protect our beneficial insects, the land, and our planet.”  

Jay Feldman, executive director of Beyond Pesticides, states, “Natural Grocers is a leader in corporate social and environmental responsibility, and the company’s support of efforts to convert land management to organic shows a strong commitment to public health and environmental protection. The funds raised for Beyond Pesticides’ Parks for a Sustainable Future program enable the organization to work with municipal governments and community people to create safe spaces for children, families, pets, wildlife, and waterways. The parks and playing fields under organic management serve as a model for parks nationwide and prove that toxic chemicals are not needed to have beautiful landscapes.”  

The Company’s underwriting effort has enabled Beyond Pesticides to convert almost a dozen parks and playing fields to organic management practices from Arizona to Utah, with more in the works in Colorado and Texas.

For those wanting to bring this program to their community, contact Beyond Pesticides at [email protected].

Beyond Pesticides’ website explains the process of joining the organic land management program as follows:

• The first step is for the community to apply for the program. Beyond Pesticides asks that the application be submitted by an individual within a local government that has oversight over land care management or with their full knowledge and consent.
• Once a community applies, Beyond Pesticides will review your application and discuss the program with local officials in charge of land care maintenance.
• Beyond Pesticides will work with the community to determine two pilot sites for transitioning to organic land care. The community is encouraged to select high-use/heavy-traffic sites to showcase the program to residents.
• Officials receive a questionnaire on past management practices to help them understand current and past management practices at the pilot sites.
• Soil samples will be taken from the pilot sites in order to analyze soil structure, chemistry, and, most importantly, soil biology.
• Once the soil test results and a completed questionnaire for the pilot sites are ready, a date for the organic land care training will be set.
• As of October 2021, training is being conducted virtually. As conditions allow, Beyond Pesticides will conduct training consisting of classroom lectures and in-field discussions. Staff will walk the pilot sites with land care officials and answer land management questions.
• After the training, the park officials will receive a detailed Organic Transition Management Plan to assist with the organic transition over the pilot sites’ next several seasons. This management plan outlines cultural practices and timing and provides product recommendations.
• Beyond Pesticides remains available to consult with officials regarding the implementation of the management plan throughout the pilot sites’ transition and the program on lands beyond the pilot site.
• Beyond Pesticides offers to conduct a community meeting with the town and community organizations to explain the program and the value that it offers for the protection of health and the environment.

Financial Arrangements: With Natural Grocers support, along with other supporters, Beyond Pesticides will pay up to 100% of the training program to our partner, Osborne Organics, or an equivalent service provider. The community may contribute to this cost; it is not required, but is appreciated to allow for expansion of the program.

Parks for a Sustainable Future supports Beyond Pesticides’ mission to protect public health and the environment, starting at the local level. Given increasing public understanding of the dangers associated with lawn care pesticides, our organization strongly encourages localities to take advantage of the growing availability of alternative practices and products that do not subject people or the local environment to these hazards. Beyond Pesticides’ efforts to eliminate the use of petrochemical pesticides and fertilizers, which contribute to existential public health threats, biodiversity collapse, and the climate crisis. Through the Parks program, communities become the leaders in their state and region to take the practical steps necessary for a sustainable future.

TAKE THE PLEDGE
To help raise funds for this effort, Natural Grocers is urging people to take or renew their pledge online and commit to not using chemicals that harm ladybugs and other beneficial insects at home, in yards, gardens and to support 100% organic produce. Natural Grocers’ goal is to raise $25,000 in April for the Organic Parks Project with Beyond Pesticides through the following in-store fundraising opportunities:  

• Whether it’s a first-time pledge or renewed, Natural Grocers will donate $1.00 (up to $25,000) to Beyond Pesticides for every Ladybug Love pledge signed from April 1 – April 30.
• For every Ladybug Zip Pouch sold from April 20 – 22, Natural Grocers will donate $2 to Beyond Pesticides.
• {N}power® members who make or renew their pledge from April 1 – 15, will receive $5 off their purchase, April 20 – 22.
• {N}power members will also receive a free limited-edition Ladybug Love reusable bag and free sticker with purchase April 20 – 22.

{N}power is Natural Grocers’ FREE member rewards program. The program is easy to join and offers exclusive discounts, digital coupons, rewards benefits, and other members-only features. Customers can sign up for {N}power at www.naturalgrocers.com/join.

Even if you’ve signed the pledge in previous years, please take a moment to sign! You do not need to shop at Natural Grocers to sign, but it’s a great store if there’s one in your area!

>> Don’t forget to advertise your commitment with a Beyond Pesticides “Pesticide Free Zone” sign, featured right. 

COUNT THE LADYBUGS SWEEPSTAKES
Throughout the month, customers are invited to count the ladybugs placed throughout the pages of the April 2024 Natural Grocers good4u® Health Hotline® magazine, for the chance to win a $500 Natural Grocers gift card. To enter the contest, customers fill out the form in the magazine and drop it off at any Natural Grocers store by April 27, 2024. A drawing among all entries with the correct number of ladybugs will determine the winner.

 SPECIAL EARTH DAY EDUCATION & DEALS
Natural Grocers will be promoting regenerative living insights and resources related to food, homes, gardens and yards all month long. Natural Grocers’ 2024 Earth Day Celebration culminates April 20 – 22, with three days of special Earth Day discounts, freebies and sweepstakes. Customers can learn more by picking up the April edition (Vol. 81) of the good4u℠ Health Hotline at their local Natural Grocers store or click here to view it online. For media requests, please contact Katie Macarelli: [email protected].

ABOUT NATURAL GROCERS BY VITAMIN COTTAGE
Founded in 1955, Natural Grocers by Vitamin Cottage, Inc. (NYSE: NGVC) is an expanding specialty retailer of natural and organic groceries, body care products, and dietary supplements. The products sold by Natural Grocers must meet strict quality guidelines and may not contain artificial colors, flavors, preservatives or sweeteners, or partially hydrogenated or hydrogenated oils. The Company sells only USDA-certified organic produce and exclusively pasture-raised, non-confinement dairy products, and free-range eggs. Natural Grocers’ flexible smaller-store format allows it to offer affordable prices in a shopper-friendly, clean, and convenient retail environment. The Company also provides extensive free science-based Nutrition Education programs to help customers make informed health and nutrition choices. Headquartered in the Union Square neighborhood of Lakewood, CO, Natural Grocers has 168 stores in 21 states. Visit www.naturalgrocers.com for more information and store locations.

ABOUT BEYOND PESTICIDES
A 501(c)3 nonprofit organization headquartered in Washington, Dc, Beyond Pesticides works with allies in protecting public health and the environment to lead the transition to a world free of toxic pesticides. Regenerative organic land management practices that use ladybugs and other beneficial insects instead of harmful synthetic pesticides to control pests, embrace the connectedness of planet Earth’s vibrant ecosystem and chart a path towards a livable world.

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

Source:

Natural Grocers® Promotes Seventh Annual Ladybug Love Campaign for Earth Month, Press Release, PRN, Natural Grocers® Promotes Seventh Annual Ladybug Love Campaign for Earth Month

(Beyond Pesticides, April 11, 2024) Scientists are moving forward in testing an agroecological method of “push-pull” pest management (reducing the attractiveness of the target organism and luring pest insects towards a trap) to fight the Asian citrus psyllid (ACP) in Florida orange groves, as it spreads a plant disease known as the pathogenic bacteria huanglongbing (HLB), also known as citrus greening, which is deadly to citrus trees. The disease is spread by the pathogenic bacteria Candidatus Liberibacter asiaticus (CLas).  The chemical-intensive, or conventional, citrus industry is under intense pressure to find alternatives, as synthetic antibiotic use for this purpose has been successfully challenged in court.

ACP is the carrier, or vector, for HLB, spreading it through the citrus groves and killing the trees. The chemical-intensive industry has focused on using antibiotics, which the environmental and public health community has rejected because of serious medical concerns associated with life-threatening bacterial resistance to antibiotics used to protect humans. A federal district court decision in December 2023 found illegal the U.S. Environmental Protection Agency’s (EPA) decision to register the antibiotic streptomycin in Florida citrus without adequate review of its impact on endangered species. The streptomycin lawsuit, filed in 2021 by a coalition of farmworker and public interest groups, including Beyond Pesticides, raises critical issues of antibiotic resistance, public health protection, and impacts on bees.

Organic citrus production has been on the cutting edge when it comes to managing citrus greening. Citrus farmers, growing under the USDA certified organic label, are prohibited from employing antibiotics along with other toxic pesticides. Organic growers like Uncle Matt’s in Florida discuss the importance of soil health that supports plant resilience, breeding programs for tolerant rootstock, the use of botanical insecticides such as neem and clove oil, and the release of the biological control agent Tamarixia wasps, which feed on Asian Citrus Psyllids. Watch Uncle Matt’s Benny McClean, production manager, speak about organic citrus production in Florida at Beyond Pesticide’s 33rd National Pesticide Forum.

Similarly, Mongabay (an international environmental science nonprofit news platform) reports that those practicing agroecology, while not certified organic, are utilizing “push-pull” methods, using an organic plant-pheromone, methyl salicylate (oil of wintergreen), to lure pests away from citrus crops and toward “trap crops” instead. The method was first developed in East Africa, and represents a more holistic and environmentally friendly approach to pest management, transitioning away from dependence on pesticides.

The “push-pull” pest management strategy focuses on manipulating the behavior of the psyllids to protect citrus crops by making the citrus trees less attractive while simultaneously luring ACP toward alternative, non-citrus “trap crops.” While the final results are pending, the anticipated outcome is a significant reduction in ACP populations on the treated citrus trees, thereby lowering the incidence of HLB transmission.

Methodology

An Argentinian research team, led by María Victoria Coll-Aráoz, PhD, formerly on the science faculty of the Universidad Nacional de Tucumán, studied a series of experimental plots designed to test the efficacy of the “push-pull” method in a real-world setting. Her research was funded under the Fulbright Scholars Program with the project title “Utilizing Plant Signaling Compounds to Manage Asian Citrus Psyllid (Diaphorina Citri), Vector of Huanglongbing Disease of Citrus.”

The three distinct test groups include:

• Control: Trees receive no treatment to serve as a baseline for comparison.
• Treated citrus only: Trees are sprayed with an organic plant hormone solution that inhibits the production of methyl salicylate, a chemical that naturally attracts psyllids.
• Treated citrus with trap crops: In addition to the treated citrus trees, this setup includes curry leaf plants (Murraya koenigii) surrounding the citrus trees. These trap crops are sprayed with methyl salicylate (a plant hormone compatible with organic systems) to make them more attractive to the psyllids than the citrus trees.

The methodological approach features two key actions simultaneously: pushing ACP away from the citrus (the “push”) and pulling them toward another target (the “pull”).

• Push: The citrus trees are sprayed with an organic plant hormone that suppresses their natural emission of methyl salicylate, a compound that attracts psyllids and other pests. Normally, when a tree becomes infected with citrus greening, the bacteria causes the tree to produce even more methyl salicylate — a positive feedback loop “designed by the bacteria for its own propagation,” as Dr. Coll-Aráoz explains. Reducing this methyl salicylate attractant makes the citrus trees less appealing to the psyllids and breaks this feedback loop.
• Pull: Simultaneously, the surrounding trap crops (curry leaf plants) are made more attractive by enhancing their emission of methyl salicylate, either through direct spraying of the substance or using dispensers that release the chemical, acting like perfume bottles to lure the insects.

Approaching HLB—No cure, but manageable under organic

HLB is one of the most researched plant diseases in the current times. Hundreds of millions of dollars have been spent on research and, as The Organic Growers Guide noted in 2019, “It is universally agreed by growers and scientists that no ‘silver bullet’ has yet been discovered” for HLB, therefore the presence of ACP poses a severe risk to citrus crops with the potential to cause catastrophic losses. [Infected trees must be completely removed to combat this disease, as symptoms may not appear for one to two years, and a tree may succumb to HLB within five years.] Measuring between 1/6 and 1/8 inches in length, this small insect serves as the carrier for the deadly bacterium. When ACP feeds on a plant, it transmits the bacterium, which is harmless to the psyllid but causes HLB, also known as citrus greening or yellow dragon disease, in citrus and certain ornamental plants. With a one to two-month lifespan, ACP can infect an enormous number of trees by spreading the bacterium.

Most management of the HLB vector centers primarily on the intensive use of synthetic insecticides, which are prohibited from use under organic management. ACP management in conventional citrus is based largely on the intensive use of synthetic insecticides such as imidacloprid, chlorpyrifos, and dimethoate, as well as new insecticides such as cyantraniliprole. Studies have investigated the development and use of synthetic pesticides, agricultural antibiotics, and genetically engineered citrus varieties. Advocates have noted with alarm the danger of continuing to rely on highly toxic synthetic pesticides like chlorpyrifos (banned in 39 countries) and aldicarb ( banned in 100+ countries). Even Florida’s Department of Agriculture and Consumer Services rejected state-level approval of aldicarb: “While there are promising new horizons for fighting citrus greening, like recent breakthroughs at UF/IFAS on genetic resistance, aldicarb poses an unacceptable risk to human, animal, and environmental health in Florida, is one of the world’s most toxic pesticides, and is banned in more than 100 countries,” said Florida Agriculture Commissioner Nikki Fried in 2021. “The registrant’s application does not meet the requirements of state law, and we must therefore deny the registration of aldicarb for use in the State of Florida.” In addition, concerns over using medical treatments as pesticides are not conjecture but borne out of experiences already concerning on the ground. In January 2021, EPA authorized the antibiotic streptomycin to combat citrus greening disease despite the potential for significant environmental and health risks. Critics point out that while citrus greening and cancer are serious threats, the solution should not involve repurposing critical medical treatments for widespread agricultural application, a practice that benefits corporate interests more than farmers and poses long-term public health risks.

The devastating impact of citrus greening disease has left the citrus industry in disarray, with declining production and economic losses. However, examination of available literature, unpublished research data, and grower observations have produced evidence that citrus greening may be managed and marketable fruit produced by adopting organic agricultural (and agroecological) methods, including push-pull pest control, strict disease prevention, diligent scouting, ACP control, nutritional support of healthy and infected trees, implementation of biological controls and the planting of cultivars considered “tolerant” or “resistant” to HLB. “Pesticides haven’t worked to control this vector, and we’re entering a time when these alternatives are unsustainable,” said Lukasz Stelinski, PhD, a leading entomologist at the University of Florida’s Citrus Research And Education Center. “They’re too expensive. They’re having negative impacts in terms of insecticide resistance development, and they’re not working.” Despite this plethora of research, there is still a dramatic underfunding of research on methods compliant with and supporting organic cultivation.

Conventional approaches relying on synthetic pesticides have proven ineffective, harmful to human health, and detrimental to the environment. Advocates say that the time has come for a transformative change in citrus farming practices, as organic citrus represents 1.5 percent of citrus acreage in the United States and three percent of the dollar value—in other words, providing a significantly greater economic return per acre planted. Organic citrus production, supported by agroecology principles like push-pull pest management, offers a superior approach to combat citrus greening disease and revive the struggling industry. By reducing reliance on synthetic pesticides, promoting ecosystem health, and meeting the demand for organic products, organic citrus production can pave the way for a brighter future for the citrus industry.

