(Beyond Pesticides, January 8, 2025) On the brink of the second Trump administration, a legal victory just last month overturned a rule issued under the first Trump administration to “practically eliminate oversight of novel GE technology and instead let industry self-regulate,” as characterized by the Center for Food Safety (CFS). CFS served as counsel in the case for the plaintiffs, led by the National Family Farm Coalition. The U.S. District Court for the Northern District of California decision, responding to the lawsuit filed in 2021 on behalf of farm and environmental groups, remanded the case back to the U.S. Department of Agriculture (USDA) with instructions to follow. “This is a critical victory on behalf of farmers, the planet, and scientific integrity,” says George Kimbrell, legal director at the Center for Food Safety, also a plaintiff in the case. Mr. Kimbrell continued, “USDA tried to hand over its job to Monsanto and the pesticide industry and the Court held that capitulation contrary to both law and science.” It remains to be seen whether the incoming Trump administration will appeal this court decision.

Unpacking The Center for Food Safety Litigation

This legal battle began in 2004 with the Animal and Plant Health Inspection Service (APHIS) announcing that it would revisit rulemaking on the governance of genetically engineered organisms. In 2008, APHIS published a notice of this proposed rulemaking that resulted in the final rule in 2020. Center for Food Safety filed the lawsuit in 2021.

The court agreed with litigants that USDA violated various keystone environmental statutes, including the Endangered Species Act (ESA), the National Environmental Policy Act (NEPA), and the Plant Protection Act (PPA). [Passed by Congress in 2000, PPA consolidated the regulatory system for genetic engineering into one unitary framework combining various other previous laws.] Ultimately, the court determined that APHIS—the leading USDA agency assessing potential harms of GE crops—made “significant” errors regarding PPA and the Administrative Procedure Act (APA). “Summary judgment is granted to plaintiffs on the PPA-based APA claim that it was arbitrary and capricious for APHIS to not incorporate its noxious-weed authority in the final rule and to implement the conventional-breeding exemptions,” reads the summary judgment, written by U.S. District Judge Hon. James Donato.

Unpacking this ruling, the court finds that APHIS acted “arbitrarily and capriciously” in regard to PPA’s statutory mandate on noxious-weed authority (a.k.a. management of invasive plants and weeds) as well as attempting “to implement the conventional-breeding exemptions.”

Relating to noxious weed authority, the court finds that “ignoring concerns the agency [APHIS] had previously recognized is not reasoned decision-making’” in highlighting “APHIS’s failure to address the limitations in the part 360 regulations with respect to GE plants that its prior assessments identified as justifying adding noxious weeds as a trigger to part 340 regulations was arbitrary and capricious.”

Relating to breeding exemptions, “Nowhere in the final rule does APHIS acknowledge the conflicting scientific evidence concerning the basis on which the exemption is premised,” says Judge Donato. This, he refers to as “arbitrary and capricious.”

A Game of Hot Potato: History of GE Litigation and Rulemaking

In 2019, USDA under the first Trump Administration proposed new rulemaking that would exempt almost all GE crops from regulation and allow the company that makes them to decide whether they are safe. In a petition submitted to the Federal Register that year, USDA Must Offer Basic Protection from Genetically Engineered Organisms, over six thousand comments were submitted by members of the public on varying sides of these issues. Environmental, public health, and consumer safety organizations, including Beyond Pesticides, urged that APHIS regulations should:

• Base the regulation of GE organisms on the unique hazards they present;
• Include “synthetic biology” in the definition of regulated genetic engineering;
• Prohibit developers from exempting themselves from regulation;
• Regulate plant-made pharmaceutical and industrial chemicals (PMPIs);
• Ensure that plant incorporated protectants (PIPs) are regulated at all scales;
• Address hazards other than “plant pest” risks, including: The unwelcome presence of GE genes in neighboring fields of organic or identity-preserved crops, the creation of new compounds in a plant formed in the plant’s detoxification of herbicides, the movement of genes for manufacture of industrial or pharmaceutical chemicals into crop plants, the creation of “superweeds” (plant pests) through selection for resistance to herbicides continually used on GE crops, the overuse of herbicides in cropping systems dependent on the use of herbicides sprayed over herbicide-tolerant crops, destruction of habitat adjacent to farm fields by overuse of nonselective herbicides sprayed over herbicide-tolerant crops, selection for resistance in insects targeted by PIPs, reduction in populations of insects due to effects of PIPs and destruction of habitat adjacent to fields sprayed by nonselective herbicides over herbicide-tolerant crops, and health effects suffered by those exposed to excessive use of herbicides.

The labeling requirement, in conjunction with the first Trump Administration’s National Bioengineered Food Disclosure Law (See Daily News review here and here), mandated that genetically engineered foods bear labels that indicate that they have been “bioengineered,” provide a text-message phone number or display a QR code to access further information. (“Additional options such as a phone number or web address were available to small food manufacturers or for small and very small packages.”) According to an agency spokesperson, the rule is designed to “balance the need to provide information to consumers with the interest in minimizing costs to companies.” Advocates and communities arrived at different conclusions. (See here for previous Daily News.)

Associated Threats Relating to GE Products

Organic advocates and farmers view federal decision-making, regardless of Republican or Democrat-run administrations, as inadequate to protect against GE contamination and subsequent health risks. Look no further than the Biden Administration-published report that promotes genetic engineering, “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology.” (See Daily News here.)

Going further, the U.S. Environmental Protection Agency (EPA)-approved the introduction of millions of GE mosquitoes in California and Florida (See Daily News here) alongside the continuous use of prophylactic synthetic insecticide spraying (including sumithirin and bifenthrin) amid outbreaks of deadly arborviruses such as West Nile and Eastern Equine Encephalitis (see Beyond Pesticides press release here and associated Action of the Week here) exacerbates insect and weed resistance to toxic chemicals and pesticides. Public health professionals and wildlife and ecosystem stewards alike, not to mention local communities across the country, continue to hold concerns that industry is creating the same problems they wish to solve for the sake of profit and at the expense of public well-being.

For more coverage of regulatory decision-making and litigation, see Daily News sections on litigation, genetic engineering, and USDA. Are you continuing to feel frustrated about the direction of food safety and health of your communities going into 2025? Consider subscribing to Action of the Week to voice your concerns directly to decision-makers. You can start with the following action telling USDA, FDA, and EPA to replace agricultural provisions in the Framework with policies that discourage GE crops and promote organic agriculture.

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

Source: Center for Food Safety

(Beyond Pesticides, January 7, 2025) A report, released in December 2024 from the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), confronts the problem of “siloing” environmental elements—food, health, water, biodiversity and climate change—when they instead intersect at a nexus from which each element affects all the others. The problem is essentially that all the elements are part of the same crisis, yet actions to address issues within each—and, importantly, to resist addressing them—are dealt with in isolation. A proper perspective, gleaned from the report, is to view each element from the center where all parts meet, thus addressing the issues in coordination.

According to the IPBES report, “[F]ragmented governance of biodiversity, water, food, health and climate change with different institutions and actors often working on disconnected and siloed policy agendas, resulting in conflicting objectives and duplication of efforts.” The IPBES is an independent body analogous to the Intergovernmental Panel on Climate Change (IPCC) but structured similarly and in close contact with the United Nations (UN). The new report comes at the behest of IPBES’s 147 member countries—75 percent of the UN’s membership—to address the interconnections among the five global crises.

The report strongly demonstrates that a holistic, globe-spanning frame of mind must be adopted to cope with the global crisis. For example, human health cannot be separated from healthy food production practices and clean water. Nor can the effects of climate change and biodiversity on human health and the food supply be ignored. IPBES stresses that without coordination, improvement in one area can damage conditions in another area, resulting in tradeoffs and unintended consequences that impede actual progress. Feedback loops can amplify tradeoffs, for instance through attempts to couple soil carbon capture with energy production, causing environmental deterioration. But if beneficial changes in, say, food production, are coordinated with beneficial changes in water management, the effects can be synergistic in a positive way for all the elements.

Beyond Pesticides supports the increased application of organic agriculture as a primary way of integrating solutions to each of the elements now treated in isolation. Organic protects biodiversity, preserves water quality, protects food quality and therefore human health, and mitigates climate change. The IPBES report stresses that current “food first” approaches to agriculture prioritize food production using energy-intensive, polluting and toxic methods, which improves nutritional health but relies on what IPBES calls “unsustainable intensification and increased per capita consumption.” Beyond Pesticides’ advocacy for nature-based solutions, such as protecting pollinators, discouraging monoculture, eliminating pesticides, and enhancing soil health, improve the food element while also being synergistic with other parts of the nexus.

IPBES also emphasizes that there are countervailing forces rooted in short-term financial gains for “a small number of people while ignoring [the] negative impacts” that affect “the well-being of some more than others.” For example, “[I]ncreases in unsustainable food production have been associated with land conversion and the expansion of unsustainable agricultural practices, particularly driven by affluence. Such practices have led to biodiversity loss, reduced water availability and quality, increases in greenhouse gas emissions and [increased risk] of pathogen emergence.” In other words, an economy that produces affluence for its own sake destroys the global system that produces life. And the affluence is generally confined to a very small stratum of humanity, leaving the consequences to the least affluent.

Such economic drivers are considered indirect influences on global environmental degradation. In fact, the trends in indirect drivers are nearly the exact opposite of trends in the nexus elements. Gross domestic product, exports, population growth and urbanization increased dramatically between 1970 and 2020, while freshwater availability and species survival plunged and climate-related disasters spiked.

The IBPES report also notes that “Global agrobiodiversity, including genetic resources for food and agriculture, is declining (with global food production heavily dependent on just 9 crop species that contribute to 65 per cent of the world’s crop production.” Nor has increased food production improved nutritional quality. And human health is certainly not improving. According to the report: “Unsustainable farming systems contribute to biodiversity loss, excessive water use, pollution and climate change, which further exacerbates health problems. Increased air and water pollution caused an estimated 9 million premature deaths in 2019 (16 per cent of all deaths worldwide) through diseases such as respiratory disease, cancer, allergies, birth defects, neurodegenerative disease and impaired cognitive development. Emerging and reemerging infectious disease events have been rising, with half of these driven by changes in land use, agricultural practices and activities that encroach on natural habitats and lead to increased contact between wildlife, domestic animals and humans. . . Transforming to more efficient, inclusive, resilient and sustainable food systems would deliver multiple benefits to the nexus elements and would help countries address land conversion and unsustainable agricultural practices.”

The report estimates that over half of global gross domestic product (GDP), $58 trillion in 2023, is generated by economic sectors moderately or highly dependent on nature. At the same time, externalities—costs not accounted for in the economic calculus—include $10-25 trillion of negative effects of fossil fuels and harmful practices in agriculture and fisheries, $5.3 trillion in private sector financing of such negatives, and public subsidies incentivizing the negatives. One of the obvious implications of the IPBES report is that there is no such thing as an externality when it comes to calculating the costs and benefits of a functioning ecosphere.

The report also constructs six approaches it calls “archetypes” and ranks them according to their synergistic positive outcomes on human health: nature-oriented, a balance of nexuses, conservation first, climate first, food first and nature overexploitation. The top three are the nature-oriented, balanced, and conservation first archetypes. IPBES unequivocally selects the “nature-oriented nexus” as the strongest positive outcome and, not coincidentally, the approach that provides the most synergy among the five elements of climate, biodiversity, water, food and human health. The nature-oriented nexus” emphasizes strong environmental regulation, sustainable agricultural practices, lower rates of global per capita consumption, and strong development of green technologies.”

At the bottom, privileging food, climate, and nature exploitation produce the worst outcomes. Only emphasizing the simultaneous and coordinated policies and practices will accomplish the goals of each individual nexus.

This could be counterintuitive for advocates of organic and regenerative agriculture, unless the goal contains an understanding of the interdependent, interactive nature of the nexus elements, and of the possibility of positive or negative reinforcements and feedbacks. Unless carefully constructed, a food first scenario might include harmful expansion of fossil fuel use, greenhouse gas emissions, and fertilizer pollution. In other words, in order to avoid negative consequences for both food and the other global elements, food production must abandon conventional agriculture’s dependence on highly industrialized products, many of its practices, and possibly some of its foundational political and economic supports. For example, as Beyond Pesticides has shown, courts tend to balance allegations of pesticide harms against corporations’ right to make a profit. This is itself an extreme imbalance of the values that make human life sustainable.

Beyond Pesticides strongly supports the de-siloing of the five nexus elements discussed in the IPBES report and has provided detailed information about the interdependencies of biodiversity, food, climate, water and human health for decades. Beyond Pesticides’ Annual Report for 2023-2024 details not only o organization’s communication of news and the latest science, but how this foundation provides support for actions aimed at changing not only agricultural and land management practices but also corporate accountability and public policy decision-making.

Biodiversity in Land Management Integral to Sustainability, in the winter 2016-2017 issues of Pesticides and You provides a deep analysis of the damage that monoculture and pesticides do to biodiversity, and the many ways that biodiversity-aware agriculture, such as cover crops, interbedding pollinator-friendly plants with food crops, and crop rotation can combat that damage. A June 2024 Daily News highlights a study showing that pesticides contaminate aquatic algae, triggering cascade effects through all trophic levels. These in turn affect four important elements: water, biodiversity, human health and food.

The report concludes that: “[S]ustainable healthy diets, reduced food loss and waste and ecological intensification and sustainable intensification of agriculture and ecosystem restoration can be combined (i.e., bundled together) and incentivized and driven by behaviour change to reduce land conversion and water pollution, halt or reverse biodiversity loss, improve human health, and reduce greenhouse gas emissions. Some response options in and of themselves are similar to bundles in that they comprise multiple synergistic actions, such as Indigenous food systems that emerge from Indigenous and local knowledge and traditional practices and which are based on holistic worldviews.”

Beyond Pesticides has highlighted numerous examples of purported climate-friendly agricultural technologies that do far more harm than good. A good example from the November 15, 2024 Daily News exposes how schemes to yoke carbon capture to energy generation in agriculture can lead to disaster. Organic agriculture can preserve and rebuild soil carbon without using biofuels such as biochar and ethanol, both of which have major downsides. The connections between agricultural chemicals and damage to human health fill the scientific literature and is captured in Beyond Pesticides’ Pesticide-Induced Diseases Database.

Making this change can seem overwhelming given the economic and political trends of the moment. However, there are many ways to implement progressive policies—what the report calls “response options”—short of convincing recalcitrant politicians and business tycoons at national and international levels. The report also notes that there are already three important international agreements: the Sustainable Development Goals, the Kunming-Montreal Global Biodiversity Framework, and the Paris Agreement, that will be strengthened and advanced by IPBES’s 71 recommended response options.

The report contains a helpful figure (SPM.7, p.23) showing how particular applications in a broad category like coordinating planning and governance policies, can include development of city region food systems, which in turn contributes to the element “food” and mitigates climate change in coordination with various other steps like integrating watershed and health interventions, making urban infrastructure water-sensitive, and so on.

Thus, there are numerous granular projects that can be implemented without having to move the needle at the macro level. Local changes can “emerge from coordinated networks by drawing on social knowledge and integrating actions across sectors by increasing collaboration among diverse actors.” Beyond Pesticides’ Parks for a Sustainable Future program illustrates steps that can be taken at the local level to eliminate the use of petrochemical pesticides and fertilizer. The IPBES report places great emphasis on urban nature-based solutions. A World Wildlife Fund report highlights cities that have adopted such solutions by building greenways, swales, green roofs and many other landscape changes that mitigate natural disaster impacts, clean polluted water, remove atmospheric carbon, provide human health benefits, and foster biodiversity. These are steps that can take place locally and regionally even if the national wheels of progress are grinding slowly or in reverse.

The current health, biodiversity, and climate crises are the most profound problems humanity has yet encountered and calls for dismantling siloes, integrating knowledge among disciplines and between actions, and committing to changing some of our most basic beliefs and dogmas. This is not an optional process; it is life or death, not only for human civilization but for the environmental processes that sustain it. But we can take beneficial steps across the broad spectrum of human activity as long as we consider their effects on the multiple health and environmental elements that intersect, and keep our eyes on the prize of a healthy, abundant, and sustainable planet.

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

Sources:

Summary for policymakers of the thematic assessment of the interlinkages among biodiversity, water, food and health (nexus assessment)
Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services
ADVANCE UNEDITED VERSION
16 December 2024
https://ipbes.canto.de/pdfviewer/viewer/viewer.html?v=IPBES11Media&portalType=v%2FIPBES11Media&column=document&id=cj0uc5396d1ed5418tsuic2r45&suffix=pdf&print=1

Scientists from 57 countries want to end siloed decision-making on climate and biodiversity
Joseph Winters
Grist Dec 18, 2024
https://grist.org/solutions/ipbes-un-panel-biodiversity-ecosystem-services-nexus-report-namibia/

IPBES: Tackle Together Five Interlinked Global Crises in Biodiversity, Water, Food, Health and Climate Change
Media Release: IPBES Nexus Assessment
16 December 2024
https://www.ipbes.net/nexus/media-release

Business As Usual “Carbon Capture” Undermines Organic Land Management as a Climate Solution
Beyond Pesticides, November 15, 2024
https://beyondpesticides.org/dailynewsblog/2024/11/business-as-usual-carbon-capture-undermines-transition-to-organic-land-management-as-a-climate-solution/

(Beyond Pesticides, January 6, 2025) With the incoming U.S. president promising the “most aggressive regulatory reduction” ever seen in the country’s history, attention shifts to local and state governments’ responsibility to protect health and the environment. While the reliance on local governments to fill the gaps left by deficient federal action is not new, the U.S. system of federalism has historically and constitutionally required a sharing of powers from local to state to federal, with a reliance on agencies like the U.S. Environmental Protection Agency (EPA) to establish a basic level of protections. While the role of local and state governments has been critical to ensuring environmental and public health protection when scientific findings have shown federal action to be inadequate, the new administration has outlined a course that suggests an increasingly important role for local and state governments. As Beyond Pesticides has reported, “Mr. Trump, who has called climate change a “hoax,” has targeted “every one” of Mr. Biden’s policies designed to transition the United States away from fossil fuels,” according to The New York Times. This is happening as the country and world face serious catastrophic threats of ongoing and escalating health, biodiversity, and climate crises.

In this context, a piece published by Harvest Public Media at the end of December, captures the power of individuals and communities working together to adopt a rather simple change that is crosscutting in its effect on the current and growing health, biodiversity, and climate crises—transitioning parks and public spaces to organic practices. For environmental and public health advocates, this is a bright spot in responding to the crises with practical steps. The article, “These Midwest cities are cutting pesticides from public parks with the help of a national nonprofit,” highlights the work of Jen Schroeder, a mother of two children in Kansas City, who wants, simply, her neighborhood park where her children play to be free of toxic chemical use. She saw a flier in her local Natural Grocers grocery store about Beyond Pesticides’ Parks for a Sustainable Future Program, reached out to her Kansas City Parks and Recreation Department, and now the city is moving ahead to transition two pilot sites to organic practices. It happened with a simple reaching out to the Parks Department. With the hands-on assistance of Beyond Pesticides, Parks Departments receive a plan and training from a horticulturist and learn about organic practices that can be applied across all parks and public spaces. (More information on the Parks Program is available here.)

In its Action of Week this week, Beyond Pesticides is urging people to become a part of the Parks Program and ask their Mayor, in the new year, to adopt a policy and program for organic management of your community’s parks and public spaces. 

In protecting children using their community parks, the organic land management program is creating models for cost-effective programs that meet community expectations, while eliminating the use of petrochemical pesticides and fertilizers. When combined with the growth of certified organic agriculture, the conversion of land management to organic eliminates the petrochemicals associated with endocrine disruption (see a talk by Tracey Woodruff, PhD here) and rising rates of related illnesses, biodiversity decline, and an escalating climate crisis. As the climate crisis causes increasingly erratic weather, more frequent flooding, and widespread fires, organic soil management draws down atmospheric carbon, which reduces the threat of greenhouse gases that contribute to climate disasters. Also, see the effects of synthetic fertilizers. 

Given the political context, advocates see this as a critical time to engage in efforts to advance organic, from choices in diet, lawn and landscape care, or community involvement. Beyond Pesticides provides more on the reasons why: 

1. Health and Safety: Organic foods and parks are free from harmful pesticides, fossil-fuel-based substances, and toxic chemicals, making them safer and healthier for all ages. Visit Beyond Pesticide’s 40 Common Lawn and Landscape Chemicals page to learn more about the health impacts of pesticides in communities. See how you can manage your landscape without petrochemical pesticides and fertilizers. 
2. Environmental Stewardship: Organic land management supports practices that protect pollinators, improve soil health, increase biodiversity, and reduce toxic runoff into water bodies. Learn more about how to protect pollinators by reading BEE Protective. 
3. Trust and Transparency: The USDA Certified Organic label ensures strict standards and regulations for organic products, providing trust and transparency for consumers worldwide. We provide oversight for parks that use organic land management. Visit Beyond Pesticide’s literature called Save Our Organic to learn more about the power of the organic label and use our Keeping Organic Strong page to keep USDA accountable to the principles and values in the Organic Foods Production Act. 
4. Just Communities: Supporting organic farming practices can benefit local communities and economies, as well as promote responsible animal welfare and fair labor conditions. Organic parks are the ethical choice to promote environmental justice. The Black Institute’s Poison Parks report shines a spotlight on New York City’s previous reliance on glyphosate-based herbicides and that people of color communities, including landscapers, bear the burden of this toxic chemical’s impact. 
5. Climate Resilience: Organic farming often exhibits better performance during droughts and challenging environmental conditions. Watering needs are very site-specific and the type of soil impacts drainage. Once established, a deep root system from organic land management requires less water and results in the drawn down of atmospheric carbon, contributing to efforts to reduce the adverse effects of carbon on climate. 

Ask your Mayor, in the new year, to adopt a policy and program for organic management of your community’s parks and public spaces. 

Letter to Mayor
I am writing to urge you to use your leadership in the new year to require as a matter of policy and practice the organic management of our community parks and public spaces. My concern about the management of public spaces—used by children and families, those with health vulnerabilities, pets, and wildlife—stems from the hazardous nature of the petrochemical pesticides and fertilizers commonly used. The adverse health and environmental effects are captured on two factsheets, 40 Commonly Used Lawn Pesticides (bp-dc.org/lawnfactsheets). With this information, we urge you to advance a policy and management decision to stop the use of these hazardous chemicals and transition our parks to organic practices.

The factsheets document, with scientific citations, a wide range of diseases and ecological effects linked to pesticides. The underlying analysis identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases.

Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects, 26 are possible and/or known carcinogens, 24 have the potential to disrupt the endocrine (hormonal) system, 29 are linked to reproductive effects and sexual dysfunction, 21 have been linked to birth defects, 24 are neurotoxic, 32 can cause kidney or liver damage, and 33 are sensitizers and/or irritants. Regarding adverse environmental effects, 21 are detected in groundwater, 24 have the ability to leach into drinking water sources, 39 are toxic to fish and other aquatic organisms vital to our ecosystem, 33 are toxic to bees, 18 are toxic to mammals, and 28 are toxic to birds.

