(Beyond Pesticides, June 27, 2024) Earlier this month, Public Employees for Environmental Responsibility (PEER) filed a lawsuit against the U.S. Environmental Protection Agency (EPA) on behalf of a group of ranchers and farmers in Texas harmed by biosolids contaminated with per- and polyfluoroalkyl substances (PFAS). The plaintiffs charge that their health and livelihoods were severely damaged due to contaminated biosolids leaching from neighboring properties onto their land. Despite EPA’s responsibility under the Clean Water Act (Section 405(d) and 40 CFR Part 503) to identify toxic pollutants in biosolids and regulate them to protect human health and the environment, the agency has not effectively addressed the dangers posed by PFAS in biosolid fertilizers. EPA’s failure has dramatic impacts on farmers as well as the public, who are eating or drinking PFAS-contaminated crops, dairy milk, beef, or other meat products. The shortcomings of federal regulations underscore the urgent need for a shift in how federal and state agencies approach these issues, prioritizing precaution to prevent future harm. The persistence of these legacy or “forever” chemicals in the environment illustrates the severe consequences of a historically lax regulatory framework in the U.S.  The National Association of State Departments of Agriculture (NASDA) has identified […]

(Beyond Pesticides, June 25, 2024) It has been a couple of weeks since U.S. Senator John Boozman (R-AR), ranking GOP member on the Senate Agriculture Committee, released the Republican framework vision without statutory language for a Senate Farm Bill that would renew the law’s commitment to chemical-intensive agriculture and undermines efforts to curtail pesticide use and hold chemical company polluters accountable. In his press statement, Sen. Boozman issues an approach that largely mirrors the House-side text, passed by the House Agriculture Committee earlier this month in a 33-21 vote. On the same day that Sen. Boozman announced the framework, the House Agriculture Appropriations Subcommittee approved the federal food and agriculture budget for Fiscal Year 2025 with a $355 million cut from last year’s budget, affecting specific programs that support pollinator health, ecosystem health, and public health related to pesticide use and organic agriculture. The full House Appropriations Committee will vote on this budget on July 10 before moving to the House floor. Advocates are adamant in their resolve to demand more – not less – support from Congress to address the climate emergency, insect apocalypse, and public health implications borne from reliance on toxic petrochemical pesticides and fertilizers. The Senate […]

Calls for Holistic Environmental Justice and a Shift Away from Societal Dependence on Petrochemical Pesticides and Fertilizers (Beyond Pesticides, June 18-19, 2024) Juneteenth (June 19) commemorates the date in 1865 when the enslavement of Black Americans ended in the westernmost Confederate state of Texas, over two and a half years after the Emancipation Proclamation of 1863 and the defeat of the Confederacy on April 9, 1865. On June 19, 1865, Union Major General Gordon Granger brought federal troops to Galveston, Texas and finally, and belatedly, implemented the Emancipation Proclamation, which proclaimed on January 1, 1863 freedom from slavery across the nation. Carl Mack, PhD, a historian and former President of the Seattle-King County NAACP, reminds us that there were still 225,000 enslaved Black Americans in Kentucky and Delaware after June 19, 1865 and the end of the Civil War until December 6, 1865 when Georgia became the 27th state to ratify the 13th amendment. “That is the day in which Georgia ratified the 13th amendment,” Dr. Mack goes on to discuss the remaining three former border states on their progress in adopting the 13th amendment. “As it applies to Delaware and Kentucky, Delaware did not ratify the 13th amendment until […]

(Beyond Pesticides, June 10, 2024) Expanding the planting of genetically engineered crops is the major focus of “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology” (Framework), released in May by three federal agencies. In its Framework, the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) use the words “exempt” or “exemption” in reference to federal safety regulations 21 times. Then, another 21 times the agencies identify their efforts to “streamline” the process for bringing genetically engineered “plant-incorporated protectants” (PIPs) to market. Without including the word “resistance” even once, the Framework advances the interests of the biotech and allied industries, ignoring the serious scientific issues regarding health and environmental effects and the economic failure for farmers facing crop loss. Meanwhile, the issue of resistance is not new to EPA, which has for years acknowledged the resistance problem despite allowing continued weed resistance to weed killers used with herbicide-tolerant crops and insect resistance to the pesticides incorporated into plants.   >> Tell USDA, FDA, and EPA to replace agricultural provisions in the Framework with policies that discourage GE crops […]

