(Beyond Pesticides, December 13, 2024) In October, the U.S. Environmental Protection Agency (EPA) approved the registration applications of BASF Corporation and Mitsui Chemicals Crop & Life Solutions, Inc. for the use of different formulations of the L-isomer of glufosinate (also known as “L-glufosinate” and “glufosinate-P”) as new active herbicidal ingredients. This decision marks one of the first times that EPA has employed its new Herbicide  Strategy Framework to determine the level of mitigation necessary to protect listed species and critical habitat under the Endangered Species Act (ESA). Glufosinate is an organophosphate, with known neurotoxic, reproductive/developmental effects, toxic to aquatic life, and mobile in soils (see Beyond Pesticides Gateway). Scientists have found that formulated glufosinate is generally more toxic to aquatic and terrestrial animals than the technical grade active ingredient.

Manufacturers are introducing newer glufosinate products as alternatives for glyphosate-based herbicides, like Bayer/Monsanto’s ‘Roundup’ and dicamba. The Center for Biological Diversity notes in comments submitted to EPA on this decision, “L-glufosinate has the potential to be used on tens of millions acres of land every year given the crops EPA has proposed to register it on. The scale of potential use is far above most new active ingredients.”

This first significant application of the Framework demonstrates, according to advocates, that the herbicide registration process remains insufficient to protect endangered species, public health, the environment, and biodiversity. As advocates, as well as Beyond Pesticides, have observed, the agency presupposes that farmers must use toxic chemicals, an assumption that clouds and undermines the regulatory process, trapping farmers on a toxic pesticide treadmill. Fundamental change requires EPA—in every pesticide registration and registration review—to examine whether there are practices that can eliminate harm, not substitute one toxic conventional pesticide for another.

Glufosinate-P is an enriched isomer of glufosinate, a broad-spectrum herbicide registered in the U.S. that targets glutamine synthetase to inhibit photosynthesis and poison plants. While the currently registered active ingredient glufosinate contains both D- and L-isomers, only the L-isomer (glufosinate-P) is herbicidally active. Two forms—glufosinate-P and its ammonium salt, glufosinate-P-ammonium—are being registered as functionally equivalent, and EPA states, “Glufosinate-P-ammonium is the ammonium salt of glufosinate-P and shares all the herbicidal properties for glufosinate-P,” as mentioned in the document entitled Memorandum Supporting Final Decision to Approve Registration for the New Active Ingredient Isomer, Glufosinate-P (Docket ID: EPA-HQ-OPP-2020-0533). Both are nonselective, postemergence contact herbicides. To align with the International Organization for Standardization (ISO) naming conventions, EPA is establishing tolerances for glufosinate-P, the ISO standard name for L-glufosinate-free acid. 

For years, EPA failed to comply with ESA by not accounting for impacts to threatened and endangered species (“listed species”) when approving pesticide usage under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (see here, here and here). Prior to the Herbicide Strategy Framework, EPA leveraged a chemical-by-chemical, species-by-species approach to meet its ESA obligations: an extremely slow process resulting in less than a five percent completion rate. The reactivity found EPA responding to legal challenges rather than proactively addressing endangered species concerns, and by early 2021 the agency faced nearly two dozen lawsuits covering thousands of pesticide products directly related to this failure.  As a result, the agency acknowledged its failure to properly assess impacts on threatened and endangered species and, in the following year, released a work plan to guide program improvements, including strategies for EPA’s pesticide program to meet its ESA obligations. In August 2024, EPA published the Final Draft of its new Herbicide Strategy Framework to “assess potential impacts and identify mitigations to reduce potential population-level impacts to listed species from the use of agricultural herbicides.”

The agency’s Herbicide Strategy Framework utilizes a three-step decision-making process for determining appropriate mitigation measures:

1. Determine the potential for population-level impacts to listed species as “not likely,” “low,” “medium,” or “high,” based on environmental fate and toxicity data submitted by registrants and EPA’s standard models.
2. Identify required mitigation requirements to reduce drift and runoff to non-target species to reduce exposure levels for listed species: three points of mitigation for “low” impacts, six points for “medium impacts,” and nine points for “high” impacts.
3. Identify where geographically the mitigation measures identified in Step 2 will apply (i.e., some mitigation measures will be required everywhere while others may only be applied in specific geographic regions).

In a notable change from an earlier draft of the Framework, EPA now allows pesticide applicators to reduce buffer zones around herbicide applications by implementing additional measures to control spray drift. The mitigation options vary based on the method of application and include using specialized equipment, lowering the application rate, adding physical barriers like windbreaks or hedgerows, adjusting the treated area’s width, and considering relative humidity. Each measure has an assigned percentage value by which the buffer can be reduced. For example, a 100-foot buffer could be lowered to 80 feet if a mitigation measure with a 20% reduction is applied.

According to EPA Deputy Assistant Administrator for Pesticide Programs for the Office of Chemical Safety and Pollution Prevention Jake Li, “By identifying protections earlier in the pesticide review process, we are far more efficiently protecting listed species from the millions of pounds of herbicides applied each year and reducing burdensome uncertainty for the farmers that use them.” However, EPA also notes that the strategy itself does not impose immediate requirements or restrictions on pesticide use. Instead, it ‘requires’ pesticide users to research and consider implementing possible and various mitigation options, depending on their geographical location and guidance available online, linked to pesticide labels.

EPA’s decision on glufosinate employs the Herbicide Strategy Framework to identify mitigation measures for potential impacts on endangered species—before completing the required formal consultation with the U.S. Fish and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS). This approach aims to streamline the process by addressing likely impacts in advance. However, advocates argue that this framework will certainly undermine ESA protections, as it relies on assumptions about species impacts without fully consulting USFWS and NMFS. They are concerned that the EPA’s preliminary mitigation measures may not fully address or protect endangered species due to the limited input from these agencies before the final consultation is complete.

Glufosinate mitigation requirements

EPA’s registration decision on glufosinate-P requires “the implementation of the following mitigation measures to address on- and off-field effects to nontarget species, including listed species:

• Prohibiting application during rainfall and when soils are saturated or above field capacity;
• Requiring users to visit EPA’s Mitigation Menu Website before application and determine an appropriate strategy for meeting or exceeding the required number of mitigation points as specified on the label;
• Maintaining a downwind buffer between the last spray row and the protection area of 50 feet for aerial application and 10 feet for ground application; and,
• Instructing users to access and follow any applicable endangered species bulletins for the two listed species–the Spring Creek bladderpod plant and the whorled sunflower plant–from ‘Bulletins Live! Two’ web-based system in English for all additional directions and restrictions.”

Advocates argue that EPA’s Framework has effectively substituted one problematic and insufficient process for another. Even once a mitigation requirement is identified after a new or renewed pesticide registration, compliance by a pesticide applicator, farmer, or worker operates under a “self-service, honor system,” relying on users to proactively seek information online and then simply consider mitigation steps from a still complex menu of possible choices. EPA notes: “The final strategy itself does not impose any requirements or restrictions on pesticide use. Rather, EPA will use the strategy to inform mitigations for new active ingredient registrations and registration review of conventional herbicides.”  Therefore, with this Framework, EPA does not appear to establish clear and specific use and site restrictions communicated through a pesticide label, which has historically been established as a set of enforceable legal restrictions under federal pesticide law.

Critics observe that EPA does not possess the scientific expertise, nor the statutory authority, to accurately determine the potential for “population level” impacts to “listed species.” They are obligated to rely on the USFWS and NMFS through a consultation process to make such assessments of the potential effects on species that inhabit such complex ecological systems. Therefore, any pesticide that has not gone through a complete ESA consultation cannot have been properly evaluated. (The Center for Biological Diversity argued this in its June 2024 comments.)

For example, there is a significant overlap (20-75%) between the habitats of some terrestrial invertebrate pollinators, such as bees and butterflies, and the areas where this pesticide is most likely to be employed. Moreover, L-glufosinate is considered “mobile” to “highly mobile” in soil and can reasonably be expected to be applied in areas of the U.S. with “high” runoff potential. Thus, the requirements of only a 50-foot buffer and one point of runoff mitigation are expected to be insufficiently protective. Migration of toxic chemicals into adjacent habitats could imperil not just listed plant species, but the habitats of listed animal species.

Beyond Pesticides and fellow changemakers—including organic and regenerative organic farmers and advocates—have long argued that the failure of EPA to consider the viability, productivity, and profitability of organic practices and product alternatives to conventional pesticides means the agency’s registration and reregistration of toxic pesticides, including glufosinate-P, have not been subject to a complete assessment. In this context and given the availability of less and nontoxic alternatives, EPA has failed in its responsibility to ensure that pesticides registered for use under FIFRA will not cause unreasonable adverse effects. In fact, EPA notes in an interim decision on glufosinate from 2016, “The (EPA) registration review program is intended to make sure that, as the ability to assess and reduce risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse effects.”

The planet is facing an urgent biodiversity crisis, with more species approaching extinction than ever before (see here and here). The purpose of ESA is to address this loss of biodiversity by protecting habitats critical to the survival of the most at-risk species. Pesticide use is a major driver of biodiversity decline, contributing to extinctions and elevating species’ vulnerability to environmental challenges such as climate change, habitat fragmentation, and exposure to toxic chemicals. To protect biodiversity, EPA is charged with examining how its decisions may exacerbate this crisis. Pesticides are a leading factor in the decline of insect populations and diversity, often referred to as the “insect apocalypse,” which threatens ecosystems across the planet. EPA’s approval of insecticides has posed risks to insect populations, while herbicides degrade insect habitats and food sources and pesticides disrupt food webs—in both freshwater and marine ecosystems (see here and here for Beyond Pesticides 2023 Forum session).

As industrial agriculture further reduces biodiversity by destroying or contaminating habitats, organic land management systems, in contrast, require producers to actively conserve and enhance biodiversity. Organic agriculture is a viable, productive option embraced by consumers and thriving as a $60 billion industry. This market success comes despite structural bias in USDA funding or programs, including the continued subsidization of conventional and monocrop agriculture through the Farm Bill in Congress. Consumers continue to make a difference by choosing to buy organic—reducing their own exposure to pesticide residues from conventional produce—and supporting organic farming, which protects not just consumers, but farmworkers and their families. Read more about agricultural justice and take action to support organic agriculture and strengthen organic certification here.

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

Sources: 

EPA Registers New Herbicide Active Ingredient Glufosinate-P, EPA website, October 18, 2024

EPA Finalizes First-of-its-Kind Strategy to Protect 900 Endangered Species from Herbicides, EPA announcement, August 20, 2024

Federal Register: EPA Announcement Glufosinate-P; Pesticide Tolerances, effective October 29, 2024, available under EPA-HQ-OPP-2020-0250 and EPA-HQ-OPP-2020-0533 

Comments to EPA on Proposed Decision to Register a New Enriched Isomer L-Glufosinate for Use on Conventional and Genetically Engineered Corn, Cotton, Canola and Soybean, The Center for Biological Diversity, June 8, 2024

Glufosinate-P. Human Health Risk Assessment for New Active Ingredient Isomer, EPA docket EPA-HQ-OPP-2020-0250-0027, May 8, 2024

Memorandum Supporting Proposed Decision to Approve Registration for the New Active Ingredient Isomer, Glufosinate-P, Memo EPA Office of Pesticide Programs, April 30, 2024

Threatened Biodiversity and Ecosystems, Pesticides and You, Beyond Pesticides, 2023-2024

(Beyond Pesticides, December 12, 2024) A literature review of 161 articles in Discover Toxicology finds that pesticides with different mechanisms of action cause memory and learning impairments. These effects are noted in nontarget species including humans. Pesticide “[e]xposure during development, as well as chronic environmental and occupational exposure, can contribute to decreased cognitive performance,” the researchers say. With a focus on organophosphate pesticides, synthetic pyrethroids, and neonicotinoid insecticides, the authors highlight neurological impacts.

Both learning and memory are crucial for the survival of many species. “Considering the importance of learning and memory for human and non-human animal behavior and the growing association between pesticide exposure and cognitive impairment, the aim of this review was to describe the studies showing the impact of pesticide exposure on memory and learning abilities in nontarget species, providing evidence of the impact of pesticides in central nervous system function,” the researchers state.

The 161 articles included in the review were identified through database searches in PubMed/Medline and Scielo. The authors note, “Inclusion criteria for article selection included all articles published in English between 2015 and 2024 containing original studies in animals or humans with single or multiple pesticides exposure.”

The articles consist of 132 preclinical studies involving animal models, most focusing on bees and rodents, and 29 human studies that assess occupational and environmental exposure. The researchers share that, “Regarding animal models, 58% of preclinical studies were conducted in rodents and 28% in bees, evidencing the lack of studies conducted in aquatic species, amphibians and other important animal models in ecotoxicological studies.” See related coverage on scientific deficiencies within Environmental Protection Agency (EPA) review processes here.

Preclinical Studies

Organophosphates

In the research, the majority of studies, related to organophosphates, assess the effects of exposure to chlorpyrifos, malathion, and diazinon and find that they cause damage to the learning and memory capacity in multiple species. The authors postulate that these effects of organophosphates on “[m]emory and learning deficits seem to involve mechanisms such as acetylcholinesterase and butyrylcholinesterase inhibition and oxidative stress.”

Notable studies include:

• In bees, chlorpyrifos leads to slower olfactory learning and memory.
• Many studies find that chlorpyrifos impairs spatial and recognition memory in mice (see here, here, here, here, and here), as well as spatial learning and memory in rats (see here, here, and here).
• Short-term exposure to malathion causes damage to spatial memory in mice. The offspring of exposed mice also exhibit decreases in memory and behavior.
• Malathion exposure in rats induces spatial learning and memory deficits through mechanisms involving oxidative stress and synaptic damage.
• Rats subjected to diazinon show impaired reference memory and deficient attentional accuracy, in addition to decreased aversive memory (see here and here).

Pyrethroids

As the researchers report, “Studies have shown that exposure to pyrethroids caused learning and memory deficits in rats and mice and was associated with the disruption of dopaminergic pathways, oxidative stress and hippocampal damage.” Additional studies reveal effects on pollinator species.

Notable studies include:

• Flumethrin exposure during the larval stage in honeybees affects memory-related behaviors and decreases the expression of memory-related genes. Long-term exposure also impacts olfactory learning and memory and causes downregulation of memory-related genes.
• Deltamethrin impairs learning and memory formation in honeybees with short-term exposure to sublethal concentrations.
• Mice treated with deltamethrin show impairments in spatial memory and memory retention, as well as learning deficits, hippocampal endoplasmic reticulum stress, and impaired hippocampal neurogenesis (see here and here).
• Rats exposed to deltamethrin exhibit mitochondrial dysfunction in the hippocampus and striatum, and impaired learning and reference memory. Studies also show impaired learning and spatial/working memory (see here, here, here, and here).
• Bifenthrin exposure in mice presents memory retention deficits.
• Exposure to permethrin during the prenatal and postnatal periods in mice causes impairments in learning and memory in adulthood.
• Treatment with lambda-cyhalothrin in mice shows a decrease in retention and learning memories.
• Developmental exposure to cypermethrin impairs spatial learning in young rats.
• Cyfluthrin affects the pathways in the hippocampus, which alters learning and memory in the offspring of exposed rats.

Neonicotinoids

Most studies of neonicotinoid insecticides in the review report harm to various species of bees. The authors find that, “Olfactory, associative and aversive learning, as well as memory capacity were affected by the exposure to several neonicotinoid insecticides, particularly imidacloprid. These sublethal effects can affect the behavioral performance of bees and consequently their pollination activity, impacting pollinator-dependent agricultural systems, in addition to the maintenance of ecosystems.” See “What the Science Shows on Biodiversity” for additional studies regarding pollinators.

Notable studies include:

• Bumblebees exposed to imidacloprid during brood or early adult development exhibit learning deficits in adulthood. Imidacloprid also causes impaired olfactory, associative, aversive, and motor learning in many bee species (see here, here, here, here, here, and here).
• Sublethal concentrations of imidacloprid also negatively affect learning and short-term memory in paper wasps.
• Imidacloprid causes a spatial memory disorder in Hipposideros terasensis bats (see here and here).
• Chronic exposure to clothianidin affects olfactory learning in honeybees and bumblebees, while acute exposure compromises short-term to mid-term memory and memory recovery in honeybees (see here and here).
• Thiamethoxam exposure in honeybees and bumblebees impairs visual and olfactory learning and presents learning delays and memory deficits.
• Rats exposed to thiacloprid display short-term working memory impairment, oxidative stress, and neuroinflammation.

Human Studies

Neurological effects in children and adults following pesticide exposure are heavily documented. Both chronic and acute exposure, even at low doses, can cause permanent damage to the brain, especially during critical periods of development. As the researchers report, “Learning and memory problems are not the only outcomes associated with early exposure to chemicals: intellectual disability, autism spectrum disorder, motor delays, attention problems, and others can have far-reaching effects on children’s educational success, socioemotional development, and quality of life.” See more on brain and nervous system disorders here.

While children are more susceptible to negative health effects from pesticide exposure due to their developing system and more limited ability to detoxify compounds, adults also experience many neurological impacts. Particularly affected are those who are subjected to pesticides during occupational activity including farmers and farmworkers. This disproportionate risk is associated with poorer memory and learning performance.

“Epidemiological studies have mostly reported the exposure of agricultural workers to organophosphate and carbamate pesticides, in addition to other pesticides used on crops. Long-term exposure to pesticides has been suggested to have long-lasting toxic effects on the central nervous system, and studies have recognized that chronic exposure is a possible risk factor for dementia and Alzheimer’s disease,” the authors say. (See studies here and here.) They continue, “In addition to cognitive deficits and neurodegenerative diseases, studies suggest a positive association between pesticide exposure and psychiatric conditions, such as depression, anxiety and suicide.”

Notable studies include:

• In 10-year-old children from a birth cohort in California, mothers living close to intensive applications of organophosphate and carbamate pesticides exhibit decreased cognitive function, such as in working memory.
• Children in Costa Rica living near banana plantations show neurodevelopment impairment. Specifically, children exposed to mancozeb have poorer verbal learning abilities, while exposure to chlorpyrifos is associated with poorer working memory.
• A study of Ecuadorian children observed an association between residential proximity to greenhouse agriculture and impaired cognitive performance.
• School-age children in rural areas of Colombia who experience environmental exposure to organophosphates, pyrethroids, and fungicides show decreased working memory index. Home usage of pesticides is also associated with a lower processing speed index.
• Organophosphate and carbamate pesticide exposure in Chile decreases cholinesterase activity and affects memory function in people living near plantations (see here and here).
• In Uganda, a cross-sectional study shows that overall pesticide exposure in farmers, specifically to glyphosate, is associated with impaired visual memory.
• Costa Rican farmers exposed to multiple pesticides with higher concentrations of insecticide biomarkers, including metabolites from chlorpyrifos and pyrethroids, display reduced prefrontal cortex activity during working memory tasks.
• After decades of occupational exposure, veterans show problems with concentration and memory as symptoms of Gulf War Illness (see studies here, here, and here as well as additional coverage on veterans here).

Organic as a Solution

The dependence on petrochemical pesticides and synthetic fertilizers leads to an increase in human exposure to toxic chemical compounds. Contamination of the environment, as well as residues in food and water, subjects nontarget organisms to chemicals that result in deleterious health effects. These pesticides also play a critical role in the current existential crises of public health, biodiversity, and climate change (see more here and here).

As an alternative, organic land management offers a path forward that mitigates these negative effects and promotes the health of all organisms and the environment. Learn more about the environmental and health benefits of organic, as well as how to buy organic products and grow your own organic food. Stay up to date with Daily News and sign up to receive Action of the Week and Weekly News Updates delivered straight to your inbox.

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

Source:

Honatel, K.F. et al. (2024) An update of the impact of pesticide exposure on memory and learning, Discover Toxicology. Available at: https://link.springer.com/article/10.1007/s44339-024-00011-9.

(Beyond Pesticides, December 11, 2024) A recent report published by the Research Institute of Organic Agriculture (FiBL) unpacks the impacts of new European Union (EU) organic regulations that are going into effect in 2025 with a “completely new set of rules for the certification of smallholder producer groups.” These regulations represent a major shift from the current “equivalence” to a “compliance” system with all EU legal requirements. The change announced almost three years ago, to provide time for transition, is intended to improve consumer trust in the organic label and eliminate a “patchwork of rules and derogations [exemptions] in place [that] did not give sufficient certainty and security” (European Commission 2017). The new EU Organic Regulation 2018/848 aims to encourage the sustainable development of organic production in the EU, guarantee fair competition for farmers and operators, prevent fraud and unfair practices, and improve consumer confidence in organic products.

According to the FiBL report, “The new EU Organic Regulation 2018/848 aims to encourage the sustainable development of organic production in the EU, guarantee fair competition for farmers and operators, prevent fraud and unfair practices, and improve consumer confidence in organic products.”

More than 7 in 10 organic producer groups globally will need to change their structure to maintain their certification, according to FiBL analysis. This EU regulation comes into effect within two years after the U.S. Department of Agriculture (USDA) published the Strengthening Organic Enforcement (SOE) final rule. (See Daily News here.)

Environmental and public health advocates welcome the improvement of organic regulations to strengthen the global marketplace and consumer trust in certified organic. However, advocates continue to demand reimagining the Farm Bill and agricultural support programs to, among other objectives, emphasize greater access for young, beginning, and farmers of color who face disproportionally significant barriers to entry. The National Young Farmers Coalition notes that Rural Prosperity and Food Security Act of 2024, advanced by retiring Senator Debbie Stabenow (D-MI) contains provisions center on “the needs of young and Black, Indigenous, and people of color (BIPOC) farmers and ranchers across the country . . .” 