In adopting organic land management, our community can make an important contribution to solving the threat that petrochemical pesticides and fertilizers are to biodiversity collapse and the climate crisis. The 2022 United Nations Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) warns that we must adopt policies and practices that reflect the value of Nature’s biodiversity, including pollinators, in supporting human life and activity. This starts with the management of soil and landscapes in our community.

As the climate crisis causes increasingly erratic weather, more frequent flooding, and widespread fires, organic soil management draws down atmospheric carbon, which reduces the threat of greenhouse gases that contribute to climate disasters. Organic management of our parks enables our community to contribute to solving this existential crisis and elevates our role in climate action.

Please take advantage of Beyond Pesticides’ offer to assist you and land managers of our community parks in the adoption of organic land management practices through its Parks for a Sustainable Future program. You can contact them at [email protected].

I look forward to your reply and working with you in the new year.

(Beyond Pesticides, January 3, 2025) Pesticides that are sprayed and become airborne significantly disrupt ecological balances and affect nontarget species that are crucial for maintaining biodiversity, according to an article in Environmental Pollution. In this review of studies throughout countries in North and South America, Europe, and Asia, among others, researchers from Germany, Norway, the United Kingdom, and Poland reinforce the science about pesticides’ direct effect on species and the cascading effects of pesticide drift through various trophic levels within food webs that lead to overall devasting population effects.

This study “addresses the interconnectedness of these impacts and illustrates the complex threats that pesticide drift poses to biodiversity across multiple ecosystems,” the researchers state. They continue: “Impacts include reduced reproductive rates, changes in growth, development, and/or behavior, modification of diversity or community organization, disruption of food webs, and declines of important species. Pesticides disrupt the delicate balance between species that define a functioning ecosystem. Impacts can be local, transnational, or even continental.”

Pesticide drift threatens beneficial species and subsequently the entire agricultural system. The process of pesticide drift, “in which up to 25% of applied pesticides are carried by air currents, can transport chemicals over hundreds or even thousands of kilometers,” the authors state. Other research has found that less than .1% of pesticides applied to crops reach the target pest. Drift rates vary due to a series of factors including temperature, wind speed, humidity, and soil type.

“The overuse of synthetic pesticides has unintentionally contaminated unintended areas, harmed non-target species and disrupted ecosystems that support agricultural productivity,” the researchers note. Pesticide drift “exposes a wide range of nontarget living organisms such as beneficial insects, birds, and other animals that live near to/or far from the incurred areas.” Drift exposure upsets the intricate balance of the ecosystem and reduces the ability of beneficial species to support agriculture. This underlines the broader environmental impacts that must be “carefully managed to preserve the ecological equilibrium on which agriculture ultimately depends,” the authors highlight.

Biodiversity is essential for ecological stability and function, as well as to ensure food security. The current biodiversity crisis, however, is perpetuated by the use of pesticides in agriculture. “Evidence shows that pesticides are driving severe biodiversity declines, often acting in concert with additional stressors,” the researchers postulate. They continue: “Herbicides, particularly glyphosate, dicamba, and 2,4-D sprays, have caused significant damage to many non-target plant species… Milkweed, a plant essential to monarch butterflies, often suffers glyphosate drift from farm areas. The resulting decline in milkweed plants has been one of the contributing factors to declining monarch populations since this plant helps in the growth and development of caterpillar stages of life during its life cycle.” (See more on monarch butterfly declines here and how to help protect this species here.)

Pesticide drift greatly impacts insect diversity, contributing to the “insect apocalypse” that not only affects primary producers and pollinators but a wide range of other species throughout the food web. As the authors share: “Some field studies have observed that, as plant diversity declines due to herbicide drift, so does the diversity of herbivores and predators and results in less balanced and more often pest-prone ecosystems. Thus, even though herbicides, insecticides, and fungicides target different organisms, their combined effects across multiple trophic levels can result in overall ecosystem destabilization.”

Microorganisms within the soil are essential to many ecosystem functions, such as nutrient cycling, decomposition, and overall soil health. When soil biota are exposed to pesticides, particularly through spray drift and runoff, entire ecosystems can be threatened. “Spray drift is a primary pathway through which environmental microbes encounter pesticides,” the researchers say. “The effects of pesticides on microbial communities and their diversity include biomass reduction, growth disturbance, shifts in microbial community structure, and respiratory problems.”

Pesticide drift is also of great concern for bodies of water and the aquatic species within them. One study in California reveals that pesticide drift has polluted more than 10% of streams in several regions. (See more on the effects of pesticides on aquatic organisms here and here.)

The widespread occurrence of pesticide drift is of global concern. “Detectable levels of pesticides in pristine regions, such as remote parts of Brazil, illustrate how atmospheric transport can disseminate the chemicals long distances from their original site of application and therefore contaminate regions with little or no direct use of pesticides,” the authors state. Detected pesticides in these areas include herbicides, insecticides, and fungicides. This diversity underlines the complex mixture of chemicals present in the atmosphere throughout various regions.

Current risk assessments, particularly through the U.S. Environmental Protection Agency (EPA), fail to address the impacts of pesticides on ecosystem functions and biodiversity, especially concerning pesticide drift for nontarget organisms. The authors share: “Pesticide regulation is based, to a great extent, on the paradigm of ‘presumed safe until proven hazardous.’ That is, pesticides are generally approved for marketing based on available determinations of safety and only subsequently restricted or removed from the marketplace when evidence develops to show that they present significant risks. EPA, for instance, is mostly very reluctant to ban or put any limits on pesticides until substantial evidence of the damage caused can be presented.” (See more on EPA failures to protect the environment and public health here, here, here, here, here, and here.) The agency has ignored studies going back decades in making exposure calculations in the registration of pesticides, whether it is direct pesticide drift or pesticides carried in fog.

“New research has shown that even when new evidence showed a risk in its use, including crop damage and health effects, the EPA has allowed the continued use of pesticides known for their environmental and health hazards, such as dicamba,” the researchers note. “Regulations must be able to better protect ecosystems and human health by requiring consideration of long-term effects before the wide acceptance of pesticides.”

Not only would more accurate risk assessments more fully characterize the cumulative impacts of pesticide drift for all potentially impacted species, but holistic solutions, if implemented, would better protect health and the environment. As the authors state, “[O]rganic agriculture completely prohibits the use of pesticides, it can be considered one solution to reducing the problems of pesticide drift.” To preserve biodiversity for future generations and to support agricultural systems that we depend on for food security, organic land management is an available, economically viable, and profitable option, which is also climate-friendly.

Organic as a solution ensures that soil health is prioritized and that the health of all organisms is protected. Learn more about the benefits of organic agriculture here and here, and take action to have your voice heard on governmental actions that are harmful to the environment and public and worker health, increase overall pesticide use, or undermine the advancement of organic, sustainable, and regenerative practices and policies.

Sign up here to receive our Action of the Week and Weekly News Updates delivered right to your inbox and stay informed with the Daily News Blog!

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

Source:

Albaseer, S. et al. (2024) Beyond the field: How pesticide drift endangers biodiversity, Environmental Pollution. Available at: https://www.sciencedirect.com/science/article/pii/S0269749124022437.

(Beyond Pesticides, January 2, 2025) Adding to the body of scientific literature on the fast escalating antibiotic resistance crisis is a study published by Chinese scientists in Environmental Science & Technology, which shows that antibiotic resistance genes (ARGs) in soils move up through trophic levels via predation. Gut microbiomes of soil fauna have been found to be reservoirs of ARGs. How this process operates in soils is vital, because what happens in soil microbes does not stay there. If bacteria altered in soils move up trophic levels, ARGs may strengthen the multicellular agricultural pests the industry is trying to kill—insects, fungi, plants—not to mention bringing their libraries of resistant genes into the microbiomes of vertebrates, including humans.

Antibiotic resistance is a natural phenomenon, but human activity has greatly increased its presence in ecosystems the world over, including in one of the ecological niches of greatest concern to the future of food and human health: soils. Soils are complexes of mineral and organic substrates populated by billions of microorganisms and tiny animals. They are rapidly being degraded by conventional agriculture, forestry, and land management practices generally—more than a third of the world’s agricultural land has already been severely damaged by pesticides, fertilizers, water depletion, and loss of biodiversity.

As Beyond Pesticides reported last May, pesticides alter the microbial species composition in agricultural soils. A Russian study found microbial taxa known for high antibiotic resistance in fields treated with pesticides. Other research covered by Beyond Pesticides has demonstrated that the resistance develops in the fields. Bacteria have numerous ways of defending themselves that can apply to both pesticides and antibiotics. For example, microbes like Salmonella and E. coli react to glyphosate, dicamba and 2,4-D with a non-specific defense mechanism that enhances their resistance to antibiotics. In fact, antibiotics may be viewed simply as pesticides aimed at microbes rather than fungi, insects, weeds or other pests.

An enormous amount of DNA is available to microbes in their environments, and genes have multiple ways to migrate from one organism to another, either in single-gene units or through mobile genetic elements that provide both genes and the adjunct equipment to function inside a cell. The packet of genes in a bacterium that confers antibiotic resistance is known as the resistome. But little is known about how genes may move through trophic levels from primary producers like bacteria and algae to higher predators.

The current study used a “model food chain” common in soils and frequently used in ecotoxicity studies consisting of Folsomia candida, a very small insect popularly called a springtail, and one of its most common predators, the mite Hypoaspis aculeifer.

The researchers exposed a group of springtails to zinc thiazole, an antibacterial and antifungal chemical, and included a control group of springtails with no exposure. Zinc thiazole has been used in China since the early 2010s, especially against rice pathogens. It is a wide-spectrum treatment and is considered to be of low toxicity, but recently evidence has emerged that it disrupts the thyroid gland. It does not appear to be registered by the U.S. Environmental Protection Agency (EPA) for use in the U.S.

The researchers allowed one group of mites to prey on zinc-thiazole-exposed springtails and another group of mites to prey on unexposed springtails. No mites were directly exposed to the pesticide. Thus, they had two trophic webs, one with pesticide exposure and one without. The researchers then analyzed the gut microbiota of all groups to see if ARGs in the springtails transferred to the mites. They did.

The balance among various microbial species was altered both in the treated springtails versus their control group, and in the mites that ate pesticide-treated springtails compared to the control mites. The mites that preyed on the exposed springtails had different ARGS than those of the control mites, and the treated springtails and their predators shared more ARGs than control springtails and their predators did. This indicated that transfer to the mites from the treated springtails had occurred, showing that pesticide-induced antibiotic resistance can travel not simply among microbes at the same trophic level but up levels via predation.

“The altered and expanded resistomes [resistant genes] of predators suggest that the transmission of ARGs through the soil food chain contributes to resistance spread to higher trophic levels, and our research indicates that this process is amplified under pesticide pressure,” the authors write. “Thus, resistomes may further transfer into higher trophic levels in the food web along with predation and may spread to diverse ecosystems accompanied by invertebrate behavior or activities.”

Antibiotic resistance is a natural feature of the biosphere because life forms have been attacking and surviving attacks for billions of years. Resistance is transparently Darwinian, whether the struggle has evolved naturally or through human activity—something the pesticide industry has willfully failed to accept since its inception. The pesticide industry’s business model markets toxic substances it knows will generate organism resistance to its chemical and then develop another often more toxic substance, or cocktail of substances, to attack the resistant organism—creating what has been called the pesticide treadmill.

Bacteria are ubiquitous; everything more complex than a microbe has a microbiome, and the current study shows that genes can easily microbiome-hop. The transfer of various resistance mechanisms through microbiomes at different trophic levels is one more consequence of conventional agriculture’s perverse attachment to a delusional idea.

The study result has obvious implications for pesticide usage, because resistance to such chemicals is likely spreading from the lower trophic webs into the microbiomes of organisms like moths and beetles and fungi that attack food crops. Pesticides and antibiotics are altering the structure of entire ecosystems. Their use creates a feedback loop of disaster. It is clear by now that the harmful microbes, like the larger agricultural pests, cannot be completely controlled by pesticides and antibiotics, and the attempt is doing more harm than good over the long term. The insistence that industrial practices can dominate one of the most fundamental of the processes that have created the biosphere—natural selection—is a flawed and dangerous assumption that must change without delay, according to healthy ecosystem advocates.

Organic agriculture supports the biodiversity of soils and preserves the qualities that make them fertile in the first place. See Beyond Pesticides’ 2023 report, Pesticides and You – Beyond Pesticides: Protecting Health and the Environment with Science, Policy, and Action, for a roadmap to transformative change supported by reliable scientific evidence.

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

Sources:

Increased Transmission of Antibiotic Resistance Occurs in a Soil Food Chain under Pesticide Stress
Liu et al.
Ecotoxicology and Public Health December 8, 2024
https://pubs.acs.org/doi/epdf/10.1021/acs.est.4c07822?ref=article_openPDF

Thyroid-disrupting effects and mechanism of thiazole-Zn-induced thyroid cell hypertrophy and hyperplasia in male Sprague-Dawley rats
Honglian et al.
Ecotoxicology and Environmental Safety
Volume 196, 15 June 2020
https://www.sciencedirect.com/science/article/abs/pii/S0147651320303833

FDA Cites Resistance to Medically Important Antimicrobials as Critical Health Issue
Beyond Pesticides, January 11, 2024
https://beyondpesticides.org/dailynewsblog/2024/01/fda-cites-antimicrobial-resistance-as-critical-health-issue/

Glyphosate Induces Antibiotic Resistance in Deadly Hospital-Acquired Infection
Beyond Pesticides, November 8, 2022
https://beyondpesticides.org/dailynewsblog/2022/11/glyphosate-induces-antibiotic-resistance-in-deadly-hospital-acquired-infection/

Antibiotic-Resistance Genes Rise with Pesticide Application, as Study Adds to a Plethora of Findings
Beyond Pesticides, May 29, 2024
https://beyondpesticides.org/dailynewsblog/2024/05/antibiotic-resistance-genes-rise-with-pesticide-application-as-study-adds-to-a-plethora-of-findings/

Widely Used Insecticide Imidacloprid Negatively Impacts Soil Communities, Study Finds
Beyond Pesticides, December 10, 2024
https://beyondpesticides.org/dailynewsblog/category/biodiversity/soil-microbiome/

Pesticides and You Beyond Pesticides: Protecting Health and the Environment with Science, Policy, and Action
Volume 42, Numbers 1–4 & Volume 43, Number 1, 2023
https://www.beyondpesticides.org/assets/media/documents/BP-TransformativeChange.2022.23.pdf

(Beyond Pesticides, December 24, 2024 – January 1, 2025) We wish you a healthy and happy holiday season! The health and environmental challenges that we face as families and communities across the nation and worldwide require us to stay engaged. The stark reality of the challenges ahead energizes us at Beyond Pesticides to strengthen our program—now, more than ever!  

And, we trust that you, like us, want to push forward for a livable future. In this context, please see our annual report and summary on the important work that we are doing, and please consider a contribution to Beyond Pesticides during this holiday season. 

While the threats of health, biodiversity, and climate crises grow exponentially, the solutions we have advocated for decades are now within reach. We know how to produce food and manage land without petrochemical pesticides and fertilizers, as organic food is widely available. Beautiful parks, playing fields, and schoolyards do not require toxic chemical use. At the same time, the regulatory system underperforms, as existential health and environmental problems escalate.  

And, we know that individual steps that we take to stay healthy, as important as they are, cannot protect us and the natural world, on which we depend, from involuntary petrochemical exposure through ongoing contamination of land, air, and water. The science is telling us that we can no longer tinker with chemical reduction strategies that fall short of protecting our health, biodiversity, and climate. 

Your support enables us to move forward with our bold program. 

A strategy for curtailing threats to health, biodiversity, and health 
Beyond Pesticides shares the vision of people and communities that are striving to ensure a future that protects health and sustains life. We are facing existential crises—the climate crisis, biodiversity collapse, and severe public health threats—from cancer to neurological, reproductive, and endocrine system effects, including brain and behavioral impacts. To reverse these threats —which we can do— we advance model organic solutions that eliminate billions of pounds of fossil fuel-based pesticides and synthetic fertilizers and nurture biological systems that take dangerous pollutants out of our environment, protecting health and the ecosystems that sustain life.    

To meet the existential health, biodiversity, and climate crises, we provide real-time support to people and organizations, from local to global, with up-to-date scientific findings, policy critiques, and timely initiatives, empowering strategic action with knowledge on:  

• The current and looming threats to human health and ecosystems and the dire consequences of inaction or measures that fall far short of what is necessary; and 

• The path forward to eliminate the use of petrochemical-based pesticides and fertilizers, including the constellation of toxic materials used in food production and the management of homes, gardens, parks, playing fields, and schools.  

Over this past year, the urgency of our work has never been more palpable. Our daily collaboration with communities across the country—via the Parks for a Sustainable Future program—to adopt organic land management policies and practices in public spaces (parks, playing fields, and schoolyards) defined the path forward as a model to eliminate toxic pesticides and fertilizers, protect children, pets, and families, and sustain local ecosystems.  

Our programs bridge policy and practice—reframing strategies that go after an endless list of toxic chemicals—and advancing a holistic approach that recognizes complex biological communities, the importance of soil microbiota, and ecosystem services in the context of broader human health and environmental protection. By developing organic systems plans and training parks and public works departments on organic-compatible practices and products, we engage in a systems approach that works with soil biology, enriches nutrient cycling, and cultivates more resilient landscapes that meet community expectations while delivering long-term cost savings.  

It is imperative that, as we focus national attention on meaningful systemic change, we simultaneously address the disproportionate risk to people of color communities and workers, from landscapers to farmworkers. Disproportionate harm to people of color from toxic petrochemicals is a continuing crisis and can only be solved when we transition away from dependency on them and use stops. The manufacture of petrochemical fertilizers and pesticides also creates a major environmental injustice for predominantly Black and Brown communities where production facilities are often located. 

We start with the science—calling for the urgent need to act  

With science made accessible to nonscientists, we empower people to advocate effectively with decision makers, elected officials, and all those responsible for directing or managing the choice of practices and products. Our Daily News, published on our website, focuses on the compelling scientific justification for eliminating pesticides. Our journal, Pesticides and You, provides a compendium of scientific research as a breathtaking warning from the science community that our laws are not adequately protective and the shift to organic is urgently needed. Our recent issue, Meeting the Existential Challenges: Empowering Action for Change with Science, shows the preponderance of science. 

With our daily monitoring, we maintain robust scientific databases that offer tools to empower local activists and more to take action in their communities, schools, workplaces, and homes as “tools for change”—including our Gateway on Pesticide Hazards and Safe Pest Management, Eating with a Conscience (on ecological and worker effects), What the Science Shows (pollinators), Pesticide-Induced Diseases Database, and ManageSafe™ (how to manage homes and gardens without pesticides). 

Elevating our voice and networking for change—taking a stand! 

In the face of the chemical industry and related service providers wielding tremendous power across all levels of government, and agencies not keeping pace with the escalating environmental and public health challenges, it is the communities and their elected officials that have chosen to actively engage in democratic decision making to protect the health of their residents. 

We advance systemic change, advocating policies and practices to change the underlying conditions associated with land management that contribute to the existential public health, biodiversity, or climate crises. In this context, we issue an Action of the Week throughout the year that targets opportunities to integrate this thinking into the public policy debate at the local, state, national, and international level. While we comment on specific chemicals and actions before regulatory agencies, we characterize them as poster children for what is wrong with toxic pesticide and fertilizer dependency. In these actions, we point to the unreasonableness of the harm that is being allowed by policy and regulatory decisions, given the availability of organic alternatives.   

Having worked with organic systems since our founding in 1981, we also know that this change can be achieved. We continue—through campaigns such as Keeping Organic Strong—to push for the growth of organic agriculture as the only acceptable and foundational form of land management for the future.     

Our work is multidimensional and collaborative— building on our organizational history!  

When Beyond Pesticides was founded in 1981, we knew that we needed to forge a new path that rejected the reliance on petrochemical pesticides and fertilizers, while the laws protected the chemical industry more than people, workers, and environment. With stronger government and chemical and allied industry alliances on the horizon, our community-based campaigns to transition to organic land management are critically important.  

We call out compromises that are unacceptable, given the existential crises. Several weeks ago, EPA announced that it would allow the continued use of the highly neurotoxic insecticide chlorpyrifos on crops that are among the most extensively grown and used in the world—soybeans, wheat, cotton, citrus, sugar beets, and numerous fruits and vegetables. EPA described the canceled uses as a victory. However, here is our response to the media: The compromises associated with petrochemical use and the public’s health are unconscionable given the availability of cost-effective and productive alternatives. . . With decisions like this in the aggregate, the toxic load on people and the environment is unsustainable.   

Forging a Path Toward a Livable Future, Together! 

Despite the challenges, we draw optimism from our community-based work, showing the path forward. We ask you to support us in expanding our grassroots work and voice, which speaks through our hands-on experience to build a sustainable future that eliminates the use of toxic pesticides and fertilizers. When the chemical industry and its allies in elective office seek to undermine public health and environmental protection, we push back with the same empowered grassroots network, calling out unacceptable harm, given the viability of the organic alternative for the common good. 

Our team at Beyond Pesticides looks forward to continuing to partner with you in the new year to meet the existential environmental and public health challenges with truly organic solutions through policy, science, and action—one day at a time for ourselves and for future generations! 

For more information and to discover actions that have defended democratic decision making to adopt organic land management on public land, informed action, and meet the challenges of 2025, please click on the image above or the link to access the Year in Review page for 2024. 

It’s a fact. Your support makes our work possible. 

A special thank you to all our donors and supporters this year. Without your engagement and incredible generosity, it would not be possible to lead the transition to a world free of toxic pesticides. Our team provides up-to-date information about the health and environmental hazards of pesticides, pesticide regulation and policy, holistic nontoxic management systems, and cutting-edge science—free of charge to the public. This program is not possible without the generosity of people like you!   

Thank you for considering support for Beyond Pesticides this year! Please mail your tax-deductible donation to our office or donate securely on our website! 

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

(Beyond Pesticides, December 23, 2024) As the U.S. Fish and Wildlife Services (FWS) proposes to list the Monarch butterfly as a threatened species under the Endangered Species Act, a look at the factors contributing to the butterfly’s catastrophic decline includes a stunning failure of the U.S. Environmental Protection Agency’s (EPA) regulation of pesticides to protect biodiversity and the ecosystems necessary to its survival. While there are many factors affecting the survival of Monarchs, EPA’s Office of Pesticide Programs (OPP) has allowed pesticide use to continue unabated, with only rhetorical attention to the problem. Meanwhile, the science shows a range of pesticide effects associated with insecticides and herbicides. A study published in PLOS One in June identifies insecticides as the primary driver in butterfly’s decline, as EPA points, almost exclusively to herbicide use and the destruction of Monarchs’ food source, milkweed habitat. While two or several factors can be true at the same time, EPA has failed to consider the confluence of factors, including the impacts of climate, as rising temperatures are exacerbated by the production and use of petrochemical pesticides.

