(Beyond Pesticides, September 22, 2020) Use of the highly hazardous, endocrine disrupting weed killer atrazine is likely to expand following a decision made earlier this month by the U.S. Environmental Protection Agency (EPA). Under the guise of “regulatory certainty,” the agency is reapproving use of this notorious herbicide, as well as its cousins simazine and propazine in the triazine family of chemicals, with fewer safeguards for public health, particularly young children. Advocates are incensed by the decision and vow to continue to put pressure on the agency. “Use of this extremely dangerous pesticide should be banned, not expanded,” Nathan Donley, PhD, a senior scientist at the Center for Biological Diversity said in a press release. “This disgusting decision directly endangers the health of millions of Americans.” Beyond Pesticides has long argued against the continued use of the triazine herbicides, which includes atrazine. Triazines are well known to interfere with the body’s endocrine, or hormonal system. Disruptions within this delicately balanced process in the body can result in a range of ill health effects, including cancer, reproductive dysfunction, and developmental harm. These weedkillers interfere with the pituitary gland’s release of luteinizing hormones, which regulate the function of female ovaries and male gonads. In comments written by Beyond Pesticides to EPA, the organization notes, “Of the numerous adverse effects associated with this disruption, […]

(Beyond Pesticides, August 28, 2020) The Environmental Protection Agency (EPA) has granted “emergency” permission to the State of Texas to allow the use of SurfaceWise®2, an unregistered pesticide, as an anti-viral surface coating. The manufacturer, Allied Bioscience, says the compound can kill coronaviruses (including SARS-CoV-2) starting at two hours post application and for up to seven days, but it is not included on EPA’s List N, of disinfectants effective against SARS-CoV-2. EPA has permitted this use via the authority of Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which allows for “emergency” use of non-registered pesticides, typically to deal with extreme threats to agricultural activities. It is rarely used for public health emergencies. Beyond Pesticides recognizes the need for protection from transmission of the novel coronavirus, and maintains that it ought to and can be done without exposing people to toxic synthetic pesticides that have not undergone evaluation for safety. See Beyond Pesticides’ guidance on effective and safe precautions against the novel coronavirus. The Texas Department of Agriculture secured the EPA exemption, making the state the first to do so; Allied BioScience is pursuing this emergency waiver across all 50 states. The exemption grants American Airlines and two health […]

(Beyond Pesticides, June 17, 2020) The June 3 decision in a high-profile “dicamba case” — against the U.S. Environmental Protection Agency (EPA) and for the plaintiffs, a coalition of conservation groups — was huge news in environmental advocacy, agriculture, and agrochemical circles. The federal Ninth Circuit Court of Appeals vacated EPA’s 2018 conditional registration of three dicamba weed killer products for use on an estimated 60 million acres of DT (dicamba-tolerant through genetic modification/engineering) soybeans and cotton. There is, however, a related issue that accompanies this and many other pesticide cases. When EPA decides to cancel or otherwise proscribe use of a pesticide (usually as a result of its demonstrated toxicity and/or damage during litigation), the agency will often allow pesticide manufacturers to continue to sell off “existing stocks” of a pesticide, or growers and applicators to continue to use whatever stock they have or can procure. Beyond Pesticides has opposed, covered, and litigated against this practice. To greenlight predictable harm is a violation of any recognized moral code, never mind of the agency’s mission — “to protect human health and the environment.” According to Beyond Pesticides, EPA should never permit continued use of a dangerous pesticide once that compound’s […]

(Beyond Pesticides, May 21, 2020) Use of the herbicide dicamba increases humans’ risk of various acute and chronic cancers, according to research published in the International Journal of Epidemiology by the National Institutes of Health (NIH). Many pesticides are “known or probable” carcinogens (cancer-causing agents), and their widespread use only amplifies chemical hazards, adversely affecting human health. However, past research lacks comprehensive information regarding human health effects associated with long-term pesticide use. This study highlights the significant role that long-term research plays in identifying potential health concerns surrounding registered pesticides, especially as the Environmental Protection Agency (EPA) plans to reaffirm its decision to allow dicamba use on genetically engineered (GE) crops. Nathan Donley, Ph.D., a scientist with the environmental health program at the Center for Biological Diversity, comments: “This sweeping study exposes the terrible human cost of the EPA’s reckless decision to expand the use of dicamba. […]For the EPA to approve widespread use of this poison across much of the country without assuring its safety to people and the environment is an absolute indictment of the agency’s persistent practice of rubber-stamping dangerous pesticides.” Dicamba—a benzoic acid chemical that controls broadleaf weeds—is one of the most widely applied herbicides in corn production. As a result of weed resistant to […]