In 2022, after yet another closure of international juice company Tropicana’s Fort Pierce processing facility from a lack of fruit supply, plant breeder Fred Gmitter, PhD, at the University of Florida’s land grant Citrus Research and Education Center, commented, “It’s difficult to imagine being much worse off in our industry right now. I ask this question all the time: Is this the bottom? Is this as bad as it’s going to get?”  In light of Dr. Gmitter’s comments and devastating crop losses (from 200 million boxes of oranges produced in Florida in the 2000s to just 20 million boxes in Florida’s 2023-2024 forecast), advocates urge that the current situation be viewed as a tipping point for the end of chemical-intensive, pesticide first industrial production of oranges. Florida-based national leader in organic orange juice production, Uncle Matt’s Organic, now a Certified B company, has seen growth and success and leads the way with supporting research, and practical application of organic compatible methods. For more information, please see Uncle Matt’s Benny McClean, production manager, speak about organic citrus production in Florida at Beyond Pesticide’s 33rd National Pesticide Forum.

Beyond Pesticides argues that the urgency of the existential crises that conventional Florida citrus management exemplifies can only be met with an immediate end to the use of highly toxic synthetic pesticides (including insecticides) like aldicarb, human antibiotics like streptomycin, and more. The time is now to follow what consumers already know, and a growing organic market shows that organic agriculture can overcome challenges of pest and plague to deliver nutritious food, without pesticide residue, or pesticide exposure and harm to farmers and fields, neighbors, children, wildlife, and the environment.

Our food choices directly affect the health of our environment and those who grow and harvest what we eat. That’s why food labeled “organic” is the right choice. In addition to serious health questions linked to actual residues of toxic pesticides on the food we eat, our food-buying decisions support or reject hazardous agricultural practices, protect farmworkers and farm families, and provide stewardship for the earth. See Beyond Pesticides for more on Eating with a Conscience. Beyond Pesticides’ article, “The Real Story on the Affordability of Organic Food,” lays out the hidden costs and risks of conventional, chemical-intensive agriculture, and offers helpful ideas on eating organic on a budget. To learn more about opportunities to strengthen the National Organic Program, please see the “Keeping Organic Strong” webpage.

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

Sources

Florida growers eye agroecology solution to devastating citrus disease, Marlowe Starling, Mongabay News, April 3, 2024

Combatting Huanglongbing in Organic Systems, International Journal of Horticulture, Agriculture and Food Science (IJHAF), Cochrane, Ellen, Shade, Jessica,  Jan-Feb 2019

Combatting Citrus Greening in Organic Systems A GROWER’S GUIDE, The Organic Center, January 2019

Citrus Greening: A positive outlook despite Mother Nature’s setbacks, Uncle Matt’s Organic, November 2022

Genetic Improvements Offer Best Long-term Solutions to Citrus Greening Disease, Uncle Matt’s Organic January 19, 2021

Progress Toward an Attract-and-Kill Device for Asian Citrus Psyllid Using Volatile Signatures of Citrus Infected With Huanglongbing as the Attractant, Journal of Insect Science, November 2020

(Beyond Pesticides, April 10, 2024) Researchers in a 2024 Chemosphere study find synergistic relationships in certain chemical mixtures, particularly heptachlor and triallate and trifluralin and lindane at lower concentrations, respectively. “Investigators should consider additional binary data for acute toxicity and potential chronic health impacts on these mixture…which showed synergism at low levels,” the researchers conclude. “According to a Centers for Disease Control (CDC) assessment, more than 50 pesticides are detected in blood or urine samples from the US population,” Researchers point to a cause for concern. The findings come as no surprise to advocates who have urged an assessment of the potential synergistic impacts of pesticide mixtures in the regulation of pesticides.

Researchers “used the exposure data from a complex operating site with legacy pesticide pollution to evaluate if

1. Inhalation of pesticide mixtures released from such contaminated sites could pose a risk to human health,
2. The component-based risk assessment approaches that rely on additivity can predict the actual risk of pesticides in a mixture, and
3. The legacy organochlorine pesticides banned many years ago interact with registered and supposedly safe herbicides in a mixture.”

The study site is “a pesticide packaging and handling facility” contaminated with the following pesticides (“historical and in current use”): 2,4-D (2,4-dichlorophenoxyacetic acid), 2,4-DB (4-(2,4-dichlorophenoxy)butyric acid), 2,4-DP (Dichlorprop), Aldrin, Bromacil, Bromoxynil, Chlordane, Clopyralid, DDD p,p, DDE p,p, DDT, o, p’, DDT, p,p’, Dicamba, Dieldrin, Dimethoate, Endrin, Heptachlor, Lindane, Malathion, MCPA, MCPP (mecoprop), Metribuzin, Treflan (Trifluralin), and Trilate/Triallate. “Only volatile COPCs (Henry’s Law Constant (H) greater than 10⁻⁵ atm m³/mol) in soil and groundwater were included in this study (triallate, trifluralin, lindane, heptachlor, dieldrin, and aldrin,” the researchers indicate in the Methods section. Quantitative risk assessment for pesticide exposure was rooted on oral exposure, which comes with potential uncertainties. For example, oral exposure tends to demand a higher dose to induce an identifiable adverse effect relative to inhalation exposure. In other words, using an oral reference dose may underestimate the potential risk.

Risk assessment of pesticide mixtures follows different logic systems depending on the research approach. As this study describes, “The default assumption is that at low concentrations, pesticides interact additively with one another; thus, the risk posed by each component of a complex mixture could be simply added up.” The binary weight of evidence, or BINWOE, builds on EPA’s approach at risk assessment through the interaction-based hazard index (HI _Interaction). There was not enough published data on animal binary pesticide interaction which meant finding an alternative approach. Researchers used a cell line, SH-SY5Y, after a previous meta study found it to be an effective method to obtain relevant binary data that fits EPA’s HI _Interaction approach while acting as a “predictive indicator” of adverse human health impacts to pesticide exposure.

Researchers did find values suggesting “significant health concerns” to toddlers, infants, teenagers, and adults in “commercial and industrial land use.” Additionally, there are several important takeaways from the study, including pivotal details on the synergistic impacts of chemical mixtures at different concentrations. “Nine of the 15 tested binary mixtures of pesticides synergistically reduced cell viability []. Seven mixtures (Trifluralin/Heptachlor, Trifluralin/Aldrin, Lindane/Heptachlor, Lindane/Aldrin, Heptachlor/Dieldrin, Heptachlor/Aldrin and Dieldrin/Aldrin) were synergistic at higher concentrations. However, two mixtures of herbicides and OCPs (Trifluralin/Lindane and Triallate/Heptachlor) interacted synergistically at lower concentrations. All binary mixtures of OCPs [organochlorine pesticides], except for Lindane/Dieldrin (additive at all concentrations), elicited synergistic effects at higher concentrations and additivity at lower concentrations.” Lindane, considered a legacy organochlorine, does in fact interact with “supposedly safe herbicides in a mixture.” The findings of this study, and similar findings in the scientific literature going back decades, demonstrate the importance of measuring the potential impacts of chemical mixtures in promulgating pesticide safety regulations.

The health consequences of chemical mixtures gained national attention in a recent dispute between the Office of the Inspector General (OIG) and the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs regarding the agency’s review of pet flea and tick collars. The OIG report indicated, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.”

Pollinators are also impacted by the mixture of toxic chemicals in the environment that are not evaluated by EPA for synergistic effects. A 2023 Nature study found a combination of insecticides and fungicides (including indoxacarb, spinosad, chlorpyrifos-ethyl, deltamethrin, dimethoate, imidacloprid, cyfluthrin, dithianon, etofenprox, and chlorpyrifos-methyl in 106 agricultural landscapes across Europe through identifiable adverse health impacts of bumble bees, signaling EPA and European environmental regulators’ failure to “safeguard bees and other pollinators that support agricultural production and wild plant pollination.” A 2014 study reached a similar conclusion regarding the synergistic effects in most pesticide combinations exacerbated pollinator mortality rates around the four-day mark of exposure. More concerning, however, were the results focusing on the allegedly “inert” ingredient, N-methyl-2-pyrrolidone. In this study, published in PLoS One, researchers indicate, “Even for the lowest concentration of [this inert ingredient], the estimated time to cause 50% larval mortality was 4 days.”

Given both the known and still unevaluated effects of pesticides, including the impact of mixtures and synergistic effects, and given the commercial viability and effectiveness of alternatives in both agricultural and nonagricultural use, Beyond Pesticides is calling for the phase out of toxic petrochemical pesticides by 2032. See the Gateway on Pesticide Hazards and Safe Pest Management to learn specific adverse health impacts of particular pesticide ingredients. See Pesticide-Induced Disease Database to peruse the latest scientific literature on pesticide exposure and health consequences. Safety Source on Pest Management Providers offers a list of pesticide application companies that avoid the use of toxic pesticides. To identify if you suspect that you or a loved one was or is being exposed to a harmful pesticide or chemical, see Pesticide Emergencies.

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

Source: Chemosphere

(Beyond Pesticides, April 9, 2024) The United States Court of Appeals for the Fifth Circuit, in an opinion authored by Circuit Judge Cory T. Wilson, has vacated an action by the U.S. Environmental Protection  Agency (EPA) that had ordered the Texas-based manufacturer Inhance Technologies, L.L.C. to stop producing plastic containers that leach toxic per- and polyfluoroalkyl substances (PFAS) into pesticides, household cleaners, condiments, and additional products. EPA has taken action after the agency determined that the PFAS created during the fluorination process “are highly toxic and present unreasonable risks that cannot be prevented other than through prohibition of manufacture.”

While the court is not challenging EPA’s authority to determine the hazards associated with PFAS exposure to be unacceptable, on a technicality, it is finding that the agency used the wrong section of the Toxic Substances Control Act (TSCA), Section 5, which the court says is focused on new uses. According to the Court, “The EPA is just not allowed to skirt the framework set by Congress by arbitrarily deeming Inhance’s decades-old fluorination process a “significant new use,” even though EPA’s awareness of the PFAS contamination was “new” to the agency and not disclosed by the manufacturer. Even if EPA were to pursue another approach (Section 6) under TSCA, the court notes that the agency must “weigh the costs to businesses and the overall economy before shutting down an ongoing manufacturing process.” And so goes the limitations of federal law in protecting public health as a primary and superseding goal.

This case serves as one example, among the many under federal law, in which efforts to limit the use of petrochemical pesticides are impeded by weak policy without clear mandates. The court decision elevates the challenges posed by federal laws that do not clearly meet the enormity of the current and escalating public health, environmental, and climate crises—in this case, exemplified by long-chain PFAS contamination from one manufacturer. 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 National Organic Standards Board (NOSB) to develop a strategy for eliminating plastics and PFAS from organic as a priority issue including at the upcoming meeting this spring.

Background
The discovery of PFAS—a group of nearly 10,000 highly persistent and human-made toxic chemicals—in widely-used pest management products, such as the mosquito insecticide Anvil 10+10, raises alarm about the extent of PFAS contamination and its potential impact on public health, including contamination of drinking water and waterways. In 2020, testing spearheaded by Public Employees for Environmental Responsibility (PEER) discovered high levels of PFAS in Anvil, subsequently confirmed by EPA in 2021, and in fluorinated products. These findings prompted EPA to investigate the source of the contamination—as the plastic containers leached PFAS. 

In response, PEER and the Center for Environmental Health (CEH) notified EPA and Inhance Technologies in October 2022 of their intent to file a lawsuit to stop the manufacture and use the PFAS-contaminated product. EPA eventually filed a lawsuit against Inhance in December 2022, as did PEER and CEH, seeking to enjoin the company from continuing to produce multiple per- and polyfluoroalkyl substances in violation of TSCA. The two cases were later combined in the District Court for the Eastern District of Pennsylvania. In April 2023, a federal district court judge dismissed the PEER and CEH suit without prejudice at the request of both Inhance and EPA on the grounds the government was “diligently prosecuting” its case.  In response to the 5th Circuit Court’s appellate decision to vacate EPA’s stop manufacturing order, PEER and CEH are moving to intervene in the DOJ suit against Inhance. In February 2024, PEER and CEH announced a newly filed lawsuit against EPA for wrongfully withholding vital information, including test data on the presence of PFAS.

The EPA’s Determination and the Fifth Circuit Decision
The two orders by EPA prohibiting Inhance from manufacturing or processing PFAS during its fluorination process were issued under Section 5 of the TSCA, which empowers EPA to oversee and examine chemicals produced or brought into the United States. (See here for EPA’s PFAS framework and TSCA section 5). However, the company argued, and the court agreed, that the agency had incorrectly applied a TSCA section related to the new uses of chemicals, asserting that its process did not represent a new use. [Inhance has been fluorinating plastic containers using the same process since 1983, a process that manufactures PFAS and produces 200+ million containers annually.] While acknowledging the unreasonable risk to human health and the environment, the court concurred with Inhance’s interpretation and vacated the orders.

The Fifth Circuit decision alarms advocates with its significant implications for public health and the environment, as the public is left exposed to toxic PFAS without adequate protection. In addition, the court’s finding raises questions about the EPA’s authority to issue significant new use rules (SNURs) under TSCA. SNURs are crucial tools for managing chemical risks, and limiting EPA’s authority in this regard weakens the agency’s ability to protect public health and the environment (see PEER and CEH response here and here). Although EPA does not regulate PFAS in pesticide formulas, the agency lists these substances in the inert ingredient database, and thus product labels do not require disclosure of contaminants fundamental to pesticide products as a result of the manufacturing or packaging process. This is yet another reason to end the use of synthetic pesticides and recognize the benefits of organic agriculture.

The Impact on Public Health  and the Only Viable Solution—Organic

As PEER noted, PFOA and twelve other PFAS chemicals are formed during the fluorination of high-density polyethylene (HDPE) plastic containers by Inhance Technologies, LLC of Houston, Texas. Inhance is the sole U.S. company conducting this type of fluorination. Studies by EPA, independent researchers, and Inhance itself show that PFAS leaches from the walls of containers into their contents, thus exposing millions of people to PFAS without their knowledge. In February 2024, EPA announced new methodology for detecting dangerous low levels of PFAS in plastic containers. The leaching of PFAS from plastic containers into various products, including pesticides, food, cosmetics, and cleaning supplies, poses a significant risk to millions of Americans though exposure via ingestion, inhalation, and dermal contact.  

PFAS have been linked to various health issues, including cancer, reproductive problems, and immune system dysfunction. Concerns of safety in the use of fluorinated plastic containers used for packaging are because exposure to PFAS comes not just from leaching into the contents of the plastic containers, but also from handling the exterior of the containers. Factory workers and farmworkers have higher cumulative exposures, while critical windows of vulnerability, from pregnancy through childhood and the elderly, experience disproportionate risks of exposure. (See here, and here). The chemicals have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma, among a range of other adverse health effects. As new drinking water health advisories issued by EPA show, PFAS levels as low as .02 parts per trillion (ppt) have the potential to cause adverse health effects for public health.