FWS is stepping in at a critical time with looming biodiversity collapse and in the absence of EPA taking the reins to eliminate pesticides that are threatening the existence of Monarchs. Populations of both Eastern and Western monarch butterflies have been decreasing in recent years, leading environmentalists to clamor for an “endangered” classification for the species. Declining monarch populations are symptomatic of the ongoing insect apocalypse, which threatens worldwide ecology and agriculture—and exemplifies the failure of the EPA, including OPP, to regulate with a holistic lens that protects biodiversity.  

EPA’s narrative on Monarchs is symptomatic of a program that is focused on some factors in isolation of the full range of critical elements associated with all the pesticides it registers in combination. In addition, rather than leading with its mandate to focus on pesticides in the protection of Monarchs, the agency appears to be deflecting on the issue by posting on its website issues other than pesticides that are affecting Monarchs’ survival.

On its Monarch page, OPP highlights “loss of breeding habitat, loss of overwintering habitat in Mexico (where the butterflies spend their winters), changes in weather patterns (including winter storms), and other factors.” The agency Incudes reference to an article that, while mentioning pesticides, stresses migratory challenges as the cause of decline. Then, the agency continues with a focus on herbicides as the problem, stating the following: “EPA believes that a holistic approach is needed for monarch conservation that includes judicious use of herbicides, balancing weed management needs with monarch conservation needs, and focusing on ways to support monarch conservation through pesticide registration review, registration and stakeholder outreach and education.” The webpage then links to a 2015 risk management document that further focuses on herbicides to the exclusion of insecticides and other pesticides. On its Action to Protect Pollinators page, EPA refers back to its 2015 document and is locked into the assumption that, despite the harm it causes, there must be continued reliance on genetically engineered herbicide-tolerant crops that are dependent on widespread herbicide use as well as other production and land management practices that rely on herbicides. The agency does not consider organic management systems in its analysis, despite its commercial and cost-effective efficacy and productivity in the market.

Although many factors are involved in the devastation of insect populations, scientific studies show that pesticide use ranks high, led by the use of seeds coated with neonicotinoid insecticides. Other pesticide impacts include mortality from insecticide drift and the destruction of milkweed by herbicides. These impacts are exacerbated by climate change, which is made worse by the production and use of petrochemical pesticides and fertilizers. 

Monarch butterflies serve as an indicator of the status of insect pollinators and their habitats. Because so many people have been involved in monitoring their populations, the U.S. Fish and Wildlife Service (FWS) has responded to the call to protect them by proposing to list monarchs as a threatened species and designate critical habitat under the Endangered Species Act (ESA). Plants or animals can be listed as either “threatened” or “endangered.” When a species is listed, it can help provide resources and even legal action to protect them. FWS explains the terms: an endangered species is a plant or animal species “that is in danger of extinction throughout all or a significant portion of its range,” and a threatened species is one “that is likely to become endangered in the foreseeable future throughout all or a significant portion of its range.” 

In 2022, the International Union for Conservation of Nature (IUCN) classified the monarch butterfly as endangered and updated the classification to vulnerable a year later. Although the IUCN listing has no legal weight in the United States, it calls attention to the plight of the butterfly, which according to IUCN 2022 estimates, showed that the eastern population of migratory monarchs declined by as much as 84 percent between 1996 and 2014 and the western migratory monarch’s population dropped from around 10 million insects in the 1980s to 1,914 in 2021—a loss of about 99.9 percent.

The proposed listing will provide increased federal protection and resources for monarch conservation, in the form of protection from harm, a comprehensive recovery plan, and ongoing funding to restore their habitat. ESA prohibits the “take” of a single individual of a listed species. “Take” is defined in ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct.” The likely “take,” which includes unintentional harm or death, of even one individual of a listed species, is enough to constitute a “may affect” determination under EPA’s policy and trigger the need for formal consultation with FWS. Hence, the proposed designation has the potential to prohibit pesticide use that harms not only monarchs but other pollinators as well. 

Tell the U.S. Fish and Wildlife Service to finalize its proposed listing of monarchs as threatened.

Comment to the U.S. Fish and Wildlife Service
I am very concerned about the impact of pesticide use on biodiversity—particularly in promoting the “insect apocalypse.” Populations of both Eastern and Western monarch butterflies have been decreasing in recent years, leading many to want an “endangered” classification for the species. Declining monarch populations are symptomatic of the ongoing insect apocalypse, which threatens worldwide ecology and agriculture. Although many factors are involved in the devastation of insect populations, scientific studies show that pesticide use ranks high, led by seeds coated with neonicotinoid insecticides. Other pesticide impacts include mortality from insecticide drift and the destruction of milkweed by herbicides. These impacts are exacerbated by climate change.

Monarch butterflies serve as an indicator of the status of insect pollinators and their habitats. I am happy to see the U.S. Fish and Wildlife Service (FWS) propose to protect them by listing monarchs as a threatened species and designating critical habitat under the Endangered Species Act (ESA). Plants or animals can be listed as either “threatened” or “endangered”. FWS explains the terms: an endangered species is a plant or animal species “that is in danger of extinction throughout all or a significant portion of its range,” and a threatened species is one “that is likely to become endangered in the foreseeable future throughout all or a significant portion of its range.” While it can be argued that monarchs should be listed as endangered, either listing will provide needed protection.

In 2022, the International Union for Conservation of Nature (IUCN) classified the monarch butterfly as endangered and updated the classification to vulnerable a year later. Although the IUCN listing has no legal weight in the United States, it calls attention to the plight of the butterfly, which according to IUCN 2022 estimates, showed that the eastern population of migratory monarchs declined by as much as 84 percent between 1996 and 2014 and the western migratory monarch’s population dropped from around 10 million insects in the 1980s to 1,914 in 2021—a loss of about 99.9 percent.

FWS’s proposed listing will provide increased federal protection and resources for monarch conservation, in the form of protection from harm and a comprehensive recovery plan and ongoing funding to restore their habitat. ESA prohibits the “take” of a single individual of a listed species. “Take” is defined in ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct.” The likely “take,” which includes unintentional harm or death, of even one individual of a listed species, is enough to constitute a “may affect” determination under EPA’s policy and trigger the need for formal consultation with FWS. Hence, the proposed designation has the potential to prohibit pesticide use that harms not only monarchs but other pollinators as well.

Please finalize the listing of monarch butterflies as threatened.

Thank you.

Image: Art Page submission from Carol Moyer, “Monarch Butterfly Sideways with Closed Wings.“

(Beyond Pesticides, December 20, 2024) On December 12, the U.S. Fish and Wildlife Service (FWS) opened a public comment period on its proposal to list the monarch butterfly (Danaus plexippus) as a threatened species and to designate critical habitats for the species under the Endangered Species Act of 1973. Under the proposal, the designated habitats would span approximately 4,395 acres throughout overwintering sites in coastal California. The public comment period will be open until March 12, 2025. These suggested protections call attention to the role of chemical-intensive agriculture in affecting populations of pollinators and other beneficial organisms.

George Kimbrell, legal director at the Center for Food Safety, shares in a press release that the “monarch listing decision is a landmark victory 10 years in the making. It is also a damning precedent, revealing the driving role of pesticides and industrial agriculture in the ongoing extinction crisis… But the job isn’t done: Monarchs still face an onslaught of pesticides. The Service must do what science and the law require and promptly finalize protection for monarchs.”

In the docket, FWS states, “Under the Act, a species warrants listing if it meets the definition of an endangered species (in danger of extinction throughout all or a significant portion of its range) or a threatened species (likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range). If we determine that a species warrants listing, we must list the species promptly and designate the species’ critical habitat to the maximum extent prudent and determinable.”

FWS continues, “We have determined that the monarch butterfly meets the Act’s definition of a threatened species; therefore, we are proposing to list it as such and proposing a designation of its critical habitat… We have determined that the monarch butterfly meets the definition of a threatened species due to the following threats: the ongoing impacts from loss and degradation of breeding, migratory, and overwintering habitat (from past conversion of grasslands and shrublands to agriculture and widespread use of herbicides; logging/thinning at overwintering sites in Mexico; urban development, senescence ( i.e., deterioration with age), and incompatible management of overwintering sites in California; and drought); exposure to insecticides; and effects of climate change.”

FWS plans to improve monarch populations include the need to “(1) achieve a significant increase in the availability of milkweed and nectar plants in monarch breeding and migratory areas; (2) protect and enhance overwintering habitat; (3) avoid and minimize impacts to monarchs and their habitat from insecticides and herbicides; and (4) maintain public support for the conservation of monarch butterflies.”

Additional regulatory conservation efforts were proposed in July of 2024 when the U.S. Environmental Protection Agency (EPA) released its Draft Insecticide Strategy, which proposes a framework meant to identify which agricultural uses of conventional insecticides impact listed species and how to determine mitigation measures for those insecticides. (See Beyond Pesticides’ comments here.) This strategy will be finalized by March 31, 2025, according to EPA, and will be applied to new insecticide registrations and for existing insecticide reevaluations. Other initiatives through EPA and FWS include the Vulnerable Species Action Plan, which identifies mitigation measures for listed species particularly vulnerable to pesticides, but despite these efforts, the U.S. often fails to take meaningful action. (See more here.)

According to an article in USA Today; “The final decision will be in the hands of the incoming Trump Administration. In 2020, during the first Trump administration, the Fish and Wildlife Service found that monarchs were threatened with extinction but did not list them because other species were more high-priority.” (See previous coverage here, here, and here) This new opportunity to add monarch butterflies to the threatened list, and to designate critical habitats for them, would be responsive to scientists and advocates who have long noted the devastating population declines.

According to FWS, the eastern migratory population of monarch butterflies is the largest and overwinters in the mountains of central Mexico, while the western migratory population primarily overwinters in California. According to the Service’s most recent species status assessment: “Today, the eastern migratory population is estimated to have declined by approximately 80%. The western migratory population has declined by more than 95% since the 1980s, putting the western populations at greater than 99% chance of extinction by 2080. During this same period, the probability of extinction for eastern monarchs ranges from 56 to 74%.”

As was reported in The Washington Post, finalizing the proposed rule would allow the monarch butterflies to “become one of the most widespread species ever protected under the 1973 law.” The Post continues: “The monarch is just one of the most visible species at risk of disappearing as an estimated 1 million plants and animals are threatened with extinction due to rising temperatures, shrinking habitat and other human-driven threats. The loss of pollinators such as butterflies could have profound effects on ecosystems and people who depend on them.”

Beyond Pesticides previously reported that the biodiversity crisis is one of multiple crises that are compounding one another. While human actions are contributing to an ongoing Holocene or sixth mass extinction, the globe is also facing crises in human disease and climate change. The Endangered Species Act focuses on the species and habitats most at risk of extinction. However, the statement of purpose also recognizes the importance of conserving the ecosystem on which they depend.

Preserving biodiversity is imperative for all life and starts by considering all the factors that contribute to the crisis in the first place. Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. (See previous coverage over the last 10+ years on how these threats impact monarch butterflies here, here, here, here, here, and here.)  

As reported by The New Lede: “Most pesticides registered for use in the US have not been rigorously tested for their impacts on insects other than honeybees, a single non-native species. Scientists and conservationists have argued for years that this system fails to protect pollinators and underestimates the toll of pesticides on these animals, which is especially relevant given the decline of many insect species worldwide.” (See Beyond Pesticides’ previous coverage on regulatory deficiencies for pollinators here, here, here, here, here, and here.)

To address these deficiencies, Earthjustice, on behalf of the Xerces Society, has petitioned EPA to require pesticide manufacturers to submit data that assesses impacts on more diverse insect pollinator species than just honeybees. In a recent article, Earthjustice shares: “We cannot ignore the risk of pesticides to the monarch and other native pollinator species. The decline of these invertebrate pollinators threatens all of us. To begin, human food systems, made possible by insect pollinators, are in trouble.”

Protecting monarch butterflies is a necessary decision rooted in science. These pollinators play a critical role in the ecosystem, and their extinction would have cascading negative impacts. As Tierra Curry, a senior scientist with the Center for Biological Diversity says in a press release: “The fact that a butterfly as widespread and beloved as the monarch is now the face of the extinction crisis is a tri-national distress signal warning us to take better care of the environment that we all share… What’s bad for monarchs is bad for humans, so we have to stop pretending that our health is somehow separate from that of the wildlife our activities are decimating.”

Within their press release, FWS’s director, Martha Williams, says: “The iconic monarch butterfly is cherished across North America, captivating children and adults throughout its fascinating lifecycle. Despite its fragility, it is remarkably resilient, like many things in nature when we just give them a chance… Science shows that the monarch needs that chance, and this proposed listing invites and builds on unprecedented public participation in shaping monarch conservation efforts. Providing monarchs with enough milkweed and nectar plants, even in small areas, can help put them on the road to recovery. Working together, we can help make this extraordinary species a legacy for our children and generations to come.” (See previous coverage on milkweed contamination from chemical-intensive agriculture here, here, and here.)

The elimination of petrochemical pesticides and synthetic fertilizers is the solution moving forward to help protect species, like the monarch butterfly, from population effects due to chemical exposure and climate change. In adopting organic land management practices, the harmful effects seen with conventional methods are mitigated and the health of the environment, including all organisms it supports, is prioritized.

The monarch as a species needs protection in the context of healthy biodiversity, which sustains life. Watch an eye-opening talk by internationally renowned researcher, professor, and author David Goulson, PhD, who in plain language draws together scientific research on the elements of nature, critical to the web of life that sustains the rich diversity needed for a healthy planet. See 2023 National Forum, Session 1.

Stay tuned for how you can take action to protect monarch butterflies through Beyond Pesticides’ Action of the Week and by submitting comments to FWS before the March 12 deadline.

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

Source:

Cervantes Jr., F. and Weise, E. (2024) Is the stunning monarch butterfly endangered? New proposal could change its status., USA Today. Available at: https://www.usatoday.com/story/news/nation/2024/12/10/monarch-butterfly-threatened-endangered-species/76898149007/.

Clark, M. (2024) Fish and Wildlife Service Proposes Endangered Species Act Protection for Monarch Butterfly; Urges Increased Public Engagement to Help Save the Species, U.S. Fish & Wildlife Service. Available at: https://www.fws.gov/press-release/2024-12/monarch-butterfly-proposed-endangered-species-act-protection.

Curry, T. and Kimbrell, G. (2024) Monarchs Proposed for Endangered Species Act Protection, Center for Biological Diversity. Available at: https://biologicaldiversity.org/w/news/press-releases/monarchs-proposed-for-endangered-species-act-protection-2024-12-10/.

Fish and Wildlife Service (2024) Endangered and Threatened Species: Species Status with Section 4(d) Rule for Monarch Butterfly and Designation of Critical Habitat, Regulations.gov. Available at: https://www.regulations.gov/document/FWS-R3-ES-2024-0137-0001.

Grandoni, D. (2024) U.S. moves to add monarch butterfly to the Endangered Species List, The Washington Post. Available at: https://www.washingtonpost.com/climate-environment/2024/12/10/monarch-butterfly-endangered-species-list/.

Main, D. (2024) EPA must tighten pesticide rules to protect pollinators like bees and butterflies, petition argues, The New Lede. Available at: https://www.thenewlede.org/2024/12/epa-must-tighten-pesticide-rules-pollinators-petition/.

Morrison, S. and Malfi, R. (2024) The Monarch Has Been Proposed for the Endangered Species List. It Still Needs Better Protections From Pesticides., Earthjustice. Available at: https://earthjustice.org/experts/sharmeen-morrison/the-monarch-has-been-proposed-for-the-endangered-species-list-it-still-needs-better-protections-from-pesticides.

(Beyond Pesticides, December 19, 2024) As The New York Times reported last month, the government in South Africa declared a national emergency—23 children died and nearly 900 people were sickened from pesticide poisoning in Johannesburg’s Soweto township. The illnesses and fatalities have been traced to small amounts of highly neurotoxic pesticides, including the insecticides terbufos and aldicarb, found in local food items. These chemicals, described by South African President Cyril Ramaphosa as “street pesticides,” are being increasingly used (legally and illegally) for pest infestations in the townships and informal settlements of South Africa’s poorest communities, where poverty and inadequate waste collection exacerbates the pest management challenges. Without formal electricity, running water, or municipal garbage collection, many residents rely on highly toxic pesticides for pest infestations in their homes and makeshift markets, resulting in food inadvertently being contaminated with pesticides. 

The announcement highlights the dangers of allowing these highly toxic agricultural chemicals to be used in farming, with tragic consequences for vulnerable communities when they are diverted for use in urban settings. This tragic situation also draws attention to the elevated threat that pesticides pose when stringent enforcement mechanisms are not in place to ensure compliance with pesticide restrictions, even with the recognition that restrictions themselves are not necessarily adequate to protect the public’s health. Despite government plans to regulate small, informal stores known as “spaza shops,” advocates argue that, in addition to addressing the vestiges of apartheid, systemic poverty, and inhumane living conditions in informal settlements, the South African government should ban toxic pesticides in agriculture to “get hazardous pesticides off the street.” [The government announced immediate plans to inspect all registered South African terbufos manufacturers to ensure that practices are in place to prevent the diversion of farm pesticides to nonagricultural markets. Regulations on the traceability, repackaging, disposal, and sale of pesticides, insecticides, and food products will be reviewed. Additionally, the Department of Agriculture “… is in the process of reviewing and updating all relevant legislation with respect to the regulation and authorisation of agricultural pesticides for use in South Africa.”] 

As reported, at least 23 children died as of the end of November, including six young children in an incident of eating contaminated snacks in Naledi, Soweto. South Africa’s National Institute for Communicable Diseases investigated this incident and attributed the deaths to traces of terbufos identified in a snack.  The organophosphate terbufos can be lethal if ingested, inhaled, or through contact with skin, and, as President Ramaphosa wrote the following in his November 15 address to the country: “Even as our investigations are ongoing, it is critical to understand that this is not a problem confined to spaza shops and other informal traders. The unregulated use of restricted pesticides in communities has become a growing problem, with devastating consequences… In many townships, another chemical, aldicarb, and an organophosphate known as Galephirimi, are commonly sold by street vendors and hawkers to control rat infestations. Aldicarb has been banned for use in South Africa since 2016.” However, public health advocates argue that the government’s position does not go far enough (see here, here, and here).  

In South Africa, tens of thousands of farmworkers are put at risk annually when they are exposed to highly toxic pesticides, including the carbamate insecticide aldicarb, often without proper personal protective equipment. In response, a partnership between Women on Farms Project and Oxfam (in South Africa and Germany) launched a “Double Standards Pesticides” campaign in 2019 to pressure the government of South Africa to ban 67 pesticides already banned in the European Union. As Beyond Pesticides has previously reported, the Women on Farms Project has organized protests in South Africa to demand an end to the indiscriminate importation and use of these insecticides, herbicides, and fungicides. More recently, over 150 farmworkers, primarily women, marched to the German Consulate-General to demand an end to the country’s exportation of pesticides that the country has determined are too dangerous for their own domestic use (see here and here). The South African protesters have called attention to what they describe as the hypocritical practices of European and U.S. agrochemical companies, which sell products in developing countries deemed unsafe for use in their own regions. Farmworkers have voiced their health concerns linked to petrochemical exposure, chanting, “We’re dying of asthma, we’re dying of cancer, we’re dying of heart attacks.”  

Despite these efforts, including the march to the German Consulate-General and another at the South African headquarters of Bayer—the German corporation responsible for producing and exporting these agrochemicals—there has yet to be any significant change to these harmful practices. Bayer’s updated website highlights products such as the fungicide Antracol 70 WP (Propineb) and insecticides Biscaya 240 OD (Thiacloprid), Confidor (Imidacloprid), and Gaucho (Imidacloprid)—all of which are banned in the European Union (EU) but remain available for purchase in South Africa. These chemicals, in addition to product mixtures containing the weed killer paraquat and terbufos, are commonly employed in the region. The blatant sales of EU-prohibited and U.S.-banned substances in the Global South underscores that the ratification of international agreements (most of which the U.S. has not ratified) can sometimes be more symbolic than impactful. Without a global regulatory framework to manage such pesticides’ transport, storage, and use, these practices foster international dependency on hazardous chemicals in agriculture.  

Beyond Pesticides, in alignment with public health and environmental advocates, argues that the regulation of petrochemical pesticides, even a global framework, will not provide a solution that addresses the enormous scope of the harm pesticides cause. The sale of pesticides deemed so hazardous they are banned in wealthier, predominantly Western countries represents a double standard that reflects a “lower value on lives and ecosystems in poorer nations.”  

Many of the systemic injustices observed in South Africa parallel the challenges faced in the U.S. agricultural sector, like in California’s Central Valley and Florida’s citrus groves, where farmworkers face some of the lowest wages and harshest conditions, including exposure to toxic pesticides (see examples here, here, and here, including aldicarb use in citrus crops). These practices perpetuate environmental racism in agricultural work, with pesticide exposure, drift, and tainted water supplies compounding health risks for farmworkers and those residing in farming-intensive regions.  

For more information on environmental racism in South Africa, see the talk of Marcos Orellana, PhD (See 2023 Forum, session 2), the United Nations Special Rapporteur on toxics and human rights. Dr. Orellana, an expert in international law and the law on human rights and the environment, issued UN reports in South Africa and Australia, capturing the significance of his work for environmental justice. Dr. Orellana teaches at the American University Washington College of Law. Dr. Orellana said, “The term ‘environmental racism’ describes institutionalized discrimination based on race or colour. In pre-1994 South Africa, the distribution of environmental risks and harms disproportionately and often deliberately targeted low-income groups and along racial lines. Today, despite the efforts by Government in setting up institutions and laws to address this legacy of environmental racism, pervasive air, water, and chemical pollution still imposes a heavy toll, especially on disadvantaged communities. Overcoming it will require significant additional efforts, including structural, legislative, economic, and environmental changes.”  

Pesticide exports from U.S. manufacturers also contribute to the dangerous global impact of these toxic chemicals. As Beyond Pesticides reported, a 2024 Brookings study by Nathan Donley, PhD, and Robert Bullard, PhD found that between 2015 and 2019, the U.S. exported unapproved pesticides containing neurotoxic organophosphates and carbamates to 42 nations. Notably, 81% of these recipient countries were low-to-middle-income nations, and 78% were estimated to experience pesticide poisoning among more than 30% of their agricultural workforce each year. The 2015 documentary Circle of Poison—featuring Beyond Pesticides’ executive director Jay Feldman and luminaries including Vandana Shiva, Noam Chomsky, and President Jimmy Carter—also focuses on the toxic pesticide export issue. It documents the power of the global pesticide industry in shaping regulations (or lack thereof) and the dependency on petrochemical pesticides in food and farming around the world. 

