(Beyond Pesticides, April 16, 2024) Citing serious health issues associated with its use, including Parkinson’s disease, and inaction by the U.S. Environmental Protection Agency (EPA), the weed killer paraquat would be banned through legislation introduced in the California Assembly (AB 1963). Assemblymember Laura Friedman (D-Burbank), in the Assembly’s leadership, chair of the bicameral Environmental Caucus, and a self-described “steadfast advocate for the environment [and] sustainable communities,” introduced the legislation to phase out and ban the use of paraquat across all uses, including agriculture, by the end of 2025. The introduction of this bill follows a long history of scientific documentation of the pesticide’s hazards, fits and starts in the regulatory process, and previous efforts to ban the herbicide through legislative action. In 2018, U.S. Representative Nydia Velasquez (D-NY) introduced legislation (Protect Against Paraquat Act) to ban paraquat. In a 1986 factsheet, Beyond Pesticides wrote, “In mammals, paraquat attacks the epithelial tissues (the skin, nails, the cornea of the eye, and the linings of the respiratory and gastrointestinal tract). There have also been reports of damage to the heart muscle and to nerves. It is easily absorbed through the skin as well as orally [and through inhalation]. Paraquat causes specific damage […]

(Beyond Pesticides, April 15, 2024) At first, some thought this was an April Fools’ announcement by pranksters like the YES men. Put out an announcement pretending to be the U.S. Environmental Protection (EPA) with a warning to farmworkers that they are being exposed to a highly hazardous weed killer, dacthal (dimethyl tetrachloroterephthalate or DCPA), offering no protection. The announcement says, “EPA is warning people of the significant health risks to pregnant individuals and their developing babies exposed to DCPA” and notes that the agency will be “pursuing” further action at some unspecified time in the future. But, this was no joke, especially for farmworkers. The agency somehow believed it was fulfilling its statutory duty to protect farmworkers and their families with a warning that a chemical they may be exposed in their workplace and possibly their homes and schools is harming them and, for those pregnant, destroying the health of their fetus. “In light of the workplace reality for farmworkers, the lack of labor protections, and the documented deficiencies in the existing worker protection standards, it is difficult to conceive of how EPA officials think this warning is protective in any way. And in light of what agency officials know, or […]

(Beyond Pesticides, April 11, 2024) Scientists are moving forward in testing an agroecological method of “push-pull” pest management (reducing the attractiveness of the target organism and luring pest insects towards a trap) to fight the Asian citrus psyllid (ACP) in Florida orange groves, as it spreads a plant disease known as the pathogenic bacteria huanglongbing (HLB), also known as citrus greening, which is deadly to citrus trees. The disease is spread by the pathogenic bacteria Candidatus Liberibacter asiaticus (CLas).  The chemical-intensive, or conventional, citrus industry is under intense pressure to find alternatives, as synthetic antibiotic use for this purpose has been successfully challenged in court. ACP is the carrier, or vector, for HLB, spreading it through the citrus groves and killing the trees. The chemical-intensive industry has focused on using antibiotics, which the environmental and public health community has rejected because of serious medical concerns associated with life-threatening bacterial resistance to antibiotics used to protect humans. A federal district court decision in December 2023 found illegal the U.S. Environmental Protection Agency’s (EPA) decision to register the antibiotic streptomycin in Florida citrus without adequate review of its impact on endangered species. The streptomycin lawsuit, filed in 2021 by a coalition of […]

(Beyond Pesticides, April 9, 2024) The United States Court of Appeals for the Fifth Circuit, in an opinion authored by Circuit Judge Cory T. Wilson, has vacated an action by the U.S. Environmental Protection  Agency (EPA) that had ordered the Texas-based manufacturer Inhance Technologies, L.L.C. to stop producing plastic containers that leach toxic per- and polyfluoroalkyl substances (PFAS) into pesticides, household cleaners, condiments, and additional products. EPA has taken action after the agency determined that the PFAS created during the fluorination process “are highly toxic and present unreasonable risks that cannot be prevented other than through prohibition of manufacture.” While the court is not challenging EPA’s authority to determine the hazards associated with PFAS exposure to be unacceptable, on a technicality, it is finding that the agency used the wrong section of the Toxic Substances Control Act (TSCA), Section 5, which the court says is focused on new uses. According to the Court, “The EPA is just not allowed to skirt the framework set by Congress by arbitrarily deeming Inhance’s decades-old fluorination process a “significant new use,” even though EPA’s awareness of the PFAS contamination was “new” to the agency and not disclosed by the manufacturer. Even if EPA were […]

