(Beyond Pesticides, October 24, 2024) When U.S. Senator Cory Booker (D-NJ) introduced S. 5084, Safe School Meals Act (SSMA) in September, he identified four objectives:

1. Directing the Food and Drug Administration (FDA) to set safe limits for heavy metals in school meals. The limits will be based on a threshold of reasonable certainty of no harm to school-age children from aggregate exposure. If the agencies fail to set these limits within two years, the limits will automatically be set to non-detectable until the agencies can determine a safe level of exposure.
2. Banning glyphosate, paraquat, and organophosphate pesticide residues in school meals. Certified organic farms would automatically meet this requirement.
3. Banning PFAS, phthalates, lead, and bisphenols in food packaging in school meals.
4. Directing FDA to reevaluate food additives with known carcinogenic, reproductive, or developmental health harms, such as artificial food dyes, and ban their use in school meals prior to the completion of FDA’s analysis.

While groups like Beyond Pesticides applaud Senator Booker’s initiative to restrict exposure to some of the most hazardous toxicants, especially the most vulnerable subpopulation of children, their goal is to provide organic food to school children. In this spirit, groups have advocated that the U.S. Department of Agriculture’s National School Lunch Program procure certified organic food (see Daily News and Action of the Week). There are concerns regarding the imposition of costly monitoring and testing components that may be unfeasible and unrealistic given previous and existing failures of the U.S. Environmental Protection Agency (EPA) and FDA to fulfill their mandates. (See Daily News here, here, and here.)

Breaking Down the Bill

Advocates are concerned that legislation requiring additional monitoring and risk assessment reviews of individual classes of pesticides or individual active ingredients will run into challenges given the already glacial pace at which EPA’s Office of Pesticide Programs moves to review the latest peer-reviewed, independent scientific analysis of toxicity. For example, the Food Quality Protection Act was passed in 1996 as an amendment to both Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Food, Drug, and Cosmetic Act (FDCA) with one of the goals to regulate and review endocrine-disrupting impacts of registered and pending pesticides. Almost two decades later, EPA has failed to review and regulate, leading to public confusion over the true health impacts of pesticide exposure. See the following Action of the Week, Tell EPA That the Failed Pesticide Program Needs a New Start, for additional context.

The review process in S. 5084 would mandate that at least every five years, the Commissioner of Food and Drugs must “determine potential adjustments to the maximum permissible levels of heavy metals and toxic metalloids” in the National School Lunch Program. Similar provisions exist for other toxic materials that this legislation is intended to regulate. Permissible levels of toxic substances, be it PFAS, heavy metals, industrial chemicals, pesticides, are now calculated without consideration given to the cumulative impacts (or toxic burden) across all exposures. Ultimately, environmental and health advocates maintain that action is needed to end the “chemical soup” that defines daily exposure. In 2020, FDA acknowledged that half of food samples tested by the agency have toxic pesticide residues and one in ten samples have levels that violate legal limits established by EPA, according to the Pesticide Residue Monitoring Report. See Daily News here for an in-depth Consumer Reports analysis of pesticide residues in various common grocery store products.

S. 5084 establishes a pathway forward for acknowledging organic food production as a public good and service by expanding funding for the Organic Cost-Share Program to fully compensate farmers for certification costs, a long-term policy goal for organic advocates across the nation. However, the legislation’s creation of a category of “clean suppliers” will compete with certified organic farmers and wholesalers who now receive just a fraction of the support from the federal government relative to chemical-intensive growers, and would more likely divert federal funds spent by school districts that would otherwise source organic food.

Given the increased public interest and demand for organic, and concern over toxic pesticide exposure, advocates call for organic certified food to be the baseline criterion for eligibility under the National School Lunch Program—which is where this bill unfortunately falls short, given the urgent need to eliminate toxic petrochemical pesticide production, manufacturing, sales, and use.

Health Benefits of Organic

There are serious long-term health implications for children and youth exposed to the toxic soup of pesticide and chemical residues found in conventionally grown food. Research published in Environmental Pollution in 2022 identified children with higher levels of certain pesticide metabolites are more likely to go through early puberty. The American Academy of Pediatrics identified in a study published this year the proliferation of anti-microbial resistant infections resulting from overreliance on antibiotics in animal agriculture and how this poses potentially severe health risks for infants and children. Additionally, a 2024 study published in Environment International finds 60 biomarkers of pollutants and pesticides in hair analyses of children throughout France, which highlights the global crisis resulting from the inadequate regulation of toxic chemicals. Despite the known health impacts of pesticide exposure, Congress may end up removing two-hundred-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields depending on how Farm Bill negotiations move forward, according to an analysis by Environmental Working Group.

There are additional associated benefits for children who consume organic food. Sticking to an organic diet has reduced toxic pesticide residues in the bodies of U.S. children and adults, based on several studies published in 2019 in Environmental Health, and in two 2015 studies published in Environmental Health Perspectives and by the Center for Environmental Research and Children’s Health. A particularly noteworthy study published in 2014 in Environmental Research found that organophosphate pesticide metabolites in the urine of adults were reduced after just a week-long organic diet. A 2019 study published in Environmental Health, led by Barcelona Institute for Global Health, found that organic food consumption among children is directly associated with higher test scores, after measuring for fluid intelligence and working memory. Conversely, lower scores on fluid intelligence tests were associated with, among other factors, children’s fast-food intake.

The transition to organic food in school cafeterias is not a new topic and policy concern. In a 2004 article published in Pesticides and You, School Lunches Go Organic: Science supports growing movement, numerous examples across the nation demonstrate a pathway forward for broader adoption of organic mandates. “Stonyfield Farm has sponsored organic programs at schools in Rhode Island, California, Massachusetts, New York, New Hampshire and Connecticut,” according to the article. Additionally, the authors wrote, “An organic salad bar started at Lincoln Elementary School in Olympia, Washington has proven so popular and economically feasible, all grade schools in Olympia now have one. California school districts in Berkeley, Santa Monica, and Palo Alto also have organic food programs. In 2004, the Seattle school district adopted H61.01, Breakfast and Lunch Program Procedure, a policy banning junk food and encouraging organic food in school cafeterias.”

Call to Action

Advocates welcome the leadership of Senator Booker in pushing forward legislation that eliminates glyphosate, paraquat, and organophosphate pesticides from the National School Lunch Program, as well as the elevation of organic food production on the national stage. This is not a surprise given the Senator’s leadership in pushing forward the Protect America’s Children from Toxic Pesticides Act (PACTPA) in 2023, which also aims to address gaps in national pesticide regulation. (See here and here for Daily News articles on PACTPA). To strengthen the objectives of this proposed legislation, see this Action of the Week to tell USDA’s Food and Nutrition Service to require organic school lunches in public schools to combat the obesity and nutrition crises facing children.

Beyond Pesticides’ 41st National Forum, Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency, begins on October 30 at 2-4pm (EDT) and then continues on November 14 at 1pm (EST). The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.

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

Source: Office of Senator Cory Booker

(Beyond Pesticides, October 23, 2024) The stark contrast of two political parties emerged around this summer’s reporting of the Project 2025 blueprint—created by extreme right-wing conservatives—that proposes the gutting of environmental and public health policy and implementation. Many political observers say “Project 2025 Presidential Transition Project,” formally titled “Mandate for Leadership: The Conservative Promise,” will be embraced by a second Trump Administration, despite denials that are challenged by insiders as outright lies. While the public became aware of Project 2025 plans to gut the U.S. Environmental Protection Agency (EPA) and many other agencies, the Biden Administration was announcing the emergency ban (see also August 6 announcement), finalized yesterday, of the weed killer Dacthal, exercising an EPA authority that has not been used in 45 years since the banning of 2,4,5-T (50% of the mixture of Agent Orange). With this decision, EPA set an important precedent for proclaiming (i) an unacceptable harm, (ii) its inability to mitigate the pesticide’s hazards with typical risk mitigation measures, and (iii) the availability of alternatives that made the chemical unnecessary. In dramatic contrast, the Trump supporters behind Project 2025 are intent on politicizing science to undermine governmental structures and laws established to protect public health and the environment. The blueprint, if followed, will surely allow the existential health, biodiversity, and climate crises to spiral out of control—ensuring that a sustainable future will suffer a deadly setback, given the urgency of the crises.

Published by the conservative Heritage Foundation and 140 former Trump administration staffers, Project 2025 lays out a plan for a hypothetical second Trump administration on a range of environmental, public health, and social issues. The document has sections devoted to EPA, the U.S. Department of Agriculture (USDA), and the Department of the Interior (DOI).

If all the plans detailed in the document were to become policy, any control over pesticides, fossil fuels, industrial chemicals, metals like lead and arsenic, and carbon dioxide emissions would evaporate like volatile gases. This is not an exaggeration. Every brake on agricultural chemicals, resource extraction, and industrial pollution, including oil, gas and coal, will be removed. The document is unapologetic and deeply radical in intent. The New York Times reported that the head of the Heritage Foundation, Kevin Roberts, said, “We are in the process of the second American Revolution.”

Project 2025 alternates between aggressively hostile terms for civil servants and environmental advocates on the one hand and insincere, benevolent-sounding statements that say one thing and mean something else. The document’s overall polemic tone makes it sound as if EPA is riddled with crazy “Leftists” who have been imposing their distorted vision on the nation by wrapping all economic activity in choking ribbons of red tape and illegally incorporating attempts to cope with climate change into every policy. To anyone who has tried to convince EPA to take urgent steps to prevent and eliminate exposures to harmful chemicals—glyphosate, for example, or dicamba, chlorpyrifos, or DDT (Dacthal, for sure)—this line of rhetoric is laughable.

Project 2025 will change the definition of pollutants and hazardous chemicals, which will likely dilute actions to control, for example, perfluoroalkyl and polyfluoroalkyl compounds (PFAS), the “forever chemicals” often contained in pesticides and as flame retardants in almost everything else. See Beyond Pesticides’ analysis of a recent Environmental Health Perspectives commentary on PFAS present in the active ingredients of pesticides.  

Project 2025’s supposed concern for safe food and Americans’ health includes a call for “reform for pesticides. . .When approving pesticides, FIFRA [the Federal Insecticide, Fungicide and Rodenticide Act] allows for cost-benefit balancing, recognizing that pesticides are effective precisely because they harm pests. However, the ESA [Endangered Species Act] does not allow for any consideration of the beneficial effects of pesticides.”

In a statement regarding EPA’s Office of Pesticide Programs that George Orwell would single out as perfect Newspeak, or purposefully ambiguous and confusing language, Project 2025 asserts that pesticide manufacturers feel the program is underfunded:

Manufacturers are also willing to pay higher fees to the fee-based portion of the program. However, grower groups have been disappointed by EPA’s actions and have significant concerns about EPA’s ability to conduct science-based risk assessments and take risk management actions that appropriately balance benefits and risks as required by FIFRA.

