(Beyond Pesticides, November 9, 2022) A team of Dutch researchers has developed an artificial predator dubbed the RobotFalcon that can quickly and successfully scare bird flocks away from fields, providing a new practical, ethical tool to deter bird strikes near airports. Although it sounds like a conspiracy theory, in the skies above Workum, The Netherlands, for a period of time, some of the birds were not real. Current data indicate there are over 17,000 wildlife strikes to aircraft each year in the U.S., costing an estimated $500 million in economic losses, yet these problems are ongoing despite the U.S. Department of Agriculture’s Wildlife Services program killing hundreds of thousands of birds in and around airports each year through a range of lethal means, including the use of guns and pesticides. As a result, new management approaches that focus on effective, nonlethal alternatives to the use of toxic chemicals are urgently needed.

Scientists began their research with the understanding that most bird deterrent methods “suffer from some degree of habituation: after repeated exposure, birds respond less.”  While habitation can be reduced through natural threats, the authors note that approaches like falconry are lethal and can be prohibitively expensive and difficult to maintain. The RobotFalcon, attempts to solve this limitation. A fiberglass drone built to resemble the shape of a peregrine falcon, the RobobotFalcon can be steered to focus on a particular flock of birds in attempts to drive them away from a given area.

Efficacy tests were conducted in Workum, NL, in an agricultural area, and focused on deterring species of corvids, gulls, and starlings – birds that are frequently involved in aircraft strikes. The deterrence capacity of the RobotFalcon was compared to a regular drone and the tactics used at a nearby airbase, which included pyrotechnics (fireworks) and distress calls. Trials began once target birds landed in the field and were measured primarily based on how quickly, and how long the approach cleared birds out of the field area.

In a direct comparison between the RobotFalcon and the drone, the RobotFalcon cleared more flocks quicker, and was more effective at keeping flocks of fleeing birds airborne, rather than occasionally landing as was seen with the drone. Efficacy in this matter increased further when the RobotFalcon fly at a higher altitude.

The RobotFalcon kept flocks of starlings out of the area for a median time of four hours, compared to distress calls and fireworks, which were effective for 1.83 and 1.1 hours respectively. Gulls were deterred for three hours by the RobotFalcon, but only half that time when researchers used distress calls. However, all approaches kept corvids away for roughly one hour.

Critically, birds did not get used to the RobotFalcon flying in the skies. “In our three months of fieldwork, there was no evidence of habituation of birds to the RobotFalcon,” the study’s authors wrote. “We speculate that the RobotFalcon continued to be effective because of its resemblance in behavior and appearance to a real falcon.”

The device has some drawbacks however, requiring training and good weather conditions, and can currently only fly for approximately 15 minutes at a time.

The results of the study find RobotFalcon as a viable alternative to the use of toxic pesticides to haze, deter, or kill bird flocks near airports. One frequently used pesticide is the product Avitrol, containing the chemical 4-Aminopyridine. The product is generally fed to birds through treated corn. The chemical is highly toxic to mammals, harming the nervous system and resulting in potential death through heart failure. Avitrol has a significant risk of killing nontarget birds and other organisms that may eat the disbursed grain. Birds that do experience seizure-like symptoms, but the manufacturer claims that affected animals “are not in pain.” In 2014, Houston’s Bush International Airport utilized the chemical and shocked airport employees as they watched hundreds of birds succumb to the poison. Animal rights groups have strongly criticized the practice, with Humane Society of the US senior scientist John Hadidian, PhD noting, “These deaths look anything but humane… The birds that are dying after ingesting this compound are suffering and in great distress.” At the time, an airport employee posted a video of what they experienced.

Help support efforts to protect migrating from toxic pesticides and other threats by urging your Senator to cosponsor S4187, the Neotropical Migratory Bird Conservation Enhancements Act. And to learn more about the threats pesticides pose to wildlife, see Beyond Pesticides Wildlife program page.

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

Source: Journal of the Royal Society Interface

Photo Credit: R. F. Storms et al./J. R. Soc. Interface (CC BY 4.0)

(Beyond Pesticides, November 8, 2022) Glyphosate weed killers induce antibiotic resistance in deadly hospital-acquired bacteria, according to a new study published late last month in the journal Scientific Reports. This is the latest finding 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. While federal regulatory agencies continue ignore the role of pesticides in the development of antibiotic resistance, it is critical for states and localities to take action to protect their most vulnerable both from toxic exposure to these herbicides and the multitude of indirect effects caused by their use. This is all happening as antibiotic resistance is rising to dangerously high levels in all parts of the world, according to the World Health Organization. In the May 1, 2022 issues of the Bulletin of the World Health Organization, Samira Choudhury, PhD, et al. writes, “Often referred to as the silent pandemic, antimicrobial resistance claims the lives of over 700,000 people annually.” The authors 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.”

Scientists focus their research on Pseudomonas aeruginosa, a bacteria commonly found in the environment, but able to cause serious disease in humans. Healthy people can be infected from improperly cleaned hot tubs or swimming pools, resulting in skin rashes and eye and ear infections. However, the greatest risk of P. aeruginosa is in the hospital setting. The bacteria is well known to infect those suffering from burn wounds, on a ventilator or other invasive medical device, and or with a catheter. Hospital-acquired P. aeruginosa is deadly in large part due to the wide spectrum of multi-drug antibiotic resistance the bacteria possesses. The U.S. Centers for Disease Control and Prevention indicate that in 2017 32,600 Americans hospitalized came down with a P. aeruginosa infection, with 2,700 passing away as a result.

To better understand the role pesticides like glyphosate are playing in these deadly infections, scientists examined five different strains of P. aeruginosa, four retrieved from the environment and one from a clinical setting. All represented strains that were initially sensitive to antibiotics.

These strains were exposed to both technical grade glyphosate and a range of glyphosate-based herbicide (GBH) formulations, including the products Roundup Mega, Dominator Extra 608 SL, Gladiator 480 SL (which are sold only in Europe). P. aeruginosa was exposed to 0.5% of glyphosate and GBH products per the volume of the medium (equivalent to 1.8–2.8 g/L [glyphosate] acid depending on the type of formulation). “This concentration falls within the recommended dilution range of GBHs [0.2–3.5% (v/v)] for agricultural and household use and similar to those found in water after agricultural practices,” the study notes.

At this level, glyphosate and its formulated products significantly increase the minimum inhibitory concentration (the lowest concentration of an antibiotic that would inhibit the growth of a given bacteria) of P. aeruginosa to the carbapenem-type antibiotic imipenem by between 2-32 fold. This occurred in all strains and under different exposure scenarios. “Considering the worldwide use of [glyphosate] and GBHs, and the simultaneous emergence of antibiotic-resistant bacteria in environmental matrices, the detected interactions between these chemicals may affect microbial communities and possess a potential environmental and human health risk,” the authors explain. Future studies will likely determine the mechanism through which this problem is occurring,

It is becoming increasingly evident that glyphosate is creating resistance problems in more than merely the weeds on which the chemical is being applied to control. Initial reports on glyphosate’s antibiotic resistance properties came in 2015, a week after the chemical was deemed a possible carcinogen by the World Health Organization. Two years later these reports were confirmed in greater detail by the same team of scientists. In 2018, researchers found that bacteria exposed to glyphosate-based Roundup can develop antibiotic resistance 100,000 times faster than average. The most recent findings indicate that this resistance is developing directly in the field, with soils sprayed with weed killers likely to contain higher amounts of antibiotic resistant bacteria.  

The regulatory response to this near decade of research on the antibiotic resistance properties of commonly used herbicides has been nil. While the U.S. Environmental Protection Agency (EPA) requires herbicide product labels to include information on abating weed resistance, antibiotic resistance is not mentioned. If anything, EPA uses the phenomenon of antibiotic resistance as a comparison point to weed resistance, without any mention of the role glyphosate and other herbicides could be playing in both phenomena.

With inaction from federal regulators, it is up to states and localities to protect their residents from the rise of pesticide-induced antibiotic resistant bacteria. Pseudomonas aeruginosa is known to attack the most vulnerable at their weakest stage. Yet, it is perfectly possible for a landscaper to be spraying glyphosate outside of the room of a patient suffering from a P. aeruginosa infection. Despite the high level of care that doctors, nurses, and custodial staff may put into deterring the spread of P. aeruginosa infections within a hospital, pesticide use outside may be resulting in patients and staff tracking in resistant bacteria, acting as a steady source of environmental exposures. Resistant bacteria travels throughout the environment through a process called horizontal gene transfer, causing widespread resistance even if the use site of the chemical does not come into direct contact with someone suffering from or vulnerable to an infectious disease. The human pathogenic organisms themselves do not need to be directly sprayed by the antibiotic because movement of genes in bacteria is not solely “vertical” –that is from parent to progeny– but can be “horizontal” –from one bacterial species to another. 

Stopping the use of carcinogenic, antibiotic resistance forming pesticides outside hospitals where individuals are suffering from the diseases these chemicals can cause is common sense. But Beyond Pesticides challenges individuals to find hospitals that are paying attention and considering the connection between their landscape practices and the health of their patients. Although some like the Adventist Hospital in Takoma Park, MD stopped their use of pesticides and supported the passage of local laws restricting their use, their involvement is unfortunately rare. More broadly, use of pesticides that cause bacterial resistance to antibiotics in agriculture is contributing to widespread resistance throughout society, making it more and more different to treat infectious diseases with antibiotics. Individuals concerned about this problem, who may have had family members or friends poisoned by pesticides or harmed by antibiotic resistant diseases, are encouraged to get active in their community to fight for meaningful protections from toxic pesticides. This fall take action to tell your mayor or county executive to transition your community landscapes to pesticide-free, organic management.  

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

Source: Scientific Reports

(Beyond Pesticides, November 7, 2022) The Maine Congressional delegation — Senators Collins (R) and Angus King (I), and Representatives Chellie Pingree (D) and Jared Golden (D), along with New Hampshire Senator Jeanne Shaheen (D) — have  introduced a bipartisan bill — the Relief for Farmers Hit with PFAS Act — to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. The bills are the identical S. 5070 and H.R. 9186, both titled “Relief for Farmers Hit with PFAS Act.”

Tell your U.S. Senators and Representative to cosponsor the Relief for Farmers Hit with PFAS Act. If they are already cosponsors, thank them. Tell EPA to stop the spread of legacy chemicals.

PFAS chemicals, also known as “forever chemicals,” are legacy contaminants or those whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

As indicated by the title of these bills, farmers have often been “hit with” legacy contaminants through no fault of their own, and these bills will authorize $500 million over FY 2023-2027 to the U.S Department of Agriculture to help farmers address the aftermath of the contamination, including: more capacity for PFAS testing of soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. The money comes from taxpayers, not the manufacturers of the chemicals responsible for the contamination.

However, since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while we urge Congress to pass bills offering relief to farmers harmed with PFAS, we must also do all that we can to prevent further contamination.

Tell your U.S. Senators and Representative to cosponsor the Relief for Farmers Hit with PFAS Act. If they are already cosponsors, thank them. Tell EPA to stop the spread of legacy chemicals.

Letter to cosponsoring Senators:

Thank you for cosponsoring S. 5070, the Relief for Farmers Hit with PFAS Act, to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill authorize $500 million over FY 2023-2027 to the U.S. Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. I should note that this money, if appropriated, comes from taxpayers, not the manufacturers of the chemicals responsible for the contamination.

However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

I urge you to use your oversight of EPA to ensure that persistent toxic pesticides and other chemicals are no longer allowed to be released into the environment. Ensure that EPA carries out its responsibility to ensure that the pesticides it registers are not endocrine disruptors.

Thank you.

Letter to Senators not yet cosponsoring:

I am writing to urge you to cosponsor S. 5070, the Relief for Farmers Hit with PFAS Act, to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill will authorize $500 million over FY 2023-2027 to the U.S. Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. I should note that this money, if appropriated, comes from taxpayers, not the manufacturers responsible for the contamination.

PFAS chemicals, also known as “forever chemicals,” are legacy contaminants whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

Since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while I urge you to pass this bill offering relief to farmers harmed by PFAS, we must also do all that we can to prevent further contamination.

I urge you to use your oversight of EPA to ensure that persistent toxic pesticides and other chemicals are no longer allowed to be released into the environment. Ensure that EPA carries out its responsibility to ensure that the pesticides it registers are not endocrine disruptors.

Thank you.

Letter to cosponsoring Representatives:

Thank you for cosponsoring H.R. 9186, the Relief for Farmers Hit with PFAS Act, to help farmers who have been adversely by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill authorize $500 million over FY 2023-2027 to the U.S. Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. I should note that this money, if appropriated, comes from taxpayers, not the manufacturers responsible for the contamination.

However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

I urge you to use your oversight of EPA to ensure that persistent toxic pesticides and other chemicals are no longer allowed to be released into the environment. Ensure that EPA carries out its responsibility to ensure that the pesticides it registers are not endocrine disruptors.

Thank you.

Letter to Representatives not yet cosponsoring:

I am writing to urge you to cosponsor H.R. 9186, the Relief for Farmers Hit with PFAS Act, to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. As indicated by the title of the bill, farmers have often been “hit with” legacy contaminants through no fault of their own, and the bill will authorize $500 million over FY 2023-2027 to the U.S. Department of Agriculture to help farmers, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms. I should note that this money, if appropriated, comes from taxpayers, not the manufacturers responsible for the contamination.

PFAS chemicals, also known as “forever chemicals,” are legacy contaminants whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

Since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while I urge you to pass this bill offering relief to farmers harmed by PFAS, we must also do all that we can to prevent further contamination.

I urge you to use your oversight of EPA to ensure that persistent toxic pesticides and other chemicals are no longer allowed to be released into the environment. Ensure that EPA carries out its responsibility to ensure that the pesticides it registers are not endocrine disruptors.

Thank you.

Letter to EPA Administrator and OPP:

The Maine Congressional delegation — Senators Collins (R) and Angus King (I), and Representatives Chellie Pingree (D) and Jared Golden (D), along with New Hampshire Senator Jeanne Shaheen (D), have introduced a bipartisan bill — the Relief for Farmers Hit with PFAS Act — to help farmers who have been adversely affected by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. The bills are the identical S. 5070 and H.R. 9186, both titled “Relief for Farmers Hit with PFAS Act.”

As you know, PFAS chemicals, also known as “forever chemicals,” are legacy contaminants whose historical use, including many decades ago in some instances, has led to their toxic persistence in the environment and in organisms. However, PFAS chemicals are not the only legacy contaminants. Others include wood preservatives, DDT, dioxins, and the termiticide chlordane. Unfortunately, some of these continue to be added to the environment, sometimes inadvertently, but also intentionally, particularly through pesticide use.

As indicated by the title of these bills, farmers have often been “hit with” legacy contaminants through no fault of their own, and these bills will provide funding to help farmers address the aftermath of the contamination, including: more capacity for PFAS testing for soil or water sources; blood monitoring for individuals to make informed decisions about their health; equipment to ensure a farm remains profitable during or after known PFAS contamination; relocation of a commercial farm if the land is no longer viable; alternative cropping systems or remediation strategies; educational programs for farmers experiencing PFAS contamination; and research on soil and water remediation systems, and the viability of those systems for farms.

However, since these legacy “forever chemicals” continue to be added to the environment, it is particularly important to stop their use. Many of them, like PFAS, are endocrine-disrupting chemicals, and EPA has neglected its duty to ensure that the pesticides it registers are not endocrine disruptors. Thus, while we urge Congress to pass bills offering relief to farmers harmed by PFAS, EPA has a duty to do all that it can to prevent further contamination.

I urge you to cancel the registrations of persistent toxic pesticides as well as those not shown to be free of endocrine-disrupting activity.

Thank you.

(Beyond Pesticides, November 4, 2022) Rural populations in the U.S., a new study finds, are particularly at risk for agriculture-related exposures associated with respiratory diseases and other kinds of airway inflammation. The exposures include those to pesticides, livestock facilities, smoke from biomass burning, agricultural dust, and endotoxin. The study paper also looked at potential protective roles for dietary DHA, and for raw milk consumption (early in life). Beyond Pesticides has regularly covered the relationships between pesticide exposures and asthma (including the outsized risks for children), COPD (chronic, obstructive pulmonary disease), and other respiratory anomalies. See our webpage on Pesticide-Induced Diseases: Asthma/Respiratory Effects for more information.

Published in Immunology and Allergy Clinics of North America [please note: this research paper is behind a paywall], and authored by a team from the Division of Allergy and Immunology at the University of Nebraska Medical Center in Omaha, the study used data from the past five years plus literature reviews of research on asthma and respiratory issues in rural populations. The team notes that multiple studies have suggested that “farming-related exposures as an adult increase the risk of asthma or asthma-like symptoms development,” adding that agricultural workers are exposed to “a complex working environment with associated disease outcomes dependent on the interplay of many factors, including genetics, gender, history of atopy [predisposition to immune response against a variety of antigens and allergens], duration of exposures, livestock diet, and pesticide exposures.”

Beyond Pesticides has reviewed the particular exposure risks farmworkers endure and health outcomes; for example, agricultural (and other) workers exposed to pesticides and other contaminants are at increased risk of developing a lung condition known as idiopathic pulmonary fibrosis.

The study researchers assert that, “When compared with those who live in metropolitan counties, dwellers of rural areas . . . have increased percentages of preventable deaths from the five leading causes of death (i.e., cancer, heart disease, unintentional injury, chronic lower respiratory disease, and stroke), with the largest disparity demonstrated from chronic respiratory disease.” They add, “Despite significant progress in farming technology, modern farming is still associated with many hazardous exposures, and is consistently identified as one of the most dangerous industries in which to work, from a health and safety perspective.”

The paper also notes that rural community members often have less access to appropriate health care and worse health outcomes than their urban cohorts, and points to barriers such as transportation problems, costs, concerns about immigration status, and language access. A 2021 study cited in the subject paper concluded that asthma mortality rates are significantly higher across all ages groups in areas with populations lower than 10,000 (with an average incidence rate of 13.4 per million residents) than in large metropolitan areas (at an average rate of 8.8 per million). This study and one from 2015 challenge the common perception that urban asthma rates are “off the charts” compared with rates in other areas.