(Beyond Pesticides, March 27, 2024) A preliminary experiment conducted by Public Employees for Environmental Responsibility (PEER) reveals concerning levels of toxic per- and polyfluoroalkyl substances (PFAS) on the skin of soccer players and coaches after playing on artificial turf fields. The Washington Post reported on March 12 on the PEER test results, which found PFAS levels increased on the skin in three out of four participants following soccer matches on artificial turf. In contrast, no similar increase was observed after games on natural grass fields. The presence of PFAS is alarming due to their association with several serious health issues, including cancer, birth defects, and developmental and immune deficiencies, among others. The U.S. Environmental Protection Agency (EPA) writes that PFAS exposure risks are particularly concerning for young children, who are more susceptible due to their developing bodies and at risk for higher levels of exposure than adults. Known as “forever chemicals” for their persistence in the environment, PFAS continue to accumulate in the human body, posing long-term health risks. Kyla Bennett, PhD, science policy director at PEER and a former scientist and lawyer with EPA, emphasized the need for further research. “Although this study is preliminary, it highlights the potential […]

(Beyond Pesticides, March 25, 2024) Because of their widespread infiltration into the environment and the bodies of all organisms, including humans, plastics contamination requires a holistic strategy to protect life— with consideration given to practices and chemical use that reduce or eliminate harm. Pesticides and other toxic chemicals are adsorbed (adhered) to microplastics, resulting in bioaccumulation and widespread contamination. This adds to the complexity of the problem, which is largely ignored by federal regulatory agencies. While most environmental policies attempt to clean up or mitigate health threats, new data reinforces the need to stop the pipeline of hazardous chemicals, wherever possible. With new data on the harm associated with plastics and related contamination, it becomes urgently necessary for all government agencies to participate in a comprehensive strategy to eliminate plastics and pesticides. Beyond Pesticides points to the evolving science on plastics contamination and their interaction with pesticides as yet another reason to transition to holistic land management systems that take on the challenge of eliminating hazardous chemical use. Organic land management policy creates the holistic systems framework through which plastics can be eliminated. >> Tell USDA, EPA, and FDA to create strong restrictions on plastics in farming, water, and food. […]

(Beyond Pesticides, March 21, 2024) Alarming levels of a hazardous pesticide plant growth regulator linked to reproductive and developmental effects, chlormequat, is found in 90% of urine samples in people tested, raising concerns about exposure to a chemical that has never been registered for food use in the U.S. but whose residues are permitted on imported food. Published in the Journal of Exposure Science and Environmental Epidemiology in February 2024 and led by Environmental Working Group toxicologist Alexis Temkin, PhD, a pilot study finds widespread chlormequat exposure to a sampling of people from across the country. U.S. Environmental Protection Agency (EPA) regulations only permit the use of chlormequat on ornamental plants and not food crops grown in the U.S. As explained in the journal article, “In April 2018, the U.S. EPA published acceptable food tolerance levels for chlormequat chloride in imported oat, wheat, barley, and some animal products, which permitted the import of chlormequat into the U.S. food supply.” In 2020, EPA increased the allowable level of chlormequat in food. Then in April 2023, EPA proposed allowing the first-ever U.S. use of chlormequat on barley, oat, triticale (a hybrid of wheat and rye), and wheat. Existing regulatory standards explain the […]

