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

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

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

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

Investigation Summary

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

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

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

Health Impacts of Telone

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

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

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

Industry Interference

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

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

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

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

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

Call to Action

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

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

Source: Inside Climate News

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Source:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Context

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

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

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

Science Behind Paraquat

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

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

Applying The Dacthal Standard & End Paraquat Registration

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

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

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

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

Call to Action in Alignment with National Organic Month

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

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

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

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

Sources: Los Angeles Times

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

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

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

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

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

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

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

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

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

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

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

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

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

Sources:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Source:

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

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

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

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

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

Some additional main takeaways include:

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

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

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

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

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

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

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

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

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

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

Source: British Journal of Environmental Sciences

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you.

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

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

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

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

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

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

Thank you.

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

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

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

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

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

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

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

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

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

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

Sources:

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

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

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

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

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

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

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

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

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

Kenya

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

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

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

Brazil

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

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

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

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

European Union-Mercosur

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

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

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

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

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

Call to Action

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Source: 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Source: 

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

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

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

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

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

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

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

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

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

Some priority issues for Beyond Pesticides at this meeting are: 

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

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

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

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

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

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

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

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

(Beyond Pesticides, September 6, 2024) A literature review in the Internal Journal of Molecular Sciences provides promising insights into biofungicides as a “sustainable and economically viable alternative” to synthetic fungicides in expanding organic agriculture. The authors note that organic “… is the most sustainable response to current crises of all kinds, as it can better anticipate and prepare for crises and create long-term equity and resilience in food systems.” The authors point out that fungal infections in crops are estimated to account for 20-40% of failures annually, and understanding how to control such agricultural diseases will be crucial to meeting the needs of a growing global population. Organic farmers and land managers note that biological tools can be integrated into practices that work with the ecosystem, rather than be utilized as “substitute” products or controls with practices that ignore soil health and beneficial organisms that enhance biodiversity and provide ecosystem services (see here and here).

Conducted by researchers in Mexico, the review examines data on biosynthesis (how plants create their own fungicide, known as secondary metabolites or SMs); the mechanisms of action of secondary metabolites against phytopathogenic (plant-killing) fungi; extraction techniques and biofungicide formulations; the biological activity of plant extracts on phytopathogenic fungi; and an overview of the current regulation and use of biofungicides in agriculture.

According to the authors, many plants can synthesize one or more of several types of secondary metabolites (SMs) that create very specific conditions. SMs can be categorized into groups based on their chemical structure and biological activity: terpenes (including volatile compounds, sterols, and carotenoids), polysaccharides, phenolic compounds, phytoalexins (sulfur-containing compounds), alkaloids (nitrogen-containing compounds), flavonoids, and hydrocarbons. These compounds are often specific to a plant genus or family and often produced in small amounts. Given their natural origins, they are environmentally friendly with a short environmental lifespan that does not pollute soil and water. It is believed that SMs can even create a microclimate by slowing respiration and thereby protecting the plant during unfavorable conditions.

Because the targeted biofungicides come from natural rather than synthetic ingredients, the authors cite research indicating limited persistence with a reduced half-life in the environment when used. The article notes that while not always harmless to other plants and organisms, plant-based chemical compounds can impact nontarget organisms, but are less toxic than synthetic pesticides. Depending on the plant source and the concentrations used, biofungicides have little influence on the growth, survival, development, and reproduction of other organisms. The review continues and notes that biofungicides exhibit “no residual hazards, and minimize “the pollution of soil, water, and the atmosphere… and finally, they promote a reduction in health problems in farmers, such as chronic degenerative diseases of the skin and respiratory tract associated with the use of synthetic pesticides.” (See here for authors’ citations). Health and environmental advocates note that synthetic fungicides are not only associated with adverse effects on health and the environment but also precipitate resistant fungi that threaten health on a global scale. (See Beyond Pesticides’ reporting on antimicrobial and fungal threats here, here, and here).

Researchers identify three SM primary types: terpenes and terpenoids, alkaloids, and phenolic compounds that are produced via four different mechanisms: the shikimic acid pathway, the malonic acid pathway, the mevalonic acid pathway, and the non-mevalonate (MEP) pathway.

Terpenes
Research shows that due to their lipophilic nature, terpenes can work against fungi by infiltrating the fungal cell membrane and destabilizing the cell. Terpenes can also destroy mitochondria, the part of the cell responsible for energy production, and induce cell death by cellular respiration and oxidative phosphorylation or inhibition of electron transport in the mitochondrial electron transport chain.

Phenolic Compounds
Researchers hypothesize that phenolic compounds can depolarize [neutralize] cellular and mitochondrial membranes of fungi, impairing the ion gradients and eventually causing cell death. Phenolic compounds can also inhibit key enzymes necessary for proper functioning of the biological system. It has also been demonstrated that phenolic compounds can modulate gene expression, which can alter growth, development, and reproduction of fungi.

Alkaloids
Alkaloids have been known to impair fungal gene replication and transcription by infiltrating the fungus’ DNA. They can also disrupt ion gradients in cell membranes by creating ion channels, leading to cell death. Alkaloids can also attach to proteins in the fungal organism, which prevents them from interacting with a plant’s receptors and prevents colonization and infection by the fungus.

The research also highlights that certain biofungicides operate similarly to synthetic fungicides due to a chemical structure akin to fungi’s naturally occurring nucleic acids, which prevent the proper performance of fungi biological functions, such as acylalanines which inhibit ribosomal RNA synthesis. Researchers identify extraction methods using specific solvents via conventional and unconventional techniques. Primarily, extraction is done using solvents and either heating and/or mixing. The type of solvent used depends on the type of compound to be extracted and largely determines the efficiency of the extraction. According to researchers, the polarity of the desired product is the most important factor determining which solvent should be used for extraction. Conventional extraction methods include the Soxhlet extraction, maceration, and hydrodistillation, while unconventional methods include ultrasound-assisted extraction, pulse electric field extraction, enzyme-assisted extraction, microwave-assisted extraction, pressurized liquid extraction, and supercritical fluid extraction.

The authors highlight several techniques that avoid using solvents (hydrodistillation) or reduce the use of solvents (enzyme-assisted extraction and pressurized liquid extraction) as more environmentally responsible and call for additional considerations when selecting solvents: “environmental safety, human toxicity, and financial viability.” Extract-based biofungicides in agricultural systems offer significant advantages to farmers, including enhanced food security, reduced presence of phytopathogens, improved (crop) product quality, and the potential for higher market prices for organic products. Some examples the authors cite of significant phytopathogenic fungi and effective biofungicides include:

• Monilinia fructicola, which infects crops such as peaches, apricots, plums, almonds, apples, and pears. In one study, scientists used purified polyphenolic extract of orange peel while another study used aqueous extracts of rapeseed and Indian mustard to successfully inhibit the growth of Monilinia fructicola by an average of 95% and 31%, respectively.
  
• The authors called Colletotrichum spp. one of the “most important group of phytopathogenic fungi in the world,” infecting crops such as strawberries, mangoes, avocados, corn, sugarcane, and sorghum and causing sunken necrotic lesions, crown and stem rot, and seedling blight. One study cited found that the extract of Brazilian red propolis inhibited 42% of the growth of Collectotrichum musae within in vitro tests.
• Alternaria alternata, a widespread fungus, is known to cause significant postharvest losses by forming black spots on various fruits and vegetables during cold storage and the marketing period. It affects crops like mangoes, cherry tomatoes, apples, mandarins, kiwifruits, and melons.
• Studies by ​Hernández et al. reveal that polyphenolic extracts from orange peel have potent antifungal activity, completely inhibiting the growth and spore germination of Monilinia fructicola, Botrytis cinerea, and Alternaria alternata. This effect is mainly due to the presence of flavonoids (naringin, hesperidin, and neohesperidin) and phenolic acids (ferulic acid and p-coumaric acid) in the peel.

Despite the promising antifungal properties of these plant extracts, there is no standardized concentration range to classify their effectiveness. Establishing a consensus on concentration ranges is recommended to better categorize these extracts as active, moderately active, slightly active, or harmless, thereby facilitating their application in agricultural settings.

This review demonstrates an evolving understanding of biofungicides—what they are, how they work, and how to acquire them. While the replacement of synthetic fungicides with biofungicides would enable worldwide food production with no or minimal fungicide residue, the authors highlight obstacles still in place preventing broader development.

Currently, the authors note, biofungicides are more expensive and do not yet achieve the level of pest control of traditional synthetic fungicides. There are also challenges related to handling, applying, and producing these natural products that are readily degraded by air, light, and temperature extremes.  In addition, the authors highlight the biopesticide registration processes as a major impediment to a broader scale of use. The cost associated with developing a product, bringing it to market, and navigating national regulation processes can vary globally as biopesticide registration processes rely “too heavily on the criteria used for chemical fungicides and require information that is not as readily available for biofungicides,” noting that expensive toxicological and environmental risk assessments are required, leaving large companies better able to afford the registration process. In the U.S., a biofungicide may be permitted under the Organic Foods Production Act and reviewed by the National Organic Standards Board and the National Organic Program at the U.S. Department of Agriculture as a soil amendment.

The growing demand for organic food contributes, the study argues, to a 15% growth rate for biofungicides annually. Given the detrimental effects of synthetic fungicides on the environment and human health, the authors call for and predict stricter government regulations on synthetic fungicides. This shift could result in increased demand for plant-based alternatives. Plant extracts offer a compelling solution as they are effective, biodegradable, and pose a feasible compared to synthetic chemicals. Transitioning to plant-based formulations aligns well with a forward-thinking approach to food and agricultural policy. Consequently, the production of biofungicides should become standard practice, and clear regulatory frameworks for their commercialization will contribute to the elimination of petrochemical pesticides.  To stay informed and participate in the NOSB review process, sign up for news alerts from Beyond Pesticides here. See also Beyond Pesticides’ Organic Agriculture page.

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

Sources:

Bio-pesticides for agriculture and environment sustainability, International Journal of Molecular Sciences, special issue, Molecular Studies on Plant and Plant In Vitro Systems Secondary Metabolism, June 2024 https://doi.org/10.3390/ijms25136879 

“Biopesticides,” with Broad Definition, Challenged as Unsustainable, Daily News, Beyond Pesticides, August 13, 2021

(Beyond Pesticides, September 5, 2024) As insect-borne diseases like EEE (eastern equine encephalitis) become a focus of mosquito managers, there is a continuing pattern of mosquito resistance to synthetic pyrethroid insecticides, which are the primary tools in conventional mosquito control programs—a strategy more focused on attempting to kill adult mosquitoes than the management of breeding sites. A study published in PLOS One documents Aedes aegypti mosquito resistance to synthetic pyrethroids permethrin, lambda-cyhalothrin, and deltamethrin in study sites in Córdoba, Colombia. Aedes aegypti is a common mosquito species that can carry the EEE virus and others.

There is significant scientific literature highlighting the prevalence of pesticide resistance in mosquito, fly, and other insect populations. Pesticide resistance is an inherent problem with pesticide dependency generally, creating a complex fabric of threats from insect resistance to plant incorporated protectants (PIPs), weed resistance in genetically engineered crop production dependent on chemical-intensive weed control, to antibiotic resistance to medically important drugs, exacerbated by agricultural use and horizontal gene transfer. As the frequency of deadly mosquito vector diseases is expected to increase with rising temperatures and greater precipitation—which raises the number of breeding sites—advocates, physicians, beekeepers, and community leaders are calling on elected officials to prioritize ecological pest management strategies that protect biodiversity and public health.

Methodology and Results

The mosquito resistance study was conducted in the northwestern section of Colombia, an area that the researchers describe as having “eco-epidemiological conditions that facilitate the persistence of the transmission of [dengue virus]” as well as other arboviruses, such as Zika and chikungunya. Researchers at the Universities of Simon Bolivar and Córdoba collaborated with public health officials in the target municipalities in which they collected mosquito populations. They also teamed up with an entomologist at the Public Health Laboratory of Córdoba to analyze resistant mosquito populations using a Centers for Disease Control and Prevention (CDC) bioassay and World Health Organization (WHO) tube method for measuring mosquito mortality after exposure to the pesticide.

The goal of this study is to analyze the susceptibility and resistance rates of mosquito populations sprayed with the three insecticides to inform Córdoba’s public health strategy moving forward. The main mechanism of resistance for synthetic pyrethroids in mosquitoes is knockdown resistance (kdr) mutations, including F1534C, V1016I, and V410L mutations, which researchers identify in this study. Researchers partially attribute pyrethroid resistance to habitual household use of DDT, leading to cross-resistance since both types of insecticides impact mosquitoes’ voltage-gated sodium channel (VGSC), which can cause resistance mutations. While the organochlorine insecticide was prohibited in 1994, previous studies on DDT resistance in Colombia highlight the long-lasting impacts of decades of previous pesticide use (See here and here).

