(Beyond Pesticides, October 9, 2024) An agrichemical industry-funded study published in International Journal of Agricultural Sustainability dissects the development of national organic standards and opportunities that can be applied in expanding the use of “regenerative” agriculture. Not surprisingly, the study authors offer support for integrated pest management (IPM) and reassurance of a rigorous pesticide registration review process before the chemicals are marketed. The study included a survey of five farmers, who farm a total of 100,000 acres, but do not have extensive experience farming organically.

For those practicing regenerative organic practices and organic advocates, the bottom line is that the study concludes that a list of criteria that would be needed for regenerative agriculture criteria (e.g., list of allowed substances) already exists within the standards and requirements of the 1990 Organic Foods Production Act (OFPA) and the National Organic Program.

Environmental and public health advocates are concerned about this piece representing an industry position being cloaked in an academic journal serving as an obstacle to the widespread adoption and improvement of organic principles and practices. The study was written by four authors with varying levels of connections to CropLife America (the major agrichemical industry trade group), including academic researchers with funding from the pesticide lobbying group or direct employment. In the disclosure statement at the end of the article in the International Journal of Agricultural Sustainability, the authors indicate that the work was supported by CropLife and then say, “No potential conflict of interest was reported by the author(s).” In fact, one author, Katie Stump, indicates that she is currently a science and policy manager at CropLife America.

The surveyed farmland represents a limited number of organically managed land within the farmers’ total land portfolio. According to the study, “Two operations were growing 7-20% of their acres as certified organic. One of the growers had not entered organic production and two growers had recently exited certified organic due to barriers they encountered. Growers not currently growing organic discussed the barriers to entry and reasons they exited organic agriculture.” While the authors do acknowledge that they must consider farms of varying sizes, they fail to consider farms such as those affiliated with the Real Organic Project—a network of over 1,000 certified organic farms that have adopted practices that exceed USDA organic standards by rejecting hydroponic practices and only raise livestock on pasture.

“For a new paradigm to be successful, it will require flexibility and options to pick from in management practices that achieve the desired outcome, acknowledgment on a regional level of varying needs and practices, a clear list of certification requirements, a third-party verification system, and should be tied to a premium to reward the grower for the practices,” according to the authors. OFPA is designed to include flexibility in the adoption and continuous review of standards, and the rules require public meetings facilitated by the National Organic Standards Board (NOSB) twice a year with a sunset review of allowed substances to facilitate additions or subtractions to the National List of Allowed and Prohibited Substances (which is a foundational feature that establishes a clear list of inputs allowed in certified organic production).

For example, the requirement that beer labeled organic contain only organic hops, typically a small fraction of the beer by weight and volume, was advanced by organic hops growers who showed that the organic crop was commercially available. OFPA contains an allowance for conventional inputs in organic-labeled processed commodities if they make up less than 5% of the products that are not commercially available as organic, incentivizing the adoption of organic production practices or “continuous improvement.” With the continuous improvement of national organic standards ongoing, the organic sector has cultivated regional production hubs for various products such as cotton. Moreover, as the farmers interviewed in this study indicate, two of the main drivers to attain organic certification are “profitability” and “meeting consumer demand,” underscoring the underlying economic viability of certified organic.

The authors take the position that IPM is the most viable systems approach. They state: “This approach [IPM] does not put process limits on the use of pesticides. In fact, The Weed Science Society of America, the American Phytopathological Society, and the Plant-Insect Ecosystems Section of the Entomological Society of America issued a statement that pesticides are an important part of IPM and that restricting their use by considering them a ‘last resort’ or selecting only the ‘least toxic pesticide’ can result in a build-up of pests and reduce the overall options for control.” Advocates find it notable, and unsurprising, that the Entomological Society of America (ESA) issued support of pesticide use as a feature of IPM, given recent instances of corruption alleged by scientists attending ESA’s 2023 annual meeting. See here for the Daily News analysis of U.S. Right to Know’s report on ESA. See an additional Daily News article, IPM (Integrated Pest Management) Fails to Stop Toxic Pesticide Use, to learn more about the structural failures of IPM to address moving beyond the chemical treadmill.

The authors continue by blurring the difference between the safety of food grown with chemical-intensive and organic practices. They say, “Consumers should have confidence in the safety of their food regardless of type of pesticides used given the robust nature of the pesticide review and registration process in the U.S. for organic and conventional pesticides.”

Numerous Office of Inspector General (OIG) reports have documented the inability of the Office of Pesticide Programs to fulfill its mandate of protecting the public from toxic pesticide exposure. For example, a recent investigation by Inside Climate News found that EPA failed to adequately assess the cancer effects of 1,3-D or Telone by, among other deficiencies, relying on industry-funded scientific studies that downplayed the carcinogenic potential of this pesticide. EPA’s failure to consider the independent scientific literature extends to other areas, including failure to complete the protocol for testing the endocrine-disrupting potential of registered pesticides.

In 2023, six years after the filing, EPA rejected a public petition to request an evaluation of complete formulations of pesticide products to include toxicological analysis of both active ingredients and inerts (or other ingredients, which pesticide manufacturers do not have to disclose on labels or to the public). In a recent analysis published in Frontiers in Toxicology, researchers identified a number of pitfalls in the broader U.S. regulatory system in terms of its failure to regulate toxic chemicals that threaten public health. Beyond the failure of the scientific and risk assessment process, the U.S. Department of Agriculture continues to mislead the public about its findings related to pesticide residues. (See here for an analysis of the 2024 data.) Meanwhile, with ongoing public criticism of its failure to adequately assess its risk assessment process, EPA solicited public comments earlier this year to update its scientific integrity guidelines.

According to the study authors, “Growers believe that for the foreseeable future, both process-based organic and development of outcome-based programs [soil health, biodiversity, and other environmental and social parameters] will continue to co-exist.” Among the categories of agricultural practices that the authors identify as needing definition is regenerative agriculture. “Whether [issues of soil health and biodiversity] will develop into a cohesive definition of regenerative agriculture remains to be seen,” the authors say. Regenerative can be put in the category of greenwashing, as documented in previous Daily News articles. (See here.) The authors rest heavily on the need for “flexibility” in the use of pesticides. According to the researchers, “A key production challenge is management of pests. Growers could benefit from more flexibility such as the development of additional tools to combat difficult pests, ensuring multiple modes of action to prevent resistance and exploration of the use of derogations in concert with an IPM plan to deal with emergency situations.” Significantly, the use of petrochemical pesticides and fertilizers have been found to undermine the benefits of healthy soil systems with microbial life, nutrient cycling, and biodiversity. (See here.)

Earlier this year, the California Department of Food and Agriculture held public listening sessions, as officials entertained the adoption of a state definition of regenerative agriculture. Farmers, consumers, and advocates in California and nationwide provided statements in opposition to the state proposal, given the absence of a proposed requirement that organic standards become a baseline in the definition of regenerative. (See here.)

One of the biggest takeaways from organic farmers and advocates is the lack of definition for what substances are allowed and prohibited in regenerative agriculture, which has resulted in a continued reliance on toxic pesticides such as glyphosate. Advocates point out that agricultural systems reliant on pesticides are antithetical to supporting ecosystem services and agroecological food production. See here, here, here, and here for numerous peer-reviewed articles and commentary on the climate resilience, soil health, carbon sequestration, and economic benefits of certified organic agriculture.

As the debate on regenerative agriculture heats up, chemical industry lobbyists are hitting Capitol Hill on the Farm Bill to establish a national policy to take away local and state authority to restrict pesticides and, at the same time, fanning out across the country to pressure state legislatures to prohibit people’s right to sue for the failure to warn on the hazards of their products. (See Daily News here for more analysis.) Beyond Pesticides has called these industry campaigns an attack on democratic institutions and principles in the United States in the Daily News article, This Independence Day, Protect Democracy.

Millions of dollars are being spent by pesticide manufacturers on lobbying efforts to support these policies that restrict basic rights. According to Open Secrets, Bayer spent 7.45 million in total lobbying expenditures for 2023, CropLife America spent over 1.5 million in 2023, and BASF spent 1.5 million in 2024. A previous Daily News addresses the legacy of CropLife America’s and pesticide manufacturers’ efforts to influence national and international frameworks for pesticide and agricultural policy. (See here.)

As a growing intersectional movement of advocates continues to push for reform, the industry is seeking to undermine the credibility of advocates through doxing of information and smear campaigns, allegedly funded by the U.S. government, as reported recently by The Guardian. The critical need identified by health and environmental advocates for broader EPA regulatory action to ban pesticides was exemplified by a landmark EPA decision in August to suspend the use of the herbicide Dacthal/DCPA without allowing continued use of existing stocks—the second time in agency history that it took this action, despite its authority clearly defined in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Beyond Pesticides has since called for the banning of weedkillers atrazine and paraquat under what it calls the Dacthal Standard.

Consider subscribing to Action of the Week to learn how to support the growth of policies and decision-making that hold the agrochemical industry accountable while supporting organic and regenerative organic food systems.

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

Source: International Journal of Agricultural Sustainability

(Beyond Pesticides, October 8, 2024) A comprehensive literature review in Endocrines, published in September, amasses hundreds of studies on endocrine-disrupting chemicals (EDCs) that showcase adverse effects on growth, development, reproduction, and metabolism. The authors, a team of scientists and academics from Brazil, shed light on the link between EDC use and thyroid dysfunction, leading to increasingly prevalent illnesses and deadly diseases.    

EDCs are any synthetic or natural compounds that hinder endocrine system functions and create harmful effects on organisms. These chemicals can impact the thyroid gland, which is vital in producing hormones and plays a role in several body functions. As the researchers state, “Several EDCs have been classified as thyroid disruptors, impairing thyroid hormone [TH] production, synthesis, metabolism, transport, and/or actions. Notably, thyroid disorders are the second most prevalent endocrine disease worldwide, with incidence increasing significantly in recent years.”

The authors continue, “[S]tudies have correlated this rise in thyroid dysfunctions and cancers with increased exposure to EDCs. Although many EDCs are linked to thyroid dysfunction, this review focuses on the deleterious effects of plasticizers, organochlorine pesticides, and per- and poly-fluoroalkyl substances on thyroid function. These contaminants are commonly found in food, water, and everyday products.”

This review helps to summarizes the consequences of exposure to thyroid disruptors for human health, which can impact hormones such as diiodothyronine (T2), triiodothyronine (T3), thyroxine (T4), and the thyroid stimulating hormone (TSH). These hormones are necessary for growth and metabolism, as well as fetal development and maturation, and play a key role in the central nervous system (CNS). Several tissues in the body rely on these hormones, which highlights the importance of limiting exposure to the more than 100 natural and synthetic compounds that have been classified as thyroid disruptors. (See studies here and here.)

Impact on Infants/Children

Higher hazards of toxic chemical exposure are associated with infants and children, as their small size and developing organ systems make them more susceptible when exposed to toxic chemicals. EDCs put young children at a disproportionate risk, “primarily because the metabolizing pathways of these substances are immature in these individuals,” the researchers point out. “Moreover, embryos, fetuses, and newborns are adversely impacted by maternal exposure to these contaminants, which are transferred through the placenta and maternal milk. Consequently, these individuals become more vulnerable to hormonal, immunological, and neurological alterations during critical stages of their development.”

Additional studies indicate that maternal exposure to EDCs, both preconception and during pregnancy, can impact fetal development, birth outcomes, and long-term health. Some studies (see here, here, and here) show that contact with EDCs “triggers epigenetic modifications in the placenta and the fetus, altering gene expression and compromising fetal development,” the authors note. These changes can lead to subsequent health problems in the offspring and cause multigenerational and transgenerational effects.

Maternal THs are critical for fetal development, as the fetus receives them through the placenta exclusively up until the 12^th-16^th week of gestation. Any alterations in the mother’s hormone levels directly impact the fetus during this time. The transport of THs across the placenta aids in not only development but also in the function of placental tissues. Studies have linked complications during pregnancy involving the placenta to untreated thyroid disorders, highlighting the role of TH production in birth outcomes. (See here and here.)

Plasticizers

Plasticizers, compounds utilized in the production of plastic products including phthalates and bisphenols, are frequently used due to their high stability. These can be found in “various commercial products such as toys, construction materials, personal care products, cosmetics, food preservation films, detergents, and medical devices,” the authors share. Exposure to phthalates, whether through ingestion, inhalation, or dermal routes, can lead to detectable levels “in urine, blood, hair, amniotic fluid, and breast milk, confirming widespread human contamination of phthalates and their metabolites.”

Studies have not only detected these plasticizers in human samples, but have demonstrated an association between exposure, such as with di(2-ethylhexyl) phthalate (DEHP), and alterations in T3, T4, and TSH concentrations in pregnant women, newborns, and children. (See studies here, here, here, here, and here). Impacts within the general populations have also been noted, as well as later-in-life impacts after neonatal exposure to phthalates.

Bisphenol A (BPA), used in products like polycarbonate plastics and food can linings, has also been found in urine and other samples from adults and newborns and is linked to impacts on thyroid function and hormone levels. Another study finds that elevated levels of bisphenols in urine correlate with increased levels of oxidative stress biomarkers and an enhanced risk of thyroid cancer. The authors summarize these results in saying, “[T]he data strongly indicate that BPA and its analogs are significant disruptors of thyroid function, with far-reaching implications for both human and other animals’ health. BPA’s ability to bind to TH receptors and thyroid transcription factors highlights its potent role in altering thyroid signaling pathways and gene expression.”

Pesticides

Numerous pesticides are considered EDCs. Substances identified by the European Union (EU) include triclosan, atrazine, mancozeb, and propiconazole, among others. Many EDCs have not been specifically tested for impacts on thyroid function, highlighting data gaps that warrant further research. The Endocrine Society further emphasizes, “There are nearly 85,000 man-made chemicals in the world, many of which people come into contact with every day. Only about one percent of them have been studied for safety; however, 1,000 or more of these chemicals may be EDCs based on their probable endocrine-interfering properties.”

A literature review in Frontiers in Endocrinology agrees in sharing from their research: “We conclude first, that many pesticides were placed on the market with insufficient testing, other than acute or chronic toxicity, and second, that thyroid-specific endpoints for neurodevelopmental effects and mixture assessment are largely absent from regulatory directives.” These authors also analyzes classes of pesticides such as organochlorine pesticides (OCPs), organophosphates, carbamates, phenylpyrazoles, and pyrethroids for thyroid disruption. The research shows potential effects for many pesticides within these classes including dichlorodiphenylotrichloroethane (DDT), chlorpyrifos, thiram, fipronil, and permethrin, respectively.

The original literature review, in Endocrines, also notes how OCPs (specifically DDT, endosulfan, and dieldrin) are known for their persistence in the environment. DDT, for example, was widely used during World War II until it was banned in developed countries in the 1970s, but it is still detected in the environment and is used in several developing countries to this day. Both DDT and its main metabolite dichlorodiphenyldichloroethylene (DDE) accumulate in the fatty tissue of humans and other animals after exposure, mainly through contaminated food and water. As the researchers share, “DDT and DDE have a similar chemical structure to THs. For this reason, they are described as potential disruptors of TH synthesis, action, and metabolism.”

Studies find that DDT and its metabolites cross the placenta and are also detected in samples of breast milk. Reports show sexually dimorphic impacts from maternal and paternal exposure to DDT with impacts on placental genes, growth and function, and metabolic parameters in offspring. “[T]he evidence shows that OCPs, particularly DDT and its metabolite DDE, disrupt thyroid function in both humans and other animals,” the authors affirm.

Per- and Poly-Fluoroalkyl Substance (PFAS)

PFASs are a class of human-made chemicals of increasing concern that are also highly persistent and chemically stable. “[M]ixtures of PFASs are commonly found in drinking water, and serum PFASs are detected in up to 99% of the population,” the researchers report. Exposure to PFAS is negatively associated with TSH and free T4 levels, causing implications for early neurodevelopment. Prenatal exposure to PFASs is also negatively associated with the IQ of school-aged children.

Studies have detected higher levels of PFAS in infants with congenital hypothyroidism, which offers a link between PFAS exposure and thyroid function. Additional research highlights the potential for multi-transgenerational effects with PFAS as thyroid disruptors as well. “Concerning thyroid cancer, PFAS exposure has been previously associated with an increased risk of papillary thyroid tumor development in humans,” say the authors. They continue, “The carcinogenesis associated with PFAS exposure has been related to changes in epigenetic mechanisms, immunosuppression, increased oxidative stress/inflammation, [and] alterations in hormonal/metabolic pathways.”

Summary of Health Implications

Through the review of a multitude of studies, the researchers find that EDCs alter thyroid function and hormone levels through several pathways. These changes impact cellular physiology and gene expression, which then leads to additional health implications. “Exposure to phthalates, bisphenols, DDT, and PFASs has been linked to disruptions in the function of the hypothalamus–pituitary–thyroid axis, as well as in the cellular physiology and gene expression of thyrocytes,” the authors summarize. Thyrocytes are the primary cells in the thyroid gland that produce and secrete thyroid hormones. “Research indicates that these EDCs impair the activity and expression of proteins critical for thyroid hormone synthesis. Additionally, findings suggest that these EDCs possibly alter signaling pathways and epigenetic mechanisms that regulate gene expression in thyrocytes,” they conclude.

The studies analyzed showcase the associations between thyroid dysfunction and various conditions such as with cardiovascular, metabolic, reproductive, neurological, behavioral, and fetal development disorders. With these findings, and the importance of TH throughout the entire body, the authors call attention to the chemicals that impair thyroid function and can have deleterious effects throughout generations.

History of EDC and Thyroid Function

The literature review in Endocrines is the latest addition to the scientific critiques showing the adverse effects from EDCs. Previous epidemiological studies find an increase in the incidence and prevalence of diseases associated with exposure to EDC. These include higher rates of breast, thyroid, prostate, and testicular cancers, diabetes, obesity, and decreased fertility over the past 50+ years. These effects occur when compounds, such as those in EDCs, bind to hormone receptors, trigger disruption in key pathways, and disrupt hormone synthesis.

Global concerns for EDC have been noted, with the European Commission restricting known endocrine disruptors in 2023 as previously covered by Beyond Pesticides. The U.S. Environmental Protection Agency (EPA), however, has been under scrutiny for incomplete testing protocols for endocrine-disrupting pesticides. As reported earlier this year, EPA’s review of these chemicals ignores a range of chronic adverse health effects even at extremely low exposure levels. (See additional information on EPA failures pertaining to endocrine disruptors here and here.)

Other Beyond Pesticides’ coverage notes that the ingredients in many pesticides (and in many consumer products) act as endocrine disruptors in humans and other animals in several ways and urges advocates to take action in telling EPA to end the use of endocrine-disrupting pesticides. This is due to EDCs ability to: (1) mimic actions of hormones the body produces (e.g., estrogen or testosterone), causing reactions similar to those generated by the naturally produced hormones; (2) block hormone receptor cells, thereby preventing the actions of natural hormones; and/or (3) affect the synthesis, transport, metabolism, and/or excretion of hormones, thus altering the concentrations of natural hormones in tissues or at receptor sites.  

In 2021, Beyond Pesticides also reported, “Specific to thyroid function, pesticides can inhibit iodine uptake, binding to hormone receptors and transport proteins, and interfere with gene expression. However, impacts on the thyroid are not the only result of endocrine disruption. The entire endocrine system directly affects traditional endocrine glands and their hormones and receptors (i.e., estrogens, anti-androgens, thyroid hormones). Furthermore, endocrine disruption can negatively impact reproductive function, nervous system function, metabolic/immune function, and fetal/body development… Considering endocrine disruption has such close ties with hormone-related cancers like thyroid cancer, it is essential to avoid toxic chemical exposure to lessen potential cancer risks.”

Organic as the Solution

Beyond Pesticides’ mission is to provide healthy air, water, land, and food for current and future generations by eliminating all petrochemical pesticides, including EDCs, and synthetic fertilizers by 2032. Beyond Pesticides also advocates for a precautionary approach in how land is managed, with organic agriculture as the answer.

You can support this holistic solution by educating yourself through the Daily News Blog and the Pesticide-Induced Diseases Database, as well as buying or growing organic food. Make The Safer Choice regarding pesticides in your home and community, and sign up for Action of the Week and Weekly News Updates. For more information on why organic is the right choice for both consumers and the farmworkers who grow our food, see Health Benefits of Organic Agriculture.

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

Source:

Rodrigues, V.G. et al. (2024) Thyroid under Attack: The Adverse Impact of Plasticizers, Pesticides, and PFASs on Thyroid Function, Endocrines. Available at: https://www.mdpi.com/2673-396X/5/3/32.

(Beyond Pesticides, October 7, 2024) American Academy of Pediatrics (AAP) released a newly revised technical report describing how antibiotic use in animal agriculture contributes to the development of antibiotic resistance in medical use and can adversely affect child health— in the context of this fast-emerging threat to U.S. and global health. This AAP finding comes just as the United Nations (UN) held its second High-Level Meeting on Antimicrobial Resistance (AMR) on September 26 (the first was held in 2016) at which global leaders committed “to a clear set of targets and actions, including reducing the estimated 4.95 million human deaths associated with bacterial antimicrobial resistance (AMR) annually by 10% by 2030.”

The release from the UN, “World leaders commit to decisive action on antimicrobial resistance,” states, ”The Food and Agriculture Organization of the United Nations (FAO), the United Nations Environment Programme (UNEP), the World Health Organization (WHO) and the World Organisation for Animal Health (WOAH), known as the Quadripartite, welcome the declaration. The Quadripartite applauds countries for recognising the need for global, regional and national efforts to address AMR through a One Health approach, which recognizes that the health of people, animals, plants and the wider environment, including ecosystems, are closely linked and interdependent.” Inger Andersen, executive director of UNEP, said, “Today’s declaration recognises this need, and UNEP will continue to be at the forefront of efforts to reduce the burden of AMR on societies and tackle the triple [human health, agriculture and animal health, and environment] planetary crisis.”

The AAP report also discusses the need for U.S. initiatives to curb unnecessary use of antimicrobial agents in agriculture. The technical report Use of Antibiotics in Animal Agriculture: Implications for Pediatrics, from the AAP Committee on Infectious Diseases and the Council on Environmental Health and Climate Change, is available online and is published in the October issue of Pediatrics. Thus, the AAP joins others in urging support for “policies that strengthen oversight of antimicrobial use and require tracking and reporting of antibiotic use and resistance across human, animal, plant and environmental sectors.” 

>> Tell the U.S. Environmental Protection Agency (EPA) and Congress to save antibiotics for important medical uses and eliminate use as pesticides.

According to a 2021 article in Current Research in Microbial Sciences, “Antibiotic resistance in agriculture: Perspectives on upcoming strategies to overcome upsurge in resistance,” the leading consumers of antibiotics in developed countries are U.S. consumers. So, it would appear that the U.S. population may have the most to lose from antibiotic resistance. As Beyond Pesticides has previously covered, a report evaluating 204 countries published by the University of Washington’s Institute of Health Metrics and Evaluation, “Global burden of bacterial antimicrobial resistance in 2019: a systematic analysis,” generated the following statistics:

• 13.66 million people who died globally had sepsis as an immediate cause of death or in the chain of events leading to their death (intermediate cause).
• 4.95 million people who died in 2019 suffered from drug-resistant infections, such as lower respiratory, bloodstream, and intra-abdominal infections.
• 1.27 million deaths in 2019 were directly caused by AMR [antimicrobial resistance].
• 1 in 5 people who died from AMR was a child under 5 years old, often from previously treatable infections. 