Certified organic agriculture can play a crucial role in addressing the widespread contamination of PFAS as the only viable solution in the long run. Organic agriculture prohibits the use of petrochemical pesticides and fertilizers under a robust regulatory system created by the Organic Food Production Act (OFPA) and overseen by the NOSB, which reports directly to the U.S. Secretary of Agriculture. As the only agricultural system with public input and standards as defined by federal law, organic promotes sustainable farming practices that prioritize soil health and biodiversity. As the governing body responsible for setting organic standards, the NOSB must take a leadership role in developing a comprehensive strategy for eliminating plastics and PFAS from organic production and packaging, ensuring that organic agriculture remains a safe and sustainable alternative to conventional farming.

Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. Given the wide availability of non-pesticidal alternative strategies, families and industry workers can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. For more information on why organic is the healthy choice, see Beyond Pesticides’ webpage, Health Benefits of Organic Agriculture. Additionally, learn more about how the lack of adequate pesticide regulations can adversely affect human and environmental health by visiting Beyond Pesticides’ website, Keeping Organic Agriculture Strong, and a special edition of Pesticides and You, “Keeping Organic Strong.” 

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

Sources 

Inhance Technologies vs US EPA, US 5th Circuit Court Decision, March 21, 2024

US court blocks EPA order to eliminate PFAS in plastic containers, The New Lede, March 25, 2024

EPA Orders Issued to Inhance Technologies Related to Long-Chain PFAS Significant New Use Notices, EPA website, December 14, 2023

(Beyond Pesticides, April 8, 2024) When Mexico in 2020 decided to protect its traditional varieties of corn for reasons of health, safety, environmental protection, and food sovereignty with the banning of the importation of genetically engineered (GE or GM-genetically modified) corn by 2024, the powerful biotech industry and the U.S. government began a concerted campaign to stop the country’s efforts. With the opposition spearheaded by BIO, “the world’s largest trade association representing biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations” (as described in its March 15 press release), including companies like Bayer/Monsanto, the U.S government is calling Mexico’s action a trade barrier. The U.S. is invoking the U.S.-Mexico-Canada Agreement (USMCA), the trade agreement that replaced the North America Free Trade Agreement (NAFTA) in 2020.

This is just one of the latest examples of corporate power reigning over U.S. environmental and economic policies. Mexico has already announced a delay in the planned April 1 ban on the importation, production, distribution, and use of glyphosate. Interestingly, this is all happening despite reports that the Biden administration is seeking to “tackle corporate abuses,” which is apparently limited  to tax reform and encouraging competition,

>> Tell the U.S. Trade Representative and the U.S. Secretary of State to withdraw opposition to Mexico’s ban on imported GE corn. 

Mexico’s decision to stop importation of GE corn into its country is examined in report by CBAN, which highlights the scientific rationale underpinning Mexico’s decision to “safeguard the integrity of native corn from GM contamination and to protect human health.” Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under USMCA. In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban. So far, there has been no public update from the Office of the U.S. Trade Representative, however, the biotech industry said in its March 15 release, “BIO thanks U.S. Trade Representative Katherine Tai and USTR Chief Agriculture Negotiator Doug McKalip for pursuing this action in support of U.S. farmers and agricultural innovation.”

Within Mexico, there is over a decade of judicial and executive actions against the spread of GE crops, as well as the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed, effective immediately, within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, citing the need for more research and prohibited agrichemical biotech companies, including Monsanto, DuPont Pioneer, Syngenta, PHI Mexico, and Dow AgroSciences, from planting or selling GE corn seed in Mexico. Then in 2020, Mexico announced the phase out of glyphosate from use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry intervenes whenever decisions are published finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or advance restrictions on genetically engineered or modified crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, the CBAN report states, “Most GM corn plants are genetically modified to kill insect pests. The GM plants express a toxin from the soil bacterium Bacillus thuringiensis (Bt) that is known to harm the guts of specific types of insects but not others. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops are different from this natural Bt in structure, function, and biological effects.” The report continues, “In fact, peer-reviewed studies across the scientific literature continue to find that Bt toxins in GM plants can harm insects (spiders, wasps, ladybugs, and lacewings, for example) that are not the intended targets.”

For background, see Ready or Not, Genetically Engineered Crops Explode on Market.

>> Tell the U.S. Trade Representative and the U.S. Secretary of State to withdraw opposition to Mexico’s ban on imported GE corn. 

 Letter to U.S. Trade Representative Katherine Tai

I am writing to ask you to withdraw U.S. opposition to Mexico’s ban on imported GE corn. Despite reports that the Biden administration seeks to “tackle corporate abuses,” the actions of the U.S. government appear to be limited to tax reform and encouraging competition, while corporate interests continue to override existential health and environmental concerns. A case in point is the attempt to stop Mexico’s ban on imported genetically engineered (GE or GM) corn.

In 2023, Mexico decided to stop importation of GE corn into its country. Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA). In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban.

Over the last decade, Mexico has taken judicial and executive actions against the spread of GE crops and the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, and prohibited agrichemical biotech companies from planting or selling GE corn seed in Mexico, citing the need for more research. In 2020, Mexico announced a phase-out of glyphosate’s use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry challenges decisions finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or restrict GE crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, most GE corn plants are genetically modified to kill insect pests, expressing a toxin from the soil bacterium Bacillus thuringiensis (Bt) that known to harm the guts of specific types of insects. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops differ from this natural Bt in structure, function, and biological effects. In fact, peer-reviewed studies continue to find that Bt toxins in GM plants can harm nontarget arthropods including spiders, wasps, ladybugs, and lacewings.

Please immediately cease U.S. opposition to Mexico’s ban on imported GE corn.

Thank you.

Letter to the Secretary of State and the White House:

I am writing to ask you to withdraw U.S. opposition to Mexico’s ban on imported GE corn. Despite reports that you seek to “tackle corporate abuses,” your actions appear to be limited to tax reform and encouraging competition, while corporate interests continue to override existential health and environmental concerns. A case in point is the attempt to stop Mexico’s ban on imported genetically engineered (GE or GM) corn.

In 2023, Mexico decided to stop importation of GE corn into its country. Mexico’s decision is meant to “protect the rights to health and a healthy environment, native corn, the milpa, biocultural wealth, peasant communities and gastronomic heritage, as well as to ensure a nutritious, sufficient and quality diet.” The phase-out of GE corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA). In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban.

Over the last decade, Mexico has taken judicial and executive actions against the spread of GE crops and the use of toxic petrochemical pesticides. In 2013, a judge in Mexico issued an injunction against the planting and selling of GE corn seed within the country’s borders. The decision came nearly two years after the Mexican government temporarily rejected the expansion of GE corn testing, and prohibited agrichemical biotech companies from planting or selling GE corn seed in Mexico, citing the need for more research. In 2020, Mexico announced a phase-out of glyphosate’s use or importation into the country by 2024, joining other nations that have issued bans, including Germany, Luxembourg, and Vietnam.

With such a history, why challenge this action, which affects only a small proportion of corn—white corn used for human consumption, as opposed to yellow feed corn or seed corn? Under the USMCA, “[E]ach Party has the right to adopt measures necessary to protect human, animal or plant life or health, called Sanitary and Phytosanitary (SPS) measures, and is clear that such measures should be “based on scientific principles.” The GE/chemical industry challenges decisions finding that GE crops or the chemical on which they depend are harmful, often leading to U.S. government and corporate agribusiness pressure on other governments when they move to ban glyphosate use or restrict GE crops. When U.S. government agencies, such as USDA, EPA, and FDA, have bought the line of corporations—many linked to those agencies through the revolving door—the fingerprints of those corporations are all over policies including labeling, agriculture policy, pesticide registration, food tolerances, and foreign policy.

In fact, in deciding to ban GE corn, Mexico has established a scientific basis for its decision. The government hosts a database of scientific studies that document the health impacts to insects, pollinators, and animals fed GE corn, as well as the adverse health impacts of glyphosate on humans. In addition to herbicide-tolerant GE crops, most GE corn plants are genetically modified to kill insect pests, expressing a toxin from the soil bacterium Bacillus thuringiensis (Bt) that known to harm the guts of specific types of insects. Farmers have long used Bt as a spray to kill pests but the Bt toxins in GM crops differ from this natural Bt in structure, function, and biological effects. In fact, peer-reviewed studies continue to find that Bt toxins in GM plants can harm nontarget arthropods including spiders, wasps, ladybugs, and lacewings.

Please immediately cease U.S. opposition to Mexico’s ban on imported GE corn.

Thank you.

(Beyond Pesticides, April 5, 2024) Exposure to chemical toxicants, molds, and algae contributes to autism and attention disorders in children, according to research that bolsters earlier findings. The exposures may be most relevant, not in the children, but one generation back—in the parents. The study, “Assessing Chemical Intolerance in Parents Predicts the Risk of Autism and ADHD in Their Children,” was published in the March issue of the Journal of Xenobiotics.

Led by Claudia S. Miller, MD, an immunologist at the University of Texas at San Antonio noted for her work on chemical intolerance (CI), the authors build on previous work published in 2015 establishing parental CI as a risk factor for autism and ADHD. Dr. Miller participated in Beyond Pesticides’ 2022 Forum Series. Recordings of her presentation are available on YouTube here and here.

In 1996, Dr. Miller concluded that CI is induced by Toxicant-Induced Loss of Tolerance (TILT). For further details, see Beyond Pesticides’ Daily News Blog. Three years later Dr. Miller developed the Quick Environmental Exposure and Sensitivity Inventory (QEESI), a questionnaire for individuals tracing their toxicant exposures and symptom histories. QEESI was first developed with groups exposed to organophosphate pesticides, volatile organic compounds in reconstruction and remodeling, various military chemicals used in the Gulf War, and breast implants. QEESI has been used in 16 countries, and the Miller team believes it offers “high sensitivity and specificity for differentiating individuals with CI from the general population.”

The concept behind TILT is that either a short-duration acute exposure to a chemical or biological agent or a low-dose chronic exposure can sensitize the immune system so that further exposures at much lower doses, or even exposures to previously tolerated substances, set off a cascade of immune responses leading to CI. CI often involves symptoms in multiple body systems and may be triggered not only by environmental chemicals, but also by foods and drugs. The prevalence of CI, if clinically diagnosed, is estimated at 0.5-6.5%; if self-diagnosed, the average is 20%.

Autism globally is estimated to occur in about one percent of children. It increased by 6-15 percent a year between 2002 and 2020. Less than a fifth of autism cases can be attributed to a specific cause. The rest, the authors write, are termed “idiopathic autism,” for which interactions between genes and the environment are thought to be the best explanation.

Attention Deficit Hyperactivity Disorder (ADHD) affects about 6% of youth and 2.5% of adults, according to the authors, and there is “substantial overlap” between autism and ADHD, estimated at 28-78%. The research team published work in 2015 showing that mothers with CI have three times the likelihood of reporting a child with autism and 2.3 times the odds of reporting a child with ADHD. The current study reinforces the association between CI and children’s behavioral problems, finding that the top 10 percent of parents with CI had 5.7 times the risk of having a child with autism and/or ADHD as the bottom 10%.

They also suggest that toxicant exposures, such as heavy metals, organophosphate pesticides, and tobacco smoke, probably stimulate epigenetic changes in gene expression.

Epigenetics refers to the process by which various molecules grant or deny access to genes by other cellular components, which in turn determines whether the genes are active. Epigenetic configurations have been shown to be heritable, although there is controversy regarding whether this applies to direct offspring that were gestating at the time of the mother’s exposure. The children in the current study would have been influenced both by their mother’s exposures and directly by any environmental substance that could penetrate the placental barrier.

The Miller team drew a random sample representing all 50 states from nearly three million people who completed an 80-question QEESI questionnaire through a SurveyMonkey online portal.

Nearly 23 percent of the respondents report high levels of CI. Of those, 13 percent report having a child with an autism spectrum disorder, and nearly 29 percent have a child with an attention disorder.  

The initiating exposures reported by respondents fall into two categories: fossil fuel-derived toxicants and biogenic toxicants such as particles and volatile organic compounds from mold or algae. The scientists note that regulatory standards for “safe exposure levels” to these substances are derived from animal tests. They rely on establishing “No Observed Adverse Effect Levels” (NOAELs). For people with CI, the level of exposure sufficient to trigger symptoms is usually far below established NOAELs. Nor do those levels capture the effects of mixtures or address carcinogenicity or mutagenicity, the authors note.

When CI, TILT, and QEESI were first developed, the theory did not include a specific mechanism for how the immune cascade develops. In 2021 Miller and colleagues proposed that toxic exposures trigger mast cells—part of the immune system—to change their behaviors and overreact to chemical signals.

Mast cells were discovered more than a century ago, but their role in CI has only recently been explored by Dr. Miller and colleagues. Mast cells are highly conserved in animal physiology, having appeared some 500 million years ago in early bony fish. Generally, they are deployed near an organism’s interface with the outside world (skin, digestive, and respiratory tracts), ready to defend against allergens, toxins, and pathogens. They are usually the first immune system responders to external invasion and release several kinds of inflammatory markers, including cytokines and histamine. They contribute to wound healing, tissue regeneration, and blood vessel formation. They also communicate with the nervous system, suggesting an involvement with responses to stress. Their roles in diseases associated with highly industrialized societies are the focus of intense scientific interest. Beyond Pesticides covered Dr.Miller’s examination of petrochemicals’ influence on mast cells in 2023.

One limitation of the current study is that QEESI is a subjective measure based on self-reporting from a self-selected population, and thus provides only anecdotal information. Further, there is no standard clinical protocol or a suite of laboratory tests for diagnosing CI. Nor is there a widely accepted method for diagnosing mast cell activation syndrome, a condition thought to underlie many disorders ranging from allergies to irritable bowel syndrome and possibly including CI.

Yet there is no doubt that environmental exposures contribute to many diseases and evidence of their influence on gene expression is mounting. What can be done? Mitigating environmental exposures by avoiding pesticides and industrial chemicals in fabrics, furniture, kitchen and bathroom cleaners, personal care products, traffic fumes, smoke, and the like, may help. But for chemical sensitivity, once the problem is established, it is very difficult to alleviate.

In order to really address the problem, it must be confronted at scale. That means reducing the presence in the ambient environment of the culprit chemicals, such as everything derived from fossil fuels—pesticides, plastics, internal combustion pollution, and the myriad compounds used in commerce, such as flame retardants and surfactants. Even biological triggers like mold and algae are often connected to human activities, especially those exacerbating climate change. Earth’s biosphere is being overwhelmed with these substances’ disruptions, impelling organisms to overamp their defense mechanisms, with the results we see about us—inflammation in every physiological system, leading to many health consequences ranging from heart disease, arthritis, depression, Alzheimer’s disease, cancer—and hair-trigger chemical sensitivities, autism and ADHD. Expecting the patients with CI/TILT, autism, and ADHD to cope individually by restricting their lifestyles to the point of absurdity, such as never being able to open a window or even go outside, is again, blaming the victim and will never result in overall improvement in public health.