Key Takeaways

Before moving forward, there are some terms that require definition for ease of future reference in this article. In EU Law, “third country” refers to a non-EU member country or a country where citizens do not have the right of free movement within the EU (Iceland, Lichtenstein, Norway, or Switzerland). “Control Bodies (CBs)” refer to organic regulators (e.g., third-party certifiers in the U.S. context) who oversee the certification process at the local, state/provincial, or national levels. “Global majority” refers to non-EU or U.S. peoples, not including First Nations, Aboriginal, and Indigenous peoples of the Americas, to account for historical power dynamics and counteract legacies of Western imperialism/colonialism in discussing policy language.

There are a few critical takeaways concerning the new EU-wide organic regulations listed below:

1. The shift to “compliance” versus “equivalence” for imported organic products into the European Union;
2. In spite of requests from organic and development associations in Global Majority countries to extend the exemption for “compliance systems” to December 31, 2025, the EU Commission set the end of the derogation period for October 15, 2025. This means that products not in “compliance” will not qualify for organic certification in Europe starting on October 16, 2025, even though “most certified organic producer groups in third countries are not yet fully aware of the potential non-compliance, the severity, and the resulting sanctions.”
3. New definitions and binding legal requirements, including “Group of Operators” and Internal Control System (ICS) requirements.
4. Third country organic producer groups consisting of smallholder farmers are facing a multitude of regulatory changes between 2023 and 2026, including the SOE 2023 update from the U.S. National Organic Program and the EU Regulation on Deforestation-free Products.
5. In surveys FiBL conducted with third country producer groups, 32% of respondents expect annual costs to increase by 50% to more than 100% and 43% of respondents expect certification costs to go up by 50% to over 200%. However, 82% plan to adapt to the new regulations.

Diving Deeper

EU organic policy was overhauled in 2018 and entered into force in January 2022. This change in certification standards is considered an extension of this legally binding legislation and goes into effect on January 1, 2025. The new regulations have far-reaching implications that vary based on commodity type, geographic region, and/or country of origin. See Chapters 5 through 7 of the report for more detailed analysis, including page 19 for a timeline of regulatory transition from equivalence to compliance models. See Figure 5: Transition from equivalence to compliance for imports from third countries (which are currently under third-country control body equivalence) on page 19 of the report.  

Group of Operators

According to the FiBL report, a new definition for “Group of Operators” (GoO) aims to “reduce the inspection and certification costs and the associated administrative burdens, strengthen, local networks, contribute to better market outlets, and ensure a level playing field…” for third country producers, particularly producers that make up the Global Majority.

The new definition for GoO can be found on page 21 of the FiBL report. Among other stipulations in the new regulation, a Group of Operators must have an ICS. IFOAM-International describes ICS as:

“[T]he part of a documented quality assurance system that allows an external certification body to delegate the periodic inspection of individual group members to an identified body or unit within the certified operator. This means that the third party certification bodies only have to inspect the well-functioning of the system, as well as to perform a few spot-check re-inspections of individual smallholders.”

There are other parameters to consider, including the fact that members of a GoO must be in the same geographic zone, have a “legal personality,” membership capped at 2,000 members, among others. Broadly speaking, there are three types of producer groups that will be affected by making ICS mandatory for EU organic certification: those who already have ICS built into their organization (group type I), processor/exporter organized groups (group type II), and groups with 100% external control without ICS (group type 3). More details on this are in Section 4.1.2 (pages 34-37) of the report.

Equivalence versus Compliance

Simply put, an “equivalence” system means that the organic certification standards in one country meet the same standards of countries to which they seek to export their products. The historical progression from “equivalence” to “compliance” systems can be found starting on page 17 of the report.

A different transition period applies to the fourteen countries with national organic certification systems that the EU recognizes through an equivalency agreement. The countries that qualify include Argentina, Australia, Canada, Costa Rica, India, Israel, Japan, New Zealand, Tunisia, the United States, as well as the United Kingdom, Switzerland, and Chile through trade agreements.

Compliance means that all organic imports must abide by all EU legal requirements In the past, internal control systems (ICSs) were considered a non-binding EU guideline for third country producer groups with the goal to “provide…a pathway towards sustainable production and income generation for an (estimated) thousand-plus organic smallholder supply chains in Latin America, Africa and Southeast Asia benefiting more than a million organic producers by granting them access to the European market via “equivalent” certification.”

There are some additional implications that will place short-term strain on organic producers in third countries, however the new regulation will provide substantial improvement in safeguarding organic integrity across the board. A shift to a compliance system “means that certain substances accepted in third countries under the ‘equivalence’ regime cannot be used anymore.” Additionally, there will be tighter requirements on producing the same crop organically and non-organically on the same farmland, crop rotation and diversity (e.g. legumes, cover crops, green manure for perennials, etc.), and documentation of potential contamination risks. These measures are welcomed by organic advocates; but concerns around equity and accessibility for hundreds of thousands of farmers who have to adjust rapidly to the new regulations—if they want to remain certified organic—continue.

There are 43 third country control bodies that are recognized for certification under the new “compliance” system as of October 31, 2024. Some control bodies have already decided to abandon third country certification under the new regulations (FiBL third country survey data corroborates this, with 18% of respondents indicating that may stop or reduce organic certification as a result of these new regulations). There are some potential policy remedies in place or that advocates are hoping to be put into effect in the coming transitional years. See Figure 5: Transition from equivalence to compliance for imports from third countries (which are currently under third-country control body equivalence) on page 19 of the report for further details on the transition for non-EU member states.

Main Recommendations

FiBL proposes the following main recommendations (in bold) to minimize negative short-term impacts of the new organic regulations, with additional Beyond Pesticide in italics:

• EU importers and brands should collaborate with small-scale and non-EU producers to consider their challenges and future costs in trade contracts and trading practices. This is particularly important given the ongoing tensions between farmers, environmentalists, and policymakers over the Mercosur-EU Trade Deal and the continuous importation of toxic pesticide products banned in Global North countries. See Daily News here, here, and here for further analysis.
• Development of tailored, “user-friendly” resources or handbooks relevant to small-scale producers to minimize confusion and increase compliance with new rules. Streamlining paperwork for U.S.-based small-scale organic producers has continuously been raised as a critical area of concern by organic advocates, researchers, and farmers. See Daily News here.
• Targeted training and support programs can support producer groups as they adapt to the new regulations, including but not limited to support and market access programs and legal advisory services, and development of regional-specific guidance. An IPES-Food report released earlier this summer highlights the impact of organic certification and producer group certification systems contributing to territorial markets across the globe. See Daily News here.
• Going one step further than the previous recommendation, certifying bodies and EU policymakers can offer regional-specific accommodations, including flexibility of this transition period in terms of temporary exemptions based on crop-by-crop, geographical, or allowable input/substances. In the U.S. context, organic operations come in different scales and models. More support is needed to support small-scale producers; however, some are banding together to increase their efficiency while upholding values. See Daily News here.
• Customs authorities can develop task forces for the 1-2 year transition period (2025-2027) to answer questions for producer groups as they navigate compliance with new regulations. Strengthening customs and import regulations is a critical feature of the U.S. SOE rule, among other updates. See Daily News here for further analysis.

Keeping Organic Strong in the United States

In the context of the U.S., FiBL does not believe that the new SOE rule, which went into effect as of March 2024, “are not likely to require legal adaptions in the setup or composition of currently NOP-certified producer groups. However, some new rules have additional certification implications for re-organization according to the Group of Operator rules since many groups are certified according to both [U.S. and EU] standards.”

The main changes in the Strengthening Organic Enforcement (SOE) rule include new requirements for certification of “grower group operations” for imported and exported organic products. New rules include the addition of unannounced on-site inspections for certified operations, standards certificates of organic operation, foreign conformity assessment systems, labeling of nonretail containers, annual update requirements for certified operations, compliance and appeals processes, and calculations for organic content of multi-ingredient products. Advocates applaud the improvement of organic standards in terms of compliance, oversight, and trade implications.

Beyond Pesticides will continue to monitor any additional repercussions or impacts that the EU regulations may impose on the U.S. organic community.

Call to Action

See Keeping Organic Strong to learn more about the history of U.S. organic regulations. As mandated in the Organic Food Production Act (OFPA), the National Organic Standards Board is required to hold public hearings twice a year for open comment periods on organic standards, including updates from subcommittees on a plethora of focus areas including the sunset of materials on the National List of Allowed and Prohibited Substances, equity and barriers to access organic certification, development of new regulations, among other areas.

Beyond Pesticides provides resources and comments for every measure brought up in the fall and spring meetings each year so communities across the nation can become more familiar with the process and demand integrity in organic products.

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

Source: The Research Institute of Organic Agriculture (FiBL)

(Beyond Pesticides, December 10, 2024) Scientists from the Engineering Research Center of Protection and Utilization of Plant Resources at Shenyang Agricultural University in China reveal adverse effects of imidacloprid on soil communities in a study published in Pesticide Biochemistry and Physiology. The researchers highlight risks to nematodes from imidacloprid exposure in maize soil, as well as potential resistance mechanisms that impact not only nematode populations but also overall soil health.

Maize, or corn, a productive crop grown worldwide, is a source of food and biofuel. In assessing the soil and species in maize fields after exposure to imidacloprid at various concentrations, the study researchers assess the impact of neonicotinoid insecticides on nontarget organisms and the health of soil communities. The assessment includes an evaluation of nematodes’ survival, growth, reproduction, and chemotaxis/locomotion behavior. With a statistical analysis of lipid and lipofuscin accumulation, acetylcholinesterase (an enzyme necessary for neurotransmission) activity, and gene expression levels, the study results show that imidacloprid induces:

• significantly reduced abundance and diversity of nematode species.
• negative effects on body length, reproduction, locomotion, lipid accumulation, lipofuscin accumulation, and acetylcholinesterase activity in Caenorhabditis elegans ( elegans).
• the upregulation of gpa-1, cyp-35a2, fat-2, fat-6, hsp-16.41, and hsp-16.2, along with the downregulation of ace-1, ace-2, and ace-3
• corresponding adaptive mechanisms and repellant behavior in nematodes.

The authors report, “[A]nalysis showed that the community richness index and community diversity index of soil nematodes in maize rhizospheric soil sprayed with imidacloprid were significantly lower than those from untreated soil. These results indicated that spraying with imidacloprid significantly reduced the number and diversity of soil nematodes in maize rhizospheric soil.”

Also of note, the relative abundance of two bacteria-feeding nematodes within the genera Prodesmodora and Oscheius is lower in soil exposed to imidacloprid. “Both bacterial- and fungal-feeding nematodes contribute to the mineralization of soil nutrients such as nitrogen, thereby facilitating plant growth,” the researchers say. Differing soil nematode community compositions between treated and untreated soils highlight the impacts of pesticides on beneficial nontarget organism populations.

The study finds body length and body width of C. elegans decrease with increasing concentrations of imidacloprid, as well as significantly reduced brood sizes in individuals exposed to imidacloprid. Locomotion behavior, due to basic nervous system functions, for nematodes is assessed through three actions, body bends, head thrashes, and pharyngeal pumping. After 24 hours of exposure to imidacloprid, the researchers note that the frequencies of all three behaviors were suppressed, confirming neurotoxicity to nematode species. Imidacloprid additionally inhibits lipid accumulation and acetylcholinesterase activity in nematodes while it increases lipofuscin accumulation that leads to intestinal damage.

Assessing gene expression in nematodes provides insight into how pesticides cause epigenetic modifications upon exposure. Genes can also play a key role in resistance mechanisms. “A growing number of studies have highlighted the development of imidacloprid resistance in insects,” the authors state. “In this study, the major metabolites, imidacloprid-guanidine and imidacloprid-urea, appeared after 24 hours’ treatment with imidacloprid… Imidacloprid-urea has been shown to reduce the harm of imidacloprid to nematodes by about half. As to imidacloprid-guanidine, it is the intermediate pathway for the conversion of imidacloprid-urea, and imidacloprid-guanidine has been shown to have no insecticidal properties in previous reports, therefore we believe that C. elegans could convert imidacloprid to imidacloprid-guanidine and imidacloprid-urea to reduce the toxicity of imidacloprid.”

In converting imidacloprid into its metabolites, nematodes show higher tolerance and experience less of the toxic effects. The enhanced expression of the cyp-35a2 gene, which is involved in resistance, as seen in C. elegans, also provides an effective defense against imidacloprid-induced damage. High expression of gpa-1 may also contribute to repelling imidacloprid. These results highlight how imidacloprid disrupts a series of physiological and biochemical indicators, as well as alters expression of genes associated with development, fat metabolism, and stress responses.

Impacts on soil biota following pesticide applications are well documented. Many nontarget organisms suffer negative impacts after exposure, such as with neonicotinoids and pollinators. While imidacloprid is primarily used to control sucking insects such as aphids, there is a wide body of science linking this pesticide to its effects on various beneficial nontarget organisms such as bees.

While impacts on nematodes are less studied, these organisms provide ecosystem services within the soil and act as an effective biological control. (See previous Daily News coverage here and here.) Healthy soil promotes biodiversity and supports numerous key ecosystem processes including decomposition and nutrient cycling.

“[T]he biodiversity present in soil makes a significant contribution to the agricultural productivity of the soil. Together with many other soil organisms, soil nematodes are crucial parts of the soil ecosystem,” the researchers share. “Nematodes, including the notorious plant-parasitic nematodes, are able to regulate the rhizospheric microbiota and drive soil microorganism community composition. Furthermore, nematode excrement has been found to contribute up to 19% of the soluble nitrogen in the soil. Therefore, their diverse ecological functions and intricate trophic positions make soil nematodes are good indicators of soil biodiversity.”

Imidacloprid and numerous other pesticides threaten critical soil communities and the needed balance in food webs. Whether as a spray or seed coating agent, imidacloprid is absorbed by plants and transported to various tissues. Residues of imidacloprid are found in the plant body and in the soil, which expose many beneficial nontarget organisms.

As an alternative, organic agriculture eliminates the use of toxic petrochemical pesticides and synthetic fertilizers that harm the environment and all the organisms it supports. In prioritizing soil health, organic land management methods mitigate against the crises of health, biodiversity, and climate change.

Learn more about the benefits of organic here and here. Join the organic solution by Eating with a Conscience and growing your own food or buying organic products. Stay informed through Beyond Pesticides’ resources. The Pesticide-Induced Diseases Database (PIDD) provides scientific literature on public health effects of exposure to pesticides and the Gateway on Pesticide Hazards and Safe Pest Management catalogs information on specific chemicals. Join Beyond Pesticides as a member today to add your voice to the urgent movement to eliminate fossil fuel-based pesticide use.

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

Source:

Zhang, J. et al. (2024) Interaction between imidacloprid residues in maize rhizospheric soil and soil nematode community, Pesticide Biochemistry and Physiology. Available at: https://www.sciencedirect.com/science/article/abs/pii/S0048357524004528.

(Beyond Pesticides, December 9, 2024) In recognition of the explosion of a chemical plant in Bhopal, India 40 years ago that was responsible for the death of 20,000 people, U.S. Representative Pramila Jayapal introduced H.Res. 1604, “Recognizing the 40th year since the 1984 Bhopal chemical disaster and helping to ensure that no other community suffers another chemical disaster, by supporting the designation of December 3 as National Chemical Disaster Awareness Day” and calling for support of survivors of the disaster and promoting public understanding of the dangers of chemical disasters.

The Union Carbide Corporation (UCC) plant explosion released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1,754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic disease range up to 95% of the affected population of 531,881. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. In spite of this history and the many adverse effects of these extremely toxic pesticides and their precursors, EPA continues to register pesticides without considering cradle-to-grave risks. 

>> Tell EPA that harm done in the manufacture, transportation, and disposal of pesticides must count as “unreasonable adverse effects.” Tell your Congressional Senators and Representative to support H.Res. 1604.

After Bhopal
Amnesty International has provided the following history and perspective:

“Shockingly, it is not only people exposed to the gas directly who have been affected. Over the years that followed, a large number of children born to gas-exposed parents have been affected by growth retardation, birth defects and other medical conditions. Meanwhile, to this day, thousands of tons of toxic waste remain buried in and around the abandoned plant. This has contaminated residents’ water supplies and harmed their health, adding to the already dismal health status of gas-exposed residents. As well as the health impacts, the tragedy has pushed already impoverished communities into further destitution. In many families, the main wage earner died or became too ill to work. Women and children suffered disproportionately.”

“An unfortunate second lesson of the Bhopal tragedy is how easy it has been for UCC to escape accountability. Pitted against the largely poor victims of the gas disaster was the hugely powerful and enormously rich multinational corporation, which escaped providing the survivors, their children and grandchildren with adequate compensation and medical care.

The catastrophic gas leak was the foreseeable result of innumerable operational failures at the plant, but from the start, UCC’s response to the disaster was inadequate and callous. For example, although thousands of people were dying from gas exposure, or suffering agonizing injuries, UCC withheld critical information regarding MIC’s toxicological properties, undermining the effectiveness of the medical response. To this day, UCC has failed to name any of the chemicals and reaction products that leaked along with MIC on that fateful night.”

“In 1989, without consulting Bhopal Gas Tragedy survivors, the Indian government and UCC reached an out-of-court compensation settlement for $470 million. This amount was less than 15 percent of the initial amount sought by the government, and far less than most estimates of the damage at the time. Thousands of claims were not registered at all, including those of gas-exposed children under the age of 18, and children born to gas-affected parents who, time later showed, were also severely affected.”

“There have been numerous attempts to hold UCC and individuals to account, either through criminal or civil claim proceedings launched in India and the U.S. But these have had no or very limited results.”

“One challenge has been created by the restructuring of the business entities involved in the tragedy. UCC sold off the India-registered subsidiary that operated the plant. It was then, in turn, bought by another giant U.S. corporation, the Dow Chemical Company (Dow). To this day, Dow shamefully claims it bears no responsibility since it “never owned or operated the plant” and that UCC only became a subsidiary of Dow 16 years after the accident.”

“In 2010, the Chief Judicial Magistrate’s Court in Bhopal found seven Indian nationals, as well as UCC’s India-based subsidiary guilty of causing death by negligence. By contrast, U.S. individuals and companies have escaped punishment, and there is significant evidence that the U.S. authorities have helped protect them.”

“Companies have a responsibility to respect human rights wherever they operate. Dow may not have caused the gas leak, but it became directly linked to the tragedy after it bought UCC. The company boasts of following the highest human rights standards, but its continued failure to respond to the urgent needs of the survivors is utterly disgraceful.”

“But there is a third lesson to draw from the Bhopal Gas Tragedy and its aftermath. It can be found in the inspiring story of the survivor groups and their supporters, who over 40 years have refused to give up their fight for justice. They have initiated or intervened in many legal actions; conducted scientific research into the contamination and health impacts; and they have launched practical initiatives in the absence of sufficient state and corporate support. For example, in 1994, survivor groups fundraised for the Sambhavna Trust Clinic and they later opened the Chingari Rehabilitation Centre. Thousands of gas- and contamination-affected adults and children have benefitted from the highly specialized and professional medical care and rehabilitation provided by these institutions – unparalleled by any of the government-run facilities.”

Continuing Chemical Accidents with Dependency on Petrochemicals
Less than a year after the Bhopal tragedy, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV. This time, at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA. A tank car ruptured, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River. Several hundred people were hospitalized after inhaling fumes. The chemical causes birth defects and fetal death and is a known mutagen, so the total impact on human health is unknown. However, the chemical sterilized a 41-mile stretch of the river, killing over a million fish and thousands of trees. Such events are not in the distant past, as shown by the derailment of about 50 out of 141 cars on the Norfolk Southern train that exploded in a towering fireball over the town of East Palestine, OH in February 2023. Among the compounds on board those cars were “inert” pesticide ingredients (vinyl chloride, ethylhexyl acrylate, and isobutylene), an antimicrobial compound (ethylene glycol monobutyl ether [EGBE]), benzene (a carcinogenic solvent), and butyl acrylate. In 2022, train accidents resulted in releases of hazardous chemicals 11 times. 

The incidents continue in 2024—including a chlorine leak from a fire at a BioLab facility near Atlanta, GA; hazardous materials released during the loading of a tractor-trailer at a hazardous waste processing facility in Coolidge, AZ that processes industrial wastes such as pesticides and other petrochemicals; and hundreds of facilities containing hazardous chemicals that were in the path of Hurricane Helene. 

These examples show that the harm caused by pesticides goes far beyond the impacts to consumers, farmworkers, other organisms, air, water, and soil caused by the application of those poisons, which are also extensive. We are all potentially affected. In some cases, the damages caused by use alone have been shown many times to be, in the words of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), “unreasonable adverse effects.”  

Organic growers know that soil biology and soil health are important to protect from diseases like citrus greening. The use of pesticides, on the other hand, destroys healthy soil biota. 

EPA must include the hazards of the manufacture, transportation, and disposal of pesticides in judging whether they pose “unreasonable adverse effects on the environment”—compared to the use of organic practices. 

>> Tell EPA that harm done in the manufacture, transportation, and disposal of pesticides must count as “unreasonable adverse effects.” Tell your Congressional Senators and Representative to support H.Res. 1604. 

Letter to the U.S. House of Representatives
I am writing to request that you cosponsor H.Res. 1604, “Recognizing the 40th year since the 1984 Bhopal chemical disaster and helping to ensure that no other community suffers another chemical disaster, by supporting the designation of December 3 as National Chemical Disaster Awareness Day,” introduced by U.S. Representative Pramila Jaypal. In addition to seeking governmental engagement with “the survivors of the Bhopal chemical disaster to strengthen the public’s understanding of the dangers of chemical disasters,” the Resolution calls for U.S. support of India’s requests regarding the Dow Chemical facility in Bhopal where the explosion occurred and take actions necessary to comply with obligations under the Treaty on Mutual Legal Assistance in Criminal Matters, signed at New Delhi on October 17, 2001.

Forty years ago this month, a Union Carbide plant in Bhopal, India released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic diseases range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. 

Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert” pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate. 

