The agency prepared this draft EIS to comply with a February 2007 judgment and order by the U.S. District Court for the Northern District of California, in which Judge Charles R. Breyer found that USDA violated federal environmental law by failing to conduct an EIS on GE alfalfa seeds before deregulating them in 2005.

The lawsuit, originally brought on by The Center for Food Safety (CFS) and several other environmental and farming groups, including Beyond Pesticides and Sierra Club, led to a 2007 court order that the deregulation may have significant environmental impacts and issued a permanent order stating that the alfalfa is once again a regulated article. The court banned the planting of GE alfalfa until USDA completed a rigorous analysis of these impacts.

The U.S. Court of Appeals for the Ninth Circuit twice affirmed the national ban on GE alfalfa planting, including earlier this year, determining that the planting of genetically modified alfalfa can result in potentially irreversible harm to organic and conventional varieties of crops, damage to the environment, and economic harm to farmers. Noting that contamination of natural and organic alfalfa by the GE variety has already occurred, Judge Breyer stated, “Such contamination is irreparable environmental harm. The contamination cannot be undone.”

“GE alfalfa threatens the very fabric of the organic industry. Organic consumers want seeds and products to not be polluted by GE,” explained George Siemon, one of the founding farmers and CEO of Organic Valley. “In order for dairy products to be marketed as organic, certified organic alfalfa must be used as forage. When contamination of GE alfalfa becomes widespread, organic dairy farmers will no longer be able to give that assurance.”

While USDA’s initial approval of GE alfalfa was found to violate environmental laws by failing to analyze risks such as the contamination of conventional and organic alfalfa and the development of “superweeds” that are resistant to glyphosate; USDA once again dismisses the potential that organic and conventional alfalfa will be endangered due to biological contamination in their court-ordered EIS.

“USDA’s announcement is simply business as usual, once again catering to Monsanto’s corporate interests at the expense of farmers and consumers,” stated Andrew Kimbrell, Executive Director of CFS. “This is a huge disappointment coming from the Obama administration, which has repeatedly claimed to support family farms and consumers’ right to know what’s in their food.”

This draft EIS ignores the new reports and studies that demonstrate the many environmental and health consequences that GE crops cause. Earlier this year, Beyond Pesticides, joined by 32 other groups and individuals, submitted comments to the U.S. Environment Protection Agency (EPA) showing new and emerging science which illustrates that glyphosate and its formulated products pose unreasonable risk to human and environmental health, and as such should not be considered eligible for continued registration.

Glyphosate poses unacceptable risks to humans. Due to such widespread use of the weed killer glyphosate and the prevalent myth that it is harmless, it has been linked to acute human health effects such as non-Hodgkin’s lymphoma. Another recent study found that Roundup kills human embryonic cells. Glyphosate is also harmful to the environment, particularly aquatic life and water quality and has been linked to intersex frogs, and is lethal to amphibians in concentrations found in the environment.

Furthermore, despite 20 years of research and 13 years of commercialization, a report by Union of Concerned Scientists found that genetic engineering has failed to significantly increase U.S. crop yields. Increases over the last decade are largely due to traditional breeding and agricultural improvements. In fact, a report published last month found that the rapid adoption by U.S. farmers of genetically modified corn, soybeans and cotton has actually promoted increased use of pesticides, an epidemic of herbicide-resistant weeds, and more chemical residues in foods.

In this Fourth Report, 75 new chemicals were added. Chemicals in the Fourth Report include metals such as lead, cadmium, uranium, mercury, and speciated forms of arsenic; environmental phenols such as bisphenol-A (BPA); acrylamide; perfluorinated chemicals; polybrominated diphenyl ethers (PBDEs); polychlorinated biphenyls (PCBs); volatile organic compounds such as benzene, styrene and methyl tert-butyl ether; pesticides; phthalates; and dioxins, furans and related chemicals.

The data analyzed in the Fourth Report are based on blood and urine samples that were collected from approximately 2400 people who participated in CDC’s National Health and Nutrition Examination Survey (NHANES) from 2003 through 2004. NHANES is an ongoing national health survey of the non-institutionalized U.S. population that includes collecting and analyzing blood and urine samples to help further research involving exposures and health effects.

The types of exposure information found in the report can help physicians and public health officials determine whether people have been exposed to higher environmental chemicals as well as help scientists plan and conduct research about health effects. Much of the information has been previously published, but this is the first publication of all the data in one place. The report does not provide new health effects information. Research separate from that compiled in the Fourth Report is needed to determine whether higher levels of environmental chemicals in blood or urine are related to health effects.