[The need to halt such exports stems from the concept of the “circle of poison,” where banned pesticides are exported, used abroad, and returned as residues on imported foods, contaminating domestic food supplies. These practices perpetuate environmental injustice, disproportionately affecting populations in developing nations and marginalized communities globally, including BIPOC (Black, Indigenous, and People of Color) populations in the U.S., who already face higher levels of pesticide exposure.]  

Banned pesticides, often referred to as “legacy chemicals,” continue to harm agricultural workers decades later. Substances like DDT, DBCP, and PFAS—long banned or restricted—still affect human health and ecosystems today. This is not merely a historical issue but an ongoing crisis, as new toxic chemicals are introduced, used, and exported, with their full impacts often emerging years later (see here and here). The seemingly intractable problem of toxic pesticide exports remains unabated as the vested economic interests in the petroleum and chemical industry keep their grip on the chemical-intensive agriculture pesticide treadmill.  

To address this challenge, Beyond Pesticides urgently calls for global collaboration to reframe the public debate and advocacy towards holistic systems change via support for organic land management. Global or national regulatory structures continue to fail to adequately protect human life and health, or the environment, and the price is too high to trust laws or enforcement can overcome industrial agriculture, pesticide and petrochemical industries, and their profit motive. A holistic solution that eliminates reliance on synthetic fertilizers and pesticides exists and U.S. organic certification and underlying principles serve as a model for a global shift in agriculture that prioritizes soil health, biodiversity, and the elimination of toxic chemicals.  

The tragic and unnecessary deaths of twenty-three children in South Africa from pesticide exposure are a stark reminder of the urgent need for change. While it is too late to reverse the clock for those who have already suffered, decisive action can prevent future harm. American readers can call on legislators and regulatory agencies, particularly EPA, to end the export of pesticides banned or deregistered domestically. 

 Advocate for the elimination of hazardous chemicals by urging U.S. senators to ratify the Stockholm Convention and require EPA to classify persistent toxic petrochemical pesticides as unreasonable environmental risks as aligned with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Visit Beyond Pesticides’ Agricultural Justice webpage to learn more!  

As 2024 draws to a close, our team welcomes you to raise your voice and join us in forging a path to a livable future! For more information on Beyond Pesticides’ programs, please the newly-released Annual Report featured on our website! 

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

Feature image: View from Kliptown Youth Program Centre in Kliptown, Soweto, South Africa. Secondary image: Soweto, Johannesburg, South Africa. Photos by Beyond Pesticides’ Community Policy and Action Manager, Rika Gopinath.

Sources:   

In South Africa, Food Poisoning Kills at Least 23 Children, The New York Times, November 23, 2024 

Exported Toxicity: The EU’s Banned Pesticides in South Africa, Women on Farms Project, editor, solidar.org, February 2024 

Government’s toxic malaise causes poisonings, not spaza shops, The Mail & Guardian, November 7, 2024  

Bayer’s Use of EU-Forbidden Pesticides Ignites Protest in South Africa, Beyond Pesticides Daily News, September 19, 2023 

Child and adolescent mortality associated with pesticide toxicity in Cape Town, South Africa, 2010–2019: a retrospective case review, BMC Public Health, April 2023  

U.S. Exportation of Banned and Highly Restricted Pesticides Continues to Inflict Serious Harm Beyond Pesticides Daily News, August 5, 2022 

Where Do Pesticides Banned in Europe Go? Mostly to Poorer Countries, While Two-Thirds of Those Sent to Richer Countries Head for the U.S., Beyond Pesticides Daily News, September 25, 2020 

(Beyond Pesticides, December 18, 2024) A bombshell investigation conducted by Canada’s National Observer finds that Bayer, which acquired the Monsanto chemical company in 2018, colluded with environmental and public health regulators in Canada to obstruct a proposed neonicotinoid insecticide ban originally introduced in 2018. Advocates were stunned back in 2021 when Canada’s Pest Management Regulatory Agency (PMRA)—the Canadian counterpart to the U.S. Environmental Protection Agency (EPA)—reversed its decision to phase out imidacloprid, clothianidin, and thiamethoxam by 2023.

The weaponization of scientific institutions and regulatory processes is commonplace in the U.S. context, with U.S. Right to Know publishing a report earlier this year on the corrupting impact of pesticide manufacturers at the Entomological Society of America 2023 annual meeting. (See Daily News here.) There are numerous Office of Inspector General (OIG) reports signaling EPA corruption and failures, including persisting industry influence in the cancer risk assessment process, inadequate leadership in addressing community harms of a former creosote-treated wood preservative plant turned Superfund site in Pensacola, Florida, and failure to protect the public from endocrine-disrupting chemicals, to name several examples.

In a recent press release, the David Suzuki Foundation, alongside numerous medical, legal, and civil society organizations, is calling on Health Canada to engage in an independent review to correct for agency corruption and industry influence.

The capitulation of regulatory agencies to industry-funded studies and science undermines public trust in environmental and public health institutions at a time when robust action is necessary to preserve public health, biodiversity, and climate resilience.

Weaponizing Science, Undermining Regulation

Christy Morrissey, PhD, a professor at the University of Saskatchewan specializing in various disciplines including avian ecotoxicology, was shocked by PMRA’s reversal, considering her research on pesticide drift in prairielands and wetlands was cited in Health Canada’s 2016 announcement and in the proposal to ban imidacloprid, the most widely used of the synthetic neonicotinoid insecticides. According to the report, “[T]he professor and freshwater ecologist shared unpublished water sampling data she had collected from wetlands in Saskatchewan farmland with the federal pesticide regulator. The data complemented her published studies on neonic contamination, which the PMRA also reviewed.” (See her published research here and here.)

Federal officials with the PMRA, Environment and Climate Change Canada, and Agriculture and Agri-Food Canada shared Dr. Morrissey’s unpublished data with industry representatives, including Bayer officials. According to the investigative report, industry representatives and regulators met for hours through a “multi-stakeholder forum” just one month after the proposed ban was made public in November 2016 to discuss ways to prevent it from moving forward. Released meeting minutes depict a “collegial” tone that is “deferential to industry and aimed at preserving neonic use.” One official commented that it was not the government’s objective to “take away products from agriculture.”

To the dismay of Dr. Morrissey, federal officials at PMRA shared her unpublished data from 2014 with Bayer despite an understanding that the pesticide regulatory body would not share the data with industry unless “they signed an affidavit to use it as a part of the registration process.” Dr. Morrisey’s data was derived from a monitoring sampling of 115 wetlands for bird breeding. “In contrast, Bayer replicated her tests during the end of summer when fields were dry and neonics weren’t running into the water,” Canada’s National Observer reports. “Instead of visiting and taking water samples from the sites, they relied primarily on Google Earth and Street View to find the wetlands Morrissey sampled and evaluate if they were relevant to the PMRA’s pesticide risk assessment. Bayer’s team only visited ‘a few sites’ in person,” the report says. In reversing the proposed ban, PMRA adopted Bayer’s critique of “relevant” sites in Dr. Morrissey’s aquatic risk assessment in its final decision to allow the continued use of imidacloprid. The Agency then went on to draw from 27 industry-run studies of mesocosms (simulated outdoor environments), even though “Environment and Climate Change Canada, the Canadian Council of Ministers of the Environment, and European Union and Dutch pesticide regulators consider mesocosm studies too scientifically weak to set water quality guidelines for pesticides,” according to the report.

Industry Interference is the Status Quo

There is an extensive record of pesticide manufacturers’ (including Bayer) interference in regulatory and academic institutions to the detriment of public health and environmental stability.

The industry has advanced the idea that petrochemical-based products are integral to climate “solutions,” including carbon markets and regenerative agriculture. Bayer-Monsanto has faced public scrutiny across the globe for the harm that its products have caused to frontline communities and stewards. For example, in 2023 a collective of Mayan beekeepers (Colectivo de Comunidades Mayas) alleged that a mass die-off of more than 300,000 bees led to a financial loss of $633,000 US dollars (12 million pesos). Not to mention the proliferation of South Africa-based farmer protests in 2023, as toxic pesticides that are banned from use in the European Union continue to be imported into their markets.

In recent years, Bayer-Monsanto and Corteva have grown to become leading players in voluntary carbon markets based in the United States. Based on Civil Eats’ reporting, Bayer/Monsanto with Climate FieldView and Corteva chemical company (previously Dow chemical company and Dupont, known as DowDuPont) with its Carbon Solutions program, cite their pesticide products as tools for sustainable agricultural practices, bundling these toxic pesticides with sustainable practices like no-till/reduced-till agriculture and cover cropping that can be healthy components of organically managed systems. (See Daily News here and Civil Eats investigation here.)

In the context of regenerative agriculture, a study funded by CropLife America, the trade association for pesticide manufacturers, highlights Integrated Pest Management (IPM) as the ideal systems solution for improving soil health in vaguely defined “regenerative” agriculture, which it maintains necessitates the continuation of pesticide inputs. The study was written by four authors with varying levels of connections to the major agrichemical industry trade group, including academic researchers with funding from the pesticide lobbying group or direct employment. In the disclosure statement at the end of the article in the International Journal of Agricultural Sustainability, the authors indicate that the work was supported by CropLife and then say, “No potential conflict of interest was reported by the author(s).” (See Daily News here.) For more Daily News on greenwashing implications of regenerative agriculture, see here.

Meanwhile, the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA), and EPA jointly released a report setting the stage for the expansion of genetically engineered crops and products that would further enrich corporations at the expense of long-term public health and ecosystem balance. (See Daily News analysis here.)

Courts have stepped in to act as a backstop to legislative and executive inaction. On July 10, 2024, the Oregon Court of Appeals ruled that the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) does not preempt pesticide exposure victims’ state law claims against pesticide manufacturers, based on reporting from The New Lede. This decision builds on years of judicial precedent from the Supreme Court of the United States (SCOTUS) that protects individuals’ right to use failure-to-warn claims against producers of toxic pesticides. (See Daily News here.) However, the chemical industry has moved the battle to state legislatures and the U.S. Congressional debate on the federal Farm Bill, where it is seeking through state and federal law to be shielded from liability for its failure to warn pesticide users about hazards.

Call to Action

Beyond Pesticides, in coordination with communities across the country, has called for the separation of corporation and state given the outsized impacts that various actors in the petrochemical and pesticide sectors have wrought on biodiversity, public health, and climate resilience.

In a study published in Frontiers in Toxicology, which builds on EPA data reports, all five neonicotinoids evaluated—acetamiprid, clothianidin, imidacloprid, thiacloprid, and thiamethoxam—are associated with significant shrinkage of brain tissue at the highest dosage. Neonics have also been linked to breast cancer, and developmental issues in the brain and nervous system, among other human health effects. There are already ten U.S. states that have restricted or banned the use of neonicotinoid insecticide products and the European Union banned neonics on all outdoor areas, only permitting their use in enclosed greenhouses. (See Daily News here, here, and here for the progression of policy changes.) For more coverage on neonicotinoids, see its dedicated Daily News section at the link above.

Join the battle to protect the right to sue when pesticide manufacturers fail to warn users about the hazards of their products. See previous Action of the Week to weigh in.

Beyond Pesticides called on Monsanto-Bayer to end its operations in Hawai’i after pleading guilty to multiple crimes, including pesticide use violations and putting field workers at risk. In both cases, they admit that they knowingly violated pesticide law and put field workers in harm’s way. (See Daily News here.)

In the spirit of moving beyond toxic pesticide reliance, Beyond Pesticides coordinated with the Center for Food Safety and numerous farmworker organizations to urge EPA to suspend the registration of glyphosate. (See Daily News here and petition here.)

While the future of EPA is in question under the Trump administration, the agency set in its suspension all uses of the weed killer Dacthal/DCPA last August, which Beyond Pesticides calls “The Dacthal Standard” because it recognized serious concerns about fetal hormone disruption and resulting “low birth weight and irreversible and life-long impacts to children [impaired brain development, decreased IQ, and impaired motor skills] exposed in-utero” and found that there are no “practicable mitigation measures” to protect against these hazards. Beyond Pesticides has launched campaigns to apply The Dacthal Standard to numerous pesticides, including atrazine and paraquat. Next up is chlorpyrifos, while we seek to apply The Dacthal Standard to additional toxic pesticides.

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

Source: Canada’s National Observer

(Beyond Pesticides, December 17, 2024) A systematic review of studies on pesticides as endocrine-disrupting chemicals (EDCs) on body weight, published in Biomedicines, evaluates 36 clinical and preclinical studies and links their agricultural use to obesity. The authors, with the lead researchers from the School of Medicine and Health Sciences at Catholic University of Valencia San Vincente, Valencia, Spain, assess studies on a range of pesticides, including organophosphates, pyrethroids, neonicotinoids, and others. In addition to concluding that the EDCs promote obesity, they report that the chemicals cause “other anthropometric changes by altering lipid and glucose metabolism, modifying genes, or altering hormone levels such as leptin.”

Endocrine disruption and obesity are public health concerns, and there is a wide body of science linking pesticide exposure to these effects (see more here). “Obesity is considered to be a worldwide pandemic that leads to an increase in medical costs and thus becomes a public health problem,” the researchers share. They continue, “[Obesity] is also associated with the increased production of environmental chemicals, also called environmental obesogens, used mainly in agriculture, as disease vector control, helping to prevent harmful effects caused by fungi, bacteria, or even pests, using pesticides, insecticides, and herbicides, or endocrine disruptors (ED), which interfere in different processes.”

In analyzing five human cross-sectional studies, 24 animal studies, and seven in vitro studies published since 2000, the authors investigate how environmental and dietary pesticide exposure is associated with anthropometric parameters, such as weight and body mass index (BMI), and metabolic changes that promote fat accumulation and adipogenesis (the process of creating fat cells).

Within the observational human studies, the pesticides evaluated span many different chemical families. These include: 2,4,5-dichlorophenol (2,4-D and 2,5-D, phenoxy herbicides); imidacloprid, acetamiprid, and clothianidin (neonicotinoid insecticides); glyphosate (phosphanoglycine herbicide); diuron (dimethylurea herbicide); chlorpyrifos (organophosphate insecticide); permethrin (synthetic pyrethroid insecticide); mancozeb and maneb (ethylene bisdithiocarbamate fungicides); carbendazim and thiophanate (carbamate fungicides); and benomyl (benzimidazole fungicide). The studies compare urinary concentrations of the pesticides to weight gain and obesity. Three of the studies use data from the National Health and Nutrition Examination Survey (NHANES) for children and adolescents aged 6–19 years and adults aged 20–85 years.

“Participants with obesity were found to have higher urinary concentrations of 2,4-D and 2,5-D. Higher concentrations of these pesticides were associated with increased BMI and waist circumference,” the authors note. “As in children, the adult study showed a higher prevalence of obesity with higher urinary levels of 2,4-D and 2,5-D.” The additional studies find that carbendazim, thiophanate, benomyl, metalaxyl, propineb, and chlorpyrifos show a statistically significant association with obesity prevalence.

In the studies on animals, 17 focus on species of mice while the other seven use rats, with nine of the 24 studies investigating chlorpyrifos. “[T]o evaluate the effect of pesticides on obesity, BMI, waist circumference, weight gain, and fat mass were the main measures used. In addition, several studies assessed biochemical parameters such as insulin levels, blood glucose, serum leptin, thyroid hormones, and lipid profile, as well as biomarkers and indicators of lipid metabolism,” the researchers explain.

As a result, chlorpyrifos exposure is associated with increased body mass, adiposity, impaired glucose tolerance, and insulin sensitivity in mice and rats when combined with a high-fat diet. It is also observed to alter gut microbiota, which can have “a significant effect on weight gain, serum-free lipopolysaccharide concentrations, and fasting glucose. Furthermore, this alteration could promote body weight gain, insulin resistance, and glucose intolerance,” the authors say.

Chlorpyrifos also alters intestinal permeability and causes an increase in lipopolysaccharide levels, “which could induce chronic inflammation and promote the development of insulin resistance and obesity. In addition, chlorpyrifos exposure may alter leptin levels, which could be associated with increased fat deposition, and a strong correlation was found between increased leptin levels and weight gain,” the researchers find.

Additional effects are noted with exposure to the organophosphate malathion (increased body weight and serum glucose levels in mice), synthetic pyrethroids bifenthrin and permethrin (significantly increased body weight, fat mass, and serum cholesterol levels in mice), and lambda-cyhalothrin and cypermethrin (increased plasma concentrations of free fatty acids, increased cholesterol, and increased hepatic triglyceride levels).

In mice, exposure to the neonicotinoid imidacloprid causes significant increases in body weight and adipose tissue, as well as increased serum glucose levels, insulin, and leptin levels, while exposure to thiamethoxam results in “[i]ncreased epididymal and retroperitoneal adipose tissue in males, increased omental adipose tissue in females, and increased adipocyte size.” Both imidacloprid and thiamethoxam exposure leads to increased levels of TG [triglycerides], free fatty acids, and cholesterol in male mice.

Seven in vitro studies evaluate the “effects of pesticides on the anatomy and physiology of hepatocytes and adipocytes” and the prevalence of obesity. Regarding hepatocytes, which are cells primarily in the liver that play a role in metabolism, cis-Bifenthrin is found to increase intracellular triglyceride levels in these cells after just 24 hours.

Adipocytes, fat cells found in adipose tissue, experience impacts from multiple pesticides:

• β-Cypermethrin induces autophagy and adipogenesis by increasing oxidative stress.
• Exposure to quizalofop-p-ethyl, dicamba, and isoxaflutole promotes lipid accumulation.
• Chlorpyrifos leads to a “significant increase in the number of differentiated adipocytes and their internal lipid storage capacity. In addition, there was an increase in the expression of PPARγ and C/EBPα transcription factors involved in the function of adipogenesis.”
• Treatment with fipronil significantly increases the triglyceride content in adipocytes, as well as causes changes in differentiation and lipid metabolism within the cells.
• Adipocytes exposed to imidacloprid show an increase in fat droplets, as well as a higher accumulation of triglycerides and enzymes responsible for lipogenesis (a metabolic process for creating fat).
• The carbamate fenoxycarb increases lipid accumulation and reduces adipocyte viability at high concentrations. This pesticide also causes an increase in the expression of genes, PPARγ and FATP1, which are involved in fat transport.
• Pyriproxyfen exposure induces an increase in lipid deposition.

“This systematic review shows the association between pesticide use and a greater tendency to be overweight and obese,” the authors conclude. In highlighting the disruption of biological processes, such as metabolism, and changes in the expression levels of genes, more evidence of pesticides as EDCs is added to existing scientific literature.  

“EDs have been implicated in a variety of adverse effects, including neurotoxicity, autism spectrum disorder and developmental delays in children after prenatal exposure, impaired behavior, learning, memory, attention, sensation and neurodevelopment, depression and anxiety in children, reduced fertility in women due to increased polycystic ovarian syndrome or premature ovarian failure, and even breast or vaginal cancer,” the researchers state. “EDs can also affect fertility in men, especially in the case of some pesticides. They are also associated with endocrine disruption, causing thyroid dysfunction, affecting both iodine uptake and thyroid hormone metabolism, and interfering with insulin physiology, becoming a risk factor for the development of diabetes.”

As the researchers mention, “The World Health Organization (WHO) has also recognized EDCs as a public health priority, emphasizing the need for improved regulatory strategies and public education to protect vulnerable populations… Government agencies and regulators need to consider these findings to develop stronger regulations and promote good agricultural practices that protect both the environment and human health.”

While many countries have bans in place for some EDCs, pesticides in the U.S. are still registered and available on the market without a regulatory framework for evaluating endocrine-disrupting effects. The long half-life of EDCs is also of concern as levels can be detected in the environment and within the body for many years after use. With agricultural pesticides such as EDCs, there are high risks associated with both environmental and dietary exposure.

“There is evidence that some pesticides can be endocrine disruptors and, among some of their effects, we find alterations in pubertal development and in the function of the thyroid gland, which could be related to a greater tendency of obesity,” the authors note. A keynote speaker at Beyond Pesticides’ 41st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency, Tracey Woodruff, PhD, MPH, has written in the New England Journal of Medicine, “We need to recognize the very real harm that petrochemicals [including pesticides] are having on people’s health. Many of these fossil-fuel-based chemicals are endocrine disruptors, meaning they interfere with hormonal systems, and they are part of the disturbing rise in disease.” Dr. Woodruff’s Forum talk is available here.

To mitigate these health risks, the adoption of organic land management as a holistic solution is necessary. Removing the use of petrochemical pesticides and synthetic fertilizers, especially in agriculture, prevents toxic chemicals from being present in our food and protects the health of all organisms and the environment. Take action to expand the Organic Dairy Product Promotion Program to all-organic lunches, as all kids should have access to safe and healthy food.

Make The Safer Choice to avoid hazardous home, garden, community, and food use pesticides and join the Parks for a Sustainable Future program. You can also become a member of Beyond Pesticides. By doing so, you can add your voice to the urgent movement to eliminate fossil fuel-based pesticide use within the next 10 years and advocate for public health and the environment.

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

Source:

Pérez-Bermejo, M. et al. (2024) Impact of Endocrine Disrupting Pesticide Use on Obesity: A Systematic Review, Biomedicines. Available at: https://www.mdpi.com/2227-9059/12/12/2677.

(Beyond Pesticides, December 16, 2024) The fact that three-quarters of all U.S. fruits and nuts and one-third of all U.S. vegetables are grown in California means that all U.S. food eaters have a stake in how food is grown there. California is proposing the continued use of the fumigant 1,3-dichloropropene (1,3-D, also known as Telone), which can cause deadly effects to farmworkers and endocrine disrupting effects to communities of people exposed through nontarget chemical drift from farmland.

So, it is with deep concern that Beyond Pesticides is urging the state of California, where the chemical is undergoing review, to ban the toxicant. Endocrine disruption, an adverse effect for which the U.S. Environmental Protection Agency (EPA) has never completed a pesticide testing protocol, adversely affects the functioning of glands and hormones and is linked to major life-threatening diseases in most organ systems in the body—contributing to attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, diabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorders, and childhood and adult cancers.

In a recently released draft regulation, the California Department of Pesticide Regulation (CDPR) will allow highly elevated exposure to 1,3-D, ignoring the scientific literature and advice of the state’s own toxicologists at its Office of Environmental Health Hazard Assessment (OEHHA). CDPR is proposing to allow continued community exposure to 1,3-D at levels that are fourteen times higher than the State’s official cancer risk level, perpetuating environmental racism and endangering vulnerable communities.  

CDPR’s draft regulation applies separate and unequal standards for different groups, allowing children and adult residents near agricultural fields to be exposed to significantly higher cancer risks than workers in neighboring fields—the “occupational bystanders.” This discrepancy is unjustifiable and fails to uphold the principles of equity and environmental justice. 