(Beyond Pesticides, June 3, 2024) Environmental advocates continue to raise concerns about the Farm Bill (H.R.8467—Farm, Food, and National Security Act of 2024) that emerged from the House Agriculture Committee on May 23 with provisions they say will allow the escalation of environmental threats and then insure big agriculture commodity producers for losses attributable to those environmental disasters through an expansion of USDA’s crop insurance program. Through this taxpayer supported program, USDA covers farm revenue losses due to “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” Petrochemical pesticide and fertilizer use in chemical-intensive land management and agricultural production contributes to the climate emergency and associated weather, insect, and plant disease threats. Advocates point out that the House Agriculture Committee Farm Bill reduces environmental protections by (i) preempting local and state government authority to allow more restrictive standards at the municipal level, (ii) taking away the right to sue pesticide manufacturers and allied companies for a failure to fully disclose adverse effects of the products they produce or use, and (iii) weakening the regulatory process intended to protect endangered species and biodiversity from pesticides.   Tell Your U.S. Representative and Senators To Support […]

(Beyond Pesticides, May 31, 2024) Among the many promises that have been made by agribusiness to farmers and consumers, the glories of crops genetically engineered (GE) to resist pests stand out. GE tools—genes—were touted as “natural,” and promised to reduce the use of toxic pesticides. The first such plants incorporating DNA or RNA from other organisms hit the market in the 1990s. Today more than 70% of all GE organisms are engineered to tolerate herbicides, and the overwhelming majority of corn, soybean and cotton varieties are engineered to to be toxic to insects. See Beyond Pesticides’ backgrounder on GE here. Despite a dramatic increase in the use of herbicides and the fast development of weed and insect resistance to plant incorporated pesticides, this month the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) jointly released a document entitled “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology.” It responds to a 2022 executive order by President Biden to “accelerate biotechnology innovation” and “support the safe use of biotechnology products” by using a “science- and risk-based, predictable, efficient, […]

(Beyond Pesticides, May 30, 2024) The House Agriculture Committee voted 33-21 on May 23 to move the Farm, Food, and National Security Act out of committee after a contentious markup and onslaught of amendments that undermine water health, soil health, and local democratic authority to protect people and the environment from toxic pesticide exposure. One of nearly sixty amendments introduced in the markup last week included the continuation of a decade-long attack on National Pollutant Discharge Elimination System (NPDES) permit via Clean Water Act (CWA) for pesticide discharge. What was most illuminating however was not the passage of the bill itself, but Big Agriculture’s raucous approval. Advocates see pesticide industry and its allies’ support for what it is—the reliance on petrochemical-based pesticides leading to economic instability, ecosystem collapse, and the degradation of democratic institutions. With support for entrenched dependency on petrochemical pesticides and fertilizers, the committee’s bill requires taxpayers to pay through the government’s crop insurance program for escalating losses caused by chemical-intensive farming practices, contributing to yield losses that the U.S. Department of Agriculture (USDA) says are “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” However, the frequency of these […]

(Beyond Pesticides, May 28, 2024) Public comments are due May 29, 2024. With 40 percent of all vegetables grown in the U.S. coming from the state of California, the current state level process to define “regenerative agriculture” could have major impact on land management practices that address the current climate, biodiversity, and health crises. That is, according to advocates, if the process, directed by the California Department of Food and Agriculture (CDFA) departs from a history of poorly defined and unenforceable terms like Integrated Pest Management (IPM) and Sustainable Agriculture. Virtually all consumers of food have a stake in the outcome of the definition of “regenerative,” so the current public comment period, which closes tomorrow, May 29, 2024, can help influence the outcome. As Beyond Pesticides has reported previously, the term “regenerative” is now increasingly being advanced as a loosely defined alternative to the organic standard and label, which is transparent, defined, certified, enforced, and subject to public input. The  publication AgFunderNews (AFN) in February published its updated “2024 list of agrifood corporates making regenerative agriculture commitments,” a who’s who of the largest food and agribusiness corporations worldwide. The list includes companies such as ADM, Cargill, Danone, General Mills, Tyson, Unilever, Walmart, and more with commitments […]