The incidents continue in 2024—including a chlorine leak from a fire at a BioLab facility near Atlanta, GA; hazardous materials released during the loading of a tractor-trailer at a hazardous waste processing facility in Coolidge, AZ that processes industrial wastes such as pesticides and other petrochemicals; and flooding of hundreds of facilities containing hazardous chemicals that were in the path of Hurricane Helene.

Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. 

Organic growers know that soil biology and soil health are important to protection from diseases like citrus greening. The use of aldicarb, on the other hand, destroys healthy soil biota.

Please ensure that EPA includes the hazards of the manufacture, transportation, and disposal of pesticides in judging whether they pose “unreasonable adverse effects on the environment”—compared to the use of organic practices. 

Again, please join with Rep. Jaypal in cosponsoring H.Res. 1604.

Thank you.

Letter to the U.S. Environmental Protection Agency
Forty years ago this month, a Union Carbide plant in Bhopal, India released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic diseases range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. 

Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert” pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate. 

The incidents continue in 2024—including a chlorine leak from a fire at a BioLab facility near Atlanta, GA; hazardous materials released during the loading of a tractor-trailer at a hazardous waste processing facility in Coolidge, AZ that processes industrial wastes such as pesticides and other petrochemicals; and flooding of hundreds of facilities containing hazardous chemicals that were in the path of Hurricane Helene.

Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. 

Organic growers know that soil biology and soil health are important to protection from diseases like citrus greening. The use of pesticides, on the other hand, destroys healthy soil biota.

EPA must include the hazards of the manufacture, transportation, and disposal of pesticides in judging whether they pose “unreasonable adverse effects on the environment”—compared to the use of organic practices.

Thank you.

(Beyond Pesticides, December 6, 2024) On December 2, the U.S. Environmental Protection Agency (EPA) announced yet another milestone in the convoluted life span of the insecticide chlorpyrifos. Under the deceptive headline “EPA Proposes Rule to Revoke Most Food Uses of the Insecticide Chlorpyrifos,” EPA stated that it is improving environmental protection by revoking all usages of chlorpyrifos except for 11 food and feed crops. The proposal was deemed “unconscionable” by Beyond Pesticides executive director Jay Feldman in an article in The New Lede.

EPA claims this plan would reduce annual chlorpyrifos application by 70% compared to “historical usage.” Chlorpyrifos is a known neurological and reproductive toxicant. EPA has been cutting back on approved uses for years but is far behind other environmental authorities—the European Food Safety Authority and Thailand have banned it altogether, and California has banned its agricultural use.

The trouble with EPA’s latest attempt is that it does nothing to clarify and rationalize EPA’s process, and it will not protect the public, because those 11 remaining products are among the most extensively grown and used in the world: soybeans, sugar beets, cotton, wheat, apples, citrus fruits, strawberries, alfalfa, cherries, peaches, and asparagus.

Chlorpyrifos is an organophosphate chemical. These compounds inhibit acetylcholinesterase (AChE), which regulates nerve signals in all invertebrates and vertebrates. Thus, there is no justification for the assumption that what harms insects will not harm humans. The lethal dose in newborn rats is 100 times lower than in adult animals. EPA has known for decades that chlorpyrifos (introduced in 1965) is a neurotoxicant, especially at crucial developmental stages, such as prenatal and infancy phases when the human brain is growing at its fastest rate. In 2016 EPA said children between one and two years old were being exposed via food to 14,000% of the risk concern level.

While AChE inhibition produces well-documented problems including attention and IQ deficits, lower birth weight, working memory loss, and motor development delays, there has also been evidence at least since the 1990s that chlorpyrifos also affects other neural pathways. For example, it can produce changes not just in the brain but in the digestive system.

The EPA’s new policy stems from decades of waffling and delay, in which industry influences sowed doubt about epidemiological evidence of health harms and emphasized uncertainties about data, particularly regarding drinking water exposure. Activists and agricultural workers, mostly in California, grew tired of waiting for health protections and filed suit against the EPA in 2007. It took until 2021 for the case to be decided by the Ninth Circuit Court of Appeals.

That court, frustrated by EPA’s indecisiveness and contradictions, ordered the agency to decide, within 60 days of its ruling, how toxic chlorpyrifos is and either revoke its food residue tolerances or declare that they are actually safe. In response, and to the surprise of the registrants and growers, EPA issued a final rule in August 2021, revoking all tolerances for chlorpyrifos. This upset the pesticide industry, which then backed a suit by growers’ associations in the Eighth Circuit Court of Appeals.

The Eighth Circuit reversed the Ninth Circuit’s decision in November 2023 and remanded the case back to the EPA for “further proceedings.” See our November 2023 Daily News analysis. In the Eighth Circuit case, plaintiffs emphasized how unreasonable the Ninth Circuit’s 60-day deadline appeared, despite the fact that the Ninth Circuit litigation had been dragging on for 14 years.

EPA’s most recent move is clearly the result of industry pressure. Interestingly, in light of recent political shifts, CropLife International’s (chemical industry’s trade group) 2022 amicus brief in the Eighth Circuit litigation argued that the EPA had failed to use its statutory authority properly—that is, a supposedly independent executive branch agency had the legal standing to make firm decisions based on its own expertise—an approach that does not comport with this year’s U.S. Supreme Court decision in Chevron v. Natural Resources Defense Council weakening this very authority.

There is a great deal of murkiness in EPA’s documents, which becomes nearly impenetrable in some of the agency documents issued after the Ninth Circuit case concluded. However, both cases focused heavily on two relatively clear EPA documents from 2016: the Chlorpyrifos Revised Human Health Risk Assessment for Registration Review and the Chlorpyrifos Refined Drinking Water Assessment for Registration Review. These two documents indicate firmly that EPA had serious worries about dietary exposures, which include both food and drinking water, for many years.

The Eighth Circuit plaintiffs tried to keep consideration of residues in food separate from drinking water exposures, even though the Ninth Circuit panel had noted that the Federal Food, Drug and Cosmetic Act requires considering food and water exposures together. EPA has previously explained its approach with a “risk cup” metaphor, saying “each use of the pesticide contributes a specific amount of…risk to the cup….[A]s long as the cup is not full, meaning that the combined total of all estimated sources of exposure to the pesticide has not reached 100% of the [tolerable daily exposure over a lifetime], EPA can consider registering additional uses and setting new tolerances. If it is shown that the risk cup is full, no new uses could be approved until the risk level is lowered.” In the Revised Human Health Risk Assessment, EPA stated that “this assessment indicates that dietary risks from food alone are of concern” and “after accounting for food exposures” there is no room for water in the risk cup. Moreover, based on model simulations, the Refined Drinking Water Assessment found that concentrations in drinking water might exceed 100 μg/L, an unsafe level. The World Health Organization’s 2022 guideline for a maximum level of chlorpyrifos in drinking water is 30 μg/L. Yet the Eighth Circuit plaintiffs repeatedly suggested that data about drinking water exposures was unreliable, convincing EPA to rely on water modeling data provided by registrants.

Trying to separate food from water exposure is bizarre because combined exposures affect everyone, and the people most exposed to chlorpyrifos—workers and other people living in agricultural areas—certainly must consume both food and water (like everyone else), and their regions certainly qualify as “vulnerable watersheds.”

EPA continues to insist that evidence of neurological damage remains inconclusive and that food and drinking water residues will require considerably more research before it can possibly decide what to do about chlorpyrifos. “With decisions like [this month’s] in the aggregate,” Mr. Feldman stated in The New Lede article, “The toxic load to people and the environment is unsustainable. The decision announced today reflects a failure of both the underlying law and a history of negotiations that fail to fully document the multidimensional catastrophic impact of pesticide use on health, biodiversity, and climate.” Beyond Pesticides advocates restoration of soil health and elimination of pesticides to cope with imbalances in biodiversity that lead to pest infestations. Organic regenerative agriculture is a far better way to reverse these declines, clean up water pollution, reduce antibiotic resistance, improve the nutritional value of food that has been degraded by synthetic pesticides and fertilizers, and support critical ecosystems that provide environmental services for the biosphere.

But the grip of chlorpyrifos is not yet loosened. According to EPA’s news release of December 2, the next step is for the agency to issue yet another amended Proposed Interim Registration Review Decision in 2026. In the meantime, advocates must continue to push back at the political winds threatening to derail environmental and health values altogether.

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

Sources:

EPA takes partial step to ban chlorpyrifos in a move called “unconscionable”
By Carey Gillam
The New Lede December 2, 2024
https://www.thenewlede.org/2024/12/epa-takes-partial-step-to-ban-chlorpyrifos-in-a-move-called-unconscionable/

EPA Proposes Rule to Revoke Most Food Uses of the Insecticide Chlorpyrifos
December 2, 2024
https://www.epa.gov/newsreleases/epa-proposes-rule-revoke-most-food-uses-insecticide-chlorpyrifos

Opinion
League of United Latin American Citizens et al. v. Michael S. Regan and USEPA
Ninth Circuit Court of Appeals
April 29, 2021
https://caselaw.findlaw.com/court/us-9th-circuit/2125208.html

Opinion and Order to vacate and remand
Red River Valley Beetgrowers et al v. Michael S. Regan and USEPA
Eighth Circuit Court of Appeals
November 2, 2023
https://caselaw.findlaw.com/court/us-8th-circuit/115405158.html

Chlorpyrifos: Revised Human Health Risk Assessment for Registration Review
USEPA November 3, 2016
https://downloads.regulations.gov/EPA-HQ-OPP-2015-0653-0454/content.pdf

Chlorpyrifos Refined Drinking Water Assessment for Registration Review
USEPA April 14, 2016
https://downloads.regulations.gov/EPA-HQ-OPP-2015-0653-0437/content.pdf

Celebrated 2021 Ag Ban of Deadly Pesticide, Chlorpyrifos, Reversed by Court Despite Decades of
Review and Litigation
Beyond Pesticides Nov 14, 2023
https://beyondpesticides.org/dailynewsblog/2023/11/2021-ag-ban-of-deadly-pesticide-chlorpyrifos-reversed-by-court-despite-decades-of-review-and-litigation/

Scientific Literature Review Again Links Pesticides to a Range of Illnesses and Ecological Decline
Beyond Pesticides, September 4, 2024
https://beyondpesticides.org/dailynewsblog/2024/09/scientific-literature-review-again-links-pesticides-to-a-range-of-illnesses-and-ecological-decline/

(Beyond Pesticides, December 5, 2024) A novel, comprehensive study published in Science reviews a library of 1,024 different chemicals (herbicides, insecticides, fungicides, and plant inhibitors) finding that, even at “sublethal” exposure levels, 57% of tested chemicals impact the behavioral and physiological health of house fly larvae. Mosquito and butterfly populations are also susceptible to long-term adverse effects at sublethal levels.

Environmental and public health advocates continue to raise concerns about adverse effects resulting from the failure of the U.S. Environmental Protection Agency (EPA) to consider cumulative exposure (resulting in aggregate and synergistic effects) across different mechanisms of toxicity and different classes of pesticides, including at exposure levels below allowable levels set by the agency.

In the context of the regulatory gaps and pesticide industry influence at EPA (See Daily News here), advocates stress the importance of transitioning land and agricultural practices to organic principles.

Methodology and Results 

Background, Goals, Primary Takeaways 

This research was led by an international team of experts from various universities and institutes, including European Molecular Biology Laboratory (EMBL), Institut Pasteur, and Heidelberg University (Center for Infectious Diseases, Parasitology Department). The authors received funding from the European Molecular Biology Laboratory, the German Center for Infection Research, and the American Society of Colon and Rectal Surgeons Research Foundation.

“[K]ey traits—such as egg-laying rates— were significantly reduced by some of these molecules at concentrations that are orders of magnitude below sublethal concentrations (),” says the researchers. “Higher temperatures also increased pesticide-induced lethality and behavioral changes (), which emphasizes the need for chemical testing under realistic environmental conditions, especially given rising global temperatures.” 

There are several additional notable findings that researchers cite for future study: 

• “Our findings highlight that many agrochemicals with high environmental prevalence can induce behavioral changes across insect species, even at sublethal levels.” 

• “Therefore, our findings suggest that the next generation of pesticides should be subjected to more comprehensive testing focused on sublethal effects across different representative species. Notably, these types of assays provide more precise data on how to target pest control for medically important vector species without negatively affecting overall insect biodiversity.” 

Drosophila larvae 

The main insect species of interest in the study was Drosophila melanogaster, acknowledged by researchers as “an insect model system for toxicology studies.” Drosophila was exposed to various chemical residue mixtures at several concentrations (2 mM, 20 mM, and 200 mM) to “assess the effects of these [chemical] molecules on larval behavior, physiology, and fitness.” Concentrations of 20 mM and 200 mM are expected for typical chemical-intensive farming operations, with the lowest concentration being the expected presence of the chemical in nature due to run-off.

To confirm the potential sublethal impacts of pesticides, researchers also tested the larvae with five pesticides at an even lower concentration (0.2 mM). While there was variability in the degree of acute harm caused by the chemicals of focus, researchers determine that “all pesticides significantly affected larval behavior at this lower concentration [of 0.2 mM].” The researchers in this study elaborate on the following conclusions: 

• “For example, glyphosate—a widely used herbicide across the world () that is not lethal at 0.2 mM ()—increased the frequency of turns (headcasting) and decreased stops, altering larval trajectories (). Only chlorpyrifos, the most toxic compound (), caused broad changes in protein levels. However, all but 1,2-dibromoethane altered the protein phosphorylation status in the treated larvae ()—including those that are not lethal at the concentration used ().” 

• “Although the developmental delay is within the expected variation among natural populations, the effect on egg laying goes beyond the physiological range measured in the above-described wild-type strains.” 

An additional area of concern that researchers identify is the heightened potential for damage of insects by pesticides. “[M]any pesticides that showed low lethality (<10%) at 25°C started exhibiting significantly higher lethality when the environmental temperature was increased by just four degrees,” the researchers provide an example. “For example, the insecticide lindane, nonlethal at 0.2 mM at 25°C (0%), became strongly lethal (79%) at 29°C. Although many molecules altered behaviors at 25°C, the changes at 29°C were often radically different.” 

The researchers also identified “nonlinear interactions” between a number of the targeted pesticides, “which suggests that synergistic pesticide interactions may be widespread.”

Mosquitoes and Butterflies 

The researchers extrapolate their findings beyond one type of house fly to include other “medically and economically relevant species,” including the mosquito Anopheles stephensi and the butterfly Vanessa cardui.

For testing adverse health impacts of pesticide exposure on mosquito populations, the researchers say, “[L]arvae were exposed overnight to varying concentrations of a neonicotinoid (thiacloprid), a pyrethroid (cyhalothrin), and a fungicide (dodine) on multiwell plates followed by recording and tracking their movement ().” “All pesticides caused larvae to move significantly slower at concentrations with negligible or low lethality (),” they continue. 

For testing the adverse health impacts of pesticide exposure on butterfly populations, caterpillars consumed food that contained traces of thiacloprid, cyhalothrin, and dodine. “Although only cyhalothrin showed some lethality (), all three molecules affected the movement patterns of the treated caterpillars (),” the researchers conclude.

“These results highlight that sublethal concentrations of pesticides can also affect the behavior of species with high ecological, economic, and clinical relevance.” 

Previous Daily News Coverage 

Environmental advocates concerned about biodiversity acknowledge the substantial, peer-reviewed scientific literature on ecosystem integrity under threat.  

A 2020 report published in Science determined that about one-quarter of the global insect population has died off since 1990. In 2022, researchers in the United Kingdom determined that “58.5% fewer flying insects” were caught on windshield wipers between 2004 and 2021, which they viewed as an indicator of systemic insect and pollinator deaths. In a 2019 study published in Biological Conservation, researchers identified “the dreadful state of insect biodiversity in the world, as almost half of the species are rapidly declining and a third are being threatened with extinction.”  

Scientists have spoken out, with over 70 scientists submitting a letter to the editor in Nature Ecology & Evolution in 2020 with a compilation of solutions necessary to curb the impending insect apocalypse. A research report in 2020 published in Nature by scientists at the University College London determined, among various findings, that the interaction between climate change () and high-intensity agriculture diminished total insect abundance by 50%, and species richness by 27%. See a review of recommended policies and practices to safeguard insect biodiversity published in Conservation Science and Practice. 

For more information on the link between petrochemical-pesticide reliance and insect die-offs, see the 2019 Pesticides and You report, Study Cites Insect Extinction and Ecological Collapse. Advocates nationwide have called upon Congress and EPA to update pesticide drift protection policy to protect families of farmworkers, schoolchildren, and other vulnerable subpopulations who face disproportionate harms of pesticide exposure. (See Action of the Week here).  

Call to Action 

Environmental and public health advocates, as well as farmers and fenceline communities, are concerned with the adverse health impacts of long-term pesticide use on their local environments.

“The loss of any insect species impacts overall biodiversity and upsets the balance of critical food webs,” says Sara Grantham, science, regulatory, and advocacy manager at Beyond Pesticides. “There is a wide body of science linking pesticide exposure to negative impacts on insects and other beneficial organisms, which are necessary in providing essential ecosystem services such as pollination. Population effects in these species threaten agricultural productivity and food security, as well as puts us one step closer to the very real threat of insect extinction.”

To access more peer-reviewed scientific literature on biodiversity issues, see the Pesticide-Induced Disease Database on biodiversity, beneficial insects, and pollinators. For more coverage and analysis of scientific literature and policy updates, see the Daily News section on biodiversity here. 

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

Source: Science 

(Beyond Pesticides, December 4, 2024) According to interviews conducted by Farm Progress, the U.S. organic food supply chain has been under pressure to come into compliance with the U.S. Department of Agriculture (USDA)’s March 19, 2024, Strengthening Organic Enforcement (SOE) final rule (See Daily News here). “We are now seeing up to 95 percent of NOP (National Organic Program) import certificates that are coming in are valid, which means that we really closed the gap on products coming into the United States without an import certificate,” says Jennifer Tucker, PhD, deputy administrator for USDA National Organic Program (NOP). “We really closed the door on illegitimate shipments.”

Organic advocates welcome accountability measures to ensure the integrity of organic certification in the spirit of continuous improvement, which is regarded as a tenet of the Organic Food Production Act (OFPA). As communities and businesses across the country anticipate a change in decision-making philosophy regarding the role of federal intervention in the marketplace, environmental and public health advocates remain clear-eyed on the importance of improving the regulatory system to advance public health, biodiversity, and climate.

Concerns Raised by Organic Supply Chain

The National Organic Coalition, with member groups including Beyond Pesticides, summarizes the five core changes that the SOE rule establishes for organic standards:

1. “Regulatory changes to require import certificates and additional handling operations to become certified.
2. Codification of the requirement that certifiers conduct unannounced inspections for a minimum of 5% of the operations they certify annually.
3. Consistent implementation of existing and additional record-keeping requirements for operations and certification agencies to ensure traceability.
4. A requirement that certifiers conduct supply chain audits for high-risk operations.
5. Requirements for certified operations to develop fraud prevention plans.”

According to reporting, farmers, certifiers, and other members of the organic supply chain are expressing concern at the rollout of the new regulations with its associated requirements. Farmers have voiced concerns about the significant amount of work hours that have to be allocated to prepare for implementation of SOE to ensure that they are up to code operating as part of complex, international supply chains. At the same time, organic certifiers are raising their fees for certification to cover the cost of additional training and staff time, given the increase in frequency and depth of inspections. In preparation for the SOE rule going into effect, NOP offered additional educational resources through its Organic Integrity Learning Center. Additionally, there has been a doubling of NOP staff since 2017 when high-profile instances of organic fraud emerged in the marketplace. See Daily News here for an analysis of some of these fraud claims, investigations, and legal consequences.

Strengthening Organic Enforcement Rule

The new requirements in the final SOE rule aim to strengthen the integrity of the organic label through enhanced oversight and enforcement of existing program regulations, and the introduction of new requirements to address occurrences of fraud in organic supply chains. As the Agricultural Marketing Service (AMS) lays out in a 2023 announcement, the rule is expansive in covering a range of regulatory topics, including:

• “[A]pplicability of the regulations and exemptions from organic certification;
• National Organic Program Import Certificates;
• recordkeeping and product traceability;
• certifying agent personnel qualifications and training;
• standardized certificates of organic operation;
• unannounced on-site inspections of certified operations;
• oversight of certification activities;
• foreign conformity assessment systems;
• certification of producer group operations;
• labeling of nonretail containers;
• annual update requirements for certified operations;
• compliance and appeals processes; and
• calculating organic content of multi-ingredient products.”

The Federal Register notice of the SOE asserts that the rulemaking is designed to “strengthen oversight and enforcement of the production, handling, and sale of organic agricultural products.” It continues, “The amendments protect integrity in the organic supply chain and build consumer and industry trust in the USDA organic label by strengthening organic control systems, improving farm-to-market traceability, and providing robust enforcement of the USDA organic regulations.” Reporting by The Washington Post notes, “Key updates to the rules include requiring certification of more of the businesses, such as brokers and traders, at critical links in organic supply chains. It also requires organic certificates for all organic imports and increases inspections and reporting requirements of certified operations.”

First, all members of the supply chain are now required to have certification (including brokers, exporters, and traders, among others), although there are also additional exemptions for certain “low-risk activities” including facilities that have minimal responsibilities, such as processing and packaging goods.

Second, all certified organic products imported into the U.S. must be declared to U.S. Customs and Border Patrol using data from NOP Import Certificates. Certifiers rely on these certificates, housed within the NOP Organic Integrity Database (INTEGRITY), to track compliance.

Third, each member of the supply chain must maintain records and establish fraud prevention plans to ensure there are zero gaps in accountability.

Fourth, non-retail containers (a.k.a containers that store organic products before entering a retail or purchasing location) must have the organic seal to ensure accountability.

Fifth, digital organic certifications entered into the INTEGRITY system must have a standardized format and data fields to ensure standardized compliance.