For decades, 1,3-D has harmed communities, particularly Latino and Indigenous populations, who are disproportionately exposed to the pesticide. The state’s toxicologists have set a cancer risk exposure level of air concentrated with 1,3-D at 0.04 parts per billion (ppb) per day. Yet, CDPR has adopted one regulation and is proposing another for the same pesticide: one adopts the 1,3-D manufacturer Dow Chemical’s preferred exposure standard of 0.56 ppb per day for residents and children, while the other uses the OEHHA standard for occupational bystanders. Even for occupational bystanders, by disregarding off-the-clock exposure, DPR proposes implementing only 100-foot buffer zones, entirely inadequate for protection against a fumigant that can drift for miles at harmful levels.

Public health advocates think it is outrageous that EPA and CDPR would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health’s PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death. 

These and other soil fumigants not only pose severe health threats to farmworkers and bystanders but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment and should be banned. 

The public has an opportunity to comment and Tell EPA and Congress to cancel the registration of all toxic soil fumigants and encourage organic alternatives. 

In addition, after submitting this Action, there is an option to copy/paste comments directly to the California Department of Pesticide Regulation website. [Unfortunately, a “click and submit” form is currently not available for CDPR comment.]

Comment to California Department of Pesticide Regulation
The California Department of Pesticide Regulation’s (DPR) draft regulation for the cancer-causing pesticide 1,3-dichloropropene (1,3-D, also known as Telone) continues to allow for exposure levels that are fourteen times higher than the State’s official cancer risk level, perpetuating environmental racism and endangering vulnerable communities.

DPR’s draft regulation applies separate and unequal standards for different groups, allowing children and adult residents near agricultural fields to be exposed to significantly higher cancer risks than workers in neighboring fields—the “occupational bystanders.” This discrepancy is unjustifiable and fails to uphold the principles of equity and environmental justice.

It is outrageous that the DPR would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices.

For decades, 1,3-D has harmed communities, particularly Latino and Indigenous populations, who are disproportionately exposed to the pesticide. The State’s own toxicologists at the Office of Environmental Health Hazard Assessment (OEHHA) have set an acceptable cancer risk exposure level of air concentrated with 1,3-D at 0.04 parts per billion (ppb) per day. Yet, DPR has adopted one regulation and is proposing another for the same pesticide: one adopts the 1,3-D manufacturer Dow Chemical’s preferred exposure standard of 0.56 ppb per day for residents and children, while the other uses the OEHHA standard for occupational bystanders. Even for occupational bystanders, by disregarding off-the-clock exposure, DPR proposes implementing only 100-foot buffer zones, entirely inadequate for protections against a fumigant that can drift for miles at harmful levels.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health’s PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.

DPR must prioritize the health and safety of California’s most vulnerable residents and adopt a single health-protective standard of 1,3-D air concentrations of 0.04 ppb for all Californians, ensuring equal protection from this carcinogenic pesticide. 1,3-D and other soil fumigants not only pose severe health threats to farmworkers and bystanders, but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment and should be eliminated.

Thank you for your attention to this urgent issue.

Comment to the U.S. Environmental Protection Agency
The California Department of Pesticide Regulation’s (CDPR) draft regulation for the cancer-causing pesticide 1,3-dichloropropene (1,3-D, also known as Telone) continues to allow for exposure levels that are fourteen times higher than the State’s official cancer risk level, perpetuating environmental racism and endangering vulnerable communities.

CDPR’s draft regulation applies separate and unequal standards for different groups, allowing children and adult residents near agricultural fields to be exposed to significantly higher cancer risks than workers in neighboring fields—the “occupational bystanders.” This discrepancy is unjustifiable and fails to uphold the principles of equity and environmental justice.

It is outrageous that CDPR would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices.

CDPR’s draft regulation highlights the dangers to which farmworkers are routinely exposed. It is outrageous that the Environmental Protection Agency would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health’s PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to the lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death. 

1,3-D and other soil fumigants not only pose severe health threats to farmworkers and bystanders but also threaten soil and water ecosystems. In contrast, organic production seeks   to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment. Their registrations should be canceled.

Thank you for your attention to this urgent issue.

Comment to the U.S. Congress
The California Department of Pesticide Regulation’s (CDPR) draft regulation for the cancer-causing pesticide 1,3-dichloropropene (1,3-D, also known as Telone) continues to allow for exposure levels that are fourteen times higher than the State’s official cancer risk level, perpetuating environmental racism and endangering vulnerable communities.

CDPR’s draft regulation applies separate and unequal standards for different groups, allowing children and adult residents near agricultural fields to be exposed to significantly higher cancer risks than workers in neighboring fields—the “occupational bystanders.” This discrepancy is unjustifiable and fails to uphold the principles of equity and environmental justice.

It is outrageous that CDPR would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices.

CDPR’s draft regulation highlights the dangers to which farmworkers are routinely exposed. It is outrageous that the Environmental Protection Agency would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices.

1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health’s PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to the lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.

1,3-D and other soil fumigants not only pose severe health threats to farmworkers and bystanders but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment. 

Please tell EPA that their registrations should be canceled. 

Thank you for your attention to this urgent issue.

(Beyond Pesticides, December 13, 2024) In October, the U.S. Environmental Protection Agency (EPA) approved the registration applications of BASF Corporation and Mitsui Chemicals Crop & Life Solutions, Inc. for the use of different formulations of the L-isomer of glufosinate (also known as “L-glufosinate” and “glufosinate-P”) as new active herbicidal ingredients. This decision marks one of the first times that EPA has employed its new Herbicide  Strategy Framework to determine the level of mitigation necessary to protect listed species and critical habitat under the Endangered Species Act (ESA). Glufosinate is an organophosphate, with known neurotoxic, reproductive/developmental effects, toxic to aquatic life, and mobile in soils (see Beyond Pesticides Gateway). Scientists have found that formulated glufosinate is generally more toxic to aquatic and terrestrial animals than the technical grade active ingredient.

Manufacturers are introducing newer glufosinate products as alternatives for glyphosate-based herbicides, like Bayer/Monsanto’s ‘Roundup’ and dicamba. The Center for Biological Diversity notes in comments submitted to EPA on this decision, “L-glufosinate has the potential to be used on tens of millions acres of land every year given the crops EPA has proposed to register it on. The scale of potential use is far above most new active ingredients.”

This first significant application of the Framework demonstrates, according to advocates, that the herbicide registration process remains insufficient to protect endangered species, public health, the environment, and biodiversity. As advocates, as well as Beyond Pesticides, have observed, the agency presupposes that farmers must use toxic chemicals, an assumption that clouds and undermines the regulatory process, trapping farmers on a toxic pesticide treadmill. Fundamental change requires EPA—in every pesticide registration and registration review—to examine whether there are practices that can eliminate harm, not substitute one toxic conventional pesticide for another.

Glufosinate-P is an enriched isomer of glufosinate, a broad-spectrum herbicide registered in the U.S. that targets glutamine synthetase to inhibit photosynthesis and poison plants. While the currently registered active ingredient glufosinate contains both D- and L-isomers, only the L-isomer (glufosinate-P) is herbicidally active. Two forms—glufosinate-P and its ammonium salt, glufosinate-P-ammonium—are being registered as functionally equivalent, and EPA states, “Glufosinate-P-ammonium is the ammonium salt of glufosinate-P and shares all the herbicidal properties for glufosinate-P,” as mentioned in the document entitled Memorandum Supporting Final Decision to Approve Registration for the New Active Ingredient Isomer, Glufosinate-P (Docket ID: EPA-HQ-OPP-2020-0533). Both are nonselective, postemergence contact herbicides. To align with the International Organization for Standardization (ISO) naming conventions, EPA is establishing tolerances for glufosinate-P, the ISO standard name for L-glufosinate-free acid. 

For years, EPA failed to comply with ESA by not accounting for impacts to threatened and endangered species (“listed species”) when approving pesticide usage under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (see here, here and here). Prior to the Herbicide Strategy Framework, EPA leveraged a chemical-by-chemical, species-by-species approach to meet its ESA obligations: an extremely slow process resulting in less than a five percent completion rate. The reactivity found EPA responding to legal challenges rather than proactively addressing endangered species concerns, and by early 2021 the agency faced nearly two dozen lawsuits covering thousands of pesticide products directly related to this failure.  As a result, the agency acknowledged its failure to properly assess impacts on threatened and endangered species and, in the following year, released a work plan to guide program improvements, including strategies for EPA’s pesticide program to meet its ESA obligations. In August 2024, EPA published the Final Draft of its new Herbicide Strategy Framework to “assess potential impacts and identify mitigations to reduce potential population-level impacts to listed species from the use of agricultural herbicides.”

The agency’s Herbicide Strategy Framework utilizes a three-step decision-making process for determining appropriate mitigation measures:

1. Determine the potential for population-level impacts to listed species as “not likely,” “low,” “medium,” or “high,” based on environmental fate and toxicity data submitted by registrants and EPA’s standard models.
2. Identify required mitigation requirements to reduce drift and runoff to non-target species to reduce exposure levels for listed species: three points of mitigation for “low” impacts, six points for “medium impacts,” and nine points for “high” impacts.
3. Identify where geographically the mitigation measures identified in Step 2 will apply (i.e., some mitigation measures will be required everywhere while others may only be applied in specific geographic regions).

In a notable change from an earlier draft of the Framework, EPA now allows pesticide applicators to reduce buffer zones around herbicide applications by implementing additional measures to control spray drift. The mitigation options vary based on the method of application and include using specialized equipment, lowering the application rate, adding physical barriers like windbreaks or hedgerows, adjusting the treated area’s width, and considering relative humidity. Each measure has an assigned percentage value by which the buffer can be reduced. For example, a 100-foot buffer could be lowered to 80 feet if a mitigation measure with a 20% reduction is applied.

According to EPA Deputy Assistant Administrator for Pesticide Programs for the Office of Chemical Safety and Pollution Prevention Jake Li, “By identifying protections earlier in the pesticide review process, we are far more efficiently protecting listed species from the millions of pounds of herbicides applied each year and reducing burdensome uncertainty for the farmers that use them.” However, EPA also notes that the strategy itself does not impose immediate requirements or restrictions on pesticide use. Instead, it ‘requires’ pesticide users to research and consider implementing possible and various mitigation options, depending on their geographical location and guidance available online, linked to pesticide labels.

EPA’s decision on glufosinate employs the Herbicide Strategy Framework to identify mitigation measures for potential impacts on endangered species—before completing the required formal consultation with the U.S. Fish and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS). This approach aims to streamline the process by addressing likely impacts in advance. However, advocates argue that this framework will certainly undermine ESA protections, as it relies on assumptions about species impacts without fully consulting USFWS and NMFS. They are concerned that the EPA’s preliminary mitigation measures may not fully address or protect endangered species due to the limited input from these agencies before the final consultation is complete.

Glufosinate mitigation requirements

EPA’s registration decision on glufosinate-P requires “the implementation of the following mitigation measures to address on- and off-field effects to nontarget species, including listed species:

• Prohibiting application during rainfall and when soils are saturated or above field capacity;
• Requiring users to visit EPA’s Mitigation Menu Website before application and determine an appropriate strategy for meeting or exceeding the required number of mitigation points as specified on the label;
• Maintaining a downwind buffer between the last spray row and the protection area of 50 feet for aerial application and 10 feet for ground application; and,
• Instructing users to access and follow any applicable endangered species bulletins for the two listed species–the Spring Creek bladderpod plant and the whorled sunflower plant–from ‘Bulletins Live! Two’ web-based system in English for all additional directions and restrictions.”

Advocates argue that EPA’s Framework has effectively substituted one problematic and insufficient process for another. Even once a mitigation requirement is identified after a new or renewed pesticide registration, compliance by a pesticide applicator, farmer, or worker operates under a “self-service, honor system,” relying on users to proactively seek information online and then simply consider mitigation steps from a still complex menu of possible choices. EPA notes: “The final strategy itself does not impose any requirements or restrictions on pesticide use. Rather, EPA will use the strategy to inform mitigations for new active ingredient registrations and registration review of conventional herbicides.”  Therefore, with this Framework, EPA does not appear to establish clear and specific use and site restrictions communicated through a pesticide label, which has historically been established as a set of enforceable legal restrictions under federal pesticide law.

Critics observe that EPA does not possess the scientific expertise, nor the statutory authority, to accurately determine the potential for “population level” impacts to “listed species.” They are obligated to rely on the USFWS and NMFS through a consultation process to make such assessments of the potential effects on species that inhabit such complex ecological systems. Therefore, any pesticide that has not gone through a complete ESA consultation cannot have been properly evaluated. (The Center for Biological Diversity argued this in its June 2024 comments.)

For example, there is a significant overlap (20-75%) between the habitats of some terrestrial invertebrate pollinators, such as bees and butterflies, and the areas where this pesticide is most likely to be employed. Moreover, L-glufosinate is considered “mobile” to “highly mobile” in soil and can reasonably be expected to be applied in areas of the U.S. with “high” runoff potential. Thus, the requirements of only a 50-foot buffer and one point of runoff mitigation are expected to be insufficiently protective. Migration of toxic chemicals into adjacent habitats could imperil not just listed plant species, but the habitats of listed animal species.

Beyond Pesticides and fellow changemakers—including organic and regenerative organic farmers and advocates—have long argued that the failure of EPA to consider the viability, productivity, and profitability of organic practices and product alternatives to conventional pesticides means the agency’s registration and reregistration of toxic pesticides, including glufosinate-P, have not been subject to a complete assessment. In this context and given the availability of less and nontoxic alternatives, EPA has failed in its responsibility to ensure that pesticides registered for use under FIFRA will not cause unreasonable adverse effects. In fact, EPA notes in an interim decision on glufosinate from 2016, “The (EPA) registration review program is intended to make sure that, as the ability to assess and reduce risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse effects.”

The planet is facing an urgent biodiversity crisis, with more species approaching extinction than ever before (see here and here). The purpose of ESA is to address this loss of biodiversity by protecting habitats critical to the survival of the most at-risk species. Pesticide use is a major driver of biodiversity decline, contributing to extinctions and elevating species’ vulnerability to environmental challenges such as climate change, habitat fragmentation, and exposure to toxic chemicals. To protect biodiversity, EPA is charged with examining how its decisions may exacerbate this crisis. Pesticides are a leading factor in the decline of insect populations and diversity, often referred to as the “insect apocalypse,” which threatens ecosystems across the planet. EPA’s approval of insecticides has posed risks to insect populations, while herbicides degrade insect habitats and food sources and pesticides disrupt food webs—in both freshwater and marine ecosystems (see here and here for Beyond Pesticides 2023 Forum session).

As industrial agriculture further reduces biodiversity by destroying or contaminating habitats, organic land management systems, in contrast, require producers to actively conserve and enhance biodiversity. Organic agriculture is a viable, productive option embraced by consumers and thriving as a $60 billion industry. This market success comes despite structural bias in USDA funding or programs, including the continued subsidization of conventional and monocrop agriculture through the Farm Bill in Congress. Consumers continue to make a difference by choosing to buy organic—reducing their own exposure to pesticide residues from conventional produce—and supporting organic farming, which protects not just consumers, but farmworkers and their families. Read more about agricultural justice and take action to support organic agriculture and strengthen organic certification here.

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

Sources: 

EPA Registers New Herbicide Active Ingredient Glufosinate-P, EPA website, October 18, 2024

EPA Finalizes First-of-its-Kind Strategy to Protect 900 Endangered Species from Herbicides, EPA announcement, August 20, 2024

Federal Register: EPA Announcement Glufosinate-P; Pesticide Tolerances, effective October 29, 2024, available under EPA-HQ-OPP-2020-0250 and EPA-HQ-OPP-2020-0533 

Comments to EPA on Proposed Decision to Register a New Enriched Isomer L-Glufosinate for Use on Conventional and Genetically Engineered Corn, Cotton, Canola and Soybean, The Center for Biological Diversity, June 8, 2024

Glufosinate-P. Human Health Risk Assessment for New Active Ingredient Isomer, EPA docket EPA-HQ-OPP-2020-0250-0027, May 8, 2024

Memorandum Supporting Proposed Decision to Approve Registration for the New Active Ingredient Isomer, Glufosinate-P, Memo EPA Office of Pesticide Programs, April 30, 2024

Threatened Biodiversity and Ecosystems, Pesticides and You, Beyond Pesticides, 2023-2024

(Beyond Pesticides, December 12, 2024) A literature review of 161 articles in Discover Toxicology finds that pesticides with different mechanisms of action cause memory and learning impairments. These effects are noted in nontarget species including humans. Pesticide “[e]xposure during development, as well as chronic environmental and occupational exposure, can contribute to decreased cognitive performance,” the researchers say. With a focus on organophosphate pesticides, synthetic pyrethroids, and neonicotinoid insecticides, the authors highlight neurological impacts.

Both learning and memory are crucial for the survival of many species. “Considering the importance of learning and memory for human and non-human animal behavior and the growing association between pesticide exposure and cognitive impairment, the aim of this review was to describe the studies showing the impact of pesticide exposure on memory and learning abilities in nontarget species, providing evidence of the impact of pesticides in central nervous system function,” the researchers state.

The 161 articles included in the review were identified through database searches in PubMed/Medline and Scielo. The authors note, “Inclusion criteria for article selection included all articles published in English between 2015 and 2024 containing original studies in animals or humans with single or multiple pesticides exposure.”

The articles consist of 132 preclinical studies involving animal models, most focusing on bees and rodents, and 29 human studies that assess occupational and environmental exposure. The researchers share that, “Regarding animal models, 58% of preclinical studies were conducted in rodents and 28% in bees, evidencing the lack of studies conducted in aquatic species, amphibians and other important animal models in ecotoxicological studies.” See related coverage on scientific deficiencies within Environmental Protection Agency (EPA) review processes here.

Preclinical Studies

Organophosphates

In the research, the majority of studies, related to organophosphates, assess the effects of exposure to chlorpyrifos, malathion, and diazinon and find that they cause damage to the learning and memory capacity in multiple species. The authors postulate that these effects of organophosphates on “[m]emory and learning deficits seem to involve mechanisms such as acetylcholinesterase and butyrylcholinesterase inhibition and oxidative stress.”

Notable studies include:

• In bees, chlorpyrifos leads to slower olfactory learning and memory.
• Many studies find that chlorpyrifos impairs spatial and recognition memory in mice (see here, here, here, here, and here), as well as spatial learning and memory in rats (see here, here, and here).
• Short-term exposure to malathion causes damage to spatial memory in mice. The offspring of exposed mice also exhibit decreases in memory and behavior.
• Malathion exposure in rats induces spatial learning and memory deficits through mechanisms involving oxidative stress and synaptic damage.
• Rats subjected to diazinon show impaired reference memory and deficient attentional accuracy, in addition to decreased aversive memory (see here and here).

Pyrethroids

As the researchers report, “Studies have shown that exposure to pyrethroids caused learning and memory deficits in rats and mice and was associated with the disruption of dopaminergic pathways, oxidative stress and hippocampal damage.” Additional studies reveal effects on pollinator species.

Notable studies include:

• Flumethrin exposure during the larval stage in honeybees affects memory-related behaviors and decreases the expression of memory-related genes. Long-term exposure also impacts olfactory learning and memory and causes downregulation of memory-related genes.
• Deltamethrin impairs learning and memory formation in honeybees with short-term exposure to sublethal concentrations.
• Mice treated with deltamethrin show impairments in spatial memory and memory retention, as well as learning deficits, hippocampal endoplasmic reticulum stress, and impaired hippocampal neurogenesis (see here and here).
• Rats exposed to deltamethrin exhibit mitochondrial dysfunction in the hippocampus and striatum, and impaired learning and reference memory. Studies also show impaired learning and spatial/working memory (see here, here, here, and here).
• Bifenthrin exposure in mice presents memory retention deficits.
• Exposure to permethrin during the prenatal and postnatal periods in mice causes impairments in learning and memory in adulthood.
• Treatment with lambda-cyhalothrin in mice shows a decrease in retention and learning memories.
• Developmental exposure to cypermethrin impairs spatial learning in young rats.
• Cyfluthrin affects the pathways in the hippocampus, which alters learning and memory in the offspring of exposed rats.

Neonicotinoids

Most studies of neonicotinoid insecticides in the review report harm to various species of bees. The authors find that, “Olfactory, associative and aversive learning, as well as memory capacity were affected by the exposure to several neonicotinoid insecticides, particularly imidacloprid. These sublethal effects can affect the behavioral performance of bees and consequently their pollination activity, impacting pollinator-dependent agricultural systems, in addition to the maintenance of ecosystems.” See “What the Science Shows on Biodiversity” for additional studies regarding pollinators.

Notable studies include:

• Bumblebees exposed to imidacloprid during brood or early adult development exhibit learning deficits in adulthood. Imidacloprid also causes impaired olfactory, associative, aversive, and motor learning in many bee species (see here, here, here, here, here, and here).
• Sublethal concentrations of imidacloprid also negatively affect learning and short-term memory in paper wasps.
• Imidacloprid causes a spatial memory disorder in Hipposideros terasensis bats (see here and here).
• Chronic exposure to clothianidin affects olfactory learning in honeybees and bumblebees, while acute exposure compromises short-term to mid-term memory and memory recovery in honeybees (see here and here).
• Thiamethoxam exposure in honeybees and bumblebees impairs visual and olfactory learning and presents learning delays and memory deficits.
• Rats exposed to thiacloprid display short-term working memory impairment, oxidative stress, and neuroinflammation.

Human Studies

Neurological effects in children and adults following pesticide exposure are heavily documented. Both chronic and acute exposure, even at low doses, can cause permanent damage to the brain, especially during critical periods of development. As the researchers report, “Learning and memory problems are not the only outcomes associated with early exposure to chemicals: intellectual disability, autism spectrum disorder, motor delays, attention problems, and others can have far-reaching effects on children’s educational success, socioemotional development, and quality of life.” See more on brain and nervous system disorders here.

While children are more susceptible to negative health effects from pesticide exposure due to their developing system and more limited ability to detoxify compounds, adults also experience many neurological impacts. Particularly affected are those who are subjected to pesticides during occupational activity including farmers and farmworkers. This disproportionate risk is associated with poorer memory and learning performance.

“Epidemiological studies have mostly reported the exposure of agricultural workers to organophosphate and carbamate pesticides, in addition to other pesticides used on crops. Long-term exposure to pesticides has been suggested to have long-lasting toxic effects on the central nervous system, and studies have recognized that chronic exposure is a possible risk factor for dementia and Alzheimer’s disease,” the authors say. (See studies here and here.) They continue, “In addition to cognitive deficits and neurodegenerative diseases, studies suggest a positive association between pesticide exposure and psychiatric conditions, such as depression, anxiety and suicide.”