“The results varied between the two techniques used, with resistance to permethrin observed in thirteen of the fourteen populations, resistance to lambda-cyhalothrin in two populations, and susceptibility to deltamethrin in all the populations under study with the CDC method,” according to the lead researchers’ description of the impact of synthetic insecticide use on mosquito management. “In contrast, the WHO method showed resistance to the three insecticides evaluated in all populations.” The researchers successfully identify all three of the kdr mutations across all populations. Approximately 4,030 females of Ae. aegypti were assessed using the WHO method, with roughly one-third of each in this group showing resistance to permethrin, deltamethrin, lambda-cyhalothrin. Meanwhile, approximately 3,255 females of Ae. aegypti were evaluated for resistance in a similar breakdown across the three active ingredients.

“[T]he WHO tube test measures the mortality rate of mosquitoes exposed (usually for 1 h[our]) to a discriminating concentration of the insecticide for a specific time (regularly 24 h[ours]) [], while the CDC bottle test determines the time necessary to incapacitate a susceptible mosquito using a predetermined concentration of insecticide [].” The researchers discuss the implications of relying on one methodological approach versus the other: “It has been shown that the CDC method generates greater variability in mortality when compared to the WHO method, which may influence the actual interpretation of the susceptibility status of the populations evaluated []. The pyrethroids assessed by the CDC test may generate knockdowns in mosquitoes at the time of diagnosis, which does not necessarily generate mortality 24 h[our] post-exposure [].” Researchers also warn of less-than-ideal accuracy in the CDC bottle test because of a variety of potential outlets for human error, including washing the bottle, insecticide volatility, and the drying procedure. The use of both methods in this study corroborates the findings of previous research on insecticide resistance to insects carrying several arboviruses, which will only increase with the climate crisis and a lack of forward-thinking approaches to safer ecological pest management.

The mainstream approach to pest management that relies on chemical-intensive practices has led to deadly outcomes. In 2016, at least 2.3 million honey bees from 46 hives in Dorchester County, South Carolina perished from aerial spraying of organophosphate insecticide Naled. The state’s Department of Health and Environmental Control launched this spraying campaign in an attempt to kill adult mosquito populations in response to fears over the Zika virus. See the Daily News section on mosquitoes to learn more about the implications of “spray-as-usual” mentality, as well as the section on integrated and organic pest management to learn about success stories involving safer alternative approaches.

The status quo relies on responding to crises through least effective practices rather than taking a proactive approach that minimizes risks by focusing on root conditions for mosquito reproduction. This is true in state-level mosquito management programs in response to both West Nile Virus and Eastern equine encephalitis (EEE). For example, in Massachusetts last week, the Division of Crop and Pest Services in the MA Department of Agriculture announced that aerial spraying would begin in parts of Plymouth County and truck-based spraying in Worcester County on the evening of August 27, and several following days, after the presence of positive mosquito samples for the virus. It has been four years since the last EEE detection led to seven deaths and 17 cases in the same counties, leading to the use of Anvil 10+10—containing the neurotoxic, synthetic pyrethroid sumithrin (the active ingredient used to target the insect) and the synergist piperonyl butoxide/PBO, used to increase the potency of the active ingredient. (See Beyond Pesticides’ press release here.)

According to a Massachusetts Department of Agricultural Resources (MDAR) Crop and Pest Services’ 2019 summary report, spraying this product lasted 26 days, treated over 2,048,865 acres across the Commonwealth, and used 9,939 gallons of Anvil 10+10. The product was also applied by air in 2006, 2010, and 2012. It has been linked to a range of adverse health effects in humans, including a higher risk of liver disease—which increases the hazardous effect of exposure to the pesticide, given that the liver is the primary organ meant to filter out toxic residues including pesticides. In addition, the insecticide’s ingredients are also linked to cancer, kidney damage, threats to reproductive health, and endocrine disruption. 

Aerial and truck spraying has also commenced in New Hampshire, Rhode Island, Connecticut, and New York for either EEE or  West Nile Virus since July.

See Gateway on Pesticide Hazards and Safe Pest Management to learn more about adverse health impacts of specific active ingredients or pesticide products to identify safer alternatives. See Safer Mosquito Management to learn more about the principles of ecologically based mosquito management plans from public health researchers and experts.

📣 To TAKE ACTION and reach out to your governor, click here to access last week’s special Action, Call for States to Adopt a Safer Strategy to Fight Eastern Equine Encephalitis (EEE) Transmission!

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

Source: PLOS One

(Beyond Pesticides, September 4, 2024) A study in the Journal of Environmental Science and Public Health adds to the body of science that highlights the ecological decline threatening all species as a result of hazardous chemicals in the environment. “When environmental changes undermine a species’ or population’s ability to survive, it is said to be in an ecological crisis,” the authors state. They continue, “Pesticides, particularly persistent organic pollutants (POPs), are among the top ten chemicals and hazardous compounds that the WHO [World Health Organization] has recognized as being a concern for global health. The overuse and improper handling of agrochemicals is the primary driver of the ecological disaster.”  

The researchers, from the Post Graduate Institute of Medical Education and Research in India, conducted a literature review to look broadly and comprehensively at the range of factors that contribute to adverse health effects (from breast cancer to genotoxic effects, chronic kidney disease, neurotoxicity, and more). They searched PubMed and Google Scholar for studies between 2004-2024 for relevant information on soil health, sustainable agriculture, food security, soil security, and the associations with human health. Their scientific findings lead the authors to conclude that the building of healthy soils will eliminate the need for toxic inputs in land management, resulting in healthier people (see studies here, here, and here), while current reliance on pesticides causes soil health and human health to suffer.  

“Studies in Northern India have shown evidence of the presence of heavy metals and pesticides in samples of fodder, vegetables, milk, urine, and blood,” the authors say. (See studies here, here, and here.) One study links water contamination from heavy metals and pesticides to increased rates of spontaneous abortions, premature births, and stillbirths that are five times as frequent in comparison to other South Asian countries. Developmental delays, blue lines in the gums, mottled teeth, and gastrointestinal diseases were also noted. These effects occur in areas with groundwater contamination of heptachlor, chlorpyrifos, b-endosulfan, dimethoate, and aldrin that is more than permissible limits (MPL).  

Higher cancer prevalence is also noted in Punjab. Two studies (linked here and here) show that cancer in the female reproductive system (breast, uterus/cervix and ovary) are more common in one district where levels of heavy metals and pesticides such as heptachlor, ethion, and chlorpyrifos were significantly higher in samples of drinking water, vegetables, and blood. There is a dependence on petrochemical pesticides worldwide that can be attributed to companies selling harmful chemicals, even though safer alternatives exist, while applicators and consumers are unaware of the risks and continue causing harm to the environment and all organisms.  

According to the researchers, “The three most important environmental problems affecting the globe now are pollution, climate change, and biodiversity loss.” Based on the science, petrochemical pesticides and fertilizers, central to conventional chemical-intensive systems, are contributors to these problems. There is an abundance of scientific, peer-reviewed evidence that shows these chemicals disrupt ecosystems that support and sustain life in addition to negatively influencing human health both directly and indirectly as well as acutely and chronically.  

Within the soil, pesticides reduce species diversity, which impacts the entire ecosystem and overall biodiversity. Soil biota are important for agricultural productivity, contributing to decomposition, nutrient availability, soil structure, disease control, and in maintaining biological equilibrium within the food web. Biodiversity begins in the soil, which is a living organism itself. Synthetic fertilizers and pesticides kill soil and prevent the symbiosis needed between soil organisms, plants, fungi, bacteria, and insects needed to sustain the base of all food chains. 

“Human health and wellbeing are significantly impacted by soil,” the authors state. “Soil health means ‘the continued capacity of soil to function as a vital living ecosystem that sustains plants, animals, and humans.’ Healthy soils support a variety of ecosystem-related functions in the environment, including biodiversity, plant-animal productivity, air-water quality maintenance or improvement, and support for human health & habitation.” 

Pesticide contamination in the environment leads to contamination in organisms. Agricultural chemical residues are found in soil, water, air, and in the blood, tissue, hair, and urine of humans and wildlife. Many of these chemicals are often lipid soluble compounds and can bioaccumulate in breast milk and fatty tissues. 

Organic agriculture, as the researchers write, is an alternative solution for reducing the contamination and subsequent negative consequences from dangerous compounds. The mantra of organic agriculture is “Feed the Soil, Not the Plant” to describe that a sustainable system starts with a healthy foundation within the soil. As stated in a previous Beyond Pesticides’ article, organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on environmentally beneficial methods such as green manure, crop rotation, and biological pest management. 

Organic practices rely on building soil health to increase biodiversity and carbon sequestration, which in turn helps alleviate climate change. Healthy soil does not require pesticides, which will then not harm human health or the health of any organisms. As stated by Hendrikus Schraven, “lf you have a healthy system, you don’t get diseases. And if you don’t get diseases then you don’t need the pesticides and herbicides to control them. Start with the solution.”  

The four principles of organic agriculture, as described by Regeneration International, need to include: 

• Health: Organic agriculture should sustain and enhance the health of soil, plant, animal, human, and planet as one and indivisible.  

• Ecology: Organic agriculture should be based on living ecological systems and cycles, work with them, emulate them and help sustain them.  

• Fairness: Organic agriculture should build on relationships that ensure fairness with regard to the common environment and life opportunities.  

• Care: Organic agriculture should be managed in a precautionary and responsible manner to protect the health and well-being of current and future generations and the environment. 

There are multiple crises occurring that call for immediate action. As Beyond Pesticides has stated before, organic regenerative agriculture (and organic land management broadly) are pivotal in solving many of the environmental and public health crises we face — biodiversity and pollinator decline; chemical pesticides that cause disease; pollution of water bodies, waterways, and drinking water sources (by tens of thousands of chemicals deployed into the environment); increasing resistance to medically critical antibiotics (caused to great extent by their use in livestock industries); a food system rife with pesticide residues and compromised nutritional value (because of soil maltreatment with synthetic pesticides and fertilizers); and harm to critical ecosystems that provide environmental services that support all life. 

Learn more about the health and environmental benefits of organic agriculture and land management practices that mitigate the toxic effects of pesticides. Start by buying organic products and growing your own organic food and take action to protect and enhance biodiversity and to keep soil health as an important pillar in the definition of organic agriculture. Stay informed with the latest Action of the Week updates and Daily News and join Beyond Pesticides as a member today! 

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

Source: 

Thakur, J.S. and Paika, R. (2024) Ecological crisis due to chemical toxicity: Addressing soil health for better human health, Journal of Environmental Science and Public Health. Available at: https://www.fortunejournals.com/articles/ecological-crisis-due-to-chemical-toxicity-addressing-soil-health-for-better-human-health.html. 

(Beyond Pesticides, September 3, 2024) A piercing investigative article in the August 14 New York Times by journalist Greg Donahue reveals the abandonment of a group of brain disease patients in an area of Canada with forestry management for paper products, agriculture, and large amounts of pesticide use, including glyphosate. It illustrates the tension in the relationship between government authorities, regulated industries, and neurologist (physician) on the front lines. The article details the manner in which health officials appeared to manipulate their own investigation of a disease cluster to make it less disruptive to the economy of the Canadian province of New Brunswick. (This Beyond Pesticides analysis, where not otherwise indicated, draws on Mr. Donahue’s article.)

New Brunswick has one major town, Moncton, and a large rural area characterized by agriculture and forestry. The province’s agriculture industry is dominated by blueberry production, which occupies the fourth largest amount of agricultural land in New Brunswick. About half the province is forested, with increasing amounts of land devoted to tree plantations intended for paper production.

Glyphosate is hands-down the most heavily used pesticide in New Brunswick forestry, and New Brunswick is second only to Ontario in Canada’s total area of glyphosate-treated forest. The herbicide is especially heavily used in clearcuts and tree plantations.

Glyphosate’s innocence, assumed for decades since it entered the market in 1974, has been thoroughly disproved. According to a comprehensive 2020 review, it is toxic to cells; disrupts hormones and gut microbe balance; contributes to non-alcoholic liver disease; may trigger heart arrhythmias; has been strongly correlated with multiple myeloma and large B-cell lymphoma; and less strongly correlated with melanoma, leukemia, and colon, rectal, bladder and kidney cancers. There is ongoing dispute over its association with non-Hodgkin lymphoma, despite the International Agency for Research on Cancer’s classification of the herbicide as “probably carcinogenic to humans” and thousands of lawsuits brought by victims, many with multimillion dollar jury awards for adverse health effects.