According to the researchers, there is increasing evidence that pesticide exposures contribute to both allergic and nonallergic asthma and “wheeze.” The U.S. National Institutes of Health defines “wheeze” or “wheezing” as “the symptomatic manifestation of any disease process that causes airway obstruction. Wheezing is commonly experienced by people who have asthma but can also be present in individuals with airway foreign bodies, congestive heart failure, airway malignancy, or any lesion that causes narrowing of the airways.” In babies and young children, wheeze often is a clinical sign of lower respiratory problems, the “lower respiratory” tract comprising the lungs, bronchi, trachea, and larynx.

Farmworkers can be exposed to pesticides through direct inhalation or via contaminated dust during handling, mixing, or spraying (or other kinds of application). The authors cite a 2017 study that examined 78 pesticide compounds and their association with both allergic and non-allergic wheeze; of more than 22,000 male applicator participants, 6% manifested allergic wheeze, and 18%, non-allergic wheeze. Of the herbicides reviewed, nearly 42% were associated with a wheeze outcome; 36% of insecticides showed this relationship. The authors note that “although non-allergic wheeze was found to be three times as common as allergic wheeze, pesticide associations were stronger with allergic wheeze, potentially implying that pesticides have greater effects in atopic individuals.” Several other studies reviewed by the University of Nebraska team show significant effects of pesticide exposures on the respiratory health of participants.

The mechanisms that underlie these associational relationships are not well understood, say the authors. They point to the need for research on these dynamics; what is obvious is that both allergic responses and non-allergic responses share some form of immunological inflammatory reaction to pesticide (and other exacerbating) exposures.

The research team looked at impacts of exposures to livestock and any relationships to respiratory issues. Farmworker exposure to livestock and their environs appears to bump up the risk of developing asthma and COPD, as well as worsening existing asthma. Unclear are the origins of causal or exacerbating exposures; the authors ask, is it exposure to the animals themselves, or exposure to some organic materials (e.g., hay, straw, dust, animal feed) in the farm environs that contribute to the heightened risk?

The researchers do point to the noxious exposures that can come with working on CAFOs (Concentrated Animal Feeding Operations) — which sector Beyond Pesticides has repeatedly taken to task — such as gases (not least among which is the methane from animal waste), organic dusts, fungal spores, particulate matter, and whatever pathogens are “available” via the vast quantities of waste such facilities produce. Again, the paper cites several studies showing that incidence of asthma is higher not only for farmworkers, but for populations that live less than three miles from CAFOs, as compared with those who live farther away. Another research project, with more than 22,000 farmer subjects, found that raising livestock on medium-to-large scale operations was positively associated with symptoms of chronic bronchitis.

Next up on the list of problematic exposures of agricultural workers and rural populations is chronic inhalation of agriculture-related dust, which — in addition to the particulates it may contain from grains, feed, soils, and biological aerosols from plant and animal matter — may harbor synthetic pesticide and fertilizer residues. Ongoing inhalation of this dust is associated with increased incidence of airway inflammatory diseases, including asthma, chronic bronchitis, and COPD. The particulates in dust play a part in development of disease, but so, too, do the various microbiota that may be part of a dusty agricultural environment. A disruption of the homeostasis of the human microbiome (known as dysbiosis) has been associated with asthma and other respiratory diseases. In addition, pesticide exposures can alter the gut microbiome, which mediates a significant portion of human immune response. Currently, there is no treatment that can reverse respiratory diseases that arise from chronic agricultural dust exposures.

The researchers also conclude that endotoxin — primarily a lipopolysaccharide found in the outer membrane of Gram-negative bacteria — is found at higher levels in the indoor/household dust in rural farming communities, as compared with urban or rural non-farming areas. (An endotoxin is a toxin present inside a bacterial cell that is released when the cell disintegrates, and can be responsible for characteristic symptoms of a disease.) The common endotoxin, lipopolysaccharide, is known to interact with the human immune system, and to have an impact on asthma — amplifying its symptoms and those of COPD.

One of the particularly interesting studies the team reviewed show that, although other research has shown increased risk of asthma in adults with endotoxin exposures, children may experience some protection from asthma due to childhood endotoxin exposures. The 2016 study looks at children in two different farming communities — an Amish enclave in Indiana and a Hutterite community in South Dakota. The populations have similar ways of living, especially related to factors that might influence asthma, but exhibit a large difference in the prevalence of asthma. The disease rate in the Amish children was 5.2%, whereas for the Hutterite children, it was 21.3%. But that much lower level in the Amish cohort was true even though the endotoxin level in their homes was nearly seven times higher than in the Hutterite homes. The notable difference between the two communities is that the Amish live on single-family farms and use traditional farming practices, while the Hutterites live on large, communal farms and use industrialized agricultural practices.

Last on the “risk list” in this study are the respiratory impacts of the burning of biomass in agricultural areas. This burning can be the combustion of wood, crop residue, and/or animal waste as fuel, or the burning of crop residue in the field (sometimes called “stubble burning”) to clear it for the next round of planting. Both are associated with the airway inflammation of asthma and COPD. A study based in rural Arkansas compares emergency room visits for asthma and COPD between Craighead County, which burns roughly half of its production acreage post-harvest, and Sebastian County, which does not use any crop burning. ER visits for Craighead were 21% higher for asthma and 17% higher for COPD, compared with Sebastian. Unsurprisingly, particulate matter (PM) levels were significantly elevated in Craighead — but only during the fall season.

As for potentially protective nutritional impacts on chronic lung disease: the research team reviewed several studies from which it concludes that consumption of dietary DHA (docosahexaenoic acid, a polyunsaturated omega-3 fatty acid) may help reduce airway inflammatory disease in those exposed to agricultural dusts. It also evaluated a study that suggests that consumption of raw milk early in life translates to better pulmonary function in adulthood, though the mechanisms for either of these effects is not yet understood.

The subject study identifies multiple factors that appear to exacerbate or contribute to development of chronic respiratory issues — asthma (both allergic and non-allergic), chronic bronchitis, and COPD chief among them — in both farmworkers and residents of rural communities. Read more about conditions for farmworkers, and their communities, on Beyond Pesticides Agricultural Justice webpage.

This research on rural environmental factors in respiratory disease reinforces Beyond Pesticides’ call for the transition to organic regenerative agricultural practices that do not involve the use of synthetic pesticides and fertilizers, or the terrible conditions that attend CAFO operations, including impacts of their waste “management.” Human health would benefit from the transition to organic, as would climate, biodiversity, and broad environmental health.

Source: https://www.sciencedirect.com/science/article/abs/pii/S0889856122000406?via%3Dihub

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

(Beyond Pesticides, November 3, 2022) In a fight against global warming, environmental groups Center for Biological Diversity (CBD) and Californians for Pesticide Reform (CPR) filed a formal legal petition in October 2022 urging the California Air Resources Board (CARB) to phase out the use of sulfuryl fluoride insecticides. Sulfuryl fluoride is a fluoride compound with various adverse health effects, including cancer, endocrine disruption, neurotoxicity (reduced IQ), and reproductive damage. CARB added sulfuryl fluoride to its list of “short-lived climate pollutants,” being the only state to do so since 1990. However, California does not include sulfuryl fluoride in the list of GHG emissions to reduce by 2020 as researchers were unaware the chemical was a greenhouse gas (GHG) until 2008. These termite and food use insecticides are 4,800 times more potent GHG than carbon dioxide at trapping carbon in the atmosphere. Furthermore, sulfuryl fluoride has high global warming potential and can remain in the atmosphere for more than 36 years.

The case of sulfuryl fluoride presents an all too familiar pattern of widespread chemical use without proper knowledge of health and environmental effects before implementation and a failure to take regulatory action on known hazards after allowed in commerce. Therefore, CBD’s environmental health legal director Johnathan Evans, senior attorney, states, “Phasing out sulfuryl fluoride would provide the same climate benefits as taking one million cars off our roads every year… California’s air regulators have a legal and moral obligation to reduce greenhouse gases that are helping to drive catastrophic global warming.”

Sulfuryl fluoride, registered for termite and other wood-boring pest extermination in 1959, gained additional attention as a potential alternative to methyl bromide, a broad-spectrum insect fumigant. Ninety-nine percent of structural fumigation treatments use sulfuryl fluoride. However, researchers have identified concentrations of sulfuryl fluoride in the atmosphere due to the chemical’s long half-life and greenhouse warming potential (GWP). Recent work from the Massachusetts Institute of Technology (MIT) demonstrates North America was the leading global source of sulfuryl fluoride emissions in 2019. The risk of multiple chemical contaminants in the atmosphere increases as global warming progresses. Melting glaciers can release persistent organic pollutants into waterways. Recently, pesticides and fertilizers overtook the fossil fuel industry in environmental sulfur emissions. Thus, health and environmental concerns will increase significantly, especially for individuals and ecosystems more vulnerable to the toxic effects of chemical exposure.

Following the 2022 report, “Termite Fumigation in California Is Fueling the Rise of a Rare Greenhouse Gas,” researchers demonstrate that sulfuryl fluoride increases greenhouse gas (GHG) emissions. Although most sulfuryl fluoride emissions in the U.S. occur in California, most global emissions also occur in California. According to the most recent data from the California Department of Pesticide Regulations, sulfuryl fluoride is the 12th most used pesticide applied to sites across California, with over 2.9 million pounds used in 2018 for structural and agricultural pest control and over three million pounds used statewide in 2021. Although 50 to 60 percent of sulfuryl fluoride emissions mainly occur in California, researchers suggest that other states, like Florida, may also produce emissions that remain unaccounted for by current National Oceanic and Atmospheric Administration (NOAA) chemical tracking.

Similar to this petition, Beyond Pesticides, and others maintain that without the phase-out of sulfuryl fluoride, there will be no incentive for grain storage facilities to upgrade and adopt modern practices that forego hazardous chemical use. In addition to the phase-out of sulfuryl fluoride, the petition also seeks to add this fumigant to California’s greenhouse gas emission inventory for better monitoring.

The history of sulfuryl fluoride has pitted one chemical use against another, instead of incentivizing movement away from chemical dependency to viable alternative and organic management practices. For example, in 2011, the Natural Resources Defense Council (NRDC) sent a letter to EPA stating its opposition to EPA’s phase-out of the toxic fumigant pesticide, which is marketed as a substitute for the outdated, ozone-depleting methyl bromide. EPA’s action was in response to a 2006 petition from Fluoride Action Network (FAN), Beyond Pesticides, and Environmental Working Group (EWG). According to its letter, NRDC believes that the “proposed action will imperil EPA’s ability to complete the long-overdue phase-out of methyl bromide, leading to prolonged and increased depletion of the ozone layer, higher levels of ultraviolet radiation, and higher risks of cancer, cataracts, and immunological disorders.” NRDC was objecting to EPA’s announcement to cancel all allowable pesticide residue levels (tolerances) for sulfuryl fluoride over three years, effectively banning its use in January 2014.

The agency found that when residues on food products are combined with fluoridated drinking water and toothpaste, aggregate exposure levels are too high. Beyond Pesticides has repeatedly pointed to nontoxic practices that have eliminated the need for either hazardous fumigant throughout the petition process. Despite this, in 2014, buried in the Agriculture Act of 2014 (the “Farm Bill”), Congress adopted an amendment at the behest of those seeking to keep sulfuryl fluoride on the market that prohibited EPA from moving against the chemical. For a more in-depth history on this, see When Politics Trumps Science and Health Suffers.

The current petition concludes, “Now that it is known and well supported by science that sulfuryl fluoride is a highly potent greenhouse gas that can remain in the atmosphere for 36 years, and there are viable alternatives to the fumigant, Petitioners request that CARB 1) initiate a rulemaking to include sulfuryl fluoride in California’s annual statewide greenhouse gas inventory pursuant to AB 32 and 2) initiate a rulemaking to phase out the use of sulfuryl fluoride.”

As the climate emergency continues, banned and current-use pesticides put human and animal health at risk upon release into the atmosphere and waterways. If pesticide use and manufacturing amplify the impacts of the climate crisis, advocates argue that pesticide policy and regulation must address and eliminate chemical use. There are many viable alternatives to sulfuryl fluoride and methyl bromide fumigation. These alternatives include temperature manipulation, atmospheric controls, biological controls, and less toxic chemical controls (diatomaceous earth). Many existing commodity storage facilities are too old and outdated to prevent pest infestation. This ineffectiveness leads to a reliance on toxic fumigation. Thus, a clean, regularly-maintained storage or processing facility can easily keep facilities pest-free.

The European Union already bans sulfuryl fluoride from any food contact. Thus, switching from chemical-intensive agriculture to regenerative organic agriculture can significantly reduce the threat of the climate crisis by eliminating toxic, petroleum-based pesticide use, building soil health, and sequestering carbon. Current organic food production and handling do not permit conventional pesticide use, including fumigants like sulfuryl fluoride. Therefore, organic production reduces greenhouse gas emissions from chemical use. Learn more about how switching to organic management practices can mitigate the climate crisis by reading Regenerative Organic Agriculture and Climate Change: A Down-to-Earth Solution to Global Warming. For more information about organic food production, visit Beyond Pesticides’ Keep Organic Strong webpage. Learn more about the adverse effects chemical-intensive farming poses for various crops and how eating organic produce reduces pesticide exposure and benefits the environment.

For more discussion, background, and strategy on fighting the climate crisis through the elimination of petro-chemical pesticides and fertilizers, attend Health, Biodiversity, and Climate: A Path for a Livable Future, the 2022 National Forum Climate Session on November 29, 2022, which will feature two speakers: Rachel Bezner Kerr, PhD, noted professor in Global Development at Cornell University (and Coordinating Lead Author for the United Nations Intergovernmental Panel on Climate Change report Climate Change 2022: Impacts, Adaptation, and Vulnerability); and Andrew Smith, PhD, chief operating officer at the Rodale Institute and coauthor of the report Regenerative Organic Agriculture and Climate Change.

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

Source: CBD Report, CBD Petition

(Beyond Pesticides, November 2, 2022) Inert ingredients called “amines” that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research recently published in Environmental Science and Technology. The findings and implications for public health are unexpected, as research until now has not considered herbicide use as a source of amine emissions. “Researchers have looked at industrial applications, animal operations and environmental sources of amines, but no one has looked at herbicides at all, as far as we have seen, despite the fact that large quantities of herbicide-amine mixtures are being sprayed onto crops across the country,” said study author Kimberly Parker, PhD, of Washington University in St Louis (WUSL). “We were really surprised to see that this source had been overlooked.”

Amines are chemical compounds derived from ammonia and often added to herbicide formulations for glyphosate, dicamba, and 2,4-D products to increase solubility and reduce volatilization. In theory, amines reduce volatilization by forming herbicide-amine salts which lock the herbicide vapors in place. However, the team of scientists conducting this research had previously found evidence that even new forms of dicamba billed by the agrichemical industry as “low volatility,” and restricted to formulations that include very specific amines, continued to cause drift problems for farmers.

This led first author Stephen Sharkey, a PhD student at WUSL to a question: “If the dicamba is volatilizing, what’s happening to the amine that’s supposed to be there stopping the volatilization process?”

In order to answer this question, researchers conducted an experiment measuring amine and herbicide losses from herbicide-amine salts. Various solutions containing glyphosate, 2,4-D, or dicamba, and combinations of these herbicides along with combinations of different amine compounds were analyzed by placing them in a glass beaker and drying them under a fume hood in the laboratory for 24 hours. After another 24 hours the beakers were then measured to determine lost residues. This process was repeated at different temperatures using a hot plate to replicate warmer conditions.

Initial testing on 2,4-D and the amine dimethylamine at room temperature saw a roughly 25% loss in dimethylamine but no significant loss of 2,4-D. As part of further testing using a process known as thermal desorption gas chromatography-mass spectrometry, researchers were able to measure the amine loss as it volatilized above a glyphosate formulation. Generally, more amines than herbicide residues were lost during the drying process, but this shifted slightly under higher temperatures. With increasing heat, researchers found both higher amine releases, and evidence of increased herbicide volatility, reinforcing earlier studies.  

To understand the aggregate impacts of amine volatility, scientists integrated herbicide use estimates from the US Department of Agriculture and US Environmental Protection Agency to model their atmospheric release. With half of glyphosate, 44% of 2,4-D, and nearly 90% of dicamba use employing an amine-based product formulation, the study estimates that herbicide use releases approximately 4,000 metric tons of amines in the US annually. When considering the use of these herbicides in other countries, as US applications account for only roughly 12% of global use, herbicide amine emissions can be compared to the 285,000 metric tons of amines globally recorded as released into the atmosphere each year from other sources, such as industrial manufacturing and livestock emmissions.

“There has been extensive work looking at the different ways in which amines enter the atmosphere. There has been a lot of effort put into understanding where amines come from, but research into its use with herbicides just wasn’t considered before,” said Dr. Parker.

Despite their listing as an “inert” ingredient, amines are toxicologically active substances. Once present in the atmosphere, amine vapors oxidize and form nitrosamines and nitroamines, which are potent carcinogens. Their release and transformation in the atmosphere likewise results in the creation of fine particulate matter that can affect heart and lung health.

While amines may be capturing some of an herbicide in formulation, it is clear through this research that drift is still occurring, merely with a different hazardous compound. Yet again, advocates note that the pesticide industry’s solution to a problem has created a new problem. This continues along the agrichemical industry’s modus operandi: privatize profits while publicizing harm to public health and the environment.  

As scientific studies continue to uncover a myriad of novel dangers herbicides and other pesticides present, it has become increasingly evident that an alternative approach is needed. The growth and success of organic regenerative agriculture that does not employ the use of amine formulated herbicides like glyphosate, 2,4-D, and dicamba reveals the most viable path for a sustainable farming future. Help promote an organic future for farming by taking action today.

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

Source: Washington University in St Louis press release, Environmental Science and Technology

(Beyond Pesticides, November 1, 2022) Honey bees exposed to a combination of multiple pesticides suffer a reduced lifespan and experience adverse changes to their gut microbiome, increasing susceptibility to pathogens and disease. This finding comes from a study published recently in Science of the Total Environment, which examines the interactions between the insecticides flupyradifurone and sulfoxaflor and the fungicide azoxystrobin on honey bee health. Both insecticides studied are considered substitutes for notorious bee-killing neonicotinoid insecticides, which move through the vascular system of the plant and contaminates its pollen, nectar, and guttation droplets. As declines in pollinator and insect life continue throughout the world, it is critical not only to understand and restrict widely used chemicals like neonicotinoids, but also the regrettable and deleterious substitutions the agrichemical industry has developed to replace them. As the present study reveals, pesticide risk assessments do not inadequately capture the range of harm that can result when pesticides are combined, necessitating a shift toward safer, alternative, and regenerative organic farming systems that do not use these dangerous chemicals.