Project 2025’s real opinion is nowhere more evident than in its treatment of science, for example in its proposal to “[s]hift responsibility for evaluating misconduct away from its Office of Scientific Integrity, which has been overseen by environmental activists, and toward an independent body.” It says EPA’s “scientific enterprise, including the ORD [Office of Research and Development], has rightly been criticized for decades as precautionary, bloated, unaccountable, closed, outcome-driven, hostile to public and legislative input, and inclined to pursue political rather than purely scientific goals.”

One of the most bizarre aspects of Project 2025’s approach to pesticides is its use of the word “transparency” regarding scientific data. Rather cryptically, the document states:

“[W]hen pesticides undergo registration review every 15 years, EPA relies on publicly available data with differing levels of quality and transparency. Data standards are needed to ensure that information relied on by EPA is made available to the agency at a similar level as the original testing data conducted by registrants to ensure that EPA can conduct a robust review and analysis of the data.”

This is code for a return to what critics call the “Censoring Science” rule, or EPA’s “Strengthening Transparency in Pivotal Science” policy proposed by then-EPA administrator Scott Pruitt in 2018 during the Trump administration. The rule was both finalized by EPA and vacated by a Montana federal judge in 2021.

The rule was an attempt by the chemical industry to repeat the ploys used by the tobacco industry, which “attacked the methodology of underlying epidemiologic research and called for the inclusion of non-peer-reviewed and industry-sponsored literature into the final assessment,” according to a powerful analysis in the Annals of the American Thoracic Society. This rule was scathingly criticized by all kinds of scientists; its effects would have been to allow non-peer reviewed literature into final reviews and bar any science that did not make its raw data public, posing severe threats to the privacy of individuals in epidemiological studies and pollution exposure surveys.  The Washington Post explains that the rule would “actually restrict the EPA from using some of the most consequential research on human subjects because it often includes confidential medical records and other proprietary data that cannot be released because of privacy concerns.” Restoration of the policy is the real goal of the “transparency” language.

Project 2025’s hypocrisy is staggering. The document attacks the present policies and staff of EPA and USDA. It claims EPA is riddled with “politically connected” and “embedded” activists, pushing “vendetta-driven enforcement,” using “fear-based rhetoric” about climate change, which is a “favored tool that the Left uses to scare the American public into accepting their ineffective, liberty-crushing regulations, diminished private property rights, and exorbitant costs.”

The document repeatedly complains about bureaucratic delays, too many confusing and far-flung offices, and the injection of political motives into what it says it values—pure science. Yet Project 2025 recommends placing political appointees in almost every office of EPA. As to the agency’s risk management policy, Project 2025 states that “each office will need a political chief of staff, senior advisers designated to run suboffices, and energized assistants. Teams should be balanced with technical knowledge, legal expertise, and political exposure.”

It further proposes to centralize authority in such a way as to give all control to appointees with explicit political skills rather than to experienced technical and scientific experts. It will:

“Appoint and empower a Science Adviser reporting directly to the Administrator in addition to a substantial investment (no fewer than six senior political appointees) charged with overseeing and reforming EPA research and science activities. Qualifications for these positions should emphasize management, oversight, and execution skills (including in leading state environmental agencies) as opposed to personal scientific output.”

In other words, Project 2025 will make EPA even more politicized and less scientifically sound than it is now.

Regarding USDA, Project 2025 has less to say about specific chemical or pesticide policies, but advocates shrinking the agency and removing its authority to regulate wetlands associated with farmland. It accuses USDA of trying to force farmers to adopt organic practices and of placing “ancillary issues like climate change ahead of food productivity and affordability.” It will eliminate USDA dietary guidelines. Regarding genetic engineering, Project 2025 will repeal the federal labeling law.

In the Department of the Interior (DOI), Project 2025’s environmental agenda is to open up all land everywhere to fossil fuel exploitation: “[N]o other initiative is as important for the DOI under a conservative President than the restoration of the department’s historic role managing the nation’s vast storehouse of hydrocarbons, much of which is yet to be discovered.” The document also takes aim at the Endangered Species Act and calls the National Environmental Policy Act (NEPA) a “tree-killing, project-dooming, decade-spanning monstrosity.” Project 2025 will eliminate NEPA’s authority to consider the cumulative impacts of multiple stressors from weather disasters to chemical exposures to social determinants of health, roll back lead regulations, and gut numerous other helpful EPA programs. 

The problem with this sweeping, agency-by-agency approach is that issues like health effects from exposure to pesticides, industrial chemicals, toxic metals, and their legacy residues permeate all life, and have relevance in every activity from the military to fish farming. Acknowledging their harms and eliminating their use to the greatest extent possible with replacement practices and products would be the fastest way to accomplish true health and safety for everyone. Instead, Project 2025 proposes to simply open the floodgates to an expansion of all these kinds of pollution beyond anything previously experienced.

There are many aspects of environmental regulation in the U.S. that are far from perfect, but EPA, USDA, DOI, and other agencies beat the alternative of no regulation whatsoever. Some of the “reforms” in Project 2025 could actually improve regulatory function by reducing the time it takes for an agency to make a decision, to clarify murky rules, arrive at equitable specifics, and so on. But much of the delay and murkiness result from industry influence in the decision-making process, not from “radical” environmentalists. See Beyond Pesticides’ 2023 Daily News  for further analysis of conflicts of interest in chemicals regulation and our 2021 Daily News regarding 37 environmental groups’ letter to EPA demanding reform of the Office of Pesticide Programs. An award-winning 2021 report by Sharon Lerner in The Intercept, “The Department of Yes: How Pesticide Companies Corrupted the EPA and Poisoned America” reveals industry’s meddling in granular detail.

In another ironic twist, there is good evidence that most Americans actually approve of environmental regulations; Mongabay reports on a new survey showing that support for wildlife conservation and the environment among American adults has risen from 80 percent in 2020 to 87 percent this year. In particular, 82 percent of Republicans say this value is part of their voting decision this year compared to 68 percent in 2020—a 14-point jump in four years. This suggests that Project 2025’s obsession with dismantling environmental protections is misplaced and out of sync with the public, since the document proposes to remove conservation protections—one of conservatives’ favorite environmental values—by delisting the grizzly bear and the gray wolf under the Endangered Species Act and giving states control over the greater sage grouse.

The environmental sections of Project 2025 constitute a very clear authoritarian agenda laying out the intention to entirely dismantle environmental policy in the United States. In a most-likely insincere rhetorical ploy, the document claims to want to preserve the federal agencies most involved with environmental health, agriculture and conservation. But this is disingenuous. The intended method is to impose something like the process of fossilization: when an organism fossilizes, its biological tissues are replaced by minerals in the exact configuration of the original, so the structure looks the same, but the function is destroyed. This is what Project 2025 aims to do: not to “drown [the government] in the bathtub” and totally dismantle the agencies, but to keep their shells visible while it hands our entire environment over to industry and corrupt politicians.

Throughout the document, Project 2025 pits private property and states’ rights against all the federal agencies’ efforts to clean up past environmental degradation caused by economic activities and to protect the health of American citizens from ongoing and combined threats. While property ownership is a basic right guaranteed by the U.S. Constitution, it is not an appropriate standard by which environmental issues should be assessed, because it completely disregards the basic facts of how ecosystems work. The truth is that Earth’s surface is mostly fluid—air and water—and anything that gets into either can and often does move far beyond political boundaries, following instead wind patterns, river drainages, temperature gradients, and many other dynamics of Earth’s systems.

The most striking proof of this is climate change, mitigation of which Project 2025 means to abandon altogether. The integration of the biosphere means that what happens in a field in Iowa, or a mine in Nevada, or a pesticide plant in Louisiana, does not necessarily stay there, so leaving environmental decisions entirely to individuals, states, or a second Trump administration will result in exactly the kind of devastation the nation experienced before there were any regulations at all. This would be a tragedy—just when we are attempting to correct our previous mistakes in time to save ourselves.

Sources:

Mandate for Leadership: The Conservative Promise (Project 2025)
The Heritage Foundation 2023
https://static.project2025.org/2025_MandateForLeadership_FULL.pdf

Science on “Forever Chemicals” (PFAS) as Pesticide Ingredients and Contaminants Documented
Beyond Pesticides, July 31, 2024
https://beyondpesticides.org/dailynewsblog/2024/07/science-on-forever-chemicals-pfas-as-pesticide-ingredients-and-contaminants-supports-need-for-immediate-action-to-end-their-use/

Int’l Group of Scientists Calls for Restraints on Conflicts of Interest in Publications and Regulation
Beyond Pesticides
December 15, 2023

Int’l Group of Scientists Calls for Restraints on Conflicts of Interest in Publications and Regulation

Groups Tell EPA’s Pesticide Program It’s a Failure, Call for Immediate Reforms
Beyond Pesticides, October 26, 2021
https://beyondpesticides.org/dailynewsblog/2021/10/groups-tell-epas-pesticide-program-its-a-failure-calls-for-immediate-reforms/

Project 2025 Means More Toxic Chemicals. We’ll Fight Back.
Earthjustice
September 24, 2024
https://earthjustice.org/article/project-2025-means-more-toxic-chemicals-well-fight-back

Project 2025 Would Make It Easier for Big Corporations To Dump Dangerous Toxins That Poison Americans
Center for American Progress
August 7, 2024
https://www.americanprogress.org/article/project-2025-would-make-it-easier-for-big-corporations-to-dump-dangerous-toxins-that-poison-americans/

Project 2025 Plan for Trump Presidency Has Far-Reaching Threats to Science
Scientific American
July 19, 2024
https://www.scientificamerican.com/article/project-2025-plan-for-trump-presidency-has-far-reaching-threats-to-science/

(Beyond Pesticides, October 22, 2024) A recent study, published through the American Chemical Society, analyzes pesticide contamination in riparian soil and plants as a result of flooding from streams in Germany. The authors hypothesize, and then prove, that frequently flooded sites have higher levels of pesticides present due to the pesticides in surface waters contaminating the soil. Results show that the plant vegetation in the contaminated soil then takes up the pesticides, which bioaccumulate and lead to higher contamination that can further cascade throughout the ecosystem and affect terrestrial food webs.

“[O]ur study provides evidence from the field that nontarget plant species typical for riparian stream sites receive considerable pesticide exposure via flooding events,” the authors share. This exposure, and subsequent bioaccumulation in plants, threatens the food web, as many riparian plants are a vital food source for insects.

According to the authors, flooding events, and their impact on pesticide contamination within soil and plants, are rarely investigated. This study, “measur[ing] 98 pesticides and metabolites in plants and root-zone soils sampled at five streams situated in an area in Southwest Germany characterized by intensive agricultural land use,” highlights the differences in contamination between frequently flooded and rarely flooded areas and the greater impacts on the environment and resident organisms.

At each of the five streams in the Upper Rhine Valley, samples were collected from paired sites with different flooding frequencies. Regularly flooded sites are closer to each stream’s usual water level while rarely flooded sites are more elevated. Samples of the plant vegetation and soil were collected during October 2022, while the water-level data utilized was for the year prior to sampling (October 2021 – October 2022). The water-level data, from the Agency for the Environment in Rhineland-Palatinate, provides data on the frequency of site flooding, permitting the authors to calculate the average flooded days per year for each sampling site.