According to the Food and Agriculture Organization of the U.N., the Global Research on Antimicrobial Resistance study found, “If action is not taken, the rise of AMR cumulatively may result in over 3.4 trillion USD loss in the world’s annual gross domestic product (GDP) in ten short years.

A 2020 scientific peer-reviewed article in Revista Panamericana de Salud Publica (Pan American Journal of Public Health)—a publication of the Pan American Health Organization, ”From environment to clinic: the role of pesticides in antimicrobial resistance,” finds the following: “Available evidence suggests that the natural environment may be a key dissemination route for antibiotic-resistant genes. Understanding the interrelationship of soil, water, and pesticides is fundamental to raising awareness of the need for environmental monitoring programs and overcoming the current crisis of AMR.”   

ReAct, an independent worldwide network focused on antibiotic resistance founded in 2005, has characterized the problem from perspectives around the world, “[A]ntibiotic resistance is here now and is a global leading cause of suffering and unnecessary loss of lives across the world. The global response must finally start to reflect this fact.” 

Not all antimicrobial pesticides are registered for their antimicrobial action. For example, the herbicides glyphosate, 2,4-D, and dicamba are able to create resistance in Salmonella and E. coli. From another health perspective, antimicrobial pesticides may negatively affect the gut microbiome, which is essential for human nutrition and immune system function. Health advocates maintain that EPA must cease registration of pesticides with antimicrobial effects (or potential antimicrobial effects) in human pathogens or beneficial human microbiota. 

The researchers and agencies raising the alarm exhibit a higher degree of concern about antimicrobial resistance—understood as a growing worldwide pandemic—than the history and ongoing inaction by EPA—resulting in the allowance of widespread nonmedical uses of antibiotics in agriculture and on synthetic (or artificial) turf. Contrary to broad scientific understanding, EPA told a federal appeals court, “There is no data that antibiotic use in agriculture leads to the presence of antibiotic resistance in bacteria of human health concern,” and that “[a]t the present time, there is little evidence for or against the presence of microbes of human health concern in the plant agricultural environment.” 

EPA’s inaction, despite the agency’s sponsoring of research that confirms the spread of antibiotic resistance to humans from horizontal gene transfer in the environment, only adds to the problem. As drug resistance has been documented as being on the rise for years, EPA’s response, or lack thereof, has been increasingly apparent. In one case, as previously reported by Beyond Pesticides, “The agency failed to assess the efficacy of any pesticides that are not used for public health purposes; EPA only evaluated the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related—thus ignoring the impact of other antimicrobial pesticides on resistance in human pathogens.”   

Despite litigation and copious studies, there is a growing crisis in health care due to drastic increases in antibiotic resistance. Nonorganic agricultural practices, which utilize antibiotics in crop and livestock production, exacerbate this major health issue by also applying harmful pesticides that promote antibiotic resistance genes in bacteria. In addition, use of antimicrobial pesticides harms the beneficial microbiota in the soil as well as in humans. Despite resistance on many farms that have led to harm and collapse, there are organic methods that offer a path forward. The foundation of all organic land management systems starts in the soil, which highlights the importance of promoting healthy soil and the microorganisms within it. 

>> Tell the U.S. Environmental Protection Agency (EPA) and Congress to save antibiotics for important medical uses and eliminate use as pesticides. 

EPA Administrator Michael Regan
Antimicrobial resistance is rising to dangerously high levels. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” They continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”

The American Academy of Pediatrics (AAP) has joined the ranks of those urging support for “policies that strengthen oversight of antimicrobial use and require tracking and reporting of antibiotic use and resistance across human, animal, plant and environmental sectors.” The AAP technical report, Use of Antibiotics in Animal Agriculture: Implications for Pediatrics, from the AAP Committee on Infectious Diseases and the Council on Environmental Health and Climate Change describes how the use of antibiotics in animal agriculture contributes to the development of resistance and can adversely affect child health, and discusses the need for U.S. initiatives to curb unnecessary use of antimicrobial agents in agriculture. It is available online and is published in the October issue of Pediatrics.

The spread of antibiotic resistance is a healthcare crisis of major proportions and requires a moratorium on the use of antibiotics in agriculture. The Centers for Disease Control and Prevention (CDC) calls antibiotic resistance “an urgent global public health threat, killing at least 1.27 million people worldwide and associated with nearly 5 million deaths in 2019.” 

Furthermore, according to the CDC, “More than 2.8 million antimicrobial-resistant infections occur in the U.S. each year, and more than 35,000 people die as a result. When Clostridioides difficile—a bacterium that is not typically resistant but can cause deadly diarrhea is associated with antibiotic use—is added to these, the U.S. toll of all the threats in the report exceeds 3 million infections and 48,000 deaths.” Many bacterial infections are becoming resistant to the most commonly prescribed antibiotics, resulting in longer-lasting infections, higher medical expenses, and the need for more expensive or hazardous medications. The development and spread of antibiotic resistance are inevitable effects of the use of antibiotics. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance.

Unfortunately, the medical profession lacks complete control over the use of antimicrobials. Many of the same chemicals used in human medicine are also used in agriculture. These may show up in or on treated food, but can also spread antimicrobial resistance through horizontal gene transfer. So, in addition to ingesting antibiotics in our food, the movement of resistant bacteria and fungi in the environment contributes to this escalating crisis.

Finally, focusing on materials sold as antibiotics or antimicrobials is too shortsighted. First, science shows that the use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens. Thus, we must stop broadcasting pesticides in the environment. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides had been disseminated in the environment for decades.

EPA must not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and must cancel the registration of those that do.

Thank you.

U.S. Representative and Senators
Antimicrobial resistance is rising to dangerously high levels. In the May 1, 2022, issue of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. write, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” They continue, “A study suggests that if no actions are taken, antimicrobial resistance will cause 10 million deaths per year by 2050 and an economic impact of over 100 trillion United States dollars.”

The American Academy of Pediatrics (AAP) has joined the ranks of joins those urging support for “policies that strengthen oversight of antimicrobial use and require tracking and reporting of antibiotic use and resistance across human, animal, plant and environmental sectors.” The AAP technical report, Use of Antibiotics in Animal Agriculture: Implications for Pediatrics, from the Committee on Infectious Diseases and the Council on Environmental Health and Climate Change, describes how the use of antibiotics in animal agriculture contributes to the development of resistance and can adversely affect child health, and discusses the need for U.S. initiatives to curb unnecessary use of antimicrobial agents in agriculture. It is available online and is published in the October issue of Pediatrics.

The spread of antibiotic resistance is a healthcare crisis of major proportions and requires a moratorium on the use of antibiotics in agriculture. The Centers for Disease Control and Prevention (CDC) calls antibiotic resistance “an urgent global public health threat, killing at least 1.27 million people worldwide and associated with nearly 5 million deaths in 2019.” Furthermore, according to the CDC, “More than 2.8 million antimicrobial-resistant infections occur in the U.S. each year, and more than 35,000 people die as a result. When Clostridioides difficile—a bacterium that is not typically resistant but can cause deadly diarrhea is associated with antibiotic use—is added to these, the U.S. toll of all the threats in the report exceeds 3 million infections and 48,000 deaths.” Many bacterial infections are becoming resistant to the most commonly prescribed antibiotics, resulting in longer-lasting infections, higher medical expenses, and the need for more expensive or hazardous medications. The development and spread of antibiotic resistance are inevitable effects of the use of antibiotics. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance.

Unfortunately, the medical profession lacks complete control over the use of antimicrobials. Many of the same chemicals used in human medicine are also used in agriculture. These may show up in or on treated food, but can also spread antimicrobial resistance through horizontal gene transfer. So, in addition to ingesting antibiotics in our food, the movement of resistant bacteria and fungi in the environment contributes to this escalating crisis.

Finally, focusing on materials sold as antibiotics or antimicrobials is too shortsighted. First, science shows that the use of any antibiotics anywhere can increase antibiotic resistance everywhere. Second, many pesticides not intended to kill microbes—such as the herbicides glyphosate, 2,4-D, and dicamba—also induce antibiotic resistance in deadly human pathogens. Thus, we must stop broadcasting pesticides in the environment. The crisis in antibiotic resistance, which creates a threat of another pandemic, is ignored in the registration of pesticides. The antibiotic impacts of pesticides cited above were discovered only after the pesticides had been disseminated in the environment for decades.

Please ensure that EPA does not register pesticides unless they have been demonstrated not to contribute to antibiotic resistance and cancels the registration of those that do.

Thank you.

(Beyond Pesticides, October 4, 2024) Coffee is a staple of morning routines for millions around the nation—and as the demand for coffee remains high, so goes the surge in certified organic coffee, offering space for coffee lovers to enjoy the drink and lower their carbon footprint, according a study in Cleaner and Circular Bioeconomy. A 2024 survey conducted by the International Food Information Council found that “[t]he majority of Americans (88%) consume caffeine, with 8 in 10 reporting they consume it daily, and nearly half (47%) reporting they consume it multiple times a day.” Coffee overwhelmingly leads in popularity, with 54% of respondents indicating the beverage as their preferred source of caffeine with soft drinks a distant second (17%).

Researchers found in the new coffee production study that certified organic coffee producers in Peru have a lower carbon footprint than transitional organic coffee farmers. As organic land management practices and principles continue to proliferate, advocates continue to stress the importance of third-party certification as an integral part of the integrity of the USDA organic label, overseen by the National Organic Program. As the National Organic Standards Board goes through its mandatory public comment review this month, consumers, companies, farmers, and policymakers engage in rigorous review of organic production across all crops.

“The results indicate that the average emissions for the production units classified as in transition are equivalent to 1.11 kg CO₂e per kilogram of green coffee, while for the organic production units, the average emissions associated with 1 kg of green coffee are equivalent to 0.68 kg CO₂e.” The data for this study was based on ten farms (a.k.a “production units/PUs” in the study) that are members of an organic coffee cooperative located in Cajamarca, Peru. Five of the farms are “organic” and the other five farms were “in transition,” meaning that some practices and principles are applied but are not subject to inspection and certification. The researchers conducted a life cycle assessment, analyzing the carbon footprint of each farm through an iterative process in alignment with the International Organization for Standardization principles and framework followed by researchers internationally (see here and here).

Researchers measure each stage of the coffee from “cradle to gate,” starting with cultivation and harvesting, and then moving on to wet processing, dry processing, and harboring (referring to exporting from ports). An important feature of life cycle assessments includes an annual inventory of the inputs and outputs for each of the phases. Under the Materials and Methods section, see Table 1 for data used to model field emissions, Table 2 for primary source data for the breakdown of inputs and outputs for coffee cherry (raw fruit pre-processing), Table 3 for equivalent data for coffee parchment (product post-wet processing stage), and Table 4 for data concerning the inputs and outputs per metric ton of “green coffee” (final product).

Researchers highlight several other conclusions from their statistical analysis of the data gathered from the ten farms in the study:

• “One way to reduce the carbon footprint of organic coffee production is through the use of organic fertilizers produced on site. Organic fertilizers are those that come from organic wastes that have been decomposed by microbial means.”
• “It is observed that “organic” production units PU08 and PU07, and the “in transition” production unit PU02 have the best relative eco-efficiency by having the best combination of lower costs and environmental impacts because they would have the best combinations of costs incurred and environmental impacts generated such as fertilizers and water, while production unit PU05 has the worst performance due to the amount of fertilizer used (guano).”
• “Thus, an opportunity for improvement to be developed by the government is to develop specific guidelines for the management of organic coffee that will serve as a tool to transfer knowledge, especially to these small farmers whose main reference is the knowledge transmitted from generation to generation.”

This type of study establishes a roadmap for the continuous research that organic advocates believe incentivizes farmers to transition to organic for a variety of benefits, including soil health and carbon sequestration. “Considering that there are few carbon footprint studies of organic coffee in small farms, that most of the world’s coffee production is concentrated in developing countries and they are now obliged to comply with the signed GHG [greenhouse gas] emissions reduction objectives in the Paris Agreement [], the aim of this study is to analyze and estimate the carbon footprint of organic coffee in order to provide knowledge that can be used to design mitigation strategies in the Peruvian coffee sector located in Cajamarca, Peru.” A group of researchers from Pontifical Catholic University of Peru led this study, with expertise drawn from the Peruvian Network for Life Cycle and Industrial Ecology (PELCAN) and Crisis and Disaster Management Group housed under the Department of Engineering. In the conclusion of this study, researchers indicate that they intend to launch an additional study that will incorporate more organic and transitional sites to build the credibility of these initial findings.

Organic Coffee Data

What is the state of organic coffee in the United States?

There are just 49 certified organic coffee farms in the United States (located in California and Hawai’i) contributing just shy of $1.5 million in sales due to climate constraints necessary for healthy production, based on the latest data from 2021 Organic Survey conducted by the U.S. Department of Agriculture’s (USDA) National Agriculture Statistics Service. Coffee Intelligence, a trade publication with sponsorship from Mayorga Coffee (“The largest exclusively organic coffee roastery in the U.S.”), identified an interesting contradiction between supply and demand: “While the overall [global] certified coffee area decreased by 2.5% in 2020, organic shot up by 24.6% in the same year” in sales. In other words, consumer demand is up while expansion of certified coffee lags.

“Farmers of organic coffee can and should focus on soil and tree health so that inputs are less or not at all required.” Colehour Bondera, Hawai’i-based organic farmer and Beyond Pesticides Board member shares his experiences and opportunities to quantify soil health benefits of organic coffee production. “Our farm has been working with other organic farms and with University of Hawaii, USDA, and Korean Natural Farming representatives in order to quantify and qualify the impacts of management and inputs which are local and which meet organic standards.” Initial results are promising with interest in strengthening available data on the carbon footprint of organic coffee in Hawai’i.

According to Research Institute of Organic Agriculture and IFOAM-Organic International’s 2024 report, “The World of Organic Agriculture Statistics and Emerging Trends 2024,” which pulled from publicly available data sourced from the private sector, certifiers, and government agencies, certified organic coffee production is up 7.9% between 2013 and 2022; however, the industry has faced recent setbacks in certification given the 17.7% decline in organic farmland for the sector between 2021 and 2022 (Table 9, p. 64). The vast majority of organic coffee is grown in Central and South America (over 421,965 hectares or over 1.04 million acres) according to the same data set (Table 13, p. 72). This is consistent with data published by the Organic Trade Association, which found that Peru produces the vast majority of certified organic coffee compared to its neighbors, with 34,313 metric tons produced as of 2020 (the total for the region is 40,677 metric tons).

This relationship between increased consumer interest in certified organic and lagging domestic organic production is reflected in economic data gathered by USDA. In 2021, the total value of organic imports was $2.7 billion. The U.S. is projected to import 24.5 million bags of coffee beans (up 900,000 bags from the previous year) due to continuous demand for coffee, according to the 2024 USDA Foreign Agricultural Service report on world markets and trade for coffee. The USDA Economic Research Service and U.S. Census Bureau, in coordination with the USDA Foreign Agricultural Research Service, began collecting economic data on organic agricultural imports in 2011 and found that organic coffee accounted for seven percent of total coffee imports and organic coffee was the most imported commodity beyond soybeans, black tea, rice, and several other agricultural imports. It is unclear if there is updated data since 2011, as of the date of this publication.

“Small scale organic coffee production is doable if we all are working together to the same purposes and supporting one another,” Bondera reflects on the potential for growing the sector across the United States. At the conclusion of National Organic Month at the end of September, support for organic agriculture continues to mount ahead of the National Organic Standards Board fall meeting. The Board will review public comments and make decisions that will define the integrity of national organic standards. See previous Actions of the Week here and here to continue engaging in keeping organic strong. See Keeping Organic Strong to learn about the various issues and opportunities to improve organic standards.

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

Source: Cleaner and Circular Bioeconomy

(Beyond Pesticides, October 3, 2024) The American Academy of Pediatrics published a technical report in September on antimicrobial resistance, which it calls a global public health threat, identifying the health implications of antibiotic use in animal agriculture. The lead authors, both medical doctors from the Department of Pediatrics at Vanderbilt University Medical Center, note the rise in antimicrobial-resistant infections that result in increased morbidity, mortality, and health care costs for not only adults, but infants and children as well. “[A]ll use of antimicrobial agents exerts selective pressure that increases the risk of development of resistance,” the authors state, highlighting the importance of limiting antimicrobial uses.

“Antimicrobial resistance is an organism’s ability to survive exposure to an antimicrobial agent that was previously an effective treatment. Resistance traits can be acquired either through new mutations or through transfer of genetic material between organisms,” the authors report. Antimicrobial-resistant pathogens, such as bacteria and viruses, can be transmitted “through the food supply, direct contact with animals, environmental pathways, and contact with infected or colonized humans,” they continue. Use of antimicrobial agents, especially over extended periods of time or with repeated exposure, can cause resistance to not only that agent, but to multiple agents.

As previously reported by Beyond Pesticides, the increased use of antimicrobial products alarms scientists, public health professionals, farmers, and various other stakeholders concerned with holistic environmental health. Antimicrobial resistance is a global crisis, as recorded in a 2019 study published in Science, where researchers identified hotspots of resistance in northeastern India, northeastern China, northern Pakistan, Iran, eastern Turkey, the south coast of Brazil, Egypt, the Red River Delta in Vietnam, and the areas surrounding Mexico City and Johannesburg. Additional studies have documented that antimicrobial pesticide exposure causes adverse impacts on gut microbiome health and fungal resistance leading to deadly infections, among other health effects. While antimicrobial use and the resulting resistance it causes are a threat all around the world, the authors of this report focus on statistics and implications within the United States (U.S.).

The “One Health” concept that the authors denote is an approach that embraces the interconnectivity between the health of people and the health of animals in a shared environment. Human health is threatened when the health of organisms and the ecosystem are affected. “Antimicrobial-susceptible and -resistant animal pathogens can reach humans through the food supply, by direct contact with animals, or through environmental contamination, including human wastewater treatment runoff, hospital effluent, and birds and other freely moving wildlife,” the authors state. “Children may also be exposed to pathogens through direct interaction with colonized or infected adults or animals, including companion animals (i.e., family pets).”

Of note is that resistant bacteria can be spread through fecal material, such as improperly composted manure that contains resistant organisms being applied to agricultural soils and contaminating food products. Runoff from farms can also impact water bodies as well. Additional contamination can occur in fruits and vegetables when wastewater is used to irrigate crops and when fish are raised in contaminated water, which puts all consumers at risk.

According to the authors, “Active antimicrobial agents have been detected in surface waters and river sediments, and resistance genes identical to those found in swine waste lagoons have been found in groundwater and soil microbes hundreds of meters downstream. These findings raise concerns that environmental contamination with antimicrobial agents from agricultural and human use could present microbial populations with selective pressure, stimulate horizontal gene transfer, and amplify the number and variety of organisms that are resistant to antimicrobial agents.” (See previous coverage from Beyond Pesticides on horizontal gene transfer here.)

Multidrug resistance has been documented in copious studies. The authors highlight a well-known study where chickens, who were given low-dose tetracycline in their food over an extended period of time, developed multidrug resistance that then spread between chickens in the same environment and to people also living on the farm. Beyond Pesticides has also previously reported on this resistance with an important article in The Lancet pointing to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”

The authors reference an abundance of studies that underscore the role of resistance in bacteria with health implications. In 2011, a study showed meat and poultry samples from five U.S. cities had Staphylococcus aureus contamination in 77% of turkey samples, 42% of pork samples, 41% of chicken samples, and 37% of beef samples. From these samples, 96% were resistant to at least one antimicrobial agent while many were resistant to other antimicrobial classes as well. Resistance from Escherichia coli (E. coli) strains, known to cause human urinary tract infections, sepsis, and other infections, are also linked to antibiotic use in food animals.

The majority of foodborne illnesses in children, the authors report, are caused by Salmonella species. A study from 2013 estimated that Salmonella infection results in 123,452 illnesses, 44,369 physician visits, 4,670 hospitalizations, and 38 deaths annually among children younger than five years in the U.S. Additionally, “[t]he CDC [Centers for Disease Control and Prevention] estimated in 2019 that there were 1.35 million nontyphoidal Salmonella infections in the United States per year, of which 20,800 were resistant to 3 or more classes of antibiotics,” the authors state.

Campylobacter infections are also prevalent. They have been estimated as the cause of 81,796 illnesses, 28,040 physician visits, 1,042 hospitalizations, and six deaths annually in U.S. children younger than five years old. “One outbreak of extremely drug-resistant Campylobacter,” the authors share, “included 168 patients with 117 (70%) reporting contact with a dog before symptoms and 69 (41%) reporting contact with a pet store puppy,” which brings a spotlight on the transmission potential between animals and humans. CDC estimated that in 2019 there were 1.5 million infections involving species of Campylobacter, 448,400 of which had reduced susceptibility to antibiotics in the classes of fluoroquinolones and macrolides that are commonly prescribed.    

Pesticides, such as the weed killer glyphosate, can also induce antibiotic resistance. In a previous article, Beyond Pesticides highlights resistance in deadly hospital-acquired bacteria as detailed in a 2022 study in Scientific Reports. This finding is one of many connecting commonly used herbicides to the rise of antibiotic-resistant bacteria, with prior research showing glyphosate, 2,4-D, and dicamba able to create resistance in Salmonella and E. coli.

In additional coverage, Beyond Pesticides reports that antibiotic-resistant genes, considered a class of pollutants, are found in certain types of bacteria and can spread through the environment and subsequently to humans and animals, with an increase in specific bacterial families that host these genes linked to pesticide exposure. (See additional study on E. coli resistance when exposed to pesticides.) These studies add to the history of pesticide usage that correlates with higher antibiotic resistance.

The authors of the technical report also call attention to the statistics from 2020 in which 18,462 infections, 4,788 hospitalizations, and 118 deaths of both children and adults were reported to the Foodborne Diseases Active Surveillance Network, a surveillance system of CDC that covers only 15% of the U.S. population. Among the infections, the number of cases was highest among individuals younger than five years of age, which shows disproportionate risk for very young children.

According to the U.S. Food and Drug Administration (FDA), antimicrobial sales for food animals (defined as animals that are raised and used for food production or consumption by humans), in the U.S. in 2020 accounted for more than 23 million pounds of antimicrobial drug active ingredients. In the same year, FDA implemented a guidance under the Veterinary Feed Directive to control the use of antibiotics. For 2020, only “4% of antibiotics used in agriculture were dispensed over-the-counter without a prescription, and the remainder were dispensed under the direction of a licensed veterinarian or with a prescription,” the authors say. “Additionally, in 2021, the FDA issued GFI #263, and as of June 11, 2023, all sales of antimicrobial agents are now under veterinary oversight, eliminating over-the-counter sales of medically important antimicrobial agents for animal production in the United States.”