Glyphosate also has numerous neurological effects. It crosses the blood-brain barrier and triggers a type of inflammation implicated in Alzheimer’s disease. A 2022 review found effects including, in humans, elevated risk of autism from childhood exposures and, in rodents, anxiety, impaired working memory, decreased curiosity, decreased movement, and other problems. It can be a source of inflammation-related pain. See Beyond Pesticides August 31, 2023 Daily News post, “Study Finds Glyphosate Exposure Among the General Population Poses a Risk to Neurological Health” for further detail.

Paraquat has also been used extensively in Canada. A class action lawsuit was filed August 15 in Canada for compensation to victims of Gramoxone, whose active ingredient is paraquat. The herbicide is no longer used in Canada and is banned in 32 other countries (but still used in the U.S.). The Canadian litigation aims to achieve justice for victims all the way back to paraquat’s introduction in 1962.

The neurological cases came from both Moncton and the rural Acadian Peninsula. As the cases emerged, the victims consulted a neurologist, Alier Marrero, M.D., for help with problems typical of a variety of neurodegenerative diseases. For example, in 2018, an 81-year-old man became very quiet. He thought it was 1992. He obsessed over a decades-old business transaction in which he believed he had been cheated. Then he began having seizures and died the next month. Other victims had a variety of similar problems, including limb pain, balance problems, teeth chattering, muscle spasms, impaired vision, hallucinations, and muscle wasting. Some patients died; others became stuck in zombie-like states. At this point, Dr. Marrero had seen more than 20 cases and eight people had died. Marrero suspected a common environmental exposure, perhaps an entirely new disease.

New Brunswick hospital doctors told the 81-year-old’s children their father had Creuzfeldt-Jakob disease (CJD), which is caused by misfolding proteins in the brain called prions. It is very rare. According to the U.S. National Institutes of Health, there are about 350 cases of CJD annually in the U.S. The doctors conducted further tests on the man’s brain. Three months later they told his children it was not CJD. They did not provide an alternative diagnosis.

Mr. Donahue’s New York Times reporting does not occur in a vacuum. New Brunswick has been struggling with the issue of pesticides for some time. First Nation groups have been pressuring governments to reduce or eliminate pesticide use, especially in areas where they continue to forage for food. Many are reluctant to forage in clearcuts, knowing that the cuts have been sprayed with glyphosate.

A few steps have been taken by government agencies. In 2019, the province reduced aerial glyphosate spraying along power lines in certain areas. In June 2021—during the same time period when the disease cluster was being dismissed by provincial authorities—a New Brunswick legislative committee held hearings on further controlling glyphosate use on paper plantations and blueberry farms. Its report calling for new restrictions was tabled. Indigenous people were not included in the testimony until one of the First Nation leaders made an unscheduled appearance. As of this writing, there does not appear to be any new law regulating pesticide use in New Brunswick.

In 2022, Dr. Marrero sent 101 samples from his cluster to a lab in Quebec, which had officially recognized a connection between glyphosate and increased risk for Parkinson’s in 2021. Ninety percent of his samples had elevated blood levels of glyphosate. One reached 15,000 times the limit of detection. Pesticide levels in New Brunswick’s general population do not appear to be available, so there was no control group. Health Canada’s biomonitoring program includes glyphosate, but the public-facing dashboard does not break the data down by province or provide interpretation.

Dr. Marrero had been reporting his cases to Canada’s Creutzfeldt-Jakob Disease Surveillance System. He found support there and in the Canadian federal health agency. In March 2021, a memo to local doctors about the cases was leaked to the press, causing international attention. Within a month of the leaked memo, federal scientists assembled a working group. Canada’s federal health research agency granted $5 million for a study that would have included interviews, diagnostic tests, and samples from humans and the environment.

From this point on, the investigation of the potential cluster and its possible explanations was rapidly derailed by intergovernmental turf wars in which one combatant was determined to make the problem go away. Within 20 months of the federal investigative study startup, the project was shut down by provincial authorities. They manipulated certain guidelines of scientific inquiry to arrive at conclusions favorable to the parties that might be responsible for the disease cluster. The footprint of industry appears in silhouette: its influence is not acknowledged in the official discourse, but its outline is visible in the shape of the provincial government’s behavior.

According to Mr. Donahue’s article, in an email circulated to provincial participants on May 6, the New Brunswick health authority “paused” the federal study and its working group to have the provincial health department “delve more deeply into existing data.” Ten days later, Dr Marrero was instructed by the province to stop reporting cases to the province, on instructions from “higher up.” New Brunswick officials’ internal communications show they were trying to keep the investigation from involving the federal people. For example, to prevent the project from being “multijurisdictional,” they eliminated two victims from the cluster who had moved out of New Brunswick.

The province also told the federal health authorities to stop communicating with the public because people in New Brunswick were becoming oversensitive. It then appointed its own new committee to oversee a surveillance study without providing details to victims and their supporters.

There is an information gap here suggesting that the province wanted to retain control because it believed the federal agencies would not be sufficiently sensitive to the economic impacts of any admission that environmental exposures to chemicals used in forestry and agriculture could be causing the problems.

Along with the federal investigation “pause,” the pathologist who did the autopsies on the first eight fatal cases decided there was nothing to the purported cluster. He announced that the null hypothesis explained everything. The null hypothesis dictates that we must assume there is no effect of whatever variable we are testing—in this case that there might be a new disease and it might be caused by environmental exposure. One of the federal working group experts called the pathologist’s position a “loophole” allowing policymakers and politicians to pretend nothing was really going on.

At this point, Kat Lanteigne, and writer and advocate, received an anonymous text saying the province was not serious about its investigation. Ms. Lanteigne is a New Brunswick native and campaigner for a safe blood supply in Canada. She followed up on the cluster issue and found that the provincial study had gone back to the federal group’s original findings in order to decide that there could not be a new disease because the victims did not have a common condition and many of their symptoms overlapped with multiple diseases.

This kind of reasoning illustrates several of the most serious problems with modern medical science. First is the silo problem. The neurologists in the New Brunswick public health system were oblivious to the plethora of research in public health itself, and in environmental health, establishing the influence of environmental exposures on disease. This allowed them to excise the idea from consideration.

Second, the New Brunswick cases included numerous households with multiple victims who were not genetically related, suggesting that a common external exposure was likely, yet the provincial health authorities eliminated any search for a toxicant—this despite the widespread adoption among scientists of the term “exposome” to encompass the thousands of environmental substances that leave their marks on humans and the biosphere.

Further, it is now commonly recognized that genes, upbringing, and external exposures interact and that very few diseases are caused by one influence alone. As the reality that diseases result from many factors becomes more and more obvious, policymakers, regulators, and health officials alike must consider cross-disciplinary evidence. In a December 2022 article in The Walrus about the New Brunswick cluster, a senior Canadian federal scientist said, “We have an unbelievably capable set of tools to look at biological and epidemiological and environmental characteristics…It’s amazing, the potential that is not being tapped.”

Third, the provincial health authorities failed to consider that the causes of symptoms that occur in multiple diseases may originate farther back in the causal chain than they have looked. For example, see Beyond Pesticides’ post “Research Links Parkinson’s and Lewy Body Disease with Chemical Effects on Brain and Gut,” which details the efforts of University of Rochester neurologist E. Ray Dorsey, M.D. to follow up on evidence that Parkinson’s disease and Lewy body dementia may be the same disease, both caused by environmental exposures—such as to paraquat—but in which the damage travels to the brain from the gut nervous system in one manifestation and via the nasal nerves in the other. Dr. Dorsey has since gone so far as to call Parkinson’s “man-made.”

On February 24, 2022, the province’s chief medical officer announced the provincial oversight committee had finished its work. It “could find no common exposure in the group.” In the final report, provincial health officials said the case definition was overly broad and overlapped other diseases. Therefore, they said, no human tissue testing was necessary.

The federal scientists appear to disagree with the province’s conclusions. Michael Coulthart, PhD, head of the federal surveillance system for CJD, said, “My scientific opinion is that there is something real going on in [New Brunswick] that absolutely cannot be explained by the bias or agenda of an individual neurologist.” He, too, thought there must be “an environmental trigger.”

Once the provincial inquiry concluded, patients were routed back to the doctors who had referred them to Dr. Marrero in the first place. They were told by provincial health officials what their doctors should consider as diagnoses, such as schizophrenia, progressive supranuclear palsy, cancer, alcoholism-induced brain damage, HIV, and various dementias. Depending on the individual patient, most of those conditions had been ruled out before they were referred to Dr. Marrero.

Dr. Marrero now has 430 patients with undiagnosable conditions, and 111 of them are under 45. Thirty-nine have died. New Brunswick, Dr. Marrero says, is the center of one of the largest dementia clusters in young people in the world.

The New Brunswick victims join a long line of populations whose sacrifice to industry has been abetted by captured experts and government officials who define their investigations in such a way as to eliminate consideration of vast amounts of relevant evidence. Victims usually have to endure years of suffering and effort, self-funding testing and further study, before accumulating the political influence to change the direction of a regulatory apparatus that grinds far too slowly toward justice.

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

Sources:

They All Got Mysterious Brain Diseases. They’re Fighting to Learn Why.
By Greg Donahue
The New York Times
Aug. 14, 2024
https://www.nytimes.com/2024/08/14/magazine/canada-brain-disease-dementia.html

New Brunswick’s Mystery Disease: Why Did the Province Shut Out Federal Experts?
by Matthew Halliday
The Walrus
December 2021
https://thewalrus.ca/new-brunswicks-medical-mystery/

Modes of Action of Persistent Pesticides Documented, with Ongoing Poisoning and Multigenerational Effects
Beyond Pesticides, August 20, 2024
https://beyondpesticides.org/dailynewsblog/2024/08/modes-of-action-of-persistent-pesticides-in-the-environment-documented-with-ongoing-poisoning-contamination-and-multigenerational-effects/

Parkinson’s Disease Explodes as Researchers Find Connection to Pesticide Exposure and Genes
Beyond Pesticides, May 3, 2024
https://beyondpesticides.org/dailynewsblog/2024/05/parkinsons-disease-explodes-as-researchers-find-connection-to-pesticide-exposure-and-genes/

Work-Related Pesticide Exposure Puts Farmers at Risk of Cognitive (Intellectual) Harm
Beyond Pesticides, January 4, 2024
https://beyondpesticides.org/dailynewsblog/2024/01/work-related-pesticide-exposure-puts-farmers-at-risk-of-cognitive-intellectual-harm/

Study Finds Glyphosate Exposure Among the General Population Poses a Risk to Neurological Health
Beyond Pesticides, August 31, 2023
https://beyondpesticides.org/dailynewsblog/2023/08/study-finds-glyphosate-exposure-among-the-general-population-poses-a-risk-to-neurological-health/

Beyond Pesticides Makes Science-based Case that It Is Imperative to Phase Out Pesticides in a Decade
Beyond Pesticides, April 15, 2022
https://beyondpesticides.org/dailynewsblog/2022/04/beyond-pesticides-makes-science-based-case-that-it-is-imperative-to-phase-out-pesticides-in-a-decade/

Pesticides Not Only Linked to Parkinson’s Disease Development, But Accelerating Disease Symptoms
Beyond Pesticides, January 12, 2023
https://beyondpesticides.org/dailynewsblog/2023/01/pesticides-not-only-linked-to-parkinsons-disease-development-but-accelerating-disease-symptoms/

Study Finds Pesticide Exposure Associated with Parkinson’s Disease
Beyond Pesticides, June 28, 2006
https://www.beyondpesticides.org/archive/daily-news-archive/2006/file1407

(Beyond Pesticides, August 30, 2024) There is no more compelling reason to embrace a precautionary pesticide poisoning standard this Labor Day than the need to protect workers. In fact, the Occupational Safety and Health Administration (OSHA) says on its website, Transitioning to Safer Chemicals, that the best way to protect workers is to  “eliminate or reduce hazardous chemicals at the source.” While some try to employ product substitution with “safer” chemicals, Beyond Pesticides urges decision makers to embrace alternative systems, such as organic management systems, that embrace management techniques to meet disease and infestation management goals and use only organic compatible substances.

According to OSHA: “In chemical management, [the industrial hygiene principle, known as the hierarchy of controls] guides employers and workers to eliminate or reduce hazardous chemicals at the source by substituting them with safer alternatives. Unlike traditional engineering controls, administrative controls, work practice controls, or personal protective equipment, these strategies can completely eliminate exposure to hazardous chemicals, reduce the potential for chemical accidents, reduce disposal costs, and remove concerns regarding worker compliance and equipment maintenance.”