Triclosan, a widely-used antibacterial pesticide found in products from countertops to toothpaste, is found in the urine of 75% of the U.S. population, with higher levels in people in their third decade of life and among people with the highest household income. Triclosan is shown to alter thyroid function, is linked to bacterial and compounded antibiotic resistance, dioxin contamination and contamination of surface waters and sewage sludge. Other studies have found that due to its extensive use in consumer goods, triclosan and its metabolites are present in, fish, umbilical cord blood and human milk.

Pesticides like synthetic pyrethroids were included for the second time. The report finds that exposure continues to be widespread, specifically for permethrin, cypermethrin, deltamethrin, and/or their metabolites which were all found in greater than 50% of the subjects tested. Exposure to synthetic pyrethroids has been reported to trigger asthma, lead to headaches, dizziness and nausea. There are also serious chronic health concerns related to synthetic pyrethroids. EPA classifies both permethrin and cypermethrin as possible human carcinogens, based on evidence of lung tumors in lab animals exposed to these chemicals. Many synthetic pyrethroids have been linked to disruption of the endocrine system, which can adversely affect reproduction and sexual development, interfere with the immune system, and increase chances of breast cancer.

According to a December 4 analysis by Environmental Health Sciences, a foundation-funded journalism organization, the researchers discovered that female rats fed atrazine at the time of ovulation released a flow of stress hormones that are known to interfere with hormones essential for reproduction. The findings reveal one way atrazine may impact female reproduction. Elevated stress hormones can disrupt the hormone signals that spur ovulation. Such a stress response to atrazine could partially explain why previous studies find that the herbicide inhibits reproduction. The stress reaction is similar to that seen when the animals are restrained against their will.

One of the most widely used agricultural pesticides in the U.S., atrazine can currently legally be applied before and after planting to control broadleaf and grassy weeds. Its increased use to manicure home lawns and gardens has become a serious environmental concern as runoff has had severe health and environmental consequences.

Even at low levels that are considered “safe” by EPA standards, atrazine is known to harm fish, and has been associated with reproductive and developmental effects as well as endocrine disruption. Research by UC Berkeley professor, Tyrone Hayes, Ph.D., demonstrates that exposure to doses of atrazine as small as 0.1 parts per billion, turns tadpoles into hermaphrodites – creatures with both male and female sexual characteristics.

As the most commonly detected pesticide in rivers, streams and wells, an estimated 76.4 million pounds of atrazine is applied in the U.S. annually. It has a tendency to persist in soils and move with water, making it a common water contaminant. Research found that intersex frogs are more common in suburban areas than agricultural areas. Another study suggests it as a possible cause for male infertility.

In October 2009, EPA announced that it will launch a new comprehensive evaluation of the pesticide atrazine to determine its effects on humans this fall. In EPA’s own words, “At the end of this process, the agency will decide whether to revise its current risk assessment of the pesticide and whether new restrictions are necessary to better protect public health.”

“Companies are working hard to convince consumers, and especially moms, that they need to regularly disinfect every surface in their homes to protect their families from illness. But that’s simply not true and it may not be healthy,” says WVE staff scientist and report author Alexandra Scranton. “We’re encouraging consumers to go back to basics for cleaning, with less of a focus on disinfection and more on non-toxic cleaners and a little elbow grease.”

According to the Centers for Disease Control and Prevention (CDC), frequent hand washing with hot water and regular soap is the best way to prevent infection and illness.

“Antimicrobial chemicals available in the home today were initially developed for hospital and clinical settings, but for the vast majority of people, the home does not need to be as sterile as an operating room,” Says Susan Luck, RN, director of the Integrative Nursing Institute.

Disinfectants tend to kill a wide variety of bacteria, reducing both “bad” bacteria associated with illness, as well as the “good” bacteria that perform useful functions in our environment and in our bodies. The overuse of antimicrobial chemicals has also been linked to the creation of drug-resistant bacteria, or “superbugs,” which are bacteria and viruses that have become resistant to the antimicrobial compounds and antibiotic drugs developed to control them.

“Even when used as directed, these chemicals inadvertently end up polluting our bodies and our environment,” says Ann Blake, PhD, University of California Berkeley Extension Instructor. The report cites a study that found that microbes in lake water adapted and became resistant to some ammonium quaternary compounds, a family of chemicals commonly found in disinfectant sprays and toilet cleaners.