The 2023 guidance, requiring a veterinary prescription for all medically important animal antimicrobial agents, states that antimicrobial use in food animals can only include treatment, prevention, and control of infectious diseases. Use of antibiotics, however, is prohibited in all certified organic food production. While the standards of the National Organic Program require that sick animals be treated, any meat and other products from such animals cannot be sold with the Certified Organic designation. While guidance improvements from FDA help to curb over-the-counter use of antibiotics, antimicrobial resistance is still rampant. Adopting organic methods, especially in food production, mitigates high resistance rates from contaminated food and environmental exposure.

Apart from the human health risks, antimicrobial-resistant infections are “often costly to treat, increase health care utilization, and increase morbidity and mortality,” the authors say. CDC findings “report that more than 2.8 million Americans become ill with antimicrobial-resistant infections each year, with more than 35,000 resulting deaths. Antimicrobial-resistant infections are estimated to cost between $21 billion and $34 billion annually, resulting in 8 million additional hospital days.”

Even with these estimations, the true impact of antimicrobial use in animal agriculture in the U.S. is unknown, as are the subsequent health effects that occur as a result of resistance. In contrast to the limited data in the U.S., “the European Union has implemented legislation to increase transparency, such as mandatory monitoring of antimicrobial use on farms,” the authors share. They also note, “Because of legislation in the European Union, antimicrobial sales for food animal production dropped by 43.2% on a biomass-adjusted (mg per population correction unit) basis from 2011 to 2020.”

While the increase in antimicrobial resistance in the U.S. necessitates a need for similar increased transparency, a switch to a system, such as organic, that eliminates antimicrobial uses in food products provides a more holistic alternative with many additional benefits. As the authors conclude, “The majority of antibiotic sales in the United States occurs for use in farm animals, potentially selecting for emergence and spread of drug-resistant pathogens than can harm the health of all individuals, including children.” The solution that protects human health, as well as the health of all organisms and the environment, is organic.

As noted in past coverage, prior research on resistance in agriculture has shown that the only true way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century. Rising resistance, and the need to retain life-saving medication for protecting people’s health, not growing crops, is another reason why investing in organic is the right choice for the future.

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

Source:

Katz, S.E. and Banerjee, R. (2024) Use of Antibiotics in Animal Agriculture: Implications for Pediatrics: Technical Report, Pediatrics. Available at: https://publications.aap.org/pediatrics/article/doi/10.1542/peds.2024-068467/199441/Use-of-Antibiotics-in-Animal-Agriculture.

(Beyond Pesticides, October 2, 2024) A comprehensive literature review in Ecotoxicology and Environmental Safety links a heightened risk of spontaneous abortion (SAB) with pesticide exposure. “The strengths of our study include being the first systematic review and meta-analysis to explore the association between exposure to pesticides and the risk of SAB,” the authors say. This novel approach includes analyzing 18 studies, totaling 439,097 pregnant participants, that allows the researchers to highlight an important public health issue and raise concerns for maternal contact with the harmful chemicals in pesticide products.

SAB, also known as spontaneous miscarriage, is defined as the loss of pregnancy occurring prior to 20 weeks of gestation. “It has been observed that approximately 10–15% of pregnancies end up terminating spontaneously,” the researchers report. According to the authors, these negative birth outcomes can be attributed to many factors such as advanced maternal age, anatomical, immunological, and endocrinological disorders, infections, tobacco use, alcohol intake, abnormalities of the placenta, and exposure to heavy metals, radiation, and pesticides.

To connect SAB specifically to pesticide exposure in mothers, a literature search was conducted for peer-reviewed studies that include pregnant study participants, ages 16 and above, who report “exposure to one or more pesticides or their metabolites, as singular compounds or as mixtures, compared with women with no history of pesticide exposure or those exposed to low doses of pesticides.” 18 studies, comprising hundreds of thousands of participants, matched these parameters and include four case-control studies, as well as eleven cohorts and three cross-sectional analyses.

These studies were predominantly conducted in the United States (U.S.) and Italy, and they reveal organophosphate pesticides as the most used type of chemical that the mothers reported. (See more coverage on organophosphates here.) From the studies, “[t]he frequency of SAB events and the total number of patients in each group were used to calculate the Relative Risk (RR),” the authors note. The RR represents an effect measure to quantify the association between the exposure and the outcome.

As a result of their analysis, the researchers find “a significant 41% increase in SAB risk among pregnant women exposed to pesticides compared to pregnant women without exposure to pesticides.” This correlation highlights the additional risks expectant mothers have for one of many negative birth outcomes that pesticides have been found to exacerbate.

“Exposure to pesticides has been proposed as a potential contributor to adverse pregnancy outcomes, possibly through the induction of inflammation, oxidative stress, and disruption of endocrine functions,” the authors share. They continue, “Females exposed to pesticides may experience various reproductive complications, such as abnormal menstruation, diminished fertility, SAB, preterm or post-term delivery, dead fetuses, congenital anomalies, and decreased birth weight. Pesticides can cross the placenta and harm the developing fetus. This can lead to problems with cellular division and differentiation, potentially causing developmental aberrations and increasing the risk of miscarriage.”

Many studies have revealed maternal exposure, both prior to conception and during pregnancy, that impacts the health of the fetus. These impacts not only include fetal death or stillbirth but life-long development effects as well. See previous coverage on the impacts of pesticides on both mothers and children here, here, here, and here.

Studies have found that regions with significant pesticide exposure have higher prevalence rates of miscarriage per 100,000 inhabitants compared to areas with lower exposure levels, which suggests pesticide exposure has negative effects on the fetus or the fetus–placenta complex. Other studies link pesticides to oxidative stress (see studies here and here), which is known to contribute to miscarriage through impaired placentation.

The researchers hypothesize that pesticides could cause SAB by impacting steroid receptors that play a role in fetal programming for development and immune function based on previous studies. Exposure may also adversely affect reproductive and embryonic development through mitotic anomalies or chromosome aberrations. “These findings highlight how pesticides impact placental processes, potentially contributing to adverse pregnancy outcomes,” the authors state.

Another study finds noncompliance with personal protective equipment (PPE) regulations to be linked to a 7.6 times greater risk of SAB, which is substantial for pregnant farmworkers. Farmworkers and their families are both threatened, as increased risk of SAB “may result from workers unknowingly carrying pesticide residues home on their clothing or personal items, exposing their spouses,” the researchers note. These findings emphasize “the importance of considering both direct and indirect exposure pathways in understanding the relationship between paternal [and maternal] pesticide exposure and adverse pregnancy outcomes, further highlighting the need for comprehensive workplace safety measures.”  

As the authors conclude, “the synthesis of evidence from the included studies consistently demonstrated an increased risk of SAB associated with pesticide exposure.” There is a myriad of health effects that are correlated to both short-term and long-term contact with pesticide products, with certain individuals at a disproportionate risk. Infants and children take in more chemicals relative to body size than adults, which leaves them at a heightened risk of toxic exposure because their organ systems are still developing. Fetuses are especially vulnerable in the womb while they are undergoing extensive growth and development.

Removing exposure to these harmful contaminants would mitigate not only negative birth outcomes for expectant mothers but would protect all populations. Organic agriculture protects farmworkers and their families, as well as all consumers. Organic methods reduce exposure to chemicals in food and remove pesticide drift from the air and water contamination. Organic food can feed us and keep us healthy without producing the toxic effects of chemical agriculture.

Pesticide-free lawns and landscapes also allow for safe areas that wildlife, children, and pets can enjoy without unnecessary risk. Managing these areas in a safe and effective manner is possible through Products Compatible with Organic Landscape Management and ManageSafe™. Using healthier alternatives to pesticides, choosing organic food, and making The Safer Choice can protect health and the environment. Be part of the organic solution by taking action, joining Beyond Pesticides as a member, or by supporting our mission with a gift today.

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

Source:

Albadrani, M.S., Aljassim, M.T. and El-Tokhy, A.I. (2024) Pesticide exposure and spontaneous abortion risk: A comprehensive systematic review and meta-analysis, Ecotoxicology and Environmental Safety. Available at: https://www.sciencedirect.com/science/article/pii/S0147651324010765.

(Beyond Pesticides, October 1, 2024) While the Environmental Protection Agency (EPA) received accolades for its August 7, 2024, decision to ban the herbicide Dacthal (or DCPA—dimethyl tetrachloroterephthalate), it also leaves many people asking, “Why Dacthal and not other very hazardous pesticides?” Paraquat, for example, poses similar elevated hazards to people and the environment, has no antidote, and has viable alternatives. Therefore, Beyond Pesticides is challenging EPA to apply the same standard that removed Dacthal from the market to the long list of pesticides that are contributing to a health crisis, biodiversity collapse, and the climate emergency. 

In the case of Dacthal, EPA used the “imminent hazard” clause of the federal pesticide law to immediately suspend the chemical’s use. At the same time, the agency is exercising its authority to prohibit the continued use of Dacthal’s existing stocks, a power that EPA rarely uses. Additionally, the agency, in coordination with the U.S. Department of Agriculture, found that there were alternatives to Dacthal. Based on the reasoning in the Dacthal decision, EPA should ban paraquat, Beyond Pesticides says.

>> EPA must apply the standard of the Dacthal decision to paraquat and issue an emergency suspension and prohibit use of existing stocks. 

Paraquat poses immediate serious harms to people and the environment. [First factor used in Dacthal decision]
Citing serious health issues associated with its use, including Parkinson’s disease, and inaction by EPA, a number of legislative efforts have been undertaken to ban paraquat. A bill in California, originally introduced as a ban bill (AB 1963), was amended to require state review and passed in August. According to the California Legislative Information website, the legislation “[r]equires, on or before January 1, 2029, the Department of Pesticide Regulation (DPR) to complete a reevaluation of paraquat dichloride (paraquat), and make the determination to retain, cancel, or suspend its registration, or to place new appropriate restrictions on the use of paraquat.” The bill’s passage 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. Paraquat was banned in the European Union in 2007, following its prohibition years earlier in 13 countries, including Sweden, Denmark, and Austria. Now, over 60 countries have banned the use, production, and sale of paraquat, including China, where it was first developed. 

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

A 2005 study in Toxicological Sciences was able to “reproduce features of Parkinson’s disease (PD) in experimental animals.” Studies continued to replicate findings associating paraquat with Parkinson’s disease, as EPA continued to reject the need for action. In the U.S., paraquat is currently a restricted-use pesticide (meaning it can only be applied by certified applicators or those working under their on- or off-site supervision) and banned on golf courses. There is established and mounting evidence of links between minimal exposure and various adverse health impacts for humans and wildlife.  

Beyond Pesticides continues to track the latest scientific literature on adverse health impacts of paraquat. Within all the single-pollutant models employed in a 2022 study published in the Journal of Clinical Endocrinology and Metabolism, researchers found a linkage between paraquat dichloride and thyroid cancer. Another study published that same year in the Independent determined the toxic impacts of paraquat on bird embryos, including the Japanese quail, mallards, bobwhite quail, and ring-necked pheasant.

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

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

>> EPA must apply the standard of the Dacthal decision to paraquat and issue an emergency suspension and prohibit use of existing stocks. 

Mitigation measures have not eliminated the harm. [Second factor used in Dacthal decision]
In 2018, EPA downplayed the connection between exposure to paraquat and the development of Parkinson’s disease in registration review documents released by the agency. But California Assemblymember Friedman, the prime sponsor of AB1963 (cited above), in a press release on the day the California legislation was introduced, said, “We cannot afford to ignore decades of mounting evidence linking paraquat exposure to Parkinson’s disease, non-Hodgkin lymphoma, and childhood leukemia.” She continued: “In 2021, the latest year for which data are publicly available, just over 430,000 pounds were applied in California, primarily in Kern, Kings, Fresno, Merced, and Tulare counties. The herbicide is extremely toxic to humans, with low doses causing death, and it has been linked to increased risk of Parkinson’s Disease.” 

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

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

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

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

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

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

EPA has sufficient information to cancel paraquat. EPA has the information above, which is in the open literature and/or provided in regulatory comments by Beyond Pesticides and others. The failed regulation, and subsequent harm, caused by paraquat is but one representation of a failed regulatory system that can and should do more to eliminate the use of toxic petrochemical-based pesticides. The convergence of crosscutting crises of health threats, biodiversity collapse, and the climate emergency stems from continued reliance on fossil fuels and petrochemical pesticides and fertilizers, which perpetuate the harms of greenhouse gas emissions. These crises are causing ecosystem fragmentation and failure, and public health crises that undermine the nutritional integrity of the food supply and the scientific integrity the public relies on for safety and well-being.

After decades of working with farmworkers and farmers who face the brunt of toxic pesticide exposure, Beyond Pesticides urges the expansion and strengthening of organic land management principles to move beyond the existing product substitution framework, or pesticide treadmill, that leads to the continuous use of toxic pesticides.

EPA Administrator Michal Regan
I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. Now, I respectfully request that EPA apply the same criteria to paraquat and stop its use.

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

Please apply the three following criteria to paraquat, the three factors used to ban Dacthal.

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

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

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

2. Mitigation measures have not eliminated harm.

EPA has downplayed the connection between exposure to paraquat and the development of Parkinson’s disease in registration review documents released by the agency, leading numerous legislators to call for the banning of paraquat.

3. The public does not benefit from continued use.

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

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

Please apply the standard of the Dacthal decision to paraquat. Issue an emergency suspension and prohibit use of existing stocks.

Thank you.

Members of Congress
I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. However, paraquat fits the criteria used to ban Dacthal. All of this is known to EPA.

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

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

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

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

2. Mitigation measures have not eliminated harm.

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

3. The public does not benefit from the continued use of paraquat.

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

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

Tell EPA to apply the standard of the Dacthal decision consistently—to ban paraquat.

Thank you.

(Beyond Pesticides, September 30, 2024) Public Comment Period on Issues of Organic Integrity Closes Today. Farming is a notoriously risky enterprise, and organic farming presents further challenges along with its multiple benefits. Generally, organic has made great strides over the last several years and is strongly supported by American consumers, findings in the latest U.S. Department of Agriculture (USDA) Census. Even late this year, there is the prospect of several more important changes that will improve the organic certification process and some issues that will take more policy changes to resolve in the future. As a part of this process to ensure the integrity of the USDA organic label and the permitted production practices, Beyond Pesticides urges that the public submit comments TODAY (the last day for the comment period) on issues currently before the National Organic Standards Board (NOSB). See two sets of comments on key issues that can be submitted with one click each. Click here on issues related to use of plastic, nonorganic ingredients in processed food, and seeds and plant starts. Click here on inert ingredients, contaminants in compost, and drugs in livestock production.

U.S. agriculture overall has remained fairly robust between the USDA Census in 2017 and the most recent one in 2022. USDA released its report comparing the two years last February.

The number of organic farmers between 35 and 44 years old grew by 15 percent, and the percentage of female principals rose by 3 percent. And, total organic product sales jumped by 24 percent, despite the intervention of the Covid pandemic. However, organic has experienced slower growth than the full sector. The number of certified organic farms dropped by four percent over the five-year interval; worse, the number of transitioning farms fell by more than half. This is not just an agricultural issue, this is a societal issue, given the need to adopt land management practices that eliminate petrochemical pesticides and fertilizers and adopt practices that reverse the existential health, biodiversity, and climate crises. “These statistics show that organic land management is still not recognized by the government as performing a social good that requires significant public investment if we are to replace unsustainable practices that are having dramatic adverse effects on people’s health, the health of the ecosystem, and weather, resulting in life-threatening events,” said Jay Feldman, executive director of Beyond Pesticides.

The success of organic agriculture has produced some pressures on organic certification that may not have been anticipated. As consumer demand grows, uncertified producers have an incentive to sneak under the organic umbrella. Many cases of fraud, both inside the United States and in imports, have revealed holes in the certification chain; and for years many organic advocates have been concerned about non-organic ingredients and techniques being allowed under the certification stamp, violating organic principles without proper vetting.

The organic context
Valid and encouraged constructive criticism of organic must be put in the context of a chemical-intensive food system that contributes to adverse impacts on people, workers, and the environment. The organic discussion begins with what is known about contaminants generally in the food supply, both domestically grown and imported. Central to this discussion is the adequacy of regulations governing pesticides and the laws and regulations under the Federal Insecticide, Fungicide, and Rodenticide Act—the degree to which there is adequate protection from levels of pesticide residues in food, air, water, and land, as well as the occupational exposure to farmworkers and farmers. There are numerous General Accountability Office reports that capture the issues, as well as numerous Office of General Counsel reports, academic studies, and scientific articles. (See Beyond Pesticides’ Resources)

The discussion also starts with what is mandated under the Organic Foods Production Act, where virtually all synthetic pesticides are prohibited as are all synthetic fertilizers. From this perspective alone, a look at pesticide use that intersects with current public health issues (major diseases associated with pesticides in the scientific literature), biodiversity decline, and climate, it is undisputed that organic is an improvement in the protections it offers. All the pesticides that have gotten headlines in the media (neonicotinoids, glyphosate, dicamba, 2,4-D, and genetically engineered crops, which have increased reliance on herbicides) are prohibited in organic by statute. Biosolids are prohibited, which is where much PFAS is making its way onto farms as fertilizer.

With respect to the inspection and certification system that exists with organic labeling—there is nothing like this type of system in conventional (chemical-intensive) agriculture—a system that establishes compliance with the law and the requirement for an organic systems plan. Whether domestic or international, the certification system must meet U.S. standards if it is going to be sold in the U.S. as organic That means that the same system of oversight is required by the certifiers. Will there be those who break the law? Of course. So, while increased funding has gone into the National Organic Program (NOP) at USDA, more funding for oversight and stronger standards will be helpful.

Organic is a practice-based standard that requires practices and limits the allowance of synthetic inputs to the National List of Allowed and Prohibited Substances. It is reviewed on a five-year sunset cycle, with clear prohibitions. When there is drift or runoff from off-site, the law provides for a small fraction of what is allowed in conventional agriculture on food, but in most cases, organic farms are required to set up buffers to prevent drift from neighboring fields/sites. Organic advocates point to the need for continuous improvement and use the transparent public engagement process through the NOSB to advance organic integrity.

Ongoing Challenges with USDA on organic
First, the USDA set a March 19, 2024 enforcement deadline for its Strengthening Organic Enforcement (SOE) policy. The SOE aims to correct some of the porous boundaries in organic oversight. One of its principal steps is to require the middle parts of supply chains to certify that the products they are handling are truly organic. This includes traders, brokers, buyers and sellers, according to Food Business News—not just the producers, packagers, labelers, and processors currently covered. Organic companies typically hire a third-party consultant to shepherd them through certification. The new requirements produce a swarm of new entities needing certification, creating a backlog. And according to one certifier, if some middle-of-the-supply chain companies remain noncompliant, they will put everyone else at risk of unacceptable delays as the enforcement requirement rolls through the system. On September 19, a bipartisan group of U.S. representatives asked NOP to extend the deadline for compliance with the SOE because third-party certifiers cannot keep up.

Another part of the SOE aims to prevent imports of products falsely claiming to be organic by imposing a requirement that all organic goods are certified at the borders. A shocking case came to light in 2023 when an Oregon hazelnut grower, Bruce Kaser of Pratum Farm, discovered that low-cost hazelnuts from Turkey and elsewhere, claiming to be organic, were skating through regulations required of U.S. growers. He had noticed that the prices of the imported nuts were far closer to the prices of conventional nuts than market rates for organic nuts. Mr. Kaser first filed a complaint with USDA against certain foreign certifiers (Bio Inspecta AG, Ecocert SAS, Bioagricert, Letis, and CCPB SRL) and then filed a lawsuit. The complaint charges that the imports were ushered in under the USDA’s “group certification” provision, which is designed to help small landholders in cooperatives and indigenous communities reach wider markets. The groups are supposed to be small entities geographically near each other. The plaintiff submitted an exhibit alleging that the Turkish growers listed in certificates were actually a nut shelling company and that there was no evidence the farms that were the source of the hazelnuts were inspected according to USDA rules. Nor were they located in the same region. The suit is being opposed by a group of U.S. companies who filed an amicus brief, alarmed that a win for the plaintiff would endanger legitimate certified groups. The case is pending. (For more, see Organic Insider and the criticism that SOE does not address the grower group problem.)

A second crucial event this year, the USDA’s NOSB meeting in Portland, Oregon will occur on October 22-24. Again, public comments are due by September 30, 2024, at 11:59 pm EDT.

The Board will consider a number of important issues, analyzed here by Beyond Pesticides. For example:

• Inert ingredients – Beyond Pesticides’ position is that so-called “inert” ingredients must be evaluated according to their risks to human health and the environment, their necessity in organic production, and their consistency with other organic practices.
• Compost – Beyond Pesticides objects to the proposal that feedstocks for organic compost could include synthetics like “compostable” tableware.
• Meloxicam – an NOSB subcommittee proposes to allow the non-steroidal anti-inflammatory drug to be used in livestock, which Beyond Pesticides opposes in the absence of an independent review of the drug’s health and environmental effects.
• Nonorganic ingredients – an NOSB subcommittee proposes to remove a nonorganic ingredient (dried orange pulp), which is available in organic form, a proposal Beyond Pesticides supports. 
• Organic seeds and starts – Given the limited availability of organic seeds and starts, Beyond Pesticides urges that the development of this becomes a priority, 
• Use of plastics in organic – Beyond Pesticides urges that efforts to remove the use of plastics in organic production and packaging become a research priority for USDA.

To round out the fall roster of important organic developments, organic practitioners are on tenterhooks awaiting resolution of the Farm Bill. Barred from passage by recalcitrant and bitter Congressional infighting, it has limped through a year-long extension whose September 30 expiration is expected to be pushed to December 20—after the election. See Beyond Pesticides’ May 24 Daily News Blog for a breakdown of the bill’s organic provisions. For a list of other pending bills, parts of which have been incorporated into the Farm Bill, see the Organic Farmers Association. These bills’ provisions include requiring the USDA to create a safety net for organic dairy farmers, improve data collection in the organic dairy sector, crack down on corporate consolidation, and even phase out concentrated animal feeding operations (CAFOs).

There remain fundamental problems with federal regulation of food quality and agricultural resiliency standards. The USDA is the frontline actor that urgently needs to protect organic at every level from attempts to blur or widen definitions and dilute the precision of regulations.

One insidious example is corporations’ efforts to sneak technologies under the organic umbrella that violate the spirit of organic. For example, Hans Eisenbeis of the Non-GMO Project told Organic Insider in January 2023 that “Biotech companies that use [genetic engineering] techniques like precision fermentation and synthetic biology are coming for organic and regenerative systems and markets.”

This trend is part of a larger problem, which is that the relationship between “regenerative” and “organic” must be clarified. See Beyond Pesticides’ August 19 Daily News Blog for an analysis of how the term “regenerative” lacks a precise definition, especially in regulatory terms. In our May 24 blog, we stress that the term “regenerative” does not have a meaningful use but is “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 term has been adopted in greenwashing campaigns by such agribusiness behemoths as General Mills, Cargill, Unilever, and Walmart.