The vegetation collected at each site includes “five plant species typical for riparian sites, namely, stinging nettle (Urtica dioica), blackberry (Rubus sect. Rubus), ivy (Hedera helix), ground ivy (Glechoma hederacea), and alder (Alnus glutinosa),” the authors state. The soil attached to the roots of the collected plants was also used as root-zone soil samples. All samples of plant material and soil were freeze-dried before being filtered and analyzed using liquid chromatography and mass spectrometry techniques.

In analyzing the amount of pesticide contamination within the samples, the authors find that the regularly flooded sites were flooded at a frequency that was 10 times higher than the rarely flooded sites and exhibit not only higher concentrations of individual pesticides but also a higher number of pesticides present.   

Of the 98 pesticides and metabolites screened, 33 are quantified in plant material from regularly flooded sites while 27 pesticides are detected in the rarely flooded site samples. At the regularly flooded site, up to 17 individual pesticides are found in a single plant sample. Within the soil from the regularly flooded sites, 39 pesticides are detected while the soil from rarely flooded sites shows only 25 pesticides present.

“The average pesticide concentration over all 98 compounds was up to 3 times higher at regularly flooded sites compared to rarely flooded sites in both soil and plants,” the authors report. In just the soil of the regularly flooded sites, about 10 times higher average pesticide concentrations are seen than in the soil of the rarely flooded sites. “Our results suggest a pathway for pesticides via flooding from the aquatic system to the terrestrial soil,” the authors conclude.

Nine pesticides are detected at high frequencies in both the soil and plants of the regularly flooded sites, including the fungicides cyflufenamid, fluopyram, metrafenone, spiroxamine, boscalid, and azoxystrobin, and the herbicides prosulfocarb, flufenacet, and pendimethalin. Of the nine pesticides, the six fungicides are detected more frequently and with higher concentrations in the soil than the three herbicides while the opposite is seen in plant material. “All of these pesticides are regularly detected in surface waters of the area,” the authors say, which “represent a usual contamination profile driven by flooding events.”

Within the plants from the regularly flooded sites, pesticide concentrations are more than twice as high as those in rarely flooded sites. According to the authors, “Four out of the nine pesticides (cyflufenamid, prosulfocarb, flufenacet, and pendimethalin) were generally detected at higher mean concentrations in plant material compared to soil material,” which highlights bioaccumulation within plant tissue.

In analyzing the different parts of the plants, the study finds that the leaves contain the highest average pesticide concentration. Higher levels are also observed in woody plants, such as the alder and blackberry, when compared to herbaceous plants. To explain these differences, the authors state, “It has been suggested that the lipid content of the roots, evapotranspiration rates, and other physiological factors influence the species-specific contamination profile.” This indicates that some species, and even parts of the plants within all species, are more likely to have contaminants present. (See studies here, here, and here.)   

Contamination of nontarget plants through flooding can greatly impact the species present, but also threaten the herbivores that feed on them as well. The five species included in this study provide a food source for many organisms, such as various butterflies, moths, and beetles. “The results of the present study indicate that different ecological niches within the same (micro)habitat are exposed to different concentrations of the same compound, posing different threats to taxa occupying these different ecological niches,” the authors highlight.

With the pattern of higher frequency and concentrations of pesticides at the regularly flooded sites, present in both plants and root-zone soil, it suggests that flooding is a vector for the aquatic−terrestrial transport of contamination in small streams. “Our study provides evidence from the field that flooding events, which may increase due to climate change, can transport pesticides to riparian soils and plants with potential cascading effects on terrestrial food webs,” the authors state.

Bioaccumulation and biomagnification of pesticides has been documented as a threat to biodiversity. As the authors point out, “[E]ven low pesticide concentrations at the base of the food web may translate via biomagnification to increased levels at higher trophic levels of the food chain, leading to cascading effects.” They continue in summarizing, “The transfer of flood-driven contaminants from water to land can result in their accumulation in the soil, and thus enter the food web via plant absorption potentially triggering bottom-up effects at higher trophic levels of the terrestrial food web.”

The authors demonstrate how surface waters, which are often polluted with chemicals such as those used in agriculture, can transport contamination back into adjacent terrestrial ecosystems. One study, that followed the extreme flooding of the rivers Elbe and Vltava in August 2002, finds similar results of a 10-fold increase in concentration of pesticides in flooded soil compared to that in nonflooded soil. Another study corroborates the higher concentrations of pesticides within plants due to the soil-to-plant uptake for various nontarget plant species, including the stinging nettle.

Riparian soil can act as a pesticide sink and is a potential source for contaminated plants in those areas that can lead to implications for the entire terrestrial food web. This study highlights the importance of the “widespread distribution of small surface waters in agriculturally dominated areas and the predicted increases in flooding events due to climate change” that can impact riparian zones but also calls for additional studies and analyses on the widespread impacts of flooding.

The runoff of pesticides from agricultural land into surface waters is well documented and continues to be a concern not only in Germany but across the globe. (See previous coverage of pesticides in rivers and streams in the United States here.) This contamination not only threatens aquatic life but terrestrial organisms, as shown by the authors’ results. The only solution to prevention of this harmful contamination that can impact all species including humans is the elimination of the source pesticides, according to environmental and public advocates. Chemical-intensive agriculture relies on petrochemical pesticides and synthetic fertilizers, but a safer alternative via organic agriculture exists.

With organic land management, the threats to biodiversity and climate change are mitigated. In adopting organic standards, which are continuously improved upon through the National Organic Standards Board (NOSB), less harmful chemicals will pollute waterways and be able to impact not only human health but the health of all organisms and the environment.

Learn more about transitioning your community to organic land management, as well as how to make The Safer Choice within your home. The Daily News Blog provides the latest information on pesticide policies and science, and you can sign up for Action of the Week and Weekly News Updates here to stay engaged and informed. Play a part in the organic solution and join Beyond Pesticides as a member today.

On the necessity, viability, productivity, and profitability of organic land management, attend the 41^st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.

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

Source:

Fiolka, F. et al. (2024) Flooding as a Vector for the Transport of Pesticides from Streams to Riparian Plants, American Chemical Society ES&T Water. Available at: https://pubs.acs.org/doi/abs/10.1021/acsestwater.4c00571.

(Beyond Pesticides, October 21, 2024) To solve the existential crises of climate change, biodiversity loss, and human disease, Beyond Pesticides is urging that organic agriculture grows—over the next decade becoming universally adopted for all agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic.

The OCCSP will disappear in 2025 unless Congress passes a five-year Farm Bill with funding or includes sufficient funding in a stopgap bill this fall.

Chemical-intensive agriculture, with its dependence on petrochemical pesticides and fertilizers, is a major contributor to the existential health and environmental crises and contamination of air, land, and water. Organic agriculture, certified and labeled in compliance with the Organic Foods Production Act (OFPA) provides:

• A definition of organic agriculture that defines health-biodiversity-climate friendly practices;
• A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests;
• A rigorous process for an allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
• A third-party certification and enforcement system;
• A process for public participation to ensure a feedback loop for continuous improvement; and,
• Funding to ensure elements are carried out in a robust way.

>> Tell Congress to ensure that organic programs, and their funding, do not lapse this fall.

While environmental and public health advocates say it is essential for organic to grow to solve the existential health, biodiversity, and climate crises, Beyond Pesticides, at the same time, advocates for continuous improvement of organic standards. Both statements before the National Organic Standards Board (NOSB), October 15, 2024, of Jay Feldman, executive director, and Terry Shistar, PhD, board member, of Beyond Pesticides are below.

[Beyond Pesticides thanks all those who participated in the public comment period before the NOSB by submitting comments through Beyond Pesticides’ Keep Organic Strong program.]

Statement of Jay Feldman:
The NOSB was established to protect and enhance the integrity of the organic label. integrity is operationalized through continuous improvement, which is key to the sunset process for synthetic materials on the National List of Allowed and Prohibited Substances AND through your oversight of USDA’s National Organic Program.

It is in this spirit that we offer our extensive written comments.

We look to organic to lead the shift away from petrochemical pesticides and fertilizers with urgency—to confront the existential health, biodiversity, and climate crises of the day. We don’t want cancer in our families or the long list of pesticide-induced illnesses associated with chemicals used in chemical-intensive agriculture—chemicals that end up in our air, water, soil, and food.

However, this shift will only happen if we as an organic community and an organic marketplace move quickly and forcefully to differentiate organic from all the destructive agricultural practices that contribute to the existential crises.

It wasn’t hard to predict that PFAS would end up contaminating farmland. Same for DDT. Contaminated biosolid fertilizer is a cheap waste product, but the externalities of cleanup and remediation, if that is even possible, are certainly not cheap. Neither is the treatment of resulting illnesses and environmental disasters. We had the foresight to prohibit biosolids in organic production.

Of course, the problem extends beyond biosolids to compost. We urge the NOSB to reopen the workplan item on contaminated inputs that is currently on hold after the issuance of a 2014 document on the issue—when I was on the NOSB.

But first, we must not further weaken the standard or exacerbate the problem. As important as compost is to organic, only synthetic materials that are specifically added to the National List should be allowed in compost. More persistent contaminants in “compost feedstocks” will certainly be found. The petition from BPI should be denied. Thank you Crops Subcommittee for recommending against and rejecting some notion of a de minimis or negligible risk assumption foreign to OFPA.

With this same thinking, organic must lead on eliminating plastics. Plastic Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. Make the elimination of plastic in organic a research priority.

And, we must push harder to replace nonorganic ingredients more broadly like the proposals to delist dried orange pulp, which is available in organic form.

And, Organic seeds and starts must become a priority, given their limited availability. 

Thank you.

Statement of Terry Shistar, PhD:
We are focused on three intertwined existential crises in which pesticides play a role:[1] Climate change, human illness, and biodiversity decline.

I will make six points:

1. Organic practices can and should play a major role in addressing all of these:

• Organic practices can mitigate climate change.
• The Organic Foods Production Act (OFPA) provides a framework for eliminating toxic chemicals in organic production and processing.
• Protecting biodiversity is central to the NOP definition of “organic production.”

Some challenges remain before organic can be the answer.

2. Organic production can mitigate climate change only if it is soil-based because soil-building practices help sequester carbon in the soil. The NOSB must take a strong stance against hydroponic and container systems that do not build soil biology.[2]

3. Although the NOSB does a good job of keeping toxic active ingredients out of organic production, the so-called “inert” ingredients make up the largest part of formulations and pose greater risks.

4. The Materials Subcommittee has proposed two alternatives [at link, search on “inert ingredients”]—one of which would address this problem and another that would not. The NOSB should recommend only Option 1, which meets the requirements of OFPA, and not forward the recommendation for Option 2 to NOP. Option 1 relies on EPA’s decision that residues in food do not pose a risk and ignores risks to farmworkers and the environment. [See “Inert” Ingredients Used in Organic Production.]