(Beyond Pesticides, March 20, 2024) A report by CBAN unpacks the ecosystem and wildlife health impacts of genetically engineered (GE) corn in the context of Mexico’s 2023 decision to stop its importation into the country. The phase out of genetically modified (GM) corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA), which replaced the North American Free Trade Agreement (NAFTA) as the primary vehicle for North American trade policy. In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban. There has been no public update from the Office of the U.S. Trade Representative as of this writing. The CBAN report highlights the scientific rationale underpinning Mexico’s decision to “safeguard the integrity of native corn from GM contamination and to protect human health” with this ban. In 2020, Mexico announced a four-year phase-out of the weed killer glyphosate, which along with other petrochemical herbicides is integral to GM corn production. When Mexico’s Minister of the Environment announced the phase-out, he said it is part of an effort to transform the country’s food system […]

(Beyond Pesticides, March 11, 2024) Inside a recent disagreement between the Office of the Inspector (OIG) and the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) on the agency’s review of pet flea and tick collars—leading to thousands of deaths and poisonings—is a basic question of the adequacy of pesticide regulation. The disagreement is over the cause of 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury, and the February 2025 OIG report’s conclusion that “[EPA] has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” While the disagreement focuses on a number of EPA process failures, Beyond Pesticides urges that the findings advance the need for the agency to address a key element of chemical mixtures in pesticide products not currently evaluated, potential synergistic effects—the increased toxic potency created by pesticide and chemical combinations not captured by assessing product ingredients individually.  Key to the dispute is what many see as a foundational failure of EPA to evaluate the effect of pesticide mixtures and full formulations of pesticide end products, a longstanding criticism of the agency’s pesticide registration process, which focuses on pesticide products’ active […]

(Beyond Pesticides, March 8, 2024) A major problem has vexed pesticide regulators and researchers for decades: Humans and other organisms almost always have multiple pesticides in their bodies, but techniques for assessing their combined effects, or cumulative body burden from multiple chemical classes are not typically available. A new study from Chinese and British researchers provides the first combined assessment of multiple classes of pesticides in human blood. The authors believe they are the first to develop a way to quantify multiple types of pesticides in human serum (clear liquid part of blood) as opposed to urine or from other sample collection methods. This is a tool that authors say is a more accurate way of assessing the real world exposure and ultimately the adverse impact of pesticide use on human health. The researchers had a small sample of 31 men and 34 pregnant women in Wuxi, China. They chose 73 pesticides and a few of their breakdown products to identify from three categories: fungicides, neonicotinoid insecticides, and triazine herbicides. Their testing protocol confirms their expectation that food—primarily produce—is the major source of pesticide exposures. This result reinforces Beyond Pesticides’ mission of supporting the shift in agriculture to pesticide-free methods […]

(Beyond Pesticides, March 6, 2024) With over 2,500 pet deaths and 900 reports of adverse effects to people, an Office of Inspector General (OIG) report, published on February 29, 2024, reveals multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP), citing inadequate safety reviews of Seresto pet collars. The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data… No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars—the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid—proven to have adverse effects on the endocrine system as […]

(Beyond Pesticides, March 5, 2024) Buried in a court decision in February that determined that the U.S. Environmental Protection Agency (EPA) violated the law in allowing harm associated with the herbicide dicamba’s registration is language that permits the damages to continue through this year’s growing season. The judge’s ruling, deferring to EPA’s interpretation of the existing stock provision in the federal pesticide law, continues a pattern of “existing stock” allowances that permit hazards to continue well after a finding of harm or noncompliance. This process contrasts with the issuance of a product recall, which is typically done when pharmaceuticals are found to violate safety standards. Despite the finding of dicamba’s harm and EPA’s failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA’s 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. EPA’s pattern of allowing the use of existing stocks has long been a concern for public health and environmental advocates, who have called for the discontinuance of use upon findings of […]