To better understand the impacts of combined pesticide exposure on honey bees, researchers employed three colonies located in Germany’s Martin Luther University that were inspected and free of mites and viruses. Technical grade versions of each pesticide were used, eliminating additional confounders that could occur in consumer use products that also include “inert” (non-disclosed) ingredients.  

Bees were exposed to field relevant levels of each pesticide per U.S. Environmental Protection Agency (EPA) data, as well as combinations of pesticides, (specifically: flupyradifurone plus azoxystrobin and sulfoxaflor plus azoxystrobin) for a period of 10 days through sugar water. A separate experiment on the honey bee gut microbiome was constructed using newly emerged bees, which were housed and reared separately, and then exposed to a similar pesticide treatment as the initial experiment. An unexposed control group of honey bees was included in each experiment. “Our approach was based on the realistic concentrations that might be found in pollen and nectar from plants that have been treated with the pesticides,” says study coauthor Yahya Al Naggar, PhD, of Martin Luther University.

For the initial experiment on individual bees, those exposed to flupyradifurone fared the worst, experiencing significantly reduced survival (50% reduction). The addition of azoxystrobin did not significantly add to this effect. However, with sulfoxaflor, it did. Bees subjected to sulfoxaflor and azoxystrobin in combination experienced significantly reduced survival when compared to a sole sulfoxaflor exposure.

While direct mortality is disturbing, the pesticide induced alterations inflicted on the bees’ guts are a more insidious problem. Impacts to the gut are not seen within the first five days after pesticide exposure, but significant shifts did occur between days five and 10. At this time, treatments of flupyradifurone alone and in combination with azoxystrobin, as well as treatments of sulfoxaflor alone and in combination with azoxystobin show significantly increased abundance of Serratia spp. This rod-shaped bacteria can serious harm honey bee fitness. “These bacteria are pathogenic and harmful to bees’ health,” said Dr. Al Naggar. “They can make it harder for the insects to fight off infection, leading to premature death.”  

The ability for insecticides alone and in combination to cause delayed gut dysbiosis in honey bees is not an effect that an EPA pesticide risk assessment would ever capture under current data requirements. EPA requires very basic screening level tests initially, and more detailed tests only if these tests indicate a need. Yet in context, while any testing is better than none, many advocates question the value of EPA protocols when initial screening is so lackluster. Case in point, both flupyradifurone and sulfoxaflor have been marketed by the agrichemical industry as “safer for bees,” despite having effectively the same mode of action as bee-killing neonicotinoids. And data since their EPA registration has backed up the concerns of pollinator advocates. In fact, EPA was sued over its approval of sulfloxaflor, and rather than accept the court’s decision to vacate the chemical’s registration, EPA went ahead and registered the chemical again. As a result, beekeepers and conservations groups are back in court yet again to stop this bee-killing decision. With flupyradifurone, this is now the second study showing that the chemical causes signficantly more harm to bees when used in combination with a fungicide. Per a 2019 study, combinations of flupyradifurone and the fungicide propiconazole resulted in 73% mortality and increased abnormal behavior among exposed bees. Despite these concerns EPA has facilitated the expanded use of the chemical.  

The combined impacts of different pesticides and how they may adversely affect the gut microbiomes of the animals we rely on to pollinate our food is something EPA should be at the cutting edge of investigating. Yet, the agency has consistently refused to implement measures that would investigate, let alone address these risks. As a result, more and more advocates, communities, and states are taking action to protect their pollinator populations. While many advocates and communities are embracing organic land care and eliminating all toxic pesticides, many states have merely restricted the neonicotinoids, permitting use of flupyradifurone, sulfoxaflor, and other equally harmful substitutes to continue. To meaningfully address the pollinator crisis, we need a team of pollinator experts to review the science and make recommendations to EPA. That is what the Saving America’s Pollinators Act would accomplish. Help bring this law into force by taking action today and telling your member of Congress to join in as a cosponsor.

For more information on the dangers pesticides pose to pollinators and what you can do see Beyond Pesticides Bee Protective webpage.

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

Source:  Martin Luther University press release, Science of the Total Environment

(Beyond Pesticides, October 31, 2022) Just as the Environmental Protection Agency (EPA) issued a request for information on improving indoor air quality, it approved 32 varieties of a new “air sanitizer” to kill bacteria and viruses in the air. These products contain 14% dipropylene glycol and 86% secret (“other”) ingredients, including fragrances.

Tell EPA that clean air, NOT “sanitized” air, protects against disease.

Through its approval of such sanitizers, EPA promotes the false reasoning that a chemical that kills a pathogen necessarily protects health. Although disinfectants and sanitizers kill viruses, bacteria, and other microbes, they can also negatively affect the immune system, thus reducing resistance to disease. People who have a preexisting condition or are of advanced age, who may have a weakened immune or respiratory system, are more vulnerable to the effects of the virus. Children are at elevated risk from exposure. When managing viral and bacterial infections, chemicals that exacerbate the risk to vulnerable individuals are of serious concern.

EPA opened a 60-day public comment period “to solicit information and recommendations from a broad array of individuals and organizations with knowledge and expertise relating to the built environment and health, indoor air quality, epidemiology, disease transmission, social sciences and other disciplines.” EPA’s request for information says it is “seeking input . . . about actions, strategies, tools and approaches that support ventilation, filtration and air cleaning improvements, and other actions that would promote sustained improvements in indoor air quality in the nation’s building stock to help mitigate disease transmission.” A new, airborne pesticide for indoor use is the opposite of what is needed.

Although dipropylene glycol, the active ingredient in the newly-approved air sanitizers, is considered less toxic than other chemicals, it may cause more problems when inhaled. These products contain 86% secret ingredients, including fragrances. Fragrances are known to trigger adverse respiratory effects.

Efficacy and creating a false sense of security is also of serious concern. The label directions instruct users to spray the chemical for 30 seconds and leave the room empty and closed-up for 12 minutes. Given that airborne viruses are being constantly introduced and reintroduced into public spaces, such as stores, schools, restaurants, and public spaces, the virus may continue to be transmitted through indoor air unless there is adequate ventilation and filtration. So, in this public context, a sanitizer application to an indoor space only protects against the target virus as long as the building is not used by the public.

EPA should focus its efforts on methods of providing increased ventilation without introducing additional chemicals into the indoor atmosphere. Ventilation with clean fresh air has been shown to reduce exposure to airborne viruses.

This action requires you to post a comment to Regulations.gov. Follow this link and type or paste in a comment. A suggested comment can be found below.

Suggested comment to EPA:

I am concerned that EPA’s request for information on improving indoor air quality coincides with the approval of 32 varieties of a new pesticide (“air sanitizer”) to kill bacteria and viruses in the air. These products contain 14% dipropylene glycol and 86% secret (“other”) ingredients, including fragrances.

Through its approval of such sanitizers, EPA promotes the false reasoning that a chemical that kills a pathogen necessarily protects health. Although disinfectants and sanitizers kill viruses, bacteria, and other microbes, they can also negatively affect the immune system, thus reducing resistance to disease. People who have a preexisting condition or are of advanced age, who may have a weakened immune or respiratory system, are more vulnerable to the effects of the virus. When managing viral and bacterial infections, chemicals that exacerbate the risk to vulnerable individuals are of serious concern.

EPA seeks “input . . . about actions, strategies, tools and approaches that support ventilation, filtration and air cleaning improvements, and other actions that would promote sustained improvements in indoor air quality in the nation’s building stock to help mitigate disease transmission.” A new, airborne pesticide for indoor use is the opposite of what is needed.

Although dipropylene glycol, the active ingredient in the newly approved air sanitizers, is considered less toxic than other chemicals, it may cause more problems when inhaled. These products contain 86% secret ingredients, including fragrances. Fragrances are known to trigger adverse respiratory effects.

Efficacy and creating a false sense of security is also of serious concern. The label directions instruct users to spray the chemical for 30 seconds and leave the room empty and closed-up for 12 minutes. Given that airborne viruses are being constantly introduced and reintroduced into public spaces, such as stores, schools, restaurants, and public spaces, the virus may continue to be transmitted through indoor air unless there is adequate ventilation and filtration. So, in this public context, a sanitizer application to an indoor space only protects against the target virus as long as the building is not used by the public.

EPA should not approve “air sanitizers” with the false hope of controlling bacteria and viruses in the air. EPA should focus its efforts on methods of providing increased ventilation without introducing additional chemicals into the indoor atmosphere. Ventilation with clean fresh air has been shown to reduce exposure to airborne viruses.

(Beyond Pesticides, October 28, 2022) The Maine Congressional delegation — Senators Collins (R) and Angus King (I), and Representatives Chellie Pingree (D) and Jared Golden (D) — along with New Hampshire Senator Jeanne Shaheen (D), have introduced a bipartisan and bicameral bill — the Relief for Farmers Hit with PFAS Act — to help farmers who have been impacted by the scourge of PFAS (perfluoroalkyl and polyfluoroalkyl substances) chemicals. (The Senate version of the bill is available; the House version should be soon.) PFAS contamination has, as Beyond Pesticides documented in two Daily News Blog articles (here and here), become a huge, life-altering problem for agricultural producers in Maine and many other states. An early 2022 Safer States analysis of state-level legislation on PFAS demonstrated the extent of the problem via the response: more than 32 states have begun to act on the issue. Beyond Pesticides has covered the presence of PFAS in pesticides and pesticide containers, and in so-called “biosludge” or “biosolids”— realities that only reinforce the call for a rapid transition off of chemical-dependent agriculture and to regenerative organic agricultural practices that do not carry the enormous health and environmental risks of pesticide products and contaminated fertilizers.

There are more than 9,000 synthetic (human-made) chemical compounds in the PFAS family, which includes the most-well-known subcategories, PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid). These PFAS compounds, dubbed “forever chemicals” for their persistence in the environment (largely because they comprise chains of bonded fluorine–carbon atoms, those bonds being among the strongest ever created). This class of synthetic chemicals, found in drinking water, surface and ground water, waterways, soils, and the food supply, among other sources, is emerging as a ubiquitous and concerning contaminant across the globe. PFAS contamination of drinking water resources is a serious and growing issue for virtually all U.S. states, as Environmental Working Group (EWG) demonstrates via its interactive map, and for hydrologic ecosystems around the world.

The widespread presence of these compounds arises from multiple sources:

• extensive “legacy” (historic) use in fabric and leather coatings, household cleaning products, firefighting foams, stain-resistant carpeting, and other products
• historic and current industrial uses in the aerospace, automotive, construction, and electronics sectors
• current uses in many personal care products (e.g., shampoo, dental flosses, makeup, nail polish, some hand sanitizers, sunscreens); water-and-stain-proof and -resistant fabrics and carpeting; food packaging; and non-stick cookware, among others

Although some of these uses have been phased out over the course of the past couple of decades, many persist, including several related to food processing and packaging. The flooding of the materials stream with thousands of these synthetic, persistent PFAS compounds since their first uses in the 1950s (notably by 3M) means that they remain widespread in the environment and in human bodies. People can be exposed to PFAS compounds in a variety of ways, including occupationally, through food sources, via drinking contaminated water (another enormous emerging issue; see below), ingesting contaminated dust or soil, breathing contaminated air, and using products that contain, or are packaged in materials that use, the chemicals.

The U.S. Environmental Protection Agency (EPA) notes on one of its webpages that, “because of their widespread use and their persistence in the environment, many PFAS are found in the blood of people and animals all over the world and are present at low levels in a variety of food products and in the environment. PFAS are found in water, air, fish, and soil at locations across the nation and the globe. Scientific studies have shown that exposure to some PFAS in the environment may be linked to harmful health effects in humans and animals.” Among the potential health risks of some PFAS compounds for humans are:
• impacts on the immune system (including decreased vaccine responses)

• endocrine disruption
• reproductive impacts, including lowered infant birth weight
• developmental delays in children
• increased risk of hypertension, including in pregnant people (eclampsia)
• alterations to liver enzymes
• increased risk of some cancers, including prostate, kidney, and testicular
• increase in circulatory cholesterol levels
• increased risk of cardiometabolic diseases(via exposure during pregnancy)
• possible increased risk of COVID-19 infection and severity

After years of advocate pressure, EPA in August proposed to “to designate two of the most widely used per- and polyfluoroalkyl substances [— PFOA and PFOS —] as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as ‘Superfund.’” That designation should mean that polluters must be more transparent about their pollution, and be held accountable for cleanup of their PFAS contamination. EPA took the step pursuant to its recognition of “significant evidence that PFOA and PFOS may present a substantial danger to human health or welfare or the environment. PFOA and PFOS can accumulate and persist in the human body for long periods of time and evidence from laboratory animal and human epidemiology studies indicates that exposure to PFOA and/or PFOS may lead to cancer, reproductive, developmental, cardiovascular, liver, and immunological effects.”

In addition, in June 2022 EPA issued interim updated drinking water health advisories for two PFAS compounds — perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) — replacing those issued in 2016. The agency also issued final health advisories on two others that had been considered “replacement” chemicals for manufacturing uses: perfluorobutane sulfonic acid and its potassium salt (PFBS), and hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (the so-called “GenX chemicals”).

In June 2022, EPA set “acceptable” exposure levels for PFOA and PFOS at 0.004 and 0.02 parts per trillion, respectively. These are lower than generally detectable levels (absent new, more-sensitive tests), so EPA now encourages municipalities or other water-supply entities to take action against PFOA and PFOS should any level be detected in a drinking water system. (See EPA’s factsheet here.) Guidelines in individual states, if they even exist, are generally much higher than these new EPA parts-per-trillion levels.

PFAS compounds have been found to contaminate water and irrigation sources, and soils themselves — often through the use of fertilizers made from so-called “biosludge” from local waste treatment plants. In addition, these plants may discharge millions of gallons of wastewater into waterways, contaminating them; current waste and water treatment does not generally eliminate PFAS compounds from the treated effluent water. (Some water providers are now piloting PFAS remediation protocols, though they are currently both challenging and quite expensive.) Biosolids and wastewater have long been sources of exposure concerns related to pesticides, industrial chemicals, pharmaceuticals, personal care products, and household chemicals; PFAS contamination is now rising as a specific and concerning addition to that nasty list.

EWG wrote, earlier in 2022, that these forever (and perhaps “everywhere”) compounds may be contaminating nearly 20 million acres of productive agricultural land in the U.S. A significant portion of producers, perhaps 5%, is using biosludge from local treatment plants as fertilizer on their acreage. Use of biosludge was thought by many, a decade ago, to be a sensible use of the waste products from treatment; it was even encouraged by many state agricultural department programs. Fast forward to the current recognition that these products have no business being spread on fields that produce food — or perhaps anywhere that presents the possibility of human, organism, or environmental exposures to potentially toxic PFAS compounds. It is notable that there are currently no federal requirements to test such sludge for the presence of PFAS.

The agricultural sector is increasingly experiencing very serious impacts from these compounds. Senator Collins, in her office’s news release on the bill she and Congressional colleagues filed, noted, “PFAS contamination has prevented some Maine farms from selling their products, creating financial hardship for many family farmers. In 2016, a dairy farmer in Arundel discovered that the milk produced on his farm contained some of the highest levels ever reported for a PFAS contaminant. In 2020, a dairy farm in Fairfield found PFAS levels in its milk were 153 times higher than the Maine standard. An organic vegetable farm in Unity uncovered PFAS contamination last year, and the couple who farmed the land have higher PFAS levels in their blood than chemical plant workers who manufactured PFAS for decades. Numerous other Maine farmers have had their livelihoods disrupted due to PFAS contamination.”

Beyond Pesticides wrote about two of the instances Senator Collins references. One is the devastation of one organic Maine farm, Songbird Farm in Unity, which learned in 2021 that its well water tested at 400 times the state’s recommended threshold for PFAS compounds. The farmers’ land, livelihood, and health are at stake, with few supports in place (at the time) to help them through this crisis. Another is an Arundel, Maine dairy farmer who has, for years, been testifying to the state legislature about the ruination of his multi-generational dairy operation by the discovery of PFAS in his water and soils, and in his cows’ milk — largely attributable, he says, to the wholesale contamination of the biosludge he had used on his silage crop fields for years.

The federal government has been slow to acknowledge and act on the threats of PFAS. With the advent of the Biden administration, that has begun to change. In 2021, EPA Administrator Michael Regan announced the PFAS Strategic Roadmap, which purports to lay out a whole-of-agency approach to addressing the multiple PFAS problems. (Read about the Roadmap here.) When Beyond Pesticides covered the PFAS (and other legacy chemicals) crisis, we wrote, “For states and localities, who are on the front lines of PFAS contamination, this is welcome news and significantly tardy. Absent much protective action on forever chemicals at the federal level . . . states have been stepping up, particularly in the past five years or so, to deal with a problem that permeates many aspects of people’s lives.”

The bill proposed in Congress (S. 5070) aims to create and fund grant programs that, administered by states, will provide:

• health monitoring for affected farms, farmers, and families
• medical care for farm workers and families exposed to PFAS, and for anyone who experiences exposure-related health effects or has a blood level higher than that of the general U.S. population
• relocation assistance for farms found to be PFAS contaminated
• compensation for contaminated land or farm products
• investments in equipment, facilities, and infrastructure to help farmers transition to different cropping approaches, implement remediation strategies, and/or switch to an alternate revenue stream (with a focus on combing solar generation with agricultural uses)
• help with income replacement and mortgage payments
• improved PFAS testing and data management for states
• support for research to quantify the impact of PFAS on commercial farms and agricultural communities

Senator Collins commented on the need for the proposed bill, “USDA needs to step up and provide support to farmers, who at no fault of their own, are at risk of losing their livelihoods. This is not just a problem in Maine — PFAS contamination has been discovered on farms in New Mexico and Michigan [and elsewhere], and this problem will only become more evident as testing becomes more readily available. Thus far, the federal government’s response has failed to keep pace with this growing problem.”

Senator Shaheen added, in her press release, “The more we look for PFAS, the more we understand how widespread these chemicals are, and unfortunately our farming community is no exception. That’s why it’s imperative that we have a robust federal response for industries and communities that have been adversely impacted. . . . This bipartisan, bicameral proposal is a comprehensive approach to help farmers who’ve been hard hit by PFAS exposure, and it addresses everything from educational programs for individuals affected to increased water and soil testing and remediation. Our farmers face enough challenges and adversity from uncontrollable shifts in our climate and economy — reacting to an expansive and troubling issue like PFAS contamination shouldn’t be another hurdle they have to face alone.”