5. Another avenue through which toxic chemicals can enter organic food—and by which organic processing fails to promote the health and environmental precepts of organic—is the allowance of non-organic ingredients through listing on §606. There is no reason that organic production cannot meet the needs for these ingredients—if processors are not allowed to use cheaper nonorganic ingredients. Besides removing potential toxic exposures to consumers, elimination of these nonorganic ingredients would avoid the support of chemical-intensive agriculture through their use in organic products.

The NOSB should also work towards elimination of toxic chemicals—such as plastics, PFAS, and bisphenols—in food packaging.

6. The NOSB has made strides towards protecting biodiversity in materials reviews and policies, but needs to address:

• Implementation of biodiversity and marine materials policies
• Phasing out the use of plastics

Thank you.

Letter to the U.S. Congress:
Now that the Farm Bill and its extension have expired on September 30, I am reaching out because I am concerned about gaps in funding for programs that are essential for organic farms and businesses.

To solve the existential crises of climate change, biodiversity loss, and human disease, it is critical that organic agriculture grow—eventually becoming the standard for agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic.

Organic agriculture also promotes economic growth by creating market opportunities for farmers, while supporting rural development through practices that protect natural resources and boost community resilience. I am writing to urge you to pass a five-year Farm Bill before the end of this year. I support the Farm Bill framework put forward by Senate Agriculture Committee Chairwoman Stabenow, which provides funding for essential organic programs and provides a foundation so organic agriculture can thrive. However, as this proposal moves forward, do not accept any legislative language that limit pesticide restrictions and the right to sue chemical manufacturers and allied users of pesticides when harmed.

If Congress does not renew the five-year Farm Bill, it is imperative that the Farm Bill extension include funding for the Organic Certification Cost Share Program (OCCSP). This essential program provides a partial reimbursement to defray the cost of organic certification. 

The cost of certification is one of the biggest challenges faced by organic farmers. Without Congressional action, this program will expire, leaving thousands of organic farmers with a huge net increase in their annual certification costs. A lapse or reduction in funding, will have a big impact on farmers’ ability to stay certified, and would come at a time when most operations are seeing significant increases in certification costs to keep up with inflation and new requirements to strengthen enforcement of organic rules.

Level funding of $8 million, as was provided last year, is no longer enough funding and would result in cuts to this essential program! The cost of the program has risen due to increasing certification costs and as more operations are getting certified. Congress needs to provide at least $11 million for the OCCSP in the Farm Bill extension (or through an ad hoc emergency assistance package).

In addition to the Organic Certification Cost Share Program, please include provisions to reauthorize the Organic Agriculture Research and Extension Program (OREI), and fund the Organic Data Initiative and the Organic Certification Trade and Tracking Program (OCTT), which is necessary for organic fraud prevention activities. Like the OCCSP, the Organic Data Initiative and the Organic Certification Trade and Tracking Program are ‘orphan’ programs. Essential funding for these programs will lapse with devastating consequences unless there is Congressional action.

Please make sure organic programs do not lapse this fall.

Thank you.

On the necessity, viability, productivity, and profitability of organic land management, click here to register to attend the 41^st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.

[1] Graphs from: https://www.climate.gov/news-features/understanding-climate/climate-change-global-temperature; https://gco.iarc.fr/overtime/en/dataviz/trends?populations=840&sexes=1_2&types=0&multiple_populations=0&cancers=0_14&mode=cancer&multiple_cancers=1; https://www.ipbes.net/news/global-assessment-summary-policymakers-final-version-now-available

[2] Picture from: https://beyondpesticides.org/dailynewsblog/2024/08/study-documents-value-of-soil-microbiome-nurtured-in-organic-farming-harmed-by-chemical-intensive-ag/

(Beyond Pesticides, October 18, 2024) On October 30 at 2:00pm (eastern time, U.S.), Beyond Pesticides convenes the first session (virtual) of its 41^st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency. The Forum provides an opportunity to discuss with world-renowned scientists, from Germany and the United States, both (i) the hazards that define the urgency of threats associated petrochemical toxicants, with a focus on chemicals that disrupt the endocrine system (including pesticides) and lead to life-threatening diseases, and (ii) the strategy for adopting a path forward that tackles the problem holistically, rather than one chemical at a time.

What’s Happening on October 30 at 2:00pm (eastern time US)?

An opportunity: Meet Felix Löwenstein, PhD, author of Food Crash: Why Organic Is the Only Way Forward, just released in the United States. 

• Focus: Adopt a holistic worldwide strategy to reverse the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.
   
• Vision: Explore Dr. Löwenstein’s passion, grown from his life as an agricultural scientist, farmer, international agricultural aid worker, and leader in Germany’s association of organic food producers and organic research. 

• Mandate: Delve into the compelling facts about the adverse impacts of chemical-intensive agriculture on ecological and human health, food sovereignty, and animal welfare—and the viability, productivity, and profitability of the sustainable alternative now! 

. . . And on November 14, at 1:00pm (eastern time US)?

An opportunity: Meet Tracey Woodruff, PhD, MPH, director of the Program on Reproductive Health and the Environment, School of Medicine, at the University of California San Francisco.

• Focus: Elevate understanding that links the deadly and debilitating effects of endocrine disrupting toxicants, including pesticides, plastics, and a wide range of manufactured products, to fossil fuels and the compelling science to support action. 

• Vision: Explore the clinical effects and inequities associated with dependency on the range of endocrine disruptors, as Dr. Woodruff calls for decarbonizing the economy with a precautionary standard. 

• Mandate: Apply scientific findings and uncertainties to policies and practices to address threats associated with serious health effects, biodiversity decline, and the climate crisis. 

ABOUT THE PROGRAM
The Forum will address the increasing understanding that the world faces existential threats to health, biodiversity, and climate for which petrochemical-based pesticides and fertilizers, among other products, are major contributors—at the same time that solutions are currently available and operational. The threats are real and scientifically defined, and so are the solutions. The goal of the Forum is to contribute to the adoption of a holistic worldwide strategy to reverse the existential crises in the production of our food and the management of land and ecosystems.

The convenors explain that the 41st National Forum, Imperatives for a Sustainable Future, offers us an opportunity to elevate our understanding of the petrochemical threats and the critical need to adopt practices and policies that eliminate one of the major sources of the problem, petrochemical pesticides and fertilizers. Among the significant changes that will be discussed is the need for an accelerated transition to organic land management, from agriculture, landscapes to playing fields, as part of a holistic strategy that recognizes the multidimensional nature of the problem and solution.

A focus of the Forum is what Beyond Pesticides describes as two major imperatives for sustainability and a livable future that require community and decision maker understanding of and action on:

1. The threats to human health and ecosystems and the dire consequences of inaction or measures that fall far short of what is necessary; and
2. The path forward to eliminate reliance on petrochemical-based products, including the constellation of toxic materials associated with chemical-intensive practices—from food production to the management of homes, gardens, parks, and schools.

Session 1: October 30, 2024, 2:00 PM (Eastern time US)  

Felix zu Löwenstein, PhD
The Forum Series begins with an agronomist who has been farming organically on his family farm in Germany since the 1990’s, bringing a wealth of hands-on experience that informs the technical information that transformational change requires. In Dr. Löwenstein’s book, Food Crash: Why Organic Is the Only Way Forward, just released in the United States, the case is made that organic land management with “ecological intensification” provides society with a social good, as opposed to chemical-intensive (conventional) practices that have externalized health and environmental costs. The book’s thesis on the organic imperative is rooted in the facts about the adverse impacts of chemical-intensive industrial agriculture on human health, food sovereignty, the environment, animal welfare, soil erosion, and soil health.  

With it being widely understood that reducing greenhouse gases must be accompanied by the drawdown of atmospheric carbon, the author explains the importance of eliminating petrochemical pesticides and fertilizers, and the essential role of soil in sequestering carbon. The history of the failed Green Revolution and continuing efforts of multinational chemical/seed companies to advance monoculture farming systems, genetically engineered seeds, and dependency on synthetic fertilizers is juxtaposed with the success of diversified organic production practices, which utilize on-farm composting, the natural cycling of nutrients, and rotations with leguminous plants such as clover, alfalfa, and beans. Most importantly, Dr. Löwenstein is focused on “What To Do,” taking urgent action with at least three objectives: (1) require cost of harm to be internalized to the polluter, (2) incentivize organic production and consumption with tax policy, and (3) elevate consumer knowledge and awareness about the personal and societal benefits of organic. 

Dr. Löwenstein’s passion for organic transition has grown from his life as an agricultural scientist, farmer, international agricultural aid worker, and leader in Germany’s association of organic food producers and organic research. 

Session 2: November 14, 2024, 1:00 PM (Eastern time US)

Tracey Woodruff, PhD, MPH 
The conversation continues with the Alison S. Carlson Endowed Professor in the Department of Obstetrics, Gynecology, and Reproductive Sciences and the director of the Program on Reproductive Health and the Environment, School of Medicine, at the University of California San Francisco. Dr. Woodruff’s work focuses on uncovering and addressing environmental determinants of disease and health inequities and has written groundbreaking material on endocrine disrupting chemicals. 

Dr. Woodruff’s research studies the harmful effects of chemicals and pollutants on health, pregnancy, and child development. She leads efforts to translate scientific information into actionable change in the clinic environment and through public policy. Previously, she has served as a senior scientist and policy advisor for the U.S. Environmental Protection Agency’s Office of Policy.  

In a recent piece in The New England Journal of Medicine, Health Effects of Fossil Fuel–Derived Endocrine Disruptors, Dr. Woodruff highlights the urgent need to address the widespread chemical pollution stemming from the petrochemical industry, underscoring the dire implications for public health. She emphatically states, “We need to recognize the very real harm that petrochemicals are having on people’s health. Many of these fossil-fuel-based chemicals are endocrine disruptors, meaning they interfere with hormonal systems, and they are part of the disturbing rise in disease.”   

Petrochemical exposure through air, water, food, and land is increasing and the health problems induced by endocrine disruptors require broader understanding among health care professionals and a more robust regulatory response, with recognition of disproportionate harm to people of color communities. In raising these issues, Dr. Woodruff is sounding the alarm to decarbonize and detoxify our economy with a precautionary approach.

To register for the Forum, Click here or go to bp-dc.org/2024-national-forum. Click here to access last year’s Forum webpage (and Daily News post)!

Beyond Pesticides (October 17, 2024) On September 30, 2024, the U.S. Environmental Protection Agency (EPA) opened a public comment period about production of specific per- and polyfluoroalkyl substances (PFAS, also known as ‘forever chemicals’)—including perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), and perfluorodecanoic acid (PFDA). EPA is collecting information on the fluorination process of high-density polyethylene (HDPE) and other plastic containers to inform possible regulatory action under the Toxic Substances Control Act (TSCA). The deadline for submitting comments is November 29, 2024.