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

Sources:

Assessing Chemical Intolerance in Parents Predicts the Risk of Autism and ADHD in Their Children
Raymond F Palmer, David Kattari, Rodolfo Rincon, Claudia S Miller
J Xenobiot, 2024 Mar 5;14(1):350-367
https://www.mdpi.com/resolver?pii=jox14010022 

Chemical Intolerance and Mast Cell Activation: A Suspicious Synchronicity
by Raymond F. Palmer, J Xenobiot, 2023 Nov 12;13(4):704-718. doi: 10.3390/jox13040045 
https://www.mdpi.com/2039-4713/13/4/45

Drug Intolerances: Potential Risk Factors for Autism and Attention Deficit Hyperactivity Disorder
Heilbrun, L.P.; Palmer, R.F.; Jaen, C.R.; Svoboda, M.; Perkins, J.; Miller, C.S. Maternal Chemical and (ADHD). J. Am. Board Fam. Med. 2015, 28, 461–470
https://www.jabfm.org/content/28/4/461

Multiple chemical sensitivity/idiopathic environmental intolerance: A disability-rights, patient-led perspective
Sophia Jaworski, Comment J Allergy Clin Immunol Pract, 2024 Jan;12(1):265-266. doi: 10.1016/j.jaip.2023.11.023
https://linkinghub.elsevier.com/retrieve/pii/S2213-2198(23)01265-5

Mast cell activation may explain many cases of chemical intolerance
Claudia S. Miller, Raymond F. Palmer, Tania T. Dempsey, Nicholas A. Ashford & Lawrence B. Afrin, Environmental Sciences Europe, Volume 33, Article number: 129 (2021)
https://enveurope.springeropen.com/articles/10.1186/s12302-021-00570-3

Multiple Chemical Sensitivity
Review Brain Sci, Gesualdo M Zucco, Richard L Doty
2021 Dec 29;12(1):46. doi: 10.3390/brainsci12010046.
https://www.ncbi.nlm.nih.gov/pmc/articles/pmid/35053790/

The Dilemma of Mast Cell Activation Syndrome: Overdiagnosed or Underdiagnosed?
Cem Akin, MD, PhD, The Journal of Allergy and Clinical Immunology: In Practice
https://www.jaci-inpractice.org/article/S2213-2198(24)00065-5/fulltext

Parental avoidance of toxic exposures could help prevent autism, ADHD in children, new study shows
Press Release, March 28, 2024, University of Texas Health Science Center at San Antonio
https://www.sciencedaily.com/releases/2024/03/240328111021.htm#:~:text=A%20population%2Dbased%20survey%20of,in%20the%20bottom%20tenth%20percentile

The mast cell: an evolutionary perspective, Enrico Crivellato and Domenico Ribatti, Biol. Rev. (2010), 85, pp. 347 – 360.347
https://onlinelibrary.wiley.com/doi/epdf/10.1111/j.1469-185X.2009.00105.x

(Beyond Pesticides, April 4, 2024) Researchers at the National Institute of Pediatrics and National Polytechnic Institute found positive associations between pesticide exposure and heightened risk of certain childhood cancers. The finding is derived from a meta-analysis of 174 studies published between 2013 and 2023 and published in the International Journal of Molecular Science. The authors note, “Although [pesticide exposure] association with childhood cancer has not been fully demonstrated, we found that more than 80% of the epidemiological studies show positive associations [with forms of childhood cancer].”

Approximately one third of identified studies (roughly 16) find positive relationships between prenatal and postnatal pesticide exposure with heightened risk of leukemia, neuroblastoma, and rare forms of cancer, such as Wilms tumor. For central nervous system (CNS) tumors, half of identified studies (roughly 24) found a positive relationship with pesticide exposure. The researchers call on further research regarding interaction between different pesticides and health impacts on cumulative exposure.

The study is broad in scope, identifying various environmental pollutants and their associations with certain childhood cancers (e.g. radon exposure, air pollution, electromagnetic fields, indoor chemicals, and tobacco and alcohol). This Daily News focuses specifically on pesticide exposure. The researchers originally identified 6,172 studies through PubMed, however 174 studies were ultimately included after two rounds of screening with the three following criteria:

1. “Original or review epidemiological studies assessing the association between environmental pollution and childhood cancer;
2. Published between 2013–2023; and,
3. With abstracts in English or Spanish.”

Table 3 in the Results section identifies the running list of studies assessing pesticide exposure and risk of childhood cancer. Out of the 376 papers initially pulled from the database using the keywords “children,” “cancer,” and “pesticides,” the researchers included 49 articles following the criteria listed above. Regarding the type of exposure, 34 percent focused on parental exposure to pesticides, 24 percent focused on postnatal exposure, and 27% focused on maternal/prenatal exposure—a relatively even distribution of potential avenues for pesticide harms. Studies that fall under the category of “childhood cancer” typically refer to studies that investigate more than one type of cancer.

In the conclusion subsection on pesticides, researchers arrive at several determinations: “Importantly, our results revealed a high percentage of studies showing associations between CNS tumors, neuroblastoma, and pesticides (Figure 7). The mechanisms assessing the potential relationship of pesticides with these types of cancer should be explored. Although the genotoxicity of pesticides has been evaluated, their epigenetic effects need to be fully investigated because their contribution to childhood cancer etiology could be at this level []. In addition, although the risks of pesticide exposure have been vastly evaluated, the transgenerational effects of these exposures need more attention. It has been shown that the environmentally induced disease risk can be transmitted to the offspring, via epigenetic mechanisms through female and male germ lines.”

The findings from the studies in the meta-analysis do not come as a surprise for advocates who have witnessed the adverse health impacts of pesticide exposure on chemically sensitive populations such as children. In “Pesticides and Children Don’t Mix,” Beyond Pesticides outlines the myriad health risks associated with childhood exposure to pesticides that corroborate the findings of this more recent study. For example, a 2015 meta-analysis study by scientists at the Harvard University’s School of Public Health finds that children’s exposure to pesticides in and around the home results in an increased risk of developing certain childhood cancers. Authors found that cancer risk is connected most closely to the type of pesticide used and its application location. 

A 2024 Environmental Research study found an association between adverse neurodevelopment (brain function and development) among infants and exposure to the herbicide glyphosate during pregnancy. To that end, researchers indicate negative neurodevelopment becomes more pronounced at 24 months or two years. Glyphosate-based herbicides were also found to induce oxidative stress-induced damage in the brain after prenatal, early life, and postnatal exposure, leading to reduced melatonin levels that ultimately disrupt circadian rhythm and lead to sleep disorders later in life, according to a 2023 study in Antioxidants.

In addition to maternal/prenatal exposure from herbicides, children experience exposure to pyrethroid insecticides earlier in life as levels significantly increase after birth leading to degenerative neurotoxic impacts later in life, according to a study published in Frontiers in Public Health in 2023. There are some elected officials who are attempting to take action. The Protect America’s Children from Toxic Pesticides Act of 2023 (PACTPA), S.269, addresses many of the controversial issues with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration and use of pesticides in the U.S. that adversely affect farmworkers. Beyond Pesticides has documented the decades of disproportionate, adverse health impacts farmworkers face from chronic and acute pesticide exposure. Additionally, see the Daily News section on children to find further research and findings regarding pesticide exposure and children’s health.

Beyond Pesticides continues to provide resources for advocates calling on the expansion and strengthening of organic land management principles and agriculture to prevent the spread of toxic petrochemical pesticides. Please see the Pesticide-Induced Disease Database to stay informed on the latest scientific analysis regarding toxic pesticide exposure and chronic illnesses. Check out the Gateway on Pesticide Hazards and Safe Pest Management to identify which toxic pesticide ingredients are included in typical household items. Click on Eating With a Conscience to learn about potential toxic chemical and pesticide exposure in commonly consumed produce to better inform your food purchases. Moreover, you can take action by telling the U.S. Department of Agriculture (USDA)’s Food and Nutrition Service to require organic school lunches and tell U.S. Environmental Protection Agency to forego any further registration of pesticides that contain obesogens. 

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

Source: International Journal of Molecular Science

New research highlights the beneficial effects of rose essential oil (REO) on tomato plants as a plant defense potentiator (a substance or treatment enhancing natural defense mechanisms against pests, diseases, and other stressors by activating the plant’s own defense responses) for organic agriculture and horticulture. As reported in the Journal of Agricultural and Food Chemistry, REO, particularly its component β-citronellol, activates defense genes in tomato plants, enhances their natural defense mechanisms, and dramatically reduces leaf damage by 45.5%. Additionally, REO attracts beneficial insects that prey on herbivore pests. This study, “Novel Potential of Rose Essential Oil as a Powerful Plant Defense Potentiator,” adds to a growing area of scientific literature on essential oil (EO), largely unexplored as plant defense potentiators. Beyond Pesticides advocates for accelerating the switch from chemical-intensive agriculture to organic agriculture, which remains the only viable solution, in the long run, to address today’s existential crises by prioritizing natural pest control methods, soil health, and biodiversity conservation to protect farmworkers and consumers from the detrimental effects of petrochemical pesticide exposure.    

Study Methods and Results 

The researchers applied highly diluted solutions of EOs to the soil of potted tomato plants and assessed the expression levels of defense genes in the tomato leaves, such as PR1 and PIN2, which are known to play a role in plant defense responses. Additionally, they evaluated the extent of leaf damage caused by herbivores, including Spodoptera litura (a leaf eating pest) and Tetranychus urticae (spider mites), with field trials to validate the findings in a real-world agricultural setting. The researchers treated the soil of tomato plants with REO solution over three weeks and compared the pest damage level to plants treated with a control solvent. This field trial aimed to assess the practical effectiveness of REO in enhancing plant defense against pests and attracting beneficial arthropods.  

The main findings of the study include: 

1. REO, particularly β-citronellol, activates defense genes, including PR1 and PIN2, in tomato plants, which enhance their natural defense mechanisms; 
2. Tomato plants treated with REO show significant reductions in leaf damage caused by herbivores, such as Spodoptera litura and Tetranychus urticae, compared to plants treated with a control solvent.
3. Field trials confirm the efficacy of REO in enhancing plant defense in real-world agricultural conditions, resulting in a remarkable reduction (45.5%) in pest damage to tomato plants.
4. REO attracts herbivore predators, such as the Phytoseiulus persimilis mite, while not repelling the spider mite herbivores themselves. 

A specific concentration of REO (1 × 10^5 dilution), identified as optimal, echoes findings similar to those for valine menthyl ester, another plant defense potentiator, suggesting that higher doses might be detrimental, while the precise dilution used showed no negative impact on plant fitness.  Additionally, the study finds that soil application of REO was the only effective method for enhancing plant defense, as direct leaf application proved ineffectual—potentially due to the volatile nature of EOs and rapid evaporation when applied to foliage. Consideration in future research designs to calibrate and test for optimal concentrations and application methods (soil and foliar) across different environmental conditions is key to understanding how EOs or their derivatives might be systematically distributed within plants to enhance defense mechanisms even more effectively.  

The study underscores EO’s enormous potential as a safer and more effective tool of pest management—compatible with organic agriculture and horticulture—while minimizing health and environmental risks, an approach supported by Beyond Pesticides. Containing compounds with potent insecticidal and repellent properties, EOs have an “exceptional safety profile…(with) a range of bioactivities that greatly benefit human health.” EOs are a promising tool against the relentless issue of resistance. Conventional agriculture and the pesticide industry respond to weed resistance, for example, with a pesticides arms race, introducing more toxics as a solution that perpetuates the problem. Apart from the toxicity and other “downstream” issues related to many synthetic control chemicals, all organisms will eventually develop resistance against the harmful substances to which they are chronically exposed. For more information, please see Beyond Pesticides’ previous coverage here.  

Mosquito Management and EOs 

As noted in the March 24, 2022, Daily News post analyzing the study “Larvicidal and adulticidal effects of some Egyptian oils against Culex pipiens,” published in Nature, various EOs show significant larvicidal and adulticidal activity against the common house mosquito, Culex pipiens, which is a vector for diseases like West Nile virus and Saint Louis encephalitis. Egyptian scientists tested 32 EOs on C. pipiens larvae and adults, identifying garlic, dill, tea plant, fennel, fennel flower, sage, garden thyme, and sweet violet as highly effective, achieving up to 100% mortality. In addition, a 2019 study in the Florida Journal of Mosquito Control, found EO-based sprays more effective than common synthetic alternatives, supporting a science-based mosquito management approach that prioritizes preventive measures and ecological considerations while advocating for the use of less toxic, biodegradable products like EOs, based on monitoring data to minimize risks to non-target species. As communities like Boulder, Colorado, lead by example, in limiting biological larvicides in favor of ecological methods to control mosquito populations, it is vital to emphasize that even the least-toxic adulticides should be viewed as a mechanism of last resort, used under strict conditions to prevent mosquito-borne disease risks.  

Solution in Organic Methods 

EOs and other nature-based pest control alternatives offer a beacon of hope amidst the escalating crises wrought by conventional chemical-intensive agriculture. Beyond Pesticides calls for an end to the use of petrochemical pesticides and fertilizers by 2032 to safeguard human health, biodiversity, and environmental integrity. Embracing organic practices means embracing a holistic approach that nurtures the soil, promotes natural pest control mechanisms, and fosters resilient ecosystems. These ecological practices can mitigate adverse health risks associated with exposures and address the root causes of environmental degradation and climate change detrimentally impacted by petrochemical pesticides.  

By calling for a systemic shift to organic land management practices through advocacy, education, and grassroots action, Beyond Pesticides continues to lead the charge in catalyzing this transformation. In the introduction of our 2023 Transformative Change report referencing the vital need for a transformation to land and building management systems that align with nature, Jay Feldman, executive director of Beyond Pesticides, writes, “The transformative solution is a partnership with nature, practices that have been adopted in organic systems. With this approach, we honor all organisms who play a role in ecological systems on which life depends, and we seek the rapid adoption of those practices and materials that are already available to us or can be incentivized to become widely available quickly.” The fundamental solution lies in transitioning from conventional chemical farming to organic, regenerative agriculture.  

For more information, please refer to the Organic Agriculture page on our website. In addition, Beyond Pesticides’ ManageSafe™ | Least Toxic Control of Pests in the Home and Garden database is an excellent resource for safer solutions for readers. To learn about pesticides that may be used in local communities, please see Beyond Pesticides Gateway on Pesticide Hazards and Safe Pest Management. If you have a concern about pesticide use in your community, please contact Beyond Pesticides’ info desk at [email protected]. 