The California Board of Food and Agriculture is attempting to define the term, but there is no indication of when it may succeed. Beyond Pesticides takes the position that any definition of “regenerative” must start with and incorporate organic standards, and build on the requirements established for organic, ranging from a certification and enforcement system to baseline practices and collection of real-time data affecting approval of allowed substances. In other words, there is no regeneration without organic.

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

Sources:

United States Summary and State Data Volume 1 Geographic Area Series
Part 51 AC-22-A-51
Issued February 2024
https://www.nass.usda.gov/Publications/AgCensus/2022/Full_Report/Volume_1,_Chapter_1_US/usv1.pdf

Fall 2024 NOSB Meeting
Beyond Pesticides
https://www.beyondpesticides.org/programs/organic-agriculture/keeping-organic-strong/fall-2024-nosb-meeting

The World of Organic Agriculture Statistics and Emerging Trends 2024
Research Institute of Organic Agriculture
https://orgprints.org/52272/1/1747-organic-world-2024_light.pdf#page=232

To Make Regenerative Meaningful, It Must Require Organic Certification as a Starting Point, according to Advocates
Beyond Pesticides
May 28, 2024

To Make Regenerative Meaningful, It Must Require Organic Certification as a Starting Point, according to Advocates

Certified Organic Principles and Practices Embraced by Farmers and Consumers; Fed Standards Eroding
Beyond Pesticides
August 19, 2024
https://beyondpesticides.org/dailynewsblog/2024/08/certified-organic-principles-and-practices-embraced-by-farmers-and-consumers-fed-standards-eroding/

What Is Regenerative Agriculture? A Review of Scholar and Practitioner Definitions Based on Processes and Outcomes
Newton et al.
Frontiers in Sustainable Food Systems 2020
https://www.frontiersin.org/journals/sustainable-food-systems/articles/10.3389/fsufs.2020.577723/full

(Beyond Pesticides, September 27, 2024) A recent article in Flatwater Free Press identifies a growing trend of companies, communities, and farms nationwide advancing organic agriculture and land management. Among the signs of this change is Belltown Farms, a Philadelphia, PA owner and operator of organic and organic-transitioning farms, that, according to Flatwater, is “the second-largest buyer of Nebraska’s increasingly expensive farmland by money spent between 2018 and 2022” with plans to expand to 50,000+ acres in various states across the country. Similarly, the continued success of the Nebraska-based, on-farm processing operation, Grain Place Foods, and its collaboration with farmers focused on small-scale organic production, represents the diversity of economic and organizational models that can exist in local, regional, national, and even international food systems.

This National Organic Month, organic advocates, consumers, and farmers continue to call on federal policymakers to expand opportunities for the proliferation of small-scale farming operations. In advancing growth of organic and integrity of the organic food label, organic advocates are seeking to ensure equity and access to land as integral to any growth. In this context, Beyond Pesticides had identified the promise of organic in fighting existential health, biodiversity, and climate crises and ongoing threats to the system’s integrity, some of which are addressed in the current public comment period (ending September 30, 2024) on issues before the National Organic Standards Board (see more). Issues of critical concern, for example, include inert ingredients used in organic production, compost regulations, meloxicam in organic livestock, making elimination of plastic in organic a research priority, eliminating nonorganic ingredients in processed organic foods as a part of NOSB’s sunset review, and advocating cooperation between all segments of organic production and regulation in ensuring that organic products are produced using organic seed and starts.

Nebraska

The leadership of Belltown Farms and Grain Place in Nebraska represents what may become the new normal in agricultural communities across the nation.

Belltown Farms is a Philadelphia-based farming company that owns over 28,000 acres of farmland separated into several thousand acres per hub with hubs based in Nebraska, New York, Illinois, Michigan, and Texas. All of these farming operations are either certified organic or in the process of going organic, dispelling the myth that organic is not economically viable and that you cannot grow commodity crops such as corn, soybeans, and grains at scale. According to its website, “Belltown regenerative farming provides an opportunity to have a positive impact on soil health, biodiversity, carbon emissions, and local communities. And, at the same time, supply high-quality ingredients to the expanding organic industry. Belltown builds partnerships with leaders in the American food and beverage industry to provide consistent organic supply chains.”

According to the U.S. Department of Agriculture (USDA) Organic Integrity Database (the one-stop location to verify organic certification for U.S.-certified producers, operators, and handlers), approximately 16,612.98 acres of the 19,000 acres in their Nebraska portfolio are certified organic based on third-party certification.

The development of organic certified farmland in a state like Nebraska, which contains just 113,000 total certified acres as of the latest USDA organic survey in 2021, is a significant move given that other bidders for this land “were already of significant size and looking to expand” their own operations, based on reporting by Flatwater Free Press. Belltown Farms was drawn to purchase farmland in Nebraska given expensive farmland prices and stricter water rights in neighboring states, says Brian Halweil, Head of Impact and Sales at the organic agribusiness.

David Vetter, founder of Grain Food Places and Grain Place Foundation, welcomes Belltown Farms and their capabilities to expand the total acreage of organic farmland given his decades of experience in the organic community. The Organic Center interviewed David Vetter and Jane Coghlan, a recently appointed board member at The Grain Place Foundation, on the significance of intergenerational action to expand organic agriculture and food systems within and outside of Nebraska.

“The Grain Place farm has been certified organic since 1978. The farm produces organic heirloom barley, soybeans, corn, popcorn and grass-finished beef in a nine-year rotation. In 1987, the family operation took the next step of establishing Grain Place Foods to process its own grains into value-added products onsite,” based on the interview from The Organic Center. “Today, Grain Place Foods employs more than two dozen people, several of whom have worked there for over 15 years. Grain Place Foods also sources organic grain to supplement what is grown on the Vetter farm because the family business has expanded so much. It purchases organic grains from over 100 organic farm families, including more than four dozen neighboring Nebraskan farms.”

Wegmans

Even household-name grocery conglomerates such as Wegmans are attempting to enter the organic space, albeit in a less systemic approach. In an interview led by Progressive Grocer, editor-in-chief Gina Acosta toured Wegmans Organic Farm in upstate New York to witness what she and the company acknowledge as an incubator for offering organic food options across all 111 stores located in Northeast and Mid-Atlantic states. The goal of this farm is not to produce for all farms across Wegmans’s supply chain, but to trial various organic crops and then partner with their nearly two dozen partner farmers (who are certified organic) to then offer organic produce across their stores.

According to Wegmans’ Organic Farm website, the Organic Farm & Orchard has grown over 100 organic crops since 2007. Wegmans Sustainability Pillars (which include “more sustainable growing”) and an interview with their organic farming team showcase growth of organic wheatgrass, pea shoots, and cat grass in a controlled environmental agriculture building (which can include aquaponics and hydroponics). While larger retail chain engagement with certified organic farmers to improve consumer access to fresh, organic produce makes a significant contribution to organic, it demonstrates how strengthening and improving the definition of “organic” is important to ensure consumer trust in the USDA organic label and the value of organic as a public good.

Importance of Organic in Soil

Organic advocates seek to maintain the values, principles, and standards that are integral to the Organic Foods Production Act (OFPA). A foundational element of the law is the building of soil health. This principle motivates organic advocates to reject hydroponics as an organic form of agriculture, even though it may have a place in nonorganic agriculture. OFPA, at 6513(b), requires that all organic crop production operations submit and follow organic plans that “shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” The same section of OFPA goes on to state, “An organic plan shall not include any production or handling practices that are inconsistent with this chapter.” See Daily News, USDA Supports Expansion of “Organic” Hydroponically-Grown Food, Threatening Real Organic, for further context on why indoor agriculture such as hydroponics or aquaculture goes against the original intent of organic for soil health.

Keeping Organic Strong

OFPA establishes a level of public involvement that surpasses other laws regarding agriculture, public health, and the environment through the creation of the National Organic Standards Board (NOSB), a 15-member stakeholder board representing environmentalists, consumers, farmers, certifiers, retailers, and scientists with governing authority. With this structure, the board receives public input on standards and allowed substances twice a year, as part of a commitment to continuous improvement. The law established a sunset process for any allowed synthetic so that the board could continually evaluate the science and encourage the development of natural alternatives. See Daily News here for further context on ensuring organic integrity and the legacy of attacks on true organic principles of environmental justice, soil health, public health, and climate action.

There have also been proposed rules to improve the viability of a continuously growing industry, including the proposal of new regulations to clarify allowable materials, practices, and subsequent regulations for organic mushrooms and pet food products. See the Daily News here for more information.

This National Organic Month, organic advocates, farmers, and the broader community are interested in maintaining and expanding organic integrity and using the authority Congress gave to the NOSB to establish the National List and guide USDA organic programs.

See Keeping Organic Strong to learn how to engage in this public input process. See the latest Action of the Week, Last Chance This Fall to Tell the NOSB to Uphold Integrity, to submit your comments to the NOSB before the deadline on September 30 at 11:59 PM EDT.

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

Sources: Flatwater Free Press, The Organic Center, Progressive Grocer

(Beyond Pesticides, September 26, 2024) DNA damage is significantly higher in Latinx children from rural, farmworker families than children in urban, non-farmworker families, according to a recent study published by French and American authors in the journal Exposure and Health. Not only do farmworker children test positive for organophosphate pesticides more frequently than non-farmworker children, but the study finds that farmworker children also experience an increased frequency of DNA damage associated with the presence of organophosphate exposure. These results highlight the disparities in exposures and outcomes for children from vulnerable immigrant communities. Advocates note that as long as pesticides remain in use, farmworkers and their families will continue to shoulder a disproportionate share of the toxic effects of these chemicals (see here, here, and here); another in a long line of reasons to shift away from toxic synthetic pesticide use to the adoption of proven organic, regenerative agricultural practices. (See here, here, and here).

Methodology

The study assesses pesticide exposure and DNA damage in 45 Latinx children ages 10 to 12 from rural, farmworker families (30) and urban, non-farmworker families (15). Participants were selected from a larger study, Preventing Agricultural Chemical Exposure (PACE5)—a community-based research project by the North Carolina Farmworkers Project and Wake Forest University School of Medicine that examines the health and cognitive effects of pesticide exposure in children. DNA damage is detected by treating five to 10 hairs plucked from the scalp to enable visual inspection using a high-powered microscope. Double-strand breaks (DSB) in DNA are visually identified by the presence of foci of 53BP1, a DSB repair factor that forms at breakage points. DSB values are determined using the average number of 53BP1 foci per nucleus.

To determine pesticide exposure, participants wear silicon wristbands for seven consecutive days. The bands are then analyzed for the presence of 72 pesticides and their degradation products using gas chromatography. Any pesticide in a concentration above the level of detection is considered a positive sign of pesticide exposure. Through blood samples collected via a finger prick, the researchers also tracked cholinesterase activity in the study participants. Cholinesterase, including acetylcholinesterase (AChE) and butyrylcholinesterase (BChE), are enzymes important for the proper function of the central and peripheral nervous system. Additional information analyzed for each participant includes estimated UV exposure, weight, height, age, and gender.

The authors note that monitoring exposures and their biological impacts is essential for addressing intersectional and disproportionate health risks. They posit that functional biomarkers, such as DNA damage, offer a faster means to predict the health effects from environmental exposures, as DNA damage is associated with cancer and other chronic diseases.

DNA Damage Results

Children from farmworker families have significantly more DSB foci than children from urban, non-farmworker families, according to the findings. In addition, DNA damage is higher from April to June and lower from October to November, corresponding with relative levels of pesticide use. Similarly, AChE levels from April to June are lower, suggesting seasonal variations in DSB levels correspond inversely with seasonal variations in AChE levels. Moreover, there is a significant correlation between DSB and AChE depression levels year-round. Because there is no significant difference in the amount of sun participants received, the authors conclude that sun exposure does not explain the significant difference in DNA damage between the two groups. Similarly, differences in DSB between genders and body mass indices (BMIs) are noted to be “insignificant factors” in explaining the amount of DNA foci discovered.

Types of Pesticide Exposure

The study finds that 43 of 45 participants test positive for pesticide exposure; however, the types of pesticides present vary between the children of farmworker and non-farmworker families. Non-farmworker children are more likely to test positive for organochlorine pesticides, while farmworker children are more likely to test positive for organophosphate pesticides. Authors report a difference of 63% versus 27% for organophosphate detection in farmworker and non-farmworker children, respectively. According to the authors, these results are akin to the results of the larger PACE5 study cohort.

The most detected organophosphate is the insecticide chlorpyrifos—observed in 21 participants, but another organophosphate, ethion, is also detected in two non-farmworker children, and a third organophosphate dimethoate is found in one farmworker child. Because of this frequency, the researchers also conducted an in vitro study of the effects of chlorpyrifos on epithelial (surface lining) cells.  They find that cells exposed to chlorpyrifos have significantly more DNA breaks than they would otherwise. Alarmingly the authors note, that these results were found after exposure to only one-tenth of the highest concentrations previously detected in mothers and newborn children in another longitudinal study, known as the CHAMACOS cohort (Center for the Health Assessment of Mothers and Children of Salinas Study, by University of California Berkeley’s Center for Environmental Research and Children’s Health in the School of Public Health). Thus, even extremely small doses of chlorpyrifos, the most commonly found pesticide in this study, are associated with damage to follicular DNA and are consistent with other findings cited by the authors. (See here, here, and here). 

Of particular concern, the study reports that participants who test positive for organophosphate pesticides have 30% more DSBs than those with no organophosphate detected. These results suggest that organophosphate is related to DNA breakage and that children of farmworkers are significantly more likely to suffer long-term and multigenerational effects of pesticide use from DNA damage than children of non-farmworkers.

Farmworkers Inadequately Protected by United States Pesticide Regulation

This study follows a series of reports on the state of farmworker protection that highlight the long history of health threats, regulatory failures, and structural racism that is integral to the chemical-intensive agricultural system (see here, here, and here). As Beyond Pesticides has reported, pesticide risks to agricultural workers (and pesticide applicators) are significant. The U.S. agricultural sector uses roughly 90% of the one billion pounds of various pesticides deployed annually in the nation and agricultural workers are regularly exposed, at atypically high rates, to chemicals that can pose considerable safety and health risks to humans. These risks to farmworkers and pesticide applicators are made worse, according to the report “Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety,” by inadequate training in handling pesticides, subsequent improper handling and application “in the farm field” or on other kinds of sites, and by bureaucratic, regulatory, and policy roadblock.

Farmworkers are uniquely not covered for chemical exposure by the Occupational Safety and Health Act and the U.S. Occupational Safety and Health Administration. The federal Agricultural Worker Protection Standard (WPS) is the primary regulation, under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), for the protection of farmworkers and pesticide handlers from “pesticide poisonings and injuries.” Although the WPS is a federal regulation, it is largely administered by states through “cooperative agreements”—negotiated by the U.S. Environmental Agency (EPA) regional offices—that allow state authorities to enact federal pesticide protections.

Meanwhile, EPA’s failure to consider cradle-to-grave effects and disproportionate impacts on farmworkers, especially farmworkers of color and their families, when it registers a pesticide continues to this day (see here, here, and here). There is a steep road to climb in reversing and correcting the failures that are inherent in EPA’s risk calculations (risk assessments) that ignore high-risk populations, including children of farmworkers. 

Advocates, including Beyond Pesticides, argue that the “precautionary principle” should be widely adopted across United States regulatory frameworks. This principle suggests a fundamental change in how government regulators approach the approval of activities that could lead to pollution. It encourages asking, “What is the minimum possible harm?” instead of, “What level of harm is acceptable,” based on mitigation measures that allow harm. Implementing this approach means setting a more stringent, science-backed threshold for proving a chemical’s safety. It grants regulators the authority to preemptively halt potentially harmful actions when safety is uncertain and promotes a thorough investigation into less harmful alternative practices and materials. This current study adds to the body of science documenting the adverse effects of pesticides on child health and development, specifically from pesticide exposure among farmworkers’ children.

Organic Agriculture is the solution

The National Organic Program’s (NOP) focus on promoting on-farm ecological balance by relying on mechanical, biological, and cultural practices—rather than chemical applications—can help protect farmworkers and farmworkers’ families from exposure to harmful pesticides.

Beyond Pesticides maintains that a far better use of the energy, time, and expense that goes into evaluating and regulating pesticides would be to undertake a broad and necessary transition away from toxic synthetic pesticide use towards organic regenerative agricultural systems. Organic practices avoid industrial agriculture’s reliance on these chemical pesticide inputs (and synthetic fertilizers) while proven to be successful, cost-effective, and beneficial for soil, human, and environmental health.

The pesticide problem is not unique to farmworkers, but they and their families suffer a disproportionate burden of the hazards. Although choosing certified organic products in the marketplace eliminates nearly all of the hazardous pesticides on the farm, it does not ensure adequate working conditions, wages, and labor practices. The Agricultural Justice Project, and its Food Justice Certified labeling, address this gap in the organic marketplace, and producers should be encouraged by consumers to participate in this certification process. For more information, see Beyond Pesticides’ webpage on Disproportionate Risk.

As Beyond Pesticides wrote on Labor Day, this can be accomplished through the adoption of local, state, and national policies that eliminate toxic pesticide use. This is a moment for building coalitions in communities to advance policies that ensure all aspects of a healthful life and environment, supported by our social structures. In doing this, we recognize that we must join to build the necessary power to effect meaningful and transformational change. See Tools for Change for a range of strategies, resources, and tips to initiate grassroots advocacy in your community, town, city, or state against pesticide use on lawns, public land, and agricultural lands. The organization also strives to maintain the integrity of organic standards through the Keeping Organic Strong campaign and historical work to transition agriculture to organic practices. 

During National Organic Month, please consider advocating on behalf of all workers required to use toxic pesticides in their work, including farmworkers and their families, and take action to push for an end to petrochemical pesticide use by keeping organic strong.

With landscapers handling hazardous pesticides and broad community exposure through parks, playing fields, and residential lawns, the opportunity to transition to organic land management is available through Beyond Pesticides’ program Parks for a Sustainable Future.

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

Sources:

Follicular DNA Damage and Pesticide Exposure Among Latinx Children in Rural and Urban Communities,  Exposure and Health, November 2023 https://doi.org/10.1007/s12403-023-00609-1

EPA’s Worker Protection Standard Fails to Protect Farmworkers’ Health, Report Finds, Beyond Pesticides Daily News, February 14, 2024

Farmworkers Still Inadequately Protected from Pesticides, Report Finds, Beyond Pesticides Daily News, September 16, 2022

USDA Announces Dramatic Increases in Support for Organic Agriculture Without Call for Total Transition, Beyond Pesticides Daily News, June 10, 2022

Disproportionate Pesticide Harm Is Racial Injustice, Beyond Pesticides, Pesticides and You, 2021

Essentiality Unprotected: A Focus on Farmworker Health Laws and Policies Addressing Pesticide, 

Exposure and Heat-Related Illness, Center for Agriculture and Food Systems at Vermont Law School and Johns Hopkins Center for a Livable Future, May 2021

Essential and in Crisis: A Review of the Public Health Threats Facing Farmworkers in the US, Johns Hopkins Center for a Livable Future and Center for Agriculture and Food Systems at Vermont Law School, May 2021

Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety, Center for Agriculture and Food Systems at Vermont Law and Graduate School, Harvard Law School Food Law and Policy Clinic, and Farmworker Justice, December 2023

(Beyond Pesticides, September 25, 2024) In a semiannual report released in August 2024, EPA’s Office of Inspector General (OIG) identifies a number of “unresolved” issues that strike the core of the agency’s failure to carry out its responsibilities to protect health and the environment. One of the issues identified is EPA’s failure to conduct an adequate and independent assessment of the cancer effects of the fumigant, 1,3-Dichloropropene (1,3-D or Telone). OIG’s original report, The EPA Needs to Improve the Transparency of Its Cancer-Assessment Process for Pesticides, was issued in 2022 and concluded that EPA’s Office of Pesticide Programs (OPP) engages in secret meetings with industry, elevates unqualified individuals to decision-making roles, uses an untested scientific approach, fails to conduct a simple literature review, and neglects public transparency. Other pesticide issues that OIG identified in its report include:

• The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health
• The EPA Has Not Verified that Its Laboratories Comply with Hazardous Waste Requirements
• EPA Needs an Agencywide Strategic Action Plan to Address Harmful Algal Blooms
• EPA’s Endocrine Disruptor Screening Program Has Made Limited Progress in Assessing Pesticides
• EPA Needs to Evaluate the Impact of the Revised Agricultural Worker Protection Standard on Pesticide Exposure Incidents

[See report Table A-4, p13: Open and unresolved recommendations associated with human health and environmental Issues deficiencies and a lack of transparency in the 1,3-Dichloropropene pesticide cancer assessment process has undermined scientific credibility and public confidence. 22-E-0053 The EPA Needs to Improve the Transparency of Its Cancer-Assessment Process for Pesticides Office of Chemical Safety and Pollution Prevention.]

In light of serious deficiencies in cancer assessment, Inside Climate News in a recent issue took a look back at the ongoing situation that puts public and worker health at serious cancer risk. Despite decades of scientific evidence linking 1,3-D exposure to heightened risk of blood cancers, including histiocytic lymphoma and leukemia, and EPA’s own assessment in 1985 that the chemical is “likely to be carcinogenic to humans,” OPP’s Cancer Assessment Review Committee (CARC) reversed the agency’s position in 2019, finding that 1,3-D “isn’t likely to cause cancer after all,” according to EPA’s Office of Pesticide Programs. After assessing a “third-party peer review” conducted by a firm known for bending to industry claims of limited harm, EPA overturned its previous position, which Inside Climate News investigates. According to Inside Climate News, EPA relied on the findings of an industry supported group, SciPinion.

Investigation Summary

Investigative reporters at Inside Climate News identified SciPinion, a science-analysis firm, as an enabling scientific uncertainity. Despite describing itself as “introduc[ing] clarity and certainty from the expert community to the world’s toughest science problems, instilling universal trust in science,” SciPinion pushes forward scientific reports on chemical products overwhelmingly funded by the same companies producing the same products. Organic advocates, farmers, and land managers point to this co-optation of EPA as key reason for eliminating petrochemical pesticides and fertilizers and transitioning to organic.

“Inside Climate News reviewed 159 scientific articles published by one or both of the principal SciPinion scientists, Sean Hays, PhD and Christopher Kirman. Papers often re-evaluated evidence of health risks or advocated using alternative methods to ‘refine’ risk estimates for dozens of toxic substances, most worth billions of dollars in sales a year, including toxic metals (like chromium, used to make stainless steel), solvents (like benzene), pesticides, flame retardants and PFAS, also known as ‘forever chemicals.’ Of the 130 papers with a funder listed, 82 percent were sponsored by corporate interests, either the producer of the substance under study or the producer’s trade group, including the American Chemistry Council, the Chlorine Chemistry Council and the American Petroleum Institute.”

The article underscores the divergence in expert opinion from SciPinion scientists, especially when considering that the National Toxicology Program and International Agency for Research on Cancer (IARC) determined the carcinogenic potential of 1,3-D. “Papers published by SciPinion scientists, who also provide expert witness testimony and “product stewardship” services through the consulting firm Summit Toxicology, rarely conclude that toxic chemicals, including known carcinogens, need stricter regulations. Instead, they often argue for safety thresholds that allow higher levels of exposure, repeating an argument made by fossil fuel and petrochemical companies since U.S. regulatory agencies were established in the 1970s.”