PFOA and twelve other PFAS compounds are created during the fluorination of HDPE plastic containers by Inhance Technologies, LLC, the only U.S. company manufacturing containers using this fluorination technique (see here). Studies by EPA, independent researchers, and the company itself demonstrate that PFAS leaches from container walls into contents, exposing millions to these toxic chemicals without their knowledge. EPA notes, “Long-chain PFAS like PFOA, PFNA, and PFDA build up in our bodies and the environment over time. Even small amounts can significantly contribute to people’s long-term exposure and health risk for cancers, impacts to the liver and heart, and immune and developmental damage to infants and children.”

The adverse effects of PFAS exposure are linked to serious health issues, including cancer, reproductive disorders, and immune system dysfunction. Factory and farmworkers, due to cumulative exposure, and vulnerable groups exposed to HDPE products, face heightened risks. Leaching affects a broad range of household and daily-use products, from pesticides to food, cosmetics, and cleaning supplies, presenting risks through ingestion, inhalation, and skin contact. In addition, cumulative exposure to PFAS emerges from multiple sources in daily life. In recent years, EPA has acknowledged this critical issue; in April 2024, the agency’s first-ever enforceable drinking water standards for PFAS, “National Primary Drinking Water Regulation” (NPDWR) included PFOA and PFNA and designated PFOA as one of the first two hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as Superfund). 

PFAS contamination from Inhance Technologies manufactured plastic containers

 EPA has been involved in the PFAS tragedy revolving around Inhance Technologies’ plastic container manufacturing process since the agency was notified by Public Employees for Environmental Responsibility (PEER) in September 2020. In April 2024, a coalition of environmental and public health organizations, including PEER, filed a TSCA Section 21 petition, urging EPA to immediately halt the production of plastic containers with PFAS levels that leach into consumer products and the environment. The petition calls on the agency to use its TSCA Section 6 authority to ban the production of PFOA, PFNA, and PFDA produced as a result of Inhance’s fluorination process. EPA approved this petition on July 10, 2024, and is now calling for public comments to inform EPA’s response.

In the petition, PEER highlights that the U.S. Court of Appeals for the Fifth Circuit, as referenced later in this post, acknowledges EPA’s authority to regulate the fluorination process that generates PFAS under TSCA’s Section 6. This provision mandates that when EPA identifies a chemical as posing an “unreasonable risk of injury to health or the environment,” it must take necessary measures to mitigate that risk. This is precisely the action sought by the petitioners.

“The Toxic Substances Control Act allows EPA to issue an immediately effective rule to prohibit or limit any chemical process determined to present an unreasonable risk of injury if serious or widespread injury is likely before completion of the rulemaking process,” said Bob Sussman, principal in Sussman and Associates, former senior EPA official in the Obama Administration, and legal advisor to the Center for Environmental Health, one of the petitioners with PEER. “EPA has all the evidence it needs to justify this action and should not allow Inhance to continue to expose Americans to dangerous PFAS one day longer than necessary,” Mr. Sussman continued.

In fact, EPA did previously take such decisive action, however, the decision was consequently reversed by the judiciary. On December 1, 2023, EPA issued stop orders to Inhance Technologies, LLC, mandating the cessation of PFAS production, which occurs during the fluorination process of the company’s HDPE plastic containers. In December 2022, Inhance submitted Significant New Use Notices (SNUN) for nine PFAS chemicals, including PFOA, PFNA, and PFDA. Following its review, EPA determined that these three PFAS chemicals pose serious health risks, requiring prohibition to prevent harm. Consequently, under TSCA Section 5(f), the agency banned further production of PFOA, PFNA, and PFDA resulting from HDPE fluorination.

In response, Inhance challenged EPA’s orders, resulting in a March 21, 2024, ruling by the U.S. Court of Appeals for the Fifth Circuit to vacate the agency’s decision. The court found that EPA had exceeded its authority by using TSCA Section 5 instead of Section 6, as Inhance’s decades-old fluorination process does not constitute a “significant new use.” Inhance argued that the process was not new due to its long-standing implementation, while the EPA contended that the lack of prior disclosure rendered it a significant new use. The court emphasized that this ruling does not restrict the EPA from regulating Inhance’s fluorination process under TSCA Section 6, provided it follows the procedural guidelines. The Fifth Circuit decision did note that if EPA were to pursue another approach (Section 6) under TSCA, the agency must “weigh the costs to businesses and the overall economy before shutting down an ongoing manufacturing process.” Public health advocates say that this starkly underscores the limitations of federal law in protecting public health in the face of corporate interests and profits. (See here).

PFAS contamination also found in pesticides

The Center for Food Safety—joined by environmental, farm, and grassroots organizations including Beyond Pesticides—submitted a groundbreaking petition to EPA in July 2024, urging immediate action to address PFAS in pesticides and pesticide containers. Numerous studies have shown that the broad use of PFAS chemicals, and the resulting environmental contamination, has devastating impacts on public health, wildlife, and pollinators. Despite acknowledging PFAS as an urgent public health and environmental issue, EPA has upheld hundreds of registrations of pesticide ingredients that fall into the PFAS category. (See here to take action).

As the situation evolves, environmental and public health advocates are continuing to pay close attention, given EPA’s recent history of testing for PFAS in pesticides from HDPE container contamination. In May 2024, PEER filed a complaint asserting that EPA issued misleading statements in falsely claiming that recent tests found no detectable per- and polyfluoroalkyl substances (PFAS) in pesticides (see here). PEER’s administrative complaint calls for the EPA to retract a 2023 research memo and press release, alleging these publications violated the agency’s standards for scientific quality and accuracy. In late 2022, research published in the Journal of Hazardous Materials Letters identified significant PFAS levels in widely used pesticides, contradicting EPA’s previous assurances that registered pesticides do not contain PFAS (see here). However, in the aforementioned  press release, EPA issued a non-peer reviewed memo stating the agency “did not find any PFAS in the tested pesticide products.”

PEER alleges that EPA omitted critical details, including:

• Detection of PFAS in samples it both received and independently collected;
• Failure to report high PFAS levels, as revealed by documents obtained via the Freedom of Information Act; and
• EPA’s failure to disclose that test samples were spiked intentionally with PFAS—a standard quality control method—which EPA’s tests failed to detect, raising concerns over test reliability.

“This memo represents some of the poorest science I’ve seen from the agency,” said Kyla Bennett, PhD, PEER’s science policy director and former EPA scientist, emphasizing that failure to detect spiked PFAS is particularly concerning. Filed under the Information Quality Act (IQA), PEER’s complaint requires EPA to address any inaccurate scientific information it has published. The complaint further alleges that EPA ignored its own standards for peer review and quality control before publication.

As a note, in February 2024, EPA introduced a new testing method capable of detecting 32 PFAS directly from HDPE container walls, enabling HDPE container users and manufacturers to assess containers prior to use and assist in preventing contamination from stored products. [It can also be adapted for broader applications, including testing PFAS in other solid materials such as fabric and packaging paper.] However, the focus of the PEER petition is not to shift the burden of testing to food producers to keep their products safe from fluorinated PFAS-contaminated plastic containers; rather, it is to require EPA to carry out its legal responsibility to regulate PFAS under TSCA.

Organic certification system poised to act more quickly and effectively

Organic agriculture offers a long-term solution to PFAS contamination. Under the Organic Food Production Act (OFPA), organic producers are prohibited from using petrochemical pesticides and fertilizers, as well as biosolids often contaminated with PFAS, operating under a regulatory framework overseen by the National Organic Standards Board (NOSB). As the only agricultural system with a requirement for a farm plan, inspections and certification for compliance with organic standards, and rigorous public oversight, organic farming promotes sustainable practices that enhance soil health and biodiversity. Organic is attempting to reverse the escalating public health, environmental, and climate crises as EPA fails to prevent long-chain PFAS contamination throughout the country. Additionally, as there are organic certified foods that are stored in HDPE Inhance manufactured containers—and thus may introduce PFAS contamination into organic foods—the organic food certification system could more rapidly and effectively address the issue in comparison to relying on EPA regulatory authority, which is untenable to rely on given the recent reversal by court order.

Organic land management practices and certified organic agriculture are critical to the systemic shift to prevent further PFAS contamination, as Beyond Pesticides continues to call on the NOSB to develop a strategy for eliminating plastics and PFAS from organic as a priority issue. For more information, please see comments by Beyond Pesticides here calling for research into the elimination of plastic—in all aspects of organic production and handling—to be made a priority for the NOSB Fall 2024 meeting from Thursday, October 22 – Saturday, October 24, 2024, in Portland, Oregon.

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

Sources:

Certain Per- and Polyfluoroalkyl Substances (PFAS) Risk Management Under the Toxic Substances Control Act (TSCA); Request for Comment, EPA notice, Federal Register website

Public Health Groups File Petition to Compel EPA to Remove PFAS Immediately from Fluorinated Plastic Containers, PEER petition, April 11, 2024

EPA Grants Petition on Three PFAS Found in Fluorinated Plastic Containers, EPA website

EPA Must Retract Fraudulent PFAS Report, PEER press release, May 28, 2024

PEER Demand for Correction under the Information Quality Act (IQA), PEER filing, May 28, 2024

EPA Completes Scientific Testing of Pesticide Products for PFAS, EPA website, May 30, 2023

(Beyond Pesticides, October 16, 2024) In a study published in the Journal of Agriculture, Food Systems, and Community Development (JAFSCD), researchers from New York University (NYU) identify gaps in various federal agricultural support systems for organic farmers in a sweeping analysis. The research was spearheaded by Carolyn Dimitri, PhD, chair of the Nutrition and Food Studies program at NYU and a current member of the National Organics Standard Board (NOSB) as a public interest/consumer interest representative serving through January 2026.

According to this study, there is a deficiency in institutionalized knowledge of national organic standards among existing U.S. Department of Agriculture (USDA) agents and staff working in various agencies, including Risk Management Agency (RMA), Natural Resources Conservation Service (NRCS), and Farming Service Agency (FSA). “A key recommendation from this study is the creation of specialized, highly trained crop insurance and conservation agents with expertise in organic farming systems to facilitate the application process and program use for conservation programs and crop insurance,” according to the researchers. The authors continue by echoing the sentiments of organic advocates and farmers across the nation on building organic integrity, saying, “The Organic Cost Share Program [a program of USDA’s FSA] would have more impact if its funds were used to support beginning organic farmers in addition to small-scale farm operators.”

Key Findings from the Study

The researchers identify barriers preventing organic farmers from engaging in top federal agricultural support programs—crop insurance (administered by RMA), Environmental Quality Incentives Program (EQIP) and Conservation Stewardship Program (CSP) (administered by NRCS), and Organic Certification Cost Share Program (OCCSP) /Organic Cost Share (administered by FSA or certain state departments of agriculture).

34 individual farmers and organic advocates were interviewed for this study: 23 were conducted with certified organic farmers engaged in diversified, specialty crop, fruit, and grain production; 11 were organic advocates engaged in technical assistance, policy analysis, and research. The farmers operate in 13 states across the United States with farm sizes ranging from a 3-acre diversified farm to a 12,500-acre grain production farm. The goal of this study is to “understand organic farmer perceptions of these programs, their decisions to participate, experiences with the application process, and how the programs worked for their operations” and provide potential policy solutions.