Sixth, the definition change from grower groups to “producer group operations,” when accounting for imports of organic products from groups of individual producers who decide to export to the U.S. as a collective unit, is intended to standardize the quality of organic products in non-U.S. and European Union contexts. This includes the addition of a requirement that these farmer groups must incorporate binding internal control systems (ICSs) as a fixture of their operational structures. IFOAM-International describes ICSs as:

“[T]he part of a documented quality assurance system that allows an external certification body to delegate the periodic inspection of individual group members to an identified body or unit within the certified operator. This means that the third party certification bodies only have to inspect the well-functioning of the system, as well as to perform a few spot-check re-inspections of individual smallholders.”

Advocates view this shift to strengthening definitions and binding force of internal control systems as an opportunity to strengthen organic integrity and ensure long-term smooth adoption across different cultural and market contexts. There will be a future Daily News delving into changes in EU and U.S. laws going into 2025 on definitions around internal control systems (ICSs) and producer groups.

Seventh, organic inspectors will now be required to conduct unannounced on-site inspections of at least 5% of all operations they certify each year; they will also need to engage in “traceability audits.”

See deeper analysis by SCS Global Services, an international third-party certification entity, here. See here for a comparative guideline for regulations pre- and post-SOE developed by the Agricultural Marketing Service.

Call to Action

Organic advocates are concerned that the burdens imposed on organic farmers through high certification costs, as well as upfront expenses that come with transitioning and maintaining organic land management systems including soil testing, training, and marketing/transportation, should not fall on farmers. “Organic farming should be a public good that is treated as such through federal agricultural support programs in the Farm Bill,” says Max Sano, organic program associate at Beyond Pesticides.

See Action of the Week, Tell Congress to ensure that organic programs, and their funding, do not lapse this fall, to inform your elected officials what is at stake.

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

Source: Farm Progress

(Beyond Pesticides, December 3, 2024) In an article in Science, Sabrina Rondeau, PhD reviews her research from 2022-2024 showcasing species of ground-nesting bees, often found in crop fields, that are highly vulnerable to soil pesticide residues and subsequently suffer population declines. Dr. Rondeau, a postdoctoral fellow in the Department of Biology at the University of Ottawa, points to regulatory deficiencies, specifically in environmental risk assessments (ERAs), and the detrimental effects of pesticides on pollinators that threaten food security and biodiversity.

“Modern intensive agriculture faces a critical paradox: The very pesticides designed to protect our crops endanger essential pollinators that sustain their productivity,” Dr. Rondeau says in the article. Her research (see here, here, here, here, here, and here) identifies important gaps overlooked in current assessments and regulations for bee species, including the common eastern bumble bee (Bombus impatiens) and the hoary squash bee (Xenoglossa pruinosa). Bumble bee queens in temperate climates hibernate for 6-9 months in the soil, while the hoary squash bee is a solitary ground-nesting species. Reference additional Daily News coverage on ground-nesting bees here and here.

“‘Our findings show that over 70% of wild bee species, which are crucial for pollinating our food crops, face significant risks from pesticide residues in soil—a threat current regulations overlook,’ says Dr. Rondeau” in a news release. See additional coverage on soil pesticide residues here, here, and here.

In reflecting on one study, Dr. Rondeau shares, “I generated the first field exposure estimates for overwintering bumble bee queens to pesticide residues in agricultural soils. I identified high risks of exposure to multiple pesticide residues for bumble bee queens that overwinter in agricultural soils in eastern Canada, especially in apple orchards. Orchard soils at suitable overwintering sites contained mixtures of up to 29 pesticides, and 95% of samples contained at least one insecticide, herbicide, and fungicide.” This study highlights the extent to which ground-dwelling bee species can be exposed to a multitude of pesticides.

In this experiment, “newly emerged bumble bee queens were offered numerous boxes of soil treated with different pesticides, alongside untreated soil, within large mesh-covered enclosures.” The bumble bee queens “were seemingly attracted to pesticide-contaminated soils. This apparent preference increases their likelihood of exposure to and potential risk from pesticide residues while they overwinter underground,” Dr. Rondeau states.

In another study, size-dependent effects are noted for bumble bee queens exposed in soil applied with the broad spectrum insecticide cyantraniliprole. The results indicate that queens that are heavier exhibit increased mortality, delayed brood emergence, and smaller offspring. Dr. Rondeau concludes that, “These larger queens likely face greater vulnerability to cyantraniliprole because of their greater muscle mass (cyantraniliprole disrupts insect muscle function), greater surface area in contact with soil, and lower metabolic detoxification capacity. My findings suggest that cyantraniliprole impairs heavier queens’ ability to feed their brood and highlight potential cascading impacts on bumble bee populations, as larger queen size is key to successful overwintering and colony establishment in the spring.”

Lastly, female squash bees show reduced pollen collection with fungicide exposure to a product containing azoxystrobin and difenoconazole, while coexposure to the insecticide flupyradifurone with the fungicide “synergistically induced hyperactivity and reduced the number of offspring that emerged from each nest,” Dr. Rondeau states. “These results highlight potentially serious consequences for squash bees,” she concludes, noting that “reduced offspring production per nest due to pesticide coexposure could contribute to population declines.”

ERAs are meant to assess agrochemicals, leading to regulatory approval for only those that pose low environmental risks. Yet, there is a wide body of science that highlights adverse effects on critical pollinator species from pesticides on the market. Current ERAs fail to adequately protect these organisms, as they rely on studies with specific model species to reflect the risks for all species. The U.S. Environmental Protection Agency (EPA) primarily focuses on the western honey bee (Apis mellifera), the differing exposure and subsequent effects experienced by other species are disregarded.

“[W]hereas most of the world’s 20,000+ bee species are solitary, honeybees live in large colonies that benefit from social detoxification strategies, which buffer pesticide impacts,” Dr. Rondeau says. She continues, “Failures to detect and document pesticide impacts on wild bees arise from multiple other deficiencies, which include incomplete consideration of potential long-term and sublethal effects, overlooked exposure routes specific to wild bees, and failures to account for possible coexposure to multiple pesticides.” See more on EPA failures here, here, here, and here.

A wider range of bee taxa needs to be considered in risk assessments to better protect all vital pollinators. As previously covered by Beyond Pesticides, pesticide sensitivity varies greatly between species. Relying on a single species to determine risks to all bees is negligent on the part of regulatory agencies. What is considered “low toxicity” for one species can be highly lethal for another.

As an alternative to harmful petrochemical pesticides, methods for crop protection can consider pollinator preservation, which in turn protects food security and biodiversity, by employing strategies for organic land management. As Dr. Rondeau states, “My research reveals a clear potential for ground-dwelling bees to be affected by field-realistic (co)exposure to soil pesticide residues. These findings urgently call for a reassessment of global pesticide regulations to create a safer, more sustainable agricultural future that protects both our crops and the pollinators they rely on.”

Organic agriculture is the solution that not only eliminates exposure to toxic synthetic pesticides for pollinators, including ground-nesting bees, but it also supports soil health and the health of all organisms, including humans. In previous coverage, Beyond Pesticides reports how researchers find that organic farming provides the highest benefit to bees, as organic practices lead directly to lower parasite load and higher colony growth.

See more on the benefits of organic land management here, as well as options for least-toxic control of pests with ManageSafe™. Make The Safer Choice to avoid hazardous home, garden, community, and food use pesticides, and learn about Eating with a Conscience by choosing organic food to protect health and the environment.

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

Source:

Rondeau, S. (2024) Digging below the surface: Hidden risks for ground-nesting bees, Science. Available at: https://www.science.org/doi/10.1126/science.adt8998.

(Beyond Pesticides, December 2, 2024) An international team of researchers has found that organic farming increases the quantity and diversity of crop plant microbiota, further safeguarding crops with enhanced pathogen resistance. Their recent study, published in Plants, People, Planet, builds on the legacy of decades of peer-reviewed research and centuries of agricultural systems that do not rely on toxic, petrochemical-based products (e.g., fertilizers, pesticides, etc.) as the driving force for agricultural productivity. As many analysts express concern that the incoming administration will increase the promotion of petrochemicals in domestic food production and eschew regulations to curtail their use, organic advocates and farmers remain committed to transforming agricultural and land management systems that reject chemical dependency, which is escalating the existential threats to biodiversity, public health, and the climate.

Goals, Methodology, and Background

The authors of this study are researchers at Université de Rennes, Université de Paris-Saclay, L’Institut Agro Rennes-Angers, European Society for Agronomy, France’s National Research for Agriculture (INRAE), and Nanjing Agricultural University in Nanjing, Jiangsu, China. The goal of this study was to compare the effects of organic with chemical-intensive agricultural plots on microbial life on winter wheat roots. Winter wheat was selected because of the projected increase in global demand and consumer interest in wheat products that are grown in environmentally responsible systems. The authors tested the four following hypotheses:

1. “[O]rganic farming changes microbial community composition and species interactions and results in more diverse microbial assemblages than conventional farming ();
2. [T]his effect is related to changes in management practices, soil properties, and/or plant diversity ();
3. [C]hanges in microbiota affect host plant reproduction and resistance to pathogens (); [and]
4. We expected responses to be more pronounced in May than in March due to the effects of the different farming systems during plant development that would increase divergences in microbiota composition.”

The researchers conducted this study on forty winter wheat fields at “Zone Atelier Armorique,” also known as the Long-Term Socio-Ecological Research (LTSER) site in north-western France. Twenty of the fields are organically managed and the other twenty are not. The environmental and agronomic data includes surveys of the land management practices, soil, and plant and cultivar types. The bacterial and fungal microbiota were sampled from “six individual wheat plants in each field (40 fields) at two dates (mid-March—vegetative stage and the end of May—early reproductive stage of wheat).” Each sampling campaign, March and May, evaluated 240 samples. Wheat fitness is measured by the plant samples’ reproductive capacity and pathogen resistance, which was pulled from the 240 samples gathered in May, at which point they “had all completed their reproductive phase.” The authors state, “We then calculated the mean total number of seeds per field as the mean number of seeds of the six individual wheat plants [gathered from each field.]”

“All the analyses were performed in 35 fields for fungi; in 34 fields for bacteria in March and in 29 fields for bacteria in May because information concerning agricultural management was lacking for three fields out of 40, and insufficient description of bacteria and fungi microbiota for one field out of 40 for bacteria in March; and for five fields out of 40 for bacteria in May. Consequently, only fields for which all variables were available were included in the analyses,” says the researchers. The bacteria tested in this study include Acidobacteria, Actinobacteria, Bacteroidetes, Firmicutes, Alphaproteobacteria, Deltaproteobacteria, and Gammaproteobacteria. Meanwhile, the fungi analyzed in this study include Ascomycota, Basidiomycota, Chytridiomycota, Glomeromycotina, and Zygomycota.

Results and Discussion

The researchers analyzed the effects of agricultural management practices, soil characteristics, and plant diversity on bacterial and fungal entities independent of one another before analyzing them in full. The bottom-line argument: “The present study provides a better understanding of the effect of organic farming on plant-associated microbiota and stresses the importance of soil characteristics and management in shaping microbiota composition and diversity. It also highlights the fact that plant seed production and resistance to pathogens are related with particular microbial assemblages. More specifically, Alphaproteobacteria and Glomeromycotina were seen to be key phyla in mediating wheat fitness, while also responding to environmental parameters.” In this study, Glomeromycotina has a statistically significantly higher degree of richness in organic fields in both March and May.

The researchers also found that the most significant richness of all bacteria and fungi is identified in organically managed farmland relative to conventional fields in the month of May. Soil properties, including carbon, nitrogen, pH level, organic matter content, and proportion of clay and coarse silt, do influence the bacteria and fungi composition of all fields regardless of when sampled.

“The positive effect of organic farming on microbial diversity was more pronounced in May than in March for both fungi and bacteria, while an early effect on bacterial composition was detected in March,” say the researchers. This is one of the study’s main conclusions,  which they attribute in part to “the cumulative effect of phytosanitary products and nitrogen inputs during crop growth.”

“Indeed, under organic farming, no phytosanitary products are used on wheat, and nitrogen inputs are lower despite the use of organic manure () (). In all responding phyla, as expected, increasing nitrogen and phytosanitary inputs had a detrimental effect on species richness and shaped sequence-cluster composition (),” the researchers explain as the beneficial impacts of the low-to-zero input approach of organic farming systems.

Organic Farming as a Driver of Soil Health

There are numerous peer-reviewed studies highlighting the importance of organic farming practices and methods for biodiversity at all scales, from microbial to planetary health.

A 2024 study published in Agriculture, Ecosystems, and Environment finds the perpetual use of pesticide-coated seeds and tillage changed the composition of various beetle, spider, and other epigeal arthropod communities on New Hampshire farmland. In Rodale Institute’s landmark Farming Systems Trial – the longest-running, multidecade investigation comparing organic and chemical-intensive grain production in North American farmland – researchers arrived at the following outcomes (See Daily News here.):

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

Researchers at Kansas State University corroborate some of the findings determined by Rodale Institute in a 2024 study published in Soil Science Society of America Journal, finding direct evidence that organic amendments (e.g., manure and compost) in a no-till agricultural system “facilitat[e] microbial diversity” that cycles plant-available nutrients. Organic banana production in Martinique are found to have 55% higher mean plant species richness and 79% greater soil weed cover in organic fields, according to a 2024 study published in Applied Soil Ecology. In the same study, the presence of earthworms, macrofauna, and other decomposers was much higher in organic fields, indicating the enhanced microbial life in organic farming systems. For additional Daily News coverage on soil microbial health and organic practices, see here, here, here, and here.

Call to Action

See the Action of the Week, Tell U.S. Department of Agriculture (USDA) to Expand Organic Dairy Product Promotion (ODPP) Program to All-Organic Lunches, to demand USDA and Congress mandate organic dairy products in the National School Lunch Program given the recent $15 million investment in ODPP through the Commodity Credit Corporation.

See Keeping Organic Strong to learn about the variety of issues that arise at statutorily mandated, biannual National Organic Standards Board (NOSB) meetings. Beyond Pesticides submits comments on all issues before the NOSB, and includes on our website guidance for the general public on engaging in the public input process to ensure the integrity of organic standards, as well as vital add-on labels such as Real Organic Project and Regenerative Organic Certified (Regenerative Organic Alliance).

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

Source: Plants, People, Planet

(Beyond Pesticides, November 27 – December 1, 2024) This Thanksgiving, as we navigate a new chapter in our nation’s history, the staff and board of Beyond Pesticides are honored and thankful to partner with and support those leading campaigns, from small to large, that are essential to our livable future. Local communities are where change happens, creating examples of practical solutions for the nation and world.  

• We believe deeply in the power of people and organizations, armed with scientific information and models for change, to push for the adoption of organic practices and policies—from local to global—that ensure that we, and our children, will have the future we envision and are working to achieve. 

• We recognize the difficult work of changing the status quo—dependency on practices and products that harm people and contaminate the ecosystems on which life depends—in the face of existential health, biodiversity, and climate crises. 

• We know that the critical importance of elevating diverse voices—from scientists, advocates, victims of chemical exposure, those disproportionately affected, land managers and practitioners, to responsible corporations calling for the urgent phaseout of petrochemical pesticides and fertilizers—to the prevention of catastrophic collapse of the natural systems that sustain life. 

From the opportunity to join together with inspiring leaders this fall during the Forum, to partnering with dozens of communities across the country to see our organic land management projects come to life in parks, playing fields, and open and public spaces, our appreciation of local changemakers who seek to protect the earth through their tireless efforts to advance the organic solution in their local communities cannot be overstated.  

In this spirit, we celebrate for a second year a Thanksgiving Address and prayer (the Ohèn:ton Karihwatéhkwen) of the Haudenosaunee (also known as the Iroquois Confederacy or Six Nations—Mohawk, Oneida, Cayuga, Onondaga, Seneca, and Tuscarora) that reflects their relationship to the Earth by giving thanks for life and the world around them. It is a prayer that is appropriate at any time, but especially on a holiday celebrating the abundance of the Earth’s gifts. 

Translated more literally, Ohèn:ton Karihwatéhkwen is “what we say before we do anything important.”  

As you read this prayer, please choose actions to protect our relationship with the natural world and her inhabitants. Beyond Pesticides thanks all of you for your support! 

The People  

Today we have gathered and we see that the cycles of life continue. We have been given the duty to live in balance and harmony with each other and all living things. So now, we bring our minds together as one as we give greetings and thanks to each other as people.  

Now our minds are one.  

The Earth Mother  

We are all thankful to our Mother, the Earth, for she gives us all that we need for life. She supports our feet as we walk about upon her. It gives us joy that she continues to care for us as she has from the beginning of time. To our mother, we send greetings and thanks.  

Now our minds are one. 

The Waters  

We give thanks to all the waters of the world for quenching our thirst and providing us with strength. Water is life. We know its power in many forms- waterfalls and rain, mists and streams, rivers and oceans. With one mind, we send greetings and thanks to the spirit of Water.  

Now our minds are one.  

The Fish  

We turn our minds to all the Fish life in the water. They were instructed to cleanse and purify the water. They also give themselves to us as food. We are grateful that we can still find pure water. So, we turn now to the Fish and send our greetings and thanks.  

Now our minds are one.  

The Plants  

Now we turn toward the vast fields of Plant life. As far as the eye can see, the Plants grow, working many wonders. They sustain many life forms. With our minds gathered together, we give thanks and look forward to seeing Plant life for many generations to come.  

Now our minds are one. 

The Food Plants  

With one mind, we turn to honor and thank all the Food Plants we harvest from the garden. Since the beginning of time, the grains, vegetables, beans, and berries have helped the people survive. Many other living things draw strength from them too. We gather all the Plant Foods together as one and send them a greeting of thanks.  

Now our minds are one.  

The Medicine Herbs  

Now we turn to all the Medicine herbs of the world. From the beginning they were instructed to take away sickness. They are always waiting and ready to heal us. We are happy there are still among us those special few who remember how to use these plants for healing. With one mind, we send greetings and thanks to the Medicines and to the keepers of the Medicines.  

Now our minds are one.  

The Animals  

We gather our minds together to send greetings and thanks to all the Animal life in the world. They have many things to teach us as people. We are honored by them when they give up their lives so we may use their bodies as food for our people. We see them near our homes and in the deep forests. We are glad they are still here and we hope that it will always be so.  

Now our minds are one. 

The Trees  

We now turn our thoughts to the Trees. The Earth has many families of Trees who have their own instructions and uses. Some provide us with shelter and shade, others with fruit, beauty and other useful things. Many people of the world use a Tree as a symbol of peace and strength. With one mind, we greet and thank the Tree life.  

Now our minds are one.  

The Birds  

We put our minds together as one and thank all the Birds who move and fly about over our heads. The Creator gave them beautiful songs. Each day they remind us to enjoy and appreciate life. The Eagle was chosen to be their leader. To all the Birds-from the smallest to the largest-we send our joyful greetings and thanks.  

Now our minds are one.  

The Four Winds  

We are all thankful to the powers we know as the Four Winds. We hear their voices in the moving air as they refresh us and purify the air we breathe. They help us to bring the change of seasons. From the four directions they come, bringing us messages and giving us strength. With one mind, we send our greetings and thanks to the Four Winds.  

Now our minds are one.  

Virtually every aspect of our lives and that which sustains us are shared—the air we breathe, the water we drink, the parks where we walk and our children play, the biodiversity that nurtures life, and the intricate balance of nature (plus, the beauty and amazement it offers us).

Beyond the shared Thanksgiving meal, this holiday season is an opportunity to explore shared thinking and action on what we can do together with our families, communities, elected and local governmental officials, health care providers, teachers, and farmers—how we can work to build this universal organic solution even when we hear rhetoric that denies the urgency of the existential threats.

We are working for holistic change in food production and land management—from farms to homes, gardens, parks, playing fields, and schools. We are building on a foundation for this change that we helped create. And now, we are taking this work to the next level, calling for and working toward the universal adoption of organic practices in communities and on farms.

Our team trusts that we share this vision for a sustainable future with you. Please consider a donation to Beyond Pesticides this holiday season. Your support is of tremendous value and deeply appreciated! 

Please consider a gift on our secure website at bp-dc.org/give2024. Your support of any size makes a tremendous difference! *Now featuring Apple Pay on our contribution page!

➡️ Click here to read a personal Thanksgiving message from Jay Feldman, executive director!

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

Art page highlight! Our thanks to Margaret from Orlando, Florida for sharing her photo, “Appalachian Ridge (Green Mountain, NC).”

(Beyond Pesticides, November 26, 2024) A study in Environment International finds that young children who exhibit higher levels of pesticide metabolites in their urine show more pronounced neurobehavioral problems at the age of ten. Researchers in China document how exposure during early childhood, especially during the sensitive window before the age of two, is linked to hyperactivity/inattention problems such as attention deficit hyperactivity disorder (ADHD).

While adding to the body of science connecting pesticide exposure to learning and developmental disorders, this study offers a “novel perspective on characterizing the fluctuation in repeated measurements of multiple environmental chemicals and identifying the potential critical windows,” the authors share. (See previous Daily News coverage here, here, and here.)

The researchers analyze data from questionnaires and urine samples through the ongoing Sheyang Mini Birth Cohort Study (SMBCS), which is a long-term prospective cohort study that associates environmental chemical exposure during pregnancy and childhood to negative health effects. This data addresses combined pesticide exposures in young children with neurobehavior analyses at the age of ten to determine any correlation.

Within the SMBCS, a total of 1303 pregnant women are enrolled. When the children reached ages one, two, three, six, seven, eight, nine, and ten years old, each mother–child pair participated in follow-up visits. During these visits, urine samples were collected and analyzed for pesticide metabolites including pentachlorophenol (PCP), 3,5,6-Trichloro-2-pyridinol (TCPy), and carbofuran phenol (CFP). These represent different classes of pesticides: organochlorines, organophosphates, and carbamates, respectively.