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

Sources: 

Novel Potential of Rose Essential Oil as a Powerful Plant Defense Potentiator, Eiki Kaneko, Kenji Matsui, Journal of Agricultural and Food Chemistry, 2024 

Products Compatible with Organic Landscape Management, Pesticides and You, Spring 2017  

https://www.beyondpesticides.org/assets/media/documents/mosquito/documents/LeastToxicMosquitoRepel.pdf 

Pesticides and Soil Health, Friends of the Earth, 2019  

Essential Oils In Organic Agriculture: A Review Of Practices And Potential, Natural Volatiles and Essential Oils, 2021 

Biocontrol Potential of Essential Oils in Organic Horticulture Systems: From Farm to Fork. Frontiers in Nutrition, 2022 

A Note on Biopesticides and EPA Definition  

“Biopesticides”—widely regarded as an alternative to chemical pesticides and hence given a special status in U.S. Environmental Protection Agency (EPA) regulation—need a better definition. Essential oils are one example of biopesticides naturally occurring substances that control pests (biochemical pesticides), microorganisms that control pests (microbial pesticides). However, Beyond Pesticides has argued that the current EPA definition for “biopesticides” is deceptive and misleading because it includes genetically modified organisms or synthetic analogs of naturally occurring biochemicals.  The development and adoption of genetically engineered (GE) and other questionable synthetic biopesticides can be seen as a diversion from the necessary shift towards sustainable food production. (See Beyond Pesticides call to action here).  

(Beyond Pesticides, April 2, 2024) There is a nascent capital investment effort in the transition to certified organic agriculture beginning to take hold across the U.S., something advocates say is critically needed to meet the current and escalating existential health threats, biodiversity decline, and climate emergency. Mad Agriculture has received early commitments from the Rockefeller Foundation, Builders Vision, and nearly a dozen other investors to contribute to the $50 million Perennial Fund II (PFII), to advance the growth of “regenerative organic” agriculture. Forbes is reporting that PFII’s primary objective is to jumpstart the organic land transition, given that this slice of U.S. agriculture makes up less than one percent of total farmland in the country relative to the European Union’s nearly 10 percent of total farmland. “We commend the work of Mad Agriculture in harnessing the spirit of organic agriculture and mobilizing the private sector to invest in farmers who engage in regenerative organic agricultural practices,” said Max Sano, organic program associate at Beyond Pesticides. In Rockefeller Foundation’s press release announcing their early commitment, Mad Capital co-founder Brandon Welch spoke on their vision: “We are aiming to build a bridge between two distant worlds that need one another to transition our food system – Wall Street and organic farmers…Providing farmers with access to capital gives humanity a shot at producing an abundance of healthy food while being ecologically accountable to our working lands and those that steward them.”

Mad Agriculture is an agricultural finance nonprofit with the specific goal of investing in the regenerative organic farmland transition in the United States. Their name is inspired by “Mad Farmer” poems from twentieth-century rural agricultural advocate and writer Wendell Berry, who warned the nation of the economic, health, and environmental consequences of farmland destruction. Mad Agriculture has four main initiatives: Mad Capital, Mad Lands, Mad Markets, and Mad Revolution. While Mad Capital is their investment fundraising arm, Mad Lands engages in business planning support for existing regenerative organic farmers providing services including impact assessments and stewardship consultancies to ensure that they are leading with ecologically beneficial practices. Meanwhile, Mad Revolution provides educational resources and Mad Markets is their newest initiative with more information to be released soon. Currently, the organization supports 79,115 acres in 14 different states. While their land portfolio is small relative to corporate commitments of millions in acreage to regenerative agriculture (not certified organic) from corporations such as General Mills, Walmart, and Unilever, Mad Capital shares Beyond Pesticides’ commitment to keeping organic strong in its theory of change, “The organic agriculture movement and certification (mainly for cropping systems) and holistic management (for livestock systems) provides a baseline of commitment to regeneration.” Mad Capital has the goal of transitioning five million acres to regenerative organic agriculture by 2032, which aligns with Beyond Pesticides’ mission to eliminate toxic petrochemical pesticides and fertilizer use from the food system by that same date.

Mad Capital is not the only player in the game. Another firm to watch is Iroquois Valley Farmland REIT, a B-corporation and real estate investment trust working in 19 states with over 60 farmers across 30,000 acres of land. “The Company is committed to scaling organic agriculture in the U.S. by getting more organic farmers on the land, funded by socially responsible investors,” according to their website. Essentially, this real estate investment trust allows investors to share the financial risk that organic farmers would otherwise take on their own by investing a minimum $10,700 over a five-year investment period, with payments available to said investors in the form of dividends at the end of their investment cycle. See here for more details on the structure of this real estate investment trust.

In their latest Public Benefit Report, Iroquois Valley identified goals for various categories, including “Environment: Where We Work,” “Customers: Our Farmers,” “Community: Our Investors,” “Workers: Our Staff,” and “Governance: Our Board” on page 11. They acquired a loan from the USDA Natural Resource Conservation Service (NRCS) to expand their soil health survey capacity to better equip their member farmers. Additionally, they added “19 new entity investors and 79 new trust accounts” into their portfolio in 2022 with the goal to continue this trajectory in 2023. It is important to note that just 55 percent of their total portfolio is certified organic as of 2022, yet 59 percent of the total production mix is devoted to cover crops –demonstrating their interest in elevating soil health as a fixture of their investment strategy even though they are not yet at 100 percent organic. Additionally, there appears to be a prioritization toward uplifting younger and more diverse groups of farmers in their portfolio. For example, in 78 percent of their clients, women are in leadership roles, and a combined 71 percent of the farm owners are Generation Z and Millennial.

“Regenerative farming without organic principles as a baseline can contribute to corporate greenwashing and misleading the public on sustainable agriculture,” said Mr. Sano. Regenerative and no-till farmers can, and often do, continue to rely on petrochemical fertilizers and pesticides, including glyphosate-based herbicide products that impose adverse health impacts, such as non-Hodgkin’s lymphoma, on farmers, farmworkers, frontline communities, and the broader public.

Surveys collected in a 2019 Friends of the Earth report, Pesticides and Soil Health, “… indicate that the majority of no-till farmers [in this study] rely on herbicides such as glyphosate, the active ingredient in Roundup. In fact, 86% of No-Till Farmer readers said they planned to plant Roundup Ready corn in 2017, while 80 percent planned to plant Roundup Ready soybeans, and some 92 percent planned to use glyphosate for weed control.” In contrast, a comprehensive study released in Journal of Cleaner Production in August 2023 identified the potential for organic agriculture to mitigate the impacts of agricultural greenhouse gas (GHG) emissions in the fight to address the climate crisis, determining that “a one percent increase in total farmland results in a 0.13 percent increase in GHG emissions, while a one percent increase in organic cropland and pasture leads to a decrease in emissions by about 0.06 percent and 0.007 percent, respectively.”

A 2019 publication from the International Monetary Fund, “Smart changes to how we farm and eat can have a huge impact on our planet,” quotes Rattan Lal of Ohio State University, a leading soil expert, who has calculated that “a mere 2 percent increase in the carbon content of the planet’s soils could offset 100 percent of all greenhouse gas emissions.”

While it is admirable that there are elements of private capital and elite financial institutions that acknowledge the contribution of synthetic pesticide and fertilizer dependency in conventional industrial agriculture in perpetuating and escalating the climate crisis, this is only one in a constellation of strategies needed—not a silver bullet. Beyond Pesticides maintains that structural change is only possible through the grassroots mobilization of concerned parents, physicians, public officials, scientists, farmers, and the broader public. See Keeping Organic Strong to learn how to engage in the public comment period for the Spring 2024 NOSB meeting, of which the deadline to contribute a comment is April 3. See Tools for Change for a range of strategies, resources, and tips to initiate grassroots advocacy in your community, town, city, or state against pesticide use on lawns, public land, and farmland.

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

Source: Forbes

(Beyond Pesticides, April 1, 2024) Comments are due 11:59 pm EDT, Wednesday, April 3.
For the public comment period—deadline Wednesday, April 3—in the lead up to the National Organic Standard Board (NOSB) meeting, advocates have identified the following priority issues:

• Getting plastics our of organic;
• Removing endocrine disrupting nonylphenols (NPs) and nonylphenol ethoxylates (NPEs) iodine from dairy production and replace with available alternatives; and
• Continuing to improve the science supporting ongoing decisions of the NOSB.

(See below for details and opportunity to submit comments on these with one click!)

Previously, Beyond Pesticides has reported on three additional priority issues, including;

• Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production;
• Eliminate nonorganic ingredients in processed organic foods as a part of the Board’s sunset review of allowed materials; and 
• Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment. 

(Please see the prior action on these issues and submit comments, if not done previously.)

Beyond Pesticides asks the public to join in commenting on priority issues that protect health and the environment as part of the upcoming NOSB meeting. The NOSB is receiving written comments from the public on key issues, preceding the upcoming public comment webinar on April 23 and 25 and deliberative in-person hearing April 29 through May 1—concerning how organic food is produced. Written comments must be submitted by 11:59 pm EDT April 3 through the link provided below. Sign up for a 3-minute comment to let U.S. Department of Agriculture (USDA) know how important organic is at the webinar by April 3. Links to the virtual comment webinars will be provided approximately one week before the webinars.

Beyond Pesticides has indicated that a strong and growing organic sector is critical to taking on the challenges of health threats, biodiversity collapse, and the climate emergency, and that the review and updating of organic standards require public involvement in the current public comment period. With this process, organic undergoes continuous improvement. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But organic will only grow stronger with public participation in voicing positions on key issues to the stakeholder advisory board, the NOSB, according to Beyond Pesticides. 

>> Submit your written comment to the National Organic Standard Board by April 3 by clicking HERE.

The NOSB is responsible for guiding USDA in its administration of the USDA organic label under the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health. Other than organic, there is no food label category that is defined in federal law and fully embraces health and biodiversity protection and enhancement, offers ongoing opportunities for public input and oversight, and is enforced with an inspection and certification system. Your comments help to make our food system what we need it to be for health, regenerative practices, and sustainability of the planet.

A draft meeting agenda is available here.  And a detailed agenda, along with the proposals, are available here.

Written comments are due by 11:59pm ET Wednesday April 3rd, 2024, as well as registration for Oral Comments. Oral Comment sign-ups fill up fast. Sign up for Oral Comments here.

The NOSB plays an important role in bringing the views of organic consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2024 Beyond Pesticides’ issues webpage.

Here are some of our high priority issues for the upcoming NOSB meeting (see others here):

• Make elimination of plastic in organic a research priority. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well documented. We need research into ways to replace all forms of plastic in organic production and handling.
  
  Microplastics—plastic fragments less than 5mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.
  
  Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products.
  
  The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics (of which 90% are at the nanoscale) with a majority containing unidentifiable chemicals. The number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. When they exposed cod eggs, embryos, and larvae to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans.
  
  Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta.
  
  
• Remove toxic nonylphenol ethoxylates from teat dips. Iodine, whose use in teat dips will be considered for relisting, is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors containing nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), in the class known as alkylphenols and their ethoxylates, are strong endocrine disruptors with impacts on many species, including gender changes. A number of alternatives are available. NPEs were banned in Europe ten years ago (in all products), and China has banned dairy product imports with NPE residues above 10 ppb. There are many commercially available non-NPE iodine-based disinfectants and teat dips that can be used instead. Iodine “without alkylphenols or alkylphenol ethoxylates” should only be listed.
  
  
• Improve the science upon which the NOSB bases decisions. The NOSB Policy and Procedures Manual (PPM) states, “A Subcommittee cannot proceed with a recommendation to list a material if it is determined that there is insufficient valid scientific information on that material’s impact on the environment, human health and its compatibility with organic principles.” When proposals have been based on Technical Reviews using the current template, they have frequently contained inadequate scientific support. These shortcomings often involve ancillary substances, nanoparticles, and excluded (GE) methods. The changes proposed on the agenda will improve the NOSB’s ability to make decisions based on science.

Comment Opportunities

• Oral Comments: The NOSB will hear oral public comments via virtual webinars on Tuesday, April 23, 2024, and Thursday, April 25, 2024, from 11:00am to approximately 5:00pm (Eastern time) OR Monday, April 29.
  
  
• In-Person Comments: In Milwaukee, WI from 2:00 to (approximately) 5:00 pm CT. Each commenter wishing to address the Board must pre-register by 11:59 p.m. ET on April 3, 2024, and can register for only one speaking slot. Instructions for registering and providing oral comments can be found HERE. The NOSB will meet in person in Milwaukee, WI, from Monday, April 29 through Wednesday, May 1, from approximately 9:00am to 6:00pm CT each day.

(Beyond Pesticides, March 29, 2024) Last week during National Agriculture Week, U.S. Senator Ben Ray Luján (D-NM) introduced S.4038, the Children’s Act for Responsible Employment and Farm Safety (CARE), aiming to elevate labor standards for young workers in the agricultural sector, as protection from pesticides remains weak. Currently, agriculture stands as the sole industry that permits children—as young as 12 years old—to work without significant limits on their hours of employment outside of school time. This scenario is a reality for hundreds of thousands of children across the U.S., who undertake the demanding tasks of planting, harvesting, processing, and packaging the food produced nationwide.

The CARE Act proposes to align the age and working hour criteria for underage workers in agriculture with those enforced in other sectors. Additionally, the legislation seeks to toughen both civil and criminal penalties for violations of child labor laws and to enhance safeguards for children against the risks of pesticide exposure. It is important to note, however, that the CARE Act would exempt farm-owning families, allowing their children to work on the family farm under the current guidelines.

Exemptions to the Fair Labor Standards Act (FLSA) currently allow children to work unlimited hours, outside of school  hours, in “non-hazardous” agricultural at the age of 12 and child farmworkers may perform may perform any agricultural job, including hazardous work, as of the age of 16. These exemptions apply only to farm labor and are significantly less stringent than laws applying to other sectors. 400,000-500,000 children and youth between the ages of 12-17 are estimated to be working in U.S. agriculture, with children ages 12-13 permitted to work in agriculture outside of school hours. Children ages 14-15 may work in nonagricultural jobs only with strict limitations on time of day and hours per week, but may work in agriculture outside of school hours without any restrictions. S.4038 will make the restrictions for agriculture child labor consistent with non-agriculture labor. Note: The CARE Act would not apply to the children of farmers working on their family farm.

Related legislation, the Fairness for Farm Workers Act (H.R. 4579/S. 2253), introduced in 2023 by U.S. Representative Raúl Grijalva (D-AZ) and U.S. Senator Alex Padilla (D-CA), would amend FLSA to provide overtime and additional minimum wage protections for farm workers. Upon introduction, Senator Padilla said, “It’s past time we correct our nation’s labor laws to include the farm workers who have been unjustly excluded from protections.”

Disproportionate Impact and “Agricultural Exceptionalism”

Creating true equity for farmworkers and specifically farmworker children, advocates point out, would require an overhaul of the laws governing pesticide use and exposure. Current law governing pesticide registration by the U.S. Environmental Protection Agency (EPA) is challenged as not adequately protective. The Food Quality Protection Act (FQPA), which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA), specifically excludes occupational exposure to pesticides from the calculation of cumulative or aggregate health risk from dietary and nondietary exposure. This means that children’s exposure to pesticides while employed in agriculture is excluded when determining the acceptable rates of their overall pesticide exposure. The statutory language of FQPA requires EPA to evaluate all exposure to the residues in food, water, and land of pesticides with a “common mechanism of toxicity” (e.g., families of chemicals like organophosphates and synthetic pyrethroids), but does not require that occupational exposure be included in that calculation.