“Farm programs that target risk management and farmland conservation are important for the economic and environmental health of farms, yet they fail to meet the needs of organic producers,” said Dr. Dimitri. “Our work suggests that inserting organic farms into programs that were designed for non-organic farms has not been widely successful, because they fail to consider differences between organic and non-organic farms.”

EQIP and CSP

The goals of EQIP and CSP are to provide funding incentives for farmers already engaged in eligible practices, such as cover cropping, that support ecosystem services and biodiversity.

Even though organic farmers engage in eligible practices for both programs, recent USDA data demonstrate significantly lower organic farmer participation relative to overall chemical-intensive or conventional farmer engagement with EQIP:

• “In total, only 0.2% of EQIP contracts administered in 2022 went to organic operations. []”
• “In 2019, organic producers had approximately 74% fewer EQIP contracts per organic farm compared to all farms.”

CSP engagement has historically remained higher among organic farms compared to total farm participation, with organic farms “maintain[ing] twice as many CSP contracts… as compared to all farms.” 17 farmers participated in EQIP and six enrolled in CSP. There were several key themes that emerged regarding participation in conservation programs:

1. The knowledge of USDA agents influenced farmer perception of CSP and EQIP;
2. EQIP-eligible practices may vary based on regional/local contexts, thus if there is not a robust organic farming sector there may be intense competition with chemically intensive growers; and
3. Funding levels offered in EQIP and CSP “were not high enough [for some organic farmers] to bother with the lengthy and cumbersome application process.”

Crop Insurance

Just 10 of the 23 farms purchased crop insurance, with organic grain producers making up the vast majority. “Many of the farmers who had diversified operations did not purchase crop insurance and expressed little to no interest in doing so in the future,” according to the study. For the handful of farmers who did participate in insurance, they were disappointed in the benefits.

For example, one diversified farmer was only paid $140 after losing $7,000 in revenue from a surprise overnight drop in temperature, while another farmer was disqualified from payment because an inspector “saw evidence of pests and crop disease.” Another diversified farmer, even after going through what was described as a “stressful” paperwork process, indicated that the inspector “could not figure out how much the crop was worth.” The result: no payout. Organic grain farmers, meanwhile, laud insurance as an essential component of their operations, given climate change-fueled natural disasters that could disrupt their production. This is consistent with general trends in crop insurance enrollment in nonorganic farms, according to the research.

Whether organic farms spoke highly or disparagingly about crop insurance enrollment and procedures, reforms were suggested in the report, including the creation of consistent best management practices across insurance and conservation programs.

“Farmers must follow the RMA good farming practices to be eligible for crop insurance payments, but competing priorities for organic or conservation programming might put them at fault with RMA.” An example of this was an organic grain farmer losing access to insurance for 120 acres of wheat fields in their portfolio after engaging in no-till and cover cropping.

The researchers emphasize that there is “a large potential payoff from additional research into best practices and the development of organic system-specific seed varieties.” This is consistent with advocates’ calls to establish whole-of-government coordination akin to the European Union’s Farm to Fork Strategy (See Daily News here and here) within and among relevant agencies to consider organic food production targets in national programs such as the National School Lunch Program. (See Daily News here.)

The authors did identify RMA efforts to update its rules on insurance policies for organic farmers, as reflected in an updated rule from the Federal Crop Insurance Corporation that went into effect in July this year. See here for more information.

Organic Cost Share

OCCSP, commonly referred to as Organic Cost Share, is the most popular program among surveyed organic farmers, which is not surprising given that the total per-year certification costs can range from $2,000 to $9,000, depending on the variety of production scopes.

This does not include the annual inspection costs to verify farm compliance with the organic standards, with certification prices based on a range of factors.

Small-scale and diversified operations tend to benefit more from OCCSP, whereas large-scale grain producers “can absorb that [certification] cost very easily.” Across the board, there were a variety of recommendations proposed by the surveyed farmers, including:

• Free certification for beginning farmers with less than 10 years’ experience and beginning farmers who are under the age of 35.
• Certification payment coverage based on farm income, with farmers yielding less than $75,000 to $100,000 per year receiving 100% reimbursement.
• Complete coverage for farmers transitioning to organic with existing certified farms paying no more than 10% to 15% total certification costs per year.
• Free certification for farmers grossing less than $250,000 per year.

The survey contains calls to streamline the administrative side of OCCSP. Recommendations include shifting the administration of the cost share (e.g. sharing of invoices and proof of certification) to the certifying body rather than a separate USDA administrative agency to minimize potential communication hardships for farmers.

One of the final recommendations from the authors of this report is the creation of an “Organic Agent Corps.” This would establish permanent positions for experts in various states or regions who are familiar with crop insurance, EQIP, CSP, and related programs, as well as organic certification. Given that there are only 17,000 organic certified farmers compared to the over two million total farm operations in the United States (2021 USDA data), researchers see more targeted expertise and resources as a potential pathway to expanding capacity for the thousands of farmers who may wish to transition to organic but do not know where to begin.

Organic Integrity and Policy

With Farm Bill negotiations in the U.S. Congress in a potential holding pattern until after the presidential election, advocates from the National Organic Coalition are sounding the alarm on the expiration (as of September 30) of funds for programs including Organic Cost Share that directly impacts organic and transitional organic farmers. (See here for this week’s Action of the Week to act now!)

This week, for its fall 2024 meeting, the NOSB convenes to take public comments virtually and will meet in person on October 22-24 in Portland, Oregon. See Keeping Organic Strong for a full list of NOSB recommendations and Beyond Pesticides comments. For more information on the benefits of, and threats to, organic agriculture, see its dedicated Daily News section here.

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

Source: JAFSCD

(Beyond Pesticides, October 15, 2024) In Environmental Epidemiology, researchers from Columbia University and the University of Southern California, along with representatives from the nonprofit Comite Civico del Valle in Brawley, California, report the heightened risk of wheezing for five- to twelve-year-olds in the rural communities of California’s Imperial Valley. Through a school-based survey, the authors find associations between living near pesticide applications and more wheeze symptoms among the children.

According to the authors, residents of the Imperial Valley, which is located near the border between the United States (U.S.) and Mexico, “are primarily Latino, 1 in 3 children live in poverty, and there is a 20% unemployment rate. The county faces poor air quality and excess particulate matter levels. Further, one in five children is diagnosed with asthma and the rate of asthma-related pediatric emergency room visits and hospitalizations is two times the CA state average.” This highlights the disproportionate risk for residents in this area regarding environmental exposure to harmful chemicals.

Children are already more susceptible to health complications following pesticide exposure, as they take in greater amounts of toxic chemicals relative to their body weight and have still-developing organ systems. Young children in environments with higher levels of pesticide usage and pesticide drift face an even greater threat, such as in the Imperial Valley. The authors note, “Industrial agriculture in the region results in one of the highest amounts of pesticide applications in the state, with Imperial County ranking in the top 12 (of 58 counties) since 2017.”

The purpose of this study, the authors share, is to “assess the respiratory health impacts of pesticide usage in a rural, structurally marginalized population of school-aged children.” This is of particular importance, as the respiratory health of children can lead to long-term consequences into adulthood. The Assessing Imperial Valley Respiratory Health and the Environment (AIRE) study was initiated as a result of the concern among residents and community organizations about cumulative effects and body burden from the copious amounts of pesticides used in the Imperial Valley.

“In this intensively farmed community, fields are planted and harvested several times a year. There are over 100 different types of crops cultivated and over 50 pesticides (differentiated by active ingredient) used in Imperial Valley amounting to over five million pounds of pesticides applied annually,” the authors state. “As schools and homes are located in close proximity to agricultural fields, exposure to pesticides is of great concern.” To address this, the AIRE study provides an analysis of pesticide usage from 2016-2020 within 400 meters (m) of the homes of over 700 children.

Elementary school-aged children from five schools across five communities throughout the Imperial Valley were considered in the voluntary study. With a parent or guardian’s consent, eligible students received questionnaires. These consisted of demographic and lifestyle questions, as well as an inquiry of respiratory symptoms based on questions adapted from the International Study of Asthma and Allergies in Childhood (ISAAC). After which, 708 children participated in the questionnaire and were enrolled in the AIRE study.

In describing their methodology, the authors say, “For each child, we computed the total pesticides applied within a 400-m buffer distance of their home, using a reported address from the questionnaire, for the 12 months before the date of the baseline survey using the following pesticide groups: all pesticides, all pesticides except sulfur, sulfur only, chlorpyrifos only, and glyphosate only.”

In choosing the 400 m buffer parameter, the authors consider that there are “(1) previous studies identifying an association between a 500-m buffer correlation with pesticides measured in homes located near agricultural fields and (2) a 2018 law in California that limits the application of pesticides within 402 m (1/4 mile) of schools.” This provides 400 m as “a buffer with both scientific and policy implications,” the authors note. While this law recognizes concerns in California about children’s exposure to pesticides, it is limited to contiguous areas around schools and does not consider the amount of residential exposure, especially in rural areas, that many children face.

With information from the questionnaires, along with data from the California Pesticide Use Registry in the areas surrounding the children’s homes, the authors are able to assess links between reported respiratory symptoms and pesticide exposure. The exposure levels for each child are categorized into one of three groupings: none, low, and high.

Important statistics the authors share from the study results include: 

• “Approximately 62% of the 708 children (aged 5–12 years) lived within 400 m of at least one pesticide application within 12 months prior to survey administration.”
• “There were 130 children (18%) with wheezing in the 12 months prior to the survey.”
• “Within 400 m of child residences, there were 150 different pesticides applied over a 12-month period. This amounted to a total of 56,824 kg of pesticides applied to agricultural fields in our Imperial Valley study area.”
• “Applications of sulfur only were the main contributor with a total of 28,060 kg, followed by all pesticides except sulfur (28,763 kg), glyphosate (3319 kg), and chlorpyrifos (523 kg).”

Of the 708 participants that were enrolled in the study, 658 are included in minimally adjusted models. These participants submitted questionnaires with complete information and a geocoded address that allows for a full assessment. The authors report, “In minimally adjusted models, children in the ‘high’ total pesticide exposure group had a prevalence of 12-month prior wheeze that was 10 percentage points higher than that of children not exposed to any pesticides. Similarly, the difference in the prevalence of 12-month prior wheeze in the ‘high’ exposure group to sulfur compared to the ‘no’ exposure group was 12 percentage points higher.”

Additional results show higher prevalence in the “high” exposure groups, such as for chlorpyrifos (15%) and glyphosate (9%) when compared to the unexposed groups. An association is also noted for pesticide exposure and respiratory symptoms in children with a history of asthma. Wheezing in these children is, on average, 18.6% greater within the “high” exposure groups for all categories. In children without asthma, the “high” exposure groups are 6% and 10% higher than that among unexposed children in the categories of all pesticides, except sulfur and chlorpyrifos, respectively.