A “Strengths and Difficulties Questionnaire” was utilized that covered “various behavioral domains including emotional symptoms, conduct problems, hyperactivity/inattention, peer relationship problems, and prosocial behavior,” the authors share. They continue, “ADHD symptoms were assessed using the ADHD Criteria of Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (ADHD-DSM-IV) rating scale.”

Complete samples and questionnaires were available for 415 children within SMBCS and are included in this study. In assessing children between ages one to ten, the researchers segmented the data into three phases including infancy and toddlerhood (ages one to two), preschool age (ages three to seven), and early school age (ages eight to ten) to track the periodic changes in trajectories and the stages of children’s growth and development within those phases.

The hyperactivity/inattention scores from questionnaires are significantly positively correlated and showed significant differences among the three childhood phases. The detection rates of the three metabolites (PCP, TCPy, and CFP) in all urine samples collected during the follow-up visits ranged from 95.2% to 100% and were significantly positively correlated in each childhood phase.

The most significantly elevated scores were identified for the group with higher levels of metabolites occurring during infancy and toddlerhood. These results reveal “significant positive associations between pesticide exposure during early life (1∼2 years) and hyperactivity/inattention symptom in 10-year-old children,” the researchers report. They continue, “[I]ndividuals with higher urinary concentrations of the three pesticide metabolites during infancy and toddlerhood (1∼2 years) had elevated hyperactivity/inattention scores compared to those with continuously low exposures (1∼10 years) and those with higher exposure levels during pre-school age (3∼7 years).”

These results highlight that early childhood, especially before the age of two, represents a critical window regarding neurobehavioral developmental effects of pesticide exposure. This is explained by the combination of children’s weak pesticide metabolism capabilities and high brain plasticity before two years of age. Prior research supports that exposure at a young age, and even during gestation, can cause developmental delays and disorders. (See here, here, here, and here.)

Since children are rapidly growing and developing, they are particularly susceptible to the adverse health effects of pesticides and are disproportionately at risk. “The timing of pesticide exposure is crucial in determining the neurotic damage inflicted, as children’s metabolic function and the growth rates of the nervous system change with age,” the researchers note. “In particular, the period of early childhood is deemed critical for the prefrontal cortex (PFC), implicated in various psychiatric disorders such as ADHD, to establish the foundational neural circuitry essential for higher cognitive functions in later life. Thus, early experiences, including early-life environmental exposure, may shape the trajectories of the PFC and have lasting implications for behavioral regulation throughout life.”

As the authors state, “Children require more attention in risk assessment than adults due to their unique exposure patterns and special susceptibilities to pesticides, which may occur at different stages of development. They may encounter pesticides through multiple routes, either simultaneously or sequentially. For instance, newborns and infants may ingest pesticides via breast milk contamination. Young children, who often engage in exploratory behaviors, are more prone to accumulating pesticides settled in dust and soil while playing and crawling, leading to increased non-dietary ingestion through frequent hand-to-mouth contact. In addition, children generally breathe more air, drink more water, and consume more food than adults by body weight, resulting in higher doses at the same environment contamination level.”

Chemical exposure at an early age increases the body burden of harmful toxicants, many of which can stay in the body for a lifetime, and escalates the risk for certain diseases such as cancer and Parkinson’s disease. Learn more about the hazards of pesticides for children’s health and how “Children and Pesticides Don’t Mix.”

With multiple routes of exposure, reducing children’s exposure to harmful chemicals is critical. By adopting organic land management strategies, this exposure can be mitigated. Beyond Pesticides promotes healthy environments for learning and recreation for children. Alternatives are available for schools and for creating sustainable parks that do not unnecessarily put children’s health at risk. Make The Safer Choice to avoid hazardous home, garden, community, and food use pesticides to protect children as they grow and develop.

There are serious long-term health implications for children and youth exposed to the toxic soup of pesticide and chemical residues found in conventionally grown food. Take action to tell your U.S. Representative and Senators to cosponsor S. 5084, which increases the funding available for schools to purchase safe school meals and expands funding for the Organic Certification Cost-Share Program to compensate organic farmers.

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

Source:

Ding, J. et al. (2024) Identifying childhood pesticide exposure trajectories and critical window associated with behavioral problems at 10 years of age: Findings from SMBCS, Environment International. Available at: https://www.sciencedirect.com/science/article/pii/S0160412024006652.

(Beyond Pesticides, November 25, 2024) When the U.S. Department of Agriculture (USDA) announced at the end of October a $15 million program to expand access to organic dairy products in schools, it added funds to an agency effort underway that is intended to support and incentivize farmers to grow organic and make organic food more widely available. While the millions being invested is a fraction of what organic advocates say is necessary, Congress and USDA have established a framework that recognizes the need to address the current health, biodiversity, and climate crises with accelerated adoption of organic. The issue now is whether organic will garner the support necessary to meet the life-sustaining challenges in the next Farm Bill, which may not be taken up until the next Congress is sworn in and the new administration is inaugurated.

The U.S commitment to organic has been building since the adoption of the Agricultural Productivity Act in 1983, which established the Low Input Sustainable Agriculture program (later becoming the Sustainable Agriculture Research and Education (SARE) program) at USDA, and then the passage of the Organic Foods Production Act in 1990. However, among the articles published on the subject, research reported in Environmental Science & Technology (2022) asserts that use of synthetic chemicals are now exceeding planetary boundary, “the point at which human-made changes to the Earth push it outside the stable environment of the last 10,000 years.“ In this context, the universal adoption of organic practices has become an urgent necessity, with Congressional, administration, and private sector support at the highest level.

In its brochure Making the Transition to Organic Production and Handling, USDA states the following:

“Organic agriculture uses cultural, biological, and mechanical practices that support the cycling of on-farm resources, promote ecological balance, and conserve biodiversity. Conservation practices are typically bundled into a conservation system to maintain or enhance soil and water quality as well as conserve wetlands, grasslands, forests, and wildlife habitats. Avoiding the use of synthetic fertilizers, sewage sludge, irradiation, and genetic engineering are paramount to organic farming.”

USDA has identified organic agriculture as climate-smart, recognizing that organic soil management practices sequester atmospheric carbon while eliminating the need for synthetic nitrogen fertilizers that reduce greenhouse gas emissions.

Beyond this, USDA describes what it has been doing to support the growth of organic as a niche market, without the goals necessary to eliminate petrochemical pesticide and fertilizer use and production:

“USDA has made significant investments in organic agriculture, including through its Organic Transition Initiative (OTI), a $300 million investment that delivers wrap-around technical assistance to producers interested in transitioning to organic. The initiative includes mentoring and advice, direct farmer assistance through conservation financial assistance, and targeted organic market development grants. Among OTI’s comprehensive suite of programs is the Organic Market Development Grant (OMDG) program which has, with the final awards announced in August, provided $85 million for 107 projects around the country. OMDG is supporting the development of new and existing organic markets to increase the consumption of domestic organic agricultural products. Another component, the Transition to Organic Partnership Program (TOPP), supports farmers transitioning to organic by connecting them with mentors, providing community building, technical assistance, workforce development, and helping producers overcome challenges during and following certification. Additionally, USDA’s Natural Resources Conservation Service (NRCS) supports conservation practices required for organic certification and leverages partnerships to expand relationships within the organic community. NRCS and its partners offer field days, workshops, and one-on-one technical assistance to producers working to meet organic standards. OTI is a part of the USDA food system transformation initiative to support local and regional food systems, expand access to markets for more producers, and increase the affordable food supply for more Americans while promoting climate-smart agriculture and ensuring equity for all producers.” 

The steps being taken are important but do not match the threat, according to Beyond Pesticides. Small and important steps, as welcomed as they are by advocates, are not viewed as expediting the transition to organic as a national priority.

>> Thank USDA for expanding access to organic dairy in schools. Tell USDA and Congress that kids deserve all-organic school lunches.

The $15 million is a drop in the bucket compared to the $17.2 billion that USDA spent on the school lunch program in 2023 to provide low-cost or free lunches to children in public and nonprofit private schools (grades pre-kindergarten–12) and residential childcare institutions. However, any support for organic food in schools leads to greater health for growing minds and bodies, and schools should be serving our nation’s children meals that are wholly supportive of human and planetary health.  

There are serious long-term health implications for children and youth exposed to the toxic soup of pesticide and chemical residues found in food grown in chemical-intensive practices. Research published in Environmental Pollution in 2022 identified children with higher levels of certain pesticide metabolites are more likely to go through early puberty. The American Academy of Pediatrics concludes in a study published this year that the proliferation of antimicrobial-resistant infections, resulting from overreliance on antibiotics in animal agriculture leads to potentially severe health risks for infants and children. Additionally, a 2024 study, published in Environment International finds 60 biomarkers of pollutants and pesticides in hair analyses of children throughout France, which highlights the global crisis resulting from the inadequate regulation of toxic chemicals. Despite the known health impacts of pesticide exposure, Congress may end up removing 200-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields depending on how Farm Bill negotiations move forward, according to an analysis by Environmental Working Group.  

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

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

In September, U.S. Senator Cory Booker (D-NJ) introduced S. 5084, Safe School Meals Act (SSMA), identifying four objectives: 

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

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

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

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

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

>> Thank USDA for expanding access to organic dairy in schools. Tell USDA and Congress that kids deserve all-organic school lunches.

Letter to Congress
The U.S. Department of Agriculture announced that it is allocating $15 million to the Organic Dairy Product Promotion Program to expand access to organic dairy products in schools. The program will be funded by the Commodity Credit Corporation, with the goal of increasing consumption of organic dairy products among children and young adults while creating new opportunities for small and mid-sized organic dairy producers. $15 million is a drop in the bucket compared to the total of $17.2 billion that USDA’s school lunch program spent in 2023. School meals should be a child’s safest source of nourishment, not another source of toxic exposure, so they should be made up of organic food.

In September, Sen. Cory Booker introduced S. 5084, Safe School Meals Act, to:

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

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

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

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

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

The serious long-term health implications for children exposed to pesticide and chemical residues found in food grown in chemical-intensive agriculture include early puberty and the proliferation of antimicrobial-resistant infections resulting from overreliance on antibiotics in animal agriculture.

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

1. 5084 also expands funding for the Organic Cost-Share Program to fully compensate farmers for certification costs and increases the funding available for schools to purchase safe school meals. Supporters of the bill include a broad spectrum of educational, health, environmental, and organic advocates.

I urge you to support S. 5084 and to direct USDA to require organic food in school lunches it underwrites.

Thank you.

Letter to USDA
Thank you for expanding access to organic dairy products in schools by allocating $15 million to the Organic Dairy Product Promotion Program for that purpose. However, $15 million is a drop in the bucket compared to the total of $17.2 billion that USDA’s school lunch program spent in 2023. School meals should be a child’s safest source of nourishment, not another source of toxic exposure, so they should be made up of organic food.

EPA has still failed to advance the protections for children mandated by the Food Quality Protection Act, passed in 1996. In 2020, FDA acknowledged that half of food samples tested by the agency have toxic pesticide residues and one in ten samples have levels that violate legal limits established by EPA. Consumer Reports recently updated its analysis of pesticide residues in various common grocery store products, finding that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day.

The serious long-term health implications for children and youth exposed to pesticide and chemical residues found in food grown in chemical-intensive agriculture include early puberty and the proliferation of anti-microbial resistant infections resulting from overreliance on antibiotics in animal agriculture.

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

I urge you to require organic food in school lunches.

Thank you.

(Beyond Pesticides, November 22, 2024) With numerous campaigns at the state and federal level to ban the weed killer paraquat and nearly 6,000 individual lawsuits alleging exposure to it causes Parkinson’s disease (PD), U.S. Senator Cory Booker (D-NJ) and six Senators on October 31 called on the U.S. Environmental Protection Agency (EPA) to ban the chemical. Citing that “[f]armworkers and rural residents are disproportionately exposed to paraquat,” the Senators’ letter to EPA stating that, “Paraquat has been linked to Parkinson’s disease, thyroid cancer, and other health harms such as kidney, liver, and respiratory damage, and reproductive harm, including neurodevelopmental impact on developing fetuses [and] [i]n rural areas, exposure to paraquat and other pesticides during pregnancy can increase the risk of leukemia.”

Most of the 6,000 cases against paraquat’s manufacturer, Syngenta, have been consolidated into Multi-District Litigation (MDL) in the U.S. District Court for the Southern District of Illinois. In April, the MDL judge ousted the plaintiffs’ expert witness regarding causality, which resulted in the first five cases ready for trial being tossed out. The defendant sells paraquat globally and is doing everything it can, according to investigative news reports, to discredit any link between paraquat and Parkinson’s, including the use of misdirection, disinformation, and character assassination.

A series of recent news reports have collectively dissected Syngenta’s malfeasance—and its power. These investigations include an October 2024 report by Evy Lewis of Investigate Midwest; a June 2023 report by Carey Gillam at The New Lede, including its documents archive; The Guardian’s October 2022 expose by Gillam and Aliya Uteuova; a March 2021 report by Crispin Dowler and Laurent Gaberell of Greenpeace’s Unearthed; and U.S. Right to Know’s series on paraquat.

See also Beyond Pesticides’ coverage of paraquat health hazards, regulation, and litigation, as well as our work on conflicts of interest in science, attacks on scientists such as Tyrone Hayes, PhD, and industry influence on federal agencies.

The MDL expert witness conflict is a perfect example of industry’s self-protective gyrations. The plaintiffs’ sole causation expert was Martin Wells, PhD, a Cornell University statistician and epidemiologist. Dr. Wells found in a meta-analysis that, in study participants occupationally exposed to paraquat, the incidence of Parkinson’s nearly tripled. The court found that Dr. Wells’ work was methodologically suspect and that, since his analysis was not generally accepted by his peers, he must be isolated from the scientific community—a marker of unreliability, according to a legal backgrounder by the conservative Washington Legal Foundation. Judges have wide latitude to determine the “reliability” of expert testimony under the “Daubert Standard.”

About 10 million pounds of paraquat a year are used in the U.S., mostly to control weeds in soy, corn, cotton, peanuts, almonds, grapes, and other crops. No residential use is approved, and more than 60 countries have banned paraquat. Concern has been mounting for decades based on its extreme acute toxicity and accumulating evidence of its neurological hazards even in lower chronic exposures. In July 2021, EPA conducted a reregistration review and decided to leave paraquat on the market with further restrictions, saying “the Agency concluded that the weight of evidence was insufficient to link paraquat exposure from pesticidal use of U.S. registered products to PD in humans.” Its most recent action, taken only under pressure from environmental groups, is to reexamine paraquat’s toxicity with results due in 2025.

But paraquat’s life is much longer than the suits filed in 2021 and afterward, as is the knowledge that paraquat damages the nervous system of animals. In a breathtaking example of scientific malpractice, the company that discovered paraquat’s herbicidal talents in 1955—Imperial Chemical Industries (ICI)—simply declared, as was also done in the case of the herbicide glyphosate, that something that kills plants would have no effect on animals. (Syngenta, the successor to ICI, is now owned by Sinochem, a Chinese state-owned company.) The industry has known for decades that paraquat kills plants via oxidative stress, a process common to bacteria, fungi, and animals as well.

The history of pesticides lays bare the mistake made by governments to leave scientific research to the entities that would be profiting from the product. Despite the assertion of no harm to animals, an ICI scientist wrote in an internal 1958 memo that dipyridyl, an active ingredient in paraquat (which is marketed in the U.S. as Gramoxone), had “moderate toxicity mainly by affecting the central nervous system” and could be absorbed through the skin. Hypocrisy is a powerful political tool.

The art of character assassination is well developed at Syngenta. Ray Dorsey, MD is a neurologist known for his proposal, analyzed by Beyond Pesticides here, that two types of Parkinson’s may be the same disease caused by chemical exposures moving through different body systems to the brain. Dorsey was dragged into the MDL by Syngenta in a bizarre and intrusive attempt at discrediting him.

Dr. Dorsey had declined to be an expert witness, but Syngenta served him with a discovery subpoena to produce documents used to prepare a co-written opinion piece in Movement Disorders, a publication of the International Parkinson and Movement Disorder Society. The piece asserted that paraquat causes Parkinson’s. Dr. Dorsey cited Syngenta’s half-century campaign to suppress evidence of paraquat’s neurological effects. He called Syngenta’s behavior “agnotology,” or “the deliberate production of ignorance.” His discussion was based on the The Guardian investigation. Syngenta attacked Dr. Dorsey simply because his opinion piece, supported by scientific evidence and investigative journalism, had attracted a lot of public attention. Apparently, Syngenta considered this unfair. The court sided with Dr. Dorsey. But Syngenta still won the skirmish in convincing the court to exclude Dr. Wells, leaving the defendants without a causation expert.

The Guardian exposé also revealed Syngenta’s extensive character assassination of neurotoxicologist Deborah Cory-Slechta, PhD, whose research has shown that paraquat crosses the blood-brain barrier and, when inhaled, travels up the nose to the olfactory bulb, whence it is distributed throughout the brain. But Syngenta knew paraquat reached the brain much earlier and might have lingering effects there. According to Investigate Midwest, “In 2008, Syngenta internally re-evaluated paraquat’s safety. In its report, it listed several ‘major sources of uncertainty,’ including the question of how long paraquat remained in the brain and the possibility the braincell death caused by paraquat exposure could progress even without further exposure.”

All these actions recall Syngenta’s scurrilous attacks on Tyrone Hayes, PhD, the University of California Berkeley researcher who demonstrated atrazine’s endocrine-disrupting effects. As detailed in a 2014 New Yorker article by Rachel Aviv, Syngenta went so far in the late 1990s to spread the rumor that Dr. Hayes was mentally unstable. Eventually, the company mounted an all-out and largely successful (at least temporarily) destruction of Dr. Hayes’ academic and public reputations. See Beyond Pesticides Daily News analyzing the Hayes case and Syngenta’s misinformation campaign against a class action suit. Dr. Hayes delivered the keynote speech at Beyond Pesticides’ 31^st National Pesticide Forum.

EPA focuses only on toxicological tests provided by the manufacturer, which are outmoded and fail to capture the real effects of pesticides on the biosphere. Standard tests usually do not include examination of brain tissue in animal models except to assess developmental effects in offspring. Thus, Syngenta has been able to ignore evidence such as that cited in the Investigate Midwest story in which a Japanese woman died of paraquat poisoning in 1968 and an autopsy subsequently found paraquat in her brain. An ICI doctor wrote that the levels found were “rather higher than we would have expected, particularly in the brain, considering the relatively small quantity that was taken.”

The Guardian investigation cited the case of a farmworker showing degenerative changes in the brain after paraquat exposure. And in an especially scurrilous attack, a completely unqualified columnist at the American Council on Science and Health, an industry-supported group, wrote last year that the MDL cases are unfounded because “paraquat probably can’t cross the blood-brain barrier efficiently enough to cause the neurological damage at the root of PD.” His statement is based on a 2021 “review of reviews” in NeuroToxicology by Douglas Weed, MD, PhD, a consultant who has worked with industry partisans to deny glyphosate’s carcinogenicity.

According to Investigate Midwest, both EPA and Syngenta have argued that animal studies on paraquat do not apply to workers using paraquat because the animal studies involve injecting huge amounts into the animals and humans are more likely to inhale, lick their lips, or have dermal exposure, “usually in very small quantities.”

The logic of toxicology testing is incredibly skewed. This argument shows that the EPA test requirements are tailored to acute exposures, not chronic ones. It also assumes inhalation is not a relevant exposure route, which is completely inaccurate. Further, one has to ask why, if the high-dose tests are irrelevant, they are being used to decide whether human health effects are plausible. In fact, in the Wells ruling, the MDL judge noted that both parties had warned against relying on animal studies to determine human causes of health effects. At the same time, however, the industry relies on arguments that denigrate human epidemiology as unreliable. The end result is the neutralization of the only methods available to enlighten the issue. Why the court does not recognize this double-dealing is unclear, especially given that evidence produced in the litigation—easily available to the judge—demonstrates how much deception and personal attack Syngenta and other pesticide companies routinely engage in.

In the words of a 2006 Lancet commentary on developmental toxicology by environmental health experts Philippe Grandjean, MD, and Philip Landrigan, MD, “The two main impediments to prevention of neurodevelopmental deficits of chemical origin are the great gaps in testing chemicals for developmental neurotoxicity and the high level of proof required for regulation.” Eighteen years later these obstacles remain. Syngenta’s concerted disinformation, deceptive science, and character assassinations are still working. Citizen pressure must force EPA to bring its regulatory practices into alignment with modern, ethical, and transparent science. Courts would likely then follow suit.