(Beyond Pesticides, May 21, 2024) In a first-of-its kind series of biomonitoring studies published in Agrochemicals, researchers identified the presence of the herbicides dicamba and 2,4-D in all pregnant participants from both cohorts in 2010-2012 and 2020-2022. The findings from this research are not surprising given the explosion of toxic petrochemical pesticides in the Midwest region of the United States. “The overall level of dicamba use (kilograms applied in one hundred thousands) in the U.S. has increased for soybeans since 2015 and slightly increased for cotton and corn,” the authors report, based on U.S. Department of Agriculture National Agriculture Statistics Service surveys. “The overall level of 2,4-D use (kilograms applied in one hundred thousands) in the U.S. was highest in 2010 for wheat, soybeans, and corn. The amount of 2,4-D applied increased the most for soybeans and corn from 2010 to 2020.” The researchers focused on the states of Illinois, Indiana, and Ohio, given the increase in dicamba and 2,4-D during the study period for both cohorts (2010-2022). The researchers are based at Indiana University School of Medicine in the Department of Biostatistics and Health Data Science and Department of Obstetrics and Gynecology, Quebec Toxicology Center within the Institut national […]

(Beyond Pesticides, May 6, 2024) The pattern of failure to protect the public from pesticides is again brought to public attention by an analysis by Consumer Reports (CR) that effectively updates its previous report released in 2020. The report and its earlier iteration identify deep structural weaknesses with the institutions charged with protecting the public’s health and safety. The health risks outlined by CR in 2020 and related to ongoing pesticide exposure, even at low levels, include cardiovascular diseases, cancers, reproductive dysfunction, respiratory problems (e.g., asthma, bronchitis), neurological impacts (e.g., developmental effects and dementia/Alzheimer’s), and endocrine dysfunction, among others. Previously, the magazine reported, “CR’s experts say the government hasn’t upheld its responsibility to protect consumers [and that] the research used to set [pesticide residue] tolerances is imperfect, and they’re often too high.” CR has cited the U.S. Environmental Protection Agency (EPA), which is primarily responsible for pesticide regulation, for multiple inadequacies. According to the latest CR analysis, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% […]

(Beyond Pesticides, May 1, 2024) According to a new analysis by Consumer Reports, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. A review of seven years of PDP data 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, according to Consumer Reports analysis. Consumer Reports contend that U.S. Environmental Protection (EPA) pesticide residue tolerances are too lenient. To better evaluate potential health risks associated with various foods, Consumer Reports applied stricter residue limits than the EPA tolerances (see here for CR’s analytical methodology). Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a function of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. The Consumer Reports results fly in the face of the rosy outlook reported by the USDA in its 2022 […]

(Beyond Pesticides, April 24, 2024) On April 16, 2024, the U.S. Environmental Protection Agency (EPA) posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency’s efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers’ “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, advocates are again questioning EPA’s commitment to fulfilling legal requirements under the Endangered Species Act (ESA) or protecting endangered species and their habitats in the midst of an unprecedented rate of global extinction. ESA is celebrated as one of the most far-reaching conservation laws globally, credited with preventing the extinction of 99 percent of those species the government targets for protection, according to the U.S. Fish and Wildlife Service (USFWS). ESA establishes a framework to categorize species as “endangered” or “threatened,” granting them specific protections. Under ESA, EPA is required to consult with relevant agencies […]

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

(Beyond Pesticides, April 1, 2024) Comments are due 11:59 pm EDT, Wednesday, April 3. For the public comment period—deadline Wednesday, April 3—in the lead up to the National Organic Standard Board (NOSB) meeting, advocates have identified the following priority issues: Getting plastics our of organic; Removing endocrine disrupting nonylphenols (NPs) and nonylphenol ethoxylates (NPEs) iodine from dairy production and replace with available alternatives; and Continuing to improve the science supporting ongoing decisions of the NOSB. (See below for details and opportunity to submit comments on these with one click!) Previously, Beyond Pesticides has reported on three additional priority issues, including; Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production; Eliminate nonorganic ingredients in processed organic foods as a part of the Board’s sunset review of allowed materials; and  Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment.  (Please see the prior action on these issues and submit comments, if not done previously.) Beyond Pesticides asks the public to join in commenting on priority issues that protect health and the environment as part of the upcoming NOSB meeting. The NOSB is receiving written comments from the […]

(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 18, 2024) Comments are due by 11:59 pm EDT on April 3, 2024. Organic standard setting provides for democratic input, full transparency, and continuous improvement. The current public comment period is an important opportunity for the public to engage with the organic rulemaking process to ensure that the National Organic Standards Board (NOSB) and the USDA National Organic Program uphold the values and principles set forth in the Organic Foods Production Act (OFPA). With the threats to health, biodiversity, and climate associated with petrochemical pesticide and fertilizer use in chemical-intensive land management, advocates stress that this is critical time to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards, public input, inspection system, and enforcement mechanism. But, organic will only grow stronger if the public participates in voicing positions on key issues to the NOSB, a stakeholder advisory board. Beyond Pesticides has identified key issues for the upcoming NOSB meeting below! The NOSB is receiving written comments from the public on key issues through April 3, 2024. This precedes the upcoming public comment webinar on April 23 and 25 and the deliberative hearing on April 29 through […]