(Beyond Pesticides, March 4, 2024) With 14.7 million children and adolescents in the U.S. recognized as obese by the Centers for Disease Control and Prevention (CDC) and the established connection with endocrine disrupting contaminants, including many pesticides, Beyond Pesticides is calling on federal food assistance programs to go organic. The problem of childhood obesity is higher in people of color and, as a result, is an environmental justice issue. According to CDC, the prevalence of childhood obesity is “26.2% among Hispanic children, 24.8% among non-Hispanic Black children, 16.6% among non-Hispanic White children, and 9.0% among non-Hispanic Asian children.” While childhood obesity is recognized as a serious problem, the National School Lunch Program of the U.S. Department of Agriculture (USDA)—although improved by the Healthy, Hunger-Free Kids Act of 2010—still provides lunches laced with obesogenic pesticides. To take meaningful steps against childhood obesity, school lunches must be organic. The program served 4.9 billion meals in fiscal year 2022 in over 100,000 public and nonprofit schools, grades Pre-Kindergarten-12. Contrary to popular opinion, the blame for the obesity epidemic cannot be attributed solely to diet and exercise broadly, but relates directly to pesticide and toxic chemical exposures, including residues in food, that may lead […]

(Beyond Pesticides, February 29, 2024)  In the face of federal inaction, an Oregon regulation banning the agricultural uses of the highly toxic chlorpyrifos took effect on January 1, 2024. Chlorpyrifos was voluntarily withdrawn from the market in 2000 for most residential uses by its manufacturer, Dow Chemical, and has been the subject of extensive litigation. At that time, the U.S. Environmental Protection Agency (EPA) allowed most agricultural uses to continue. Oregon joins four other states that have acted to ban chlorpyrifos, including Hawai’i, New York, California, and Maryland.   Central to state action are nervous system and brain effects in children, especially farmworker children. Chlorpyrifos is banned in 39 countries, including the European Union (see here for more Beyond Pesticides coverage). State action has become important since the November 2023 decision by the U.S. Court of Appeals for the 8th Circuit, which overturned the EPA rule revoking all food tolerances for chlorpyrifos, an effective ban on chlorpyrifos use. The final EPA rule, issued in August 2021, came in response to a 9th Circuit Court of Appeals ruling that found the agency’s inaction on chlorpyrifos unlawful. The case was filed by Earthjustice, on behalf of public health, labor, and disability organizations.  The […]

(Beyond Pesticides, February 28, 2024) The U.S. Environmental Protection Agency (EPA) is putting on hold its Vulnerable Species Project (VSP) after vociferous comments from the petrochemical pesticide industry to instead, “create a narrow, tailored policy rather than a sweeping, burdensome one,” according to a recent op-ed in the Wall Street Journal. Upon heavy pushback from the petrochemical pesticide industry and agribusiness, EPA is hosting a variety of workshops and openings for the public to provide feedback not just on VSP, but the Endangered Species Act (ESA) Workplan the Biden Administration originally introduced in 2021 in its entirety. Advocates are calling for the strengthening of pesticide regulation given the impending decisions that may shape the fate of ESA-FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) compliance for years to come. As EPA continues through its pesticide registration program to advance continued dependency on pesticides through its interpretation of FIFRA, despite the availability of nontoxic alternatives, endangered species extinction and biodiversity collapse has never been a high priority. While EPA has initiated efforts to address a significant backlog of pesticide evaluations, Civil Eats has reported that the agency faces a task so extensive that it may require several additional decades to fully catch up. EPA officials stated, “Even if EPA completed […]

(Beyond Pesticides, February 26, 2024) Beyond Pesticides today launched an action to stop a nationwide campaign by chemical manufacturers to shield themselves from liability cases filed by those who have been harmed by pesticide products. As widely reported, Bayer/Monsanto has been hit with numerous jury awards and settlements totaling billions of dollars for adverse health effects associated with their weed killer glyphosate (RoundupTM). After unsuccessfully seeking U.S. Supreme Court review of two of these cases, the industry is now pushing legislation in state legislatures that will shield them from future liability litigation. This is not the first time that the pesticide and toxic chemical industry has sought protection from the states after losing in the highest U.S. Court. After the Supreme Court upheld the right of localities to restrict pesticides more stringently than the U.S. Environmental Protection Agency and state regulatory agencies in Wisconsin Public Intervenor v. Mortier (501 U.S. 597, 1991), the industry went to every state legislature in the country to seek state preemption of their local jurisdictions’ authority to restrict pesticides. They were successful in putting state preemption laws in place in 43 states and have since added another.   Having failed in the courts, history is […]