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

Sources:

Syngenta spent decades attempting to quiet health concerns about its profitable herbicide
by Evy Lewis, Investigate Midwest
October 23, 2024
https://investigatemidwest.org/2024/10/23/herbicide-paraquat-sygenta-legal-troubles-parkinsons-disease-health-claims-lawsuits

The Paraquat Papers: How Syngenta’s bad science helped keep the world’s deadliest weedkiller on the market
by Crispin Dowler and Laurent Gaberell
Greenpeace Unearthed
March 24, 2021
https://unearthed.greenpeace.org/2021/03/24/paraquat-papers-syngenta-toxic-pesticide-gramoxone/
details international paraquat overdose problems and syngenta’s refusal to include an adequate emetic in its formulations

Syngenta’s “SWAT” team- Internal files reveal secret strategies to influence science
by Carey Gillam
The New Lede
https://www.thenewlede.org/2023/06/syngentas-swat-team-internal-files-reveal-secret-strategies-to-influence-science/

Assault on Science what is getting in the way of using science to protect health and the environment?
Beyond Pesticides – Pesticides and You, Winter 2017–2018
https://www.beyondpesticides.org/assets/media/documents/infoservices/pesticidesandyou/documents/TyroneHayesProtectingLife.pdf

Beyond Pesticides Urges Ban of Weed Killer Paraquat Using Same Criteria Used in the Landmark Dacthal Ban
Beyond Pesticides, October 1, 2024
https://beyondpesticides.org/dailynewsblog/2024/10/beyond-pesticides-urges-ban-of-weed-killer-paraquat-using-same-criteria-used-in-the-landmark-dacthal-ban/

Biden EPA Reapproves Paraquat with Weaker Protections than Trump Administration Proposed
Beyond Pesticides, August 10, 2021
https://beyondpesticides.org/dailynewsblog/2021/08/biden-epa-reapproves-paraquat-with-weaker-protections-than-trump-administration-proposed/

California Bill Would Ban Deadly Weedkiller, Paraquat, Linked to Parkinson’s Disease in Face of EPA Inaction
Beyond Pesticides, April 16, 2024
https://beyondpesticides.org/dailynewsblog/2024/04/california-bill-would-ban-deadly-weedkiller-paraquat-linked-to-parkinsons-disease-in-face-of-epa-inaction/

Parkinson’s Disease Explodes as Researchers Find Connection to Pesticide Exposure and Genes
Beyond Pesticides, May 3, 2024
https://beyondpesticides.org/dailynewsblog/2024/05/parkinsons-disease-explodes-as-researchers-find-connection-to-pesticide-exposure-and-genes/

Research Links Parkinson’s and Lewy Body Disease with Chemical Effects on Brain and Gut
Beyond Pesticides, April 19, 2024
https://beyondpesticides.org/dailynewsblog/2024/04/research-links-parkinsons-and-lewy-body-disease-with-chemical-effects-on-brain-and-gut/

Uncertain Harvest: Examining the globe-spanning relationship of chemical companies, academics and regulators, and the powerful toxins and genetically modified seeds used to grow food in many parts of the world.
Scientists Loved and Loathed by an Agrochemical Giant
by Danny Hakim
New York Times, December 31, 2016
https://www.nytimes.com/2016/12/31/business/scientists-loved-and-loathed-by-syngenta-an-agrochemical-giant.html

New Report Showcases Atrazine Manufacturer’s Efforts to Discredit Critics
Beyond Pesticides, June 21, 2013
https://beyondpesticides.org/dailynewsblog/2013/06/new-report-showcases-atrazine-manufacturers-efforts-to-discredit-critics/

(Beyond Pesticides, November 21, 2024) Be it Patagonia Provisions or Brooklyn Brewery, there is a buzz around organic beer that is increasingly evident given interest by brewing and food companies. The expansion of the organic beer market in the United States would not have been possible without the leadership of advocates, farmers, breweries, and the National Organic Standards Board (NOSB), which led to the strengthening of organic standards for beer back in 2010. The growth of this sector and transition to truly organic beer speaks to the spirit of “continuous improvement,” the original design of the Organic Foods Production Act (OFPA), and the importance of mobilizing the public to engage in the public input process that continues to keep organic law strong in opposition to those seeking an easier path to the organic label.

Continuous Improvement and Organic Hops

In the original drafting of OFPA, advocates came together to determine how to encourage the development of certified organic sectors despite the lack of available, verifiable organic inputs for many products—beer included. With this spirit in mind, the improvement of standards for beer encapsulates the significance of OFPA in the context of its flexibility, incentives, and the statutory intent to encourage public input to strengthen the integrity of organic standards. This oversight process—with public, organic grower, and scientific input, and the authority of the stakeholders (environmentalists, consumers, growers, retailers, certifiers, and scientists) on the NOSB to manage the allowed substances in organic production and processing—operationalizes the underlying principle of continuous improvement in the law. Nonorganic ingredients, up to five percent of total product ingredients, are allowed in products labeled organic with the showing that these ingredients are not “commercially available.” This allowance was intended by the drafters of the law to incentivize innovation, development of environmentally sensitive materials, and expansion of organic production by those seeking a market opportunity for organically produced ingredients. In the spirit of continuous improvement, the American Organic Hop Growers Association and their formal 2009 petition urged the removal of the exemption that allowed nonorganic hops in organically labeled beer.

Beer is mostly water, and so, in the early years of OFPA, beer producers could rely on non-organic hops since this ingredient is less than five percent of total product ingredients and still label their beer organic. The situation created a bit of a chicken-and-the-egg problem, because as long as the law allowed the use of nonorganic hops, brewers were not looking for organic hops, and growers did not produce them in large quantities. In other words, even though growers of hops showed that the crop could be grown organically, it was not produced to supply the market because lower-cost, conventional (nonorganic) hops were permitted in processing organic beer. In addition, many breweries and wholesalers were locked into contracts with conventional hop growers. As a result, after the filing of the petition and getting the issue on the agenda of the NOSB, organic hop growers descended on the 2010 NOSB meeting, testifying to the fact that they could fill the demand for organic hops and challenging their “not commercially available” status.

The process of continuous improvement worked as intended. Listening to the facts, the NOSB passed a recommendation to remove hops grown with chemical-intensive practices from the National List of Allowed and Prohibited Substances by adopting language that, by January 1, 2013, removed hops from 7 CFR § 205.606 (Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as “organic”) under OFPA. This gave the breweries time to transition organic labeled beer to organically grown hops without breaking existing production contracts.

In 2012, two years after Beyond Pesticides (as an NOSB board member at the time), growers, and advocates across the nation came together to speak out against chemical-intensive hops in “organic” beer, the U.S. Department of Agriculture (USDA) announced in a new rule that hops must be grown in compliance with the National List of Allowed and Prohibited Substances in order for beer products to meet USDA organic certification standards. (See Daily News here and here.)  

Cracking Open the Organic Beer Sector

Patagonia Provisions, the food brand branch of Patagonia, speaks to some of the underlying barriers to the widespread expansion of organic beer markets. “The key factors that have disincentivized breweries from producing organic beer include cost, supply, quality of ingredients, accessibility and distribution, competitive pricing and brand recognition. For example, commercial nonorganic grains can be up to six percent cheaper than organic grains. . .. Any costs or losses need to be covered by the brewery, forcing them to raise prices, which may discourage customers with less disposable income from purchasing the beer,” said Ruvani de Silva, a freelance writer who worked with Patagonia Provisions and conducted a market analysis of price and flavor profiles. “Until recently, certain beer ingredients, particularly organic hops, were also considered inferior products whose flavors weren’t up to the standard of traditional varieties. And the question of loyalty also comes into play. A beer brewed with organic ingredients may taste different from the beers a brewery may be known for, and they may not want to risk alienating their core market who come for the same flavor experience every time.” See the full analysis, Shifting the Beer Industry, Organically.

Growing consumer interest in organic beer is reflected in the growth of breweries sourcing least-toxic ingredients. In a recent article published in The Philadelphia Tribune, a growing list of craft breweries are switching to fonio, an ancient grain originally from West and sub-Saharan Africa, as a main ingredient substitute and/or supplement to barley and wheat for their beer. Pierre Tham, a Senegalese chef who inspired Brooklyn Brewery to incorporate beers with a blend of fonio and malted barley, believes that fonio “could have a transformative impact on economic growth and sustainability in sub-Saharan Africa.” Fonio is significant for its importance within various African cultures, but also for the fact that it does not require toxic pesticides or fertilizers for a productive harvest, due to its growth for thousands of years without toxic synthetic inputs. See Food Revolution for a deep dive into the legacy of the supergrain here. Brooklyn Brewery approached other breweries, including Thornbridge Brewery, Omnipollo, Carlsberg, Jing-A Brewing, Guinness, Russian River Brewing, and others to develop a “coordinated fonio beer push” to create a competitive market for beer that relies on ingredients that can easily be grown with organic principles and practices.

Research on Pesticide Residues in Beer

There is a distinction between organic and nonorganic certified beer products. Glyphosate residues have been found in dozens of popular beer brands in the United States and Germany based on research from U.S. Public Interest Research Group (2019) and Munich Environmental Institute (2016). In a study published in Toxicology Reports in 2023, researchers conducted a comparative analysis of mycotoxin and pesticide levels in both craft and mainstream beer brands in Spain. “Only one sample was free from residues. This was a craft beer with organic certification, which was the only certified organic sample in the survey.” The 2023 study found that craft beers generally contained higher levels of toxic pesticides, while the 2019 U.S. PIRG study found the beer samples had just slightly lower average levels of residues than wine tested, the highest being Tsingtao beer with 49 parts per billion (ppb). Miller Lite, Corona, and Budweiser ranged from 25-30 ppb. Samuel Smith’s Organic Lager had a 5.7 ppb glyphosate concentration, and Peak Beer Organic IPA was the only sample with no detectable level of glyphosate. Given its status as a possible carcinogen, according to the International Agency for Research on Cancer, and its association with potential adverse effects on the gut microbiome, establishing “safe” levels for exposure to glyphosate has been called into question, especially given its widespread contamination of the environment and food commodities.

In a first-of-its-kind study published earlier this year in Environmental Pollution, researchers determined a methodological approach to calculate multiple pesticide residues and their cumulative body burden. All participants contained pesticide residues, with findings of more than 10 pesticides in the bodies of more than 80 percent of the study subjects. The most common pesticides include boscalid, triazoles, and simazine, among other toxic pesticides with documented adverse health impacts, including impacts on central nervous system development, triggering oxidative stress, and acting as an endocrine disrupter, respectively. Despite increasing documented cases of multiple exposures, the U.S. Environmental Protection Agency continues to take “a siloed approach” to the cumulative and disproportionate impacts of multiple chemical exposures, according to a 2023 Office of the Inspector General report. See Daily News here for an in-depth analysis.

As of 2021, there are 40 organic hops farms in the United States valued at $20.3 million, based on data gathered from USDA. Advocates across the nation are interested in enjoying food, including an ice-cold beer, without fear of pesticide exposure and their associated adverse, long-term health effects. Stay abreast of key issues that affect health, biodiversity, and climate with Beyond Pesticides’ Keeping Organic Strong webpage. See Eating with a Conscience to learn about the potential impacts on the ecosystems and farmworkers where various types of produce are grown with petrochemical pesticides. For more information on the pesticides to which we are daily exposed, see Gateway on Pesticide Hazards and Safe Pest Management and Pesticide-Induced Diseases Database. See also Why Organic to learn more about the biodiversity, environmental justice, and public health implications of choosing certified organic products.

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

Sources: The Philadelphia Tribune, Toxicology Reports, Patagonia Provisions

(Beyond Pesticides, November 20, 2024) The perpetual use of pesticide coated seeds and tillage changed the composition of various beetle, spider, and other epigeal arthropod communities on New Hampshire farmland, according to a recent study published in Agriculture, Ecosystems, and Environment. Researchers fell short of finding conclusive results about the multi-variable impacts of both practices on biodiversity but raise notable issues on the impact of treated seeds. This research builds on the existing peer-reviewed scientific literature that highlights the threats of toxic pesticides and pesticide-coated seeds. Environmental and public health advocates are in agreement with organic and agroecological farmers who reject chemical-intensive land management practices.

“At the root of the cascading crises of public health collapse, biodiversity loss, and the climate crisis is a reliance on petrochemical-based toxic products, rather than public policy and investments that strengthen consumer and institutional trust of nature-based, organic systems,” says Max Sano, organic program associate at Beyond Pesticides. “This is consistent with various interactions I have had with advocates across New England who are demanding action to stymie the impending biodiversity collapse enabled by government inaction.”

Background and Methodology

This study was coauthored and led by environmental researchers at the Department of Natural Resources and the Environment at the University of New Hampshire. The report authors are specialized in plant biology, conservation, and entomology with numerous studies in peer-reviewed publications.

The goal of this three-year field study was to “quantify the effects of pesticide seed treatment (crops grown from seeds coated with pesticides versus uncoated seeds) and tillage system (full-tillage with a moldboard plow, strip-tillage, and no-tillage) on epigeal arthropod communities in a long-term conventionally managed annual feed grain rotation experiment.”

The study itself was conducted between 2017 and 2019 growing seasons at the University of New Hampshire Kingman Research Farm. On this site, tillage system experiments began in 2013 and pesticide seed treatment experiments began in 2016 as part of a separate long-term study. Corn and soybeans were the crop of choice for previous experiments, as well as the focus of this study. Tillage treatments were applied for three years before adding treated seeds as an additional variable, and by the end of the study (2019) the treated seed versus no treated seeds component had been in place for four growing seasons.

All plots were sprayed with the weed killer glyphosate pre- and post-planting. The research plots included the following: full-tillage treated with glyphosate and then tilled with two different devices (moldboard plow and industrial-scale plow); strip-tillage treated with glyphosate and then tilled with one industrial-scale plow; and no-tillage sprayed but no plowing occurred.

The epigeal arthropod (including insects that decompose organic matter and other ecosystem services) communities sampled for this study include approximately “1669 individual arthropods, representing 47 species.” The researchers go on to list the various species from the collection periods in both 2018 and 2019. “In 2018, carabid beetles, including P. melanarius, H. erraticus, H. fuscipalpis, H. pensylvanicus, Stenolophus ochropezus Say, S. lecontei (Chaudoir), and Anisodactylus sanctaecrucis (Fabricius) accounted for 34.8 % of the total captures, while other arthropods, including individuals from Gryllidae, Formicidae, Lygaeidae, Scolytidae, Curculionidae, Meloidae, Cydnidae, and Araneae accounted for the remainder (65.2 %). In 2019, carabid beetles (P. melanarius, H. pensylvanicus, B. quadrimaculatum, Chlaenius tricolor, S. lecontei, C. tricolor, Zuphium sp.) represented 12.2 % of total captures, while the remainder (87.8 %) included individuals from Orthoptera, Gryllidae, Formicidae, Coccinellidae, Scolytidae, Curculionidae, Meloidae, Cydnidae, and Araneae.”

Results and Discussion

Researchers find the four following discoveries from this experiment:

1. “Tillage and pesticide seed treatments affected epigeal arthropod community composition.
2. Activity-density was lower in full-till compared to strip-till and no-till.
3. Spider abundance in strip-till was reduced by pesticide seed treatment.
4. Weed seed predation was higher in strip-till compared to full-till.”

Weed seed predation refers to the ecosystem service that wildlife provides in consuming seeds of weeds that would otherwise be treated with pesticides in chemical-intensive agriculture. The main variable in 2018 was pesticide seed treatment, whereas the main variable in 2019 was the degree of tillage. The “activity densities of Pterostichus melanarius (Illiger) [rainbeetles] were higher in the strip-till compared to full-till treatment in 2018.” The authors conclude, “These data provide evidence that both pesticide seed treatments and tillage systems can influence the communities of epigeal arthropods that inhabit annual row crop agroecosystems relatively late in the growing season, when the majority of pesticide residues have likely dissipated, and that the weed seed predation services provided by members of this community can be strongly negatively impacted by intensive tillage.”

The researchers also find that arthropod diversity was higher in full-till versus no-till plots in 2019, however they do acknowledge that “it is possible that had sampling of the epigeal arthropod community occurred earlier in the growing season a stronger pesticide treatment effect would have been detected.” The researchers remain unclear on why treated seeds did not impact spider abundance in the no-till and full-till plots. The variability can be attributed to other factors as well, including the corn-soybean crop rotation model used for this study.

The results of this experiment highlight the compounding impacts of chemical-intensive agricultural practices on biodiversity. Farmers who acknowledge the interconnected systems of agriculture and ecosystems understand the long-term impacts of soil disturbance through tilling disrupts microbial life and biodiversity, not to mention the impacts of glyphosate applications and pesticide-treated seeds can have on soil and human health.

Rise of Organic No-Till Farming

Beyond Pesticides has reported on organic no-till as a potential solution to the issue of toxic inputs and practices. Rodale Institute’s 40-year comparative field study on organic versus non-organic farming finds that, “No-till and organic no-till are not created equal. Conventional no-till utilizes herbicides to terminate a cover crop, whereas organic systems use tools like the roller crimper. We have found that organic no-till practices year after year do not yield optimal results, so our organic systems utilize reduced tillage, and the ground is plowed only in alternating years.” The Rodale Institute’s website adds that, in order to model standard agricultural approaches, GM (genetically modified) crops and no-till were introduced to the conventional plots in 2008 when those techniques became common in the U.S. (See Daily News here.)

The Institute’s Farming Systems Trial (FST) on its 12-acre Pennsylvania parcel uses 72 experimental plots, with three broad approaches:

• Organic manure, representing a typical organic dairy or beef operation, featuring long rotations of annual feed grain crops and perennial forage crops, fertilized through legume cover crops and periodic applications of composted manure, and using diverse crop rotations as primary defenses against pests;
• Organic legume, representing a typical cash grain operation, featuring mid-length rotations of annual grain crops and cover crops, deploying leguminous cover crops as the sole fertilizers, and using only crop rotations as pest defense;
• Conventional synthetic, representing a typical U.S. grain-producing enterprise, using synthetic nitrogen fertilizer, and controlling weeds with synthetic herbicides (according to recommendations of Penn State University Cooperative Extension).

As reported, each of those three is further divided into “no-till” and “tillage” strategies (tillage being the practice of digging up, turning over, or otherwise agitating the soil with mechanical tools — typically a plow or disc). This yields six different systems in the FST.

The FST finds:

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

See Beyond Pesticides’ National Forum session, Tackling the Climate Emergency (see November 29, Session 3 recording), with presentation by Rodale Institute’s Andrew Smith, PhD and coauthor of several landmark reports on soil biology and carbon sequestration — including the just-released Farming Systems Trial — 40-Year Report.

Call to Action

Advocates view both pesticide-treated seeds and high-tillage farming systems as extensions of the chemical-intensive agriculture and land management systems that perpetuate public health crises, undermine biodiversity integrity, and amplify the climate emergency.

Various studies indicate the failure of chemical-intensive no-till farming systems, including a 2022 study published in Nature which finds widespread herbicide resistance on pesticide-intensive corn and soybean farms leads to an increase in greenhouse gas emissions due to need for more tillage. Conversely, reporting from Vermont Public Radio in 2021 highlights the perspective of a retired state scientist, Nat Shambaugh, who found “regenerative” no-till farms increase use of toxic herbicides that ultimately run off into surrounding waterbodies, undermining ecosystem health.

A 2023 study published by American Bird Conservancy finds “a single corn kernel coated with a neonicotinoid can kill a songbird. Even a tiny grain of wheat or canola treated with the oldest neonicotinoid, imidacloprid, can poison a bird.” This report builds on previous studies, including a 2022 study published in Environmental Pollution finding that parents’ ingestion of pesticide-treated or contaminated seeds results in chronic exposure that adversely impacts offspring health, even at “sublethal” doses. (See additional Daily News coverage on neonicotinoid insecticide impacts on wildlife here and here.) With neonicotinoid insecticides in particular, a recent study published this year in Frontiers in Toxicology uncovered serious flaws in the pesticide registration process for five neonic insecticides (acetamiprid, clothianidin, imidacloprid, thiacloprid, and thiamethoxam) in terms of potential adverse effects on human health. The issue of pesticide-treated seeds continues to surface in various state legislatures, with New York and Vermont passing the first laws in the nation to restrict the use of pesticide-treated seeds beginning in 2029, pending rulemaking. (See Daily News here and here.)

Earlier this year, advocates across the nation called on EPA to not exempt pesticide-treated seeds and paint from thorough risk assessment and examination. (See Action of the Week here.) To learn more on how to engage in strengthening USDA organic standards, see Keeping Organic Strong.

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

Source: Agriculture, Ecosystems and Environment

(Beyond Pesticides, November 19, 2024) Researchers at Stanford University recently published a study in Cancer, an international interdisciplinary journal of the American Cancer Society (ACS), that reveals a correlation for numerous pesticides with increased prostate cancer occurrence and associated death. The study finds that exposure to 22 pesticides is positively associated with prostate cancer. The 22 pesticides include 2,4‐D, acephate, azoxystrobin, bifenthrin, carbaryl, chloropicrin, cloransulam‐methyl, cyhalothrin‐lambda, diflufenzopyr, diuron, glyphosate, hexazinone, linuron, methyl parathion, pendimethalin, propiconazole, sulfosate, thiamethoxam, thifensulfuron, tribenuron methyl, trifloxystrobin, and trifluralin. (See more on 2,4-D and cancer prevalence here and here.)

As prostate cancer is a leading national health concern, the authors investigate agricultural pesticide exposure and compared it to prostate cancer incidence and mortality across counties in the contiguous U.S. “The geographic variation in prostate cancer incidence and mortality suggests that regional environmental factors, such as pesticide exposure, may contribute to the development of prostate cancer,” the researchers postulate.

In comparing county‐level associations of 295 pesticides and prostate cancer reports, the authors were able to conduct an environment‐wide association study (EWAS) to determine any statistically significant links. “We acquired annual estimated total usage data (kg per county) for all pesticides reported and applied to agricultural crops grown in the United States from 1997 to 2006 from the National Water‐Quality Assessment Project through the U.S. Geological Survey Pesticide National Synthesis Project,” the researchers note. “We selected these years to allow for lag‐time between exposure and prostate cancer outcomes.”

The prostate cancer incidence and mortality rates were acquired for the timeframes of 2011–2015 and 2016–2020 from the U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, and the National Cancer Institute. This data is U.S.‐wide, county‐level, and age-adjusted. The final data is compiled from 3,107 counties within the 48 states. Two cohorts were created based on the pesticide data for 1997–2001 and 2002–2006 and were then compared to cohorts for the prostate cancer data. Of the 295 pesticides that are analyzed, the authors focus on those that are available in both cohorts and that appear in at least 35 counties.

To further explain their methodology, the researchers say, “We used linear regression models examining 5‐year cumulative pesticide use separately for each of the 295 individual pesticides measured in 1997–2001 and age‐adjusted prostate cancer incidence rates from 2011–2015 (discovery cohort). We conducted parallel analyses for pesticide use in 2002–2006 among the same 295 pesticides and prostate cancer incidence rates in 2016–2020 (replication cohort).”