A report released in January, US pesticide regulation is failing the hardest-hit communities. It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report, which follows an earlier article (see earlier coverage), documents the long history of “agricultural exceptionalism,” whereby agriculture is specifically excluded from many U.S. labor and occupational safety laws, can exacerbate the well-documented pesticide risks that farmworkers face on the job. 

What is the CARE ACT?

The CARE Act revises FLSA to update agricultural child labor age and work hour standards to match those for non-agricultural child labor, while still maintaining exemptions for family farms, 4-H, and educational or vocational programs that promote agricultural careers.

Key points in the legislation:

• It preserves and broadens exemptions for children working on family farms, ensuring they can continue to contribute to family agricultural operations.
• The legislation significantly raises civil and criminal penalties for child labor law violations, with civil penalties going up to $151,380 and penalties for serious violations leading to death or serious injury up to $690,000, both adjusted for inflation. Criminal penalties could reach $750,000 or include up to five years of imprisonment.
• It eliminates exceptions that currently allow for hand harvest laborers under 16 and reduces children’s exposure to pesticides by repealing certain worker protection standards. Additionally, it extends FLSA child labor protections to independent contractors, requires annual injury reports including workers’ ages to Congress, and mandates improved data sharing between the Department of Labor’s Occupational Safety and Health and Wage and Hour Divisions.
• The proposed law mandates that, within 90 days after its enactment, the Assistant Secretary of Labor for Occupational Safety and Health and the Administrator of the Wage and Hour Division must sign a memorandum of understanding. This agreement aims to enhance coordination and enforcement between the Occupational Safety and Health Administration (OSHA) and the Department of Labor Wage and Hour Division by sharing information and facilitating enforcement activities. This includes sharing records and reports related to worker injuries, illnesses, or fatalities, especially those involving children under 18. Additionally, the Assistant Secretary of Labor for Occupational Safety and Health is to encourage state agencies with approved state plans to participate in this information sharing. The memorandum is to be modeled after a similar agreement that was effective on May 4, 2023.

Risks to All Farmworkers, Children Uniquely Vulnerable

Children, in particular, face unique risks from pesticide and toxic chemical exposures. Due to their smaller body size, they absorb a higher relative amount of pesticides through the food they consume and the air they breathe. Additionally, children’s developing organ systems make them more vulnerable to the impacts of toxic exposure. Several authoritative bodies, including EPA, the National Academy of Sciences, and the American Public Health Association, have all voiced concerns about the potential dangers that pesticides pose to children. Scientific evidence has shown that pesticide exposure can negatively impact a child’s neurological, respiratory, immune, and endocrine systems, even at low levels. Some pesticides, such as synthetic pyrethroids, organophosphates, and carbamates, are known to cause or exacerbate asthma symptoms.

A specific example of the failure of EPA to protect children and specifically child farmworkers is found in the case of chlorpyrifos, a previously banned organophosphate insecticide under a federal court ruling, only to be overturned on appeal by the agrichemical and conventional agriculture industry. Beyond Pesticides has long reported on the multitude of twists and turns in EPA’s actions on chlorpyrifos, see background and a timeline of developments here. Chlorpyrifos is a dangerous, proven neurotoxicant that has dire impacts on children, making EPA’s action to allow its continued use a failure of both its protective mission and ethics. Further, it is an environmental justice failure, given that risks of exposure fall disproportionately on low-income African American and Latino families, including farmworker families, who are at the greatest risk of harm.

Despite several years of study, the science addressing neurodevelopmental effects [of the insecticide chlorpyrifos] remains unresolved,” as reported in The New York Times. This conclusion contradicts both ample scientific evidence and the agency’s own findings. Beyond Pesticides has repeatedly advocated for a ban on the use of chlorpyrifos because of the grave risks it poses. In 2019, Rep. Nydia Velásquez (D-NY) introduced the Ban Toxic Pesticides Act, H.R.230 to ban the insecticide chlorpyrifos from commerce. “It’s unconscionable for EPA to turn a blind eye as children and workers are exposed to this poison,” Rep. Velázquez said.  “If the EPA won’t do its job when it comes to chlorpyrifos, then Congress needs to act—and do so quickly.” No similar legislation has been introduced in the current Congress.

Current State and Federal Legislation

In 1938, the U.S. Congress enacted FLSA to enhance the welfare of workers, notably by restricting the employment of minors in severe forms of child labor. FLSA exempts certain types of agricultural work, permitting children aged fourteen and above to engage in non-hazardous farm tasks outside school hours. It also allows twelve and thirteen-year-olds to participate in such activities with a parent’s or guardian’s permission. The act specifically identifies eleven agricultural jobs as hazardous, which children under sixteen are prohibited from undertaking. Additionally, there are roles deemed hazardous for minors aged 16 to 18. The Department of Labor is responsible for FLSA’s enforcement.

States may pass their own child labor laws, but FLSA is seen as the “floor.” In other words, if a state law is less restrictive than FLSA, then FLSA will be the standard that employers must follow. If the state law is more restrictive than FLSA, then the state law will be the standard that employers must follow.

As documented in the U.S., according to the Department of Labor’s website, states like Alabama, Delaware, Georgia, Kansas, Kentucky, Louisiana, Maryland, Mississippi, Montana, Nebraska, North Carolina, Oklahoma, Rhode Island, Tennessee, Texas, West Virginia, and Wyoming have largely exempted agricultural labor from their child labor regulations. Meanwhile, California, Hawaii, New Hampshire, Washington, and Wisconsin stipulate that individuals must be 18 to engage in farm work during school hours. Furthermore, 14 states have designated 14 as the minimum age for children to work on farms outside of school hours. 

Federal legislation has been introduced often over many years and finds stiff opposition from big agricultural-industrial interests, including an earlier version of the CARE Act in 2023. U.S. Sen. Cory Booker (D-N.J.) also reintroduced legislation in February 2023 to increase protections against exposure to toxic pesticides. The Protect America’s Children from Toxic Pesticides Act (PACTPA) of 2023 includes a ban on the highly toxic pesticide paraquat, which is known to cause Parkinson’s disease, as well as dangerous organophosphates and neonicotinoids. The legislation addresses foundational weaknesses in federal law and the pesticide registration process that have resulted in U.S. approval of numerous pesticides already banned by many other nations.

More on Disproportionate Impact

The authors of the above-mentioned report on disproportionate harm—Nathan Donley, environmental health science director at the Center for Biological Diversity and Robert Bullard, known as the “Father of Environmental Justice” and executive director of the Robert D. Bullard Center for Environmental and Climate Justice at Texas Southern University in Houston—address the impact on child farmworkers. 

Children remain unprotected:

• Following recommendations from the National Academy of Sciences, the Food Quality Protection Act of 1996 (FQPA) established a mandate that the EPA further protect children from pesticide harm due to their heightened susceptibility to chemical exposures. This protection came in the form of a 10X safety buffer, reducing allowable exposures to all people from pesticides by tenfold as a way of protecting young children and the developing fetus. Given that children are more susceptible to harm from pesticides and children of color are more likely to be exposed to pesticides, this was widely seen as one way to protect the most vulnerable of at-risk populations.
• Unfortunately, Congress’s intent regarding protecting young children from pesticides has never been fully realized. The National Research Council found that the EPA only put in place the tenfold child safety factor for five out of 59 pesticides it analyzed, and a larger analysis of more than 400 pesticides by the U.S. Government Accountability Office (GAO) found that only 22% had the full safety factor utilized in approval decisions. A more recent analysis of 47 pesticides similarly found that only a small minority of pesticides that are present in food had any safety buffer incorporated for children.
• The lack of adequate protections can hit certain communities particularly hard. For instance, over 50% of migrant children in the U.S. have an unmet health need compared to just over 2% of all children living in the U.S. Compounding stressors can significantly increase the sensitivity of children to pesticides and other pollutants. Without added protections, children of color and those in low-income households are more likely to remain unprotected.

While OSHA is responsible for monitoring chemical exposures in various sectors, EPA has yet to implement mandatory biological monitoring for agricultural workers exposed to harmful pesticides. Such monitoring, involving the analysis of blood or urine to confirm exposure levels are not hazardous, is operational for certain pesticides through state-led initiatives in California and Washington. Findings from these programs indicate that harmful physiological effects can occur from pesticide exposure even when applied correctly and without immediate symptoms. Instituting a nationwide policy for biological monitoring, inspired by these state efforts, could mitigate risks for agricultural workers nationwide. This will take a concerted effort that rejects the chemical-by-chemical approach to reform, which at the current pace will not meet the urgency of the existential crises that we face as a nation and globe. The solution lies with proven organic methods to manage agricultural production, land spaces, and buildings without toxic chemicals. Reform legislation in Congress must meet the urgent need to make this a transformational moment.

Solutions to Protect Child Farmworker Safety and Fair Labor Standards

Advocates, including Beyond Pesticides, argue that the “precautionary principle” should be widely adopted across United States regulatory frameworks. This principle suggests a fundamental change in how government regulators approach the approval of activities that could lead to pollution. It encourages asking, “What is the minimum possible harm?” instead of, “What level of harm is acceptable?”  Implementing this approach means setting a more stringent, science-backed threshold for proving a chemical’s safety. It grants regulators the authority to preemptively halt potentially harmful actions when safety is uncertain and promotes a thorough investigation into less harmful alternatives. Although pesticides have adverse effects on child health and development, too little research has examined pesticide exposure among child farmworkers.

For more background on deficiencies in farmworker protection, see Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety.

Consumer food choices have a direct effect on those who grow and harvest food production around the world. This is why food labeled organic is the right choice. Certified organic food eliminates the most hazardous pesticides to which farmworkers are exposed in chemical-intensive agriculture. At the same time, an organic diet eliminates these pesticide residues in food and reduces a number of health threats like diabetes and increases brain function. In addition to mitigating serious health concerns associated with petrochemical pesticides and fertilizers, our decisions at the supermarket not only influence agricultural practices, but have a direct impact on the health and safety of farmworkers and their families. Advocates urge everyone to know where their food comes from and eat organic and fairly traded foods whenever possible and say thank you to those who grow and harvest our food. 

For more information on the importance of eating organic food for you, farmworkers, and the environment, please see Beyond Pesticides’ Eating with a Conscience and Organic Agriculture webpages.

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

Sources:

Senate Bill 4038: Children’s Act for Responsible Employment and Farm Safety (CARE) (S.4038)

During Ag Week, Luján Introduces Legislation to Improve Child Protections and Safety Standards for Agriculture Industry, Press Release, March 21, 2024

US pesticide regulation is failing the hardest-hit communities. It’s time to fix it., Brookings Institution, Nathan Donley, Robert Bullard, January 18, 2024

Pesticides and environmental injustice in the USA: root causes, current regulatory reinforcement and a path forward, Nathan Donley, Robert Bullard, Jeannie Economos, BMC, April 2022

(Beyond Pesticides, March 28, 2024) Last week, Maine Central reported the first application was filed for Maine’s first-in-the nation PFAS (per- and polyfluoroalkyl substances) Fund. This $70 million federal-state Fund to Address PFAS Contamination (PFAS Fund) provides compensation for commercial farmers whose health, business, and land have been impacted by PFAS contamination. A critical component of this fund enables the state to purchase contaminated farmland at fair market, pre-contamination value, which in the state of Maine hovers at approximately $3,729 per acre when including estimated market value of land and buildings, according to newly released data in the 2022 Census of Agriculture. “Maine became the first state to ban sludge recycling and approve a 2030 ban on PFAS in nonessential products,” according to reporting by Maine Central.

The state of Maine has exhibited extraordinary leadership in prioritizing public health, ecosystems, and the environment, setting an example for addressing a widespread contamination problem at the local, state, and national level. However, advocates in Maine are raising warnings after the Maine Department of Environmental Protection, according to reporting by Portland Press Herald, proposed “a compromise plan to regulate the sale of products containing forever chemicals [which] would exempt some federally regulated industries such as the automotive, aeronautical, and defense sectors from [the] 2030 ban on the sale of products that contain forever chemicals, even if a safer chemical alternative is available.” Beyond Pesticides will continue to track updates on this proposed plan as more details emerge. 

Jim Britt, Maine Department of Agriculture, Conservation, and Forestry (DACF) spokesperson, shared in a March 18 press release the expanded funding opportunities through the PFAS Fund, building on the framework of the existing PFAS Response Program: “Commercial farmers who have been impacted by PFAS contamination can now apply for an expanded suite of financial support programs:

• Administrative Cost Grants: A one-time grant intended to partially compensate commercial farms for time spent on activities common to most farms upon the initial discovery of PFAS contamination.
• Income Replacement Payments: Commercial farms that have stopped selling some or all products due to PFAS contamination may apply to DACF for up to a total of 24 months of lost income support, adjusted for inflation, while they avail DACFs technical assistance to determine a viable path forward.
• Technical Assistance / Professional Services: Financial support for professional services to help guide recovery efforts (e.g., business planning).
• Clean Feed Assistance: Short-term financial support for clean feed when it is necessary for the health and welfare of livestock and when clean feed is not available from the farm.
• Equipment and Input Cost Grants: Financial support for equipment and related input costs to allow a commercial farm to convert its operations to accommodate new products and production methods.
• Infrastructure Grants: Financial support for infrastructure projects (permanent physical assets and structures) that will help a commercial farm transition to new products and production methods.
• Debt Service on Existing Loans: Payments toward loan obligations directly related to farm infrastructure built/installed just prior to the discovery of PFAS contamination.
• New Loan Assistance: Financial support for costs associated with obtaining new loans.”

A growing list of state governments and industry actors are moving to phase out and ultimately ban PFAS in consumer products:

• “Maine, Minnesota, and Washington have given state agencies the authority to ban PFAS in a wide range of products.
• Twelve states, including California, Colorado, Connecticut, Hawai’i, Maine, Maryland, Minnesota, New York, Oregon, Rhode Island, Vermont, and Washington, have enacted phase-outs of PFAS in food packaging.
• Eight states, including California, Colorado, Maine, Maryland, Maine, New York, Vermont, and Washington, have adopted restrictions on PFAS in carpets, rugs, and/or aftermarket treatments.
• Six states, including California, Colorado, Maryland, Minnesota, Oregon, and Washington, are taking action to eliminate PFAS in cosmetics.
• Twelve states, including California, Colorado, Connecticut, Hawai’i, Illinois, Maine, Maryland, Minnesota, New Hampshire, New York, Vermont, and Washington, have banned the sale of firefighting foam containing PFAS.
• 32 unique retail chains, [including Burger King, McDonald’s, Starbucks, Sweetgreen, among others,] have committed to eliminating or reducing PFAS in food packaging, textiles and/or other products.”