Beyond Pesticides commends these legislators for filing this bill, which would, if passed and enacted, bring significant help to agricultural producers and their communities affected by PFAS. These groups currently are struggling to deal with the devastating discoveries of contamination of their soil, water sources, and/or agricultural products, largely without much governmental support. Beyond Pesticides’ only recommendation might be to specify that the “transition to different cropping approaches” would wisely require the transition to organic systems.

For its part, Maine has been more proactive than most states on PFAS; the state legislature, for example, passed a bill in early 2022 to ban the use of pesticides and fertilizers contaminated with PFAS. It has also passed a bill to reduce toxic chemicals in packaging, and another that will ban the sale or distribution of carpets, rugs, or fabric treatments that use PFAS compounds (effective 2023), and in 2030, the use of PFAS in all consumer products in the state.

Meanwhile, according to Maine Public (radio), the Maine Department of Environmental Protection is now testing more than 700 sites in the state considered at high risk for PFAS contamination because they were licensed to receive applications of municipal biosludge. PFAS contamination has been found at more than 40 Maine farms (as a result of biosludge fertilizer applications). Maine Public reports, in addition, that “hundreds more private drinking wells — as well as some school drinking water supplies — have . . . been found to be contaminated. In response, the administration of Gov[ernor] Janet Mills and state lawmakers have earmarked $100 million for PFAS testing, response, remediation and research in recent years.”

Responding to the proposed federal legislation, Maine Organic Farmers and Gardeners Association Executive Director Sarah Alexander said, “I think this [proposed federal] legislation is really critical for setting a safety net for farmers . . . because we know that the problem of PFAS contamination on agricultural lands is not specific to Maine. We just happen to be the first state that’s looking for it.” She also noted that the federal bill mirrors some initiatives underway as the Maine response to increasing numbers of PFAS hotspots linked to contaminated sludge.

The “meta” issue, about which Beyond Pesticides wrote earlier this year, continues to be relevant: “These most-recent PFAS discoveries, and state legislative efforts to deal with them, underscore not only the [historical] federal failures, but also, the urgency and gravity of realigning federal and state agencies so that precaution becomes the guiding watchword. Legacy/forever chemical contamination is a dramatic demonstration of how the historical, non-precautionary ethic in the U.S. can cause egregious harm — even years and decades hence. Government regulation should, at the very least, stop making the problem worse through continued permitting of the use of PFAS compounds and toxic pesticides.”

Sources: https://www.mainepublic.org/environment-and-outdoors/2022-10-24/maines-congressional-delegation-seeks-federal-support-for-farmers-grappling-with-pfas and https://www.collins.senate.gov/newsroom/maine-delegation-introduces-bill-to-support-farmers-affected-by-pfas

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

(Beyond Pesticides, October 27, 2022) A study published in Environment International adds to the growing body of research evaluating the association between neonicotinoid insecticides (neonics/NIs) and breast cancer. Past studies suggest neonics act as endocrine disruptors, affecting the development and regulation of estrogen hormones that promote breast cancer. However, this study is one of the few to evaluate the toxicological and molecular mechanisms involved in initiating breast cancer events. According to the Centers for Disease Control and Prevention (CDC), breast cancer is a disease that causes breast cells to grow out of control, with the type of breast cancer depending on the cells themselves. Most common forms of breast cancer have receptors on the cell surface that can increase cancer growth when activated by estrogen, progesterone, or too much of the protein called HER2. One in ten women will receive a breast cancer diagnosis, and genetics can only account for five to ten percent of cases.

When a cancer cell lacks receptors for these molecules, G protein-coupled estrogen receptors (GPERs) are an essential biological target of estrogen and plays a role in hormone-dependent cancer development. GPERs regulate estrogen through non-genetic cellular pathways, forgoing attachment to standard molecular receptors, leading to triple-negative breast cancer (TNBC). Although past studies suggest genetic and environmental factors interact to produce these differences in breast cancer outcomes, genetic factors only play a minor role, while disparities (differences) in external factors (i.e., chemical exposure) may play a more notable role.

Studies like this highlight the significance of understanding how chemical exposure drives disease outcomes and increases disease risk, especially when disease biomarkers are not genetic. The study notes, “[…]NIs could promote breast cancer progression at human-related exposure levels, which was owing to the activation and up-regulation of GPER. We found a novel estrogenic disruption molecular mechanism of NIs and revealed NIs’ potential female adverse effects via GPER pathway, which are expected to provide a new theoretical basis for the health risk assessment and safe usage of NIs.”

The researchers suggest upregulation of GPER is a biomarker for breast cancer, specifically triple-negative breast cancer (TNBC), which has a higher rate of recurrence and worse clinical outcomes than other breast cancers. External estrogen and synthetic compounds sources can stimulate GPER up-regulation and activation in cancer cells. However, the cells in TNBC lack receptors for estrogen or progesterone hormones, as well as limited HER2 protein occurrence. Therefore, TNBC does not respond to hormonal therapy medicines or medicines that target the HER2 protein.

The study evaluates the activity of seven neonics on the GPER pathway using a calcium mobilization assay. The seven neonics include thiamethoxam, imidacloprid, nitenpyram, thiacloprid, clothianidin, acetamiprid, and dinotefuran. Of the seven neonics, clothianidin, acetamiprid, and dinotefuran bind most strongly and activate GPER, thus indicating these chemicals induce breast cancer cell migration. Thus, GPER is a potential molecular target for the estrogenic disruption of neonicotinoids. Overall, the study demonstrates that neonics promote breast cancer progression through the GPER pathway at human-related exposure levels.

Over the past 20 years, neonicotinoids have replaced four major chemical classes of insecticides in the global market (organophosphates, carbamates, phenyl-pyrazoles, and pyrethroids). These systemic agricultural pesticides are highly toxic, resembling nicotine and affect the central nervous system of insects, resulting in paralysis and death, even at low doses. Like other pesticides, neonics readily contaminate water and food resources as traditional water waste treatments typically fail to remove the chemical from tap water, and the systemic nature of neonics allows the chemical to accumulate within the product rather than externally. According to the Centers for Disease Control and Prevention (CDC), nearly half the U.S. population encounters at least one type of neonic daily, with children ages three to five having the highest exposure risk. Health impacts of exposure to neonics can include neurotoxicity, reproductive anomalies, hepatic and renal damage, and an increase in gene expression linked to hormone-dependent breast cancer. Additionally, researchers identified the role some neonicotinoids play in enzyme (aromatase) production that stimulates excess estrogen production, a known event in hormone-dependent cancer development.

Beyond its link to human health effects, neonicotinoids are infamous for their well-documented role in driving mass pollinator declines. However, pollinators are far from the only victims of ubiquitous neonicotinoid contamination. In a recent avian risk assessment, EPA scientists found that neonicotinoids present in treated seeds exceeds the agency’s level of concern for certain birds by as much as 200-fold. A 2017 study by researchers at the University of Saskatchewan confirmed that tiny amounts of neonicotinoids – the equivalent of just four treated canola seeds, for example – are enough to cause migrating songbirds to lose their sense of direction and become emaciated. Recent research uncovered the endocrine-disrupting health impacts of imidacloprid on white-tailed deer, adding to the concern of the same effect in humans.

Several studies link pesticide use and residue to various cancers, from more prevalent forms like breast cancer to rare like kidney cancer nephroblastoma (Wilms’ tumor). Although the connection between pesticides and associated cancer risks is nothing new, this study is one of the first to report GPER upregulation in cancer cells (4T1-Luc) associated with breast cancer development. The researchers consider these cancer cells ideal models to study the upregulation of GPER function, especially for TNBC. Past research demonstrates the mechanism by which cancer can develop after pesticides enter the bloodstream. In 2013, an experimental study showed that exposure to pesticides produces reactive oxygen species (ROS), which are highly unstable and cause potential DNA and cell damage that propagates cancer development. Additionally, pesticides can increase cancer risk through alternate mechanisms, including genotoxicity (gene damage), epigenetics (gene expression), immunotoxicity, tumors, and endocrine disruption. Therefore, it is essential to understand how external stimuli—like environmental pollution from pesticides—can drive breast cancer development, as female health risks need urgent concerns.

Cancer is a leading cause of death worldwide. Much pesticide use and exposure are associated with cancer effects. Studies concerning pesticides and cancer help future epidemiological research understand the underlying mechanisms that cause cancer. Although the link between agricultural practices and pesticide-related illnesses is stark, over 63 percent of commonly used lawn pesticides and 70 percent of commonly used school pesticides have links to cancer. Advocates argue that global leaders must fully understand the cause of pesticide-induced diseases before the chemicals enter the environment. Policy reform and practices that eliminate toxic pesticide use can end the uncertainty surrounding potential harm. For more information on the multiple health effects associated with pesticides, see Beyond Pesticides’ Pesticide-Induced Diseases Database pages on breast cancer, endocrine disruption, and other diseases. This database supports the need for strategic action to shift away from pesticide dependency.

Prevention of the causes of breast cancer, not just awareness, is critical to solving this disease. In 1985, Imperial Chemical Industries and the American Cancer Society declared October “Breast Cancer Awareness Month” as part of a campaign to promote mammograms for the early detection of breast cancer. Unfortunately, most people are all too aware of breast cancer. Detection and treatment of cancers do not solve the problem. Tell EPA to evaluate and ban endocrine-disrupting pesticides, and make organic food production and land management the standard that legally establishes toxic pesticide use as “unreasonable.”

Moreover, proper prevention practices, like buying, growing, and supporting organics, can eliminate exposure to toxic pesticides. Organic agriculture has many health and environmental benefits that curtail the need for chemical-intensive agricultural practices. Regenerative organic agriculture nurtures soil health through organic carbon sequestration while preventing pests and generating a higher return than chemical-intensive agriculture. For more information on how the organic choice is the right choice, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture. 

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

Source: Environment International

(Beyond Pesticides, October 26, 2022) Inflammatory bowel disease (IBD) may be exacerbated by exposure to the herbicide propyzamide, used in both agriculture and on ornamental lawns and landscapes, according to research published in the journal Nature this month. As the rate of autoimmune diseases continues to increase rapidly in the U.S. and the world, it is critical for scientists to better understand the etiology behind these diseases and the environmental factors contributing to their development. Recent data show that the number of people living with Crohn’s disease and ulcerative colitis, common types of IBD, have risen annually by 3.4% and 2.8% respectively, between just the years 2001 to 2018. “As we learn more about the environmental factors that might contribute to disease, we can develop state- and national-level strategies to limit exposures,” said study coauthor Francisco Quintana, PhD. “Some chemicals don’t seem to be toxic when tested under basic conditions, but we do not yet know about the effect of chronic, low-level exposures over decades, or early-on in development.”

Researchers did not begin their study investigating propyzamide. Initial intent focused on better understanding environmental factors that may be contributing to IBD. Using a range of different models, scientists cross-referenced data from the U.S. Environmental Protection Agency’s ToxCast database to screen hundreds of different chemicals that had an affect on intestinal inflammation. Ultimately, 20 candidate chemicals were found, and scientists decided to focus on propyzamide due to its broad use patterns in food and in residential areas.

Using a mouse model, scientists found that propyzamide worsened an inflammatory process that had already been triggered by another exposure, but did not initiate the inflammation. Subsequent RNA sequencing confirmed an up-regulation of inflammatory pathways in the presence of propyzamide. Further modeling reveals that propyzamide boosts inflammation by interfering with signaling by aryl hydrocarbon receptors (AHR),  a protein that codes for immune response and detoxification, and thus works to reduce bodily inflammation.  

“Our methodology allowed us to identify a chemical that disrupts one of the body’s natural ‘brakes’ on inflammation,” said Dr. Quintana. “This method can identify new chemical candidates for epidemiological studies, as well as novel mechanisms that regulate autoimmune responses. In addition, this platform can also be used to screen and design for therapeutic anti-inflammatory drugs.”

The authors note that in the United States, the levels of propyzamide estimated by EPA to be present in surface and groundwater are concerning and similar to the rate at which adverse effects are seen for other common environmental contaminants like benzene, toluene, and certain phthalates. “Exposure levels to propyzamide would be expected to be much greater in communities in which higher levels of ground water contamination can occur from propyzamide use, as well as for people working in the agricultural sector who would be more directly exposed on a regular basis,” the study notes.

Researchers indicate that real-world data from disproportionately affected communities could help further explain the etiology of IBD. “Future studies should determine actual exposure levels in communities with potential high exposure to propyzamide and among agricultural workers, and determine whether other environmental, microbiome and genetic factors synergize with propyzamide during the pathogenesis of IBD,” the authors wrote.

While IBD has long been long viewed as a disease most prevalent in western nations, recent evidence indicates that the prevalence is rising rapidly in newly industrialized countries in South America, Asia, and Africa. The continued rise of autoimmune and nervous system disorders among the residents of industrialized nations should be a warning sign for other countries looking to U.S. chemical-based agricultural production as a model for development.

While the European Union is looking to address the rampant use of pesticides linked to public health and biodiversity declines, officials in the U.S. are working against this initiative at the behest of agrichemical industry interests. Instead of turning away from chemicals like propyzamide that are associated with autoimmune disorders, the U.S. is working to bring more countries into our unsustainable and ultimately self-defeating method of food production.

Stop the use of propyzamide and other toxic pesticides in your community by promoting alternative organic approaches, and eating organic food whenever possible. Act now to tell your local leaders to transition your public parks to organic management. And for more information on the link between pesticides and autoimmune disorders, see the page on Immune System Disorders in Beyond Pesticides’ Pesticide Induced Diseases Database.

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

Source: Nature, Brigham and Women’s Hospital press release

(Beyond Pesticides, October 25, 2022) Fungicide use harms soil and jeopardizes crop yields by reducing the prevalence of arbuscular mycorrhizal fungi (AMF), according to recent research published in Nature Ecology and Evolution. AMF are important fungi that form symbiotic relationships with plants in both natural and cropland soils, and their presence helps facilitate nutrient uptake, particularly for phosphorus. With global phosphorus supplies dwindling and persistent pollution problems from the nutrient, practices that enhance the presence of AMF in cropland soils will be critical for the future of farming worldwide.

Scientists set out to better understand the conditions that promote AMF’s ability to transfer phosphorus (P) to plants by considering climate and soil characteristics, soil type, and agricultural practices. To start, samples were taken from 150 cropland soils and 60 natural grassland soils in various countries throughout Europe. Environmental data and soil samples were collected for each location, as were past management practices for the cropland sites, which generally all grew cereal grains like wheat, oats or barley. To understand the P transfer rates of AMF hyphae, scientists grew the plant Plantago lanceolata in the collected soils in a greenhouse, utilizing the radioisotope 33P in order to achieve a real-time view of P transport by AMF hyphae. Plantago lanceolata, also known as English plantain, is commonly considered a weed but acted as an an ideal specimen for the experiment given its known ability to form associations with a range of different AMF species. As the plantains grew, 33P was injected at week ten, and 12 days later the plants were harvested and assessed for the amount of 33P taken up from the soil.

The natural grassland soils took up 64% more 33P than soils from the cropland sites. Analysis also finds that AMF richness and microbial biomass was lower in croplands soils by 41% and 29% respectively, with these soils having significantly more available P than in natural grassland soil. Using a statistical model, scientists worked out the relative importance of various conditions and management practices to P transfer and uptake by AMF. The strongest correlation was found for soil pH, which significantly increased P uptake in both soils.

In cropland soils, AMF richness (i.e., the total number of AMF species present within a given soil) and fungicide use were the most important predictors of P transfer and uptake. Cropland soils that were not treated with a fungicide had an average P transfer 2.3 times greater than soils that had three fungicide applications over the last year in the study. In fact, P recovery rates decreased in tandem with the number of each additional fungicide application. Unsurprisingly, scientists found evidence for fungicides diminishing AMF richness, thereby reducing P uptake.

“Our results…call for reconsidering the design of agricultural systems to be able to make full use of the potential of AMF symbiosis for plant nutrition,” the study reads. “For example, applying agroecological techniques, such as crop diversification, can be a promising way to reduce disease pressure, and hence the need to use pesticides, while at the same time promoting AMF richness, which could indirectly support plant P uptake [] and to other benefits provided by AMF.”

Most domesticated crops grown today are not bred to have a symbiotic relationship with AMF. Scientists say that should be an area of further exploration. As the study indicates, “[T]he breeding and use of AMF-responsive crops, an aspect which hasn’t been directly investigated in this study, is a way to promote AMF-supported crop production that requires further consideration in future research.”

The use of fungicides presents a range of hazards beyond harm to soil life. In the environment, their use can induce trophic cascades that result in an overgrowth of algae. Certain fungicide classes, like the strobilurins, have been linked to genetic changes similar to autism and Alzheimer’s disease, and there is evidence that one fungicide, fludoxonil, decreases the body’s ability to fight back against covid-19. Rampant use of these chemicals is putting the human species at risk of another pandemic, as deadly fungal infections are becoming increasingly prevalent in hospitals, and strong evidence is pointing to agriculture as the incubator for these virulent strains of otherwise common fungi like Candida auris and Aspergillus fumigatus.

Help promote the best alternative to chemical agriculture by joining efforts to maintain the integrity of organic production. Organic agriculture does not allow the use of synthetic pesticides, and includes a mandate to maintain or improve soil on the farm. It is critical for consumers to engage with the organic standards process to ensure that agrichemical interests and the U.S. Department of Agriculture do not undermine efforts towards continuously improving organic production practices. Visit Beyond Pesticides Keep Organic Strong and Action of the Week archives for steps you can take to defend organic standards.

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

Source: Nature Ecology and Evolution

(Beyond Pesticides, October 24, 2022) We need prevention of the causes of breast cancer, not just awareness. In 1985, Imperial Chemical Industries and the American Cancer Society declared October “Breast Cancer Awareness Month” as part of a campaign to promote mammograms for the early detection of breast cancer. Unfortunately, most of us are all too aware of breast cancer. Detection and treatment of cancers do not solve the problem.

Tell EPA to evaluate and ban endocrine-disrupting pesticides, and make organic food production and land management the standard that legally establishes toxic pesticide use as “unreasonable.” 