To summarize the results, the authors say, “We observed consistent cross-sectional associations between exposure to pesticides applied within 400 m of children’s residences within the past 12 months and reported wheeze during this time. Those in the highest exposure group experienced a higher prevalence of wheeze compared to unexposed children for all pesticides groups we examined: all pesticides, sulfur only, all pesticides except sulfur, chlorpyrifos, and glyphosate, respectively.”

They continue, “Associations between exposure to pesticides and respiratory symptoms appear to be higher in children with asthma, but positive, albeit weaker trends, also were observed among nonasthmatic children.” This study shows how detrimental the pesticide drift exposure pathway can be, particularly for rural communities, as living in areas with pesticide applications increases the risk of health effects. The results indicate that individuals with already documented health effects are more susceptible to additional respiratory implications, but all exposed children are still in jeopardy.

The authors also highlight the role of environmental justice, saying, “Disparities in pesticide exposures by race/ethnicity also persist, with higher exposures concentrated in structurally marginalized communities.” The AIRE cohort consists primarily of children from under-resourced Latino families, the authors note. “[P]esticide use is disproportionately located in communities experiencing the highest levels of poverty, and communities of color. Rural communities such as Imperial Valley continue to rank among the top communities most burdened by toxic pollution, including pesticides.” See additional coverage on environmental justice here, here, and here.

Concerns from residents of the Imperial County, which led to the initiation of the AIRE study, are due to many of the pesticides sprayed in the area being classified as respiratory irritants (e.g., chlorpyrifos, glyphosate, and sulfur). While each of these pesticides has a different mode of action, they are all considered irritants when inhaled. Previous studies link these pesticides to an increase in respiratory symptoms in both children and adults. One study finds that sulfur, used as a fumigant, is associated with an increase in respiratory symptoms and a decrease in pulmonary function in children, while another finds the weed killer glyphosate is associated with atopic asthma. Chlorpyrifos, in addition to pendimethalin and trifluralin, is associated with wheezing in farmers.

The authors note a limited but growing number of studies focused on the association between various types of pesticides and wheezing in children. Such studies (here and here) report increased wheezing in young children with pesticide exposure, particularly pyrethroids. Another California-based study finds decreased lung function with a 10-fold increase in exposure to sulfur within 1000 m of a child’s residence. See more coverage on respiratory implications here and here.

While the escalated health risks to farmworkers and their children have been documented, the AIRE study highlights how “pesticide drift and inhalation may be of greater concern than the take-home exposure pathway” that farmworker families face since the majority of children in the AIRE cohort are not from a household with a farmworker parent or guardian. This calls to attention the proximity of residences to agriculture and how prevalent pesticide drift is, especially in posing a threat to children’s health, as compared to the risk for farmworker children with pesticide residues brought into the house on a parent’s clothing.

The authors conclude, “Pesticide exposures have long been identified by researchers and community voices as an important environmental justice issue impacting not only agricultural workers but also nearby residents. In the United States alone, the agricultural sector accounts for nearly 90% of the total pesticide usage, making agricultural farmworkers, their families, and nearby residents particularly vulnerable to the effects of pesticides.”

To protect children’s health and mitigate respiratory effects, pesticide applications near residential homes should be eliminated. Chemical-intensive agriculture, as well as the use of household pesticides on lawns and gardens, threatens not only the health and development of growing children but all humans, pets, wildlife, and ecosystems. The Safer Choice to protect human health, biodiversity, and the environment is in organic land management.

Take action to protect the health of infants and children, as well as advocate for the removal of harmful pesticides such as paraquat, to help further Beyond Pesticides’ mission of phasing out all petrochemical pesticides and synthetic fertilizers by 2032. The path forward for a livable future is organic, which focuses on healthy soil as the foundation for land management. Organic methods promote soil health, biodiversity of microorganisms, and ecological functions as a whole. (See more here, here, and here.)

Stayed informed with Beyond Pesticides’ Daily News, which shares the latest news on the health and environmental hazards of pesticides, pesticide regulation and policy, pesticide alternatives, and cutting-edge science. Become a Parks Advocate to encourage your community to transition to organic and join Beyond Pesticides as a member today to support the movement of eliminating fossil fuel-based pesticide use and adopting the organic solution.

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

Source:

Ornelas Van Horne, Y. et al. (2024) Exposure to agricultural pesticides and wheezing among 5–12-year-old children in the Imperial Valley, CA, USA, Environmental Epidemiology. Available at: https://journals.lww.com/environepidem/fulltext/2024/10000/exposure_to_agricultural_pesticides_and_wheezing.2.aspx.

(Beyond Pesticides, October 11-14, 2024) Indigenous Peoples’ Day is celebrated this year on Monday, October 14, 2024 and has been described as follows: “[T]hroughout our Nation’s history, Indigenous peoples have faced violence and devastation that has tested their limits. . . Today, Indigenous peoples are a beacon of resilience, strength, and perseverance as well as a source of incredible contributions. . . They challenge all of us to celebrate the good, confront the bad, and tell the whole truth of our history.  And as innovators, educators, engineers, scientists, artists, and leaders in every sector of society, Indigenous peoples contribute to our shared prosperity.  Their diverse cultures and communities today are a testament to the unshakable and unbreakable commitment of many generations to preserve their cultures, identities, and rights to self-governance.  That is why, despite centuries of devastation and turmoil, Tribal Nations continue to thrive and lead in countless ways.” This language is taken from a Proclamation issued by President Biden (2023), first issued in 2021 and then again last year.

This year’s Proclamation states: “On Indigenous Peoples’ Day, we honor Indigenous peoples’ strength, courage, and resilience.  We celebrate the vast contributions of Indigenous communities to the world.  And we recommit to respecting Tribal sovereignty and self-determination and working to usher in a new era of our Nation-to-Nation relationships.” (See 2024 Proclamation.)

The federal holiday on October 14, known as Columbus Day, has for many been reoriented to recognize that the “discovery” of America was, in fact, an invasion of the Western hemisphere by Europeans who took unceded land and undermined culture, self-governance, and a way of life. In fact, the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), adopted in 2007, found that:

“[I]ndigenous peoples have suffered from historic injustices as a result of, inter alia, their colonization and dispossession of their lands, territories and resources, thus preventing them from exercising, in particular, their right to development in accordance with their own needs and interests.”

In explaining why the United States has never “endorsed” the Declaration, the U.S. Agency for International Development (USAID) wrote: “The UNDRIP is not legally binding on States and does not impose legal obligations on governments, but like all human rights instruments, it carries moral force. While not endorsing the UNDRIP, the United States has agreed to support the Declaration.”

Indigenous Peoples’ Day has increasingly become a day to remember the people of those nations indigenous to their country. Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. As Kaipo Kekona shared with the Beyond Pesticides 39^th Pesticide Forum, it is critical for us to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

In Indigenous Peoples in North America: An Overview of Progress and Report of the Regional Dialogues for the United Nations Permanent Forum on Indigenous Issues, the author writes: “Numbering over 370 million people in over 70 countries around the world on every continent, Indigenous Peoples are practitioners and knowledge-bearers of distinct cultural, ecological, spiritual, health and healing practices, as well as systems of governance. Yet tragically, the rights of Indigenous Peoples have been violated worldwide through processes of colonization involving forced relocation as well as removal of children from their families. Large numbers of children were often placed in residential schools, where they suffered severe psychological and physical abuse.”

>> Tell EPA to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. Tell EPA that when needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment.”

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those in the Great Plains, Eastern North America, or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the Indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our well-being and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

According to A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “There are stark differences between agricultural systems in Indigenous communities and agricultural systems in contemporary communities. The first being the idea of collective resources. In an Indigenous community, there are some things that just cannot be commodified – land, water, air, animals, even the health of the people, all of which are considered collective resources. Collective resources require collective and community management. Contemporary agriculture doesn’t have the same base. In contemporary agriculture, there are individualized, commodified resources like land, you can buy water, at one point in our history you could even buy somebody’s body and health.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although Indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency that although it “adhered to applicable tribal consultation policies when it conducted consultations for the three RUP [restricted use pesticide] actions that we reviewed, the EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The investigation was specifically directed toward RUP actions, but the OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate.

>> Tell EPA to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment.”

Letter to EPA
On Indigenous Peoples’ Day, I urge the U.S. Environmental Protection Agency (EPA) to recognize that indigenous agriculture and landcare provide a model for a truly sustainable relationship with the land. These practices must be integrated into the agency’s decision making that now allows unreasonable levels of harm to health and the environment despite the availability of alternative practices and products. By ignoring this fact in registering pesticides, EPA promotes unsustainable practices, increasing crises with health, biodiversity, and climate—and undermines the opportunity for humans to live sustainably on Earth.

Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for EPA to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those Great Plains or Eastern North America or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the Indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our well-being and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although Indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency, “EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how Indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate. A starting place is the understanding that, in the words of A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “In an Indigenous community, there are some things that just cannot be commodified—land, water, air, animals, even the health of the people, all of which are considered collective resources.”

I urge you to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment”—the statutory standard for regulating pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act—and should result in the cancellation of the pesticide use.

Thank you.

Letter to U.S. Senators and Representative
Indigenous agriculture and landcare provide a model for a truly sustainable relationship with the land. By ignoring this fact in registering pesticides, EPA promotes the opposite, increasing problems with health, biodiversity, and climate–not to mention the possibility of humans living sustainably on Earth.

On Indigenous Peoples’ Day, I urge you to require the U.S. Environmental Protection Agency (EPA) to engage in constructive dialogue with Native American Tribes to incorporate Indigenous agriculture and landcare practices in its assessment of pesticide registrations that allow unreasonable harm to people and the environment, despite the viability of truly sustainable Indigenous methods. These Indigenous practices must be integrated into the agency’s decision making. By ignoring these practices in registering pesticides, EPA promotes unsustainable practices, increasing crises with health, biodiversity, and climate—and undermines the opportunity for humans to live sustainably on Earth.

Indigenous cultures—because they arose as part of the land—have a history of generating food, clothing, medicines, and other necessities without destroying the land that provides them. It is critical for EPA to learn from history—including the positive lessons from those ancestors who lived in harmony with their surroundings.

Indigenous agriculture arises from the ecology of a place, so the successful practices in Hawai’i are not necessarily the same as those Great Plains, Eastern North America, or the Andes. But all offer wisdom that could protect us all from the health, biodiversity, and climate emergency that faces us. In the words of the Indigenous authors of the White/Wiphala Paper on Indigenous Peoples’ Food Systems, “Since millennia, Indigenous Peoples have been protecting their environment and biodiversity. Today scientists are telling us that 80 percent of the remaining world’s biodiversity is in our lands and territories. We didn’t know this. Our ancestors did not know about biodiversity, ecology, ecosystem services, or CO2 trapping, but they knew that protecting the ecosystems, environment, and biodiversity were essential for our wellbeing and sustainability. Our elders, mothers and fathers taught us this as a way to exhibit good behaviour in the community.”