Significant documentation and scientific research indicates the adverse health effects of PFAS for humans, wildlife, ecosystems, and environmental justice communities. A 2023 Environmental International study published by the U.S. Geological Survey (USGS) reveals that 45% of U.S. tap water is contaminated with at least one of the more than 12,000 types of PFAS. This percentage is likely to be on the low end, according to USGS Survey authors, given that only 32 of the 12,000 types of PFAS are detectable by their lab tests. The U.S. Environmental Protection Agency (EPA) last year proposed new limits to PFAS levels in drinking water. The urgency of public health implications for PFAS is stark, given that they have been found in water supplies in nearly 3,000 locations in all 50 states and two territories. PFAS chemicals have also been found in human breast milk, umbilical cord blood, deer meat, fish, and beef. One study using data from the National Health and Nutrition Examination Survey (NHANES) found PFAS compounds in 97% of Americans. Studies have suggested a wide range of health effects, including raised cholesterol levels, high blood pressure or pre-eclampsia during pregnancy, and increased risk of kidney cancer. Just as Bayer/Monsanto have faced waves of lawsuits regarding failure to warn liability claims of the severe adverse health impacts on their product labels, industrial chemical companies have faced similar scrutiny in the legal realm. In 2023, DuPont, Chemours, and Corteva agreed to a $1.185 billion dollar settlement with cities and towns across the United States to cover the cost of PFAS remediation and monitoring in public drinking water systems. To learn more about policy action, litigative history, and scientific literature, see the Daily News Archive on PFAS.

Beyond Pesticides is committed to eliminating the use of toxic petrochemical pesticides, including PFAS, by 2032. To realize this goal, we continuously engage grassroots organizers, communities, and cross-cutting movements in actions to contact state legislatures, Congress, and federal agencies. In 2024 alone, there are two ongoing actions to participate in including “Tell Your Delegate to Protect Marylanders from ‘Forever’ PFAS Pesticides” and “Tell Congress to Protect Farmers and the Public from PFAS.”

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

Sources: Central Maine, Maine Department of Agriculture, Conservation, and Forestry

(Beyond Pesticides, March 27, 2024) A preliminary experiment conducted by Public Employees for Environmental Responsibility (PEER) reveals concerning levels of toxic per- and polyfluoroalkyl substances (PFAS) on the skin of soccer players and coaches after playing on artificial turf fields. The Washington Post reported on March 12 on the PEER test results, which found PFAS levels increased on the skin in three out of four participants following soccer matches on artificial turf. In contrast, no similar increase was observed after games on natural grass fields. The presence of PFAS is alarming due to their association with several serious health issues, including cancer, birth defects, and developmental and immune deficiencies, among others.

The U.S. Environmental Protection Agency (EPA) writes that PFAS exposure risks are particularly concerning for young children, who are more susceptible due to their developing bodies and at risk for higher levels of exposure than adults. Known as “forever chemicals” for their persistence in the environment, PFAS continue to accumulate in the human body, posing long-term health risks. Kyla Bennett, PhD, science policy director at PEER and a former scientist and lawyer with EPA, emphasized the need for further research. “Although this study is preliminary, it highlights the potential risk of dermal absorption of PFAS from artificial turf,” Dr. Bennett stated. She also pointed out the significant gap in our understanding of PFAS exposure through skin contact, a potentially major pathway of exposure. Larger scale scientific studies are currently underway; as The Washington Post noted, “Wayne State University researchers are preparing to conduct a study on whether the chemicals found in turf can affect the endocrine system. For more information, please see Beyond Pesticides reporting on PFAS adding to the legacy of persistent toxics hurting generations of people and the environment.

“If the intent was to spread PFAS contamination across the globe, there would be few more effective methods than lacing pesticides with PFAS,” said Dr. Bennett. Her remarks underscore the significant environmental impacts as these chemicals can leach into surrounding surface and groundwater, posing a threat to drinking water sources. In addition, broader systemic impacts are emerging in addition to the direct contamination of water. As Beyond Pesticides reported, PFAS persistence is due to a fluorine–carbon atom bond being among the strongest ever created. PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply, among other resources, is a ubiquitous and concerning contaminant across the globe.

With health risks including developmental and endocrine system disruption, reproductive harm, cancer, and damage to the liver, kidneys, and respiratory system, PFAS presents a chronic danger that demands action. According to Dianne Woelke, a retired nurse and member of Safe Healthy Play Fields, “PFAS chemicals are so toxic that they are measured in parts per trillion,” Ms. Woelke said. “For every 80,000 square feet of plastic turf, there is between one and 38 pounds of various PFAS chemicals.” She further elaborates on the toxicity of the tire crumbs in between the synthetic blades of turf—found to contain over 350 chemicals. “Parents need to be made aware… just because a consumer product has been made for sale does not mean it is safe.”

States and local communities are taking action

The United States has an estimated 12,000 to 13,000 synthetic turf sports fields, with over a thousand new installations each year. Activists have sparked increased efforts to limit or remove artificial turf from various settings, including schools, parks, and professional sports arenas, spurring states and local governments to take action. New York has banned the sale of artificial turf with PFAS, starting at the end of 2026, and recognizes that recycling artificial turf can be a greenwashing fallacy (see NRDC 2022). Bills prohibiting the purchase of new artificial turf fields in select locations, such as schools, have also been introduced in Massachusetts and Vermont. In addition, California passed a 2023 bill banning the sale of PFAS-containing artificial turf, but it was not signed into law last year by Governor Gavin Newsom, who sought stronger enforcement and signaled that the issue could return in this legislative year. Newsom did allow cities and counties to again ban artificial turf when he signed a new law reversing a previous law preventing, or preempting, local governments from banning artificial turf. As Times of San Diego reported in October 2023, some California cities have already begun moving to prohibit synthetic lawns, including Millbrae in San Mateo County and San Marino in Los Angeles County. “Emerging research is making it clear that artificial turf poses an environmental threat due to its lack of recyclability and presence of toxins such as lead and PFAS,” said state senator Ben Allen, a Redondo Beach Democrat who authored the state bill. With the new law, “Local governments will again be able to regulate artificial turf in a way to both protect our environment in the face of drought and climate change but also by preventing further contribution to our recycling challenges and toxic runoff,” he said.

Organically managed natural grass is an overlooked solution

Beyond Pesticides and local advocates are fighting with a campaign to bring organically maintained natural grass into the ongoing discussions about artificial turf use. Cortney Jansen, a concerned parent from Sunnyvale, California, expressed her views to the Fremont Union High School District regarding this matter. Despite concerns, the district has agreed to replace six fields with new synthetic turf. [A notable conflict of interest, highlighted by the situation in Sunnyvale—the landscape consultant and construction firm engaged to provide impartial advice on turf replacement was the same entity granted a $14.5 million contract to carry out the work. This consultant was initially tasked with evaluating various alternatives for the replacement of 12 artificial turf fields due for removal before reaching their expected lifespan of eight to ten years.]

Testing for PFAS in artificial turf

Testing for PFAS in water is well defined. For an in-depth discussion that explains the science for non-science audience, please see Toxics Use Reduction Institute (TURI) at University of Massachusetts Lowell fact sheet, Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf Carpet. As TURI notes, testing for PFAS presents significant challenges due to the vast number of compounds within this class and their ability to cause adverse effects at very low concentrations. While testing methods for drinking water and wastewater have been developed, there is a lack of standardized guidelines for assessing PFAS in solid materials, such as artificial turf components. One important way to overcome these challenges includes developing techniques for assessing the total concentration of fluorine-containing organic compounds, which do not specifically target PFAS but indicates their presence. The importance of fluorine atoms as a proxy to measure the presence of PFAS is recognized by 20 states and is the subject of Maryland’s proposed HB1190 bill that would ban pesticides that contain PFAS. Read Beyond Pesticides’ call to action here and testimony here.

Does the synthetic turf industry know this and harken back to the tobacco industry’s playbook? In an email to the Washington Post, Melanie Taylor, the president and chief executive of the Synthetic Turf Council (STC), a trade association for the industry, pointed to the tests showing the presence of PFAS in soil. “STC has worked with its members to ensure their products contain no intentionally added PFAS constituents,” Ms. Taylor said. Advocates note that the real explanation for PFAS contaminated soil could be from pesticides containing PFAS commonly used on conventional natural grass turf, the same PFAS containing pesticides that are the subject of Maryland’s proposed ban.

Given the extreme toxicity of PFAS, its alarming ubiquity, its persistence, and the cost of remediating contaminated drinking water, there is an urgent need to do all we can to stop adding it to the environment. As the federal government has been slow to regulate the industry, local residents, and communities have taken up the call to eliminate the use of PFAS. One impactful area that can be addressed at this level is land management. 

A common and dangerous misconception is that the options for community athletic fields are limited to synthetic turf or synthetically managed natural turf. This is a false dichotomy. There is a third option that avoids both sources of PFAS: organically managed natural turf. Organic management practices build soil health, cycle nutrients naturally, enhance turf resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers. The organic alternative is central to a community’s discussion about its residents’ commitment to the elimination of practices and products that are petrochemical-based and the ability of organically managed soils to draw down (sequester) atmospheric carbon as a reasonable price point—even factoring in water and labor costs.

To take action, sign up to be a Parks Advocate today to encourage your community to transition to organic land management! For more information on the Parks for a Sustainable Future program, please reach out to our team at [email protected].

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

Sources:

PFAS in Artificial Turf Coats Players’ Skin, Dermal Uptake Little Examined Exposure Pathway for Toxic PFAS, PEER, March 12, 2024  

Turf fields may have ‘forever chemicals.’ Should kids be playing on them? The Washington Post, March 12, 2024

Dermal uptake: An important pathway of human exposure to perfluoroalkyl substances? Environmental Pollution, August 15, 2022

Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf Carpet, Toxics Use Reduction Institute (TURI) University of Massachusetts, Factsheet, February 2020

Gestational and childhood exposure to per- and polyfluoroalkyl substances and cardiometabolic risk at age 12 years, Environment International, February 2021

Organic vs Chemical Land Management Differentiating Two Approaches Beyond Pesticides, Pesticides and You, Winter 2019-2020

Recycling Lies: “Chemical Recycling” of Plastic Is Just Greenwashing Incineration, Natural Resources Defense Council, September 2022

The Devil they Knew: Chemical Documents Analysis of Industry Influence on PFAS Science, Annals of Global Health, 2023

PFAS in Artificial Turf Technical Report, New Jersey Department of Environmental Protection Division of Science and Research, Sandra Goodrow, Ph.D., February 2023

(Beyond Pesticides, March 26, 2024) The authors of a case study in Canale D’Aiedda, Taranto, Italy, published in Scientific Reports, conclude that, “[T]he results of monitoring and modeling activities revealed a chronic risk associated with the presence of Cu [copper] from November to April in several river reaches and acute risk associated to the presence of glyphosate in several reaches mainly in the wet season.”  According to the authors, “The most important factor influencing the chronic risk for Cu were the combination of two factors: the high surface runoff and the Cu applications. The most important factor influencing the glyphosate peaks of concentration is the streamflow.”

The authors of the study measure the flow of pesticide concentrations through the soil and water assessment tool (SWAT). The ecotoxicological data was collected at two stations in Germany that flow into Italy, within the Canale d’Aiedda basin. The streamflow was monitored between August 2017 and December 2019. Out of hundreds of pesticides and six metabolities investigated in this study, “only traces of copper and glyphosate were found.” The authors continue, “The banks and the bed of the river system are almost all covered by concrete. The hydrological regime is natural and intermittent in the upstream part of the basin, while it is almost perennial, in the remaining area, due to the presence of the discharges from three wastewater treatment plants (WWTPs), located in the municipalities of Montemesola, Monteiasi, and San Giorgio Ionico.”

While the researchers found significant levels of glyphosate and copper in the study area, they also acknowledge the potential gaps in the SWAT model. “The SWAT model performed satisfactory and good for Cu and glyphosate, respectively. However, it underestimated measured concentrations for both compounds,” as the study reports. “This could depend on the fact that SWAT does not simulate the drift loss which occurs during a pesticide application[], it is still unable to spatially reflect the fate of the drifted part of particles explicitly due to oversimplification[]. Other sources of uncertainty, which could have influenced the results, are related to the quality and quantity of measurements (i.e. discrete data instead of continuous data) used for the calibration and to the temporal discrepancy between the calibration of the streamflow and the calibration of the pesticides concentration[]. Similarly, the input data (i.e. application rates of the pesticides), which were derived from regulations or from the safety sheet, could be affected by a large uncertainty and they have had a key role in the modelling pesticides concentrations [].”

There are years of scientific studies and reporting that indicate the adverse ecological and public health consequences of widespread glyphosate-based herbicide use in agriculture and land management. A 2023 study in Chemosphere points out that glyphosate exhibits strong evidence of genotoxicity, epigenetic alterations (heritable changes in gene expression), oxidative stress, chronic inflammation, endocrine disruption, and disturbs gut microbiota implicated in lymphomagenesis (growth and development of lymphoma). See the Gateway on Pesticide Hazards and Safe Pest Management for more information and analysis of glyphosate harms. The petrochemical pesticide industry faces continuous litigation from victims of pesticide exposure, including Bayer/Monsanto on Roundup Ready. As of 2022, Bayer settled over 100,000 lawsuits on glyphosate/Roundup, paying out approximately $11 billion. The company faces an additional 30,000 lawsuits pending, according to reporting by Forbes. For a full history of litigation see, “Bayer/Monsanto in Roundup/Glyphosate Case Stung with Largest Multi-Billion Dollar Jury Award, Asks States to Stop Litigation.”

Copper is widely used in agriculture, both conventional and organic for fungal and bacterial diseases in a wide range of crops, including orchards and vegetable production. It is also widely used to treat utility poles throughout communities. Under the Organic Foods Production Act, “The National List [of Allowed a Prohibited Substances] may provide for the use of substances in an organic farming or handling operation that are otherwise prohibited under this title only if” the synthetic allowed materials fit in several categories including copper.

Copper sulfate is widely used in organic rice production to control algae and an invertebrate known as tadpole shrimp. Most of the world transplants rice seedlings into flooded paddies. Dryland rice production eliminates the need for control of tadpoles, which eat the rice seedlings in flooded fields. Ironically, tadpole shrimp are regarded as a biological control for algae. In 2021, the Crops Subcommittee of the National Organic Standards Board (NOSB) acknowledged the following:

It appears that to date there is sufficient evidence to conclude that:

1. use of copper sulfate in rice fields can cause environmental damage,
2. alternative seeding practices could eliminate the need for copper sulfate as both algae and tadpole shrimp cease to be problematic once seedlings are established, and
3. international standards do not allow for spraying of copper sulfate for organic rice production.

Copper sulfate is a toxic pesticide that has documented incidents of adverse impacts on reproductive, kidney, and liver health. A recent study found that copper sulfate has an association with the development of Parkinson’s disease. Studies also found that copper sulfate is moderately toxic to birds, and it is toxic to fish and aquatic organisms. In previous years, Beyond Pesticides has called for expanded research to determine alternatives to copper sulfate and continues to call for its phase-out of organic agriculture. A 2023 study published in Science of the Total Environment identifies a progressive decline among three endpoints: motor skills, cognitive function, and mental health regarding depression. Markedly, individuals living near residential areas or working in occupations with higher exposure to copper sulfate experience a rapid decline in all endpoints.