(Beyond Pesticides, May 7, 2020) On April 22, 2020, the Ninth Circuit U.S. Court of Appeals granted the U.S. Environmental Protection Agency (EPA) 90 days to respond to Natural Resources Defense Council’s (NRDC) petition requesting cancellation of tetrachlorvinphos (TCVP), a toxic organophosphate pesticide in pet products. The order followed the Ninth Circuit’s decision to grant NRDC’s petition for a writ of mandamus (a court’s order requiring a lower court or public authority to perform its statutory duty) as EPA withheld action to fulfill NRDC’s judicial review of TCVP, for over a decade. A favorable ruling on NRDC’s mandamus petition can influence other petitioners that hope to coerce agency action, especially when public health is at risk. The court states, “Repeatedly, the EPA has kicked the can down the road and betrayed its prior assurances of timely action, even as it has acknowledged that the pesticide poses widespread, serious risks to the neurodevelopmental health of children.” NRDC petitioned EPA to cancel TCVP pesticide registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in April 2009, after studies indicated humans absorb TCVP through contact with pesticide-treated pet products. EPA failed to respond to the initial petition after five years, and NRDC filed a 2014 mandamus requiring […]

(Beyond Pesticides, May 6, 2020) The Trump Administration announced late last month that it is waiving a requirement that multinational chemical company Syngenta-Chemchina continue to monitor Midwest waterways for the presence of the weedkiller atrazine throughout 2020. While rationalized by the Administration as “due to the unanticipated impact of Covid-19,” the move will instead put residents health at increased risk. Atrazine is one of 78 pesticides that has been linked to the development of respiratory ailments like wheeze. “The public will now have no idea whether dangerous levels of atrazine are reaching rivers and streams throughout the Midwest. That’s absurd and reckless,” said Nathan Donley, PhD a senior scientist with the Center for Biological Diversity. “Syngenta should suspend the sale and use of this extremely toxic pesticide until it can safely ensure it’s not polluting Corn Belt waterways.” Syngenta, which merged with state-owned China Nation Chemical Corporation (Chemchina) in 2016, has been bound by EPA to monitor Midwestern waterways since a 2004 review by the agency. This is because atrazine is a potent groundwater contaminant. Just two years ago, an analysis by the Environmental Working Group found atrazine to be exceeding legal limits in drinking water for many Midwestern states. […]

(Beyond Pesticides, February 28, 2020) State legislators in Boise, Idaho have advanced House Bill 487, An Act Relating to Pesticides and Chemigation, out of the House Agricultural Affairs Committee. If passed, the statutory alterations in this bill would, according to the Idaho Statesman, loosen some rules on aerial application by crop-dusting airplanes, and reduce state agricultural investigators’ ability to regulate the spraying of pesticides. The legislation replaces sections of current rules and deletes language regarding drift, including “Chemicals shall not be applied when wind speed favors drift beyond the area intended for treatment or when chemical distribution is adversely affected.” Such changes will exacerbate the already-significant issue of pesticide drift. In an overview of the pesticide dicamba, Beyond Pesticides recently reported on this legislative development, as well as on a precipitating exposure event in an Idaho hops field. Banning of aerial spraying, as has been attempted by some localities, would go a long way toward eliminating the harms of pesticide drift. The only conclusion that can be drawn from this is the following: As the problem of drift grows and farmers’ crops and people are put at risk, this legislation attempts to define away serious problems and eliminate protections. The Idaho […]