(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 15, 2024) The latest U.S. Department of Agriculture (USDA) pesticide residue report, the 32nd Pesticide Data Program (PDP) Annual Summary report, released in January, finds that over 72 percent of tested commodities contain pesticide residues (27.6 percent have no detectable residues), mostly below the level the U.S. Environmental Protection Agency (EPA) has set for tolerances (allowable residues) whose safety standards have been called into question by advocates. USDA spins its report findings as a positive safety finding because, as the Department says, “[m]ore than 99 percent of the products sampled through PDP had residues below the established EPA tolerances.” USDA continues, “Ultimately, if EPA determines a pesticide use is not safe for human consumption, EPA will mitigate exposure to the pesticide through actions such as amending the pesticide label instructions, changing or revoking a pesticide residue tolerance, or not registering a new use.” As Beyond Pesticides reminds the public annually when USDA uses the report to extol the safety of pesticide-laden food, 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, children, and perhaps, […]

(Beyond Pesticides, January 22, 2024) Today, Monday, January 22, is the last day for public comment on a three-year extension of U.S. Department of Agriculture’s (through its Agricultural Marketing Service’s National Organic Program (NOP)) authority to collect information from certifiers entrusted with ensuring compliance with organic standards. Beyond Pesticides, along with allied organizations and organic advocates, is urging USDA to use this process to clarify the need for USDA to collect key information needed to verify compliance with key language in OFPA (Section 6513(b))—a provision that requires farming practices that “foster soil fertility.” Advocates maintain that information on organic farmers’ practices to foster soil fertility, required in the law, is critical to organic integrity, public trust in the organic label, and certifier responsibility. As USDA states, “The Organic Foods Production Act of 1990 (OFPA), as amended (7 U.S.C. 6501–6524), authorized the Secretary of Agriculture to establish the National Organic Program (NOP) and accredit certifying agents to certify that farms and businesses meet national organic standards. Under OFPA, the purpose of the NOP is to: (1) establish national standards governing the marketing of certain agricultural products as organically produced products; (2) assure consumers that organically produced products meet a consistent standard; […]

Update: This Daily News is updated to address the organic status of the company cited in the piece, Merchant’s Garden. The article now indicates that the company is certified as organic under a different name (Merchant’s Garden Agrotech) than the name used in the USDA press release.  As a result, their name did not appear in USDA’s Organic Integrity Database (OID) at the time of the original Daily News and Action of the Week posting. USDA updated OID on December 8, 2023, the same day that it received a complaint on this matter from former National Organic Standard Board chair Jim Riddle. The critical focus of the piece remains the same: It is not disclosed to consumers on food products labeled “organic” when that food or ingredients are grown hydroponically. Beyond Pesticides, as indicated in the article, views hydroponic as a conventional growing practice that does not meet the spirit and intent of the organic system, as defined in the Organic Foods Production Act.  (Beyond Pesticides, December 11, 2023) U.S. Department of Agriculture (USDA) Secretary Tom Vilsack announced on November 27, 2023 funding that appears to be supporting the expansion of “organic” hydroponic, an approach to food production that has […]

(Beyond Pesticides, September 25, 2023) It happens twice a year. The transparent process of a stakeholder board of farmers, consumers, environmentalists, a scientist, retailer, and certifier get together as members of the National Organic Standards Board (NOSB) and vote on allowable materials and standards in organic agriculture. This Congressionally mandated board has authorities not often given to people outside of government—authorities to determine what should be allowed in organic food production, under assessments of synthetic and natural substances. And the underlying law that makes this happen, the Organic Foods Production Act (OFPA), stipulates that the Secretary of Agriculture may not allow synthetic and prohibited natural materials unless they are recommended by the NOSB. The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by September 28, 2023. The values and principles embedded in OFPA far exceed the standards of health and environmental protection of any other health and environmental laws, which establish risk mitigation measures to determine allowable harm, under a set of guiding standards that require the board to (i) protect health (from production of inputs to their disposal), (ii) ensure compatibility with organic systems (with determinations that inputs do not hurt […]