The NOSB has previously discussed alternative growing systems that would eliminate the need for copper sulfate and made such alternatives a research priority. Copper sulfate is widely used in organic rice production to control algae and an invertebrate known as tadpole shrimp. Most of the world transplants rice seedlings into flooded paddies. Dryland rice production eliminates the need for control of tadpoles, which eat the rice seedlings in flooded fields. Ironically, tadpole shrimp are regarded as a biological control for algae.

Beyond Pesticides encourages the public to engage with the National Organic Standards board to end the use of all toxic petrochemical pesticides. Every six months the NOSB hosts meetings, reviews allowed substances, and continuously updates their review to ensure the integrity of the organic label and the protection of health and the environment.  People are encouraged to see Beyond Pesticides’ Keeping Organic Strong webpage to learn about next month’s NOSB meeting and a link for submitting comments (due April 3, 2024).

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

Source: Scientific Reports

(Beyond Pesticides, March 25, 2024) Because of their widespread infiltration into the environment and the bodies of all organisms, including humans, plastics contamination requires a holistic strategy to protect life— with consideration given to practices and chemical use that reduce or eliminate harm. Pesticides and other toxic chemicals are adsorbed (adhered) to microplastics, resulting in bioaccumulation and widespread contamination. This adds to the complexity of the problem, which is largely ignored by federal regulatory agencies. While most environmental policies attempt to clean up or mitigate health threats, new data reinforces the need to stop the pipeline of hazardous chemicals, wherever possible.

With new data on the harm associated with plastics and related contamination, it becomes urgently necessary for all government agencies to participate in a comprehensive strategy to eliminate plastics and pesticides. Beyond Pesticides points to the evolving science on plastics contamination and their interaction with pesticides as yet another reason to transition to holistic land management systems that take on the challenge of eliminating hazardous chemical use. Organic land management policy creates the holistic systems framework through which plastics can be eliminated.

>> Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food.

The human and environmental health implications of plastic and related contamination are becoming increasingly well documented. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—on a wide range of organisms. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

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. A study published by researchers at Columbia and Rutgers universities in the January 2024 Proceedings of the National Academy of Sciences reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale.

Researchers at Norway’s MicroLEACH project published a study that analyzes the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys and balloons. They found, as in previous studies, that many hazardous chemicals are in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown.

In the Columbia/Rutgers study, the researchers checked for seven types of plastic, but they were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. (Tap water also contains microplastics in many places, although in much lower concentrations.) The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.” The Norwegian scientists also exposed cod eggs, embryos and larvae to water containing microplastics. The toxic effects they observed include spinal deformities reminiscent of scoliosis in humans.

In other new studies, out of a total of 257 patients who completed the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles been found in human lungs, blood, feces, and breast milk. They have even shown up in the brain as well as the placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

>> Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food.

Letter to EPA:

Because of the adsorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask EPA to develop drinking water standards and ambient water quality standards for microplastics. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

Researchers at Columbia and Rutgers universities in the January 2024 Proceedings of the National Academy of Sciences reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Researchers checked for seven types of plastic but were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. Tap water also contains microplastics in many places. The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.”

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown. They also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) leach out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

Please do your part to eliminate microplastics from our water supplies.

Thank you.

Letter to USDA:

Because of the adsorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask USDA to discourage the use of plastic in agriculture. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size. They can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

Soil organisms and edible plants have been shown to ingest microplastic particles. Earthworms can move microplastics through the soil, and microplastics can move through the food chain to human food. Microplastics can have a wide range of negative impacts on the soil, which are only beginning to be studied, but include reduction in growth and reproduction of soil microfauna.

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown. The scientists also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

Please do your part to eliminate microplastics from our food and environment by discouraging the use of plastic mulch and other plastics in agriculture.

Thank you.

Letter to FDA:

Because of the adsorption of pesticides and other toxic chemicals to microplastics and resulting bioaccumulation, among other health threats, I am writing to ask FDA to develop standards for food containers and food contact materials to eliminate movement of plastics and associated contaminants into food and bottled water. Plastics are everywhere, including the human body. As we learn about the risks associated with plastics, it becomes crucial for all government agencies to participate in a comprehensive strategy to eliminate them.

Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—which can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish show that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.

A study published by researchers at Columbia and Rutgers universities reports that the average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale. The other ten percent are slightly larger, at microscale. Researchers were only able to identify about ten percent of the nanoparticles they found. Polyethylene terephthalate (PET) was a common ingredient, probably because many water bottles are made of it. However, they also found polyamide, polystyrene, polyvinyl chloride, and polymethyl methacrylate. Tap water also contains microplastics in many places, although in much lower concentrations. The team found that the number of individual chemical compounds varied wildly among products, ranging from 114 to 2,456, leading them to conclude that “assessing the toxicity of plastic chemicals present in a product based on testing individual target chemicals has limited value.”

Researchers at Norway’s MicroLEACH project analyzed the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys, and balloons, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products, suggesting that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites, and degradation products. The scientists also exposed cod eggs, embryos, and larvae to water containing microplastics, observing toxic effects, including spinal deformities reminiscent of scoliosis in humans.

A study published in the New England Journal of Medicine found that out of a total of 257 patients completing the study, polyethylene was detected in carotid artery plaque of 150 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic has also been found in human lungs, blood, feces, breast milk, the brain, and the placenta.

Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products, according to research published in Environment Technology and Letters. The data confirm the results of prior research focused on the propensity of PFAS to contaminate various pesticide products through the storage containers.

Please do your part to eliminate microplastics from our food and water supplies.

Thank you.

(Beyond Pesticides, March 22, 2024) With long-running efforts to keep organic land management in the forefront of public health and environmental measures to eliminate petrochemical synthetic substances, including pesticides and fertilizers, plastic again emerges as an increasing threat in a study linking microplastics to cardiovascular disease. The study by Italian researchers, published in the March 7 issue of the New England Journal of Medicine, finds an elevated risk factor for heart attack and stroke associated with plastics found in the plaque of the majority of patients’ carotid arteries. A holistic approach to agriculture that embraces principles and values to enhance biodiversity and protect health, the organic system requires that synthetic substances are compatible with that system. In this context, the environmental and public health effects of plastics are increasingly subject to scrutiny as they permeate nearly every aspect of food production, including fields, crops, foods, and food packaging.

Plastics also migrate from other sectors into agriculture via wind and water and are now ubiquitous in every environment. Removing plastics from any ecosystem is extremely problematic, so getting them out of agriculture will be difficult – but necessary, given the accumulating evidence of their toxicity.

Beyond Pesticides continues to push for eliminating plastic use in organic agriculture. The organization is urging the U.S. Department of Agriculture’s National Organic Standards Board (NOSB) to increase its research into ways to accomplish this. The NOSB is accepting online public comments on its policy goals until April 3 this year. In a recent comment to the NOSB, Beyond Pesticides notes that major sources of plastic inputs to agriculture include plastic mulches, compost, and leachate that migrate from landfills into ground and surface water. Beyond Pesticides has identified key issues, available here, and urges the board to take important actions regarding microplastics and compostable materials.

Beyond Pesticides’ comment states that in addition to their direct harm to health, microplastics “also act as carriers of toxic chemicals that are adsorbed to their surface.” For example, many plastics contain additives such as bisphenol A, organotins and phthalates, all known endocrine disrupters, and these can hitch a ride on the plastic particles. The letter continues, “Some studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.” Studies have shown that microplastics migrate into many human tissues, including the lungs, liver, breast milk, urine, blood, and the placenta.

The universal distribution of plastics ensures that they cannot be avoided. Humans and other organisms take up plastics in the form of micro- and nano-particles by inhalation, ingestion, and skin contact every day. Micro-plastics are about the width of a human hair; nano-plastics are much smaller, about twice the width of a DNA strand. Larger pieces of plastic are ground down to these tiny sizes by weathering, temperature, biological processes, and chemical conditions.

Emerging evidence shows that plastics affect many organs and physiological processes. They can influence cellular metabolism, cell signaling, iron transport, and other vital cellular processes. As scientists find closer connections among various systems previously considered separate, such as gut health, mental health, and immune responses, plastics’ effects on cardiovascular health are attracting more scrutiny. Plastics can impair heart function. They can induce several markers of oxidative stress and associated inflammation. Pregnant mice fed microplastics developed disturbed gut microbes and changes in lipid metabolism, including cholesterol levels, which are factors in cardiovascular disease.

The Italian researchers studied a group of 257 hospital patients who had been diagnosed with plaque in their carotid arteries, a major risk factor for heart attack and stroke. Plaque is a sticky goo of cholesterol and fats that narrows arteries. The researchers examined each patient’s plaque for the presence of microplastics. (They added micro- and nano-scale sizes together in their analysis.) They found two types of plastic out of the 11 they looked for: polyethylene (PE) and polyvinyl chloride (PVC), two chemically related compounds used globally in massive quantities. At 36 percent of the global plastics market, PE is the highest-production non-fiber plastic in the world; PVC is third at 12 percent.

More than half of the full group of patients had PE in their plaque; 12 percent had PVC. The team divided their subjects into those with microplastics and those without microplastics and followed both groups for 34 months, tracking their incidence of cardiovascular events. At the end of the study period, the scientists found that the group with microplastics was at “a higher risk of a composite of myocardial infarction, stroke, or death from any cause” than the group without microplastics. The team tested a set of inflammation markers in the plaques, finding sharply higher levels in the group having microplastics in their plaque. They also checked collagen levels in the plaque as an indicator of activity by lymphocytes and macrophages, immune cells with a role in cardiovascular disease development, finding higher levels associated with the microplastics group.

The study results were adjusted to account for age, sex, body mass index, total cholesterol, diabetes, hypertension, and other conditions. The patients with microplastic-laden plaques were younger, more likely to be male, less likely to have hypertension, more likely to be diabetic, and to have heart disease and high cholesterol. They were also more likely to smoke. Thirty of 150 patients with microplastics in their plaque died or had non-fatal cardiovascular events, while only eight out of the 107 patients without microplastics experienced such events. 

Size matters at the scale of these plastic particles. The smaller the particle, the farther it can travel and the more types of tissues it can enter. Nanoplastics are in the size range of viruses, which means they may enter individual cells. The present study’s authors suggest that nanoplastics likely account for the bulk of the plastics in the plaques. In addition, the smaller a particle, the larger its surface area in proportion to its mass. This makes micro- and nanoplastics able to carry relatively high amounts of absorbed chemicals like pesticides, increasing their effects. And more surface area increases the likelihood of chemical reactions with other substances in the environment, so that the microplastics themselves may be more reactive with biochemistry than their larger versions. Nanoscale particles can also cross the blood-brain barrier. These properties have not been comprehensively assessed for their role in health risks, but they are of increasing concern regarding the smallest particle sizes.

It is also dawning on researchers that plastics’ full chemical interactions with biology are only dimly comprehended and not confined to any compound’s disclosed ingredients. Beyond Pesticides’ letter to NOSB cites a Norwegian study finding that “the components of 50 items in common use—plastic bags, disposable cups, dishwashing gloves, car tire granules, children’s toys and balloons…could not be identified because they were not listed in the major chemical substance databases. Only 30 percent of the chemical compounds identified in the study were present in two or more products. This suggests that most plastics contain many unidentified chemicals, far beyond the known impurities, metabolites and degradation products. Further, it suggests that in the environment plastics are chemically reactive and forming new compounds no one has anticipated and whose toxicity is unknown.” This problem applies to micro- and nano-plastics to an even greater degree, partly because of the abovementioned property of increased chemical reactivity with increased surface area at small scales.

A 2017 Science Magazine review titled “Production, use and fate of all plastics ever made” observed that “without a well-designed and tailor-made management strategy for end-of-life plastics, humans are conducting a singular uncontrolled experiment on a global scale, in which billions of metric tons of material will accumulate across all major terrestrial and aquatic ecosystems on the planet.”

As widely recognized, plastics are a form of fossil fuel, and it is not just its contribution to the climate crisis that is of concern. Their intractable ubiquity makes the urgency of removing plastics to the greatest extent possible from food production systems all the more dire. Plastic production must be cut drastically back, and a way to recover and sequester even the smallest particle sizes must be developed and implemented without delay. Fossil fuels must, from now on, be left in the ground rather than extracted, extruded, and distributed as micro- and nano-scale invaders of the biosphere.

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

Sources:
Microplastics and Nanoplastics in Atheromas and Cardiovascular Events, N Engl J Med 2024;390:900-10, DOI: 10.1056/NEJMoa2309822, https://www.nejm.org/doi/full/10.1056/NEJMoa2309822; PVC, other microplastics found in clogged arteries: Medical News Today, March 12, 2024, https://www.medicalnewstoday.com/articles/pvc-other-microplastics-found-in-clogged-arteries; Production, use, and fate of all plastics ever made, Roland Geyer, Jenna R. Jambeck, Kara Lavender Law, Science Magazine, July 2017, https://www.science.org/doi/epdf/10.1126/sciadv.1700782; The need for environmentally realistic studies on the health effects of terrestrial microplastics, Lauren Mills, Joy Savanagouder, Marcia de Almeida Monteiro Melo Ferraz and Michael J. Noonan, Microplastics and Nanoplastics,  https://doi.org/10.1186/s43591-023-00059-1, https://microplastics.springeropen.com/articles/10.1186/s43591-023-00059-1; Farm animals as a critical link between environmental and human health impacts of micro-and nanoplastics, Hilde Aardema, A. Dick Vethaak, Jorke H. Kamstra & Juliette Legler, Microplastics and Nanoplastics, volume 4, Article number: 5 (2024), https://microplastics.springeropen.com/articles/10.1186/s43591-024-00082-w; Interactions of Microplastics with Pesticides in Soils and Their Ecotoxicological Implications, Aránzazu Peña, José Antonio Rodríguez-Liébana and Laura Delgado-Moreno, Agronomy (2023) 13(3), https://doi.org/10.3390/agronomy13030701, https://www.mdpi.com/2073-4395/13/3/701; Nanoplastics and Human Health: Hazard Identification and Biointerface, Hanpeng Lai, Xing Liu, and Man Qu, Nanomaterials, April 2022, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9026096/, Genotoxic and neurotoxic potential of intracellular nanoplastics: A review, Claudio Casella and Santiago J Ballaz, Journal of Applied Toxicology, 24 February 2024, https://analyticalsciencejournals.onlinelibrary.wiley.com/doi/epdf/10.1002/jat.4598; Microplastics derived from plastic mulch films and their carrier function effect on the environmental risk of pesticides, Xin Bao, Yuntong Gu, Long Chen, Zijian Wang, Hui Pan, Shiran Huang, Zhiyuan Meng, Xiaojun Chen, Science of the Total Environment, 10 May 2024, https://www.sciencedirect.com/science/article/pii/S0048969724016139?via%3Dihub