Health Impacts of Telone

Telone is a broad spectrum and cancer-causing soil fumigant used to control various soil-borne diseases, nematodes, and/or garden symphylans on a range of agricultural and non-agricultural crops. Various studies have identified this pesticide to increase risk of numerous adverse public health and environmental impacts, including cancer, kidney and liver damage, leaching potential into ground and surface water, and posing toxic harms to birds, fish, and other aquatic organisms. See further peer-reviewed literature and information on 1,3-D in the Gateway on Pesticide Hazards and Safe Pest Management.

In 2022, the California Department of Pesticide Regulation (CDPR) proposed to remove existing limits on the use of 1,3-D in order to allow Californians to breathe in more of the chemical than state toxicologists deemed safe. (See here for Beyond Pesticides comments to Director Julie Henderson and relevant CDPR staff for more details.)

Advocates across the nation, and within California, submitted comments—as did Beyond Pesticides—calling on EPA, Congress, and California Department of Pesticide Regulation to cancel the registration of all toxic soil fumigants and push forward organic compliant alternatives. (See previous Actions of the Week here and here for more information). Despite, this EPA and CDPR pushed forward their final proposals loosening restrictions on 1,3-D use, as reflected in the general requirements for its handling in the updated regulation found here and here.

Industry Interference

The article raises longstanding concern about EPA’s failure to adequately protect the public in the broader context of petrochemical pesticide and fertilizer industries success at infiltrating regulatory and academic entities both within and outside of the U.S.

A series of internal Monsanto documents were brought into the public sphere in 2017 discovery stage of various lawsuits against the pesticide manufacturer, leading to intrepid reporting by Carey Gillam (former Reuters and Huffington Post reporter, as well as executive director of U.S. Right to Know). Coined “The Monsanto Papers,” hundreds of internal emails, documents and correspondence with the federal government (particularly EPA) revealed “questionable research practices by the company, inappropriate ties to a top EPA official, and possible ‘ghostwriting’ of purportedly ‘independent’ research studies” that it publicly attributed to academics. Gillam incorporated these leaked documents and other findings from her reporting in the book Whitewash, and she discussed her research at the 38^th National Pesticide Forum (See here). For previous Daily News coverage of The Monsanto Papers, see here and here.

Advocates, after years of petitions and outreach, successfully pushed for the United Nations Food and Agriculture Organization (FAO) to sunset its “strategic partnership” with petrochemical pesticide and fertilizer trade association CropLife International to address the systemic issue of corporate interference in global pesticide policy. This interference is not novel, as investigated by various outlets. “Merchants of Poison,” a first-of-its-kind investigative piece by U.S. Right to Know and Friends of the Earth, highlights Bayer/Monsanto’s “defense strategy” used to deny peer-reviewed, independent science, sow doubt among the public, and discredit voices of dissent that inconveniences their narratives. (See Beyond Pesticides analysis of this report here). Industry interference has also led to rollbacks of what would previously be sweeping biodiversity protections, including the retraction of the Vulnerable Species Pilot Project underneath the Herbicide Strategy Framework.

Unfortunately, there are continuing concerns in academic settings as well. For example, U.S. Right to Know reported on industry infiltration into the Entomological Society of America (ESA) in its 2023 annual meeting. ESA reportedly changed its approach to meeting sponsorships from the standard method employed by thousands of organizations, in which corporations and other organizations seeking to impress or recruit attendees organize “hospitality suites” and receptions. Instead, ESA adopted a “sponsorship program” that permitted industry-backed scientists more chances to present during scientific sessions, publish in ESA journals, and serve as officers in the organization. See the full Daily News here and the full report from U.S. Right to Know here.

See Daily News sections on Office of Inspector General and industry interference for more information and coverage.

Call to Action

The perfect disinfectant to corruption is shining a light on how it pervades institutions originally established in service of defending and enhancing the public interest. This Organic Month, advocates have the opportunity to engage in submitting input to the National Organic Standards Board on how to strengthen federal organic policy and programs. See Keeping Organic Strong to learn more about how to engage in this process ahead of the September 30 deadline.

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

Source: Inside Climate News

(Beyond Pesticides, September 24, 2024) Recent commentary in Frontiers in Toxicology by two researchers, Maricel Maffini, PhD and Laura Vandenberg, PhD, highlights the pitfalls in the current regulatory systems in the United States (U.S.) for chemicals that threaten human health. Despite many advancements in science over the past few decades, and the wealth of studies that tie chemical exposure to negative health effects, risk assessments, and subsequent risk management, remain “static” and “outdated,” according to the authors.

“There is increasing concern amongst public health professionals, environmental health scientists, and medical organizations about exposures to synthetic chemicals,” the researchers say. “These organizations’ concerns are based on the overwhelming evidence showing associations between chemical exposures and adverse health outcomes in human populations.” Such concerns have sparked a debate on current regulatory methods for chemicals that are present in highly used products, such as pesticides, plastic containers, and food.   

The authors continue, “There are now thousands of studies showing associations between these chemicals and adverse health effects in humans including neurological disorders and learning disabilities, metabolic outcomes, infertility, thyroid dysfunction, and cancers.” Additional health effects can be seen in the Pesticide-Induced Diseases Database.

Of the many harmful chemicals, per- and polyfluoroalkyl substances (PFAS), and more specifically perfluorooctanoic acid (PFOA), have become increasingly scrutinized. Present in widely used products, these chemicals have high exposure, and “studies have revealed associations between PFOA exposures and human health effects including cardiometabolic issues, thyroid disorders, kidney and testicular cancer, and ulcerative colitis,” the authors point out. See more on PFAS here. With PFAS contamination in the spotlight, advocates are asking for protections from these compounds.

According to the researchers, some of the strongest evidence for the dangers that come with exposure to toxic chemicals is from persistent organic pollutants, such as PFAS, that bioaccumulate in animals, humans, and the environment and become biomagnified throughout the food chain. Bioaccumulation and biomagnification threaten entire ecosystems and biodiversity through cascading impacts.

The growing body of scientific evidence linking “chemical exposures to chronic diseases has led experts to deem the testing approaches recommended by regulatory agencies for risk assessment insufficient to protect human health,” the authors write. Current assessments do not utilize appropriate assays to assess endpoints such as developmental neurotoxicity, immunotoxicity, endocrine disruption, and non-genotoxic carcinogenicity, which leaves these serious impacts on human health unknown. The authors call for more sensitive and health-relevant endpoints to mitigate exposure to hazardous chemicals before they even enter the marketplace.

“Although the exact number of chemicals remains unknown, scientists estimate there are 140,000–300,000 chemicals on the global market,” the researchers report. The U.S. Environmental Protection Agency (EPA) alone has more than 42,000 chemicals listed on the Toxic Substances Control Act (TSCA) inventory that are available for use in consumer products or utilized in industrial processes. While pesticide product labels are required to list their active ingredients, there are many others (known as inert or other ingredients) that are not listed or tested in the same manner. This adds to the gaps in data for adverse effects of individual compounds as well as synergistic effects between compounds. 

“Current approaches also rely on the assumption that testing chemicals one at a time is appropriate to understand how chemicals act under real-world conditions. Numerous mixture studies, including ones that demonstrated cumulative effects, have disproven this assumption,” the authors note. The synergy between substances within a single product or between multiple products used in tangent represents an area that can have exponentially worse impacts than the individual components alone, but synergistic effects are not considered during product registration. For example, a study “combining chemicals at concentrations that were 80-fold lower than their individual lowest-observed-adverse-effect-levels can act together to induce malformations of the male reproductive tract,” the researchers share. Additional studies on synergistic effects can be found here.

Proper pre-market testing needs to occur to protect the health of humans and the environment, but, as the authors state, “often the hazards of these chemicals are revealed years after they enter commerce, and in the U.S., there are very few options to restrict the use of chemicals once they have been allowed in products.” While suspensions and bans are within EPA’s power, they are not utilized often enough, safety advocates say. The “dacthal standard,” as Beyond Pesticides calls it, should be regularly implemented for handling the many chemicals that have been shown, through peer-reviewed scientific studies, to cause unnecessary risk to humans and other vital organisms.

Many of the current standard assays for risk assessment focus on acute toxicity in organisms such as fish, frogs, mice, or rats. These studies do not inform chronic effects that are increasing in human populations. There is also a need for more early-life exposure tests to “focus on health-related outcomes rather than overt signs of toxicity,” the researchers say. Previous early-life exposures from epidemiology studies include dichlorodiphenyltrichloroethane (DDT) being linked to later-life breast cancer risk, perchlorate and diminished IQ levels in children, and bisphenol A (BPA) and increased risk of asthma in children. See studies here, here, and here.

Risk assessments relying on outdated principles and expectations put human health at risk. “[C]ommon testing approaches assume that chemicals are quickly eliminated from the body, something that many PFAS and other persistent organic pollutants have disproven, even considering species-specific differences in their half-lives. In fact, this assumption continues to create problems in the testing (and risk management) of shorter-chain PFAS, which were assumed to be less bioaccumulative, and thus less hazardous, than the long-chain PFAS,” the authors relay. They continue, “Unfortunately, this was revealed to be untrue. Another long-held assumption is that chemical metabolites are less hazardous than the parent compounds. Phthalates, which have several metabolites that are more biologically active than the parent compounds, have disproven this assumption as well.” More extensive testing for all chemicals and their degradation products would create clarity for health effects and environmental fate.

The researchers highlight many areas that are currently lacking in the regulation of chemicals that humans are exposed to every day. Pesticide exposure can occur through inhalation, skin absorption, or ingestion from contaminated air, water, soil, or food. Even within the home, it is estimated that 75% of U.S. households used at least one pesticide product indoors in the past year. Other groups are at an increased disproportionate risk, such as people who live near agricultural fields and farmworkers/their children. According to previous EPA estimates, 13,000 to 15,000 farmworkers become ill from pesticide exposure each year, but that number could be as high as 300,000 if undiagnosed workers are included.

“Risk assessment involves the combination of hazard, exposure, and dose response data to quantify the probability of an adverse effect at a specific level of exposure. After a risk assessment is performed, the next step is to decide whether the risk to health is substantial enough that it must be managed,” the authors state. “Risk management is defined as ‘the process of weighing policy alternatives and selecting the most appropriate regulatory action, integrating the results of risk assessment with engineering data and with social, economic, and political concerns to reach a decision.’”

With these established processes, advocates are enraged at the lack of emphasis on health and how slow federal and state agencies are to act in the face of protecting the public from these risks. “For example, repeated lawsuits against manufacturers of herbicides containing glyphosate have been successful because of strong evidence these products increase the risk of Non-Hodgkin Lymphoma, even though the EPA maintains that glyphosate does not cause cancer,” the researchers share. Despite these lawsuits and a wealth of scientific evidence, many products on the market still contain glyphosate.

As the authors say, “To address these problems collectively, we need reliable assays that can be used for risk assessment and regulatory purposes… [T]here needs to be evidence-based periodic post-market reevaluations and updated risk management decisions to remove the bad actors without introducing regrettable replacements.” This highlights the current pesticide treadmill in which any bans or restrictions result in the use of other harmful chemicals, that are often more toxic, as alternatives.

The researchers propose that risk assessments and regulations should rely on “modern scientific principles of toxicology including mixture toxicology, endocrinology, physiology, and immunology. Testing needs to be nimbler to account for the growth in knowledge of these fields over the last three decades and the new knowledge that is yet to come as well as the complexity of chemical exposures and new chemistries.” As science and our knowledge base evolve, so should the systems for assessments that are meant to inform decisions that have a wide impact on human and ecosystem health.

“[R]isk assessment informs risk management which may also consider the economic cost to the regulated industry, availability of safer substitutes, societal values, political will, and the precautionary principle. In an ideal world, risk assessment and risk management should be performed by different groups of experts to ensure that the risk assessment is solely based on scientific evidence and is not influenced by the ‘costs’ of taking action,” the authors postulate. This type of approach is in place in Europe regarding food and food packaging where the European Food Safety Authority and European Commission both play a role. The European Union (EU), however, still fails to accurately or reliably predict pesticide exposure rates, sometimes by several orders of magnitude, during the risk assessment process required for registration, as shown in a recent study covered by Beyond Pesticides.

“The problems we describe here illustrate a common paradox in U.S. regulatory agencies: they are mandated to make safety decisions based on science that is constantly evolving while the risk management is commonly static,” the authors conclude. “Better testing, and better use of testing data, can protect the public’s health.” Improvements in the risk assessments for chemicals within commonly used products will inform not only agencies like EPA but also consumers about the potential impacts that exposure to these compounds can have.

With more extensive testing, decisions regarding approving or reregistering products can be better informed and would result in less harmful products on the market. Any reforms to the current practices within EPA would face stiff resistance from the chemical industry and those aligned with their positions in Congress. The strategies currently in place in the U.S. and around the world leave all organisms, including humans, vulnerable to adverse health effects from chemical exposure and creates a pressing need for the public to call for change. By taking action, your voice can be heard on governmental actions that are harmful to health and the environment. You can also call for EPA action and promote safer options through strong organic values.

Organic alternatives to toxic chemicals found in pesticides would mitigate these harmful effects without the drawn-out process of reform. By promoting organic systems, the reliance on petrochemical pesticides and synthetic fertilizers is removed. This eliminates exposure to many products that can damage DNA, cause cancer, and even increase infant mortality.

Organic land management, whether in agriculture or on lawns/gardens, focuses on soil health and the health of all organisms within the ecosystem. By starting at the foundation, organic methods create a sustainable system in which all organisms that rely on each other are supported and biodiversity can flourish. This creates a healthy system with healthier food production without endangering the environment or any organisms within it.

Be part of the organic solution by becoming a member of Beyond Pesticides today. You can also participate as a Parks Advocate to transition your community towards organic land management, grow your own organic food, or support local organic farmers. Stay up to date on the latest science and policy with the Daily News and sign up for Action of the Week and Weekly News Updates to be delivered straight to your inbox to remain informed.

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

Source:

Maffini, M. and Vandenberg, L. (2024) Science evolves but outdated testing and static risk management in the US delay protection to human health, Frontiers. Available at: https://www.frontiersin.org/journals/toxicology/articles/10.3389/ftox.2024.1444024/full.

Image: Shelf labeling at Blue Hill Coop, Blue Hill, Maine. Note three levels of information: Local Maine Organic, Organic, and Local Maine, as well as country of origin. Photo by Jay Feldman, heading to the Maine Organic Farmers and Gardeners Assn (MOFGA) Common Ground County Fair.

(Beyond Pesticides, September 23, 2024) Public Comments on organic standards are due by 11:59 PM EDT on September 30, 2024. Beyond Pesticides is calling for the public to submit comments to the National Organic Standards Board during its Fall review of standards and allowed substances—a second action in a two-part request for the public to weigh in on key issues that go to the heart of the integrity of practices allowed under the USDA organic food label. The issues addressed in this call for action include the following: end plastic in organic production and processed food as a research priority; eliminate nonorganic ingredients in processed organic food; and, require organic products to be produced using only organic seeds and starts. The first action during the current comment can be found here and includes the following issues: full review of “Inert” ingredients used in organic production; strengthened compost regulations; and, rejection of proposal for new animal drug in livestock production without required specific use information.

The National Organic Standards Board (NOSB) is receiving written comments from the public on key issues, which must be submitted by 11:59 PM EDT on September 30, 2024. Written comments can be submitted via the linked form. 

This precedes the upcoming public comment webinar on October 15 and 17 and the deliberative hearing from October 22-24—concerning how organic food is produced and processed. Currently, the oral comment registration is full—to be considered for a potential waitlist (and let the U.S. Department of Agriculture know how important organic is), please contact NOSB Advisory Committee Specialist Michelle Arsenault at [email protected]. Links to the virtual comment webinars will be provided on this webpage in early October, about one week before the meeting.  

As a means of taking on the challenges of health threats, biodiversity collapse, and the climate emergency, the review and updating of organic standards requires public involvement in the current public comment period. This is required to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But organic remains strong and grows stronger only if the public participates in voicing positions on key issues to the stakeholder advisory board, the National Organic Standards Board (NOSB). Beyond Pesticides has identified key issues for the meeting below. 

>> Click here to submit your comments to the NOSB by 11:59 PM EDT on September 30, 2024.

The NOSB is responsible for guiding USDA in its administration of the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as society depends on organic production to protect the environment, mitigate climate change, and enhance health.

The NOSB plays an important role in bringing the views of organic consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Fall. ➡️ For a complete discussion, please see the Keeping Organic Strong page and review the UPDATED Fall 2024 issues! 

Some of Beyond Pesticides’ high-priority issues for the upcoming NOSB meeting (see others here):

—Make the elimination of plastic in organic a research priority. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well-documented. Research is needed into ways to replace all forms of plastic in organic production and handling. 

Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.  

Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products. 

The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale, 90% of which are not identifiable, but the number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. When they exposed cod eggs, embryos and larvae to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans. 

Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta. 

—Eliminate nonorganic ingredients in processed organic foods as a part of NOSB’s sunset review. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and virtually anything can be grown organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” Materials on §205.606 up for sunset review this year made from agricultural products that can be supplied organically should be taken off the National List of allowed materials. 

The majority of the Handling Subcommittee voted to remove dried orange pulp from §205.606 because organic dried orange pulp is now available. This should be supported. 

Cultured celery powder is a way of adding “natural” nitrites. The quotation marks are appropriate since it is not possible to achieve the high levels of nitrate desired through organic celery production. Rather, the celery must be grown in chemical-intensive production where it takes up nitrates from synthetic fertilizers. Given the known health effects of nitrates, Beyond Pesticides says there is a good reason for keeping celery powder on the National List. The Agency for Toxic Disease Registry (ATSDR)/Centers for Disease Control and Prevention (CDC) lists, for example, methemoglobinemia, hypotension, risk of pregnancy complications, a number of reproductive effects, and cancer, among others.  

In addition, there are 62 pesticides with allowed residues (tolerances) for celery, 27 are acutely toxic and create a hazardous environment for farmworkers, 57 are linked to chronic health problems (such as cancer), 15 contaminate streams or groundwater, and 56 are poisonous to wildlife. Celery powder should be removed from the National List. 

—All segments of organic production and regulation should ensure that organic products are produced using organic seed and starts. Processors should not require organic growers to produce varieties if the seeds or starts for those varieties are not available organically. Processors who sell products with the organic seal benefit from certification and should share the responsibility for continuous improvement.  

Organic cotton growers find it very difficult to source organic seed due to the small size of the industry. Most growers must use conventional, untreated, non-GMO seed. Given current seed regulations, the delinting process used on conventional seeds (sulfuric acid) is allowed since the seeds themselves are untreated and non-GMO. Also, due to the consolidation of seed companies, organic growers have an increasingly hard time finding their desired varieties that have been available in the past. The push for genetically modified cotton varieties has also made seed sourcing for organic growers even more difficult. The NOSB and NOP should make the availability of organic seed a priority. 

>> Click here to submit your comments to the NOSB by 11:59 PM EDT on September 30, 2024.

Beyond Pesticides urges you to submit comments to the docket on the above issues and to add a sentence or two at the beginning of the comments explaining why organic is important to you! For those who prefer to copy and paste comments directly to Regulations.gov, please see Beyond Pesticides’ comments included on our Fall issues page.

(Beyond Pesticides, September 20, 2024) As the California State Assembly wrapped up the 2024 legislative session, what was once a proposed ban of the deadly weed killer paraquat (in both agricultural and nonagricultural contexts) was amended and passed as a requirement for California Department of Pesticide Regulation to complete an “expedited review” by January 1, 2029. Paraquat exposure has been linked to Parkinson’s disease. According to reporting by Los Angeles Times, Assemblymember Laura Friedman (D-Burbank) (the original sponsor of the bill) spoke candidly about the prospects for this legislation, “We never thought we’d get a full ban through the Legislature. But we had to push as hard as we could.” Assemblymember Friedman is chair of the bicameral Environmental Caucus and a self-described “steadfast advocate for the environment [and] sustainable communities.”

Environmental advocates, public health professionals, and many who have been affected by Parkinson’s disease are calling for the emergency suspension of paraquat, applying the same standard used by the U.S. Environmental Protection Agency (EPA) to ban the herbicide Dacthal/DCPA last month. (See Daily News here.)

Context

The original legislation responds to significant scientific documentation of the pesticide’s hazards, and an unresponsive regulatory process, as well as previous legislation efforts. In 2018, U.S. Representative Nydia Velasquez (D-NY) introduced legislation (Protect Against Paraquat Act) to ban paraquat.

In response to a lawsuit filed by Earthjustice on behalf of farmworkers, EPA, by January 2025, is expected to submit a final report following up on its 2024 report, “Preliminary Supplemental Consideration of Certain Issues in Support of its Interim Registration Review Decision for Paraquat,” which has been criticized by the litigants as severely inadequate. EPA is reviewing the registration of paraquat-based pesticide products after an Earthjustice lawsuit prompted the agency to reconsider the toxic herbicide’s connection to Parkinson’s.

See Daily News, California Bill Would Ban Deadly Weedkiller, Paraquat, Linked to Parkinson’s Disease in Face of EPA Inaction, for further information.

Science Behind Paraquat

There is no shortage of peer-reviewed, scientific literature identifying the adverse health effects of Paraquat exposure. According to research supported by Parkinson’s Foundation, there was “a steep 50% increase” in diagnoses in the United States from 2012 to 2022. In a 2020 study published in the International Journal of Environmental Research and Public Health, researchers identify the heightened risk of Parkinson’s disease to paraquat exposure down to the zip code based on data gathered by the U.S. Geological Survey and Louisiana State University. In a 2023 study published in Ecotoxicology, researchers confirmed that paraquat is one of the most highly toxic herbicides with respect to acute toxicity, which corroborates EPA’s acknowledgment that “[o]ne small sip [of paraquat] can be fatal, and there is no antidote.” Cumulative exposure to paraquat increases the risk of developing Parkinson’s, according to a meta-analysis and systemic review published in 2019 in Journal of Toxicology and Environmental Health.

See the Pesticide-Induced Disease Database for easy access to a directory of the latest peer-reviewed research regarding Parkinson’s and other severe health conditions associated with paraquat exposure. See the Gateway on Pesticide Hazards and Safe Pest Management for more information on the adverse public health and environmental impacts of the herbicide. For more news updates on paraquat, see its dedicated Daily News section.

Applying The Dacthal Standard & End Paraquat Registration

In a groundbreaking decision, EPA used its statutory authority outlined in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)’s “imminent hazard” clause to cancel the registration of the toxic herbicide Dacthal/DCPA on August 7. This decision came after decades of documented adverse health impacts to children and pregnant mothers exposed to Dacthal, including fetal hormone disruption leading to “life-long impacts” such as impaired brain development and motor skills.