A look through the state and federal databases that track occupational pesticide poisoning for both acute (immediate short-term) and chronic (long-term) pesticide effects yields incomplete data through a state-based data collection mechanism that cites eight states (2019-2020), which is acknowledged by the federal government to identify a small fraction of pesticide incidents that are certainly occurring. Government agencies, principally the National Institute for Occupational Safety and Health (NIOSH), point to the Sentinel Event Notification System for Occupational Risks (SENSOR), which reflects a limited effort to ensure worker protection.

A 2016 Morbidity and Mortality Weekly Report (MMWR) explains the limitations of the nation’s efforts to protect workers: “For multiple reasons, the data provided in this report are likely to be underestimates of the actual magnitude of acute occupational pesticide-related illness and injury. Many cases of pesticide-related illness or injury never are ascertained because affected persons neither seek medical care, nor call appropriate authorities. Furthermore, because the signs and symptoms of acute pesticide-related illnesses are not pathognomonic, and because most healthcare professionals are not acquainted with the recognition and management of these illnesses, many persons who seek medical care might not receive an accurate diagnosis. Even among those who do receive an accurate diagnosis, many cases are not reported to state surveillance systems, despite the fact that each of the participating states has mandatory reporting of occupational pesticide-related illness and injury.” None of this addresses the chronic effects of pesticide exposure.

The MMWR piece explains why occupational data is so important to protecting workers: “These surveillance data assist EPA in determining whether labeling is effective or if labeling improvements are needed. When health effects occur despite adherence to label instructions, and EPA determines the magnitude to be unreasonable, EPA requires that interventions be instituted that involve changing pesticide use conditions and/or modifying regulatory measures.”

On Labor Day, we remind decision makers in our community of the importance of worker health as one foundational reason for stopping the use of toxic pesticides. This is a day of reflection and commitment to taking meaningful action for workers who serve our communities and are expected to handle toxic pesticides in the process. We can be a part of changing that expectation by stopping the use of toxic pesticides through the adoption of organic land management. In the process, we protect landscapers who are daily applying toxic pesticides and, in the process, protect children, pets, and biodiversity. We also protect those who produce, handle, transport, and dispose of the toxic pesticides used in chemical-intensive land management. 

Part of this Labor Day reminder includes the question: What can I do about the problem of pesticides in a regulatory and policymaking climate that is unresponsive to the need for restrictions on toxic chemicals? Is it enough to advocate for the adoption of large-scale reforms—agreed by most health and environmental advocates to be necessary for worker and general health as well as environmental protection—when we know that achieving the necessary policy reforms may not be attainable in the near term? There is more we can do now.   

>> Tell your governor and mayor to exercise their leadership in recognizing and acting on the importance of worker health to eliminate pesticide use in your community and state.

For instance, we know that the only ethical policy for the regulation of toxic pesticides is a precautionary policy that restricts or eliminates uses based on the preponderance of scientific information. So, we call for policy change and action by regulators, the U.S. Congress, and state policymakers to keep these issues in front of them and to define the limitations of current policy to protect workers, the general public, and the environment. At the same time, in the absence of federal and state action, these actions help to frame what can and should be done locally by local governments, which are integral to decisions by individuals and households.  

For example, we can define the hazards of the weedkillers glyphosate (Roundup, see here and here) and atrazine, as well as neonicotinoid insecticides, and urge action at the federal and state levels.

Action can be taken now, in our communities, to: 

Stop parks departments, school districts, and households from using these toxic pesticides now. In the process, we are not waiting for the possibility of action by regulators to protect the workers who apply these chemicals and the communities and environment that are exposed. When a community or school district acts to stop toxic pesticide use and adopt organic land management practices, the first in line of exposure—those workers who handle the toxic materials—are protected; and 

Stop the purchasing by school cafeterias, religious institutions, civic clubs, and others of food grown with toxic pesticides now. In purchasing organic food, we are protecting those who grow and harvest our food, farmworkers. 

As we say on Labor Day, our communities must annually renew the commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color who suffer elevated levels of harm. We can do this through the adoption of local, state, and national policies that eliminate toxic pesticide use, which disproportionately affects workers. This is a moment for building coalitions in our communities to advance policies that ensure all aspects of a healthful life and environment, supported by our social structures. In doing this, we recognize that we must join together to build the necessary power to effect meaningful and transformational change. 

A note on toxic body burden. When it comes to the total amount of toxicants in our body (toxic body burden) from pesticide exposure, workers’ occupational exposure to pesticides is not a part of the aggregate risk calculation (or cumulative risk calculation) that the U.S. Environmental Protection Agency (EPA) uses to determine allowable exposure. So, when we, a school district, a parks department, or a business purchase conventional food grown with chemical-intensive practices, we are supporting management practices that permit elevated, inadequately restricted exposure to those who grow our food or manage our parks and playing fields. When EPA was mandated by Congress in the 1996 Food Quality Protection Act (FQPA)—which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)—to start calculating real hazards from dietary and nondietary exposure, as a part of the pesticide registration process, the law explicitly did not, and still does not, require consideration of occupational exposure. 

***See Parks for a Sustainable Future for community assistance in converting parks to organic land management. 

>> Tell your governor and mayor to exercise their leadership in recognizing and acting on the importance of worker health to eliminate pesticide use in your community and state.

Letter to Governor

On Labor Day, I am writing to ask you to exercise your leadership in recognizing and acting on the importance of worker health as one foundational reason for stopping the use of toxic pesticides. This is a day of reflection and commitment to taking meaningful action for workers who serve our state and are expected to handle toxic pesticides in the process. We can be a part of changing that expectation by stopping the use of toxic pesticides through the adoption of organic land management. In the process, we protect landscapers who are daily applying toxic pesticides and, in the process, protect children, pets, and biodiversity. We also protect those who produce, handle, transport, and dispose of the toxic pesticides used in chemical-intensive land management.

We can do this now. 

We would hope that federal policy would adopt the only ethical policy for the regulation of toxic pesticides, which is a precautionary policy that restricts or eliminates toxic chemical uses based on the preponderance of scientific information. However, in the absence of federal action in this regard, it falls to our state and local elected officials and state and local government to protect those employees in our state and community who are working with toxic chemicals.

I am urging you to stop public parks management with toxic pesticides now. When we as a state stop toxic pesticide use and adopt organic land management practices, the first in line of exposure—those workers who handle the toxic materials—are protected. We urge you to advance policies that would do the same for all school grounds and the cosmetic use of toxic pesticides on privately held land statewide.

We also urge you to end state institutional purchasing of food grown with toxic pesticides now. In purchasing organic food, we are protecting those who grow and harvest our food, farmworkers. We urge you to encourage school cafeterias, religious institutions, civic clubs, and others to do the same.

As we say on Labor Day, our communities must annually renew the commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color who suffer elevated levels of harm. We can do this through the adoption of local policies and practices that eliminate toxic pesticide use, which disproportionately affects workers.

Toxic Body Burden. When it comes to the total amount of toxicants in our body (toxic body burden) from pesticide exposure, workers’ occupational exposure to pesticides is not a part of the aggregate risk calculation (or cumulative risk calculation) that the U.S. Environmental Protection Agency (EPA) uses to determine allowable exposure. So, when we, a school district, a parks department, or a business purchase conventional food grown with chemical-intensive practices, we are supporting management practices that permit elevated, inadequately restricted exposure to those who grow our food or manage our parks and playing fields. When EPA was mandated by Congress in the 1996 Food Quality Protection Act (FQPA)—which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)—to start calculating real hazards from dietary and nondietary exposure, as a part of the pesticide registration process, the law explicitly did not, and still does not, require consideration of occupational exposure.

Thank you for your consideration of my request. Happy Labor Day and thanks for your work.

The Action for mayors is for those whose communities have not already adopted organic land management ordinances, practices, food purchases, and products. 

Letter to the Mayor

On Labor Day, I am writing to ask you to exercise your leadership in recognizing and acting on the importance of worker health as one foundational reason for stopping the use of toxic pesticides. This is a day of reflection and commitment to taking meaningful action for workers who serve our community and are expected to handle toxic pesticides in the process. We can be a part of changing that expectation by stopping the use of toxic pesticides through the adoption of organic land management. In the process, we protect landscapers who are daily applying toxic pesticides and, in the process, protect children, pets, and biodiversity. We also protect those who produce, handle, transport, and dispose of the toxic pesticides used in chemical-intensive land management.

We can do this now. 

We would hope that federal and state policy would adopt the only ethical policy for the regulation of toxic pesticides, which is a precautionary policy that restricts or eliminates toxic chemical uses based on the preponderance of scientific information. However, in the absence of federal and state action in this regard, it falls to our local elected officials and local government to protect those employees in our community who are working with toxic chemicals.

I am urging you to stop our parks department from using toxic pesticides now. When we as a community stop toxic pesticide use and adopt organic land management practices, the first in line of exposure—those workers who handle the toxic materials—are protected. We urge you to encourage the same for all school grounds and the cosmetic use of toxic pesticides on private property in our community.

We also urge you to end town purchasing of food grown with toxic pesticides now. In purchasing organic food, we are protecting those who grow and harvest our food, farmworkers. We urge you to encourage school cafeterias, religious institutions, civic clubs, and others to do the same.

As we say on Labor Day, our communities must annually renew the commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color who suffer elevated levels of harm. We can do this through the adoption of local policies and practices that eliminate toxic pesticide use, which disproportionately affects workers.

Toxic Body Burden. When it comes to the total amount of toxicants in our body (toxic body burden) from pesticide exposure, workers’ occupational exposure to pesticides is not a part of the aggregate risk calculation (or cumulative risk calculation) that the U.S. Environmental Protection Agency (EPA) uses to determine allowable exposure. So, when we, a school district, a parks department, or a business purchase conventional food grown with chemical-intensive practices, we are supporting management practices that permit elevated, inadequately restricted exposure to those who grow our food or manage our parks and playing fields. When EPA was mandated by Congress in the 1996 Food Quality Protection Act (FQPA)—which amends the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)—to start calculating real hazards from dietary and nondietary exposure, as a part of the pesticide registration process, the law explicitly did not, and still does not, require consideration of occupational exposure.

Thank you for your consideration of my request. Happy Labor Day and thanks for your work.

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

(Beyond Pesticides, August 29, 2024) The Center for Agriculture and Bioscience International (CABI) earned the 2024 Innovators Award from The Better Cotton Initiative (Better Cotton) for its leadership in developing capacity and expansion of organic standards and practices in the Pakistani cotton sector, according to a press release by Better Cotton. Given the millions of pounds of some of the most toxic chemicals used to produce cotton, and Pakistan being an exporter of $3.5 billion worth of cotton (2021), including $240 million to the U.S. (2022), cotton production is a worldwide contamination problem. The U.S. is currently the fourth largest cotton producer (domestic and export) and the largest cotton exporter in the world, accounting for 30% of all cotton produced, valued at $5.7 billion (2021). The farm value of U.S. organic cotton is $35.55 million (2021). According to the Organic Trade Association, organic cotton comprises approximately 0.95% of global cotton production.

“CABI, for its multifaceted work in Pakistan which has included the creation of a national organic agriculture policy for Pakistan that is currently being assessed by the country’s Ministry of Food Security and Research,” the release goes on to discuss the implications of the years-long initiative. “If approved, the policy is expected to strengthen and build bridges between stakeholders working to promote sustainability.”

Cotton production is the third most chemical-intensive crop in the United States after corn (at least 166 million pounds applied in 2021) and soybeans (at least 138.9 million pounds applied in 2023), with at least 17.2 million pounds of herbicides applied to cotton acres in 2021. The United States and other nations continue to rely on toxic petrochemical-based pesticides, including paraquat, dicamba, and glyphosate-based herbicides in the U.S., as well as organophosphate, pyrethroid, and neonicotinoid insecticides. Advocates continue to push for regenerative organic principles to move beyond toxic pesticides for all crops and support the well-being of farmworkers, farmers, and consumers.

CABI has engaged in various projects to promote the development of organic cotton production in Pakistan, including reports surveying progress, obstacles, and opportunities in the sector as well as engagement with the government, including the Ministry of National Food Security and Research. In a 2021 working paper, Pakistan National Organic Cotton Policy GAP Analysis, CABI established the following recommendations to proliferate organic cotton capacity:

• “Develop an organic cotton policy with engagement of relevant stakeholders/working groups.
• Establish an organic cotton premium (as per the final price of textile-sector products at national and international markets) to encourage and promote organic cotton farming.
• Establish organic cotton seed multiplication programmes, with a focus on immediate, medium-term, and long-term approaches that also engage research institutes, seed companies, FSC&RD [Federal Seed Certification and Registration Department], farming communities, etc.
• Provide free laboratory testing facilities for cotton seed and organic cotton samples of farmer’s fields.
• Establish a national organic certification system for organic cotton textile products.
• Carry out an ethnobotanical survey to identify local plant varieties that can be used as raw materials in the preparation of biopesticides, and develop a supply chain of medicinal plants and their products for starting income generation activities.
• Establish a bio-inputs supply chain for effective control of organic cotton insect, pests and diseases.
• Create an organic cotton-specialised credit facility for organic cotton farmers that requires farmers to provide minimum amounts of formal documentation.
• Include organic cotton regions in the government’s priority development programme.
• Promote organic cotton at identified hotspots in Punjab, Sindh, and Balochistan.
• Include youth, especially women, in organic agriculture and organic cotton and bioinput businesses for job creation and enterprise development in the region.”