Notable studies include:

• In 10-year-old children from a birth cohort in California, mothers living close to intensive applications of organophosphate and carbamate pesticides exhibit decreased cognitive function, such as in working memory.
• Children in Costa Rica living near banana plantations show neurodevelopment impairment. Specifically, children exposed to mancozeb have poorer verbal learning abilities, while exposure to chlorpyrifos is associated with poorer working memory.
• A study of Ecuadorian children observed an association between residential proximity to greenhouse agriculture and impaired cognitive performance.
• School-age children in rural areas of Colombia who experience environmental exposure to organophosphates, pyrethroids, and fungicides show decreased working memory index. Home usage of pesticides is also associated with a lower processing speed index.
• Organophosphate and carbamate pesticide exposure in Chile decreases cholinesterase activity and affects memory function in people living near plantations (see here and here).
• In Uganda, a cross-sectional study shows that overall pesticide exposure in farmers, specifically to glyphosate, is associated with impaired visual memory.
• Costa Rican farmers exposed to multiple pesticides with higher concentrations of insecticide biomarkers, including metabolites from chlorpyrifos and pyrethroids, display reduced prefrontal cortex activity during working memory tasks.
• After decades of occupational exposure, veterans show problems with concentration and memory as symptoms of Gulf War Illness (see studies here, here, and here as well as additional coverage on veterans here).

Organic as a Solution

The dependence on petrochemical pesticides and synthetic fertilizers leads to an increase in human exposure to toxic chemical compounds. Contamination of the environment, as well as residues in food and water, subjects nontarget organisms to chemicals that result in deleterious health effects. These pesticides also play a critical role in the current existential crises of public health, biodiversity, and climate change (see more here and here).

As an alternative, organic land management offers a path forward that mitigates these negative effects and promotes the health of all organisms and the environment. Learn more about the environmental and health benefits of organic, as well as how to buy organic products and grow your own organic food. Stay up to date with Daily News and sign up to receive Action of the Week and Weekly News Updates delivered straight to your inbox.

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

Source:

Honatel, K.F. et al. (2024) An update of the impact of pesticide exposure on memory and learning, Discover Toxicology. Available at: https://link.springer.com/article/10.1007/s44339-024-00011-9.

(Beyond Pesticides, December 11, 2024) A recent report published by the Research Institute of Organic Agriculture (FiBL) unpacks the impacts of new European Union (EU) organic regulations that are going into effect in 2025 with a “completely new set of rules for the certification of smallholder producer groups.” These regulations represent a major shift from the current “equivalence” to a “compliance” system with all EU legal requirements. The change announced almost three years ago, to provide time for transition, is intended to improve consumer trust in the organic label and eliminate a “patchwork of rules and derogations [exemptions] in place [that] did not give sufficient certainty and security” (European Commission 2017). The new EU Organic Regulation 2018/848 aims to encourage the sustainable development of organic production in the EU, guarantee fair competition for farmers and operators, prevent fraud and unfair practices, and improve consumer confidence in organic products.

According to the FiBL report, “The new EU Organic Regulation 2018/848 aims to encourage the sustainable development of organic production in the EU, guarantee fair competition for farmers and operators, prevent fraud and unfair practices, and improve consumer confidence in organic products.”

More than 7 in 10 organic producer groups globally will need to change their structure to maintain their certification, according to FiBL analysis. This EU regulation comes into effect within two years after the U.S. Department of Agriculture (USDA) published the Strengthening Organic Enforcement (SOE) final rule. (See Daily News here.)

Environmental and public health advocates welcome the improvement of organic regulations to strengthen the global marketplace and consumer trust in certified organic. However, advocates continue to demand reimagining the Farm Bill and agricultural support programs to, among other objectives, emphasize greater access for young, beginning, and farmers of color who face disproportionally significant barriers to entry. The National Young Farmers Coalition notes that Rural Prosperity and Food Security Act of 2024, advanced by retiring Senator Debbie Stabenow (D-MI) contains provisions center on “the needs of young and Black, Indigenous, and people of color (BIPOC) farmers and ranchers across the country . . .” 

Key Takeaways

Before moving forward, there are some terms that require definition for ease of future reference in this article. In EU Law, “third country” refers to a non-EU member country or a country where citizens do not have the right of free movement within the EU (Iceland, Lichtenstein, Norway, or Switzerland). “Control Bodies (CBs)” refer to organic regulators (e.g., third-party certifiers in the U.S. context) who oversee the certification process at the local, state/provincial, or national levels. “Global majority” refers to non-EU or U.S. peoples, not including First Nations, Aboriginal, and Indigenous peoples of the Americas, to account for historical power dynamics and counteract legacies of Western imperialism/colonialism in discussing policy language.

There are a few critical takeaways concerning the new EU-wide organic regulations listed below:

1. The shift to “compliance” versus “equivalence” for imported organic products into the European Union;
2. In spite of requests from organic and development associations in Global Majority countries to extend the exemption for “compliance systems” to December 31, 2025, the EU Commission set the end of the derogation period for October 15, 2025. This means that products not in “compliance” will not qualify for organic certification in Europe starting on October 16, 2025, even though “most certified organic producer groups in third countries are not yet fully aware of the potential non-compliance, the severity, and the resulting sanctions.”
3. New definitions and binding legal requirements, including “Group of Operators” and Internal Control System (ICS) requirements.
4. Third country organic producer groups consisting of smallholder farmers are facing a multitude of regulatory changes between 2023 and 2026, including the SOE 2023 update from the U.S. National Organic Program and the EU Regulation on Deforestation-free Products.
5. In surveys FiBL conducted with third country producer groups, 32% of respondents expect annual costs to increase by 50% to more than 100% and 43% of respondents expect certification costs to go up by 50% to over 200%. However, 82% plan to adapt to the new regulations.

Diving Deeper

EU organic policy was overhauled in 2018 and entered into force in January 2022. This change in certification standards is considered an extension of this legally binding legislation and goes into effect on January 1, 2025. The new regulations have far-reaching implications that vary based on commodity type, geographic region, and/or country of origin. See Chapters 5 through 7 of the report for more detailed analysis, including page 19 for a timeline of regulatory transition from equivalence to compliance models. See Figure 5: Transition from equivalence to compliance for imports from third countries (which are currently under third-country control body equivalence) on page 19 of the report.  

Group of Operators

According to the FiBL report, a new definition for “Group of Operators” (GoO) aims to “reduce the inspection and certification costs and the associated administrative burdens, strengthen, local networks, contribute to better market outlets, and ensure a level playing field…” for third country producers, particularly producers that make up the Global Majority.

The new definition for GoO can be found on page 21 of the FiBL report. Among other stipulations in the new regulation, a Group of Operators must have an ICS. IFOAM-International describes ICS as:

“[T]he part of a documented quality assurance system that allows an external certification body to delegate the periodic inspection of individual group members to an identified body or unit within the certified operator. This means that the third party certification bodies only have to inspect the well-functioning of the system, as well as to perform a few spot-check re-inspections of individual smallholders.”

There are other parameters to consider, including the fact that members of a GoO must be in the same geographic zone, have a “legal personality,” membership capped at 2,000 members, among others. Broadly speaking, there are three types of producer groups that will be affected by making ICS mandatory for EU organic certification: those who already have ICS built into their organization (group type I), processor/exporter organized groups (group type II), and groups with 100% external control without ICS (group type 3). More details on this are in Section 4.1.2 (pages 34-37) of the report.

Equivalence versus Compliance

Simply put, an “equivalence” system means that the organic certification standards in one country meet the same standards of countries to which they seek to export their products. The historical progression from “equivalence” to “compliance” systems can be found starting on page 17 of the report.

A different transition period applies to the fourteen countries with national organic certification systems that the EU recognizes through an equivalency agreement. The countries that qualify include Argentina, Australia, Canada, Costa Rica, India, Israel, Japan, New Zealand, Tunisia, the United States, as well as the United Kingdom, Switzerland, and Chile through trade agreements.

Compliance means that all organic imports must abide by all EU legal requirements In the past, internal control systems (ICSs) were considered a non-binding EU guideline for third country producer groups with the goal to “provide…a pathway towards sustainable production and income generation for an (estimated) thousand-plus organic smallholder supply chains in Latin America, Africa and Southeast Asia benefiting more than a million organic producers by granting them access to the European market via “equivalent” certification.”

There are some additional implications that will place short-term strain on organic producers in third countries, however the new regulation will provide substantial improvement in safeguarding organic integrity across the board. A shift to a compliance system “means that certain substances accepted in third countries under the ‘equivalence’ regime cannot be used anymore.” Additionally, there will be tighter requirements on producing the same crop organically and non-organically on the same farmland, crop rotation and diversity (e.g. legumes, cover crops, green manure for perennials, etc.), and documentation of potential contamination risks. These measures are welcomed by organic advocates; but concerns around equity and accessibility for hundreds of thousands of farmers who have to adjust rapidly to the new regulations—if they want to remain certified organic—continue.

There are 43 third country control bodies that are recognized for certification under the new “compliance” system as of October 31, 2024. Some control bodies have already decided to abandon third country certification under the new regulations (FiBL third country survey data corroborates this, with 18% of respondents indicating that may stop or reduce organic certification as a result of these new regulations). There are some potential policy remedies in place or that advocates are hoping to be put into effect in the coming transitional years. See Figure 5: Transition from equivalence to compliance for imports from third countries (which are currently under third-country control body equivalence) on page 19 of the report for further details on the transition for non-EU member states.

Main Recommendations

FiBL proposes the following main recommendations (in bold) to minimize negative short-term impacts of the new organic regulations, with additional Beyond Pesticide in italics:

• EU importers and brands should collaborate with small-scale and non-EU producers to consider their challenges and future costs in trade contracts and trading practices. This is particularly important given the ongoing tensions between farmers, environmentalists, and policymakers over the Mercosur-EU Trade Deal and the continuous importation of toxic pesticide products banned in Global North countries. See Daily News here, here, and here for further analysis.
• Development of tailored, “user-friendly” resources or handbooks relevant to small-scale producers to minimize confusion and increase compliance with new rules. Streamlining paperwork for U.S.-based small-scale organic producers has continuously been raised as a critical area of concern by organic advocates, researchers, and farmers. See Daily News here.
• Targeted training and support programs can support producer groups as they adapt to the new regulations, including but not limited to support and market access programs and legal advisory services, and development of regional-specific guidance. An IPES-Food report released earlier this summer highlights the impact of organic certification and producer group certification systems contributing to territorial markets across the globe. See Daily News here.
• Going one step further than the previous recommendation, certifying bodies and EU policymakers can offer regional-specific accommodations, including flexibility of this transition period in terms of temporary exemptions based on crop-by-crop, geographical, or allowable input/substances. In the U.S. context, organic operations come in different scales and models. More support is needed to support small-scale producers; however, some are banding together to increase their efficiency while upholding values. See Daily News here.
• Customs authorities can develop task forces for the 1-2 year transition period (2025-2027) to answer questions for producer groups as they navigate compliance with new regulations. Strengthening customs and import regulations is a critical feature of the U.S. SOE rule, among other updates. See Daily News here for further analysis.

Keeping Organic Strong in the United States

In the context of the U.S., FiBL does not believe that the new SOE rule, which went into effect as of March 2024, “are not likely to require legal adaptions in the setup or composition of currently NOP-certified producer groups. However, some new rules have additional certification implications for re-organization according to the Group of Operator rules since many groups are certified according to both [U.S. and EU] standards.”

The main changes in the Strengthening Organic Enforcement (SOE) rule include new requirements for certification of “grower group operations” for imported and exported organic products. New rules include the addition of unannounced on-site inspections for certified operations, standards certificates of organic operation, foreign conformity assessment systems, labeling of nonretail containers, annual update requirements for certified operations, compliance and appeals processes, and calculations for organic content of multi-ingredient products. Advocates applaud the improvement of organic standards in terms of compliance, oversight, and trade implications.

Beyond Pesticides will continue to monitor any additional repercussions or impacts that the EU regulations may impose on the U.S. organic community.

Call to Action

See Keeping Organic Strong to learn more about the history of U.S. organic regulations. As mandated in the Organic Food Production Act (OFPA), the National Organic Standards Board is required to hold public hearings twice a year for open comment periods on organic standards, including updates from subcommittees on a plethora of focus areas including the sunset of materials on the National List of Allowed and Prohibited Substances, equity and barriers to access organic certification, development of new regulations, among other areas.

Beyond Pesticides provides resources and comments for every measure brought up in the fall and spring meetings each year so communities across the nation can become more familiar with the process and demand integrity in organic products.

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

Source: The Research Institute of Organic Agriculture (FiBL)

(Beyond Pesticides, December 10, 2024) Scientists from the Engineering Research Center of Protection and Utilization of Plant Resources at Shenyang Agricultural University in China reveal adverse effects of imidacloprid on soil communities in a study published in Pesticide Biochemistry and Physiology. The researchers highlight risks to nematodes from imidacloprid exposure in maize soil, as well as potential resistance mechanisms that impact not only nematode populations but also overall soil health.

Maize, or corn, a productive crop grown worldwide, is a source of food and biofuel. In assessing the soil and species in maize fields after exposure to imidacloprid at various concentrations, the study researchers assess the impact of neonicotinoid insecticides on nontarget organisms and the health of soil communities. The assessment includes an evaluation of nematodes’ survival, growth, reproduction, and chemotaxis/locomotion behavior. With a statistical analysis of lipid and lipofuscin accumulation, acetylcholinesterase (an enzyme necessary for neurotransmission) activity, and gene expression levels, the study results show that imidacloprid induces:

• significantly reduced abundance and diversity of nematode species.
• negative effects on body length, reproduction, locomotion, lipid accumulation, lipofuscin accumulation, and acetylcholinesterase activity in Caenorhabditis elegans ( elegans).
• the upregulation of gpa-1, cyp-35a2, fat-2, fat-6, hsp-16.41, and hsp-16.2, along with the downregulation of ace-1, ace-2, and ace-3
• corresponding adaptive mechanisms and repellant behavior in nematodes.

The authors report, “[A]nalysis showed that the community richness index and community diversity index of soil nematodes in maize rhizospheric soil sprayed with imidacloprid were significantly lower than those from untreated soil. These results indicated that spraying with imidacloprid significantly reduced the number and diversity of soil nematodes in maize rhizospheric soil.”

Also of note, the relative abundance of two bacteria-feeding nematodes within the genera Prodesmodora and Oscheius is lower in soil exposed to imidacloprid. “Both bacterial- and fungal-feeding nematodes contribute to the mineralization of soil nutrients such as nitrogen, thereby facilitating plant growth,” the researchers say. Differing soil nematode community compositions between treated and untreated soils highlight the impacts of pesticides on beneficial nontarget organism populations.

The study finds body length and body width of C. elegans decrease with increasing concentrations of imidacloprid, as well as significantly reduced brood sizes in individuals exposed to imidacloprid. Locomotion behavior, due to basic nervous system functions, for nematodes is assessed through three actions, body bends, head thrashes, and pharyngeal pumping. After 24 hours of exposure to imidacloprid, the researchers note that the frequencies of all three behaviors were suppressed, confirming neurotoxicity to nematode species. Imidacloprid additionally inhibits lipid accumulation and acetylcholinesterase activity in nematodes while it increases lipofuscin accumulation that leads to intestinal damage.

Assessing gene expression in nematodes provides insight into how pesticides cause epigenetic modifications upon exposure. Genes can also play a key role in resistance mechanisms. “A growing number of studies have highlighted the development of imidacloprid resistance in insects,” the authors state. “In this study, the major metabolites, imidacloprid-guanidine and imidacloprid-urea, appeared after 24 hours’ treatment with imidacloprid… Imidacloprid-urea has been shown to reduce the harm of imidacloprid to nematodes by about half. As to imidacloprid-guanidine, it is the intermediate pathway for the conversion of imidacloprid-urea, and imidacloprid-guanidine has been shown to have no insecticidal properties in previous reports, therefore we believe that C. elegans could convert imidacloprid to imidacloprid-guanidine and imidacloprid-urea to reduce the toxicity of imidacloprid.”

In converting imidacloprid into its metabolites, nematodes show higher tolerance and experience less of the toxic effects. The enhanced expression of the cyp-35a2 gene, which is involved in resistance, as seen in C. elegans, also provides an effective defense against imidacloprid-induced damage. High expression of gpa-1 may also contribute to repelling imidacloprid. These results highlight how imidacloprid disrupts a series of physiological and biochemical indicators, as well as alters expression of genes associated with development, fat metabolism, and stress responses.

Impacts on soil biota following pesticide applications are well documented. Many nontarget organisms suffer negative impacts after exposure, such as with neonicotinoids and pollinators. While imidacloprid is primarily used to control sucking insects such as aphids, there is a wide body of science linking this pesticide to its effects on various beneficial nontarget organisms such as bees.

While impacts on nematodes are less studied, these organisms provide ecosystem services within the soil and act as an effective biological control. (See previous Daily News coverage here and here.) Healthy soil promotes biodiversity and supports numerous key ecosystem processes including decomposition and nutrient cycling.

“[T]he biodiversity present in soil makes a significant contribution to the agricultural productivity of the soil. Together with many other soil organisms, soil nematodes are crucial parts of the soil ecosystem,” the researchers share. “Nematodes, including the notorious plant-parasitic nematodes, are able to regulate the rhizospheric microbiota and drive soil microorganism community composition. Furthermore, nematode excrement has been found to contribute up to 19% of the soluble nitrogen in the soil. Therefore, their diverse ecological functions and intricate trophic positions make soil nematodes are good indicators of soil biodiversity.”

Imidacloprid and numerous other pesticides threaten critical soil communities and the needed balance in food webs. Whether as a spray or seed coating agent, imidacloprid is absorbed by plants and transported to various tissues. Residues of imidacloprid are found in the plant body and in the soil, which expose many beneficial nontarget organisms.

As an alternative, organic agriculture eliminates the use of toxic petrochemical pesticides and synthetic fertilizers that harm the environment and all the organisms it supports. In prioritizing soil health, organic land management methods mitigate against the crises of health, biodiversity, and climate change.

Learn more about the benefits of organic here and here. Join the organic solution by Eating with a Conscience and growing your own food or buying organic products. Stay informed through Beyond Pesticides’ resources. The Pesticide-Induced Diseases Database (PIDD) provides scientific literature on public health effects of exposure to pesticides and the Gateway on Pesticide Hazards and Safe Pest Management catalogs information on specific chemicals. Join Beyond Pesticides as a member today to add your voice to the urgent movement to eliminate fossil fuel-based pesticide use.

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

Source:

Zhang, J. et al. (2024) Interaction between imidacloprid residues in maize rhizospheric soil and soil nematode community, Pesticide Biochemistry and Physiology. Available at: https://www.sciencedirect.com/science/article/abs/pii/S0048357524004528.

(Beyond Pesticides, December 9, 2024) In recognition of the explosion of a chemical plant in Bhopal, India 40 years ago that was responsible for the death of 20,000 people, U.S. Representative Pramila Jayapal introduced H.Res. 1604, “Recognizing the 40th year since the 1984 Bhopal chemical disaster and helping to ensure that no other community suffers another chemical disaster, by supporting the designation of December 3 as National Chemical Disaster Awareness Day” and calling for support of survivors of the disaster and promoting public understanding of the dangers of chemical disasters.

The Union Carbide Corporation (UCC) plant explosion released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1,754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic disease range up to 95% of the affected population of 531,881. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. In spite of this history and the many adverse effects of these extremely toxic pesticides and their precursors, EPA continues to register pesticides without considering cradle-to-grave risks. 

>> Tell EPA that harm done in the manufacture, transportation, and disposal of pesticides must count as “unreasonable adverse effects.” Tell your Congressional Senators and Representative to support H.Res. 1604.

After Bhopal
Amnesty International has provided the following history and perspective:

“Shockingly, it is not only people exposed to the gas directly who have been affected. Over the years that followed, a large number of children born to gas-exposed parents have been affected by growth retardation, birth defects and other medical conditions. Meanwhile, to this day, thousands of tons of toxic waste remain buried in and around the abandoned plant. This has contaminated residents’ water supplies and harmed their health, adding to the already dismal health status of gas-exposed residents. As well as the health impacts, the tragedy has pushed already impoverished communities into further destitution. In many families, the main wage earner died or became too ill to work. Women and children suffered disproportionately.”

“An unfortunate second lesson of the Bhopal tragedy is how easy it has been for UCC to escape accountability. Pitted against the largely poor victims of the gas disaster was the hugely powerful and enormously rich multinational corporation, which escaped providing the survivors, their children and grandchildren with adequate compensation and medical care.

The catastrophic gas leak was the foreseeable result of innumerable operational failures at the plant, but from the start, UCC’s response to the disaster was inadequate and callous. For example, although thousands of people were dying from gas exposure, or suffering agonizing injuries, UCC withheld critical information regarding MIC’s toxicological properties, undermining the effectiveness of the medical response. To this day, UCC has failed to name any of the chemicals and reaction products that leaked along with MIC on that fateful night.”

“In 1989, without consulting Bhopal Gas Tragedy survivors, the Indian government and UCC reached an out-of-court compensation settlement for $470 million. This amount was less than 15 percent of the initial amount sought by the government, and far less than most estimates of the damage at the time. Thousands of claims were not registered at all, including those of gas-exposed children under the age of 18, and children born to gas-affected parents who, time later showed, were also severely affected.”

“There have been numerous attempts to hold UCC and individuals to account, either through criminal or civil claim proceedings launched in India and the U.S. But these have had no or very limited results.”

“One challenge has been created by the restructuring of the business entities involved in the tragedy. UCC sold off the India-registered subsidiary that operated the plant. It was then, in turn, bought by another giant U.S. corporation, the Dow Chemical Company (Dow). To this day, Dow shamefully claims it bears no responsibility since it “never owned or operated the plant” and that UCC only became a subsidiary of Dow 16 years after the accident.”

“In 2010, the Chief Judicial Magistrate’s Court in Bhopal found seven Indian nationals, as well as UCC’s India-based subsidiary guilty of causing death by negligence. By contrast, U.S. individuals and companies have escaped punishment, and there is significant evidence that the U.S. authorities have helped protect them.”

“Companies have a responsibility to respect human rights wherever they operate. Dow may not have caused the gas leak, but it became directly linked to the tragedy after it bought UCC. The company boasts of following the highest human rights standards, but its continued failure to respond to the urgent needs of the survivors is utterly disgraceful.”

“But there is a third lesson to draw from the Bhopal Gas Tragedy and its aftermath. It can be found in the inspiring story of the survivor groups and their supporters, who over 40 years have refused to give up their fight for justice. They have initiated or intervened in many legal actions; conducted scientific research into the contamination and health impacts; and they have launched practical initiatives in the absence of sufficient state and corporate support. For example, in 1994, survivor groups fundraised for the Sambhavna Trust Clinic and they later opened the Chingari Rehabilitation Centre. Thousands of gas- and contamination-affected adults and children have benefitted from the highly specialized and professional medical care and rehabilitation provided by these institutions – unparalleled by any of the government-run facilities.”