(Beyond Pesticides, February 21, 2024) In addition to its effects including cancer, and reproductive, immune or nervous system disruption, according to international findings, a review published in Toxics finds that the the widely used weed killer 2,4-dichlorophenoxyacetic acid (2,4-D) causes significant changes in liver structure and function. 2,4-D can damage liver cells, tissue, and inflammatory responses through the induction of oxidative stress. The liver, the largest solid organ in the human body, is an essential part of the digestive system responsible for blood detoxification, nutrient metabolization, and immune function regulation. However, rates of chronic liver diseases are increasing, representing the second leading cause of mortality among all digestive diseases in the U.S. In fact, researchers warn of the rise in liver disorders and metabolic syndrome among young people. Therefore, reviews like this highlight the research available to make decisions on safeguarding human health from chemical exposure to mitigate further disease outcomes and complications. 2,4-D is used on turf, lawns, and rights-of-way, as well as in forestry and aquatic systems. 2,4-D products are available as liquid, dust, and granule fields, as well as fruit and vegetable crops, including in genetically engineered crop production. The chemical is widely used in “weed and feed” lawn products. It is […]

(Beyond Pesticides, February 20, 2024) With health risks including developmental, metabolic, cardiovascular, and reproductive harm, cancer, damage to the liver, kidneys, and respiratory system, as well as the potential to increase the chance of disease infection and severity, per- and polyfluoroalkyl substances (PFAS) and their toxic trail of contamination in the environment is wreaking havoc with all life. The use of PFAS in industrial and commercial applications has led to widespread contamination of water and biosolids used for fertilizer, poisoning tens of millions of acres of land and posing a significant threat to the biosphere, public health, gardens, parks, and agricultural systems. Farmers and rural communities, in particular, bear the brunt of this contamination, as it affects their drinking water, soil quality, and livestock health.   Tell Congress that the Farm Bill must include the Relief for Farmers Hit with PFAS Act and the Healthy H2O Act to protect farmers and rural communities from PFAS contamination.  Led by Chellie Pingree (D-ME), U.S. Senators Tammy Baldwin (D-WI), and Susan Collins (R-ME), a bipartisan and bicameral bill—the Relief for Farmers Hit with PFAS Act—has been introduced to provide assistance and relief to those affected by PFAS. A second bill, the Healthy H2O Act, introduced by Representatives Pingree and David Rouzer (R-NC) and Senators Baldwin […]

(Beyond Pesticides, February 16, 2024) A report released in January, US pesticide regulation is failing the hardest-hit communities. It’s time to fix it, finds “people of color and low-income communities in the United States and around the world continue to shoulder the societal burden of harmful pollution.” More specifically, the authors state that “ongoing environmental injustice is the disproportionate impact these communities suffer from pesticides, among the most widespread environmental pollutants.” The report follows an earlier article by the same lead authors and others (see earlier coverage) on the long history of documented hazards and government failure to protect farmworkers from pesticide use in agriculture. In a piece posted by Beyond Pesticides earlier this week, the serious weaknesses in the worker protection standard for farmworkers are documented.   The latest report was led by Nathan Donley, environmental health science director at the Center for Biological Diversity and Robert Bullard, known as the “Father of Environmental Justice” and executive director of the Robert D. Bullard Center for Environmental and Climate Justice at Texas Southern University in Houston. In addition to these authors, the 2022 review was coauthored by Jeannie Economos of the Farmworker Association of Florida, Iris Figueroa of Farmworker Justice, Jovita […]