This report went on to identify existential challenges to growing the industry, including limited non-genetically engineered cotton seed availability (reportedly upwards of 90% of cotton seed is GE) primarily due to cross-contamination with Bacilus thuringiensis (Bt) seed varieties due to lack of supply. U.S. researchers first found Bt resistance in cotton production as early as 2008, just five years after deployment of GE cottonseeds. (See Daily News here for further information on Bt resistance.) Also, the CABI report identified many research institutes and government agencies, their statutory mandates relating to biosafety, certification, and cotton, and their potential roles in implementing the recommendations.

Earlier this year, one of those recommendations came to fruition after CABI organized and facilitated a review and validation workshop with the Pakistan Agricultural Research Council, textile industry leaders, farmers, testing laboratories, government agencies, researchers, and additional stakeholders to push forward discussions on the eventual proposal for regulations on domestic organic standards for cotton to be finalized later this year. CABI has also facilitated the growth of organic cotton in the province of Balochistan, developing the first draft of what will become provincial and national organic standards, in addition to the publication of three organic training manuals for farmers and training workshops on applicable bio-inputs and connecting with compliant suppliers. The long-term goal is to create a domestic supply of non-GE seeds produced by Balochistan farmers who can then sell to growers in Punjab and Sindh (most of the national cotton stock is produced in these two provinces).

Pakistan is the fifth largest producer of cotton worldwide, making up 6% of total production amounting to 6.7 million bales produced in the 2023/2024 season according to the U.S. Department of Agriculture (USDA) Foreign Agricultural Service. CABI secured funding from Better Cotton back in 2014 to embark on a decade-long initiative to promote the “Better Cotton Standard System” in high-producing provinces; however, the goal has moved to be more specific and establish organic-certified cotton as the baseline for ethical, climate-resilient production in a national industry that continues to lose hundreds of millions of dollars each year due to “poor traditional agricultural practices.”

The Pakistan Credit Rating Agency attributes approximately 69% of total domestic agricultural pesticide use to cotton. Ayub Agricultural Research Institute, a research center for Punjab province, estimates “[a]bout 1.3 million out of 5 million farmers cultivate cotton on an area of 6.0 million acres, covering 15% of cultivated area in the country.” Ongoing research, including a report published in Scientific Reports in June 2024 written by agricultural researchers at the University of Agriculture Faisalabad, identified “excessive use of adulterated and expensive pesticides” as a driving contributor “to the decline in cotton production.” Punjab-based farmers interviewed in this study express frustration at the status quo of rampant pesticide use without quantifying true costs and benefits: “Farmers are being manipulated from both ends. On the one hand, the cost of pesticides is very high, and on the other hand, the results of the pesticides are poor. More importantly, farmers have to repeat the sprays, encountering the fear of crop yield loss by investing a lot of money in pesticides.” Pakistan cotton production has shrunk by nearly 61 percent and total land area cut by 25 percent between 2015 and 2021 due to climate change and “inaccessibility to the latest generations of GE cottonseed,” according to a USDA Foreign Agricultural Service report.

There are also farmworker and gender injustice concerns surrounding the conventional agricultural sectors, including in major cotton-producing provinces such as Sindh. In 2019, the provincial government passed the Sindh Women Agriculture Workers Act to “recognize the right of women workers to have a written contract, minimum wage, social security, and welfare benefits including for child health, maternity leave, and access to government subsidies and credit,” following up on analysis by Human Rights Watch and a 2018 report by UN Women finding that “67 percent of Pakistani women in the labor force work in agriculture and 60 percent of their work is unpaid.” Five years after the passage of this law, continued violations have prompted the Sindh Human Rights Commission to facilitate discussions on enforcing this labor law earlier this year in March. Given the failure of chemical-intensive agriculture to protect farmworkers, particularly women farmworkers, from labor violations, advocates emphasize the importance of organic systems that center such protections in their roots, as does CABI in its analysis of growing organic cotton.

The U.S. produces over 12 million bales of cotton in the past crop season. It is mainly grown in Texas, Georgia, Mississippi, and Arkansas. Organic cotton production, meanwhile, is significantly lower at 47,737 bales produced predominantly in Texas, Arizona, New Mexico, and North Carolina in 2021. Of these 75 organic cotton farms, 63 are based in Texas. Cotton growers in this state, both organic and conventional, have faced challenges to production based on pesticide resistance and lack of viable, and compliant inputs, respectively. In 2014, the Texas Department of Agriculture requested that EPA issue an exemption to permit conventional farmers to spray fields with propazine to control pigweed, an invasive plant that had grown increasingly resistant to glyphosate. (The EPA denied their request).

Despite court rulings that “[U.S. Environmental Protection Agency] EPA did not adequately consider adverse effects from ‘over-the-top’ dicamba in approving the conditional registration,” the chemical is one of the predominant herbicides used in conventional cotton production. See Beyond Pesticides’ full comments to EPA on the pesticide production registration for new dicamba-tolerant cotton and soybeans to learn more about the environmental and public health issues of dicamba, as well as regulatory failure from the EPA.

There is a slew of scientific literature documenting numerous adverse health effects to exposure from commonly used pesticides in the chemical-intensive cotton sector. The presence of dicamba and 2,4-D in pregnant women in Midwest states has increased significantly in the last decade based on research facilitated by the Heartland Health Research Alliance. Dicamba has also been linked to neurotoxicity, birth defects, and kidney and liver damage, not to mention posing harm to birds, fish, and other aquatic organisms, according to various peer-reviewed studies identified in the Gateway on Pesticide Hazards and Safe Pest Management. Paraquat has been linked to the rise in mental health/suicidal ideation among farmworkers and increased rates of neurodegenerative diseases including Parkinson’s, among other chronic health issues. The California legislature is considering prohibiting the use of paraquat for most uses while the EPA is undergoing a final registration review of paraquat with comments due by January 2025. There are proven alternatives to pest management that move beyond toxic chemical dependance, including crop diversification/intercropping, cover crops (proven especially effective for cotton), and other practices that are elements of organic land management systems.

Advocates across the nation welcome EPA’s unprecedented action earlier this month to use its emergency suspension authority, as permitted by its statutory mandate under Federal Insecticide, Rodenticide, and Fungicide Act (FIFRA), to pull Dachtal/DCPA off the market. This is the type of action that enables EPA to stand up and adequately address the known adverse health and ecological effects of registered pesticide products despite viable alternatives built on organic principles.

With greater recognition of the hazards associated with chemical-intensive cotton production, and more stringent EPA implementation of laws restricting pesticides, the growth of organic is understood to be increasingly important, but still a fraction of a huge market. The Textile Exchange (which bases certified organic data on various certifiers and the USDA National Organic Program) estimates that 1.4% of all cotton grown is within “organic and in-conversion land” in its 2021 report on organic cotton markets.

While eliminating the toxic pesticides, organic cotton processing is still reliant on the toxic hydrogen chloride to de-lint cotton seeds before planting. Under the banner of “continuous improvement,” Beyond Pesticides has called for more urgency in supporting research on alternatives that are compatible with organic. “It is our understanding, from conversations with a representative of the Texas Organic Cotton Marketing Cooperative, that organic cotton growers in the U.S. currently do not have a lot of choice about how their seed is prepared for planting,” says Terry Shistar, Ph.D., Board of Directors at Beyond Pesticides. See Beyond Pesticides’ full NOSB comments on relisting hydrogen chloride to support organic cotton growers and the call for less toxic alternatives.

See Pesticide-Induced Disease Database and Gateway on Pesticide Hazards and Safe Pest Management to access peer-reviewed, independent scientific literature on the human and environmental health impacts of toxic pesticides used in cotton production. Stay tuned for more information on the Fall 2024 NOSB public meetings on Keeping Organic Strong.

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

Source: Better Cotton

(Beyond Pesticides, August 28, 2024) The U.S. Environmental Protection Agency’s (EPA) pesticide labeling requirements fail to adequately communicate acute toxicity levels to the public, as evidenced in a recent study of consumers published last month in the journal Nature. After evaluating whether the current three “signal” words (CAUTION, WARNING, DANGER) on pesticide products adequately convey pesticide toxicity, the authors conclude that current labeling may result in “unintended adverse effects” because it does not “effectively communicate toxicity risks to consumers.” The signal words on pesticide labels, based on laboratory animal testing for determining lethal doses, are intended to protect users of the product from exposure that can kill through inhalation, skin absorption, and ingestion of the pesticide. However, the signal words do not warn about long-effects like cancer, neurological diseases, reproductive harm, as well as other adverse effects associated with pesticide exposure. (See Pesticide-Induced Diseases Database.)  

The study tests two prototype labels to evaluate the effectiveness of visual elements in communicating toxicity information, citing research in cognitive psychology that indicates visual elements, like images and graphics, are more effective for conveying information than text alone. This is particularly crucial for pesticide labels, where complex toxicity details need to be communicated quickly and clearly. The authors note that consumers are highly responsive to visual cues like colors and symbols, which capture their attention and influence purchasing decisions, especially regarding environmental and health concerns. 

Methodology and Results. 

To examine the efficacy of EPA’s label in conveying toxicity information to potential consumers, the researchers conduct an incentivized field experiment with eye tracking to evaluate the effectiveness of pesticide labels using signal words as compared to two alternative visual designs: traffic light colors and skull intensity symbols. Using a “between-subjects” design primarily examining the format of the label display, the study recruited 180 participants from the Southwest region of the United States through local newspaper ads and recruitment emails.  

Participants in the study are presented with three tasks, each involving a series of 12 choices between two pesticides that differed only in their toxicity levels (HIGH, MEDIUM, LOW), but were otherwise identical. The price of the more toxic pesticide was fixed, while the price of the less toxic options decreased incrementally across the choices. This setup allowed the authors to estimate how much more participants were willing to pay to avoid higher toxicity.

The authors cite previous research that indicates that consumers’ awareness and understanding of pesticide risks significantly influences their behavior. In addition, the results support the notion that consumers are willing to pay a premium for less toxic alternatives when they understand the choice. For example, under the current “three-word system,” only 21% of participants indicate a willingness to pay an extra dollar for a “less toxic pesticide,” while under the traffic light system, 60% of consumers will choose to pay more. When the price of two pesticides is the same, 60% opt for the less toxic pesticide under the three-word system, as compared to 80% under the traffic signal system.

These results demonstrate that even a simple modification to EPA’s labeling requirements would lead to a significant change in consumer behavior. The authors conclude that incorporating graphic representations of toxicity in labeling can significantly assist in empowering consumers to make “more discerning decisions and minimize exposure to potentially hazardous chemicals in pesticides.”  Advocates argue that the most effective way to protect themselves, their families, and the environment from the hazards posed by toxic pesticides is to eliminate their use, especially petrochemical pesticides, and fertilizers, in favor of organic methods.  

However, perhaps of greater concern than the ineffectiveness of the label on safety is the highly criticized underlying statutory and regulatory standards that allow pesticides on the market. As Beyond Pesticides has noted, pesticides are registered and labeled based on data submitted by the manufacturer—not studies conducted or commissioned by EPA or discussed in the independent peer-reviewed scientific literature. The data submitted by the manufacturer, and not released to the public before initial product registration, is used by the agency to assess adverse effects of the pesticide, including impacts such as those on farmers and farmworkers, and to set allowable human dietary and non-dietary exposures.   

Pesticide manufacturers are not required to provide toxicity data for all pesticide formulation ingredients. Additionally, EPA does not require manufacturers to disclose so-called “inert” (those not claimed to attack the target pest) or “other” ingredients, which are classified as “proprietary information” under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). FIFRA requires all pesticides distributed or sold in the U.S. to be registered by the EPA.  Section 10(d)(1) [7 USC 126h], Protection of Trade Secrets and Other Information, of FIFRA states that it “does not authorize the disclosure of any information that—(C) discloses the identity or percentage quantity of any deliberately added inert ingredient of a pesticide, unless the Administrator has first determined that disclosure is necessary to protect against an unreasonable risk of injury to health or the environment.” Many of these “inert” ingredients that have been classified as hazardous under various laws, including the Clean Air Act, the Clean Water Act, and the Emergency Planning and Community Right to Know Act (EPCRA under Superfund Act) and the agency does not require testing data on the full formulation of a pesticide product, including inert ingredients (see here, here and here). Thus, data on the human health and environmental effects of the actual product on the market is entirely lacking—and not included on labels. 