(Beyond Pesticides, January 28, 2020) The practice of coating seeds with insecticides, now widely adopted as a result of the agrichemical industry, has created increasingly toxic conditions for pollinators foraging on US cropland, finds a study published in Scientific Reports by Penn State University scientists. The data finds that even as overall volume of insecticide use has decreased, the total “bee toxic load” – a term branded by researchers – has increased markedly due in large part to the use of hazardous seed coatings. The switch from one toxic chemical to another is indicative of a chemically-driven agricultural system that, in order to reverse insect, pollinator and bird declines, must undergo rapid changes over the next several decades. Researchers used information from multiple US databases to determine regional patterns in pesticide use and corresponding toxicity loads to pollinators. Thus the term “bee toxic load” was determined by combining the area of land where insecticides were applied with the total toxicity of the particular insecticide used. To compare the impact of changes in the mode of action of the insecticides used, toxicity data was separated between oral and contact toxicity.    Findings indicate that from 1997-2012, contact bee toxic load remained […]

(Beyond Pesticides, October 18, 2019) The U.S. Environmental Protection Agency (EPA) issued a directive in September, under Administrator Andrew Wheeler, that changes its pesticide approval process and aims to reduce (mammalian) animal testing significantly by 2035. The agency also announced awards totaling $4.25 million to four universities for development of alternative methods to evaluate chemicals, including pesticides. The move will likely be seen both as an advancement of animal rights, and as a setback for the kinds of testing that can have important implications for human health. Resolution of this issue could be found in a shift away from chemical agriculture and to organic and regenerative practices, which eschew toxic chemicals and synthetic fertilizers, and obviate need for them. The directive affects not only the agency’s own research, but also, as the memo says, EPA will “come as close as possible to excluding from its approval process any reliance on mammal studies conducted after January 1, 2035, including those performed by third parties.” The schools receiving EPA funds to work on alternative testing are Johns Hopkins University, Vanderbilt University and Vanderbilt’s Medical Center, Oregon State University, and the University of California-Riverside. President of the International Science Consortium for People for the […]

(Beyond Pesticides, September 4, 2019) Sixteen organizations representing health, environmental, farmer, and farmworker communities joined together yesterday to call on EPA to remove glyphosate from the marketplace. The groups cite a combination of high-profile lawsuits, environmental impacts, increasing reports of weed resistance, and growing public concern over the health effects of glyphosate in their comments on EPA’s interim reregistration review decision for the chemical. The comments warn that EPA is at risk of damaging the public’s trust in the agency’s review process for toxic pesticides. “EPA’s myopic review and response to the dangers posed by glyphosate does a disservice to American farmers, farmworkers, and commercial landscapers wishing to use least-toxic products that do not put them at risk of health impacts, and consumers aiming to make the safest choice in regards to what to feed their family and how to manage their yards,” the comments read. The document likewise replies to EPA’s attacks against the World Health Organization’s International Agency for Research on Cancer (IARC), which determined glyphosate to be a probable carcinogen based on sufficient evidence of carcinogenicity in experimental organisms. EPA has indicated that its process for evaluating glyphosate, “…is more transparent than IARC’s process” and that IARC’s […]

(Beyond Pesticides, July 29, 2019) A research study, published in March in Scientific Reports, uncovers a pesticide effect on a sugar-metabolizing enzyme common to all cells that has broad health ramifications ignored by the U.S. Environmental Protection Agency’s (EPA) safety testing protocol. This finding raises a larger question regarding the need for EPA to test for the synergistic effects of pesticides, whereby pesticides and chemicals in combination have an even greater effect than they do by themselves. The research, by T. Tristan Brandhorst, PhD, Iain Kean, PhD, and others in the lab of Bruce Klein, PhD, of the University of Wisconsin–Madison and UW School ofMedicine and Public Health, specifically sheds light on the mode of action of the fungicide fludioxonil. Fludioxonil, a phenylpyrrole fungicide, was developed to treat seeds during storage, and has come to be used commonly on grains, vegetables, fruits, and ornamental plants during cultivation, and produce after harvest to extend “shelf life.” As reported by the American Association for the Advancement of Science publication, EurekAlert, “The ability of [the fungicide] fludioxonil to act on a sugar-metabolizing enzyme common to all cells, and to produce the damaging compound methylglyoxal, may mean that the pesticide has more potential to harm non-fungal cells than previously […]