Next to skin cancer, breast cancer is the most common cancer among women, causing the second most cancer-related deaths in the United States. Genetic factors only play a minor role in breast cancer incidence, while exposure to external environmental factors such as pesticides plays a more notable role. For breast cancer, one in eight women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how environmental exposure to chemicals like pesticides can drive breast cancer development. Several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with breast cancer risk. 

Most types of breast cancers are hormonally responsive and are thus affected by estrogen or progesterone or other chemicals that mimic them, known as endocrine disruptors. Endocrine-disrupting chemicals include pesticides like DDT, organophosphate (OP) insecticides, glyphosate, neonicotinoids, and synthetic pyrethroids, as well as dioxins, PCBs, various solvents, and many other chemicals.

We must mitigate the multigenerational impacts pesticides pose on human and animal health. Adopting regenerative organic practices and using least-toxic pest control can eliminate harmful exposure to pesticides. Solutions like buying, growing, and supporting organic can also help eliminate the extensive use of pesticides in the environment.

In addition to these personal actions, public policy must be changed.

Tell EPA to evaluate and ban endocrine-disrupting pesticides, and make organic food production and land management the standard that legally establishes toxic pesticide use as “unreasonable.” 

 Letter to EPA:

In 1985, Imperial Chemical Industries and the American Cancer Society declared October “Breast Cancer Awareness Month” as part of a campaign to promote mammograms for the early detection of breast cancer. Unfortunately, most of us are all too aware of breast cancer. Detection and treatment of cancers do not solve the problem. We need prevention of the causes of breast cancer, not just awareness.

Next to skin cancer, breast cancer is the most common cancer among women, causing the second most cancer-related deaths in the United States. Genetic factors only play a minor role in breast cancer incidence, while exposure to external environmental factors such as pesticides plays a more notable role. For breast cancer, one in eight women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how environmental exposure to chemicals like pesticides can drive breast cancer development. Several studies and reports, including U.S. Environmental Protection Agency data, identify hundreds of chemicals as influential factors associated with breast cancer risk.

Most types of breast cancers are hormonally responsive and are thus affected by estrogen or progesterone or other chemicals that mimic them, known as endocrine disruptors. Endocrine-disrupting chemicals include pesticides like DDT, organophosphate (OP) insecticides, glyphosate, neonicotinoids, and synthetic pyrethroids, as well as dioxins, PCBs, various solvents, and many other chemicals.

EPA’s examination of the endocrine-disrupting effects of pesticides has stalled. If we are to take action to prevent breast cancer, we must eliminate those pesticides. Organic production and land management need to become the standard against which EPA measures all pesticides.

Thank you.

Letter to U.S. Senators and Representative:

In 1985, Imperial Chemical Industries and the American Cancer Society declared October “Breast Cancer Awareness Month” as part of a campaign to promote mammograms for the early detection of breast cancer. Unfortunately, most of us are all too aware of breast cancer. Detection and treatment of cancers do not solve the problem. We need prevention of the causes of breast cancer, not just awareness.

Next to skin cancer, breast cancer is the most common cancer among women, causing the second most cancer-related deaths in the United States. Genetic factors only play a minor role in breast cancer incidence, while exposure to external environmental factors such as pesticides play a more notable role. For breast cancer, one in eight women will receive a diagnosis, and genetics can only account for five to ten percent of cases. Therefore, it is essential to understand how environmental exposure to chemicals like pesticides can drive breast cancer development. Several studies and reports, including U.S. Environmental Protection Agency (EPA) data, identify hundreds of chemicals as influential factors associated with breast cancer risk.

Most types of breast cancers are hormonally responsive and are thus affected by estrogen or progesterone or other chemicals that mimic them, known as endocrine disruptors. Endocrine-disrupting chemicals include pesticides like DDT, organophosphate (OP) insecticides, glyphosate, neonicotinoids, and synthetic pyrethroids, as well as dioxins, PCBs, various solvents, and many other chemicals.

EPA’s examination of the endocrine-disrupting effects of pesticides has stalled. If we are to take action to prevent breast cancer, we must eliminate those pesticides. Organic production and land management need to become the standard against which EPA measures all pesticides.

Please use your oversight responsibility to ensure that EPA takes steps to prevent breast cancer.

Thank you.

(Beyond Pesticides, October 21, 2022) The U.S. Environmental Protection Agency (EPA) has just made two announcements, related to the quest for improved indoor air quality in buildings, that address mitigation of disease transmission — and that of COVID-19, in particular. Related to enactment of the National COVID-19 Preparedness Plan, EPA issued guidance on the efficacy of antimicrobial products used on surfaces, and registered a new pesticide product the agency says can be used against influenza and corona viruses (some of the latter cause COVID-19 infections). In addition, EPA opened a 60-day public comment period “to solicit information and recommendations from a broad array of individuals and organizations with knowledge and expertise relating to the built environment and health, indoor air quality, epidemiology, disease transmission, social sciences and other disciplines.” Beyond Pesticides cannot help but note the irony of an intention to improve air quality that EPA couples with registration of a new, airborne pesticide for indoor use.

EPA expands on its RFI (Request for Information) related to indoor air quality, saying that it is “seeking input from a diverse array of stakeholders . . . about actions, strategies, tools and approaches that support ventilation, filtration and air cleaning improvements, and other actions that would promote sustained improvements in indoor air quality in the nation’s building stock to help mitigate disease transmission.”

EPA provided interim guidance in 2020 on products that look to claim residual efficacy (ability to continue killing pathogens beyond immediate application). The new guidance identifies three categories of such products: (1) residual disinfectants, (2) antimicrobial surface coatings and films, and (3) fixed/solid surfaces, such as copper, or other impregnated materials. The “residuals” are fairly standard disinfectants that generally show efficacy for up to 24 hours after application; the other two categories represent newer approaches for which EPA now requires a “stewardship plan” in order to gain (conditional) registration. In addition, the agency has issued guidance on new antimicrobial testing methods and standard procedures for evaluation of efficacy of disinfectants on hard surfaces again specific viruses and bacteria.

EPA’s October 6 registration announcement asserts that the newly registered pesticide, Lysol Air Sanitizer spray, is the first registered antimicrobial product that can kill both viruses and bacteria. EPA explains the utility of the new product: “When users spray the aerosol product in a closed, unoccupied room in accordance with the label use-directions, Lysol Air Sanitizer can kill bacteria and viruses in the air.” The product will reportedly kill 99.9% of airborne viruses when all doors, windows, air vents, and air returns in the room are closed, the product is sprayed for 30 seconds, and the room left empty and closed up for 12 minutes. Product instruction do note that there is “no residual effect after room is reopened.” Given that last proviso, the practicality of such a product may be somewhat limited, but Inside Energy and Environment opines that it “may pave the way for other types of registered pesticides that kill airborne viruses and bacteria.” EPA has a history of registering fumigants, such as sulfuryl fluoride, and indoor sprays that leave residues in closed spaces and structural voids in the indoor environment, despite claims that ventilation clears the poison. In terms of efficacy, airborne viruses are being constantly introduced and reintroduced in public spaces, such as stores, schools, restaurants, and public spaces. So, in this public context, a sanitizer application to an indoor space only protects against the target virus as long as the building is not used by the public.

The active ingredient in Lysol Air Sanitizer spray is dipropylene glycol (DPG), an ingredient used in some cosmetics. The Environmental Working Group’s Skin Deep database considers it a generally low-risk compound, but has limited data available on the chemical; the web page also indicates that health risks can be greater if DPG is used in an inhalable form, which the Lysol product obviously deploys. EPA’s review finds low acute inhalation toxicity of DPG, but that assessment is based on studies of mostly acute, not chronic or subchronic inhalation.

The agency announcement adds that EPA “conducted a robust risk assessment on exposure from both household and commercial use. When used following label directions, this product poses no unreasonable adverse risks to human health or the environment.” This may be true for some people, but Beyond Pesticides emphasizes two points:

• EPA’s track record on what pesticides constitute a human health threat, and to what degree, is not stellar; consider our reporting on, among other considerations, risks even with low-level exposures, potential synergistic impacts of multiple chemical exposures, and industry influence on agency risk assessments, among other shortcomings.
• Increasing numbers of people in the U.S. are reporting “chemical intolerance (CI)” — extreme sensitivity to one or more chemicals. A 2021 research study on CI reported that 15–36% of the population reports this experience. The phenomenon has been called numerous things over the years — among them, Multiple Chemical Sensitivity and Idiopathic Environmental Illness. EPA reassurance of “no unreasonable adverse risks” may be cold comfort to people dealing with this condition.

A more-recent and -comprehensive concept (and moniker) is Toxicant-Induced Loss of Tolerance, or TILT — a disease theory that joins germ theory and immune theory to describe and explain what CI people may experience. A leading researcher on TILT is Dr. Claudia Miller, an allergist/immunologist, professor emerita in the Department of Family and Community Medicine at The University of Texas Health Science Center (San Antonio), and leader of its Hoffman TILT Program. She was also a co-author of the paper on the 2021 study referenced above, Toxicant-induced loss of tolerance for chemicals, foods, and drugs: assessing patterns of exposure behind a global phenomenon.

That work examined eight major exposure events that preceded the onset of CI in groups of people who shared the same exposure experience. Those groups comprised, respectively: workers at EPA headquarters during renovations; Gulf War veterans; casino workers with pesticide exposures; workers with exposures to aircraft oil fumes; people who experienced the 2001 World Trade Center tragedy; people with surgical implants; those exposed to moldy environments; and tunnel workers exposed to solvents. Study findings were that “mixed volatile and semi-volatile organic compounds (VOCs and SVOCs), followed by pesticides and combustion products, were most prevalent across TILT initiation events. As a broader category, synthetic organic chemicals and their combustion products were the primary exposures associated with chemical intolerance. Such chemicals included pesticides, peroxides, nerve agents, anti-nerve agent drugs, lubricants and additives, xylene, benzene, and acetone.”

Dr. Miller describes TILT: “It is a two-step process. First, initiation involves acute or chronic exposure to environmental agents such as pesticides, solvents, or indoor air contaminants, followed by triggering of multi-system symptoms by exposure to small quantities of previously tolerated substances such as traffic exhaust, cleaning products, fragrances, foods, drugs, or food-drug combinations.” The 2021 study identified that, for the initiation to occur, the exposure must “interact” with the human nervous system or immune system (or both) in such a way that the individual is rendered intolerant to later triggering events. The co-authors assert that too little is yet known about the nature of that requisite “interaction,” but clearly point to synthetic organics (e.g., pesticides) as one of several primary exposure sources.

In its coverage, Beyond Pesticides notes that, “In the second stage, affected individuals are ‘triggered’ even by minute exposures, not only to the chemical that affected them in the first place, but also to other chemicals that did not affect them previously.” These post-acute trigger exposures can result in a range of symptoms, some fairly debilitating: chronic fatigue; gastrointestinal (GI) issues; problems with memory, attention, and/or mood; headaches or migraines; asthma; rashes; muscle pain; and/or allergy-like symptoms.

Beyond Pesticides adds, “TILT sufferers are often bounced from doctor to doctor based on individual symptoms, have significant difficulties receiving a diagnosis, and must navigate a world filled with triggering compounds, ranging from pesticides, to fragrances, molds, and other indoor air contaminants, traffic exhaust, pharmaceutical drugs, certain food, or food and drug combinations, or other volatile compounds. . . . The [fact] of TILT undermines [the] classical toxicological concept that ‘the dose makes the poison.’ . . . a better phrase may be that ‘[the] dose plus host makes the poison,’ with an understanding that past exposures and various genetic factors are likely at play in terms of individual tolerance to environmental pollutants. These factors play into why it is so difficult for affected individuals to receive treatment, let alone a diagnosis.”

About these triggers, Dr. Miller points out that the tens of thousands of pesticides, petrochemicals, and plastics in our materials stream broadly expose humans in industrialized countries to compounds with which humans did not co-evolve, and that roughly 20% of the populations of such countries exhibit chemical intolerances. Dr. Miller has developed diagnostic instruments to help identify patients suffering from TILT-related intolerances, including the Chemical Intolerance Self-Assessment (QEESI). For more information on TILT, read a transcript of a talk given by Doris Rapp, MD, and published in Beyond Pesticides’ Pesticides and You newsletter, and visit the UT San Antonio website on the Hoffman TILT program. See Dr. Miller’s talk at Beyond Pesticides National Forum Series, Health, Biodiversity, and Climate: A Path for a Livable Future.

The Hoffman program page lists, among other information, common triggers and alternatives to them. Among those triggers is the category “bleach, ammonia, disinfectants, and strong cleaning products.” The alternatives offered are “elbow grease, non-toxic soap and water, baking soda, and vinegar.” Great advice for general cleaning, but unlikely to seem sufficient to those looking for anti-COVID-19 “magic bullets” — an understandable desire, given the havoc this pandemic has wreaked. That said, EPA should be paying more, and more-granular, attention to vulnerable, chemically intolerant segments of the population in its review of, and risk assessments for, new pesticide products, such as this new Lysol spray. Chemically intolerant people, as individuals and as a cohort, are given far too little consideration in this regard.

Beyond Pesticides has previously published articles and fact sheets on COVID-19 protective strategies (some from early in the pandemic), including: EPA-allowed disinfectants increase vulnerability; safer personal protection: a disinfectants factsheet; and a Q&A on sanitizers and disinfectants.

Beyond Pesticides encourages response to EPA’s Request for Information/public comment invitation; comments are due no later than December 5, 2022. Instructions for submitting them are listed under the “Addresses” section of the Federal Register webpage: https://www.federalregister.gov/documents/2022/10/05/2022-21590/request-for-information-better-indoor-air-quality-management-to-help-reduce-covid-19-and-other.

Sources: https://www.insideenergyandenvironment.com/2022/10/epa-provides-guidance-regarding-novel-antimicrobial-pesticides-and-seeks-comment-on-indoor-air-quality-issues/#page=1\ and https://enveurope.springeropen.com/articles/10.1186/s12302-021-00504-z

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

(Beyond Pesticide, October 20,2022) Exposure to environmentally relevant levels of glyphosate-based herbicides (GBHs) weakens bumblebees’ (Bombus Terrestris) ability to distinguish between colors or fine-color discrimination. According to research published in Science of The Total Environment, a lack of fine-color discrimination skills can threaten bumble bee survivability through impact on colony fitness and individual foraging success. Much research attributes the decline of insect pollinators (e.g., commercial and wild bees and monarch butterflies) over the last several decades to the interaction of multiple environmental stressors, from climate change to pesticide use, disease, habitat destruction, and other factors. In the U.S., an increasing number of pollinators, including the American bumblebee and monarch butterfly, are being added or in consideration for listing under the Endangered Species Act, with specific chemical classes like systemic neonicotinoid insecticides putting 89% or more of U.S. endangered species at risk.

Pollinator decline directly affects the environment, society, and the economy. Without pollinators, many plant species, both agricultural and nonagricultural, will decline or cease to exist as U.S. pollinator declines, particularly among native wild bees, limits crop yields. In turn, the economy will take a hit, as much of the economy (65%) depends upon the strength of the agricultural sector. As science shows, pesticides are one of the most significant stressors for pollinators. In a world where habitat loss and fragmentation show no sign of abating, scientists have concluded that the globe cannot afford to continue to subject its critically important wild insects to these combined threats. Therefore, studies like these highlight the need to establish monitoring and conservation frameworks incorporating varying habitats and species to assess fluctuations in biodiversity. The study coauthor and university teacher, Olli Loukola, PhD, of the University of Oulu, Finland, notes, “[T]he results are quite worrying considering the importance of color vision for bumblebees. Even small disturbances in color vision can be catastrophic in terms of foraging and nesting success.”

GBHs are the most common herbicides used globally. Previous studies evaluating chronic glyphosate or GBH exposure assessed the survival, development, physiology, colony thermoregulation, or gut microbiota specific to honey bees. However, very few studies have tested field-realistic exposure to glyphosate honey bees’ cognitive performance, and no studies examined this question in non-honey bee pollinators (e.g., bumble bees). Thus, researchers evaluated the effect GBHs have on bumblebee cognition when exposed to acute levels of environmental (field) realistic doses of these chemicals. To simulate field-realistic exposures of GBH, the researchers provided each bumblebee with 60 percent sugar with or without GBH quinine. A series of learning and memory experiments represented cognition traits as these traits determine the successful foraging and social behavior of insects and their fitness. In the learning phase, bees can choose between a rewarding sucrose solution or an aversive quinine solution in the flowers of 10 different plants. Two days after the learning phase, the bees underwent a memory test with the same setup as in the learning phase, except that each flower contained water. The experiment examined how to control bumblebees (not exposed to GBH) and GBH-exposed bees to distinguish between flowers based on ten different colors when searching for nectar or pollen. Moreover, researchers tested if the cognitive impacts of GBH-exposed bees affect general vision and/or olfactory (odor) senses.

One to several acute exposures to GBHs, similar to field-realistic perspectives, significantly impairs bumble bees’ ability to discriminate between the ten flower colors. During the learning phase, control and GBH-exposed bees display differences in learning rate. Control bees learning rate increased after two sessions, while GBH-exposed bees’ learning rate dropped to zero. Two days after the completion of the learning phase, researchers performed a memory test on both bee groups. The researchers split the control group into two, leaving half without GBH exposure while treating the remaining control bees with GBHs. The results find the second group of control bees performed at the same level as the learning session, while the new group of GBH-exposed bees lost all learning from the previous two days. The study also demonstrates GBH does not affect bumble bees’ ability to discriminate between odors or two spectrally different colors (i.e., yellow, and blue in the experiment). Thus, the results suggest GBHs’ impact on fine-color discrimination among bees obscures the color information of rewarding flowers used in memories for future decisions. The study suggests, “…that acute sublethal exposure to GBH poses a greater threat to pollination-based ecosystem services than previously thought, and that tests for learning and memory should be integrated into pesticide risk assessment.”

Clean air, water, and healthy soils are integral to ecosystem function, interacting between Earth’s four main spheres (i.e., hydrosphere, biosphere, lithosphere, and atmosphere) to support life. However, toxic pesticide residues readily contaminate these spheres, frequently in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. The scientific literature demonstrates pesticides’ long history of adverse environmental effects, especially on wildlife, biodiversity, and human health. Most notably, pesticides are immensely harmful to pollinators. Over the last decade and a half, increasing scientific evidence shows a clear connection between the role of pesticides in the decline of honey bees and wild pollinators (e.g., wild bees, butterflies, beetles, birds, bats, etc.) alike. The agricultural industry relies on insect pollinators to aid in plant pollination and crop productivity. Globally, the production of crops dependent on pollinators is worth between $253 and $577 billion yearly. Hence, pesticide use fails to support sustainability goals, decreasing agricultural and economic productivity and social (human/animal) and environmental well-being.