This was the second time in EPA history that the agency took this emergency action, the first time being in 1979 with the suspension of the herbicide 2,4,5-T (one-half of the notorious chemical herbicide Agent Orange). In evaluating its decision to suspend Dacthal, EPA considered the five following points:

• The seriousness of the threatened harm;
• The immediacy of the threatened harm;
• The probability that the threatened harm will occur;
• The benefits to the public of the continued use of the pesticide; and
• The Nature and extent of the information before the Agency at the time it makes a decision.

EPA also decided to prohibit the continued use of existing stocks of dacthal-based herbicide products, which departs from the agency’s decision earlier this year to permit the use of existing stocks for three dicamba-based herbicides following a federal court decision in February declaring EPA violated federal pesticide law. Rather than relying on private settlements and existing stocks orders, EPA’s decision on Dacthal opens the door for fenceline communities and the public to demand robust actions on a variety of toxic pesticides, including atrazine and paraquat.

Call to Action in Alignment with National Organic Month

On the Parkinson’s National Day of Action (September 17), the Michael J. Fox Foundation called on the public to contact their members of Congress and ask them to reach out to the White House and EPA to cancel the registration of paraquat ahead of the agency’s deadline to make a decision on the herbicide by January 2025.

Learn more about the national grassroots movement to ban paraquat (Beyond Pesticides is a member of this coalition alongside dozens of public health, farmworker, environmental justice, and climate action-oriented organizations) here.

Additionally, contact EPA here to suspend the registration of atrazine by applying the Dacthal Standard. This month is also National Organic Month, with September 30 serving as the deadline for the public to submit comments for the Fall 2024 National Organic Standards Board meeting. See Keeping Organic Strong for an updated list of Beyond Pesticides’ comments, as well as resources and guides for submitting comments.

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

Sources: Los Angeles Times

(Beyond Pesticides, September 19, 2024) An article published in the journal Science of the Total Environment finds that the European Union’s (EU) risk assessment process, required for registration, fails to accurately or reliably predict pesticide exposure rates, sometimes by several orders of magnitude. Pesticide registration in the EU leverages the Agricultural Operator Exposure Model (AOEM)—a predictive model developed in 2014 to estimate expected non-dietary pesticide exposure levels for operators [pest control operators in the U.S.] based on a very limited set of data generated by the pesticide industry. Models that predict real-world exposure and underestimate field data raise critical questions about the efficacy of risk assessment reviews that determine product labels and allowed level of harm.

By comparing the dermal exposure measured during a field study conducted in a nonagricultural area with the corresponding values estimated by AOEM, researchers in France add to the body of scientific literature indicating that the fossil fuel and petrochemical pesticide industry data cannot be relied upon as a benchmark to ensure public health and safety.

The study describes the difficulty and complexity of calculating the ability of protective equipment to provide protection. According to the authors, “[AOEM] underestimated hand exposure by 42 times and it systematically underestimated the exposure when the operators were wearing gloves, especially during the application. The model failed at being conservative regarding hand exposure and highly overestimated the protection afforded by the gloves.” The authors conclude that AOEM yielded higher estimations than field measures and state, “(h)owever, hand exposure was systematically underestimated when hands were protected by gloves, meaning that the model overestimates the protection that they afford. While AOEM is a fast and cheap predictive tool compared to laboratory exposure assessment, it is based on a limited number of studies that were carried out exclusively under controlled conditions by the pesticide companies. No studies have been conducted in the nonagricultural area, even though there are some similarities with the agricultural sector regarding the way pesticides are used.” Since the knapsack sprayer is common equipment used in agriculture and nonagricultural areas, the sample size used by AOEM is called into question—having only four studies with this type of equipment included in the model. “It therefore appears crucial to consider academic studies conducted in real work conditions and to modify the model so that it estimates operator exposure accurately,” the authors conclude.

To test AOEM, researchers examine data from a 2011 exposure study of private and public gardeners in France wielding knapsack sprayers (also known as backpack sprayers) to apply glyphosate products in nonagricultural settings. All participants are male, with a mean age of 40 and prior experience spraying glyphosate weed killers. The whole-body method was used to determine dermal exposure, as described by the Organisation for Economic Co-operation and Development (OECD) Guidance Document for the Conduct of Studies of Occupational Exposure to Pesticides During Agricultural Application. To determine actual exposure, operators wore pre-washed cotton undergarments (long pants and a long-sleeve t-shirt) and cotton gloves. The clothes were tested daily while the gloves were changed between application phases.

Theoretically, AOEM would be expected, according to the design, to conservatively estimate pesticide exposure rates. As such, the model should overestimate the amount of predicted pesticide exposure. In terms of specific numbers, AOEM estimated the median overall daily exposure to be 27.9 mg/day, which was higher than what was actually measured in the field. For body exposure, AOEM’s estimate was 20 mg/day, again higher than the field measurements. However, the most significant difference was seen in hand exposure: AOEM estimated it at only 0.11 mg/day, which was 42 times less than the field-measured exposure of 4.62 mg/day. According to AOEM, hands accounted for 26% of the total daily exposure, whereas in the field study, hands accounted for 84% of actual total daily exposure.

Ultimately, the model results do not correlate with the field results, suggesting that the model’s overall precision is lacking. Considering that the model is used to determine whether a pesticide is safe for public use, such gross miscalculations could result in massive unintended and unexpected exposures to highly toxic chemicals, the authors note. The study concludes that the model is not sufficiently cautious regarding hand exposure and recommends that field studies conducted under real-world conditions by academic researchers are needed to improve AOEM systemically, particularly for nonagricultural settings, to provide more accurate exposure estimates and strengthen safety measures.

Additional critiques offered by the authors include the fact that the model does not apply empirical or real-world field data to inform estimates. AOEM relies on 34 studies, some unpublished, despite the availability of academic research available on nonagricultural sectors. In addition, certain studies included are not published, limiting the availability of detailed methodologies for peer and public review. AOEM incorporates a total of 88 data points, but with only four studies involving knapsack sprayers, this study argues that the calculations may be too simplistic to account for the complexity of real-world exposure in different environments. Furthermore, despite the availability of applicable research, all the studies employed in AOEM were conducted by pesticide companies and not published in peer-reviewed journals where they can be critiqued. Perhaps most importantly, only four of the studies involved the use of a knapsack sprayer, which means the model cannot possibly account for average variations in applications under this method.

By not considering empirical use and field testing, the EU approach used for estimating pesticide operator exposure is akin to the pesticide regulation process conducted by the U.S. Environmental Protection Agency (EPA), which relies on pesticide manufacture’s supplied data on only the active ingredient, rather than the pesticide product formulation. Beyond Pesticides has long criticized EPA’s pesticide risk assessment process which ignores the availability of less toxic, viable alternatives, as proven in organic agriculture and organic land care. Instead of delaying important applicator standards, public health and environmental advocates call on EPA to honor the agency’s mandate to protect against “unreasonable” adverse effects by evaluating the reasonableness of risk with an assessment of alternative organic practices that eliminate their use (see here and here).

Beyond Pesticides’ coverage of farmworker exposure to pesticides and resultant harms began in the late 1970s and continues to this day, with recent attention drawn to a long history of health threats, U.S. and international pesticide regulatory failures, and (U.S.) structural racism, operationalized through disproportionate risk, that is imbued in the chemical-intensive agricultural system that feeds the nation and world. (See here, here, here, and here). Jay Feldman, executive director of Beyond Pesticides, adds, “These practices are particularly abhorrent, given the availability of organic compatible products that do not cause harm.”

With the knowledge that risk calculations are often not adequately protective and that the chemical widely used can be replaced by practices and products without the hazards, Beyond Pesticides advocates for the adoption of organic land management, a systems approach that eliminates toxic chemical pesticides and fertilizers while building organic matter and soil biology (see here) as a means of cycling nutrients for plant health. This approach is successfully and economically used in managing lawns, parks, and playing fields across the country, including as the foundation of the Parks for a Sustainable Future Program. Without proper enforcement and oversight, applicators, their clients, and the environment continue to be at risk. The study’s recommendation to call for stricter applicator standards is incremental and not a holistic solution that can meet the triple threat of existential crises stemming from chemical-intensive agriculture and land use. Continued use of petrochemical pesticides and fertilizers not only threaten the health and safety of pesticide applicators, including farmworkers, but their families and neighbors, the broader public, and the environment by means of the degradation wrought upon vital natural resources that sustain all life on Earth.

Beyond Pesticides has long sought a broad-scale marketplace transition to organic practices that, as a default, prohibits the use of synthetic pesticides by law—unless subject to rigorous health and environmental standards and recommended by the National Organic Standards Board (NOSB)—and requires a systems-based approach that is protective of health and the environment. This approach never allows the use of highly toxic synthetic pesticides, such as toxic organophosphates, and advances a viable, scalable path forward for growing food. Find out more about why organic is the right path forward for the future of farming by going to Beyond Pesticides’ organic agriculture webpage.

Take action today to keep organic strong! The NOSB is receiving written comments from the public, which must be submitted by 11:59 EDT on September 30, 2024. Written comments can be submitted via our “click and submit” form or directly through Regulations.gov. Click here to read suggested comments on our priority issues!

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

Sources:

Pesticide exposure in greenspaces: Comparing field measurement of dermal contamination with values predicted by registration models, Science of The Total Environment, April 2024
https://doi.org/10.1016/j.scitotenv.2024.170816

EPA’s Worker Protection Standard Fails to Protect Farmworkers’ Health, Report Finds, Beyond Pesticides Daily News, February 14, 2024

Toxicology Human Health Threats, Pesticides and You, 2023-2024

Science: Human Health Threats, Biodiversity, Climate, Pesticides and You, 2022-2023

Pruitt’s EPA Delays New Rules to Protect Pesticide Applicators, Beyond Pesticides Daily News, May 17, 2017

Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety, Center for Agriculture and Food Systems at Vermont Law and Graduate School, the Harvard Law School Food Law and Policy Clinic, and Farmworker Justice, December 2023

Essential and in Crisis: A Review of the Public Health Threats Facing Farmworkers in the US, Johns Hopkins Center for a Livable Future, May 2021

The Organic Farming Response to Climate Change, Pesticides and You, 2007

(Beyond Pesticides, September 18, 2024) A literature review in Trends in Analytical Chemistry analyzes scientific articles from the last ten years from around the globe that identify more than 300 pesticides in bee pollen. Bee pollen, often used as an edible dietary supplement, is not regulated for pesticide residues, which sparks concern for human exposure due to contamination with pesticides, heavy metals, metalloids, and mycotoxins. “Bee pollen is a food supplement that is receiving increasing attention for its nutraceutical and therapeutic properties. However, several uncertainties on the safety of this beekeeping product still exist. The present work addressed this issue through the critical evaluation of 61 studies, published over the 2014–2024 period,” the Spanish authors state.

Bee pollen is produced by honey bees. After they forage on flowers and gather pollen on their hind legs (in pollen baskets or corbiculae) to transport back to the hive, it is moistened with nectar and salivary secretions to create bee pollen in the form of pellets. While the composition of bee pollen can vary between geographical locations with different flowers, the studies reviewed all utilize mass spectrometry to pinpoint pesticides, as well as mycotoxins (created by naturally occurring mold spores), that threaten human health.

“Pesticides are chemicals designed to control agricultural pests, hence preventing product losses, but their toxicity can also affect non-target species, including humans, causing various disorders such as metabolic syndrome, inflammation, and nerve injuries,” the researchers say. These effects have been widely documented in peer-reviewed scientific journals. See more coverage from Beyond Pesticides here.

The authors continue, “Despite the measures introduced by several governments to control pesticides overuse… their employment in agriculture [has] resulted in an increase of approximately 50% in average total pesticide use during the last decade. This scenario is expected to worsen because of climate change, which could provoke a geographical redistribution of agricultural pests, possibly causing a further increase in pesticides usage.” With the myriad of negative effects on health and the environment with this usage, advocates are alarmed and are calling for alternative measures. 

The selected studies the researchers included in their review analyzed bee pollen samples globally, including Australia, Africa, North and South America, Asia, and Europe. Their results find that 358 pesticides were in the bee products tested in 53 of the studies, while seven mycotoxins were detected in the remaining eight studies. Many compounds were globally distributed, while others were more common in specific areas. The included studies offer a range of sampling parameters, with some focused on specific classes of pesticides, some occurring over many years, and some throughout multiple locations. One study analyzed 862 samples from 62 apiaries located in four U.S. states.

“Overall, an average of 118 pesticides were included in the scope of the reviewed literature, with some studies comprehending more than 300 analytes,” the researchers note. “An average of 27 chemicals were detected by each study, which corresponds to 23% of the average 118 compounds included in the analytical methods. Varied outcomes were observed across different studies, with the number of identified pesticides ranging from 0 (only in 2 studies) to 120.”

The identified compounds are insecticides (40%), fungicides (28%), herbicides (21%), metabolites (6%), miscellaneous compounds (3%), and veterinary treatments (1%). This highlights the exposure of bees to these toxic chemicals and their degradation products, during foraging in croplands and gardens, which then transfer to bee-derived products such as bee pollen. 

Of the pesticides detected, some were also miticides that beekeepers can use to combat Varroa mites. Amitraz and its degradation products (DMF and DMPF) were among those specified. Acrinathrin and chlorfenvinphos were also in the bee pollen samples analyzed, despite being banned in various countries, as they were previously widely used to combat hive infestations.

Many studies find high detection frequencies of neonicotinoid insecticides in bee pollen. “Despite their unique insecticidal effects, neonicotinoids have shown undesired effects, like high mobility in the environment, high persistence, and toxic effects on non-target organisms, including pollinators and human beings. For this reason, the outdoor employment of neonicotinoids like imidacloprid, thiamethoxam, and clothianidin—respectively detected in bee pollen by 62%, 28%, and 25% of studies conducted over the last 10 years—has been prohibited by several countries, including the EU [European Union],” the authors state. (See more studies on the negative effects of neonicotinoids here and here.)

The researchers continue, reporting that, “Besides neonicotinoids, other relevant compounds, banned by the EU for their toxicity, were detected in the selected studies. For instance, dimethoate, methomyl, and propargite were respectively found in bee pollen by 26%, 15%, and 9% of studies.” Chlorpyrifos and carbendazim were also frequently reported (detected by 55% and 43% of studies, respectively).

Currently for food products, the EU has Maximum Residue Levels (MRLs) in place for 666 pesticides across 13 food product categories such as fruits, vegetables, and spices. While there is a category for “honey and other apiculture products,” it does not include bee pollen. This is similar to other governmental authorities, such as the Environmental Protection Agency (EPA) and Food and Drug Administration (FDA) in the U.S. and National Health Commission (NHC) and China Food and Drug Administration (CFDA) in China.

The U.S. Department of Agriculture (USDA) has a MRL Database with the established maximum acceptable levels of some pesticides (such as fluvalinate, spinosad, dichlorvos, coumaphos, and amitraz) in raw and processed honey. In raw honey, the levels are between 0.01-5 parts per million (ppm) while the processed honey limits are much higher. Compared to the thousands of pesticides available on the market, only a handful are included in this database.

In 2016, U.S. Right to Know shared an article saying, “In examining honey samples from various locations in the United States, the FDA has found fresh evidence that residues of the weed killer called glyphosate can be pervasive – found even in a food that is not produced with the use of glyphosate. All of the samples the FDA tested in a recent examination contained glyphosate residues, and some of the honey showed residue levels double the limit allowed in the European Union, according to documents obtained through a Freedom of Information Act request. There is no legal tolerance level for glyphosate in honey in the United States.” Despite these concerning findings, to this day there are still not established MRLs for many widely used pesticides like glyphosate.

Data on pesticide residues in honey are numerous, with one study from 2020 reporting: “The results showed that 92 pesticide residues were found in honey samples from 27 countries. Six residues belong to class IA toxicity [of highly acute toxicity and severely irritating], eight residues belong to class IB toxicity, 42 residues belong to class II, 35 residues belong to class III and one residue belong to class IV toxicity.”

Another study detected fluvalinate and coumaphos in honeycomb and wax up to 204 and 94 ppm, respectively, in North American apiaries while MRLs for both of those pesticides are well below 1 ppm in raw commodities. Additional studies from around the world, such as a study in Italy, have identified dozens of pesticide residues, including illegal compounds, in honey. This alphabet soup of pesticides present in ecosystems nationwide underscores the infiltration of pesticides and their breakdown chemicals into the broader ecosystem.

The authors say that “in the case of bee pollen, the scarcity of specific data on its consumption and contamination introduces a series of approximations, when performing the risk assessment, that often impede obtaining unambiguous results. In addition, the absence of common standards for bee pollen production and distribution makes these predictions even vaguer and potentially inaccurate.”

The researchers are calling for international efforts to “harmonize risk assessment methodologies, and maximum levels of contaminants in food, especially in areas involving global food trade, to ensure consistent and reliable evaluations. The ultimate goal is to establish food safety standards based on scientifically sound risk assessments to protect public health.” There are current efforts through the International Organization for Standardization (ISO), but this is a long-term process towards the standardization of production methodologies and the homogenization of safety regulations that are lacking.

The current bee pollen market, exceeded only by honey, was valued around $756 million in 2022 and is expected to grow at an average rate of 5.5% over the next 10 years. Bee pollen has become increasingly popular for human consumption, as it contains proteins, carbohydrates, lipids, fibers, vitamins, minerals, and phenolic compounds. It is also “rich in essential elements like potassium, magnesium, sodium, calcium, iron, zinc, and many more, making it a food supplement with potential health claims,” the authors note. Studies have also been conducted on rabbits and chickens where the supplementation of bee pollen improves the animal’s growth and antioxidant status. This shows potential for bee pollen to be used as a replacement for synthetic antibiotics. (See studies here and here).

With the rise in use of bee pollen as a natural supplement, the lack of internationally shared quality norms for its production and distribution is of concern. The presence of hundreds of contaminants in these beekeeping products enhances the need for not only better risk assessments and globally standardized food safety regulations but also safer alternatives that remove petrochemical pesticides from use in agriculture and land management.

The adoption of organic methods mitigates the exposure of all organisms, specifically beneficial insects like pollinators, to toxic chemicals. Managing all land organically, whether that is in parks, gardens, athletic fields, or croplands, focuses on the health of all organisms and the environment by starting at the foundation with soil health. Organic food, under the Organic Foods Production Act (OFPA), embodies the expectations of organic agriculture with an ecological approach to farming that does not rely on or permit toxic pesticides, chemical fertilizers, genetically modified organisms, antibiotics, sewage sludge, or irradiation.

Keeping Organic Strong is vital to protect all life. Take action to continuously improve upon the values and standards for organic food production that ensures protection of the ecosystem and biodiversity, mitigates climate change, and enhances human health.

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

Source:

Carrera, M. et al. (2024) Unveiling bee pollen’s contamination with pesticides and mycotoxins: Current analytical procedures, results and regulation, Trends in Analytical Chemistry. Available at: https://www.sciencedirect.com/science/article/abs/pii/S0165993624004187.

(Beyond Pesticides, September 17, 2024) Today, International Microorganism Day, is a prime moment to focus on the complexity of billions of living beings that establish the foundation of land management and food production. Organic advocates, community members, and farmers identify the protection and enhancement of biological diversity in the soil as a key goal, especially in light of mounting concerns over rising microbial resistance to chemical-intensive practices.

A recent article in British Journal of Environmental Sciences points to several microbial populations adversely affected by pesticide-contaminated soil on various farmland plots in Nigeria. There are significant variations in bacteria presence between pesticide-treated and control plots, with a lab analysis finding “[s]eventy-five percent (75%) of pesticide residue was detected in the soil samples,” which includes paraquat dichloride, endosulfan, diazinon, and N-(phosponomethyl)glycine [glyphosate]. This report builds on years of research from higher education institutions worldwide, including participatory research centering applied experiments on farmland, demonstrating the consequences of relying on pesticide-intensive agriculture and land management.

The main goal of this report is to “determine the influence of pesticide contamination on the microbial population, physiochemical parameters and pesticide residue of soil of selected farmlands in Otuoke, Bayelsa State, Nigeria.” Researchers document the presence of eleven different bacteria isolates and sixteen different fungi across four different farmland sites (with one site serving as the control in which no pesticides were sprayed during the course of the experiment), since researchers identified in previous research that several selected bacteria “thrive as a response to environmental stress, possibly induced by pesticide contamination.” [The sites are identified as Bakery 1, Bakery 2, Dorcas, PGS, and Control.]

Researchers found high variability between levels of different bacteria and fungi across the experimental and control sites, indicating that pesticide contamination influences microbial activity. Across all five sites, there was relatively higher microbial activity at the control site corresponding with limited pesticide residue (except a small presence of paraquat across all sites). For example, the highest occurrence of beneficial fungi including Trichoderma species (14.3%), Lichtheimia hyalospora (28.6%), Penicillium camemberti (14.3%), as well as beneficial bacteria including Streptomyces coelicolor (29.4%), were found at the control site.

Some additional main takeaways include:

• “Pseudomonas aeruginosa shows a significant presence at Bakery 2 (10.4%) and Control (40.6%), but it is absent at the other farmlands. Since Pseudomonas aeruginosa is known for its adaptability and can thrive in various conditions, its prevalence at Bakery 2 might indicate its ability to thrive despite the contamination of the pesticides (Diazinon) and environmental conditions in this farmland [].”
• “Rhodotorula glutinis is prevalent at Bakery 1 (82.3%), Bakery 2 (77.5%), and Dorcas (81.1%). Rhodotorula species are known to be resilient to various stress factors, including pesticides [].”

These bacteria include Pseudomonas aeruginosa, Streptomyces coelicolor, Streptomyces scabies, Actinomyces isrealii, Streptomyces aureofaciens, Streptomyces griseus, Nocardia asteroids, Proteus vulgaris, Streptococcus pyogenes, Klebsiella pneumoniae, and Bacillus subtilis. The fungi types include Alternaria alternata, Fusarium oxysporum, Candida tropicalis, Rhodotorula glutinis, Lichtheimia hyalospora, Rhizopus arrhizus, Fusarium chlamydosporium, Rhizopus stolonifera, Penicillium camemberti, Fusarium fumonisin, Trichoderma spp, Aspergillus flavus, Phytophthora occultans, Penicillium italicum, Aspergillus niger, and Cladosporium hyalospora.

This study was published on August 17, 2024 in a publication of the European Center for Research Training and Development in the United Kingdom. The main authors specialize in microbiology and botany from Nigerian universities, including Federal University Otuoke, University of Lagos, and Rivers State University. One of the leading researchers, Omokaro Obire, PhD, is a professor of environmental microbiology at Rivers State University and has authored approximately twenty studies garnering over 1,600 citations since her first publication in 1996. She is also the editor-in-chief of International Journal of Microbiology and Applied Sciences — the official journal for Rivers State University.