Indigenous systems of agriculture and the wisdom they embody are threatened by industrial agriculture, especially toxic chemical use. Indigenous agriculture depends on biodiversity—both in the plants and animals used for food and in the ecosystem in which they are grown. Although Indigenous agriculture is more resilient to climate changes, recent extreme climatic events threaten peoples who can no longer move with the changing seasons.

In a recent report, EPA’s Office of Inspector General (OIG) told the agency, “EPA could update guidance to enhance the meaningful involvement of tribal governments in decision-making processes that affect Indian Country.” The OIG’s advice that EPA define what constitutes “meaningful” involvement with tribes suggests that the agency might begin to learn from tribes about how Indigenous farming and land management practices could avoid the use of pesticides that are so dangerous for health, biodiversity, and climate. A starting place is the understanding that, in the words of A-dae Romero-Briones (Cochiti/Kiowa) of the First Nations Development Institute, “In an Indigenous community, there are some things that just cannot be commodified—land, water, air, animals, even the health of the people, all of which are considered collective resources.”

Please urge EPA to begin meaningful dialogue with tribes to learn how pesticide use can be avoided by adopting indigenous practices. When needs can be met without using pesticides, such use causes “unreasonable adverse effects on the environment”—the statutory standard for regulating pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act— and should result in the cancellation of the pesticide use.

Thank you.

(Beyond Pesticides, October 10, 2024) On September 16, 2024, the U.S. Environmental Protection Agency (EPA) announced an order allowing Kaizen Technologies LLC to sell off its chlorpyrifos-based insecticide product—Bifenchlor, a known neurotoxicant. This reverses an existing stocks agreement that Kaizen voluntarily negotiated with EPA in August 2022 when the company withdrew Bifenchlor from use. The agency attributes this new order to a November 2023 Eighth Circuit Court of Appeals decision, which vacated EPA’s prior 2021 chlorpyrifos ban on food crops (see here). EPA’s practice of permitting the sale and use of existing stocks of canceled pesticides has been a longstanding concern for public health and environmental advocates, as it enables the continued use of petrochemical pesticides that the agency has found to be dangerous. Chlorpyrifos, an organophosphate with adverse health effects on children (see here and here), is now the latest example. 

In reporting on the almost unprecedented decision on August 7, 2024, to use its emergency authority to ban Dacthal/DCPA, Beyond Pesticides argues that the “Dacthal Standard” is a positive precedent, a step forward in modern regulatory history; however, EPA’s continued approval of chlorpyrifos’s existing stock, complicated by the 2023 court decision, may suggest otherwise.  

As demonstrated historically with chlordane, dicamba, methyl iodide, atrazine, and other pesticides, EPA’s decision making, delay tactics, and contradictory policies are not confined to chlorpyrifos. In fact, when EPA negotiated in 2000 a withdrawal from the market residential uses of chlorpyrifos, based on the neurotoxic impacts on children, it allowed Dow Chemical to sell off all its existing stocks over a one-year period.  “Chlorpyrifos, glyphosate, 2,4-D, atrazine, and many others are poster children for a failed regulatory system that props up chemical-intensive agriculture despite the availability of alternative organic practices not reliant on these toxic chemicals,” says Jay Feldman, executive director of Beyond Pesticides. 

Ironically, as in the short interval between EPA’s rule banning agricultural uses of chlorpyrifos and the Eighth Circuit’s intervention, “the need for any use of chlorpyrifos has been refuted,” as Earthjustice Senior Attorney Patti Goldman noted in a press release. “Crops have been successfully grown in the two years since chlorpyrifos has been banned,” Ms. Goldman said. Despite the growth of the $70 billion organic industry, organic agricultural methods and materials are still not considered by EPA to be a legitimate alternative to chemicals when determining the “reasonableness” or “acceptability” of adverse pesticide effects under federal pesticide law.  

This most recent “chlorpyrifos existing stock order notice” by the agency is another footnote in an ongoing chapter of what environmental and health advocates see as regulatory failure by EPA under a weak federal statute, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The current 2024 growing season allowed the use of chlorpyrifos pesticides on most food crops [except for five states that have stepped up, independent of EPA, to ban the insecticide to protect children: Hawaii, Maryland, New York, Oregon, and California]. (See here and here.) In 2000, EPA discontinued all uses of chlorpyrifos on tomatoes, restricting use on apples, and lowering the grape tolerances. 

Background  

In 2021, EPA issued a rule that revoked food tolerances for chlorpyrifos, effectively banning its use on food crops. This decision, however, faced legal challenges from a chlorpyrifos manufacturer and several agricultural groups, which filed a lawsuit in the U.S. Court of Appeals for the Eighth Circuit. On November 2, 2023, the Eighth Circuit vacated EPA’s 2021 rule revoking all tolerances in Red River Valley Sugarbeet Growers Associations, et al. v. Regan, 85 F.4th 881 (8th Cir. 2023) and directed the agency to reconsider.  

In response to this legal development, EPA published a notice in the Federal Register on February 5, 2024. This notice served as a technical correction to the Code of Federal Regulations, formally acknowledging the Eighth Circuit’s reinstatement of chlorpyrifos tolerances, and allowing its use for the 2024 growing season on all crops effective February 5, 2024. The Eighth Circuit’s decision also referenced EPA’s 2020 Proposed Interim Registration (PID) Review Decision for chlorpyrifos, which identified eleven specific crops for potential continued use of the pesticide. The crops include alfalfa, apples, asparagus, cherries, citrus, cotton, peaches, soybeans, strawberries, sugar beets, and wheat. As discussed below, EPA is now in discussions with chlorpyrifos registrants to cancel its use on all food crops, except for the eleven identified in the 2020 Proposed Interim Registration Review Decision (PID). 

Door opens to chlorpyrifos’ expanded use and toxic exposure—‘Existing stocks’ orders 

“Since the Final Rule has been vacated—and the tolerances are again in effect—growers can use currently registered chlorpyrifos products on crops consistent with label directions. Products that were cancelled or amended may be able to be used if use is consistent with the existing stocks provisions…”—Chlorpyrifos; Amendment to Existing Stocks Provisions in Kaizen Product Cancellation Orders, A Notice by the U.S. Environmental Protection Agency on September 16, 2024. 

When courts defer to EPA’s interpretation of the existing stock provision in the federal pesticide law, a pattern of “existing stock” allowances permit hazards to continue well after a finding of harm or noncompliance. This process contrasts with the issuance of a product recall, which is typically done when pharmaceuticals are found to violate safety standards. In addition to chlorpyrifos, Beyond Pesticides has previously objected to the agency’s expansion of existing stock use for dicamba, dacthal, and paraquat. As this latest example shows, manufacturers have found a short-term workaround to quickly return to selling and distributing chlorpyrifos. Their solution—petitioning EPA for new or amended existing stock orders.  

As of September 16, chlorpyrifos can be used on all food crops that were previously subject to the formal revocation of tolerances. According to EPA’s Frequently Asked Questions about the Current Status of Chlorpyrifos and Anticipated Path Forward, the agency intends to issue a new rule to revoke the tolerances for all food commodities except for the 11 uses cited in the December 2020 PID. After providing an opportunity for public comments on PID-referenced crops——anticipated updates are tentatively proposed for 2025. However, this will only apply to specific states under agency review with limits on application rates and methods. 

Meanwhile, in an analogous decision despite the finding of harm and EPA’s violation of law in allowing harm associated with the herbicide dicamba’s registration, the continued use of the weed killer through the 2024 growing season is also effectively authorized by the U.S. District Court of Arizona (which vacates EPA’s 2021 authorization for three over-the-top uses of dicamba-based herbicide products). In response, EPA issued an existing stocks order, which means that dicamba will continue to be sold and used through 2024—although it has been linked to environmental and health adverse effects.  

As the agency continues to prioritize commercial interests and agricultural continuity over public safety and environmental protection by expanding existing stocks, Beyond Pesticides advocates for immediate discontinuation of pesticide use when risks are identified and emphasizes the availability of safer, profitable alternatives, such as USDA-certified organic farming practices. They advocate for these organic principles to be adopted more broadly to replace the reliance on harmful chemical pesticides like dicamba and chlorpyrifos. 

As clearly indicated by the evidence at hand, individual chemical bans are not the strategy for systemic change, nor are they an effective methodology for cultivating a livable future for ourselves and future generations. Given the proven viability and profitability of cost-effective organic production practices, the solution must be the urgent adoption of organic agriculture and land care that eliminates not just chlorpyrifos, but the pesticide treadmill that chemical manufacturers and chemical-intensive agriculture fuels.  

Organic management practices build soil health, cycle nutrients naturally, enhance plant resiliency, reduce water use, and do not use petrochemical pesticides or fertilizers. The organic alternative is central to a commitment to both the elimination of practices and products that are petrochemical-based and the ability of organically managed soils to draw down (sequester) atmospheric carbon, which contributes to mitigating global warming and erratic temperatures.  

For a detailed analysis, see Beyond Pesticides’ article “Abandoning Science: A look back at the failure to regulate the neurotoxic insecticide chlorpyrifos,” featured in a special edition of Pesticides and You, where the clarion call to action notes that “… states should ban chlorpyrifos compounds . . . should undertake organic management on state-owned lands, and should support producers in transitioning away from chemical agriculture and to organic, regenerative, and sustainable practices.” 

As we emerge from a celebration of National Organic Month in September, please continue to take action to strengthen organic locally! >> Tell your governor and mayor to adopt policies that support organic land management. 

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

Sources: 

EPA’s Momentous Decision to Ban the Weed Killer Dacthal/DCPA: An Anomaly or a Precedent? Beyond Pesticides Daily News, August 8, 2024 

EPA and Court Allow Violations and Hazards of Weed Killer Dicamba Under Existing Stock Order, Beyond Pesticides Daily News, March 5, 2024  

Oregon Is the Latest State to Step In and Ban Widely Used Neurotoxic Pesticide, Chlorpyrifos, as EPA Stalls, Beyond Pesticides Daily News, February 29, 2024  

Celebrated 2021 Ag Ban of Deadly Pesticide, Chlorpyrifos, Reversed by Court Despite Decades of Review and Litigation, Beyond Pesticides Daily News, November 14, 2023 

Commentary: Are Children, Agricultural Workers, and the Food Supply Safe with EPA’s Chlorpyrifos Decision? Beyond Pesticides Daily News, August 19, 2021 

Abandoning Science: A look back at the failure to regulate the neurotoxic insecticide chlorpyrifos, Beyond Pesticides, Pesticides and You, Special Edition 2020  

Widely Used Pesticide in Food Production Damages Children’s Brains—EPA Science on Chlorpyrifos Ignored as Agency Reverses Decision to Stop Insecticide’s Agricultural Use, Beyond Pesticides, Pesticides and You, Winter 2017-2018 

What You Need To Know About Chlorpyrifos, Earthjustice, April 9, 2024 

Frequently Asked Questions about the Current Status of Chlorpyrifos and Anticipated Path Forward, EPA website 

(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.