Regulated by both the FDA and EPA, triclosan is an antibacterial used in hundreds of common consumer products such as soaps, cosmetics, deodorants, toys, and even clothing. According to the triclosan factsheet in the Fourth National Report and Human Exposure to Environmental Chemicals, released in December 2009, the National Health and Nutrition Examination Study (NHANES) finds triclosan in the bodies of nearly 75 percent of people tested. Studies show the two chemicals may have hormone-disrupting effects, which means they change the activity of hormones in the body. For example, triclocarban appears to amplify testosterone in the body, while triclosan has been shown to interfere with communication between cells in the brain and the heart.

A U.S Geological Survey (USGS) study found that triclosan is one of the most detected chemicals in U.S. waterways and at some of the highest concentrations, because it is so frequently used in households and washed down the drains.

Other studies have found that due to its extensive use in consumer goods, triclosan and its metabolites are present in fish, human milk, serum, urine, and foods. Further, the pesticide can also interact with other chemicals to form dioxin and chloroform, thereby exposing consumers to even more dangerous chemicals.

At its annual convention this past summer, the Canadian Medical Association called on the federal government to ban the sale of household antibacterial products such as those containing triclosan.

In July of this year, Beyond Pesticides and Food and Water Watch submitted an amended petition to the United States Food and Drug Administration (FDA) requiring that the agency ban the use of the controversial pesticide triclosan for non-medical applications on the basis that those uses violate the Federal Food, Drug and Cosmetics Act.

In addition, nanosilver has been promoted for its antibacterial properties and is used in many products such as sporting goods, band-aids, clothing, baby and infant products, and food and food packaging. However, very little is known about where these particles end up when such products are put to use. Many consider silver to be more toxic than other metals when in nanoscale form and that these particles have a different toxicity mechanism compared to dissolved silver. Scientists have concluded that nanoparticles can pass easily into cells and affect cellular function, depending on their shape and size. Preliminary research with laboratory rats has found that silver nanoparticles can traverse into the brain, and can induce neuronal degeneration and necrosis (death of cells or tissue) by accumulating in the brain over a long period of time.

Disinfectant Overkill also contains information on how to reduce usage of disinfecting products as well as suggestions for non-toxic cleaning alternatives. Disinfectants are a growing sector of business for cleaning product manufacturers. The industry has seen significant growth in recent years, and analysts project that the global disinfectant market will reach $2.5 billion by 2012.

“We would like to see greater conscience of the importance (of agriculture),” Jacques Diouf, director-general of the Food and Agriculture Organization (FAO), told Reuters in an interview this week at the Copenhagen climate talks. “Historically the discussion centered on the industrial aspects of climate change, be it in terms of factories, transport, but less on the primary sector of agriculture.”

FAO believes carbon sequestration, lower-input of fossil fuel dependant resources, and use of renewable energy all present opportunities for organic agriculture to lead the way in reducing energy consumption and mitigating the negative effects of climate change. Organic agriculture incorporates management practices that can help farmers adapt to climate change through strengthening agro-ecosystems, diversifying crop and livestock production, and building farmers’ knowledge base to best prevent and confront changes in climate.

FAO promotes organic agriculture as an alternative approach that maximizes the performance of renewable resources and optimizes nutrient and energy flows in agroecosystems. Life cycle assessments show that emissions in conventional production systems are always higher than those of organic systems, based on production area. Soil emissions of nitrous oxides and methane from arable or pasture use of dried peat lands can be avoided with organic management practices.

The agency points to many field trials worldwide that show that organic fertilization compared to mineral fertilization is increasing soil organic carbon and thus sequestering large amounts of CO2 from the atmosphere to the soil. Lower greenhouse gas emissions for crop production and enhanced carbon sequestration, coupled with additional benefits of biodiversity and other environmental services, makes organic agriculture a farming method with many advantages and considerable potential for mitigating and adopting to climate change, says FAO.

Beyond Pesticides believes conventional agricultural practices have contributed to climate change through heavy use of fossil fuels–both directly on the farm and in the manufacturing of pesticides and fertilizers–and through degradation of the soil, which releases carbon. The herbicide use that conventional no-till depends on, is no exception. The adoption of organic methods, particularly organic no-till, is an opportunity for farming both to mitigate agriculture’s contributions to climate change and cope with the effects climate change has had and will have on agriculture.

Research from the Rodale Institute’s Farming Systems Trial (FST) has documented that organic, regenerative agriculture actually has the potential to lessen the impacts of climate change. This occurs through the drastic reduction in fossil fuel usage to produce the crops (approximately 75% less than conventional agriculture) and the significant increase in carbon sequestration in the soil (approximately 1000 lbs. of carbon per acre). The organic no-till methods they have developed produce comparable yields to conventional systems on average, and higher yields in drought years because of the greater water holding capacity of the organic soils.