As a result, the discovery cohort with the 2011–2015 data shows 953,204 prostate cancer diagnoses and 140,086 deaths, while the replication cohort from 2016–2020 increased to 1,063,671 diagnoses and 156,687 deaths.

Statistical analyses reveal exposure to the 22 pesticides is positively associated with prostate cancer incidence in both cohorts. “The 22 candidate pesticides identified by this EWAS approach include pesticides previously reported to be associated with the incidence of prostate cancer: 2,4‐D, linuron, and carbaryl… Of the 19 candidate pesticides not previously reported as associated with the incidence of prostate cancer, many have been evaluated by the EPA [Environmental Protection Agency] for their potential carcinogenic effects, although not explicitly in relation to prostate cancer, with seven of these pesticides classified as possible human carcinogens,” the researchers report. They continue, “[F]our of these candidate pesticides [cloransulam‐methyl, diflufenzopyr, thiamethoxam, and trifluralin] were associated with prostate cancer mortality, highlighting their potential relevance to the development of clinically significant prostate cancer.”

In the results connecting four pesticides to an increase in death from prostate cancer, further investigation into these classes of pesticides is needed. Three of the pesticides are herbicides, but come from different classes—trifluralin (dinitroaniline), cloransulam‐methyl (triazolopyrimidine), and diflufenzopyr (aryl‐carboxylates)—while thiamethoxam is a neonicotinoid insecticide. Of these, EPA considers only trifluralin as a possible human carcinogen. The other three are considered not likely to be carcinogenic or have evidence of non-carcinogenicity. Advocates are calling for EPA to fully evaluate all chemicals regarding endocrine disruption, carcinogenicity, and other long-term effects, as many currently registered pesticides lack chronic epidemiological studies.

There are many studies (see here and here) connecting pesticides with an increased prostate cancer risk. Beyond Pesticides has also highlighted this link through Daily News coverage over the last 10+ years here, here, and here. The correlation between pesticide exposure and endocrine disruption is also heavily documented. As reported in 2017, alterations in gene expression, such as with oxidative stress and endocrine disruption, can occur after contact with pesticides. One study finds that these DNA changes and “subsequent gene inactivation has been consistently associated with prostate cancer.” (See additional coverage here and here.)

ACS estimates that prostate cancer incidence in the U.S. for 2024 will include 299,010 new cases and 35,250 deaths. They also note that about 1 in 8 men will be diagnosed with prostate cancer, as it is the most common cancer among men in the U.S., second to skin cancer. Regarding cancer deaths in U.S. men, prostate cancer ranks second, with lung cancer being first. This translates to 1 in every 44 men dying from prostate cancer, which is lower than in past decades as early detection and treatment options have increased. ACS also finds that globally prostate cancer is the most diagnosed cancer type in men for 66% of the world (118 countries).

With the high prevalence of prostate cancer, and many other cancers, within the U.S. and worldwide, contributing factors such as pesticide use and exposure from drift need to be addressed. As the study authors conclude, “Public health efforts to reduce the burden of prostate cancer should consider pesticides as environmental exposures that may contribute to the incidence of, and mortality related to, prostate cancer.” Beyond Pesticides has not only called for more extensive testing but the adoption of alternative practices and products that eliminate toxic pesticide use to safeguard human health and the environment.

In organic land management, the reliance on petrochemical pesticides and synthetic fertilizers is removed. Instead, least-toxic alternatives are used to effectively manage insects, rodents, and weeds without exposing any organisms or the environment to harmful chemicals. You can make The Safer Choice to avoid hazardous home, garden, community, and food use pesticides and eat with a conscience.

Choosing organic food rejects hazardous agricultural practices, mitigates climate change, protects farmworkers and farm families, and promotes healthy systems. Whether buying organic products or growing your own organic food, you can support the organic solution. Become a member of Beyond Pesticides today and sign up for Action of the Week and Weekly News Updates delivered right to your inbox!     

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

Source:

Soerensen, S. et al. (2024) Pesticides and prostate cancer incidence and mortality: An environment-wide association study, Cancer. Available at: https://acsjournals.onlinelibrary.wiley.com/doi/10.1002/cncr.35572.

(Beyond Pesticides, November 18, 2024) With the reported appointment of former U.S. Representative Lee Zeldin (R-NY) to the position of Administrator of the U.S. Environmental Protection Agency (EPA), Senate confirmation hearings will be an important process that is intended to shine a light on individual nominations, the policies of an administration, and the science (or lack thereof) behind them. There have been reports in the media that the Trump administration may attempt to circumvent the “advice and consent” rule of the U.S. Senate by making recess appointments. Alexander Hamilton wrote in the Federalist Papers: No. 76 that Senate confirmation hearings act as a safeguard against the appointment of “unfit” officials.

Numerous interviews and critiques are painting a picture of what the future holds for environmental protection and all that means for addressing the serious catastrophic threats of ongoing and escalating health, biodiversity, and climate crises. “Mr. Trump, who has called climate change a “hoax,” has targeted “every one” of Mr. Biden’s policies designed to transition the United States away from fossil fuels,” according to The New York Times reporting on June 26, 2024. The Guardian reported on October 1 after Hurricane Helene, “As the hurricane continued to ravage the region over the weekend, the former president dismissed global warming in a Saturday speech, and the following day referred to the climate crisis as “one of the great scams of all time.” “More than 230 people have been killed from Hurricane Helene, which unleashed devastation across Florida, Georgia, South Carolina, North Carolina, Virginia and Tennessee,” ABC News reported on October 7. The intensity and severity of hurricanes are directly related to climate change, according to Center for Climate and Energy Solutions.

French researcher and professor Barbara Demeneix, PhD points out in her article, “How fossil fuel-derived pesticides and plastics harm health, biodiversity, and the climate,” in The Lancet, that, ”[Rachel] Carson [now over 60 years ago] showed that the decline in bird and fish populations was due to the pesticide DDT— 30 years before research showed that DDT acted through endocrine mechanisms. Oil is used to make chlorobenzene, which in turn is used to synthesize DDT. Similarly, many pesticides such as neonicotinoids, pyrethroids, and glyphosate are produced from gas and oil.” Plastics, PFAS, and more, are a part of this list. Tracey Woodruff, PhD (professor in the Department of Obstetrics, Gynecology, and Reproductive Sciences and the director of the Program on Reproductive Health and the Environment and the EaRTH Center), School of Medicine, University of California San Francisco, earlier this year wrote the article ”Health Effects of Fossil Fuel–Derived Endocrine Disruptors” in The New England Journal of Medicine, highlighting the urgent need to address the widespread chemical pollution stemming from the petrochemical industry and underscoring the dire implications for public health. In addition to the effects on climate, Dr. Woodruff points out that, “Many of these fossil-fuel-based chemicals are endocrine disruptors, meaning they interfere with hormonal systems, and they are part of the disturbing rise in disease.”  (See Daily News.) [Shortly, Beyond Pesticides will be posting Dr. Woodruff’s keynote to Beyond Pesticides’ National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency, on November 14.]

It is expected that the Trump administration will withdraw the United States from the Paris climate agreement, which is considered “the most important UN [United Nations] process to tackle climate change,” according to the BBC. The BBC reports that, “The agreement saw almost all the world’s nations—for the first time—agree to cut the greenhouse gas emissions which cause global warming.”

Beyond the climate crisis, as the Trump administration is preparing to take office, the nation and world face existential crises that require urgent action. Human actions are contributing to an ongoing Holocene or sixth mass extinction, as well as crises in human disease. Humans and the biosphere will suffer if President-elect Trump’s new EPA Administrator follows a course destructive of EPA’s mission. Although some have called the environmental record of Mr. Trump’s nominee Lee Zeldin “mixed,” citing his past acknowledgment that climate change is real and support for regulating PFAS, he has shown his loyalty by supporting the former president through his first impeachment trial and challenges to the 2020 election results.  

>> Tell your U.S. Senators, under their responsibility to provide “advice and consent” for presidential appointments, to fully vet Lee Zeldin—for the position of EPA Administrator—on his understanding of the current existential environmental crises and the mission of EPA.

According to Mother Jones magazine, “By tapping former New York Rep. Lee Zeldin to head the Environmental Protection Agency, President-elect Donald Trump opted to put his planned radical rollback of climate policy in the hands of a staunch ally who is skilled at projecting an image of a moderate conservationist.” 

Climate change is a real crisis and requires serious action. It is one of multiple crises that are compounding one another. Continued reliance on petrochemical pesticides and fertilizers is a major contributor to the release of greenhouse gases and the failure to reverse the threat through atmospheric carbon sequestration in healthy soils. While climate change may be most apparent—128 degrees F in Death Valley, heat waves in India, the U.S., and globally, the earliest Category 5 hurricane on record, another wildfire season, etc.—there are also crises in human disease and biodiversity collapse. Heat makes the health effects of pesticides more serious. Climate change is intensifying the impacts of habitat destruction and toxic chemicals on biodiversity. The urgency to act is made more apparent every day. 

Both Mr. Trump and Mr. Zeldin have made clear that the mission of the new EPA Administrator is to enact “deregulatory decisions that will be enacted in a way to unleash the power of American businesses.” Of course, businesses and the environment can coexist if industry adapts to the need for practices and products that are compatible with a healthy environment.

The stated mission of EPA is “to protect human health and the environment,” ensuring that:

• Americans have clean air, land, and water; 
• National efforts to reduce environmental risks are based on the best available scientific information; 
• Federal laws protecting human health and the environment are administered and enforced fairly, effectively and as Congress intended; 
• Environmental stewardship is integral to U.S. policies concerning natural resources, human health, economic growth, energy, transportation, agriculture, industry, and international trade, and these factors are similarly considered in establishing environmental policy; 
• All parts of society—communities, individuals, businesses, and state, local and tribal governments—have access to accurate information sufficient to effectively participate in managing human health and environmental risks; 
• Contaminated lands and toxic sites are cleaned up by potentially responsible parties and revitalized; and 
• Chemicals in the marketplace are reviewed for safety. 

Unless Mr. Trump is successful in evading the U.S. Senate confirmation hearing process, Senators will have an opportunity to probe the nominee’s knowledge of environmental crises and how his deregulatory mission aligns with the mission of protecting human health and the environment. 

How does Mr. Zeldin’s support of profligate energy use and petroleum-based industries further EPA’s mission to protect public health, in view of their numerous adverse existential impacts on human health, biodiversity, and climate? How does he intend to ensure that Americans have clean air, land, and water, while pursuing a deregulatory agenda? How will he guarantee that EPA acts on the best independent science? How will EPA limit use of chemicals to those that are thoroughly reviewed for possible impacts on human health, biodiversity, and climate? 

>> Tell your U.S. Senators, under their responsibility to provide “advice and consent” for presidential appointments, to fully vet Lee Zeldin—for the position of EPA Administrator—on his understanding of the current existential environmental crises and the mission of EPA. 

Letter to U.S. Senators
I am writing to ask you to use the confirmation hearing of President-elect Trump’s nominee for Administrator of the Environmental Protection Agency (EPA) to shine a light on the environmental plans of the new administration. It is critical that you exercise your responsibility to provide advice and consent for all presidential appointments, especially those that have a dramatic impact on the health and well-being of the people of our state and nation. Do not permit the circumvention of Senate confirmation hearings, which, as Alexander Hamilton wrote in the Federalist Papers, act as a safeguard against the appointment of “unfit” officials.

The nation and world face existential crises that require urgent action. Human actions are contributing to an ongoing sixth mass extinction, as well as crises in human disease and climate change. We cannot politicize science that informs public policy intended to protect public health and the environment. Although some have called the environmental record of President-elect Trump’s nominee Lee Zeldin “mixed,” citing his past acknowledgment that climate change is real and support for regulating PFAS (or per- and poly-fluoroalkyl substances known as “forever chemicals”), the EPA Administrator must exercise a first loyalty to the mission of the agency and health of the environment that sustains our lives. 

Both President-elect Trump and Mr. Zeldin have made clear that the mission of the new EPA Administrator is to enact “deregulatory decisions that will be enacted in a way to unleash the power of American businesses.” In contrast, the stated mission of EPA is “to protect human health and the environment.” Both can be achieved as industry adapts to the need for practices and products that are compatible with a healthy environment. EPA’s mission has been clearly nonpartisan and focused on the health of everyone and future generations. 

EPA states that it works to ensure that: 

*Americans have clean air, land, and water;

*National efforts to reduce environmental risks are based on the best available scientific information;

*Federal laws protecting human health and the environment are administered and enforced fairly, effectively, and as Congress intended;

*Environmental stewardship is integral to U.S. policies concerning natural resources, human health, economic growth, energy, transportation, agriculture, industry, and international trade, and these factors are similarly considered in establishing environmental policy;

*All parts of society–communities, individuals, businesses, and state, local, and tribal governments–have access to accurate information sufficient to effectively participate in managing human health and environmental risks;

*Contaminated lands and toxic sites are cleaned up by potentially responsible parties and revitalized; and

*Chemicals in the marketplace are reviewed for safety.

Senate confirmation hearings must shine a light on the policies of the new administration and the science behind them. How can Mr. Zeldin’s address energy use and petroleum-based industries within the context of EPA’s mission to protect public health, recognizing the existential crises, identified by independent scientific analyses, that threaten human health, biodiversity, and climate stability? How does he intend to ensure that Americans have clean air, land, and water while pursuing a deregulatory agenda? How will he guarantee that EPA acts on the best independent science? How will EPA limit use of chemicals to those that are thoroughly reviewed for possible impacts on human health, biodiversity, and climate?

Thank you for your consideration. I would appreciate knowing that you intend to fulfill your important advice and consent responsibility on presidential appointments, and help the nation unify on the protection of our health, the health of our nation’s children, and the health of the environment for future generations.

(Beyond Pesticides, November 15, 2024) There are many pie-in-the-sky ideas to address the climate crisis while allowing business as usual in the extractive and industrial systems that are causing the crisis. Prominent among them are geoengineering to block sunlight and building industrial plants to prevent carbon dioxide (CO₂) from reaching the atmosphere, known as carbon capture and sequestration (CCS).

Like geoengineering, CCS is a “solution for the future that always will be.” It has garnered decades of hype, research, and government funding of prototype projects without doing much of anything to remove carbon and keep it out of the atmosphere.

The Biden administration’s Inflation Reduction Act (IRA) contains numerous revenue streams aimed at coping with the climate crisis, including CCS. But it is a mixed bag of good and bad ideas. Beyond Pesticides analyzed the IRA in 2022, lauding the act’s “provision of unprecedented sums to address the existential threats we face related to climate, biodiversity, and health.” These include about $21 billion for “climate smart” agriculture and programs to reduce petrochemically dependent farming. But the analysis also details the many provisions for infeasible and counterproductive projects.

Rather than complex and expensive technological projects, the best practitioners of CCS are plants and soil. In fact, soils hold more than three times the carbon in the atmosphere. This is why agriculture—organic agriculture—can provide the simplest and most direct counter to the catastrophic load of greenhouse gases in the atmosphere.

Industrial methods have made agriculture a major contributor to greenhouse gas emissions by virtue of deforestation, soil erosion, nutrient depletion, and general degradation of landscapes. More than half the entire soil carbon loss since agriculture began has occurred in the last 150 years, according to Farming Our Way Out of the Climate Crisis, a report from Project Drawdown. But organic methods offer a route to re-capture much of that carbon and prevent further emissions. Another report from American Farmland Trust, Combatting Climate Change on US Cropland, notes that the U.S. has almost 400 million acres of cropland, offering an enormous opportunity to rebuild soil organic carbon, capture atmospheric carbon, and reduce emissions. Just adopting cover crops and no-till practices could reduce emissions “equal to 40% of 2018 U.S. agricultural emissions,” the report states, and if proper practices are applied, “soil carbon emissions could be halved from 2010 levels by 2050.”

Thus, decoupling agriculture from fossil fuels should be a primary goal of any climate mitigation plan, yet it takes second place to more technological proposals in federal initiatives and is being actively obscured by fossil fuel companies. Many of the touted elements of industrially-based carbon reduction programs include materials that are of doubtful utility at best, such as biofuels including biochar and ethanol. Further, pesticides, which are mostly derived from fossil fuels, add directly to carbon emissions. At least one pesticide is actually a greenhouse gas itself, sulfuryl fluoride, which is used to kill termites, moths, bedbugs and beetles.

The policymakers, corporate interests, and researchers focusing on climate solutions tend to concentrate on the energy balance of technologies in the hope that a carbon capture or prevention method will also produce more energy than it consumes. This strong emphasis on combining carbon control with energy production can compromise the former and often results in more energy being expended than is produced. The approach also omits consideration of unintended consequences and harms to public and worker health that may be present in any climate solution application. In other words, technological and economic benefits take precedence over human and ecological protections without actually mitigating climate change.

The White House Environmental Justice Advisory Council (WHEJAC) has just issued a report with a number of recommendations for how we may manage carbon without harming communities already vulnerable to multiple environmental stressors. The first recommendation is that all types of carbon capture should undergo analysis of their “environmental impacts (including Soil), human and public health risks and impacts, cumulative impacts, explosion and seismic risks, full life cycle assessments of greenhouse gas emissions outcomes, and co-pollutant emissions related to these projects.” The report addresses how climate policy decisions may themselves contribute to the injustices faced by groups already bearing the brunt of industrial practices and their effects on climate: communities of color, Native American tribes, farmworkers, and poor people.

The WHEJAC report takes aim at the CCS variant Bioenergy with Carbon Capture and Storage (BECCS). This involves burning biomass to produce energy and capturing the resulting carbon emissions. BECCS is widely considered a crucial element in an overall climate-saving strategy, and is supported by the IRA.

But the WHEJAC report details a number of substantial concerns with BECCS methods, which “contribute to soil erosion, nutrient depletion, and degradation of soil quality, and … are painted as carbon negative [climate-protective] despite the fact that BECCS ‘leads to significantly more carbon emissions in the grid than the current average.’” Moreover, BECCS projects compete with actual crop production and require major inputs of land and water. Some proposals even suggest burning existing forests to provide energy, the logic of which is incomprehensible. And according to a Natural Resources Defense Council analysis, in at least one typical BECCS scenario, the CO₂ emissions occurring along the biomass supply chain would offset 60 percent of the captured emissions at the biomass power station.

Another as-yet-unworkable idea, carbon markets, has also been promoted as a way to reduce emissions since the Kyoto Protocol enabled them in the 1990s. The idea is that carbon emitters can buy credits from others who did not use their allotted carbon emissions, and producers can “offset” carbon emissions in other ways, such as paying for tree planting elsewhere. But last year the Guardian reported that 90 percent of the offsets traded in the world’s largest offset program were “phantom” credits and resulted in zero carbon reductions.

Further, as Beyond Pesticides covered in the August 27 Daily News, carbon markets have also had another serious negative consequence. Carbon offset and reduction concepts inspired pesticide companies to set up purported “sustainable” programs based on the continued use of agrochemicals including pesticides and pesticide-treated seeds, greenwashing them by claiming they are useful in reduced or no-till agriculture and cover cropping and can conserve soil carbon.

Pesticides, treated seeds and biochar contamination are serious issues both for organic practitioners generally and for vulnerable populations. The WHEJAC report warns that any climate mitigation programs based on carbon capture, biomass burning, and biochar must be thoroughly vetted and required to specify the types of feedstocks used and ensure that public health risks are taken into account.

Beyond Pesticides covered a particularly egregious version of converting biomass to energy in 2021. According to a Guardian investigation, a company called AltEn in Mead, Nebraska produced ethanol from unused seeds. Unfortunately, the seeds were coated with toxic pesticides, including bee-killing neonicotinoids. Ethanol plants typically sell their leftover fermented seeds to livestock farmers as “spent grains.” But the company recognized that its spent grains were too poisonous for livestock, so they sold them to farmers as a soil amendment. This merely spread the toxicity around more, and farmers and the community objected. Finally the state banned the sale of the spent grains, so the company piled them up around the ethanol plant, where the level of the neonicotinoid cloathianidin reached 427,000 parts per billion. Another neonicotinoid was measured in a wastewater storage pond at over 300 times its acceptable level in drinking water. Two days after the state shut the company down in 2021, a pipe burst and spilled millions of gallons of tainted wastewater. The state is now conducting a cleanup of the site at the scale of a Superfund site, although the plant is not so designated.

Biochar is a very popular component of many carbon reduction programs. It is basically biomass—either waste material or grown for the purpose—reduced to carbon in a low-oxygen environment so that CO₂ does not form. The heat energy produced in that process can be tapped for human use. And the biochar, used as a soil amendment, sequesters carbon.

Biochar can have other virtuous applications, such as removing pollutants from water. But, as a 2024 study found, its virtue is also its Achilles heel; like charcoal, it can absorb and retain just about anything, including heavy metals and pesticides in soil. Further risks from biochar depend on the chemistry of the source material, which can include hemp, wood, wheat chaff, and many other plants. For example, depending on source and processing, levels of toxic polycyclic aromatic hydrocarbons such as naphthalene may vary in the end product. It is not a neutral and uniform material that will save the planet without careful management.

The WHEJAC report expresses concern for workers and others exposed to biochar. Particulates, high temperatures and contaminants can lead to respiratory, skin and eye injuries. There may be allergenic potential in some types of biochar, and contaminants in feedstocks may be transferred to soil and water. Currently, the report says, few of the downstream or unintended consequences like these are considered in climate projects.

Pesticides contribute directly to climate change in multiple ways. According to a 2022 Pesticide Action Network report, “99 percent of all synthetic chemicals—including pesticides—are derived from fossil fuels.” Production of one kilogram of pesticide takes about ten times more energy than one kilogram of fertilizer, resulting in proportionally more greenhouse gas emissions. And just as nitrogen fertilizers do, fumigant pesticides multiply formation of the greenhouse gas nitrous oxide in soils, which then escapes to the atmosphere.