While it is evident that each factor contributing to the decline of the American bumblebee is problematic, including pesticides, parasites, and poor nutrition, pollinators are exposed to multiple stressors at once that act together to increase the risk of bee mortality.

Almost five decades of extensive glyphosate use has put animal, human, and environmental health at risk as the chemical’s ubiquity threatens 93 percent of all U.S. endangered species. Although the direct effect that pesticides have on pollinators is concerning, the indirect impacts that pesticides have on pollinator habitats are equally troublesome. Glyphosate use in mono-crop agriculture and genetically engineered crops can drift onto and destroy adjacent habitats. Habitat destruction results in the loss of species biodiversity and stable ecosystem processes integral to sustainability. 

When looking at pesticide exposure, glyphosate represents only one class out of thousands of agrichemicals that pollinators may encounter. Pesticide use poses one of the most significant threats to bumblebees and places their entire life cycle at risk. A 2018 study found that commonly used neonicotinoid insecticides begin to kill off bumblebees during their nest-building phase, as exposure makes it more difficult for a queen to establish a nest. Exposure to neonicotinoids results in bumblebee colonies that are much smaller than colonies not exposed to the systemic insecticide. Moreover, a 2017 study finds that neonicotinoid exposure decreases pollination frequency and results in fewer social interactions. That is likely because neonicotinoids alter bumblebee feeding behavior and degrade the effectiveness of bumblebee’s classic “buzz pollination” process. Research published in 2017 determined that fungicides also play an important role in bumblebee declines by increasing susceptibility to pathogens. Moreover, the U.S. Environmental Protection Agency (EPA) assesses the toxicity of individual active ingredients on bees through various testing methods when regulating pesticides. However, there are no requirements for EPA to test multiple active or inert ingredients to the same degree, despite evidence demonstrating these chemicals harm pollinators. 

The study demonstrates acute exposure to GBH during foraging sessions within a recently sprayed area significantly impairs bumblebees’ fine-color discrimination and long-term memory. In the wild, when discriminating between different colored flowers, bees must distinguish between flowers that appear much closer in color than in the 2-color experiment (yellow and blue flower). Thus, the results of the 10-color experiment, noting impacts on fine-color discrimination and long-term memory, represent a more ecologically relevant environmental condition for bee foraging. Although the study suggests impairment of fine-color discrimination and long-term memory may decrease individual and colony fitness, “The relative biological importance of bees’ contrasting color and fine-color discrimination performance, as well as their ability to discriminate between different odors, remains to be revealed in future studies.”

The study concludes, “[O]ur results emphasize the imperative need to direct our collective research focus on the substantial, complicated, and ecologically relevant risk scenarios rather than lethal doses alone. These risks are not limited to agroecosystems because glyphosate residues are near-ubiquitous in wild environments as well, and a vast majority of plant species are animal pollinated. Thus, sublethal consequences of GBHs should be considered not only in future research but also in public discussion, decision making, and development of environmentally friendly pesticides.”

Pollinator protection policies need improvements, not only to safeguard wild pollinators but the crops they pollinate as well. Beyond Pesticides holds that we must move beyond pesticide reduction to organic transition and commit to toxic pesticide elimination in our agricultural system to prevent crop loss presented in this study. Pesticide elimination can alleviate the effect of these toxic chemicals on humans and wildlife. With EPA failing to take the most basic steps to protect declining pollinators, it is up to concerned residents to engage in state and community action and demand change. Moreover, the government should pass policies that eliminate a broad range of pesticides by promoting organic land management. Habitat in and of itself may assist, but it must be free of pesticides to protect wild pollinator populations. To protect wild bees and other pollinators, check out what you can do by using pollinator-friendly landscapes and pollinator-friendly seeds, engaging in organic gardening and landscaping, and supporting organic agriculture through purchasing decisions. Learn more about the science and resources behind the adverse effect of pesticides on pollinators and take action against the use of pesticides. Buying, growing, and supporting organic will help eliminate the extensive use of pesticides in the environment. Organic land management and regenerative organic agriculture eliminate the need for toxic agricultural pesticides. For more information on the organic choice, see the Beyond Pesticides webpages, Health Benefits of Organic Agriculture, Lawns and Landscapes, and Parks for a Sustainable Future. 

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

Source: Phys.org, Science of The Total Environment

(Beyond Pesticides, October 19, 2022) Pet flea collars containing the insecticide tetrachlorvinphos (TCVP) are set to be banned by the U.S. Environmental Protection Agency, according to the agency’s long overdue response to a petition from the Natural Resources Defense Council (NRDC). The highly toxic pesticide has not been used on crops since 1987, yet was permitted for decades in flea collars where children could be intimately exposed to the chemical while petting and playing with the family pet. The decade-long process of bringing use of these products to an end exposes the failures of the U.S. pesticide regulatory system, and how EPA’s weak and flawed decisions that infect the marketplace with severe consequences. One may ask: How many veterinarians prescribed these dangerous flea collars to pet owners, assuming that EPA has properly assessed exposure risks to their human owners? Advocates concerned about EPA’s ongoing propensity to defer to the pesticide industry are urging an overhaul of the regulatory process and a reorientation toward toxic pesticide elimination and the adoption of organic in order to address serious health and environmental threats.

NRDC originally filed its petition to ban all uses of TCVP in 2009. The petition noted that the agency completely neglected to include exposures from pet collars in its risk assessment for residential uses of the chemical, despite finding that pet collar uses represent the highest level of exposure for adults. It further explained that EPA’s review of risks to toddlers were flawed, and significantly underestimated their likely exposure. Specifically, the agency assumed that toddlers only interacted with one treated pet per day, for no more than one hour a day. EPA also ignored the potential for a toddler to touch food or another object with pesticide-contaminated hands, and then place that food or object in their mouth. Further, testing from NRDC contradicted EPA’s assertion that exposure risks from TCVP pet collars were “insignificant,” finding that residue levels found on pets exceeded the dose considered safe by the agency.

Despite strong evidence of flawed science, the agency denied NRDC’s petition in 2014. A petition for review was filed and EPA requested a voluntary remand of its denial, which the court granted. Rather than investigate the specific issues raised by NRDC in its original petition, the agency explained it would incorporate new risk mitigation measures into its risk assessment for TVCP, and in 2017 proceeded to reregister all uses of the chemical. In doing so, the agency noted label precautions it said would protect pet owners, including not allowing children to play with TVCP collars, keeping TCVP out of the reach of children, and washing hands after handling. Advocates at the time noted how these precautions fly in the face of reality, as they suggest a scenario where kids must be prevented from petting and coming in close contact with a family dog or cat.

Another legal challenge was filed in 2019, aimed at forcing the agency to respond. After ten years, the agency required TCVP’s major manufacturers to provide data specifically on the release of TCVP from pet collars. A review of that data resulted in minimal mitigation measures, and ultimately, the agency denied the petition.

NRDC again challenged this decision, noting that EPA’s analysis of the new test on the release of TCVP from pet collars was miscalculated and significantly underestimated exposure risks. “EPA’s 2020 risk analysis was profoundly flawed in its approach and conclusions. It has needlessly delayed the removal of these dangerous products and further exposed millions of children to serious, life-long health risks,” said Miriam Rotkin-Ellman, NRDC senior scientist. In April of this year, a federal court agreed with the group, vacated the denied petition yet again, and required EPA to provide a response by October 11, 2022.

In its latest response granting the cancellation request, the agency explains that a reevaluation of the data submitted for the 2020 assessment finds that it did not “adequately assess the physical form (liquid or dust) of TCVP released from the pet collars.”

In the same breath, however, the agency explains that it is still waiting on outstanding data from manufacturers that may impact its decision, and is retaining all other use of TCVP on the marketplace, including liquid and dust products intended for use on dogs and cats.

“Other types of TCVP exposures, including residues on food, also pose worrisome health risks, particularly in combination with exposure from pet products, said Ms. Rotkin-Ellman. “EPA must act swiftly to prohibit other dangerous uses of this toxic pesticide. The health of our families can no longer wait.”

TCVP and other organophosphates in its class work by inhibiting the enzyme acetylcholinterase. Inhibition leads to the accumulation of acetylcholine and ultimately toxicity to the central and peripheral nervous system. Insects are killed through this mechanism, yet with humans such toxicity can cause numbness, tremors, nausea, incoordination, blurred vision, difficulty breathing or respiratory depression, and slow heartbeat. Risks are most pronounced for young children, who have developing organ systems and take in more of a pesticide relative to their body weight than adults. In calling for a ban on all organophosphate use in the United States, scientists noted how even low-level exposures to organophosphates put children at risk of neurodevelopmental disorders, and cognitive and behavioral deficits. A study published in 2020 shows the real-world effect of these risks. It finds that organophosphate pesticide exposure results in an estimated 26 million lost IQ points and 110,000 cases of intellectual disability, totaling roughly $735 billion in economic costs to society based on data beginning in 2008.

EPA’s characteristic response to nonprofit groups critiquing their science stands in stark contrast to how it responds to industry groups doing the same. When it comes to protecting health and the environment, the agency drags its feet, strongly challenges criticism, and requires public interest groups to fight for years in the courts to implement critical protections. The fight over a different organophosphate, chlorpyrifos, is another example of this. In finally forcing EPA’s hand on chlorpyrifos, a federal court ruling took the agency to task, asserting, “The EPA has had nearly 14 years to publish a legally sufficient response to the 2007 Petition [filed by environmental and farmworker groups]. During that time, the EPA’s egregious delay exposed a generation of American children to unsafe levels of chlorpyrifos.”

Yet when the industry challenges EPA, the agency almost invariably capitulates. With the chemical paraquat, EPA allowed an industry umbrella group dubbed the Agricultural Handler Exposure Task Force to correct its data risks posed to workers, resulting in the agency changing its position within months. With the synthetic pyrethroid class of insecticides, EPA allowed an industry group to rework its methodology for addressing pyrethroid risks to children, and followed the request of another industry group to allow the pyrethroids to be sprayed with smaller buffer zones during windier conditions. With the chemical glyphosate, despite overwhelming evidence of its carcinogenic properties, the agency has refused to acknowledge this risk, even after a federal court chastised its review process, and instead has acted on the behest of chemical manufacturers to stop glyphosate from being banned in other countries.

With federal protections consistently failing U.S. residents by harming their health and the environmental on which we all rely, while contributing to outsized corporate profits, concerned residents can still join together to push for change. Join Beyond Pesticides in supporting changes to our pesticide laws by urging your Senators to cosponsor Senator Cory Booker’s (D-NJ) Protect America’s Children from Toxic Pesticides Act, and take further action to reform our toxic and no longer functioning federal pesticide regulatory system.  And for more information on the risks pesticides pose to pets and how to address flea and tick problems without toxic pesticides, see Beyond Pesticides’ Pets and Pesticides program page.

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

Source: EPA TCVP, NRDC press release and TCVP case documents

(Beyond Pesticides, October 18, 2022) Washington, D.C. Attorney General (AG) Karl Racine is suing chemical manufacturer Velsicol to recover damages caused by the company’s production and promotion of the insecticide chlordane despite full knowledge of the extreme hazards posed by the pesticide. Over 30 years after it was banned, chlordane is still contaminating homes, schools, yards, private wells and waterways throughout the United States, including DC’s Anacostia and Potomac rivers. While the District’s focus on restitution and remediation for this highly hazardous, long-lived insecticide is laudable, many advocates say the city is not doing enough to stop pesticide contamination currently entering the city’s waterways. Despite passage of a strong pesticide bill in 2016 limiting toxic pesticide use on schools, child occupied facilities, and within 75ft of a waterbody, D.C. Department of Energy and Environment (DDOE) director Tommy Wells has failed to update regulations and enforce the law.

Chlordane is an organochlorine insecticide, of the same class as DDT, and was likewise discussed extensively in Rachel Carson’s Silent Spring. Like other organochlorines, it is bioaccumulative, increasing contamination levels as it works its way up the food chain, and highly persistent, remaining in the environment for decades and perhaps even centuries, with breakdown products of similar toxicity to the parent compound. The chemical has been associated with diabetes, developmental disorders, miscarriage, depression, bone marrow diseases, and is a potent carcinogen. More recent data have linked the chemical to autism and endometriosis. Sales of chlordane began in the mid-1940s and continued until 1988, when the US Environmental Protection Agency (EPA) finally banned its remaining uses for household termite applications.

By that time, per EPA estimates, chlordane had been applied to 30 million homes in the United States. This contamination persists today. Chlordane has been discovered on the grounds of a New Jersey middle school at levels above EPA limits, in the private wells of many Connecticut residents,  in what were once considered “pristine” National Parks, and in coral reefs along the South China Sea.

In Washington DC, the year before chlordane was banned, it was found in Potomac and Anacostia River fish at levels three times above what the US Food and Drug Administration considered safe for human consumption at the time. AG Racine notes in the legal filing that 38 miles of D.C.’s waterways are out of compliance with water quality standards for chlordane, making it impaired under the Clean Water Act. D.C. has spent tens of millions of dollars adding filters in catch basins and stormwater outfalls and investigating chlordane contamination in Anacostia and Potomac river sediment.

In it’s release for the lawsuit, the Attorney General’s office explains that the harm caused chlordane pollution has fallen most sharply on the District’s communities of color. “The environment is a precious resource that belongs to everyone, and far too often Black and brown communities of color are forced to bear the brunt of pollution, toxic sites, and contaminated water supplies,” said AG Racine. “With today’s lawsuit, we are going after Velsicol which – for decades – made dollar after dollar of profit while poisoning DC residents with dangerous chemicals that they knew caused severe health problems, including cancer. The damage that Velsicol caused will continue to impact the health of communities in the District of Columbia far into the future, particularly Black and brown community members, as these chemicals persist in our environment and continue to wreak havoc on our natural resources.”

“The fact that there continues to be contamination from chlordane, decades after its removal from the market, is testament to the abject failure of our federal and state pesticide laws,” said Jay Feldman, executive director of Beyond Pesticides. “EPA permits a legacy of health and environmental threats because of poor analyses on the front-end, ineffective mitigation measures, and slow negotiated phaseouts that extend the deleterious effects of pesticides well after findings of harm,” Mr. Feldman continued. Beyond Pesticides (then the National Coalition Against the Misuse of Pesticides/NCAMP sued EPA (see The Washington Post and The New York Times) in the late 1980’s when the agency negotiated an agreement with Velsicol to phase-out chlordane use and allow all existing stocks to be used up. Then the issue was cancer and the judge in the case found that the additional cancers that would be caused by leaving the chemical in commerce for the phase-out period, including the cost to cancer victims, were unacceptable. On a regulatory level, the judge also found that EPA’s failure to evaluate the harm caused during the phase-out period was a violation of the agency’s responsibility under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The District Court’s finding was reversed on appeal, but by then, EPA had negotiated a shortened phase-out period and established a recall/buy-back program, something the agency rarely does. For a history lesson in the failure of FIFRA, see National Coalition Against the Misuse of Pesticides, et al., Appellees, v. Environmental Protection Agency, et al., Appellants, 867 F.2d 636 (D.C. Cir. 1989). “The chlordane story is a vivid telling of federal regulators’ failure to use their discretionary authority to curtail corporations from causing an “imminent hazard” with toxic pesticide use and the resulting decades of destruction and health threats that continue to destroy people’s lives and the environment,” said Mr. Feldman. “After repeating this tragedy with newer generations of pesticides, the only reasonable path forward is to stop the pesticide treadmill by phasing out all toxic pesticides, while transitioning to an organic society,” he said.

Pesticide use is an environmental justice issue. Yet unfortunately, many of the same practices that permitted this contamination to occur in the first place are being repeated today. EPA continues to register pesticides without full accounting of the impacts to health and the environment, particularly chronic, long-term effects, and impacts on vulnerable communities, such as children, pregnant mothers, immunocompromised individuals, and people of color. In the lawsuit, Velsicol is cited for covering up a study showing chlordane caused cancer, which resulted in criminal charges for Velsicol executives. As it currently stands, manufacturers are still permitted to conduct tests on the pesticides they produce, and because of the elimination of statutes like the Delaney Clause for pesticide registrations, which forbid the use of products found to induce cancer, a wide range of products on the market today are carcinogenic. Further, EPA has effectively provided cover for products like glyphosate, which published studies show to be carcinogenic yet are ignored by EPA in favor of studies conducted by the manufacturer. Federal regulators are similarly slow to take needed protective action. Use of chlordane began in the 40s yet continued until the late 80s;  like other ‘slow plays’ by the agency, as recently evidenced by how it dealt with the insecticide chlorpyrifos, EPA eliminates certain uses of a pesticide but keeps it on the market, registered for other uses. In the case of chlordane, termiticide uses continued to poison the homes, yards and private wells of families around the country, resulting in calls for a country-wide Superfund designation by advocates.

Not only is historical pesticide use still hurting communities of color, but current use pesticides are further compounding these harms. Chlordane contamination presents a significant threat to public health, yet so does glyphosate contamination. A study by the National Park Service found glyphosate and over a half-dozen other current-use pesticides present in vernal pools and waterways in D.C.’s Rock Creek Park. Research published by The Black Institute in 2020, titled Poison Parks, shows in detail how pesticides like glyphosate are disproportionately sprayed in communities of color. Although focused on data from New York City, this trend is likely to hold in major metropolitan areas throughout the United States.

In 2016, the D.C. City Council updated its pesticide laws to reflect a changing regulatory landscape, and better protect residents and the local environment from present-day pesticide contamination. The update was necessary after officials at DDOE failed to properly implement a 2012 law with similar provisions. Advocates returned to the D.C. Council and successfully passed the 2016 update. Yet now, after passage six years ago, DDOE Director Tommy Wells has still not implemented the law.

Thus, while the city makes efforts to remove historical contamination, it is doing nothing to prevent to new pesticides, which pose variety of hazardous chemistries and transformation products, from continuing to contaminate District waterways. Neither DC nor any other community in the U.S. can afford to continue to repeat the same mistakes when it comes to pesticide regulation. With EPA unable to provide effective protections, it is critical that localities take action to pass and implement safer practices for their residents and unique local environments. Help bring these safer practices to your community by telling your mayor or county executives to transition to nontoxic, organic land care practices today.