Beyond Pesticides previously reported on a 2000 report, The Secret Ingredients in Pesticides: Reducing the Risk, produced by the New York State Attorney General, that found 72 percent of pesticide products available to consumers contain over 95 percent inert ingredients and fewer than 10 percent of pesticide products list any inert ingredients on their labels. The report also found that more than 200 chemicals used as inert ingredients are hazardous pollutants in federal environmental statutes governing air and water quality, and, from a 1995 list of inert ingredients, 394 chemicals were listed as active ingredients in other pesticide products. For example, naphthalene is an inert ingredient in some products and listed as an active ingredient in others. See 2006 petition seeking disclosure of “inert” ingredients on pesticide product labels.

In evaluating allowed exposure and labeling of pesticides, EPA’s decisions rely on risk assessments that often adopt questionable exposure assumptions and overlook vulnerable groups, such as children and individuals with preexisting health conditions, including cancer, disruption of the endocrine system, and neurological disorders, which can be exacerbated by pesticide exposure. Amendments to FIFRA adopted in the 1996 Food Quality Protection Act, while creating requirements for evaluating cumulative dietary and nondietary exposure in determining label restrictions, have done little to curb overall reliance on toxic chemicals in agriculture and land management. It should be noted that the law does not include occupational exposure when determining acceptable cumulative exposure. Despite the rise of the $70 billion organic industry with third-party organic certification that proves food crops are successfully grown without reliance on synthetic pesticides and fertilizers, EPA still does not consider organic practices as a viable alternative when assessing the “reasonableness” or “acceptability” of pesticide risks, instead focusing on the acceptability of chemical risks in relation to other chemical alternatives. 

The study authors’ recommendation that policymakers could impact consumer safety through ”a comprehensive shift” in labeling policies while addressing an important issue of EPA requirements for effective communication with consumers, does not address the inherent adverse impacts of toxic pesticides and the availability of nontoxic alternatives. A continued reliance on petrochemical pesticides perpetuates the trifecta of existential crises of human health threats, biodiversity collapse, and the climate emergency. In contrast is a precautionary approach—embodied in organic and regenerative organic land management practices. The existence, availability, and economic feasibility of alternative materials and practices, as demonstrated in organic management, is challenging the continued reliance on synthetic chemical pesticides. Environmental and health advocates argue that a truly protective strategy requires a transition from this chemical dependency to organic practices across food production, parks, playing fields, and all public spaces.  

Beyond Pesticides aims to facilitate through our resources educating the public on pesticides’ adverse effects on human health, including through the Pesticide Illness and Disease Database (PIDD). For consumer resources on safer management of pests, including weeds and insects, see the Safer Choice page. See Tools for Change for a range of strategies, resources, and tips to initiate grassroots advocacy in your community, town, city, or state against pesticide use on lawns, public land, and agricultural lands. Beyond Pesticides established the Parks for a Sustainable Future program to assist with the transition to organic land management in communities across the U.S. The organization also strives to maintain the integrity of organic standards through Keeping Organic Strong campaign and historical work to transition agriculture to organic practices. 

[For more information on the importance of eating organic food for you, farmworkers, and the environment, please see Beyond Pesticides’ Eating with a Conscience and Organic Agriculture webpages. For more background on deficiencies in farmworker protection, see Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety.] 

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

Sources: 

Improving consumer understanding of pesticide toxicity labels: experimental evidence, Nature Scientific Reports, July 27, 2024  

Implementation of PRIA 5 Bilingual Labeling Requirements To Make Bilingual Pesticide Labeling Accessible to Farmworkers; Request for Comments, EPA Notice, June 20, 2023 

Image: Art Page submission from Max Sano, “Maryland Farmland“

(Beyond Pesticides, August 27, 2024) A recent entry in the Civil Eats investigative series, “Chemical Capture: The Power and Impact of the Pesticide Industry,” unpacks the troubling coordination between carbon markets, toxic pesticide products, and industrial agriculture to mutually reframe their business models under the guise of climate-smart agriculture. In recent years, powerful agribusiness corporations—including Corteva (chlorpyrifos) and Bayer/Monsanto (glyphosate)—have made significant progress in becoming leading providers of carbon markets based in the United States. Advocates, farmers, and communities view the misrepresentation of carbon offsets and trading as a climate solution in a strategy that undermines proven alternative systems of agriculture and land management (aka organic).

The underlying concept of carbon markets began with the emissions trading program as a result of the Kyoto Protocol back in the 1990s. “Emissions trading, as set out in Article 17 of the Kyoto Protocol, allows countries that have emission units to spare—emissions permitted them but not “used”—to sell this excess capacity to countries that are over their targets,” according to the United Nations. Based on Civil Eats’ reporting, Bayer/Monsanto with Climate FieldView and Corteva with its Carbon Solutions program, cite their pesticide products as tools for sustainable agricultural practices, such as no-till/reduced-till agriculture and cover cropping. “Independent” carbon trading platforms, such as Indigo and Nora, have begun partnering with Bayer and Corteva respectively because they view collaboration as an opportunity to expand their services to new clients (e.g., farmers who are trapped in the toxic pesticide dependency treadmill). Beyond Pesticides has covered extensively the greenwashing of no-till and individual regenerative agriculture practices that do not comply with organic principles. (See here, here, here, and here.)

In Bayer’s 2022 annual report, the company recognizes Climate FieldView for its ability “to use novel modeling to make custom product recommendations that are precisely tailored to each individual field. With these insights we can maximize the value of our seed and chemistry portfolio, help farmers expand participation in the carbon markets and food, feed, fiber, and fuel value chains, and lead Bayer toward digitally enabled business models and new opportunities for growth.” To enter Bayer’s carbon offset program farmers must input on-farm data to Climate FieldView, which “recommends planting protocols and offers product discounts.” CropLife International, a pesticide trade association that represents Bayer, Corteva, and other manufacturers of pesticide products, submitted a letter to the U.S. Department of Agriculture (USDA) in 2022 emphasizing the recognition of pesticides as a critical tool for climate-smart farming practices as USDA developed its Partnerships for Climate-Smart Commodities Program. Organic advocates are concerned that this influenced the Biden Administration’s decision to establish its climate-smart agriculture approach, rather than coordinate with the European Union’s organic agriculture targets for 2030 as a part of its Farm to Fork (F2F) initiative. F2F seeks to slash use of synthetic pesticides and fertilizers, and move one-quarter of European farmland to organic production by 2030. CropLife International also advocated for the eventually successful passage of the Growing Climate Solutions Act, which set up the conditions for the voluntary carbon trading market for the U.S. agricultural sector. See previous Daily News coverage on the impact of CropLife International in preventing forward-thinking policy to move beyond pesticides within the U.S., as well as an Action of the Week calling on Congress to vote against this bill and instead support organic farming as the leading framework for U.S. climate action.

Both organic and conventional farmers who are navigating the introduction and expansion of carbon offset tools remain concerned “that carbon markets would inadequately support a full range of beneficial soil management practices,” according to farmer interviews from Hamilton College, included in a report published last year in Nature. This sentiment is not just true for a small population pool of row-croppers in New York, but also represents farmer perspectives across the U.S. “Over 70% of farmers did not use or participate in software-based sustainability tools in 2020. The majority might not see carbon credits as a compelling incentive to begin,” according to surveys from over 500 farmers across 45 states in a 2022 report published under the “Trust in Food” initiative of the Farm Journal. It remains to be seen if carbon markets will have a long-term impact on farmers looking to move beyond fossil fuel dependency.

Beyond the specific context of agricultural carbon offset markets, there are numerous reported instances of carbon markets/trading missing the mark or resulting in outright failure:

• The Guardian (2023): “The research into Verra, the world’s leading carbon standard for the rapidly growing $2bn (£1.6bn) voluntary offsets market, has found that, based on analysis of a significant percentage of the projects, more than 90% of their rainforest offset credits – among the most commonly used by companies – are likely to be “phantom credits” and do not represent genuine carbon reductions.”
• MIT Technology Review (2023): “These projects often harm Indigenous communities and fail to deliver the promised climate benefits. And that’s when they don’t burn down in wildfires, wiping out years of carbon gains in days…. In recent months, corporations including Shell, Nestlé, EasyJet, and Fortescue Metals Group all announced they were backing away from offsets or the claims of carbon neutrality that relied upon them.”
• Carbon Market Watch (2023): “Offsetting provides an excuse for avoiding real emission reductions and can create a dangerous mirage of ‘climate neutrality’ when emissions are actually rising. . .The two editions of the Corporate Climate Responsibility Monitor, which Carbon Market Watch publishes together with NewClimate Institute, show that the net zero claims of dozens of corporations are exaggerated and conceal continued high emissions. ‘Net-zero pipe dreams’ demonstrates that fossil fuels cannot claim carbon neutrality. ‘Poor tackling’ casts serious doubt on FIFA’s carbon neutrality claim for the 2022 football World Cup in Qatar. ‘Flights of fancy’ reveals the inadequate climate actions taken by eight major European airlines.”

As Beyond Pesticides has previously reported in a 2021 Daily News, the mechanisms of carbon markets, or the purchasing of carbon offsets, do not establish an end date for admittedly unacceptable materials and practices, nor do they ensure a transition to life-sustaining practices. Just as there are proposals to end production of the combustion engine and move to electric vehicles, we must demand that agriculture—across the board and on an expedited schedule—shift to organic practices, whose standards are already codified in federal law. As mentioned in their name, carbon markets only focus on carbon dioxide (CO₂) emissions rather on other agricultural emissions that have an outsized impact on the climate crisis, including methane (CH₄), nitrous oxide (N₂O), and sulfuryl fluoride (SO₂F₂). Organic production and handling practices have a proven, commercially viable, track record and both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. The sector has grown to a $70 billion industry in the roughly two decades of USDA organic certification going into force, according to data from the Organic Trade Association. And, importantly, the Rodale Institute’s 40-year research project on organic and regenerative organic farming systems corroborates findings (see Daily News here and here) that this sector of agriculture is now operating without sacrificing productivity, profitability, or climate and environmental resilience.

See Keeping Organic Strong to learn how to engage in the public input sessions to improve upon the baseline standards outlined in the National Organic Program, including the National List of Allowed and Prohibited Substances that sets certified organic apart from private standards that do not establish organic as a baseline. Also, note Beyond Pesticides’ efforts to ensure the integrity of organic standards through Take Back Organic. See Parks for a Sustainable Future program to learn how to engage your community in transitioning public parks and playing fields to certified organic.

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

Source: Civil Eats

(Beyond Pesticides, August 26, 2024) In July, the U.S. Environmental Protection Agency (EPA) announced it was raising the allowable levels of the highly toxic weed killer atrazine in the nation’s waterways from the 2016 level of 3.4 to 9.7 micrograms per liter (µg/L), which scientists and environmental advocates say is a serious threat to aquatic plants, fish, invertebrates, and amphibians, in addition to people who recreate in waterways or eat food from them. With EPA’s August 7 decision to ban the weed killer Dacthal (or DCPA–dimethyl tetrachloroterephthalate), Beyond Pesticides is rallying public support for the removal of atrazine from the market under the same standards of harm, inability to mitigate hazards, and the availability of alternatives.

As Beyond Pesticides points out in its 2022 atrazine comments (2020 and 2016 comments included) to EPA, the agency in November 2021 released the final Biological Evaluation (BE) assessing risks to listed species from labeled uses of atrazine (in the triazine chemical family). The agency made “likely to adversely affect (LAA) determinations” for 1,013 species and 328 critical habitats, which it is now rejecting, while using a “community-equivalent level of concern (CE-LOC)” measure that is filled with uncertainty and lacks any sense of precaution with a chemical like atrazine—known to disrupt the endocrine system at miniscule doses. Meanwhile, the agency asserts mitigation measures associated with uncertain conservation practices and alleged benefits that outweigh risks. While calling for additional study of atrazine’s benefits, the Northern New York Agricultural Development Program’s Field Crops IPM [Integrated Pest Management] coordinator, Mike Hunter, said in July, “The results of this limited-scope, preliminary trial demonstrated that excellent corn weed control was achievable regardless of the atrazine rate used and without inclusion of atrazine in the herbicide treatment.” Beyond Pesticides points to the efficacy and profitability of organic practices and products for all crops, turf (see also), and vegetation use for which atrazine is registered by EPA.