Wetlands, which are extremely important carbon sinks, can be turned into carbon emitters by pesticides, according to a July 2024 study. For example, the authors cite research indicating the fungicide tridemorph increases methane production in flooded rice fields; in the authors’ direct experiment, the herbicides glyphosate and 2,4-D combined increased CO₂ production in wetland sediment.

As we showed in our Daily News last May, sulfuryl fluoride has been known to be a greenhouse gas since 2008 and was listed as such by the Intergovernmental Panel on Climate Change in 2013. Sulfuryl fluoride use has increased since the 1987 Montreal Protocol on the ozone layer led to reduction in methyl bromide applications. In 2009, Beyond Pesticides reported on a study showing that sulfuryl fluoride absorbs infrared light at a high rate and lasts a long time in the atmosphere—at least 30 to 40 years, and possibly as long as 100 years. It is up to 4,000 times as effective at trapping heat as CO₂. When used indoors, 90 percent of it escapes to outdoor air within two hours.

Nor is sulfuryl fluoride benign otherwise. Several cases of acute exposure resulting in death have been documented. The chemical can also result in cancer, endocrine disruption, neurotoxicity, and impacts on reproduction and development. EPA allows it to be used in the production of raw and processed foods. U.S. emissions of sulfuryl fluoride are highest in southern California, according to a study published in Nature Communications Earth & Environment last April. The study includes an analysis of imagery showing that after the chemical is applied inside tents, plumes of the gas drift over residential areas. This pesticide does double duty as a threat to the climate and directly to human and ecosystem health.

Taken together, the evidence shows that conventional agriculture using industrial chemicals does more harm than good with respect to climate change. Tying progressive agricultural CCS to energy production hamstrings the climate benefits. Endorsing BECCS, biochar, pesticide-treated seeds, and the like by commercial interests and policy experts without serious consideration of unintended consequences will likely fail to have the desired effect and produce numerous additional harms to humans and ecosystems.

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

Sources:

Recommendation Report 2 White House Environmental Justice Advisory Council Recommendations: Carbon Management
White House Environmental Justice Advisory Council (WHEJAC)
October 4, 2024
https://www.epa.gov/system/files/documents/2024-10/whejac-carbon-management-recommendations-october-2024.pdf#page51

Unregulated Greenhouse Gas Emissions from Potent Pesticide Impact Climate Crisis and Public Health
Beyond Pesticides, May 2, 2024
https://beyondpesticides.org/dailynewsblog/2024/05/unregulated-greenhouse-gas-emissions-from-potent-pesticide-impact-climate-crisis-and-public-health/

Harnessing soil carbon sequestration to address climate change challenges in agriculture

Project Drawdown
Soil and Tillage Research
Volume 237, March 2024
https://www.sciencedirect.com/science/article/abs/pii/S0167198723003264

Combatting Climate Change on US Cropland: Affirming the Technical Capacity of Cover Cropping and No-Till to Sequester Carbon and Reduce Greenhouse Gas Emissions
American Farmland Trust
https://s30428.pcdn.co/wp-content/uploads/2020/12/AFT_Carbon-WP-2020_FNL-web.pdf

The energy return on investment of BECCS: is BECCS a threat to energy security?
Mathilde Fajardyab and Niall Mac Dowell
Energy & Environmental Science 2018
https://pubs.rsc.org/en/content/articlelanding/2018/ee/c7ee03610h

Pesticides and Climate Change: A Vicious Cycle
Pesticide Action Network 2022
https://www.panna.org/resources/pesticides-and-climate-change-a-vicious-cycle/

Historic Federal Support Could Effectively Take on Climate, Health, and Biodiversity Crises—with Grassroots Advocacy
Beyond Pesticides, August 19, 2022
https://beyondpesticides.org/dailynewsblog/2022/08/historic-federal-support-could-effectively-take-on-climate-health-and-biodiversity-crises-with-grassroots-advocacy/

Carbon Markets Entrench Pesticide Use
Beyond Pesticides, August 27, 2024
https://beyondpesticides.org/dailynewsblog/2024/08/carbon-markets-entrench-pesticide-use/

Termite Insecticide a More Potent Greenhouse Gas than Carbon Dioxide
Beyond Pesticides, January 26, 2009
https://beyondpesticides.org/dailynewsblog/2009/01/termite-insecticide-a-more-potent-greenhouse-gas-than-carbon-dioxide/

Ethanol Plant Processing Pesticide Coated Seeds Contaminates Nebraska Town
Beyond Pesticides, January 13, 2021
https://beyondpesticides.org/dailynewsblog/2021/01/ethanol-plant-processing-pesticide-coated-seeds-contaminates-nebraska-town/

Exploring negative emission potential of biochar to achieve carbon neutrality goal in China
Deng et al.
Nature Communications 2024
https://www.nature.com/articles/s41467-024-45314-y

Common use herbicides increase wetland greenhouse gas emissions
Cornish et al.
Science of the Total Environment
https://www.sciencedirect.com/science/article/pii/S0048969724030286

(Beyond Pesticides, November 14, 2024) The destructive impact of Hurricane Milton, a climate-change-fueled extreme weather event that smashed into Florida in early October, led to the temporary closure of all phosphate mining facilities, integral to petrochemical fertilizer production, in the state after reported wastewater spillage, according to reporting by Tampa Bay Times. The Mosaic Company, the largest phosphate mining company in Florida, reported at least 17,500 gallons of wastewater from one of their processing plants leaked into Tampa Bay (“The Bay”), according to a company press release. It is unclear to local communities if the U.S. Environmental Protection Agency (EPA) will permit the company’s request earlier this year to test 1,200 tons of phosphogypsum, an industrial byproduct of phosphate rock mining, as a potential material in roadways. Local advocates find this alarming given a reported tear in a gypsum stack operated by Mosaic in one of its plants in New Wales. The wastewater was used as a storage medium for phosphogypsum, which when dissolved contains cancer-causing radon, according to reporting by Reuters.

Besides phosphate waste leakage, over 30 waterways across Tampa Bay were polluted after back-to-back hurricanes (Tropical Storm Debby in August, Hurricane Helene in September, and Hurricane Milton in October), leading to “an estimated 68 million gallons of spilled pollution has been reported so far across seven counties, a number that is likely a vast undercount and sure to rise as wastewater managers learn more about how facilities fared,” according to a separate Tampa Bay Times analysis.

As extreme weather events occur with higher frequency and severity due to the climate emergency, frontline communities are increasingly concerned about the potential for worsening toxic spills from existing and planned petrochemical infrastructure, particularly in the Southeast and Gulf of Mexico regions, but also nationwide. Advocates prefer a wholesale transition to organic land policies and practices, rather than continuing to invest in infrastructure (e.g., carbon capture and storage/carbon credits, phosphate mines) framed by industry as climate solutions.

Florida Phosphate Mines

Florida is the hub of domestic phosphate production. In 2017, the Land Change Monitoring, Assessment, and Projection (LCAMP) initiative through the U.S. Geological Survey (USGS) published a historical, geospatial analysis of the legacy of phosphate production in the state going back to the 1880s. (See here for the full report.)

Four of the nation’s nine currently operating plants are located in the Sunshine State, according to a Mineral Commodities Summary for phosphate conducted by USGS and published in January 2024. “More than 95% of the phosphate rock mined in the United States was used to manufacture wet-process phosphoric acid and super phosphoric acid, which were used as intermediate feedstocks in the manufacture of granular and liquid ammonium phosphate fertilizers and animal feed supplements,” according to the report. Phosphate rock is also produced in Idaho, North Carolina, and Utah. While the report is technically correct that “there are no [elemental] substitutes for phosphorus in agriculture,” organic and agroecological farmers point to the availability of phosphorus-containing substances compatible with national organic standards (e.g., liquid fish products and squid byproducts containing phosphoric acid), as well as manure and compost.

Phosphate facilities, both active and retired, pose demonstrable environmental and public health impacts. In 2021, over 200 million gallons of contaminated wastewater was pumped into Tampa Bay from the retired Piney Point phosphate plant in Manatee County. In a previous Daily News, Beyond Pesticides covered the immediate aftermath of this crisis. (See here.) The phosphogypsum stacks at Piney Point storage “pond” contain uranium and its decay products, such as the isotope radium-226 (which has a half-life of 1,600 years and decays into radon); these are highly radioactive elements. The stacks also contain toxic elements, such as lead and arsenic. In the Piney Point incident, the concern—beyond the potential tsunami of wastewater had the holding pond been breached—was that the stacks might then collapse and send radioactive waste in the flood waters. The plant was built in 1966 to process phosphate rock into synthetic fertilizer, and for decades there was a pattern of mismanagement resulting in the release of polluted wastewater into The Bay. (See here for a timeline developed by Tampa radio station WUSF.)

Petrochemical Infrastructure and Permissible Harms

There are extensive analyses and documentation of the existing and projected impacts of petrochemical infrastructure on ecological and public health.

The Center for International Environmental Law (CIEL) released a report earlier this year, The U.S. Petrochemical Buildout: America’s Next Big Climate Mistake, outlining the greenhouse gas emissions impacts of petrochemical pesticide and fertilizer sectors. According to CIEL analysis, “planned petrochemical projects across the US could add a staggering 153.8 million metric tonnes of CO₂ equivalent (CO₂e) emissions annually. This is equal to the emissions of nearly 40 coal power plants or all US domestic commercial aviation emissions.” The development of these planned projects will exacerbate existing inequalities for frontline communities in Louisiana’s “Cancer Alley,” as well as Gulf South and Ohio River Valley communities who have faced decades of toxic exposure to the fossil fuel supply chain.

According to the website of American Fuel & Petrochemical Manufacturers (AFPM), the leading petrochemical trade association in the U.S., there are 311 petrochemical facilities in the United States. Additionally, AFPM describes U.S. refineries and petrochemical facilities as “among the most technologically advanced and efficient in the world.”

Publicly available data paints a different picture. The U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) releases reports on national pipeline performance measures and tracks various leaks from fossil fuel infrastructure, including crude oil, refined petroleum, and biofuel pipelines. According to most recently published DOT data, there have been approximately:

• 12,494 reported leaks on federal lands (not including the National Park System) between 2010 and 2023;
• 20 serious incidents [defined as “a fatality or injury requiring overnight, in-patient hospitalization”] between 2005 and 2023 for “crude oil/refined petroleum/biofuel” pipelines, with operator failure as the leading cause; and
• 1,189 “accidents impacting people or the environment” between 2010 and 2023, with the four leading causes being corrosion, equipment failure, material failure of pipe/weld, and incorrect operation.

Environmental and public health advocates are not surprised by the expectation of allowable harms borne from toxic substances in the context of U.S. energy production, given the pervasiveness of tolerances EPA sets for the permissible amount of pesticides that can be legally allowed in food, drinking water, and other sources, as set by Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

As previously reported, the U.S. Department of Agriculture (USDA) releases annual pesticide residue reports through the Pesticide Data Program (PDP). Each year, USDA finds a vast majority of tested products have some level of residues in food products, yet spins the findings as a positive: “More than 99 percent of the products sampled through PDP had residues below the established EPA tolerances.” According to the latest data released in the 32^nd Annual Summary Report, over 72 percent of tested commodities contain residues. The tolerance setting process has been criticized as highly deficient because of a lack of adequate risk assessments for vulnerable subpopulations, such as farmworkers, people with compromised health or preexisting health conditions, and children, as well as a failure to fully assess serious health outcomes such as disruption of the endocrine system (which contributes to numerous serious diseases). For example, in a Consumer Reports review also published earlier this year, seven years of PDP analyses show that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day. (See Daily News here.)

Call to Action

See the latest Action of the Week, EPA Must Not Register Pesticides Without Sufficient Data Demonstrating No Endocrine Disruption, to demand EPA consider complete data for endocrine disruption and call upon Congress to ensure that EPA follows through in not registering pesticides without sufficient data demonstrating no endocrine disruption.

Talk with Beyond Pesticides about creating a livable future: Attend Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency. The Forum Session 2 will be held today, November 14 at 1:00pm (EST). Tracey Woodruff, PhD, will be speaking on issues she published earlier this year in the New England Journal of Medicine on the impact of petrochemical pesticides, fertilizers, and plastic linked to severe health consequences, including endocrine disruption. (See Daily News here.) Dr. Woodruff, a former U.S. Environmental Protection Agency (EPA) senior scientist and policy advisor, is director of the Program on Reproductive Health and the Environment, and professor in the Department of Obstetrics, Gynecology, and Reproductive Sciences in the School of Medicine at the University of California San Francisco. 

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

Registration is complimentary, with contributions appreciated. 

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

Source: Tampa Bay Times

(Beyond Pesticides, November 13, 2024) A study in Chemosphere, conducted by researchers from the Institute of Biochemistry and Molecular Biology in Germany, reveals the varied lethal and sublethal effects of different glyphosate mixtures through tests on the South African clawed frog, Xenopus laevis (X. laevis). After exposing embryos to four glyphosate formulations, mortality, morphological defects, altered heartbeat rate, and impaired heart-specific gene expression are observed. Glyphosate, an herbicide and popular weed killer in many Roundup® products, is one of the most commonly detected pesticides in waterbodies worldwide, threatening aquatic organisms and overall biodiversity.

This study investigates the effects of Glyphosat TF, Durano TF, Helosate 450 TF, and Kyleo, four formulations containing glyphosate, as compared to the effects of pure glyphosate on embryonic development in amphibians. The formulations consist of varying concentrations of the active ingredient glyphosate, as well as other active and inert ingredients. The authors share that, “Glyphosat TF contains 34% glyphosate and 10–20% d-glucopyranose, while Durano contains 39–44% glyphosate and 1–5% N–N-dimethyl-C12-C14-(even numbered)-alkyl-1-amines. In Helosate most of the ingredients are listed – 50–70% glyphosate, 1–10% isopropylamine, 1–3% lauryl dimethyl betaine, 0.25–1% dodecyl dimethylamine. Kyleo only lists the active ingredients glyphosate (27.9%) and 2,4-D (32%).”

2-cell stage embryos (early stage of embryonic development) were utilized as the exposure start point to assess embryo developmental effects within the pesticide solutions. All solutions were prepared with glyphosate concentrations of 0.01, 0.1, 1, 10, and 100 mg/L. “The exposure of embryos to 0.01–10 mg/L glyphosate reflects environmentally relevant concentrations already measured in different countries, with 100 mg/L glyphosate representing ‘worst-case’ scenarios (e.g., incorrect handling or improper disposal), but already measured in water bodies in Argentina,” the researchers state.

Embryos were observed for death every 30 minutes for the first two hours after the start of exposure, and then every 24 hours until they reached stage 44/45. Surviving organisms were analyzed for their general morphological phenotype and potential developmental retardation, as well as embryo mobility, heart rate measurements, immunostaining of the heart, brain and heart measurements, gene expression analysis, and cell apoptosis.

Lethal effects are seen with many of the formulations during the first few days of exposure. “100% embryo mortality was detected after four days (NF-stage 30) of exposure to 100 mg/L glyphosate in Durano,” the authors note. Three days of exposure to 100 mg/L glyphosate in Helosate also shows 100% mortality. Embryos exposed to Kyleo have the most severe lethal effects, as “exposure to Kyleo containing 100 mg/L glyphosate caused 100% mortality within two days (NF-stage 15), while even at 10 mg/L Kyleo exposure led to 96% mortality after five days (NF-stage 33/34).”  

In the surviving organisms, the formulations result in malformations such as reduced eye and head size. These sublethal concentrations are also linked to impaired heart morphology and function, as well as altered expression of heart-specific genes. As compared to the control group, a reduction of the embryos’ heart rate after exposure to all four glyphosate formulations is also seen.

Expression of key cardiogenic genes (mhcα, mef2d, and tnni3) aids in heart muscle cell differentiation and is critical for development. In exposing embryos to each of the four formulations, expression intensity and area were altered for these genes. The researchers report, “[E]xposure to Durano (0.1 mg/L glyphosate) increased the intensity of mhcα expression… Exposure to 0.1 mg/L glyphosate in Helosate led to an increase in the area and intensity of mhcα expression.”

Exposure to 0.1 mg/L glyphosate in both Glyphosat TF and Kyleo led to reduced intensity of mef2d expression. “Helosate (0.1 mg/L glyphosate), on the other hand, resulted in an increase in mef2d expression intensity,” the authors say. The gene tnni3 showed a reduced expression intensity with 0.1 mg/L glyphosate in both Glyphosat TF and Helosate, and helosate exposure also led to an increase in apoptotic cells with the embryos. A study in 2022 has shown that glyphosate and glyphosate-based herbicides (GBH) like Roundup® induce DNA damage and alter biological mechanisms (gene regulatory microRNAs [miRNAs or miRs]) associated with cancer development (See more on altered genes here.)

“Exposure to glyphosate-based herbicides investigated in present study altered the expression levels (area and intensity) of the genes mhcα, mef2d and tnni3 to varying degrees depending on the specific formulation,” the researchers find. “Despite the differences in gene expression among formulations, all showed significant deviations from control embryos, confirming that these formulations disrupt cardiac differentiation in X. laevis embryos.” Altering the embryos of X. laevis down to a molecular level shows the adverse effects of glyphosate and its formulations on key species that can ripple throughout the ecosystem.

“The present study confirmed that glyphosate formulations can have both lethal and sublethal effects on X. laevis embryos. The different formulations selected for exposure experiments showed varying degrees of lethal effects at the same concentrations of the active ingredient glyphosate,” the researchers summarize. With the varied results, the authors hypothesize that the other ingredients play a role in toxicity. “The high lethal effect of the Kyleo formulation (starting at 10 mg/L glyphosate) may be due to the addition of the second active ingredient 2,4-D as this herbicidal active ingredient mimics the plant growth hormone auxin and overstimulates cell division leading to plant death,” they postulate. “[W]e attribute the high mortality observed with Kyleo primarily to a combination effect of different ingredients (glyphosate, 2,4-D, and other ingredients) in the formulation and not to glyphosate alone.”

Currently, the U.S. Environmental Protection Agency (EPA) performs risk assessments on individual active ingredients, ignoring the potential synergistic effects of pesticide mixtures. Beyond Pesticides has long documented how synergy should be included in all pesticide registration processes, as well as the regulatory failures of EPA. (See more here and here.)

This study confirms that glyphosate formulations have a stronger effect on X. laevis embryogenesis than pure glyphosate, leading the authors to conclude that “it is crucial to evaluate the active ingredient and the co-formulations independently, as well as the combined, commercially available products, during pesticide risk assessments and renewal procedures of agrochemicals. The severe global decline of amphibians, partly due to herbicide use, highlights the need for strict and efficient monitoring of environmental pesticide loads and application areas.” (See previous coverage here.)

Formulations containing glyphosate as the active ingredient also incorporate other, often undisclosed, co-formulants. These additional components could alter or intensify the toxicity towards organisms like X. laevis. “To date, the herbicide glyphosate and its various formulations have been widely studied in laboratory, driven by the increasing concerns over their unanticipated effects on a wide range of non-target organisms (from soil microbes to vertebrates) and their potential risks they pose to human health,” the researchers emphasize. “Nevertheless, uncertainties remain regarding their toxicity and effects on aquatic non-target organisms.”

These uncertainties are threatening the health of all organisms, as well as the stability of both aquatic and terrestrial food webs. This study “highlights the importance of evaluating not only the active ingredients but also their combinations in formulations before new authorizations or renewals are granted,” the researchers note. “Given the substantial variation in lethal concentrations across different amphibian species, it is crucial to investigate the effects of herbicides, and more generally pesticides, across a diverse range of taxa to safeguard wildlife and ecosystem stability.”

Biodiversity loss is one of the major and escalating crises today. Impacts on biodiversity cascade to all natural ecosystems and the essential services they provide. “Amphibians are the most severely affected group of all vertebrates, with 40.7% of species facing an acute risk of extinction,” the authors state. With pesticide residues entering water bodies via various routes like spray drift, leaching, and run-off, these impacts on aquatic species need to be prioritized in risk assessments.

The current dependence on petrochemical pesticides and synthetic fertilizers subjects all humans and wildlife to chemicals that bring a myriad of health effects. There is a wide body of science linking pesticide exposure to asthma/respiratory effects, birth/fetal effects, brain and nervous system disorders, cancer, sexual and reproductive dysfunction, learning/developmental disorders, diabetes, immune system disorders, and endocrine disruption.

As the researchers state, “Herbicides, including glyphosate-based formulations, have been widely suggested to act as endocrine disruptors, which is especially critical given the key role of thyroid hormones during the amphibian metamorphosis.” (See additional studies here and here.) Take action to tell EPA that it must consider all data concerning endocrine disruption and must not register pesticides without sufficient data to demonstrate no unreasonable adverse endocrine risk.

National Forum

To learn more, plan to attend Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future! The second session, on Thursday, November 14, 2024, at 1 PM (EST), is with Tracey Woodruff, PhD, MPH, the director of the Program on Reproductive Health and the Environment at the University of California, San Francisco. Dr. Woodruff’s work focuses on uncovering and addressing environmental determinants of disease and health inequities, and she has written groundbreaking material on endocrine-disrupting chemicals. Dr. Woodruff is the author of “Health Effects of Fossil Fuel–Derived Endocrine Disruptors,” published earlier this year in The New England Journal of Medicine.

Roundtable Discussion

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

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

Source:

Flach, H. et al. (2024) Glyphosate formulations cause mortality and diverse sublethal defects during embryonic development of the amphibian Xenopus laevis, Chemosphere. Available at: https://www.sciencedirect.com/science/article/pii/S0045653524025244.

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

Keynote Speaker

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

Roundtable Discussion

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

Paraquat.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

*Mitigation measures have not eliminated harm.

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

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

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

*EPA has sufficient information to ban paraquat.

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

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

Thank you.

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

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

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

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

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

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

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

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

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

Thank you.

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

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

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

PACT Act Analysis

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

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

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

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

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

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

Connection to The Dacthal Standard

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

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

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

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

Call to Action

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

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

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

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

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

Source: Department of Veterans Affairs