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

Source: Office of the Attorney General for the District of Columbia press release, DC AG Legal Complaint

(Beyond Pesticides, October 17, 2022)  A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic to ensure sustenance for the nation and world. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

While we are encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty.

Tell EPA, Congress, and your Governor (Mayor in DC) to protect farmworkers from pesticides. Choose organic. 

The acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels.

EPA’s Worker Protection Standards Are Inadequate to Protect Farmworkers. Worker protection standards are set by EPA under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). The original standard was developed after field hearings in the 1970s in which EPA heard from growers, but not farmworkers. After several tries, the WPS still do not adequately protect farmworkers. These standards have been notoriously difficult to enforce and require no record keeping documenting whether the rules have been implemented and only minimal training—all of which can threaten farmworkers and their families.

Systemic Racism is Embodied in EPA’s Risk Assessments. Exposure assessments inevitably discount the impact workers, people of color, and those with preexisting health conditions or comorbidities. For example, EPA routinely calculates worker exposure separately from other exposures. In applying aggregate exposure assessments of pesticides, EPA does not include worker exposure. Risk assessments do not include exposures to multiple chemicals—and such exposures routinely occur to fenceline communities, farmworkers, and factory workers.

In the past, EPA has admitted that even with maximum feasible personal protective equipment (PPE) and engineering controls, including all provisions required by the WPS, risks to workers still exceed EPA’s levels of concern. A 2008 study analyzing poisonings of pesticide workers between 1998 and 2005 concluded that in 30% of the cases of high levels of pesticide exposure, all labeling requirements, including those involving re-entry and PPE, had been followed — clearly demonstrating that the WPS and/or labeling requirements are inadequate.

Farm work is demanding and dangerous physical labor. As the scientific literature confirms, farmworkers, their families, and their communities face extraordinary risks from pesticide exposures. Pesticide application and drift result in dermal, inhalation, and oral exposures that are typically underestimated. A 2004 study detected agricultural pesticides in homes near to agricultural fields. According to a 2010 study, workers experience repeated exposures to the same pesticides, evidenced by multiple pesticides routinely detected in their bodies. As a result of cumulative long-term exposures, farmworkers and their children, who often also work on the farms, are at risk of developing serious chronic health problems such as cancer, neurological impairments, and Parkinson’s disease. Children, according to an American Academy of Pediatrics (AAP) report (2012), face even greater health risks compared to adults when exposed to pesticides. For more information, read our factsheet, Children and Pesticides Don’t Mix.

Congress Should Improve Farmworker Protection in the Law. By leaving farmworker protection entirely under the pesticide law, Congress removed it from the oversight of the Occupational Health and Safety Administration (OSHA). Congress should restore partial jurisdiction over the regulation of pesticide-related occupational hazards to OSHA to ensure better coordination between OSHA and EPA. Simultaneously, Congress should eliminate the small farms exemption from the Occupational Safety and Health Act. Congress should also increase OSHA and EPA appropriations to improve the agencies’ capacity to inspect more of the worksites they regulate, particularly given the Biden Administration’s clear focus on racial equity and justice.

Protections that are present in other environmental statutes are missing in FIFRA, and Congress should correct this oversight. It should appropriate funds for more monitoring and enforcement.

Don’t Forget to Choose Organic Food. Our food choices have a direct effect on those who, around the world, grow and harvest what we eat. This is why food labeled organic is the right choice. In addition to serious health questions linked to actual residues of toxic pesticides on the food we eat, our food buying decisions support or reject hazardous agricultural practices and the protection of farmworkers and farm families. See Beyond Pesticides’ guide to Eating with a Conscience to see how your food choices can protect farmworkers. In addition to choosing organic, it is important to consider food labels that create standards for farmworker safety and fairness.

Tell EPA, Congress, and your Governor (Mayor in DC) to protect farmworkers from pesticides. Choose organic. 

Letter to EPA Administrator

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, to feed us. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by EPA, while study after study documents the disproportionate level of illness among farmworkers.

This acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. While I am encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty. This combination amounts to systemic racism.

EPA’s Worker Protection Standards are inadequate to protect farmworkers. After several tries, the WPS still do not adequately protect farmworkers. These standards have been notoriously difficult to enforce and require no record keeping documenting whether the rules have been implemented and only minimal training—all of which can threaten farmworkers and their families.

In the past, EPA has admitted that even with maximum feasible personal protective equipment (PPE) and engineering controls, risks to workers still exceed EPA’s levels of concern. A 2008 study analyzing poisonings of pesticide workers concluded that in 30% of the cases of high levels of pesticide exposure, all labeling requirements, including those involving re-entry and PPE, had been followed — clearly demonstrating that the WPS and/or labeling requirements are inadequate.

Farm work is demanding and dangerous physical labor. As the scientific literature confirms, farmworkers, their families, and their communities face extraordinary risks from pesticide exposures. Pesticide application and drift result in dermal, inhalation, and oral exposures that are typically underestimated. As a result of cumulative long-term exposures, farmworkers and their children, who often also work on the farms, are at risk of developing serious chronic health problems such as cancer, neurological impairments, and Parkinson’s disease. Children, according to an American Academy of Pediatrics report (2012), face even greater health risks compared to adults when exposed to pesticides.

Please implement strong Worker Protection Standards and reverse the weakening changes of the Trump administration. More fundamentally, EPA must base its pesticide risk assessments on the dangers to the most vulnerable people—farmworkers and their families. EPA must reverse its policy and require that risk assessments adopt a standard that protects farmworkers. Penalties for violations of the WPS should be increased to reflect the grave harm caused to human health and safety. Higher penalties are crucial to create a deterrent effect.

Thank you.

Letter to U.S. Senators and Representative

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, for ensuring that we are kept well-fed. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

This acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. By leaving farmworker protection entirely under the pesticide law, Congress removed it from the oversight of the Occupational Health and Safety Administration (OSHA). Congress should restore partial jurisdiction over the regulation of pesticide-related occupational hazards to OSHA to ensure better coordination between OSHA and EPA. Simultaneously, Congress should eliminate the small farms exemption from the OSH Act. Congress should also increase OSHA and EPA appropriations to improve the agencies’ capacity to inspect more of the worksites they regulate, particularly given the Biden Administration’s clear focus on racial equity and justice.

Protections that are present in other environmental statutes are missing in FIFRA, and Congress should correct this oversight. This could include consideration of a private right of action, a greater ability for EPA to address states’ nonattainment of minimum standards, and other measures to strengthen states’ incentives to remain in compliance.

While I am encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty.

Congress should grant EPA greater authority to respond to states failing to meet enforcement goals, including the authority to impose sanctions related to the agriculture industry. Congress can look to other environmental statutes, such as the CAA, where it has given EPA the authority to impose sanctions for noncompliance in the interest of public health.

Congress should appropriate more funds to NIOSH’s SENSOR program to support states in consistently reporting data on acute pesticide-related illness and to expand the number of states in the program.

Thank you for taking action to protect farmworkers.

 Letter to Governor

A recent report, Exposed and At Risk: Opportunities to Strengthen Enforcement of Pesticide Regulations for Farmworker Safety, by the Center for Agriculture and Food Systems at Vermont Law and Graduate School, in partnership with the nonprofit advocacy group, Farmworker Justice, again highlights the systemic racism of our country’s pesticide policies. Our nation depends on farmworkers, declared “essential workers” during the COVID-19 pandemic, for ensuring that we are kept well-fed. Yet the occupational exposure to toxic pesticides by farmworkers is discounted by the Environmental Protection Agency (EPA), while study after study documents the disproportionate level of illness among farmworkers.

This acceptance of harm to farmworkers is embodied in national and state policies under the purview of EPA, Congress, and state agencies. Correcting the injustice requires a concerted effort at all levels. While I am encouraged to see the formation of EPA’s new Office of Environmental Justice and Civil Rights, the agency has a historical bias against preventive action to ensure the protection of those disproportionately poisoned by toxic chemicals. While critically important to clean up contaminated communities, EPA must stop the flow of toxic pesticides at the front end because of the disproportionate poisoning effects of use, handling, transportation, and disposal. We live in an age of practices and products that make toxic pesticides unnecessary and their use unconscionable. Yet, EPA insists on the acceptability of harm (which it calls risk), despite its failure to (i) recognize comorbidities and preexisting health conditions, (ii) consider a combination of multiple chemical exposure interactions, and (iii) cite extensive missing health outcomes information (e.g., on endocrine disruption) and a resulting high level of uncertainty.

As Governor of our state, please commit to reducing the influence of industry over pesticide regulation. At a minimum, prohibit enforcement officials from being involved in sale, manufacture, or distribution of pesticides, as California has done.

Please implement a neighbor notification system to reduce the incidence of exposure caused by pesticide drift.

Mandatory reporting requirements, both for pesticide use and for incidents of pesticide exposure, would offer protection to both farmworkers and the general public. The state department of health should more authority to conduct inspections and investigations of suspected pesticide exposure incidents, independent of the state’s designated lead agency.

Penalties for violations of the WPS (or state-equivalent regulations) should be increased to reflect the grave harm caused to human health and safety. Higher penalties are crucial to create a deterrent effect.

Thank you.

(Beyond Pesticides. October 14, 2022) A team of researchers has taken on the challenge of integrating data from multiple and disparate sources in order to devise tools with which scientists can evaluate pollinator pesticide exposures and impacts more effectively at “landscape scale” (and at real-life exposure levels). Accessing data that are useful and relevant at this landscape level has been a significant problem for researchers and conservationists. This “zoomed out” view is critical because pollinators are highly mobile across thousands of meters of foraging area. A functional understanding of the risks pollinators encounter in their territories requires integrated data at this level, as opposed to the large geographic areas across which pesticide use is typically tracked. The team’s paper on their work — Putting pesticides on the map for pollinator research and conservation — was published in Nature.com in mid-September.

Pollinators are essential to healthy ecosystems and to a third of human food sources, as well as to plants used for commercial seed production. As the authors note, nearly 90% of flowering plant species benefit from the services of pollinators that help plants set their seeds and produce flowers and fruit (this last term includes foods widely considered to be “vegetables,” but which are the product of pollination). But for years, pollinators and insects broadly have been in dramatic decline, making worse the biodiversity crisis we face globally.

Pesticides are a chief driver of pollinator decline, along with habitat fragmentation and loss caused by human development and encroachment; these drivers are, according to the study authors, most documented for honey bees (including managed colonies), wild bees, and butterflies. The loss of appropriate habitat reduces food and nesting resources for these populations, and pesticide exposures can outright kill pollinators or lead to behavioral, immunological, and/or reproductive impacts. In addition, herbicide use can mitigate against pollinator health by reducing their plant food sources. Neonicotinoid and organophosphate insecticides are among the worst pesticides for these and other insect populations — and are commonly used; see here and here.

The coauthors explain their mission: “Scientists’ and conservationists’ ability to [evaluate pollinator decline] has been limited by a lack of accessible data on pesticide use at relevant spatial scales and in toxicological units meaningful to pollinators. Here, we synthesize information from several large, publicly available datasets on pesticide use patterns, land use, and toxicity to generate novel datasets describing pesticide use by active ingredient . . . and aggregate insecticide load . . . for state–crop combinations in the contiguous U.S. Furthermore, by linking pesticide datasets with land-use data, we describe a method to map pesticide indicators at spatial scales relevant to pollinator research and conservation.”

The datasets they have created include these, for 10 major crops (or crop groups) in each of the 48 contiguous U.S. states.

• average application rate of more than 500 common pesticide active ingredients (1997–2017)
• aggregate bee toxic load (honey bee lethal doses) of all insecticides combined (1997–2014); note that this dataset ends in 2014 because after that year, data on seed-applied pesticides were excluded, and these contribute significantly to bee toxic load
• reclassification tables relating these pesticide-use indicators to land use/land cover classes, enabling the creation of maps predicting annual pesticide loading (at 30–56 m resolution)

According to the study paper, researchers have heretofore generated useful models for predicting pollinator abundance and ecosystem services as a function of the landscape, especially for wild and honey bees, and monarch butterflies. But the subject researchers assert that these models could be vastly improved by integrating into them metrics on patterns of pesticide use, in the geographic areas under consideration, at landscape scale.

The team identifies several hurdles encountered in their work: (1) U.S. data on pesticide use, land use, and pesticide toxicity are spread across “disparate government databases, each with idiosyncratic nomenclature and organization”; (2) available pesticide use data are reported as averages at primarily county, state, or national scales, whereas data on pollinator populations are structured at smaller scales, e.g., hundreds or thousands of meters (for foraging ranges); and (3) because there are hundreds of commonly used active pesticide ingredients, the available data do not generally capture the relevant toxicity “doses” to which pollinators are exposed; translating pesticide use data into relevant “units of toxicity” would help researchers evaluate aggregate/cumulative and synergistic impacts.

The researchers tackle these obstacles, and created datasets and methods that allow mapping of pesticide use estimates to extant land use data. They recommend “matching state-level, crop- and year-specific pesticide use averages to land use estimated through remote sensing.” Through these methods, they say, it is “possible to generate maps of predicted bee toxic load and individual active ingredients at 30 m resolution, a finer spatial grain than reported in our county-level analysis, and one more suited to landscape research on pollinator populations and communities. . . . Moreover, while this work is motivated primarily by the effects of pesticides on pollinators, the estimates and mapping method we describe have potential application in a wide array of settings ranging from water quality monitoring to human epidemiology.”

The researchers note that their focus on bee toxic insecticides was largely because (1) the quality of available data on insecticides is both higher and more consistent than that for herbicides and fungicides; (2) insecticides have greater acute toxicity than the other two categories (“insecticides account for > 95% of bee toxic load nationally, even when herbicides and fungicides are included, and even though insecticides make up only 6.5% of pesticides applied on a weight basis”); and (3) focusing metrics on insecticides “increases their interpretability, reflecting efforts directed toward insect pest management, rather than a mix of insect, weed, and fungal pest management.”

To support other researchers and conservationists (and other interested parties) in exploring insecticide use patterns, the team created an interactive website: https://insecticideexplorer.shinyapps.io/insecticideexplorer/. It allows users to generate graphs showing trends in national and state-level insecticide use, and to download reclassification tables for bee toxic load for particular state–year combinations.

This research team tackled a troublesome byproduct of how pesticide use is evaluated — the “siloing” of information, which relates to how science “works.” For all the utility of the scientific norm of isolating variables, there is also great risk in making this the sole means of scientific inquiry. Traditionally, scientists break down phenomena into constituent parts, and look for mechanistic, linear causality. But the work of both Rachel Carson (on pesticide impacts) and Theo Colborn (on endocrine disruption and later, the dangers of fracking), for example, demonstrates that this “narrowed field” lens is not adequate to the systemic and highly interactive problems of our globalized, technological, and chemically saturated world. This is eminently so for attempts to understand the multiplicity of factors, among which pesticide use looms large, that attend the dramatic decline in pollinator populations and health, and the broader and global “insect apocalypse.”

Beyond Pesticides has long worked toward adoption of more holistic and precautionary approaches to evaluating and regulating pesticides. Beyond our clamor for more-comprehensive risk assessment and more-protective regulation stands the genuine solution for which we advocate: “eschewing pesticide use, and focusing on soil health, diversification, and sustainable practices — [essentially,] organic and regenerative farming and land management” practices that can help reverse the decline of pollinator health and populations. The public can contribute to this effort by purchasing organic whenever possible (whether at the supermarket or, even better, from local farms and CSA [Community Supported Agriculture] programs), planting diverse, pesticide-free habitat on your property, and encouraging local communities to follow suit.

Source: https://www.nature.com/articles/s41597-022-01584-z

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

(Beyond Pesticides, October 13, 2022) Offspring’s exposure to glyphosate-based herbicides (GBHs) preceding and proceeding birth (perinatal) induces liver damage. A study published in Toxicology and Applied Pharmacology demonstrates the role excess iron in the body from GBH exposure plays in liver toxicity via an increased uptake of calcium and oxidative stress. The liver, the largest solid organ in the human body, is an essential part of the digestive system, responsible for blood detoxification, nutrient metabolization, and immune function regulation. The rates of chronic liver diseases are increasing, representing the second leading cause of mortality among all digestive diseases in the U.S.

Because GBHs are ubiquitous in many herbicide products, studies report that these toxic chemical compounds are detectable in infants, children, and pregnant women. Children are particularly vulnerable to the impacts of pesticide exposure as their developing bodies cannot adequately combat exposure effects. Although studies show how chemical exposures affect overall human health, more research is now questioning how these toxic chemicals influence digestive health and the subsequent occurrence of diseases. Therefore, it is essential to understand how harmful chemical exposure impacts health and well-being during critical developmental periods. The study notes, “[T]he possible role played by perinatal exposure to GBH on the onset of adverse outcomes later in life show an urgent need for research to understand the impact of early life exposure to this herbicide to ensure well-being across life stages.”

The perinatal period is one of the more susceptible timeframes for adverse health effects among infants from environmental exposure. However, the consequences of perinatal exposure to GBH in children’s health outcomes lack complete understanding. To access how GBH exposure impacts offspring, researchers exposed pregnant Wistar rats to relevant doses of glyphosate in drinking water during the perinatal period, day five of gestation day until day 15 postpartum. During this period, GBH exposure increased calcium influx and iron accumulation in the offspring’s liver, resulting in oxidative stress and inflammation. The imbalance in calcium and iron depletes and alters the glutathione (GSH) enzyme responsible for the antioxidant defense against xenobiotics (e.g., external chemicals, drugs, pesticides, carcinogens) for detoxification by making these compounds more soluble. Moreover, excess iron levels present a biomarker for liver injury as excessive amounts of iron may increase reactive oxygen species (ROS), activating inflammatory enzyme pathways. 