(Beyond Pesticides, February 14, 2024) The latest in a series of reports on the state of farmworker protection, released last December, highlights the long history of health threats, regulatory failures, and structural racism that is imbued in the chemical-intensive agricultural system that feeds the nation and world. The authors conclude that farmworkers “face a level of occupational risk unrivaled by most workers.” They continue: “From repeated exposure to pesticides and extreme heat, to injuries from machinery and repetitive motion, conditions on American farms involve myriad hazards. Meanwhile, a lack of access to healthcare and legal services, low wages, marginalization, language barriers, racism, and the threat of deportation among these largely immigrant communities compound their many challenges.” Describing the U.S. food system and the workers who serve as its foundation, Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety is the third publication in a series of reports on farmworker health and safety, led by the Center for Agriculture and Food Systems (CAFS) at Vermont Law and Graduate School and written with the Harvard Law School Food Law and Policy Clinic and the nonprofit group Farmworker Justice. Johns Hopkins Center for a Livable Future and Farmworker Justice partnered on the […]

(Beyond Pesticides, February 13, 2024) Last week, the United States District Court for the District of Arizona struck down the U.S. Environmental Protection Agency’s (EPA) 2021 approval of three dicamba-based herbicides. This is the second lawsuit since 2020 to call out EPA’s violation to both the Endangered Species Act (ESA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to authorize the use of over-the-top (OTT) dicamba-based herbicide products from Bayer and other petrochemical pesticide companies. This rejection of dicamba-based herbicides fuels advocates’ push for stronger regulatory actions by EPA for all petrochemical pesticides and their push for the more widespread adoption of organic practices that do not use these chemicals. The case was filed by Center for Food Safety (CFS), Center for Biological Diversity, National Family Farm Coalition, and Pesticide Action Network North America. Beyond Pesticides has covered the dicamba tragedy for years, including the EPA Office of the Inspector General’s critical 2021 report, EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision. The report identifies EPA’s abandonment of science and assault on agency integrity. In addition to citing adverse impact on nontarget crops and the environment, the Court zeroes in on EPA’s failure to adequately manage […]

(Beyond Pesticides, February 12, 2024) Public Comments Due February 23, 2024. As the U.S. Environmental Protection (EPA) takes public comments on its updated scientific integrity policy (until February 23, 2024), Beyond Pesticides issued an action and reminds the agency that when it fails to carry out its mission to protect health and the environment—by allowing use of pesticides that are known to be hazardous and not fairly and scientifically evaluated, it is responsible for a toxic tragedy that has debilitating and deadly consequences for people and the ecosystems critical to sustaining life. Key to the recommendations Beyond Pesticides is urging EPA to consider are the following: (i) incorporate independent and emerging science into its chemical reviews; (ii) Update protocol to keep pace with new science; (iii) address vulnerabilities of those at highest risk, including those with preexisting health conditions; (iv) consider safer alternatives in calculating unreasonable risk; (v) disclose uncertainties associated with agency science or data gaps, and (vi) establish criminal penalties for EPA staff integrity violations. In the wake of intense criticism of the U.S. Environmental Protection Agency’s (EPA) scientific integrity, the agency has announced updates to its scientific integrity guidelines. As the agency acknowledges in its 2012 Scientific Integrity Policy: […]

(Beyond Pesticides, February 9, 2024) EPA is accepting public comments through today, Friday February 9, on its long-held policy of exempting “treated objects,” including seeds and paint, from pesticide registration. Although EPA does not ask the most important question—“Should pesticide-treated seeds and paint be exempt from the scrutiny given pesticide products?”—this comment period offers an opportunity to respond to EPA’s questions and express concern about hazards associated with chemical use and product ingredients. Despite exposure patterns associated with the use of pesticides in treated objects that are linked to environmental contamination and human poisoning, EPA is focused on labeling and not regulation. Instead of focusing on the exposure and harm associated with the object’s use—whether treated seeds poison pollinators, soil, and water or whether paint treated with fungicides poisons people exposed to the paint—EPA takes the position that unless the manufacturer makes a pesticidal claim, the object is not regulated as a pesticide for its pesticidal effects.  Beyond Pesticides states: At the very least, if EPA deems the hazards associated with the use of the pesticide in the treated article acceptable, then the agency should disclose the chemical used in the treatment (of the seed or the paint) and require […]