(Beyond Pesticides, March 17, 2019) Forget about single-pesticide issues: this affects every single one of them. EPA is allowing massive data gaps to persist for each and every pesticide product it registers by conducting the bulk of its health and environmental risk assessments using active ingredients alone. With its current practices, EPA is failing its federal mandate to protect public health and the environment and misleading the public about what is “safe.” Tell your Congressional delegation that EPA must assess the real risks of pesticide use, not rely on false representations of risk based on tests of isolated ingredients. When pesticides are sprayed on our crops, lawns, and roadsides, and enter into our waterways, groundwater and drinking water, we are exposed to whole formulations, whole tank mixtures, and whole pesticide combinations, not just active ingredients (those that the manufacturer claims are the only ingredients that attack the target pest). It is the whole formulation that makes the poison, and that whole formulation must be regulated. Active ingredients are far from the whole story of pesticide poisoning. Despite their name, “inert” ingredients are very often not chemically, biologically, nor toxicologically inert or innocuous. According to a peer-reviewed study, as of 2006, more […]

(Beyond Pesticides, February 11, 2019) Aminocyclopyrachlor (ACP) is a tree-killing pesticide masquerading as a broadleaf herbicide. The Oregon Department of Agriculture (ODA) has the opportunity to lead the country in banning this inherently dangerous chemical. According to ODA, nearly 1,500 dead or dying trees have been reported along Oregon’s iconic Interstate 20, home to old growth ponderosa pines. Many of these 150- to 300-year old trees are now dead from ACP exposure. ODA indicated that “because [ACP] is a relatively new herbicide it is unknown how many trees stressed from past applications of [ACP] will die in the future.” Even at tiny levels, ACP run-off and drift kills trees. Tell Oregon’s Department of Agriculture to lead the country in completely banning its use. In 2014, DuPont chemical company settled a nearly $2 million lawsuit with the U.S. Environmental Protection Agency (EPA) after the herbicide (under the brand name Imprelis®) was found to kill trees at golf courses, homeowners associations, businesses, and private residences. Despite this history, regulators left ACP on the market. Its use was banned on lawns and turfgrass, but allowed for roadside rights-of-way. A couple years ago, Bayer purchased the rights to ACP from DuPont and continues to market […]

(Beyond Pesticides, February 7, 2019) A new study, released in Environmental Science and Policy, systematically reviews all state-level pollinator protection acts passed since 2000 and makes a somewhat dim diagnosis: as a rule, state policies fall far below the mark for protecting invaluable ecosystem services and ensuring long-term, sustainable food production. Authors judge the legislation against a set of pollinator protection policy benchmarks established in 2016 by a group of scientists from the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES). Citing the ten policy recommendations laid out by IPBES experts, researchers point to the failure of all enacted state policies to address three main target areas – (1) to improve genetically modified crop risk assessment, (2) to incentivize farmers to make the switch from agrochemical dependence to sustainable benefits from ecosystem services, and, critically, (3) to support diversified farming systems. Beyond Pesticides notes one additional missed target: (4) funding for research on organic, diversified, and ecologically intensified farming. The study includes a total of 109 state laws passed from 2000 to 2017, which authors tracked down by searching usa.gov and state legislative websites and by submitting requests to state librarians. To uncover common themes and patterns among these […]

(Beyond Pesticides, February 5, 2019) Linuron, an herbicide registered for use by the U.S. Environmental Protection Agency (EPA), yet recently banned in Europe due to health concerns, appears to trigger inflammatory signals that have been linked to the onset of Multiple Sclerosis (MS). This new evidence, published in the journal Cell by researchers at Brigham and Women’s Hospital in Boston, MA, indicates that exposure to chemicals and pesticides in the environment may be a risk factor in the development of neurodegenerative diseases. “We created a platform to systematically investigate the understudied effects of environmental exposures,” said study coauthor Francisco Quintana, PhD. “The goal of our work is to return results that can guide future epidemiological studies and identify actionable targets.” Researchers began their investigation with 976 chemicals identified by EPA’s ToxCast program, an inventory of compounds that have undergone screening for a battery of laboratory tests. Within that inventory, 75 chemicals, including linuron, were found to interfere with the signaling pathways linked to MS. To confirm the adverse impacts, scientists used the embryos of zebrafish, animals often used as models in laboratory research. The zebrafish embryos were altered to contain low levels of myelin, a protein that protects nerve cells, as […]