The U.N. Climate Change Conference is taking place in Copenhagen, Denmark, December 7-18, 2009. The conference includes the 15th Conference of the Parties (COP 15) to the U.N. Framework Convention on Climate Change and the 5th Meeting of the Parties (COP/MOP 5) to the Kyoto Protocol.

“Better information and applying these tools will strengthen EPA’s protections for farm workers exposed to these chemicals, and children living in and around the areas of highest possible exposure,” says EPA Administrator Lisa P. Jackson. “It’s essential we have the tools to keep everyone, especially vulnerable populations like children, safe from the serious health consequences of pesticide exposure.”

EPA licenses or registers pesticides for sale and distribution under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The agency establishes tolerances, limits for pesticide residues in or on food, under section 408 of FFDCA. In contrast to the risk/benefit standard for registration under FIFRA, FFDCA applies a risk-only standard for tolerances and explicitly sets certain approaches for assessing risks and establishes acceptable rates of harm. Critics of the risk assessment approach (as opposed to the precautionary approach) to toxics regulation have maintained that the methodology ignores data gaps on important health outcomes not evaluated (e.g. endocrine disruption), possible interactions, additive and synergistic effects resulting from chemical mixtures permitted to be released in the environment, effects of all the contaminants associated with a pesticide, and the availability of less or non-toxic approaches and products to the pesticide under evaluation. Health advocates have said that multiplying an uncertainty factor (called a safety factor by EPA) of ten times an unknown outcome (equivalent to zerio) does not necessarily improve the protection of children or others exposed. In simple math terms, ten times zero (knowledge) equals zero (knowledge). The best example of this are endocrine disruptors and sublethal effects associated with low dose exposure, where miniscule amounts of a chemical can induce serious health outcomes for a spectrum of disorders throughout ones life.

Under the policy, EPA risk assessments for children, farmworkers and others would consider aggregate pesticide exposures from all sources (which is currently done when there is a non-occupational food-related exposure) in addition to the cumulative effects from multiple pesticides that have similar toxicity (also done currently when there is food-related non-occupational exposure). The risk-only standard and the mandated risk assessment approaches were added to FFDCA by the Food Quality Protection Act of 1996 (FQPA). However, FQPA explicitly did not require EPA to use these risk assessment approaches in assessing worker risks or non-food use pesticides that do not have any food uses. Also, historically, EPA has not considered children in assessing worker risks.

Specifically, the policy will include using an additional uncertainty factor for children, considering aggregate exposures to pesticides from multiple sources, and considering cumulative effects which may occur from exposure to multiple pesticides with a common mechanism of toxicity. Moreover, risks will be explicitly reported for individuals who had not been explicitly considered, specifically workers age 12 to 17 and children taken into agricultural fields. EPA also would apply the additional uncertainty factor for infants and children in cases where the agency has incomplete data.

This “safety” factor, as EPA refers to it, however, is merely the allowable margin of error or the uncertainty factor in risk determinations. FQPA mandates that an additional 10X safety factor be applied to protect infants and children “to take into account potential pre- and postnatal toxicity and completeness of the data with respect to exposure and toxicity to infants and children.” This additional factor can only be reduced or removed if there are reliable and sufficient data on effects in infants and children.

Beyond Pesticides has historically criticized the agency for what appears to be an arbitrary application of the FQPA 10X “safety” factor, for manipulating safety data and allowing hazardous pesticide uses to remain on the market. Despite these concerns, Beyond Pesticides believes that, in principle, expanding and increasing the uncertainty factor for some chemicals to protect sensitive populations will help reduce the hazards posed by pesticide use, but not eliminate the use of toxic pesticides that are not necessary given the availability of less and non-toxic methods and products. However, taking this step to eliminate the disproportionate risk to farmworkers and their children by equalizing protections across the population under risk calculations has important environmental justice ramifications, especially since occupational exposures were excluded from FQPA when it was passed in 1996. Additionally, advocates are asking EPA to evaluate the reasonableness of of any pesticide-related risks (especially given the unknowns) to children and workers when less and non-toxic approaches to agricultural land management are available and profitable.

TAKE ACTION! Tell EPA that you support their efforts for a more thorough assessment of risks to workers, including farmworkers and farm children, but that more needs to be done to restrict the availability of toxic pesticides on the market. Comments can be submitted to www.regulations.gov, docket number EPA-HQ-OPP-2009-0889 on or before February 8, 2010.