Glyphosate is the most commonly used active ingredient worldwide, appearing in many herbicide formulations and readily contaminating soil, water, food, and other resources. Decades of extensive glyphosate herbicide use (e.g., Roundup) have put human, animal, and environmental health at risk. Four out of five U.S. individuals over six years have detectable levels of glyphosate in their bodies. Exposure to glyphosate has implications for the development of various health anomalies, including cancer, Parkinson’s disease, developmental and birth disorders, and autism. Although the U.S. Environmental Protection Agency (EPA) classifies glyphosate herbicides as “not likely to be carcinogenic to humans,” stark evidence demonstrates links to various cancers, including non-Hodgkin lymphoma. EPA’s classification perpetuates adverse impacts, especially among vulnerable individuals, like pregnant women, infants, children, and the elderly. Glyphosate’s ubiquity threatens 93 percent of all U.S. endangered species, resulting in biodiversity loss and ecosystem disruption (e.g., soil erosion, loss of services, and trophic cascades). Moreover, chemical use has been increasing since the inception of crops genetically modified to tolerate glyphosate. Not only do health officials warn that continuous use of glyphosate will perpetuate adverse health and ecological effects, but that use also highlights recent concerns over antibiotic resistance. This increase in resistance is evident among herbicide-tolerant GE crops, including seeds genetically engineered to be glyphosate-tolerant.

This study demonstrates the role of iron accumulation in the liver, blood, and bone marrow plays in oxidative damage and inflammation, and the association with calcium influx. Therefore, the results of this study and others like it will clarify the mechanism ultimately involved in chemical-medicated liver dysfunction and associated diseases. Regarding glyphosate, past studies find links between chemical exposure and liver impacts. A 2015 study found that chronically exposing rats to ultra-low doses of glyphosate in drinking water results in tissue and organ damage, including changes to gene expression within the liver and kidneys. And a 2017 study, which also fed minuscule doses of glyphosate weed killer to rats, found an increased likelihood that exposed animals would develop non-alcoholic fatty liver disease. Like this study, research suggests glyphosate exposure increases proinflammatory cytokine proteins in the blood, especially TNFα. Excessive iron accumulation in the body augments ROS availability and subsequent activation of proinflammatory enzymes in response. The overexpression of these proinflammatory proteins has associations with cancer, rheumatoid arthritis, psoriasis, multiple sclerosis, and other diseases. 

Therefore, the study concludes, “The GBH-induced oxidative stress in rat liver is associated with iron accumulation and may induce early epigenetic changes that could lead to adverse outcomes later in life. […] Therefore, we suggest that the neurotoxic effects of glyphosate previously reported by us may be connected to the iron accumulation demonstrated in the present study. However, whether iron accumulation and developmental neurotoxicity after GBH exposure are linked needs to be further evaluated.”

Beyond Pesticides challenges the registration of chemicals like glyphosate in court due to their impacts on soil, air, water, and our health. While legal battles press on, the agricultural system should eliminate the use of toxic synthetic herbicides to avoid the myriad of problems they cause. Chemical exposures have real, tangible impacts not only on individuals but on society as a whole. Pesticides impose unnecessary hazards on children’s health. Early life exposures during “critical windows of vulnerability” can predict the likelihood or otherwise increase the chances of an individual encountering a range of pernicious diseases. Environmental disease in children costs an estimated $76.8 billion annually. Exposures that harm learning and development also impact future economic growth in the form of lost brain power, racking up a debt to society in the hundreds of billions of dollars. Therefore, it is essential to mitigate preventable exposure to disease-inducing pesticides. For more information about pesticides’ effects on human and animal health, see Beyond Pesticides’ Pesticide-Induced Diseases Database, including pages on immune system disorders (e.g., hepatitis [liver condition]), birth abnormalities, brain, and nervous system disorders, and more.

One way to reduce human and environmental contamination from pesticides is to buy, grow, and support organic. Numerous studies show that switching to an organic diet can rapidly and drastically reduce the levels of synthetic pesticides in one’s body. A 2020 study found a one-week switch to an organic diet reduced an individual’s glyphosate body burden by 70%. Furthermore, given the wide availability of non-pesticidal alternative strategies, these methods can promote a safe and healthy environment, especially among chemically vulnerable individuals or those with health conditions. For more information on why organic is the right choice for consumers and the farmworkers that grow our food, see the Beyond Pesticides webpage, Health Benefits of Organic Agriculture.

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

Source: Toxicology and Applied Pharmacology

(Beyond Pesticides, October 12, 2022) The U.S. Environmental Protection Agency (EPA) is asking a federal court for permission to go back and reconsider its decision to reapprove use of the highly hazardous herbicide paraquat, according to a filing submitted by the agency late last month. Advocates see the move as encouraging, since meaningful EPA action on this Parkinson’s-linked chemical is long overdue. Last year, advocates condemned the Biden Administration for its reapproval of the weed killer with fewer protections than those proposed by the Trump Administration, marking a deeply concerning sign for pesticide reform campaigners looking to the administration for positive change.

EPA’s request is the result of a legal challenge brought by the California Rural Legal Assistance Foundation, Earthjustice, Farmworker Association of Florida, Pesticide Action Network, and the Michael J. Fox Foundation for Parkinson’s Research.  The groups argued that the agency’s decision to reregister paraquat was not legal based on substantial evidence that the chemical poses unreasonable risks to human health and the environment.

While EPA made its initial decision to reapprove paraquat in the late days of the Trump Administration, it was under the Biden Administration that the agency reversed a proposed ban on aerial use, permitting broad-scale spraying of this dangerous chemical. According to reporting from EENews, the agency used information provided by an industry umbrella group dubbed the Agricultural Handler Exposure Task Force, a consortium of chemical companies that includes BASF, Bayer Monsanto, Corteva, FMC, and Syngenta/ChemChina, the primary producer of paraquat. Data produced by this cabal of chemical companies appeared to show that EPA miscalculated risks to workers, and as a result, aerial spray campaigns must be permitted. EPA’s decision to accept industry positions stands in sharp contrast to its interaction with farmworker, health, and environmental campaigners. Over 50 groups signed on to oppose the reregistration of paraquat, but were provided no substantive response from the agency.

Paraquat is the most dangerous herbicide still on the market. As the agency readily admits, “One small sip [of paraquat] can be fatal, and there is no antidote.” In addition to its high acute toxicity, it also presents a range of chronic concerns, including cancer, damage to the reproductive system and organs like the kidney and liver. It also poses hazards to birds and bees, and is prone to leaching into groundwater, where it disrupts the stability of aquatic ecosystems.

Standing out among the wide range of impacts that make clear this chemical poses unreasonable risks are its neurotoxic effects. Inhalation of low doses can disrupt one’s sense of smell, and past research has found the chemical can cause damage to the lungs of farmers who apply it. Data is increasingly showing that cumulative exposures over one’s life increases risk of developing Parkinson’s disease, and other factors such as genetics, and exposure to other chemicals further elevates the threat. Recent studies have even found that one’s zip code and proximity to paraquat’s use in farm field is likely playing a role in an individual’s Parkinson’s Disease risk. Strong links to this chronic condition are incredibly concerning given emerging evidence of a Parkinson’s pandemic, predicting that rates of the disease will double between now and 2040.

In addition to health and environmental risks from the use of paraquat are growing legal troubles for its primary manufacturer Syngenta, a Switzerland based company that was purchased by the Chinese National Chemical Corporation (ChemChina) in 2016. Mounting lawsuits against Syngenta/ChemChina were consolidated and are set to begin jury trials next year for farmworkers and other individuals who worked with paraquat and are now suffering from Parkinson’s disease. Plaintiffs in the suit claim “that manufacturers and sellers of paraquat deliberately concealed the dangers of paraquat for at least four decades, hid evidence of its dangers from government safety agencies, and knowingly unleased a product they knew caused Parkinson’s Disease on the public.”

Advocates are uncertain how far EPA will go in restricting paraquat, and underline that more public pressure is needed for EPA to act meaningfully. Other recent decisions by the agency on dangerous herbicides dicamba and glyphosate are not cause for much hope. After acknowledging a range of problems with dicamba formulations registered for genetically engineered crops, including an Office of Inspector General Report, a court case that noted the chemical “would tear the social fabric of farming communities” and completely vacated the registration, and a mea culpa from EPA’s acting assistant administrator that “political interference sometimes compromised the integrity of our science,” EPA went ahead and reregistered dicamba formulations with very few additional restrictions. On glyphosate, despite a range of high profile lawsuits, and strong links to cancer, the agency waited for a federal court to void its registration.

Perhaps EPA is trying to get ahead of the curve with paraquat. Rather than wait for a court decision and completely fail to hit mandated deadlines as the agency has done with glyphosate, EPA is requesting the ability to review paraquat at its leisure, with no deadline for a decision. Yet, experience with the agency shows that remanding “without vacatur” – (i.e., without removing paraquat from commerce) permits pesticide manufacturers to continue to sell their products without any new, protective regulatory measures.

It is not acceptable to need to use the court system to force EPA to conduct the work it should always be doing to protect health and the environment. For too long, agrichemical companies have driven EPA to make decisions at the behest of their overpaid executives over the health and well-being of the general public. Join us in urging the Biden EPA to stand up to pesticide manufacturers by holding them accountable for the dangers associated with their products.

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

Source: Ninth Circuit Court Filing, AboutLawsuits.com.

(Beyond Pesticides, October 11, 2022) Without continuously improving organic standards and certification, advocates maintain that there is no holistic way to combat the existential crises associated with petroleum-based pesticides and fertilizers—the multiple and growing health threats, biodiversity collapse, and the climate emergency. Have you been confused at the egg case in your grocery store where egg carton labels proclaim “cage-free,” “free-range,” and “pasture raised” organic eggs? The U.S. Department of Agriculture (USDA) is accepting comments on proposed regulations to protect the welfare of livestock and poultry on organic farms. The Organic Livestock and Poultry Standard (OLPS) is a slightly revised version of the Organic Livestock and Poultry Practices (OLPP) rule, which was promulgated after many delays in January 2017, then withdrew the rule before it became effective.

USDA acknowledges that a failure to act on OLPS undermines the organic market, saying “a market failure exists in the organic label,” and the intent of new standard is to “clarify and ensure consistent application of the USDA organic standards.” The inconsistent application of organic standards by certifiers has resulted in a plethora of add-on labels that ensure that organic livestock and poultry production meet the expectations of organic consumers.

However, the proposed OLPS lacks the specificity to meet the stated intention and if implemented, will allow the inconsistencies among certifiers to continue. In order to protect the meaning of the organic label, a few changes are needed. Since these changes are consistent with the stated intentions of USDA, they should not cause delay in implementing the OLPS. Please tell USDA to make the changes listed below.

This action requires a submission at Regulations.gov. Members of the public can copy and paste from Beyond Pesticides’ suggested comment below.

Suggested Public Comment

The proposed OLPS lacks the specificity to meet USDA’s stated intention and if implemented, will the inconsistencies among organic certifiers to continue. In order to protect the meaning of the organic label, a few changes are needed. Since these changes are consistent with the stated intentions of USDA, they should not cause delay in implementing the OLPS. Please make the following changes.

*Do not allow current producers to continue practices inconsistent with the proposed rule for 5-15 years. Three years is adequate for existing operations to provide the outdoor access required in the regulation.

*Define “outdoors” to be soil-based with maximal vegetative cover appropriate for the season, climate, geography, species of livestock, and stage of production.

*Define “access to the outdoors” for poultry to be “having sufficient exit areas that are appropriately distributed to ensure that all birds have ready access to outdoors no more than 10 feet from the house; exit areas for birds to get outside must be designed so that more than one bird at a time can get through the opening and to have a combined length of at least 12 ft per 1,000 ft² area of the house available to the birds.”

*Do not permit estimates of stocking rates to be based on expected mortality.

*Require that artificial light supplement rather than substitute for natural light. Adopt OLPP provision that required an inspector to be able to read and write with lights turned off on a sunny day. Do not allow any birds to be raised in darkness.

*Remove the provision that allows confinement in inclement weather, including when air temperatures are under 40 degrees F or above 90 degrees F. This loophole could allow confinement for as much as half the year. The provision for confinement in “conditions under which the health, safety, or well-being of the animal could be jeopardized” is sufficient and puts the onus on the producer to demonstrate ill effects of outdoor access, and birds can judge whether they want to go outside in “inclement” weather.

*Monitoring for ammonia levels in poultry houses must be performed frequently—automated continuous monitoring is possible in large houses—and must measure ammonia at the height at which the birds are breathing.

To compromise on the above foundational issues is to undermine public trust in the organic label and the growth of the organic sector. A failure to protect public trust in the USDA organic label for livestock and poultry is to a failure for all of organic and threatens the progress being made in the organic marketplace.

Thank you.

(Beyond Pesticides, October 10, 2022) The National Museum of the American Indian, a part of the Smithsonian Institution, sits on the National Mall in Washington, DC and as a part of its history program is commemorating Indigenous Peoples’ Day on October 10. This year, President Biden, while commemorating Columbus Day, issued the second Presidential Proclamation on Indigenous Peoples’ Day. The National Museum of the American Indian marks the day with an effort to teach the true history of the United States. This history is introduced on the Museum’s website with the following:

Unlearning Columbus Day Myths: Celebrating Indigenous Peoples’ Day
“Many students learn the phrase, “In 1492, Columbus sailed the ocean blue”. But Columbus was not the first foreign explorer to land in the Americas. Neither he nor those that came before him discovered America—because Indigenous Peoples have populated the Western Hemisphere for tens of thousands of years. European contact resulted in devastating loss of life, disruption of tradition, and enormous loss of lands for Indigenous Peoples in the Americas. It is estimated that in the 130 years following first contact, Native America lost 95 percent of its population.”

“Indigenous Peoples of the Western Hemisphere immediately experienced enslavement and theft of resources by the explorers turned settlers. Colonies created by the Portuguese, Spanish, French, Dutch, and English grew throughout the Americas and increasingly encroached upon Native lives and lands. Warfare, enslavement, and forced relocation disrupted and altered the lives of Indigenous Peoples in the Americas. Celebrating Columbus and other explorers like him dismisses the devastating losses experienced by Indigenous Peoples of the Western Hemisphere in the past and the ongoing effects of colonialism today.”

“Indigenous Peoples are still here. Contemporary Native Americans have led numerous movements to advocate for their own rights. Native people continue to fight to maintain the integrity and viability of Indigenous societies. American Indian history is one of cultural persistence, creative adaptation, renewal, and resilience. Native Peoples, students, and allies are responsible for official celebrations of Indigenous Peoples’ Day in such states as Maine, Oregon, Louisiana, New Mexico, Iowa, and Washington, DC. Indigenous Peoples’ Day is celebrated on the second Monday of October and recognizes the resilience and diversity of Indigenous Peoples in the United States.”

“We promote including Indigenous perspectives, like those of the Taíno Peoples, to provide a more complete narrative when teaching about Columbus. We encourage students to advocate for Indigenous Peoples’ Day as a replacement for Columbus Day in their school, city, state, and beyond.”

Fenway Community Health Center on Indigenous Peoples’ Day

Fenway Community Health Center in Boston, Massachusetts eliminated Columbus Day as an organizational holiday, replacing it with a floating holiday that individual staff can use for a religious or cultural observance/occasion or other purpose of their choosing. This step was taken in August 2020 as part of its broad organizational commitment to “racial equity in everything we do and to work to undo disparities and inequities that exist. Fenway Health explains that its mission “advocates for and delivers innovative, equitable, accessible health care, supportive services, and transformative research and education. It also centers LGBTQIA+ people, BIPOC [Black, indigenous, People of Color] individuals, and other underserved communities to enable our local, national, and global neighbors to flourish.” As Fenway Health says, “This day is a time to honor and celebrate the histories, cultures, and contributions of Native American people in the United States. It is also a time to acknowledge and reflect upon the grave mistreatment of Indigenous people throughout U.S. history.”

A Proclamation on Indigenous Peoples’ Day, 2022, The White House

When the first presidential proclamation on Indigenous Peoples’ Day was issued in 2021 (see 2022 Proclamation below), it said, “For generations, Federal policies systematically sought to assimilate and displace Native people and eradicate Native cultures. Today, we recognize Indigenous peoples’ resilience and strength as well as the immeasurable positive impact that they have made on every aspect of American society. We also recommit to supporting a new, brighter future of promise and equity for Tribal Nations — a future grounded in Tribal sovereignty and respect for the human rights of Indigenous people in the Americas and around the world.”

2022 Presidential Proclamation
On Indigenous Peoples’ Day, we honor the sovereignty, resilience, and immense contributions that Native Americans have made to the world; and we recommit to upholding our solemn trust and treaty responsibilities to Tribal Nations, strengthening our Nation-to-Nation ties.

For centuries, Indigenous Peoples were forcibly removed from ancestral lands, displaced, assimilated, and banned from worshiping or performing many sacred ceremonies.  Yet today, they remain some of our greatest environmental stewards.  They maintain strong religious beliefs that still feed the soul of our Nation.  And they have chosen to serve in the United States Armed Forces at a higher rate than any other group.  Native peoples challenge us to confront our past and do better, and their contributions to scholarship, law, the arts, public service, and more continue to guide us forward.

I learned long ago that Tribal Nations do better when they make their own decisions.  That is why my Administration has made respect for Tribal sovereignty and meaningful consultation with Tribal Nations the cornerstone of our engagement and why I was proud to restore the White House Council on Native American Affairs.  To elevate Indigenous voices across our Government, I appointed Deb Haaland as Secretary of the Interior, the first Native American to serve as a cabinet secretary, along with more than 50 other Native Americans now in significant roles across the executive branch.

My Administration is also directly delivering for Native communities — creating jobs, providing critical services, and restoring and preserving sacred Tribal lands.  We have made the biggest investment in Indian Country in history, securing billions for pandemic recovery, infrastructural improvements, and climate change resilience, and we are working together with Tribal Nations to end the scourge of violence against Indigenous women and girls.

These efforts are a matter of dignity, justice, and good faith.  But we have more to do to help lift Tribal communities from the shadow of our broken promises, to protect their right to vote, and to help them access other opportunities that their ancestors were long denied.  On Indigenous Peoples’ Day, we celebrate indigenous history and our new beginning together, honoring Native Americans for shaping the contours of this country since time immemorial.

NOW, THEREFORE, I, JOSEPH R. BIDEN JR., President of the United States of America, do hereby proclaim October 10, 2022, as Indigenous Peoples’ Day.  I call upon the people of the United States to observe this day with appropriate ceremonies and activities.  I also direct that the flag of the United States be displayed on all public buildings on the appointed day in honor of our diverse history and the Indigenous peoples who contribute to shaping this Nation. 

IN WITNESS WHEREOF, I have hereunto set my hand this seventh day of October, in the year of our Lord two thousand twenty-two, and of the Independence of the United States of America the two hundred and forty-seventh.