(Beyond Pesticides, January 29, 2019) After eight months of deliberation and discussion, the European Parliament’s Special Committee (the PEST Committee) overwhelmingly approved its draft report in early December 2018 with recommendations to strengthen pesticide restrictions. PEST was established in January 2018 to assess the European Union’s authorization procedure for pesticides. The group’s charge was to review the European Union’s (EU’s) pesticide authorization process, identify its failures in evaluating and approving pesticides and their use (including any conflicts of interest impacting the process), and make recommendations to improve the protection of human, animal, and environmental health from pesticides. The 30-member committee concluded: improvement of the system will require changes in the entirety of the pesticide approval process — from the point of industry application for authorization of a pesticide, to the sale and use of any products containing the compound in EU Member States, to evaluation of impacts of its use once on the market. The approval, sale, use, and regulation of what the EU calls “Plant Protection Products” [PPP] — active substances used to “1) to protect plants or plant products against pests/diseases, 2) to influence the life processes of plants (such as substances influencing their growth, excluding nutrients) and […]

(Beyond Pesticides, January 14, 2019)  A petition submitted on January 7 by the Center for Biological Diversity calls on the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS) to initiate rulemaking to proscribe nearly all pesticide use in areas that are deemed critical habitat for endangered species. It asks these federal agencies to use the authority they have under the 1973 Endangered Species Act (ESA) to protect wildlife from the threats represented by pesticides — which threats both agencies have long recognized. The language of the ESA says its purpose is “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved.” In its press release on the petition, the Center for Biological Diversity (CBD) notes that it comes “after decades of intransigence by the Environmental Protection Agency, which has refused to comply with the legal mandates of the Endangered Species Act to protect the nation’s most imperiled species from highly toxic pesticides like chlorpyrifos and atrazine that are known to harm wildlife.” CBD environmental health director Lori Ann Burd said, “Pesticides pose a devastating danger to endangered wildlife, from coast to coast. If the EPA isn’t going to […]

(Beyond Pesticides, December 13, 2018) The U.S. is pushing back against international standards that restrict pesticides by appealing to the World Trade Organization (WTO) to intervene. At issue are new EU maximum residue levels (MRLs) on food for the following pesticides: buprofezin, diflubenzuron, ethoxysulfurom, ioxynil, molinate, picoxystrobin and tepraloxydim. Advocates are concerned that a U.S. challenge to stronger EU standards could cause the WTO to force a weakening of standards internationally. Most significantly, EU proposed lowering its MRLs on imports. The EU said lower MRLs are needed to protect consumers, as research shows pesticides are shown to be carcinogenic, and that, contrary to chemical-industry claims, no level of allowable exposures can be assumed. Taking issue with the new MRLs – as with all other STCs mentioned above – the U.S. said new MRLs would cause barriers to trade, and therefore, must be rejected by the WTO. Advocates point to the introduction of GMOs as an example of the U.S. using the WTO to block standards that restrict potentially hazardous products. Recently, the U.S. has been involved in four of five new specific trade concerns (STCs) raised before WTO. As part of reviewing the current agreement of the Committee on Sanitary and Phytosanitary […]

(Beyond Pesticides, November 21, 2018) A study published last month in the Journal of Apicultural Research finds significant numbers of U.S. honey bees at risk after exposure to hazardous synthetic pesticides intended to control mosquitoes. With many beekeepers rarely given warning of insecticide spraying, researchers say the risk of losing colonies could increase. Advocates say fear of Zika and other mosquito-borne illnesses could result in counterproductive and reactionary insecticide spraying that will add further stress to managed and native pollinators already undergoing significant declines. Researchers aimed to determine whether neighboring honey bee colonies could be similarly affected by aerial insecticide spraying. To calculate the percentage of colonies that could be affected, density of honey bee colonies by county was compared with projections of conditions thought to be prone to regional Zika virus outbreaks. Researchers found 13 percent of U.S. beekeepers at risk of losing colonies from Zika spraying. In addition, it was determined that many regions of the U.S. best suited for beekeeping are also those with favorable conditions for Zika-prone mosquitoes to proliferate. These regions include the southeast, the Gulf Coast, and California’s Central Valley. “[Considering] all the threats facing bees,” says study lead author Lewis Bartlett of the […]