The increased use of antimicrobial products alarms scientists, public health professionals, farmers, and various other stakeholders concerned with holistic environmental health. The Food and Drug Administration (FDA) warned nine manufacturers and distributors in December last year to stop selling unapproved and misbranded antimicrobial animal drugs over concerns about co-resistance and cross-resistance mechanisms. Antimicrobial resistance (AMR) is a global crisis, as recorded in a 2019 study published in Science where researchers identified hotspots of resistance in northeastern India, northeastern China, northern Pakistan, Iran, eastern Turkey, the south coast of Brazil, Egypt, the Red River Delta in Vietnam, and the areas surrounding Mexico City and Johannesburg. Additional studies have documented antimicrobial pesticide exposure to cause adverse impacts regarding gut microbiome health and fungal resistance leading to deadly infections, among others. According to the study published in Nature Communications, triclosan (antibacterial) worsens the effects of ulcerative colitis, an inflammatory bowel disease (IBD), through the retention of harmful bacteria. On the matter of fungal resistance, a recent study conducted by scientists at the University of Georgia finds fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens. 

As Beyond Pesticides has reported previously on microbial resistance to pesticides, resistant genes move from the farm after being treated with antibiotics or antifungals—or other chemicals like the weed killer glyphosate, which has antibiotic properties—through society as the efficacy of antibiotic and antifungal medicines declines. A pool of resistant soil bacteria or commensal gut bacteria can provide the genetic material for resistance in human pathogens. The basic mechanism is as follows. If bacteria on the plants and in the soil are sprayed with an antibiotic, those organisms with genes for resistance to the chemical increase compared to those susceptible to the antibiotic. These chemical sprays increase the frequency of resistant genotypes by killing those susceptible to the antibiotic and spare the others. Those genes may be taken up by other bacteria through a number of mechanisms, collectively known as “horizontal gene transfer.” (See Daily News.)

In the early months of the Covid-19 pandemic, there were wide concerns about the health impacts of contracting the disease and public officials attempting to mitigate risk. Following reporting from local news outlets amplified by Beyond Pesticides and advocacy led by the Tennessee Black Caucasus of State Legislators, free masks were recalled in the state upon discovery that they were treated with a toxic antimicrobial chemical. (See Pesticides and You article, “Antimicrobial” Facemask Unnecessarily Toxic, here for more information). Public health officials have warned about the increased risk of future global pandemics amidst increasing antimicrobial resistance, in a 2020 study published in The Lancet. For more research on the impacts of antimicrobial resistance and antimicrobial products, see Daily News section on antimicrobials as well as our dedicated page on Disinfectants, Sanitizers, and Microbials.

While celebrating International Microorganism Day today, this month is also National Organic Month. To improve the viability and expand the reach of organic agricultural systems in the United States, communities should feel empowered to engage in strengthening federal organic standards, research, and policies in service of public health, biodiversity, and climate resilience.

See Keeping Organic Strong to access opportunities to engage in the Fall 2024 National Organic Standards Board public comments process before the deadline on September 30.

Consider subscribing to the Action of the Week to receive regular updates on how to advocate for transformative policy change on your preferred electronic device.

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

Source: British Journal of Environmental Sciences

(Beyond Pesticides, September 16, 2024) After the release of a hard-hitting study last week published in Science that pinpoints the cycle of increasing pesticide use with ecosystem and bat decline, resulting in higher infant mortality, Beyond Pesticides is calling for state and local action to transition public land to organic practices. Without a healthy ecosystem, the study documents increased pesticide use with dramatic adverse health effects.

To take corrective action, Beyond Pesticides’ action asks governors and mayors to do the following: Eliminate the use of pesticides that imperil bats by adopting biodiversity conservation goals including— (1) ecological mosquito management with measures that recognize the benefit of preventive strategies, establish source reduction programs to manage breeding sites on public lands, educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonicotinoids; and (3) land management on public lands—including hospitals, higher education institutions, schools, and parks—using regenerative organic principles and organic certified practices and products, to transition to a viable organic system that prioritizes long-term health of the public, ecology, and economy.

The new research connects declines in bat populations with increased human infant mortality. The connection is increased pesticide use. The study by Eyal Frank, PhD, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes with a finding that “declines in insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.” 

>> Tell your Governor and Mayor to stop the cycle of increasing pesticide dependency tied to an imbalance in ecosystems degraded by pesticide use and other factors—resulting in a loss of natural insect management by bats and other wildlife that leads to rising pesticide use and increasing infant mortality and public health threats.

Many farmers rely on bats as alternatives to insecticides to protect their crops from insects, but the invasive fungus Pseudogymnoascus destructans, White-Nose Syndrome (WNS) has caused a serious decline in bat populations since 2006. Bats are also important in keeping mosquitoes under control. According to bat experts, 52% of bat species in North America are at risk of severe declines over the next 15 years. While there are numerous causes of fungal diseases, pesticide use can increase vulnerability by depressing the immune system. With the collapse of many bat populations from WNS found in caves that affect bats during hibernation, farmers turn to toxic chemicals to replace the ecosystem services bats usually provide. These chemicals, however, lead to ripples through the ecosystem and endanger human health.  

To determine the impacts on human health from these population declines, Dr. Frank collected data from WNS-affected counties on insecticide use and infant mortality from 2006-2017. In comparing these numbers, “after the onset of bat die-offs, farmers in the county increase their insecticide use by 31.1%, on average,” he states. “Infant mortality rates due to internal causes of death (i.e., not due to accidents or homicides) increased by 7.9%, on average, in the affected counties. This result highlights that real-world use levels of insecticides have a detrimental impact on health, even when used within regulatory limits.” These rates correspond to an additional 1,334 infant deaths—for every 1% increase in pesticides, a 0.25% increase in the infant mortality rate is documented. The CDC (Centers for Disease Control and Prevention) says, “The infant mortality rate is an important marker of the overall health of a society.” Although infant mortality in the U.S. has been decreasing, 43 countries have infant death rates lower than the United States.  

But, not only does decreasing bat populations lead to more pesticide use, leading to more infant deaths, but pesticide use also leads to decreasing bat populations. An extensive article by William Quarles, PhD, published in the IPM Practitioner in 2013, lays out much of the research that has been done on bats, pesticides, and WNS. Dr. Quarles finds that the immune system of bats in the U.S. is unable to prevent infection with WNS. He reviews studies showing that pesticides including DDT, organophosphates, and carbamates result in death or reproductive toxicity in bats. More recently, Pierre Mineau, PhD, and Carolyn Callaghan, PhD, find, “[T]here is evidence to support the claim that bats are being negatively affected by neonicotinoid insecticides in several different ways, indirectly through reduction in insect abundance and directly through impairment.” J.M. Oliviera et al. review research on pesticide impacts on bats, finding, “Pesticide toxicity leads to immunosuppression and makes the individual more susceptible to infections by pathogenic organisms.” 

The cycle of pesticide use causing decreasing bat populations causing more pesticide use is an engine leading to ongoing and increasing infant deaths. We can break the cycle of increasing pesticide dependency with organic practices that are in sync with nature and intended to protect and enhance biodiversity.  

Multiple crises impacting biodiversity, human health, and climate change threaten ecological balance. Bats are one of many species providing important ecosystem services, such as mosquito management and pollination, who are underappreciated until their services are no longer available.  

>> Tell your Governor and Mayor to stop the cycle of increasing pesticide dependency tied to an imbalance in ecosystems degraded by pesticide use and other factors—resulting in a loss of natural insect management by bats and other wildlife that leads to rising pesticide use and increasing infant mortality and public health threats. 

Dear Governor
Shocking new research connects declines in bat populations to increased human infant mortality. The connection is increased pesticide use. The study by Eyal Frank, PhD, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes, “[D]eclines in insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.”

Bats help protect crops from insects and control mosquitoes, but the White-Nose Syndrome (WNS), has reduced bat populations. According to bat experts, 52% of bat species in North America are at risk of severe declines over the next 15 years. While there are many causes of fungal diseases, pesticide use can increase vulnerability by depressing the immune system. With the collapse of many bat populations from WNS, farmers turn to toxic chemicals to replace the ecosystem services bats usually provide—chemicals that ripple through the ecosystem and endanger human health. 

To determine impacts on human health from bat population declines, Dr. Frank collected data from counties with WNS regarding insecticide use and infant mortality from 2006-2017. In comparing these numbers, “[A]fter the onset of bat die-offs, farmers in the county increase their insecticide use by 31.1%, on average,” he states. “Infant mortality rates due to internal causes of death (i.e., not due to accidents or homicides) increased by 7.9%, on average, in the affected counties. This result highlights that real-world use levels of insecticides have a detrimental impact on health, even when used within regulatory limits.” These rates correspond to an additional 1,334 infant deaths—for every 1% increase in pesticides, a 0.25% increase in the infant mortality rate results. 

Not only do decreasing bat populations lead to more pesticide use, leading to more infant deaths, but pesticide use also leads to decreasing bat populations. William Quarles, Ph.D., in The IPM Practitioner, summarizes research done on bats, pesticides, and WNS. He finds that the immune system of bats in the U.S. is unable to prevent infection with WNS and reviews studies showing that pesticides including DDT, organophosphates, and carbamates, result in death or reproductive toxicity in bats. More recently, Pierre Mineau, PhD, and Carolyn Callaghan, PhD, find, “[T]here is evidence to support the claim that bats are being negatively affected by neonicotinoid insecticides in several different ways, indirectly through reduction in insect abundance and directly through impairment.” J.M. Oliviera et al. review research on pesticide impacts on bats, finding, “Pesticides toxicity leads to immunosuppression and makes the individual more susceptible to infections by pathogenic organisms.”

The cycle of pesticide use causing decreasing bat populations causing more pesticide use is an engine leading to ongoing and increasing infant deaths. We can break the cycle of increasing pesticide dependency with organic practices that are in sync with nature and protect and enhance biodiversity.

Please eliminate the use of pesticides in our city that imperil bats by adopting biodiversity conservation goals including: (1) ecological mosquito management with measures that recognize the benefit of preventive strategies, establish source reduction programs to manage breeding sites on public lands, educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonicotinoids; and (3) land management on public lands—including hospitals, higher education institutions, schools, and parks—using regenerative organic principles and organic certified practices and products, to transition to a viable organic system that prioritizes long-term health of the public, ecology, and economy.

Thank you.

Dear Mayor
Shocking new research connects declines in bat populations to increased human infant mortality. The connection is increased pesticide use. The study by Eyal Frank, PhD, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” concludes, “[D]eclines in insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.” 

Bats help protect crops from insects and control mosquitoes, but the invasive fungus Pseudogymnoascus destructans, White-Nose Syndrome (WNS), has reduced bat populations since 2006. According to bat experts, 52% of bat species in North America are also at risk of severe declines over the next 15 years. While there are numerous causes of fungal diseases, pesticide use can increase vulnerability by depressing the immune system. With the collapse of many bat populations from WNS, farmers turn to toxic chemicals to replace the ecosystem services bats usually provide—chemicals that ripple through the ecosystem and endanger human health.  

To determine impacts on human health from bat population declines, Dr. Frank collected data from counties with WNS regarding insecticide use and infant mortality from 2006-2017. In comparing these numbers, “[A]fter the onset of bat die-offs, farmers in the county increase their insecticide use by 31.1%, on average,” he states. “Infant mortality rates due to internal causes of death (i.e., not due to accidents or homicides) increased by 7.9%, on average, in the affected counties. This result highlights that real-world use levels of insecticides have a detrimental impact on health, even when used within regulatory limits.” These rates correspond to an additional 1,334 infant deaths—for every 1% increase in pesticides, a 0.25% increase in the infant mortality rate results.  

But not only does decreasing bat populations lead to more pesticide use, leading to more infant deaths, but pesticide use also leads to decreasing bat populations. William Quarles, PhD, summarizes research done on bats, pesticides, and WNS; he finds that the immune system of bats in the U.S. is unable to prevent infection with WNS. He reviews studies showing that pesticides including DDT, and more recently organophosphates, and carbamates, result in death or reproductive toxicity in bats. More recently, Pierre Mineau, PhD, and Carolyn Callaghan, PhD, find, “[T]here is evidence to support the claim that bats are being negatively affected by neonicotinoid insecticides in several different ways, indirectly through reduction in insect abundance and directly through impairment.” J.M. Oliviera et al. review research on pesticide impacts on bats, finding, “Pesticides’ toxicity leads to immunosuppression and makes the individual more susceptible to infections by pathogenic organisms.” 

The cycle of pesticide use causing decreasing bat populations causing more pesticide use is an engine leading to ongoing and increasing infant deaths. We can break the cycle of increasing pesticide dependency with organic practices in sync with nature and intended to protect and enhance biodiversity. 

Please eliminate the use of pesticides that imperil bats by adopting biodiversity conservation goals including: (1) ecological mosquito management with measures that recognize the benefit of preventive strategies, establish source reduction programs to manage breeding sites on public lands, educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonics; and (3) land management on public lands—including hospitals, universities, schools, and parks—using regenerative organic principles and organic certified practices and products, to transition to a viable system that prioritizes long-term health of the public, ecology, and economy. 

Thank you.

(Beyond Pesticides, September 13, 2024) While chemical companies persist in pushing simplistic solutions to complex problems, there is a large amount of evidence that organic farming presents effective solutions to many of those problems. Now there is new evidence that organic agriculture prevents the untold harms of pesticide-driven monoculture. In a new study, German researchers compared 16 agricultural landscapes in Lower Saxony and northern Hesse that had different combinations of semi-natural habitat, organic practices, and annual and perennial flower strips. Overall, the researchers find that organic farming provides the highest benefit to the bees, along with the presence of diverse flowering plants in and near monoculture fields.

The study compares the effects of three honey bee conservation methods on the prevalence of the parasitic mite Varroa destructor and the 11 parasites Varroa transfers to bees, and the impact of these destructive organisms on bee colony growth. The findings were reported in the June issue of the Journal of Applied Ecology.

Organic practices lead directly to lower parasite load and higher colony growth—essentially, the more organic crops, the more bees, and the more parasites, the fewer bees. Pesticides plus monoculture doubles the damage: Pesticides increase mortality, damage bees’ immune systems, and reduce foraging capacity, while monoculture disturbs bees’ nutritional balance, making them less able to resist parasites and survive pesticide exposure.

In a perverse irony, conventional agriculture has been shifting toward more pollinated crops. Beyond Pesticides has covered research showing that between 1961 and 2016, the aggregate land area of crops requiring pollination grew by 136.9%, all while actual pollinator abundance was plunging because of pesticides, land use and climate changes, and monoculture. Yet the chemical company persuaders push the very practices that are causing the problems. In part, as noted in a 2019 study analyzed by Beyond Pesticides, the jump in pollinator-requiring crops is because they have higher market value than non-pollinated crops like cereals. Oilseed has been a particularly fast-growing sector. That 2019 study also found that crop diversity has not increased with the expansion of pollinated species. Like the larger effect of general biodiversity, crops diversity provides a much better environment for pollinators.

After organic practices, honey bee health depends on flower diversity in nearby semi-natural habitats and non-crop strips alongside fields. The health of European honey bees sometimes appears at odds with that of other wild pollinators, because of a disparity between perennial and annual flowers. Honey bees do better in the study from access to annuals and had higher parasite loads when semi-natural habitats and flower strips were dominated by perennials. This is likely because perennials produce fewer flowers than annuals, crowding more bees into smaller spaces. Further, annuals are associated with lower numbers of Varroa. This is important because, while Varroa directly harms bee health, the numerous other parasites such as viruses that Varroa harbors and transmits may cause even more damage. Yet, other wild pollinators need perennials more, and the authors stress that all insect types benefit from the provision of diverse flower species in fields and their surroundings.  

Other research has shown that large fields of flowering plants, such as oil rapeseed (the parent plant of canola), attract bees and support colony growth, but also increase parasite loads. They do create masses of flowers that attract masses of insects. They may offer a large amount of food but only for short periods. In fact, previous research has shown that mass-flowering monoculture increases the exposure of bees to parasites, and that “monoculture alone cannot support healthy bees.” Buffer zones like semi-natural habitats and flower strips featuring mixed flowers that bloom at different times provide more stable, long-lasting food supplies.

Both wild pollinators and honey bees are suffering deep losses, and restoring varied landscapes with both perennial and annual flower varieties would help everyone, including farmers. The rationale advanced by some that monoculture of flowering crops by itself will rescue pollinators is wrong, say the authors: “We also found that the relationship of colony growth and parasitism to organic farming is not driven by mass-flowering crops, but rather by a complementary effect of mass-flowering and non-mass-flowering organic agriculture.” Although they did not specify what other organic practices contribute to bee health, there is surely much less stress on pollinators in an environment without pesticides that includes all varieties of biodiversity.

The authors note that their results support the European Union’s Green Deal, which aims to reach 25% organic agriculture in Europe by 2030. A 2023 evaluation of U.S. organic farming compares the success of U.S. policies to those of Denmark. The U.S. came out the clear loser. In 2022 the U.S. Department of  Department of Agriculture (USDA) created an “Organic Transition Initiative” to help reverse the trend that “the number of non-certified organic farms actively transitioning to organic production dropped by nearly 71 percent since 2008,” according to the U.S.D.A. press release. This drop occurred even as demand for organic products doubled between 2013 and 2023. Assessment of the Organic Transition Initiative’s success so far is scarce, but organic advocates praised the initiative when it was announced because it aims to provide mentors, extension agents and crop advisors with organic expertise to farmers transitioning to organic practices.

Everyone can contribute to the shift away from our toxic “business as usual” approaches and toward a genuinely sustainable agroeconomy. As set out in the June 18, 2019 Beyond Pesticides Daily News entry, “through public pressure and consumer choice, we can shift towards alternative products and practices, improve biodiversity, and begin to repair the damage done by industrial agriculture.” You can track pollinator, biodiversity, and organic agriculture developments with Beyond Pesticides’ multiplicity of tools, including our Daily News and the journal Pesticides and You. Support our work by becoming a member and/or signing up to learn about actions to take in support of our mission.

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

Sources:

Organic farming and annual flower strips reduce parasite prevalence in honeybees and boost colony growth in agricultural landscapes
Patrycja Pluta et al.
Journal of Applied Ecology
June 2024 
https://besjournals.onlinelibrary.wiley.com/doi/10.1111/1365-2664.14723

Global agricultural productivity is threatened by increasing pollinator dependence without a parallel increase in crop diversification
Marcelo A. Aizen, et al.
Global Change Biology
July 10, 2019
https://onlinelibrary.wiley.com/doi/full/10.1111/gcb.14736

European Commission: Directorate-General for Environment, Agri-environment schemes – Impacts on the agricultural environment
Publications Office, 2017
https://data.europa.eu/doi/10.2779/633983   

Industrial Agriculture Practices Contribute to the Insect Apocalypse
June 18, 2019
https://beyondpesticides.org/dailynewsblog/2019/06/industrial-agriculture-practices-contribute-to-the-insect-apocalypse/

Monoculture in Crop Production Contributes to Biodiversity Loss and Pollinator Decline
Beyond Pesticides, July 26, 2019
https://beyondpesticides.org/dailynewsblog/2019/07/monoculture-in-crop-production-contribute-to-biodiversity-loss-and-pollinator-decline/

Study of Pesticide Risk in Wild Bee Species Highlights EPA Risk Assessment Inadequacies
Beyond Pesticides, August 23, 2024
https://beyondpesticides.org/dailynewsblog/2024/08/study-of-pesticide-risk-in-wild-bee-species-highlights-epa-risk-assessment-inadequacies/

Neonicotinoid Insecticides Contribute to Honey Bee Vulnerability to Parasitic Varroa Mites
Beyond Pesticides, July 10, 2024
https://beyondpesticides.org/dailynewsblog/2024/07/neonicotinoid-insecticides-contribute-to-honey-bee-vulnerability-to-parasitic-varroa-mites/

Mass-flowering monoculture attracts bees, amplifying parasite prevalence
Hamutahl Cohen et al.
Proceedings of the Royal Society B
October 13, 2021
https://royalsocietypublishing.org/doi/10.1098/rspb.2021.1369

(Beyond Pesticides, September 12, 2024) In a year with 74 national elections on the calendar, legislators and executive branches alike are in contention on the future of business-as-usual pesticide use and manufacturing. Be it Kenya or Brazil, the European Union and Mercosur (South American Trade Bloc), there is a growing contingency of farmers, advocates, researchers, and public leaders who desire a pathway forward in strengthening pesticide restrictions and supporting alternatives to chemical-intensive agriculture and land management, including organic. As leadership shifts and domestic conversations mount ahead of the 2024 United Nations Climate Change Conference (COP29) in Azerbaijan and the 2024 National Organic Standards Board meeting this fall, environmental and health advocates say it is vital that world leaders acknowledge the decades of grassroots advocacy and market development that led to the growth of organic systems in service of building capacity for nutrition, public health, biodiversity, and climate resilience while advancing food security.

Kenya

Earlier this month, the Kenyan parliament introduced a resolution to ban hazardous pesticides including glyphosate-based herbicide products such as RoundUp sold by Bayer/Monsanto, leading to a fiery debate on the state of agricultural uses. Hon. Gladys Boss, Deputy Speaker for the National Assembly, speaks to the rationale for introducing the petition:

“The issue of carcinogenic pesticides and Round-Up herbicides is of significant concern to our country. This challenge is known in all levels of Government. The “Pesticide Atlas”, a document developed by 20 scientists from the University of Nairobi, confirms that 267 pesticides banned in Europe and America are still in use in Kenya. The Pest Control Products Board (PCPB) is responsible for approving pesticides and yet, banned pesticides [in other nations] are still on our list. The offender here is the Pest Control Products Board. I have submitted a Petition to the Cabinet Secretary for Agriculture and Livestock, requesting for the removal of the Pest Control Products Board from office due to their failure, which has endangered Kenyan lives.” (p.10)

Following the submission of this petition, the National Assembly Health Committee charged the PCPB to review the list of allowable pesticides and update regulations to remove toxic pesticides from the market. There is expected to be a follow-up after an August legislative recess. The Pesticide Atlas project—led by Friends of the Earth Europe with support from Friends of the Earth Germany, Pesticide Action Network Europe, and Heinrich Böll Foundation and edited by renowned food systems researcher and advocate Anna Lappé, PhD—analyzes the intersectional harms posed by toxic pesticides, as well as the industry interference in scientific risk assessment and regulatory oversight processes that lead to rampant pesticide use reflected in trade, agricultural, health, and environmental policies. Given that the Gates Foundation-funded Alliance for Green Revolution in Africa’s (AGRA) headquarters is based in Kenya, advocates are interested to see what direction the government will take in regulating toxic pesticides and genetically engineered seeds.

Brazil

There are also ongoing debates in Brazil regarding the direction of the national government on how to approach pesticide regulations. Brasil de Fato reported over the summer a series of political infighting within the Administration of President Lula da Silva on reducing pesticide use—particularly, given fundamental disagreements between the Ministry of Agriculture and Livestock (MAPA) and the Ministry of Agrarian Development (MDA).

Both ministries are leading administrative agencies within the Interministerial Chamber for Agroecology and Organic Food Production (CIAPO), which is tasked with implementing the National Plan for Agroecology and Organic Food Production (PLANAPO). MDA Minister Paulo Teixeira has called for the taxation of “pesticides that pose a high risk to health…in order to promote healthy eating,” receiving praise for these comments from various farmworkers, farmer advocacy, and environmental groups. Meanwhile, MAPA has postponed the rollout of PLANAPO twice so far by not allowing the National Program for the Reduction of Pesticides (PRONARA) to be included in PLANAPO, which advocates believe would undermine the effectiveness of the broader systemic plan.