Continuing Chemical Accidents with Dependency on Petrochemicals
Less than a year after the Bhopal tragedy, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV. This time, at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA. A tank car ruptured, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River. Several hundred people were hospitalized after inhaling fumes. The chemical causes birth defects and fetal death and is a known mutagen, so the total impact on human health is unknown. However, the chemical sterilized a 41-mile stretch of the river, killing over a million fish and thousands of trees. Such events are not in the distant past, as shown by the derailment of about 50 out of 141 cars on the Norfolk Southern train that exploded in a towering fireball over the town of East Palestine, OH in February 2023. Among the compounds on board those cars were “inert” pesticide ingredients (vinyl chloride, ethylhexyl acrylate, and isobutylene), an antimicrobial compound (ethylene glycol monobutyl ether [EGBE]), benzene (a carcinogenic solvent), and butyl acrylate. In 2022, train accidents resulted in releases of hazardous chemicals 11 times. 

The incidents continue in 2024—including a chlorine leak from a fire at a BioLab facility near Atlanta, GA; hazardous materials released during the loading of a tractor-trailer at a hazardous waste processing facility in Coolidge, AZ that processes industrial wastes such as pesticides and other petrochemicals; and hundreds of facilities containing hazardous chemicals that were in the path of Hurricane Helene. 

These examples show that the harm caused by pesticides goes far beyond the impacts to consumers, farmworkers, other organisms, air, water, and soil caused by the application of those poisons, which are also extensive. We are all potentially affected. In some cases, the damages caused by use alone have been shown many times to be, in the words of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), “unreasonable adverse effects.”  

Organic growers know that soil biology and soil health are important to protect from diseases like citrus greening. The use of pesticides, on the other hand, destroys healthy soil biota. 

EPA must include the hazards of the manufacture, transportation, and disposal of pesticides in judging whether they pose “unreasonable adverse effects on the environment”—compared to the use of organic practices. 

>> Tell EPA that harm done in the manufacture, transportation, and disposal of pesticides must count as “unreasonable adverse effects.” Tell your Congressional Senators and Representative to support H.Res. 1604. 

Letter to the U.S. House of Representatives
I am writing to request that you cosponsor H.Res. 1604, “Recognizing the 40th year since the 1984 Bhopal chemical disaster and helping to ensure that no other community suffers another chemical disaster, by supporting the designation of December 3 as National Chemical Disaster Awareness Day,” introduced by U.S. Representative Pramila Jaypal. In addition to seeking governmental engagement with “the survivors of the Bhopal chemical disaster to strengthen the public’s understanding of the dangers of chemical disasters,” the Resolution calls for U.S. support of India’s requests regarding the Dow Chemical facility in Bhopal where the explosion occurred and take actions necessary to comply with obligations under the Treaty on Mutual Legal Assistance in Criminal Matters, signed at New Delhi on October 17, 2001.

Forty years ago this month, a Union Carbide plant in Bhopal, India released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic diseases range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. 

Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert” pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate. 

The incidents continue in 2024—including a chlorine leak from a fire at a BioLab facility near Atlanta, GA; hazardous materials released during the loading of a tractor-trailer at a hazardous waste processing facility in Coolidge, AZ that processes industrial wastes such as pesticides and other petrochemicals; and flooding of hundreds of facilities containing hazardous chemicals that were in the path of Hurricane Helene.

Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. 

Organic growers know that soil biology and soil health are important to protection from diseases like citrus greening. The use of aldicarb, on the other hand, destroys healthy soil biota.

Please ensure that EPA includes the hazards of the manufacture, transportation, and disposal of pesticides in judging whether they pose “unreasonable adverse effects on the environment”—compared to the use of organic practices. 

Again, please join with Rep. Jaypal in cosponsoring H.Res. 1604.

Thank you.

Letter to the U.S. Environmental Protection Agency
Forty years ago this month, a Union Carbide plant in Bhopal, India released a cloud of highly toxic methyl isocyanate (MIC) gas in the middle of the night, killing thousands of people immediately—estimates range from 1754 to 10,000—and up to 20,000 subsequently. Estimates of the number suffering permanent disabilities or chronic diseases range up to 500,000. MIC is a precursor used in the manufacture of carbamate insecticides, including aldicarb, carbofuran, and carbaryl. 

Less than a year later, a cloud containing aldicarb oxime—which is combined with MIC to make aldicarb—leaked from a Union Carbide plant in Institute, WV, and at least 135 residents were treated for eye, throat, and lung irritation. In 1991, seven cars of a freight train derailed near Dunsmuir, CA, dumping 19,000 gallons of the soil sterilant metam sodium into the Sacramento River, resulting in the hospitalization of several hundred people, with unknown future impacts from birth defects, fetal death, and mutations. Miles of the river were sterilized, killing over a million fish and thousands of trees. In February 2023, about 50 out of 141 cars on a Norfolk Southern train exploded in a towering fireball over East Palestine, OH. Among the compounds on board those cars were “inert” pesticide ingredients, an antimicrobial compound, benzene, and butyl acrylate. 

The incidents continue in 2024—including a chlorine leak from a fire at a BioLab facility near Atlanta, GA; hazardous materials released during the loading of a tractor-trailer at a hazardous waste processing facility in Coolidge, AZ that processes industrial wastes such as pesticides and other petrochemicals; and flooding of hundreds of facilities containing hazardous chemicals that were in the path of Hurricane Helene.

Thus, the harm caused by pesticides goes far beyond the impacts caused by the application of those poisons, which are also extensive. We are all potentially affected. 

Organic growers know that soil biology and soil health are important to protection from diseases like citrus greening. The use of pesticides, on the other hand, destroys healthy soil biota.

EPA must include the hazards of the manufacture, transportation, and disposal of pesticides in judging whether they pose “unreasonable adverse effects on the environment”—compared to the use of organic practices.

Thank you.

(Beyond Pesticides, December 6, 2024) On December 2, the U.S. Environmental Protection Agency (EPA) announced yet another milestone in the convoluted life span of the insecticide chlorpyrifos. Under the deceptive headline “EPA Proposes Rule to Revoke Most Food Uses of the Insecticide Chlorpyrifos,” EPA stated that it is improving environmental protection by revoking all usages of chlorpyrifos except for 11 food and feed crops. The proposal was deemed “unconscionable” by Beyond Pesticides executive director Jay Feldman in an article in The New Lede.

EPA claims this plan would reduce annual chlorpyrifos application by 70% compared to “historical usage.” Chlorpyrifos is a known neurological and reproductive toxicant. EPA has been cutting back on approved uses for years but is far behind other environmental authorities—the European Food Safety Authority and Thailand have banned it altogether, and California has banned its agricultural use.

The trouble with EPA’s latest attempt is that it does nothing to clarify and rationalize EPA’s process, and it will not protect the public, because those 11 remaining products are among the most extensively grown and used in the world: soybeans, sugar beets, cotton, wheat, apples, citrus fruits, strawberries, alfalfa, cherries, peaches, and asparagus.

Chlorpyrifos is an organophosphate chemical. These compounds inhibit acetylcholinesterase (AChE), which regulates nerve signals in all invertebrates and vertebrates. Thus, there is no justification for the assumption that what harms insects will not harm humans. The lethal dose in newborn rats is 100 times lower than in adult animals. EPA has known for decades that chlorpyrifos (introduced in 1965) is a neurotoxicant, especially at crucial developmental stages, such as prenatal and infancy phases when the human brain is growing at its fastest rate. In 2016 EPA said children between one and two years old were being exposed via food to 14,000% of the risk concern level.

While AChE inhibition produces well-documented problems including attention and IQ deficits, lower birth weight, working memory loss, and motor development delays, there has also been evidence at least since the 1990s that chlorpyrifos also affects other neural pathways. For example, it can produce changes not just in the brain but in the digestive system.

The EPA’s new policy stems from decades of waffling and delay, in which industry influences sowed doubt about epidemiological evidence of health harms and emphasized uncertainties about data, particularly regarding drinking water exposure. Activists and agricultural workers, mostly in California, grew tired of waiting for health protections and filed suit against the EPA in 2007. It took until 2021 for the case to be decided by the Ninth Circuit Court of Appeals.

That court, frustrated by EPA’s indecisiveness and contradictions, ordered the agency to decide, within 60 days of its ruling, how toxic chlorpyrifos is and either revoke its food residue tolerances or declare that they are actually safe. In response, and to the surprise of the registrants and growers, EPA issued a final rule in August 2021, revoking all tolerances for chlorpyrifos. This upset the pesticide industry, which then backed a suit by growers’ associations in the Eighth Circuit Court of Appeals.

The Eighth Circuit reversed the Ninth Circuit’s decision in November 2023 and remanded the case back to the EPA for “further proceedings.” See our November 2023 Daily News analysis. In the Eighth Circuit case, plaintiffs emphasized how unreasonable the Ninth Circuit’s 60-day deadline appeared, despite the fact that the Ninth Circuit litigation had been dragging on for 14 years.

EPA’s most recent move is clearly the result of industry pressure. Interestingly, in light of recent political shifts, CropLife International’s (chemical industry’s trade group) 2022 amicus brief in the Eighth Circuit litigation argued that the EPA had failed to use its statutory authority properly—that is, a supposedly independent executive branch agency had the legal standing to make firm decisions based on its own expertise—an approach that does not comport with this year’s U.S. Supreme Court decision in Chevron v. Natural Resources Defense Council weakening this very authority.

There is a great deal of murkiness in EPA’s documents, which becomes nearly impenetrable in some of the agency documents issued after the Ninth Circuit case concluded. However, both cases focused heavily on two relatively clear EPA documents from 2016: the Chlorpyrifos Revised Human Health Risk Assessment for Registration Review and the Chlorpyrifos Refined Drinking Water Assessment for Registration Review. These two documents indicate firmly that EPA had serious worries about dietary exposures, which include both food and drinking water, for many years.

The Eighth Circuit plaintiffs tried to keep consideration of residues in food separate from drinking water exposures, even though the Ninth Circuit panel had noted that the Federal Food, Drug and Cosmetic Act requires considering food and water exposures together. EPA has previously explained its approach with a “risk cup” metaphor, saying “each use of the pesticide contributes a specific amount of…risk to the cup….[A]s long as the cup is not full, meaning that the combined total of all estimated sources of exposure to the pesticide has not reached 100% of the [tolerable daily exposure over a lifetime], EPA can consider registering additional uses and setting new tolerances. If it is shown that the risk cup is full, no new uses could be approved until the risk level is lowered.” In the Revised Human Health Risk Assessment, EPA stated that “this assessment indicates that dietary risks from food alone are of concern” and “after accounting for food exposures” there is no room for water in the risk cup. Moreover, based on model simulations, the Refined Drinking Water Assessment found that concentrations in drinking water might exceed 100 μg/L, an unsafe level. The World Health Organization’s 2022 guideline for a maximum level of chlorpyrifos in drinking water is 30 μg/L. Yet the Eighth Circuit plaintiffs repeatedly suggested that data about drinking water exposures was unreliable, convincing EPA to rely on water modeling data provided by registrants.

Trying to separate food from water exposure is bizarre because combined exposures affect everyone, and the people most exposed to chlorpyrifos—workers and other people living in agricultural areas—certainly must consume both food and water (like everyone else), and their regions certainly qualify as “vulnerable watersheds.”

EPA continues to insist that evidence of neurological damage remains inconclusive and that food and drinking water residues will require considerably more research before it can possibly decide what to do about chlorpyrifos. “With decisions like [this month’s] in the aggregate,” Mr. Feldman stated in The New Lede article, “The toxic load to people and the environment is unsustainable. The decision announced today reflects a failure of both the underlying law and a history of negotiations that fail to fully document the multidimensional catastrophic impact of pesticide use on health, biodiversity, and climate.” Beyond Pesticides advocates restoration of soil health and elimination of pesticides to cope with imbalances in biodiversity that lead to pest infestations. Organic regenerative agriculture is a far better way to reverse these declines, clean up water pollution, reduce antibiotic resistance, improve the nutritional value of food that has been degraded by synthetic pesticides and fertilizers, and support critical ecosystems that provide environmental services for the biosphere.

But the grip of chlorpyrifos is not yet loosened. According to EPA’s news release of December 2, the next step is for the agency to issue yet another amended Proposed Interim Registration Review Decision in 2026. In the meantime, advocates must continue to push back at the political winds threatening to derail environmental and health values altogether.

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

Sources:

EPA takes partial step to ban chlorpyrifos in a move called “unconscionable”
By Carey Gillam
The New Lede December 2, 2024
https://www.thenewlede.org/2024/12/epa-takes-partial-step-to-ban-chlorpyrifos-in-a-move-called-unconscionable/

EPA Proposes Rule to Revoke Most Food Uses of the Insecticide Chlorpyrifos
December 2, 2024
https://www.epa.gov/newsreleases/epa-proposes-rule-revoke-most-food-uses-insecticide-chlorpyrifos

Opinion
League of United Latin American Citizens et al. v. Michael S. Regan and USEPA
Ninth Circuit Court of Appeals
April 29, 2021
https://caselaw.findlaw.com/court/us-9th-circuit/2125208.html

Opinion and Order to vacate and remand
Red River Valley Beetgrowers et al v. Michael S. Regan and USEPA
Eighth Circuit Court of Appeals
November 2, 2023
https://caselaw.findlaw.com/court/us-8th-circuit/115405158.html

Chlorpyrifos: Revised Human Health Risk Assessment for Registration Review
USEPA November 3, 2016
https://downloads.regulations.gov/EPA-HQ-OPP-2015-0653-0454/content.pdf

Chlorpyrifos Refined Drinking Water Assessment for Registration Review
USEPA April 14, 2016
https://downloads.regulations.gov/EPA-HQ-OPP-2015-0653-0437/content.pdf

Celebrated 2021 Ag Ban of Deadly Pesticide, Chlorpyrifos, Reversed by Court Despite Decades of
Review and Litigation
Beyond Pesticides Nov 14, 2023
https://beyondpesticides.org/dailynewsblog/2023/11/2021-ag-ban-of-deadly-pesticide-chlorpyrifos-reversed-by-court-despite-decades-of-review-and-litigation/

Scientific Literature Review Again Links Pesticides to a Range of Illnesses and Ecological Decline
Beyond Pesticides, September 4, 2024
https://beyondpesticides.org/dailynewsblog/2024/09/scientific-literature-review-again-links-pesticides-to-a-range-of-illnesses-and-ecological-decline/

(Beyond Pesticides, December 5, 2024) A novel, comprehensive study published in Science reviews a library of 1,024 different chemicals (herbicides, insecticides, fungicides, and plant inhibitors) finding that, even at “sublethal” exposure levels, 57% of tested chemicals impact the behavioral and physiological health of house fly larvae. Mosquito and butterfly populations are also susceptible to long-term adverse effects at sublethal levels.

Environmental and public health advocates continue to raise concerns about adverse effects resulting from the failure of the U.S. Environmental Protection Agency (EPA) to consider cumulative exposure (resulting in aggregate and synergistic effects) across different mechanisms of toxicity and different classes of pesticides, including at exposure levels below allowable levels set by the agency.

In the context of the regulatory gaps and pesticide industry influence at EPA (See Daily News here), advocates stress the importance of transitioning land and agricultural practices to organic principles.

Methodology and Results 

Background, Goals, Primary Takeaways 

This research was led by an international team of experts from various universities and institutes, including European Molecular Biology Laboratory (EMBL), Institut Pasteur, and Heidelberg University (Center for Infectious Diseases, Parasitology Department). The authors received funding from the European Molecular Biology Laboratory, the German Center for Infection Research, and the American Society of Colon and Rectal Surgeons Research Foundation.

“[K]ey traits—such as egg-laying rates— were significantly reduced by some of these molecules at concentrations that are orders of magnitude below sublethal concentrations (),” says the researchers. “Higher temperatures also increased pesticide-induced lethality and behavioral changes (), which emphasizes the need for chemical testing under realistic environmental conditions, especially given rising global temperatures.” 

There are several additional notable findings that researchers cite for future study: 

• “Our findings highlight that many agrochemicals with high environmental prevalence can induce behavioral changes across insect species, even at sublethal levels.” 

• “Therefore, our findings suggest that the next generation of pesticides should be subjected to more comprehensive testing focused on sublethal effects across different representative species. Notably, these types of assays provide more precise data on how to target pest control for medically important vector species without negatively affecting overall insect biodiversity.” 

Drosophila larvae 

The main insect species of interest in the study was Drosophila melanogaster, acknowledged by researchers as “an insect model system for toxicology studies.” Drosophila was exposed to various chemical residue mixtures at several concentrations (2 mM, 20 mM, and 200 mM) to “assess the effects of these [chemical] molecules on larval behavior, physiology, and fitness.” Concentrations of 20 mM and 200 mM are expected for typical chemical-intensive farming operations, with the lowest concentration being the expected presence of the chemical in nature due to run-off.

To confirm the potential sublethal impacts of pesticides, researchers also tested the larvae with five pesticides at an even lower concentration (0.2 mM). While there was variability in the degree of acute harm caused by the chemicals of focus, researchers determine that “all pesticides significantly affected larval behavior at this lower concentration [of 0.2 mM].” The researchers in this study elaborate on the following conclusions: 

• “For example, glyphosate—a widely used herbicide across the world () that is not lethal at 0.2 mM ()—increased the frequency of turns (headcasting) and decreased stops, altering larval trajectories (). Only chlorpyrifos, the most toxic compound (), caused broad changes in protein levels. However, all but 1,2-dibromoethane altered the protein phosphorylation status in the treated larvae ()—including those that are not lethal at the concentration used ().” 

• “Although the developmental delay is within the expected variation among natural populations, the effect on egg laying goes beyond the physiological range measured in the above-described wild-type strains.” 

An additional area of concern that researchers identify is the heightened potential for damage of insects by pesticides. “[M]any pesticides that showed low lethality (<10%) at 25°C started exhibiting significantly higher lethality when the environmental temperature was increased by just four degrees,” the researchers provide an example. “For example, the insecticide lindane, nonlethal at 0.2 mM at 25°C (0%), became strongly lethal (79%) at 29°C. Although many molecules altered behaviors at 25°C, the changes at 29°C were often radically different.” 

The researchers also identified “nonlinear interactions” between a number of the targeted pesticides, “which suggests that synergistic pesticide interactions may be widespread.”

Mosquitoes and Butterflies 

The researchers extrapolate their findings beyond one type of house fly to include other “medically and economically relevant species,” including the mosquito Anopheles stephensi and the butterfly Vanessa cardui.

For testing adverse health impacts of pesticide exposure on mosquito populations, the researchers say, “[L]arvae were exposed overnight to varying concentrations of a neonicotinoid (thiacloprid), a pyrethroid (cyhalothrin), and a fungicide (dodine) on multiwell plates followed by recording and tracking their movement ().” “All pesticides caused larvae to move significantly slower at concentrations with negligible or low lethality (),” they continue. 

For testing the adverse health impacts of pesticide exposure on butterfly populations, caterpillars consumed food that contained traces of thiacloprid, cyhalothrin, and dodine. “Although only cyhalothrin showed some lethality (), all three molecules affected the movement patterns of the treated caterpillars (),” the researchers conclude.

“These results highlight that sublethal concentrations of pesticides can also affect the behavior of species with high ecological, economic, and clinical relevance.” 

Previous Daily News Coverage 

Environmental advocates concerned about biodiversity acknowledge the substantial, peer-reviewed scientific literature on ecosystem integrity under threat.  

A 2020 report published in Science determined that about one-quarter of the global insect population has died off since 1990. In 2022, researchers in the United Kingdom determined that “58.5% fewer flying insects” were caught on windshield wipers between 2004 and 2021, which they viewed as an indicator of systemic insect and pollinator deaths. In a 2019 study published in Biological Conservation, researchers identified “the dreadful state of insect biodiversity in the world, as almost half of the species are rapidly declining and a third are being threatened with extinction.”  

Scientists have spoken out, with over 70 scientists submitting a letter to the editor in Nature Ecology & Evolution in 2020 with a compilation of solutions necessary to curb the impending insect apocalypse. A research report in 2020 published in Nature by scientists at the University College London determined, among various findings, that the interaction between climate change () and high-intensity agriculture diminished total insect abundance by 50%, and species richness by 27%. See a review of recommended policies and practices to safeguard insect biodiversity published in Conservation Science and Practice. 

For more information on the link between petrochemical-pesticide reliance and insect die-offs, see the 2019 Pesticides and You report, Study Cites Insect Extinction and Ecological Collapse. Advocates nationwide have called upon Congress and EPA to update pesticide drift protection policy to protect families of farmworkers, schoolchildren, and other vulnerable subpopulations who face disproportionate harms of pesticide exposure. (See Action of the Week here).  

Call to Action 

Environmental and public health advocates, as well as farmers and fenceline communities, are concerned with the adverse health impacts of long-term pesticide use on their local environments.

“The loss of any insect species impacts overall biodiversity and upsets the balance of critical food webs,” says Sara Grantham, science, regulatory, and advocacy manager at Beyond Pesticides. “There is a wide body of science linking pesticide exposure to negative impacts on insects and other beneficial organisms, which are necessary in providing essential ecosystem services such as pollination. Population effects in these species threaten agricultural productivity and food security, as well as puts us one step closer to the very real threat of insect extinction.”

To access more peer-reviewed scientific literature on biodiversity issues, see the Pesticide-Induced Disease Database on biodiversity, beneficial insects, and pollinators. For more coverage and analysis of scientific literature and policy updates, see the Daily News section on biodiversity here. 

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

Source: Science 

(Beyond Pesticides, December 4, 2024) According to interviews conducted by Farm Progress, the U.S. organic food supply chain has been under pressure to come into compliance with the U.S. Department of Agriculture (USDA)’s March 19, 2024, Strengthening Organic Enforcement (SOE) final rule (See Daily News here). “We are now seeing up to 95 percent of NOP (National Organic Program) import certificates that are coming in are valid, which means that we really closed the gap on products coming into the United States without an import certificate,” says Jennifer Tucker, PhD, deputy administrator for USDA National Organic Program (NOP). “We really closed the door on illegitimate shipments.”

Organic advocates welcome accountability measures to ensure the integrity of organic certification in the spirit of continuous improvement, which is regarded as a tenet of the Organic Food Production Act (OFPA). As communities and businesses across the country anticipate a change in decision-making philosophy regarding the role of federal intervention in the marketplace, environmental and public health advocates remain clear-eyed on the importance of improving the regulatory system to advance public health, biodiversity, and climate.

Concerns Raised by Organic Supply Chain

The National Organic Coalition, with member groups including Beyond Pesticides, summarizes the five core changes that the SOE rule establishes for organic standards:

1. “Regulatory changes to require import certificates and additional handling operations to become certified.
2. Codification of the requirement that certifiers conduct unannounced inspections for a minimum of 5% of the operations they certify annually.
3. Consistent implementation of existing and additional record-keeping requirements for operations and certification agencies to ensure traceability.
4. A requirement that certifiers conduct supply chain audits for high-risk operations.
5. Requirements for certified operations to develop fraud prevention plans.”