(Beyond Pesticides, November 8, 2018) Two months after publishing its first series of tests, part two of an Environmental Working Group (EWG) study finds residues of Roundup’s active ingredient, glyphosate, in all General Mills’ Cheerios and PepsiCo’s Quaker Oats products sampled. Health advocates are expressing concern about the consequences of chronic glyphosate exposure, and say U.S. federal agencies must limit the herbicide’s use on oat-based breakfast foods regularly marketed to children. In addition, organic itself is under threat, as chemical-intensive management practices undermine the future of the growing organic movement. In this second round of testing, EWG scientists purchased products around San Francisco and Washington DC. 28 samples of conventional and 16 samples of organic oat products were collected. Approximately 300 grams of each General Mills and PepsiCo product were packaged and shipped to Anresco Laboratories, in San Francisco. Detected glyphosate residues were compared to EWG’s own health benchmark of 160 parts per billion (ppb). This benchmark is based on risks of lifetime exposure and what EWG scientists consider allowable and protective of children’s health with an adequate margin of safety.  EWG’s results detected glyphosate residues in all 28 samples of conventionally grown oat products. The vast majority (all but two) […]

(Beyond Pesticides, October 25, 2018) A study published last month in Scientific Reports finds that eating sunflower pollen significantly reduces protozoan infection in bumblebees. Studying ecosystem services and what she calls “floral rewards,” evolutionary ecologist Lynn Adler, Ph.D. at the University of Massachusetts Amherst says sunflowers may provide a long sought after solution for improving bees’ immune system response to both disease and parasites. The researchers studied the protozoan Crithidia bombi, a common parasitic infection of bumble bees, known to impair learning and foraging, shorten lifespan and destabilize colony hierarchies by impacting queen bee behavior. From the outset of the study, Dr. Adler says, “the more sunflowers were grown at the farm, the lower the Crithidia load for the bees at that farm.” Knowing pollinators eat pollen as a source of protein and healthy fats, Dr. Adler hypothesized that both pollen and nectar might have medicinal effects against disease and parasites. However, her experiment did not show consistent results with nectar. After bees in the lab were starved for 4-6 hours, researchers fed individual worker bees from small colonies a drop of fructose fluid containing 6,000 Crithidia cells, being the approximate concentration bees may encounter in the wild while foraging. After […]

(Beyond Pesticides, September 28, 2018) Despite French President, Emmanuel Macron’s pledge to see glyphosate banned in his country, French ministers of parliament (MPs) have once again refused to enter the banning of glyphosate into legislation. Glyphosate’s use in Europe has come under scrutiny and heated debate. But despite evidence of harms, and interference by Monsanto, the European Union (EU) extended its license last year. However, France has pledged to ban the chemical within a few years. French MPs –who were voting at second reading on a comprehensive reform measure aimed at reforming the trade relations in the agricultural sector and promoting healthier food – have once again refused to approve the banning of glyphosate. A promise by Emmanuel Macron, the banning of glyphosate within the next three years was not initially included in the government’s bill. Following the intensification of the debate about the herbicide’s renewal at European level, the question of including the president’s promise in the legislative text was posed in the parliamentary debate. In May, MPs followed recommendations of the government to consider a ban. But they were opposed to a ban within the framework of the French law, and rejected the amendments mentioning a ban of the […]

(Beyond Pesticides, September 27, 2018) The U.S. Environmental Protection Agency’s (EPA) Office of the Inspector General (OIG) released a report finding the agency’s practice of routinely granting “emergency” approval through its Section 18 program for pesticide use does not effectively measure risks to human health or the environment. The inspector general recommends EPA “develop and implement applicable outcome-based performance measures to demonstrate the human health and environmental effects of the EPA’s emergency exemption decisions.” EPA disagreed with the recommendation, leaving the issue of chronic overuse of the emergency exemptions unresolved. Under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the EPA has the authority to approve the temporary emergency use of unapproved pesticides if the agency determines the pesticide is needed to prevent the spread of an unexpected outbreak of crop-damaging insects, for example. But this provision has been widely abused. OIG’s report finds “significant deficiencies in the OPP’s online database management, in its draft Section 18 emergency exemption standard operating procedure and application checklist, and in its reports to Congress and the Office of Management and Budget.” Specifically, the report notes EPA, “does not have outcome measures in place to determine how well the emergency exemption process […]