Meanwhile, various political parties and organizations are challenging a law known as the “Poison Package” in the Supreme Court because of fears that it would make pesticide regulations more flexible and undermine PLANAPO. The push for this law began in 1999 with former Senator Blairo Maggi, known as “the king of soybeans,” due to his ties to the industry that is the most chemical-intensive sector of the agricultural economy in the nation. Brazil’s pesticide usage has increased by over 700 percent in the past four decades, with over 2,179 new registrations approved between 2019 and 2022, based on reporting by Scientific American and Mongabay. See the Human Rights Watch (HRW) article, “Brazil: Veto Dangerous Pesticide Bill,” for a comprehensive analysis of the adverse impacts this legislation would have on environmental, public health, and biodiversity protections.

As Maria Laura Canineu, formerly HRW Director in Brazil (now deputy director of the Environment and Human Rights Division), puts it, “Instead of opening the floodgates for dangerous pesticides, President Lula should veto the bill and improve regulations to protect Brazilians’ lives and the environment.”

European Union-Mercosur

The issue of pesticide regulations is a common thread in discussing different agricultural, environmental, public health, and occupational safety laws in different countries. As a result, some pesticides that are outlawed in the European Union are still sold to countries including Brazil and Kenya or, in the case of the deadly and destructive weedkiller paraquat, sold in the United States despite being banned in China—the country that acquired the company that began the production of paraquat-based herbicides in 1955. These inquiries around environmental injustice versus chemical-intensive agricultural support systems have led to tense trade relations, including between the European Union and Mercosur.

Mercosur is a trading bloc that represents Argentina, Bolivia, Brazil, Paraguay, and Uruguay, a significant slice of South American economic interests and agricultural production. The EU-Mercosur deal reached an agreement in December 2019 after two decades of negotiations, yet five years later, it remains unclear whether respective member states will ratify this deal for a variety of reasons, including agricultural and pesticide policy. According to an analysis by the Center for Strategic and International Studies, “European farmers are represented by a lobby that, by even the standards of Brussels, enjoys remarkable access to both the European Union’s executive and legislature.”

France has been skeptical of an EU-Mercosur deal primarily due to internal pressures from farmers who are frustrated with EU-wide pesticide and agricultural policies, as well as price competition with South American producers. European Parliament members representing The Greens/European Free Alliance (Greens) submitted the report, “The EU-Mercosur Free Trade Agreement, its impacts on Agriculture,“ which discusses the implications of an EU-Mercosur Deal on agricultural, environmental, and pesticide regulations. The report points out weaknesses in pesticide regulations among Mercosur member states, including the use of banned pesticides and antibiotics by farmers in the bloc (with special emphasis on Brazilian producers) as well as concerns around price competition that aligns with CSIS analysis. The Greens are calling for a complete redrawing of the 2019 deal to account for these discrepancies.

With the reelection of Ursula Von der Leyen as President of the European Commission, it remains an open question as to the direction of EU agricultural policy and trade agreements as President-elect Von de Leyen considers the next Commissioner of Agriculture following the end of Commissioner Janusz Wojciechowski’s tenure. Analysis led by US Times Mirror indicates that some of the likely candidates will come from Luxembourg, Portugal, Greece, or The Netherlands. Organic advocates and farmers, as well as the general public, recognize the benefit of an appointment from the first three nations considering the growth and prevalence of organic producers and infrastructures in those nations relative to other nations.

For example, Greece saw a 78% increase in organic farmland in the last year with approximately 17.6 percent of total agricultural land farmed organically, with Portugal at 19.1% and Luxembourg at 6.2%, based on analysis from IFOAM Organics International. The Netherlands sits at just 4.2% of the total share and, according to analysts, the nation’s vision for the future of agriculture “focuses on innovation, scale production, and less organic farming.” Moreover, the appointment of a Dutch Commissioner would likely conflict with ambitious EU targets including the Farm to Fork Strategy (F2F) and European Green Deal (EGD)—with the goal to have at least 25 percent of European farmland run on organic land management practices by 2030.

Call to Action

As different countries pave new approaches to pesticide regulations, many of which are beginning to take seriously the consequences of failing to pass holistic climate policy that considers public health, biodiversity, and environmental justice, advocates continue to call on strengthening organic land management and agricultural systems. See Keeping Organic Strong to learn how to engage in the Fall 2024 National Organic Standards Board (NOSB) meeting. Also consider subscribing to Action of the Week to engage with elected officials, agency rulemaking, and other actions as they pertain to pesticide regulations, environmental protections, climate resilience, and public health.

Sources: The Hansard, Brasil de Fato, Center for Strategic & International Studies, European Parliamentary Research Service

(Beyond Pesticides, September 11, 2024) A literature review in Environments, written by researchers from South Korea and Ghana, highlights the threat to nontarget species and the biodiversity of insects that occur as a result of agricultural pesticide use. “Insects have experienced a greater species abundance decline than birds, plants, and other organisms, which could pose a significant challenge to global ecosystem management. Although other factors such as urbanisation, deforestation, monoculture, and industrialisation may have contributed to the decline in insect species, the extensive application of agro-chemicals appears to cause the most serious threat,” the authors state. The so-called “insect apocalypse” has been reported with one-quarter of the global insect population lost since 1990. 

The authors, seeking to summarize the decline in insect species richness and abundance, link reliance on petrochemical pesticides and synthetic fertilizers to cascading negative impacts. Insects provide many important services, such as maintaining healthy soil, recycling nutrients, pollinating flowers and crops, and controlling pests. These nontarget and beneficial species are at risk through pesticide exposure, both directly and indirectly, which then affects these essential functions.  

“Extensive and indiscriminate pesticide application on a commercial scale affects insect species abundance and non-target organisms by interfering with their growth, development, behaviour, and other metabolic and physiological processes,” the researchers find, based on their analysis of peer-reviewed scientific studies. The pesticide residues that contaminate plants and insects that provide a food source for other organisms can lead to population effects throughout multiple trophic levels. Since the active ingredients in pesticides can affect a wide range of taxonomic groups, they cause harm to numerous species rather than just the target species.  

As the authors state, “Chemical residues pose a significant threat to species richness and abundance… For instance, the efficacy of [the weed killer] glyphosate requires plants to absorb its residues through their leaves or roots when applied. However, if glyphosate is accidentally spread on the ground, it is absorbed into soil particles and may remain active, threatening other species if not absorbed by the plant.” Whether nontarget insects are sprayed directly during pesticide application or are exposed to residues after spraying, this puts them at risk.  

“Pesticides are known to be harmful to insects, with direct mortality frequently reported, with nontarget insects being the most vulnerable when compared to other insects,” the researchers comment. They continue, “These pesticides work directly by disrupting the insect’s nervous system or damaging its exoskeleton, causing paralysis and death.” With an increase in pesticide use, there is also an increase in related insect mortality. 

As Dave Goulson, PhD says, an insect apocalypse is occurring that threatens all ecosystems. In an essay in Current Biology, he states, “Insects are integral to every terrestrial food web, being food for numerous birds, bats, reptiles, amphibians and fish, and performing vital roles such as pollination, pest control and nutrient recycling. Terrestrial and freshwater ecosystems will collapse without insects… we may have failed to appreciate the full scale and pace of environmental degradation caused by human activities in the Anthropocene.” 

The literature review authors reinforce this by saying, “The widespread use of pesticides in agricultural production has been identified as the primary cause of the overall loss of insect species and individual numbers” and studies show that insect declines appear to be much greater than those observed in birds or plants. “For instance, in 71% of butterfly species in Britain, the total number of individuals has decreased over 20 years, compared to birds (54% over 20 years), and plant species (28% over 20 years),” they note. 

Direct pesticide exposure to insects causes changes within species and at the population level. The authors share examples: “Neonicotinoids increased bee and butterfly mortality while reducing their behaviour and survival. Glyphosate exposure caused changes in bees’ gut microbiome, leaving them vulnerable. In the United Kingdom, the direct effects of pesticides reduced butterfly species richness on conventional farms more than on organic farms.” 

Additional studies show the same concerning statistical trend for many pollinator species such as 45 butterfly species in Belgium, which declined by nearly 69%, and 733 moth species in the Netherlands, which declined by 85%, over the past century. 38% of these declining species are listed as threatened and 34% as susceptible by the European Red List of Threatened Species. (See original studies here and here.)  

Effects of pesticides on species of bees are also heavily documented. “Agricultural intensification, chemical fertilisers, and pesticide application have been identified as the primary causes of bee species richness and abundance declines in Sweden. A comparable decline was observed in Europe (46% Bombus species), North America (50% of the 14 bumble bee species), Brazil (63%), Costa Rica (60%) and Finland (23%), China (3–13%), South Africa (29%), and Minnesota (11 stingless bees) as a result of extensive herbicide application,” the researchers state. 

Varying effects on bee species are noted, as each species can have drastically different sensitivity to different chemicals. There are approximately 4,000 native bee species in the United States and hundreds of registered pesticides, each with the potential to negatively impact multiple species. “Historical records from 382 geographical areas in the United States show that 3.5 million out of 6.0 million honey bee populations have declined, representing a 0.9% loss per year,” the authors report, which they attribute to the use of pesticides on croplands.  

Many other insects, such as Odonata (e.g., dragonflies), are also affected, which are important for pest control and mosquito management. “A previous study found that 118 aquatic insect species were threatened, with Odonata species accounting for 90%. A long-term comprehensive study found that 52 species of dragonflies and damselflies are declining in the United States, 15% of Odonata species are endangered, with two species of damselflies and dragonflies being highly vulnerable to extinction in Europe, and 57 Odonata species are declining in Japan,” the researchers specify.  

Also of concern is the increased vulnerability to diseases, pathogens, and parasites that occur with exposure to pesticides. “Research shows that extensive and consistent application of insecticides stimulates the incidence of viral diseases and pathogens among insect pollinators. For instance, honey bees that fed on a neonicotinoid– and fipronil-treated field experienced higher pathogen infestation, reducing their population,” the authors say. An additional study, previously covered by Beyond Pesticides, shows that neonicotinoids can increase parasitism from Varroa mites in honey bees.   

The rapid decline in a myriad of insect species coincides with growing agricultural production demands due to a global increase in the human population. Estimates expect the population to reach over 9.7 billion by 2050, which only exacerbates the biodiversity crisis. According to the researchers, “The average pesticide usage worldwide is estimated to be 4.4 kg/ha per year, with agriculture accounting for roughly one-fifth of the Earth’s land area. As a result, insect diversity and other ecosystem services are severely threatened.” 

Pesticide usage in recent years has seen tremendous growth. “In 2022, the total pesticides used in agriculture was 3.70 million tonnes, representing a 4% increase from 2021, a 13% increase over a decade, and a doubling since 1990,” the authors note. These pesticides, such as malathion, methamidophos, abamectin, acetamiprid, imidacloprid, and acephate, are reported to be toxic to both target and nontarget insects, while other insecticides have been found to affect bugs (e.g., sucking insects), wild bees, and moth populations without impacting the actual target pests.  

With large numbers of insects at risk, the reliance on pesticides in agriculture and land management threatens biodiversity. “Biodiversity is a key driver of ecosystem services… and thus it must be protected for current and future generations,” the authors state. Within this context, organic agriculture provides a holistic solution for enhancing and protecting biodiversity.  

Managing land with organic methods provides multiple health and environmental benefits, and studies indicate “that it can increase species richness by approximately 34% and abundance by around 50%. Organic farming promotes biodiversity by increasing the abundance and variety of plant and insect species. This, in turn, can lead to enhanced biological control, as more predators can help regulate pest populations,” the researchers conclude. (See studies here and here.) 

Promoting ecological balance and restoring biodiversity can be achieved through the elimination of petrochemical pesticides and synthetic fertilizers and with the adoption of organic practices. Studies show that organic farming has five times higher plant biodiversity and 20 times higher insect species richness compared to conventional farming and that higher biodiversity of insects is seen in fields with genetically diverse crops. 

As previously reported by Beyond Pesticides, studies upon studies upon studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. Take action to protect biodiversity and keep organic strong with a focus on the health of all organisms. 

Be part of the organic solution by becoming a member of Beyond Pesticides and stay informed with the Daily News Blog. Join the Parks for a Sustainable Future program as a Parks Advocate to transition your community to organic and make The Safer Choice to avoid hazardous home, garden, community, and food use pesticides. 

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

Source: 

Quandahor, P. et al. (2024) Effects of agricultural pesticides on decline in insect species and individual numbers, Environments. Available at: https://www.mdpi.com/2076-3298/11/8/182.

(Beyond Pesticides, September 10, 2024) Results from a natural experiment, published in Science, shows ecosystem disruption of bat populations with cascading impacts on human health. Eyal Frank, PhD, an assistant professor of the Harris School of Public Policy at the University of Chicago, links increased insecticide use in croplands in the absence of bat species to a rise in infant mortality. As Dr. Frank says in an article in Science Daily, “[B]ats do add value to society in their role as natural pesticides, and this study shows that their decline can be harmful to humans.” 

Many farmers rely on bats as alternatives to pesticides to protect their crops from insects, but White-Nose Syndrome (WNS) has greatly impacted bat populations since 2006. With the collapse of many bat populations in counties in North America, these farmers turn to toxic chemicals to replace the ecosystem services bats usually provide. These chemicals, however, lead to ripples through the ecosystem and endanger human health. 

WNS is an invasive fungus (Pseudogymnoascus destructans) found in caves that affects bats during hibernation. As highlighted in an article in the New York Times, three species of bats in North America have been decimated by this syndrome, and bats with WNS have been confirmed in 40 states and nine Canadian provinces. According to bat experts, 52% of bat species in North America are also at risk of severe declines over the next 15 years.  

Multiple crises impacting biodiversity, human health, and climate change are threatening ecological balance. Bats are one of many beneficial species that provide important ecosystem services, such as mosquito management and pollination, that are underappreciated until their services are no longer available. 

As Dr. Frank highlights in his latest study, “Bats provide biological pest control through their high population size and predation rates on a variety of insects, many of which are crop pests. Insectivorous bats consume 40% and above of their body weight in insects each night.” When fewer bats are available to remove these insects, especially ones known to damage produce and other crops, farmers are left seeking other pest control options.  

WNS has caused high mortality in bats, with rates averaging above 70%. This syndrome causes premature awakening from hibernation, which leaves bats with scarce food and low temperatures that threaten their survival over the winter. “By 2010, mortality rates of infected populations were between 30 and 99%, with a mean of 73%, characterized by rapid disease dynamics that can lead to local extinctions within 5 to 6 years,” Dr. Frank specifies. He continues, “As of 2024, 12 of the roughly 50 insectivorous bat species in the US are negatively affected by WNS.” 

To determine the impacts on human health from these population declines, Dr. Frank collected data from counties experiencing WNS regarding insecticide use and infant mortality from 2006-2017. In comparing these numbers, “after the onset of bat die-offs, farmers in the county increase their insecticide use by 31.1%, on average,” he states. “Infant mortality rates due to internal causes of death (i.e., not due to accidents or homicides) increased by 7.9%, on average, in the affected counties. This result highlights that real-world use levels of insecticides have a detrimental impact on health, even when used within regulatory limits.” These rates correspond to an additional 1,334 infant deaths which shows for every 1% increase in pesticides, there is a 0.25% increase in the infant mortality rate. 

This study calls attention to the observable and statistically significant increases in insecticide use in counties that document WNS compared to non-WNS counties, with increased infant mortality also occurring in those areas. This correlation highlights the direct agricultural and health benefits that bats provide, as these effects were not seen in the years preceding WNS detection. 

Dr. Frank also evaluates “the magnitude of the losses attributable to the decline in bat populations and estimates total agricultural losses, crop revenue, and chemical expenditure on the magnitude of $26.9 billion (2017 dollars) for the WNS-confirmed counties across the 2006-to-2017 period. To anchor this magnitude, consider that crop revenue across the entire US in 2017 alone was around $190 billion (2017 dollars).” He also estimates that the additional 1334 infant deaths during that period “reflect damages valued at $12.4 billion. Combined, these amount to damages of $39.4 billion, or $1932.20 per capita, in the WNS-confirmed counties.”  

As the Science Daily article adds, the quality of the crops during this period “likely declined, as farmers’ revenue from crop sales decreased by nearly 29 percent.” These statistics prove the loss of crucial bat populations impacts biodiversity, human health, and the economy in considerable ways. The article concludes: “‘When bats are no longer there to do their job in controlling insects, the costs to society are very large—but the cost of conserving bat populations is likely smaller,’ says [Dr.] Frank. ‘More broadly, this study shows that wildlife adds value to society, and we need to better understand that value in order to inform policies to protect them.’” 

As previously stated by Beyond Pesticides, bats, among other wildlife including birds and bees, provide important ecosystem services to farmers by helping to manage pest populations and increase plant resilience and productivity. While degradation of ecosystems is attributable to many factors, pesticide use accounts for an important element in harm to bats and biodiversity.  

Species of bats are crucial for ecosystem functioning and maintaining ecological balance. Also previously reported is the fact that they are one of the only nocturnal pollinators and the only nocturnal insect predator in the U.S., playing a key role both for plants and for farmers. Organic farmers, in particular, are reliant on bat pollinators as a pest management tool: one brown bat can kill between 3,000 and 7,000 insects per night. A study published in 2011 in Science estimated that bats provide $3.7 billion to $53 billion per year worth of pest control services to agricultural operations, and that number does not include pollination services. Bat pollination, technically known as chiropterophily, is integral for many wild and commercial tropical fruits. Over 500 plants worldwide are completely or partially dependent on bat pollination. 

Aside from the cascading effects involving bats, pesticide use, and human health, bat species can be directly impacted by harmful chemicals. In another Beyond Pesticides article, it was noted that because bats are unusually long-lived for animals their size—lifespans range from 20 to 40 years—their bodies can accumulate pesticide residues over a long period, exacerbating adverse effects associated with those pesticides that can accumulate in fatty tissue. Also, during migrations or winter hibernation (when their fat stores are metabolized), bats’ consumption of large volumes of pesticide-contaminated insects can mean that these compounds may reach toxic levels in their brains—making them more susceptible to WNS. Bats also tend to have only one offspring each year, making them vulnerable to the population impacts of negative reproductive effects caused by pesticides, because low reproductive rates require high adult survival rates to avoid population declines. 

The direct and indirect effects of pesticides on target and nontarget species are widely documented. As highlighted by Dr. Franks’ work, the loss of natural predators for managing insects has led to an increased reliance on toxic substitutes with many harmful, unintended consequences while safer alternatives exist. Organic agriculture provides land management techniques that safeguard biodiversity and the health of all organisms. 

Organic systems offer a path forward that would mitigate severe human health impacts, such as the infant mortality noted here. As the management of insects becomes increasingly important with insect-borne diseases like EEE (eastern equine encephalitis), it is vital to take action and call for safer strategies to combat these health issues.  

The organic solution provides a holistic approach with health benefits as well as environmental benefits. Keeping Organic Strong is essential to protect all organisms and the environment. Through National Organic Standards, organic integrity needs to be continuously improved upon. Tell the National Organic Standards Board (NOSB) to guide the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA) towards the best practices that support the ecosystem, mitigate climate change, and enhance human health.  

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

Source: 

Frank, E. (2024) The economic impacts of ecosystem disruptions: Costs from substituting biological pest control, Science. Available at: https://www.science.org/doi/10.1126/science.adg0344.

(Beyond Pesticides, September 9, 2024)  Comments are due by 11:59 PM EDT on September 30, 2024.

With the opening of the public comment period on organic standards that determine the integrity, strength, and growth of the organic agricultural sector, a study was released last week that shows degradation of the ecosystem linked to increased infant mortality associated with higher pesticide use by chemical-intensive farmers compensating for losses in bat populations. It is well known that bats, among other wildlife including birds and bees, provide important ecosystem services to farmers by helping to manage pest populations and increase plant resilience and productivity. While degradation of ecosystems is attributable to many factors, pesticide use accounts for an important element in harm to bats and biodiversity. The study, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes with a finding  that “insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.” Daily News will cover this study in depth in an upcoming edition. According to research published in the Journal of the Association of Environmental and Resource Economists (2022), bat population declines cost American farmers as much as $495 million annually.

Why organic matters. A major tenet of organic land management is the protection and enhancement of biodiversity. Organic as a systemic approach to environmental and human health protection is well-documented to be a productive and profitable path to averting biodiversity collapse, eliminating toxic pesticide use, and creating a sustainable future. Organic advocates stress the importance of public involvement in the deliberations of the National Organic Standards Board during the current public comment period ending September 30 to ensure that the standards are upheld and strengthened, as big agricultural interests and some within the U.S. Department of Agriculture (USDA) seek to reduce the rigor associated with the USDA organic food label. There is no other system of agricultural production that is subject to as rigorous a public standard-setting process, labeling, certification, and enforcement—while being governed by a stakeholder board composed of a majority of organic farmers, consumers, and conservationists/environmentalists. Beyond Pesticides says that the label and governing standards are only as strong as the level of public participation by those who eat organic food, practice organic land management, and/or are concerned about the elimination of all the petrochemical pesticides that contribute to existential climate, biodiversity, and health threats.

How to participate in growing the shift to organic and protecting its integrity. The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by 11:59 PM EDT on September 30, 2024. This precedes the upcoming public comment webinar on October 15 and 17 and a deliberative board hearing on October 22-24—concerning how organic food is produced.

📌 Sign up to speak at the webinar by 11:59 pm EDT on September 30. (Speaking slots are generally filled early.)
📌 Written comments can be submitted via our form below or directly through Regulations.gov.
📌 Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October. 

The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials (substances) allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health. 

>> Click here to submit your comments to the National Organic Standard Board by September 30, 11:59 pm EDT. [In addition to the issues identified, Beyond Pesticides will issue another action before the comment deadline with comments on all the issues before the board.]

The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and our NEWLY UPDATED (as of September 11, 2024) Fall 2024 issues page! 

Some priority issues for Beyond Pesticides at this meeting are: 

“Inert” ingredients used in organic production. USDA’s National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection Agency (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA.  

The Materials Subcommittee has proposed two options for addressing this problem.  

• The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling. 
   
• The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food and not adverse effects to the environment and workers, falling short of the holistic assessment required by the organic law. 

Compost regulations. The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. Beyond Pesticides supports the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a ‘de minimis’ doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.” 

Meloxicam in organic livestock. The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes to list the drug without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.”  

Beyond Pesticides opposes the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.  

>> Click here to submit your comments to the National Organic Standard Board by September 30, 11:59 pm EDT. [Beyond Pesticides will issue another action before the comment deadline with comments on all the issues before the board.]

Beyond Pesticides urges the submission of public comments to the docket on the above issues and to add a sentence or two at the beginning of the comments explaining why organic is important to each person submitting a comment! As an alternative to using the above link, for those who prefer to copy and paste comments directly to Regulations.gov, please see a copy of our comments included on Beyond Pesticides’ archive page.