Exposure to atrazine, manufactured by Syngenta, is widespread in the environment. According to EPA, “Pesticide products containing atrazine are registered for use on several agricultural crops, [including] field corn, sweet corn, sorghum, and sugarcane, []wheat, macadamia nuts, and guava, as well as non-agricultural uses such as nursery/ornamental and turf.” It is the second most widely used herbicide in the U.S. after glyphosate (found in Roundup), but banned in the European Union in 2004 and in over 40 countries worldwide. Many organizations have called for the chemical to be banned in the U.S. and have joined in litigation against EPA. 

In the case of Dacthal, EPA used the “imminent hazard” clause of the federal pesticide law to immediately suspend the chemical’s use. At the same time, the agency is exercising its authority to prohibit the continued use of Dacthal’s existing stocks, a power that EPA rarely uses. The last time EPA issued an emergency action like this was in 1979 when the agency acknowledged miscarriages associated with the forestry use of the herbicide 2,4,5-T—one-half of the chemical weed killer Agent Orange, sprayed over people to defoliate the landscape of Vietnam in the war there—with the most potent form of dioxin, TCDD (2,3,7,8-Tetrachlorodibenzo-p-dioxin). The chemical manufacturer of Dacthal, AMVAC Chemical Corporation, can challenge the agency’s findings under the law and seek court review, but EPA’s action takes effect immediately while any appeal is considered. Meanwhile, EPA has stopped use under 7 U.S.C. 136 et seq., pursuant to section 6(c)(3) (7 U.S.C. 136d(c)(3)). (See Unit IV.) The prohibition on the use of existing stocks is mandated under Section 6(a)(1). 

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

The timeline for review and action on individual pesticides has taken decades since the 1972 overhaul of nation’s pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The law’s risk-benefit standard allows for high levels of harm, especially to farmworkers and those handling pesticides, as well as public exposure through residues in food, water, and air. EPA’s decisions are based on agency risk assessments that use flawed assumptions and ignore vulnerable populations like children and those with preexisting health conditions—like cancer, endocrine system disruption, neurological illness, and other health effects that are exacerbated by exposure. Amendments to FIFRA in 1996, in the Food Quality Protection Act (FQPA), have done little to reduce the ongoing reliance on toxic chemicals in food production and land management, despite the growth of the $70 billion organic industry—still not considered by EPA as a legitimate alternative to be evaluated when determining the “reasonableness” or “acceptability” of risk under pesticide law. Instead, EPA calculates acceptability of risk in the context of available alternative chemicals. In its press release on the Dacthal decision, EPA said, “In deciding whether to issue today’s Emergency Order, EPA consulted with the U.S. Department of Agriculture to understand how growers use DCPA and alternatives to this pesticide.” The agency’s consultation with USDA evaluated alternative chemicals, not alternative organic management systems and organic-compatible substances. 

The current mechanism that EPA uses to restrict pesticides—negotiated settlements instead of regulatory action—compromises the health of people and the environment, often disproportionately for people of color and workers, who are the first to be exposed as applicators or agricultural workers. Could the Dacthal decision be a watershed moment to change a regulatory process that allows daily pesticide exposure, poisoning, and contamination at rates that EPA deems acceptable—despite the overwhelming science linking real-world pesticide use (homes, parks and playing fields, schools, and farms) to dreaded illnesses, biodiversity collapse, and the climate crisis? (See Pesticide-Induced Diseases Database and the Pesticide Gateway.) 

In making its decision to ban Dacthal, EPA states that it considered: 
1. The seriousness of the threatened harm; 
2. The immediacy of the threatened harm; 
3. The probability that the threatened harm will occur; 
4. The benefits to the public of the continued use of the pesticide; and 
5. The nature and extent of the information before the Agency at the time it makes a decision. 

These criteria could be met for most of the pesticides for which EPA has negotiated settlements with pesticide manufacturers, resulting in partial withdrawals of pesticides from the market and compromises that threaten health and the environment. 

Atrazine poses immediate serious harms to people and the environment. 
Registration of the endocrine-disrupting herbicide propazine (in the triazine family of frog-deforming endocrine disruptors) was canceled by EPA, eliminating use of the hazardous herbicide by the end of 2022. However, all pesticides in the triazine class, including atrazine and simazine, have similar properties and should be eliminated from use. 

Under an Endangered Species Act review, initiated by EPA only after a lawsuit from health and environmental groups, the triazine chemicals were found to adversely affect a range of species. Propazine was found to harm 64 endangered species, while simazine and atrazine were both likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds, “aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates.” In addition, evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine. 

The triazine class of chemicals also poses significant threats to human health and is particularly concerning in the context of the range of chemicals one may be exposed to in today’s world. As Tyrone Hayes, PhD, University of California, Berkeley professor, noted at a presentation at Beyond Pesticides’ National Pesticide Forum, “Children in utero may be exposed to over 300 synthetic chemicals before they leave the womb… I would argue that a human fetus trapped in contaminated amniotic fluid is no different than one of my tadpoles trapped in a contaminated pond.”   

Atrazine has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia (where nasal passages are blocked at birth), and hypospadias (where the opening of a male’s urethra is not located at the tip of the penis). The mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH), which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset. 

Despite these endocrine-disrupting effects, EPA reduces the margin of safety and underestimates exposure to children. 

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

Mitigation measures have not eliminated the harm. 
In November 2020, Beyond Pesticides and allied environmental groups launched a lawsuit against EPA for its intent to reregister the triazine family of chemicals. The agency’s interim approval of the herbicides, conducted under the Trump administration, eliminates important safeguards for children’s health and a monitoring program intended to protect groundwater from contamination. As is typical with EPA, the agency merely proposed minor label changes in attempts to mitigate risks identified in its registration review. According to a release from EPA, it made the decision not out of concerns relating to human health and environmental protection, but in order to provide “regulatory certainty” for farmers and local officials. 

Although a hefty 200,000 lbs. of propazine were used each year, mainly on sorghum in Texas, Oklahoma, and Kansas, this amount pales in comparison to the over 70 million lbs. of atrazine used throughout the United States. Under an Endangered Species Act review, initiated by EPA only after a lawsuit from health and environmental groups, the triazine chemicals were found adversely affect a range of species. Propazine was found to harm 64 endangered species, while simazine and atrazine were both likely to harm over 50% of all endangered species and 40% of their critical habitats. 

The public does not benefit from continued registration of atrazine. 
While industry consistently lines up local Congressmembers, former EPA officials, and agrichemical lobbyists to pressure EPA to keep triazines in the market, there is no evidence that the herbicides benefit the farmers these officials claim to represent. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would provide an economic benefit to farmers. “The winners,” the research concludes, “in an atrazine free future would include farm workers, farmers and their families, and others who are exposed to atrazine either directly from field uses or indirectly from contaminated tap water along with natural ecosystem that are currently damaged by atrazine.”  

EPA has sufficient information to cancel atrazine. 
EPA has long known about triazine’s threats to wildlife, including its ability to chemically castrate male frogs. However, the agency has consistently defended the chemical, and sat by while independent researchers like Dr, Hayes, who conducted seminal research on atrazine’s endocrine disrupting properties, are pilloried by chemical industry propaganda. In a Critical Perspectives piece published in Environmental Toxicology and Chemistry, Jason Rohr, PhD, provides an in-depth investigation of the atrazine controversy. 

“I argue that the atrazine controversy must be more than just a true story of cover-ups, bias, and vengeance,” he writes in the piece. “It must be used as an example of how manufacturing uncertainty and bending science can be exploited to delay undesired regulatory decisions and how greed and conflicts of interest—situations where personal or organizational considerations have compromised or biased professional judgment and objectivity—can affect environmental and public health and erode trust in the discipline of toxicology, science in general, and the honorable functioning of societies.” 

The Draft Ecological Risk Assessments for the Registration Review of Atrazine, Simazine, and Propazine, dated October 5, 2016, found high risks that were supported by EPA’s assessments. EPA states, “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates in these same locations. In the terrestrial environment, there are risk concerns for mammals, birds, reptiles, plants and plant communities across the country for many of the atrazine uses. EPA levels of concern for chronic risk are exceeded by as much as 22, 198, and 62 times for birds, mammals, and fish, respectively. For aquatic phase [stage] amphibians, a weight of evidence analysis concluded there is potential for chronic risks to amphibians based on multiple effects endpoint concentrations compared to measured and predicted surface water concentrations. The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift. Average atrazine concentrations in water at or above 5 μg/L for several weeks are predicted to lead to reproductive effects in fish, while a 60-day average of 3.4 μg/L has a high probability of impacting aquatic plant community primary productivity, structure and function.”

The agency acknowledges many risks of concern associated with the uses of atrazine, but asserts the serious worker and ecological risks remaining after adoption of all proposed mitigation measures are outweighed by the benefits of atrazine use. EPA has determined that the chlorotriazines (triazines) and their three chlorinated metabolites share a common mechanism of toxicity, and as such, human health risks were assessed together through a triazine cumulative risk assessment. The mechanism of toxicity is perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary, leading primarily to a disturbance in the ovulatory surge of luteinizing hormone (LH), which results in both reproductive and developmental alterations. Of the numerous adverse effects associated with this disruption, the two that appear to be the most sensitive and occur after the shortest duration (4 days) of exposure are the disruption of the ovarian cycles and the delays in puberty onset. Importantly, this perturbation manifests after a short duration exposure with long-term life-cycle consequences, so it establishes both acute and chronic toxicity levels of concern (LOCs). 

Toxicity and exposure data available to EPA are sufficient to demonstrate that several atrazine uses exceed risk levels of concern. Exposures to children 1-2 years old playing on turf sprayed with atrazine exceed a risk estimate of concern for combined dermal and incidental oral exposures when assuming the maximum labeled rate for spray applications (2.0 lb ai/A). However, a screening aggregate assessment without the FQPA required safety factor was performed assuming that the application rate for turf is reduced to 1.0 lb ai/A, which would not be of concern for 4-day aggregate exposures. Even with this rate reduction, it can be presumed children are still at serious risk. For occupational handlers, EPA identified use scenarios that exceed risk concerns even with the maximum available personal protective equipment and/or engineering controls (proposed mitigation measures). 

Here is how EPA describes its truncated process for DCPA: 
In 2013, the agency issued a Data Call-In (DCI) to AMVAC Chemical Corporation, the sole manufacturer of DCPA, requiring it to submit more than 20 studies to support the existing registrations of DCPA. The required data included a comprehensive study of the effects of DCPA on thyroid development and function in adults and in developing young before and after birth, which was due by January 2016. Several of the studies that AMVAC submitted from 2013-2021 were considered insufficient to address the DCI, while the thyroid study and other studies were not submitted at all.

In April 2022, EPA issued a very rarely used Notice of Intent to Suspend the DCPA technical-grade product (used to manufacture end-use products) based on AMVAC’s failure to submit the complete set of required data for almost 10 years, including the thyroid study. While AMVAC submitted the required thyroid study in August 2022, EPA suspended the registration based solely on AMVAC’s continued failure to submit other outstanding data on Aug. 22, 2023, following an administrative hearing.  In November 2023, the data submission suspension was lifted after AMVAC submitted sufficient data. Most DCPA use on turf was voluntarily canceled by AMVAC in December 2023, but unacceptable risks from other uses remained. 

As society and the global community struggle with petrochemical pesticides and their contribution to health threats, biodiversity collapse, and the climate emergency, EPA must acknowledge that Dacthal is one active ingredient among over 1,000 in 56,000 pesticide products whose uses can be eliminated by the use of organic systems that have now been shown to be effective.  

*** For more information on the dangers of atrazine and its chemical cousins, read Beyond Pesticides’ comments to EPA, and watch Dr. Tyrone Hayes’ presentations from former National Pesticide Forum events on YouTube. 

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

Letter to EPA Administrator Michael Regan
I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks. The weed killer atrazine fits the criteria used to ban Dacthal and it too should be banned immediately. 

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

Atrazine poses immediate serious harms to people and the environment. Under an Endangered Species Act review, the triazines were found to adversely affect many species. Atrazine is likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds impacts on aquatic and terrestrial ecology. Evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine.

Atrazine also poses significant threats to human health. It has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia and hypospadias. The mechanism of toxicity—perturbation of the neuroendocrine system—results in reproductive and developmental alterations. 

Mitigation measures have not eliminated harm. In typical fashion, EPA proposed minor label changes to mitigate risks identified in its registration review, deciding not out of concerns relating to human health and environmental protection, but to provide “regulatory certainty” for farmers and local officials. Environmental and health harms continue.

The public does not benefit from continued use of atrazine. There is no evidence that atrazine benefits farmers. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would economically benefit farmers. Claims that losing atrazine will lead to reduced corn yields and increased prices have been refuted by these researchers. Because much of the corn grown in the U.S. is intended for ethanol producers and livestock feed, corn prices are heavily determined by the demand from these two sectors, compared to production costs. 

Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.”

EPA has sufficient information to ban atrazine.
EPA has long known about atrazine’s threats to wildlife, including its ability to chemically castrate male frogs. EPA’s ecological risk assessment found high risks: “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates. . . The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift.” 

EPA has determined that the triazines and their chlorinated metabolites share a common mechanism of toxicity—perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary—leading to a disturbance in the ovulatory surge of luteinizing hormone, resulting in reproductive and developmental alterations. These risks exceed levels of concern, including children and workers. 

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

Thank you.

Letter to U.S. Representative and Senators
I am pleased to see EPA’s action to ban Dacthal and prohibit the use of existing stocks.  The weed killer atrazine fits the criteria used to ban Dacthal and it too should be banned immediately. 

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

Atrazine poses immediate serious harms to people and the environment. Under an Endangered Species Act review, the triazines were found to adversely affect many species. Atrazine is likely to harm over 50% of all endangered species and 40% of their critical habitats. EPA finds impacts on aquatic and terrestrial ecology. Evidence shows that subsequent life stages or generations of fish are at greater risk of reproductive dysfunction after embryonic/early life exposure to atrazine.

Atrazine also poses significant threats to human health. It has been linked to a range of adverse birth outcomes, including smaller body sizes, slower growth rates, and certain deformities like choanal atresia and hypospadias. The mechanism of toxicity—perturbation of the neuroendocrine system—results in reproductive and developmental alterations. 

Mitigation measures have not eliminated harm. In typical fashion, EPA proposed minor label changes to mitigate risks identified in its registration review, deciding not out of concerns relating to human health and environmental protection, but to provide “regulatory certainty” for farmers and local officials. Environmental and health harms continue.

The public does not benefit from continued use of atrazine. There is no evidence that atrazine benefits farmers. According to research published in the International Journal of Occupational and Environmental Health, banning atrazine would economically benefit farmers. Claims that losing atrazine will lead to reduced corn yields and increased prices have been refuted by these researchers. Because much of the corn grown in the U.S. is intended for ethanol producers and livestock feed, corn prices are heavily determined by the demand from these two sectors, compared to production costs. 

Significantly, EPA routinely refuses to recognize the success of organic farming, which does not depend on synthetic pesticides, in calculating “benefits.” 

EPA has sufficient information to ban atrazine. EPA has long known about atrazine’s threats to wildlife, including its ability to chemically castrate male frogs. EPA’s ecological risk assessment found high risks: “Based on the results from hundreds of toxicity studies on the effects of atrazine on plants and animals, over 20 years of surface water monitoring data, and higher tier aquatic exposure models, this risk assessment concludes that aquatic plant communities are impacted in many areas where atrazine use is heaviest, and there is potential chronic risk to fish, amphibians, and aquatic invertebrates. … The breadth of terrestrial plant species and families potentially impacted by atrazine use at current labeled rates, as well as reduced rates of 0.5 and 0.25 lbs. a.i./A, suggest that terrestrial plant biodiversity and communities are likely to be impacted from off-field exposures via runoff and spray drift.” 

EPA has determined that the triazines and their chlorinated metabolites share a common mechanism of toxicity—perturbation of the neuroendocrine system by disrupting hypothalamic regulation of the pituitary—leading to a disturbance in the ovulatory surge of luteinizing hormone, resulting in reproductive and developmental alterations. Data available to EPA demonstrate that several atrazine uses exceed risk levels of concern, including children and workers. 

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

Thank you.

Image: Art Page submission from Sara Grantham, “Sunflower Pollinators” 

(Beyond Pesticides, August 23, 2024) A study in Science of The Total Environment calculates and compares pesticide risk in 594 wild bee species associated with crops in North America. Current pesticide risk assessments that analyze effects on bees primarily focus on a limited subset of species and do not provide comprehensive protection of all wild bees. “Species commonly proposed as models for pesticide risk assessments may not accurately represent risk for those bee species facing the highest potential risk in agricultural contexts,” the authors postulate.

The researchers continue, “This study presents a novel approach to characterize and compare the relative potential pesticide risk among wild bee species of their association with crops in North America using suites of intrinsic bee traits to quantify species’ vulnerability and extrinsic factors based on the toxic load of crops for bees and the strength of each species’ association with those crops.” In considering multiple factors that vary by species and determining potential harm to each from pesticide exposure, this study highlights the inadequacies of the current risk assessment process used by the U.S. Environmental Protection Agency (EPA).   

The system for risk assessment for pesticides that impact bees includes a tiered process, with Tier I as a screening tool within the laboratory and Tiers II and III as field studies. According to EPA, Tier I uses “conservative assumptions regarding exposure (i.e., assumptions that are likely to overestimate exposure) and uses the most sensitive toxicity estimates from laboratory studies of individual bees to calculate risk estimates.” These studies, however, primarily focus on honey bees such as Apis mellifera and do not consider the varying sensitivity in other bee species.

As the authors point out, “the use of a very unusual and non-representative species, A. mellifera, as a model for all bee species in pesticide risk assessments [is] because of the ease with which the species can be maintained by humans, well developed risk assessment protocols for the species, and its cost effectiveness.” The use of this species is not due to its ability to well-represent all other bee species.

EPA’s process does not factor in the growing body of scientific evidence regarding the negative impacts of pesticide exposure on a wide range of bee species, as well as other vital pollinators. This study suggests that efforts should be focused “on the subset of wild bee species likely experiencing the highest potential pesticide risk as a starting point for protection and conservation goals” instead of a reliance on a single species where the majority of data collected is under laboratory settings that do not mirror real-world exposure. See more on EPA’s failure to protect bees here.

Over 20,000 known wild bee species exist worldwide, with about 3,600 native to North America. Of those, 739 species are known to be associated with agricultural crops. For their research, the authors of this study obtained complete information for all life history categories and size for 594 of those identified bee species to analyze. Since exposure to agricultural pesticides is one of the multiple interacting drivers of wild bee declines globally, representative risk assessments are imperative to protect biodiversity and ecosystem services and thus need to be thorough.

For proper risk assessments, “a comprehensive understanding of both the nature of the risk (risk = hazard x exposure) attributable to pesticide use on crops and the nature of the intrinsic vulnerability of bees to pesticides is required,” the researchers state. In chemical-intensive agriculture, each crop requires different pesticide use regimes, each pesticide has varying toxicity, and bee species have different vulnerabilities that need to be considered. The authors continue in saying, “Across North America, the amount, type (active ingredient, systemicity, and toxicity), application method, and environmental persistence of pesticides used in agriculture vary by crop. The combination of these defines the bee toxic load unique to each crop.”

The main objectives of this study are to:

1. characterize and compare the relative potential risk experienced by wild bee species that are associated with agriculture in North America using (a) suites of bee traits to quantify species’ intrinsic vulnerability and (b) extrinsic factors based on the toxic load of crops to bees and the strength of each species’ association with those crops; and
2. describe the relative influence of extrinsic factors and intrinsic traits on calculated relative risk to bees from agricultural pesticides.

This was achieved by combining “both the Bee Vulnerability Score (BVS) and the Crop Association-Weighted Toxic Load for each bee species to calculate the relative potential risk experienced by that species from its association with agriculture” that then allows the researchers to rank the species by their potential risk score. Higher point values correspond to higher risk of exposure and/or susceptibility to agricultural pesticides.

The available data that was utilized in this study focus on crops for alfalfa, almond, apple, blueberry, cherry, corn, cotton, cucumber, eggplant, melon, pear, peppers, plum, potato, pumpkin, raspberry, soybean, strawberry, sunflower, tomato, and watermelon; these crops are known to be associated with 713 total bee species.

The authors find, “The highest BVS was shared by bee species that were small, ground nesting, solitary, and with crop specialization,” which includes the species Andrena melanochroa, Panurginus atramontensis, and Pseudopanurginus albitarsis. The lowest scores were found in Bombus species. Within the 90th percentile for the vulnerability scores, the researchers note that, “Five families (Andrenidae, Apidae, Colletidae, Halictidae, Megachilidae), 20 genera, and 60 bee species were represented.”

From the results, the authors point out that, “Importantly, species that are commonly used as models to assess the effects of pesticides on wild bees, like Bombus impatiens, Megachile rotundata, and Osmia species, all exhibited BVS below the median.”

The data also reveals that corn, peppers, potato, raspberry, and cherry have the highest toxic loads per crop for bees. As the authors say, “The high toxic loads of corn and peppers can be explained by the intensive use of bee toxic insecticides, including pyrethroids (e.g., cyfluthrin, zeta-cypermethrin, cypermethrin, bifenthrin) and organophosphates (chlorpyriphos) in corn, and neonicotinoids (e.g., imidacloprid, clothianidin, thiamethoxam, dinotefuran), pyrethroids (e.g., zeta-cypermethrin, cyfluthrin, permethrin, bifenthrin, lambda-cyhalothrin), and organophosphates (naled) in peppers… The intensive use of neonicotinoid (e.g., imidacloprid, thiamethoxam) and pyrethroid (e.g., zeta-cypermethrin, bifenthrin) insecticides in potato, raspberry, and cherry also contributes significantly to the high toxic loads of these crops.”

The researchers establish that extrinsic factors with environmental exposures are more strongly associated with risk to bees than intrinsic traits within the species. Extrinsic factors, such as bees not only foraging from crops but also nesting or overwintering in soils, can increase their pesticide exposure. Life history traits can vary greatly between species, “showing differences in phylogeny, nesting behaviour, sociality, size, reproductive strategies, phenology, larval provisioning strategies, diet breadth, and ability to detoxify pesticides.” All factors must be considered for risk assessments as studying a single species with a certain subset of traits is not representative of all bees.

Species that can detoxify pesticides more efficiently than others are less vulnerable to the effects of pesticides they are exposed to. For species that do not have this ability, such as “some species of the Megachile genus [that] lack important detoxification genes found commonly in other bee groups,” they have substantially higher sensitivity. This includes Megachile rotundata, which the authors identify in the top 10% for potential risk.

The authors highlight that, “Pesticide exposure for bees visiting treated perennial crops such as orchards may be higher than in annual crops because there is no crop rotation and no soil tillage, meaning that persistent pesticides are likely to accumulate in soil. Conversely, annual crops planted with pesticide-treated seeds may also bear higher risk to wild bees because some highly bee toxic neonicotinoid insecticides (e.g., imidacloprid, thiamethoxam) are often applied in this manner and because potential exposure of ground-dwelling bees to pesticide residues in the soil is high. Systemic pesticides can travel into nectar and pollen from their points of application, and persistent chemicals can accumulate in soil, causing an increase in toxic load over time that is especially relevant to bees that nest or overwinter in the ground.”

Pesticides used as seed coatings were not included in the data for this study, and as such the “reported toxic loads for alfalfa, corn, cotton, cucurbits, eggplant, pepper, potato, soybean and sunflower (i.e., crops that may be grown using treated seeds) may be well below their true toxic load and should be understood in that light,” the authors say.

This study helps to highlight relative potential risk, not absolute risk, for the varying bee species currently not considered by EPA when performing risk assessments even though hundreds of species are exposed to pesticides through foraging and nesting behaviors within North America. For a more representative risk assessment process, the authors “suggest an approach that combines information about intrinsic suites of bee traits that define a species’ vulnerability to pesticides with extrinsic factors such as the toxic load born by crops and the strength and breadth of a species’ association with those crops that define potential environmental risk for that species in agroecosystems.”

The researchers hope that this study “can empower stakeholders to (1) prioritize research efforts towards studying species or groups identified as being at highest risk, (2) address environmental factors contributing to risk generally, (3) tailor management practices in specific crops to mitigate risks effectively, (4) design conservation plans for agriculture, and (5) inform future risk assessment protocols, particularly by highlighting bee species or groups that exhibit the highest vulnerability based on their unique traits.”

While the risk assessment process for toxic pesticides is lacking and needs improvement, a better solution exists with organic land management. The holistic approach with organic practices provides a healthy alternative to the detrimental effects of chemicals that pollute the environment and all organisms within it. Protecting all bee species, as well as other pollinators, from pesticides is crucial to agricultural and economic productivity, as well as food security. Take action to advance organic, sustainable, and regenerative practices and policies and be part of the organic solution by becoming a member of Beyond Pesticides today.

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

Source:

Chan, D. and Rondeau, S. (2024) Understanding and comparing relative pesticide risk among North American wild bees from their association with agriculture, Science of The Total Environment. Available at: https://www.sciencedirect.com/science/article/pii/S0048969724055281?ref=pdf_download&fr=RR-2&rr=8b318d57dae85782.