According to reporting, farmers, certifiers, and other members of the organic supply chain are expressing concern at the rollout of the new regulations with its associated requirements. Farmers have voiced concerns about the significant amount of work hours that have to be allocated to prepare for implementation of SOE to ensure that they are up to code operating as part of complex, international supply chains. At the same time, organic certifiers are raising their fees for certification to cover the cost of additional training and staff time, given the increase in frequency and depth of inspections. In preparation for the SOE rule going into effect, NOP offered additional educational resources through its Organic Integrity Learning Center. Additionally, there has been a doubling of NOP staff since 2017 when high-profile instances of organic fraud emerged in the marketplace. See Daily News here for an analysis of some of these fraud claims, investigations, and legal consequences.

Strengthening Organic Enforcement Rule

The new requirements in the final SOE rule aim to strengthen the integrity of the organic label through enhanced oversight and enforcement of existing program regulations, and the introduction of new requirements to address occurrences of fraud in organic supply chains. As the Agricultural Marketing Service (AMS) lays out in a 2023 announcement, the rule is expansive in covering a range of regulatory topics, including:

• “[A]pplicability of the regulations and exemptions from organic certification;
• National Organic Program Import Certificates;
• recordkeeping and product traceability;
• certifying agent personnel qualifications and training;
• standardized certificates of organic operation;
• unannounced on-site inspections of certified operations;
• oversight of certification activities;
• foreign conformity assessment systems;
• certification of producer group operations;
• labeling of nonretail containers;
• annual update requirements for certified operations;
• compliance and appeals processes; and
• calculating organic content of multi-ingredient products.”

The Federal Register notice of the SOE asserts that the rulemaking is designed to “strengthen oversight and enforcement of the production, handling, and sale of organic agricultural products.” It continues, “The amendments protect integrity in the organic supply chain and build consumer and industry trust in the USDA organic label by strengthening organic control systems, improving farm-to-market traceability, and providing robust enforcement of the USDA organic regulations.” Reporting by The Washington Post notes, “Key updates to the rules include requiring certification of more of the businesses, such as brokers and traders, at critical links in organic supply chains. It also requires organic certificates for all organic imports and increases inspections and reporting requirements of certified operations.”

First, all members of the supply chain are now required to have certification (including brokers, exporters, and traders, among others), although there are also additional exemptions for certain “low-risk activities” including facilities that have minimal responsibilities, such as processing and packaging goods.

Second, all certified organic products imported into the U.S. must be declared to U.S. Customs and Border Patrol using data from NOP Import Certificates. Certifiers rely on these certificates, housed within the NOP Organic Integrity Database (INTEGRITY), to track compliance.

Third, each member of the supply chain must maintain records and establish fraud prevention plans to ensure there are zero gaps in accountability.

Fourth, non-retail containers (a.k.a containers that store organic products before entering a retail or purchasing location) must have the organic seal to ensure accountability.

Fifth, digital organic certifications entered into the INTEGRITY system must have a standardized format and data fields to ensure standardized compliance.

Sixth, the definition change from grower groups to “producer group operations,” when accounting for imports of organic products from groups of individual producers who decide to export to the U.S. as a collective unit, is intended to standardize the quality of organic products in non-U.S. and European Union contexts. This includes the addition of a requirement that these farmer groups must incorporate binding internal control systems (ICSs) as a fixture of their operational structures. IFOAM-International describes ICSs as:

“[T]he part of a documented quality assurance system that allows an external certification body to delegate the periodic inspection of individual group members to an identified body or unit within the certified operator. This means that the third party certification bodies only have to inspect the well-functioning of the system, as well as to perform a few spot-check re-inspections of individual smallholders.”

Advocates view this shift to strengthening definitions and binding force of internal control systems as an opportunity to strengthen organic integrity and ensure long-term smooth adoption across different cultural and market contexts. There will be a future Daily News delving into changes in EU and U.S. laws going into 2025 on definitions around internal control systems (ICSs) and producer groups.

Seventh, organic inspectors will now be required to conduct unannounced on-site inspections of at least 5% of all operations they certify each year; they will also need to engage in “traceability audits.”

See deeper analysis by SCS Global Services, an international third-party certification entity, here. See here for a comparative guideline for regulations pre- and post-SOE developed by the Agricultural Marketing Service.

Call to Action

Organic advocates are concerned that the burdens imposed on organic farmers through high certification costs, as well as upfront expenses that come with transitioning and maintaining organic land management systems including soil testing, training, and marketing/transportation, should not fall on farmers. “Organic farming should be a public good that is treated as such through federal agricultural support programs in the Farm Bill,” says Max Sano, organic program associate at Beyond Pesticides.

See Action of the Week, Tell Congress to ensure that organic programs, and their funding, do not lapse this fall, to inform your elected officials what is at stake.

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

Source: Farm Progress

(Beyond Pesticides, December 3, 2024) In an article in Science, Sabrina Rondeau, PhD reviews her research from 2022-2024 showcasing species of ground-nesting bees, often found in crop fields, that are highly vulnerable to soil pesticide residues and subsequently suffer population declines. Dr. Rondeau, a postdoctoral fellow in the Department of Biology at the University of Ottawa, points to regulatory deficiencies, specifically in environmental risk assessments (ERAs), and the detrimental effects of pesticides on pollinators that threaten food security and biodiversity.

“Modern intensive agriculture faces a critical paradox: The very pesticides designed to protect our crops endanger essential pollinators that sustain their productivity,” Dr. Rondeau says in the article. Her research (see here, here, here, here, here, and here) identifies important gaps overlooked in current assessments and regulations for bee species, including the common eastern bumble bee (Bombus impatiens) and the hoary squash bee (Xenoglossa pruinosa). Bumble bee queens in temperate climates hibernate for 6-9 months in the soil, while the hoary squash bee is a solitary ground-nesting species. Reference additional Daily News coverage on ground-nesting bees here and here.

“‘Our findings show that over 70% of wild bee species, which are crucial for pollinating our food crops, face significant risks from pesticide residues in soil—a threat current regulations overlook,’ says Dr. Rondeau” in a news release. See additional coverage on soil pesticide residues here, here, and here.

In reflecting on one study, Dr. Rondeau shares, “I generated the first field exposure estimates for overwintering bumble bee queens to pesticide residues in agricultural soils. I identified high risks of exposure to multiple pesticide residues for bumble bee queens that overwinter in agricultural soils in eastern Canada, especially in apple orchards. Orchard soils at suitable overwintering sites contained mixtures of up to 29 pesticides, and 95% of samples contained at least one insecticide, herbicide, and fungicide.” This study highlights the extent to which ground-dwelling bee species can be exposed to a multitude of pesticides.

In this experiment, “newly emerged bumble bee queens were offered numerous boxes of soil treated with different pesticides, alongside untreated soil, within large mesh-covered enclosures.” The bumble bee queens “were seemingly attracted to pesticide-contaminated soils. This apparent preference increases their likelihood of exposure to and potential risk from pesticide residues while they overwinter underground,” Dr. Rondeau states.

In another study, size-dependent effects are noted for bumble bee queens exposed in soil applied with the broad spectrum insecticide cyantraniliprole. The results indicate that queens that are heavier exhibit increased mortality, delayed brood emergence, and smaller offspring. Dr. Rondeau concludes that, “These larger queens likely face greater vulnerability to cyantraniliprole because of their greater muscle mass (cyantraniliprole disrupts insect muscle function), greater surface area in contact with soil, and lower metabolic detoxification capacity. My findings suggest that cyantraniliprole impairs heavier queens’ ability to feed their brood and highlight potential cascading impacts on bumble bee populations, as larger queen size is key to successful overwintering and colony establishment in the spring.”

Lastly, female squash bees show reduced pollen collection with fungicide exposure to a product containing azoxystrobin and difenoconazole, while coexposure to the insecticide flupyradifurone with the fungicide “synergistically induced hyperactivity and reduced the number of offspring that emerged from each nest,” Dr. Rondeau states. “These results highlight potentially serious consequences for squash bees,” she concludes, noting that “reduced offspring production per nest due to pesticide coexposure could contribute to population declines.”

ERAs are meant to assess agrochemicals, leading to regulatory approval for only those that pose low environmental risks. Yet, there is a wide body of science that highlights adverse effects on critical pollinator species from pesticides on the market. Current ERAs fail to adequately protect these organisms, as they rely on studies with specific model species to reflect the risks for all species. The U.S. Environmental Protection Agency (EPA) primarily focuses on the western honey bee (Apis mellifera), the differing exposure and subsequent effects experienced by other species are disregarded.

“[W]hereas most of the world’s 20,000+ bee species are solitary, honeybees live in large colonies that benefit from social detoxification strategies, which buffer pesticide impacts,” Dr. Rondeau says. She continues, “Failures to detect and document pesticide impacts on wild bees arise from multiple other deficiencies, which include incomplete consideration of potential long-term and sublethal effects, overlooked exposure routes specific to wild bees, and failures to account for possible coexposure to multiple pesticides.” See more on EPA failures here, here, here, and here.

A wider range of bee taxa needs to be considered in risk assessments to better protect all vital pollinators. As previously covered by Beyond Pesticides, pesticide sensitivity varies greatly between species. Relying on a single species to determine risks to all bees is negligent on the part of regulatory agencies. What is considered “low toxicity” for one species can be highly lethal for another.

As an alternative to harmful petrochemical pesticides, methods for crop protection can consider pollinator preservation, which in turn protects food security and biodiversity, by employing strategies for organic land management. As Dr. Rondeau states, “My research reveals a clear potential for ground-dwelling bees to be affected by field-realistic (co)exposure to soil pesticide residues. These findings urgently call for a reassessment of global pesticide regulations to create a safer, more sustainable agricultural future that protects both our crops and the pollinators they rely on.”

Organic agriculture is the solution that not only eliminates exposure to toxic synthetic pesticides for pollinators, including ground-nesting bees, but it also supports soil health and the health of all organisms, including humans. In previous coverage, Beyond Pesticides reports how researchers find that organic farming provides the highest benefit to bees, as organic practices lead directly to lower parasite load and higher colony growth.

See more on the benefits of organic land management here, as well as options for least-toxic control of pests with ManageSafe™. Make The Safer Choice to avoid hazardous home, garden, community, and food use pesticides, and learn about Eating with a Conscience by choosing organic food to protect health and the environment.

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

Source:

Rondeau, S. (2024) Digging below the surface: Hidden risks for ground-nesting bees, Science. Available at: https://www.science.org/doi/10.1126/science.adt8998.

(Beyond Pesticides, December 2, 2024) An international team of researchers has found that organic farming increases the quantity and diversity of crop plant microbiota, further safeguarding crops with enhanced pathogen resistance. Their recent study, published in Plants, People, Planet, builds on the legacy of decades of peer-reviewed research and centuries of agricultural systems that do not rely on toxic, petrochemical-based products (e.g., fertilizers, pesticides, etc.) as the driving force for agricultural productivity. As many analysts express concern that the incoming administration will increase the promotion of petrochemicals in domestic food production and eschew regulations to curtail their use, organic advocates and farmers remain committed to transforming agricultural and land management systems that reject chemical dependency, which is escalating the existential threats to biodiversity, public health, and the climate.

Goals, Methodology, and Background

The authors of this study are researchers at Université de Rennes, Université de Paris-Saclay, L’Institut Agro Rennes-Angers, European Society for Agronomy, France’s National Research for Agriculture (INRAE), and Nanjing Agricultural University in Nanjing, Jiangsu, China. The goal of this study was to compare the effects of organic with chemical-intensive agricultural plots on microbial life on winter wheat roots. Winter wheat was selected because of the projected increase in global demand and consumer interest in wheat products that are grown in environmentally responsible systems. The authors tested the four following hypotheses:

1. “[O]rganic farming changes microbial community composition and species interactions and results in more diverse microbial assemblages than conventional farming ();
2. [T]his effect is related to changes in management practices, soil properties, and/or plant diversity ();
3. [C]hanges in microbiota affect host plant reproduction and resistance to pathogens (); [and]
4. We expected responses to be more pronounced in May than in March due to the effects of the different farming systems during plant development that would increase divergences in microbiota composition.”

The researchers conducted this study on forty winter wheat fields at “Zone Atelier Armorique,” also known as the Long-Term Socio-Ecological Research (LTSER) site in north-western France. Twenty of the fields are organically managed and the other twenty are not. The environmental and agronomic data includes surveys of the land management practices, soil, and plant and cultivar types. The bacterial and fungal microbiota were sampled from “six individual wheat plants in each field (40 fields) at two dates (mid-March—vegetative stage and the end of May—early reproductive stage of wheat).” Each sampling campaign, March and May, evaluated 240 samples. Wheat fitness is measured by the plant samples’ reproductive capacity and pathogen resistance, which was pulled from the 240 samples gathered in May, at which point they “had all completed their reproductive phase.” The authors state, “We then calculated the mean total number of seeds per field as the mean number of seeds of the six individual wheat plants [gathered from each field.]”

“All the analyses were performed in 35 fields for fungi; in 34 fields for bacteria in March and in 29 fields for bacteria in May because information concerning agricultural management was lacking for three fields out of 40, and insufficient description of bacteria and fungi microbiota for one field out of 40 for bacteria in March; and for five fields out of 40 for bacteria in May. Consequently, only fields for which all variables were available were included in the analyses,” says the researchers. The bacteria tested in this study include Acidobacteria, Actinobacteria, Bacteroidetes, Firmicutes, Alphaproteobacteria, Deltaproteobacteria, and Gammaproteobacteria. Meanwhile, the fungi analyzed in this study include Ascomycota, Basidiomycota, Chytridiomycota, Glomeromycotina, and Zygomycota.

Results and Discussion

The researchers analyzed the effects of agricultural management practices, soil characteristics, and plant diversity on bacterial and fungal entities independent of one another before analyzing them in full. The bottom-line argument: “The present study provides a better understanding of the effect of organic farming on plant-associated microbiota and stresses the importance of soil characteristics and management in shaping microbiota composition and diversity. It also highlights the fact that plant seed production and resistance to pathogens are related with particular microbial assemblages. More specifically, Alphaproteobacteria and Glomeromycotina were seen to be key phyla in mediating wheat fitness, while also responding to environmental parameters.” In this study, Glomeromycotina has a statistically significantly higher degree of richness in organic fields in both March and May.

The researchers also found that the most significant richness of all bacteria and fungi is identified in organically managed farmland relative to conventional fields in the month of May. Soil properties, including carbon, nitrogen, pH level, organic matter content, and proportion of clay and coarse silt, do influence the bacteria and fungi composition of all fields regardless of when sampled.

“The positive effect of organic farming on microbial diversity was more pronounced in May than in March for both fungi and bacteria, while an early effect on bacterial composition was detected in March,” say the researchers. This is one of the study’s main conclusions,  which they attribute in part to “the cumulative effect of phytosanitary products and nitrogen inputs during crop growth.”

“Indeed, under organic farming, no phytosanitary products are used on wheat, and nitrogen inputs are lower despite the use of organic manure () (). In all responding phyla, as expected, increasing nitrogen and phytosanitary inputs had a detrimental effect on species richness and shaped sequence-cluster composition (),” the researchers explain as the beneficial impacts of the low-to-zero input approach of organic farming systems.

Organic Farming as a Driver of Soil Health

There are numerous peer-reviewed studies highlighting the importance of organic farming practices and methods for biodiversity at all scales, from microbial to planetary health.

A 2024 study published in Agriculture, Ecosystems, and Environment finds the perpetual use of pesticide-coated seeds and tillage changed the composition of various beetle, spider, and other epigeal arthropod communities on New Hampshire farmland. In Rodale Institute’s landmark Farming Systems Trial – the longest-running, multidecade investigation comparing organic and chemical-intensive grain production in North American farmland – researchers arrived at the following outcomes (See Daily News here.):

1. Organic systems achieve 3–6 times the profit of conventional production;
2. Yields for the organic approach are competitive with those of conventional systems (after a five-year transition period);
3. Organic yields during stressful drought periods are 40% higher than conventional yields;
4. Organic systems leach no toxic compounds into nearby waterways (unlike pesticide-intensive conventional farming);
5. Organic systems use 45% less energy than conventional ones; and
6. Organic systems emit 40% less carbon into the atmosphere.

Researchers at Kansas State University corroborate some of the findings determined by Rodale Institute in a 2024 study published in Soil Science Society of America Journal, finding direct evidence that organic amendments (e.g., manure and compost) in a no-till agricultural system “facilitat[e] microbial diversity” that cycles plant-available nutrients. Organic banana production in Martinique are found to have 55% higher mean plant species richness and 79% greater soil weed cover in organic fields, according to a 2024 study published in Applied Soil Ecology. In the same study, the presence of earthworms, macrofauna, and other decomposers was much higher in organic fields, indicating the enhanced microbial life in organic farming systems. For additional Daily News coverage on soil microbial health and organic practices, see here, here, here, and here.

Call to Action

See the Action of the Week, Tell U.S. Department of Agriculture (USDA) to Expand Organic Dairy Product Promotion (ODPP) Program to All-Organic Lunches, to demand USDA and Congress mandate organic dairy products in the National School Lunch Program given the recent $15 million investment in ODPP through the Commodity Credit Corporation.

See Keeping Organic Strong to learn about the variety of issues that arise at statutorily mandated, biannual National Organic Standards Board (NOSB) meetings. Beyond Pesticides submits comments on all issues before the NOSB, and includes on our website guidance for the general public on engaging in the public input process to ensure the integrity of organic standards, as well as vital add-on labels such as Real Organic Project and Regenerative Organic Certified (Regenerative Organic Alliance).

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

Source: Plants, People, Planet

(Beyond Pesticides, November 27 – December 1, 2024) This Thanksgiving, as we navigate a new chapter in our nation’s history, the staff and board of Beyond Pesticides are honored and thankful to partner with and support those leading campaigns, from small to large, that are essential to our livable future. Local communities are where change happens, creating examples of practical solutions for the nation and world.  

• We believe deeply in the power of people and organizations, armed with scientific information and models for change, to push for the adoption of organic practices and policies—from local to global—that ensure that we, and our children, will have the future we envision and are working to achieve. 

• We recognize the difficult work of changing the status quo—dependency on practices and products that harm people and contaminate the ecosystems on which life depends—in the face of existential health, biodiversity, and climate crises. 

• We know that the critical importance of elevating diverse voices—from scientists, advocates, victims of chemical exposure, those disproportionately affected, land managers and practitioners, to responsible corporations calling for the urgent phaseout of petrochemical pesticides and fertilizers—to the prevention of catastrophic collapse of the natural systems that sustain life. 

From the opportunity to join together with inspiring leaders this fall during the Forum, to partnering with dozens of communities across the country to see our organic land management projects come to life in parks, playing fields, and open and public spaces, our appreciation of local changemakers who seek to protect the earth through their tireless efforts to advance the organic solution in their local communities cannot be overstated.  

In this spirit, we celebrate for a second year a Thanksgiving Address and prayer (the Ohèn:ton Karihwatéhkwen) of the Haudenosaunee (also known as the Iroquois Confederacy or Six Nations—Mohawk, Oneida, Cayuga, Onondaga, Seneca, and Tuscarora) that reflects their relationship to the Earth by giving thanks for life and the world around them. It is a prayer that is appropriate at any time, but especially on a holiday celebrating the abundance of the Earth’s gifts. 

Translated more literally, Ohèn:ton Karihwatéhkwen is “what we say before we do anything important.”  

As you read this prayer, please choose actions to protect our relationship with the natural world and her inhabitants. Beyond Pesticides thanks all of you for your support! 

The People  

Today we have gathered and we see that the cycles of life continue. We have been given the duty to live in balance and harmony with each other and all living things. So now, we bring our minds together as one as we give greetings and thanks to each other as people.  

Now our minds are one.  

The Earth Mother  

We are all thankful to our Mother, the Earth, for she gives us all that we need for life. She supports our feet as we walk about upon her. It gives us joy that she continues to care for us as she has from the beginning of time. To our mother, we send greetings and thanks.  

Now our minds are one. 

The Waters  

We give thanks to all the waters of the world for quenching our thirst and providing us with strength. Water is life. We know its power in many forms- waterfalls and rain, mists and streams, rivers and oceans. With one mind, we send greetings and thanks to the spirit of Water.  

Now our minds are one.  

The Fish  

We turn our minds to all the Fish life in the water. They were instructed to cleanse and purify the water. They also give themselves to us as food. We are grateful that we can still find pure water. So, we turn now to the Fish and send our greetings and thanks.  

Now our minds are one.  

The Plants  

Now we turn toward the vast fields of Plant life. As far as the eye can see, the Plants grow, working many wonders. They sustain many life forms. With our minds gathered together, we give thanks and look forward to seeing Plant life for many generations to come.  

Now our minds are one. 

The Food Plants  

With one mind, we turn to honor and thank all the Food Plants we harvest from the garden. Since the beginning of time, the grains, vegetables, beans, and berries have helped the people survive. Many other living things draw strength from them too. We gather all the Plant Foods together as one and send them a greeting of thanks.  

Now our minds are one.  

The Medicine Herbs  

Now we turn to all the Medicine herbs of the world. From the beginning they were instructed to take away sickness. They are always waiting and ready to heal us. We are happy there are still among us those special few who remember how to use these plants for healing. With one mind, we send greetings and thanks to the Medicines and to the keepers of the Medicines.  

Now our minds are one.  

The Animals  

We gather our minds together to send greetings and thanks to all the Animal life in the world. They have many things to teach us as people. We are honored by them when they give up their lives so we may use their bodies as food for our people. We see them near our homes and in the deep forests. We are glad they are still here and we hope that it will always be so.  

Now our minds are one. 

The Trees  

We now turn our thoughts to the Trees. The Earth has many families of Trees who have their own instructions and uses. Some provide us with shelter and shade, others with fruit, beauty and other useful things. Many people of the world use a Tree as a symbol of peace and strength. With one mind, we greet and thank the Tree life.  

Now our minds are one.  

The Birds  

We put our minds together as one and thank all the Birds who move and fly about over our heads. The Creator gave them beautiful songs. Each day they remind us to enjoy and appreciate life. The Eagle was chosen to be their leader. To all the Birds-from the smallest to the largest-we send our joyful greetings and thanks.  

Now our minds are one.  

The Four Winds  

We are all thankful to the powers we know as the Four Winds. We hear their voices in the moving air as they refresh us and purify the air we breathe. They help us to bring the change of seasons. From the four directions they come, bringing us messages and giving us strength. With one mind, we send our greetings and thanks to the Four Winds.  

Now our minds are one.  

Virtually every aspect of our lives and that which sustains us are shared—the air we breathe, the water we drink, the parks where we walk and our children play, the biodiversity that nurtures life, and the intricate balance of nature (plus, the beauty and amazement it offers us).

Beyond the shared Thanksgiving meal, this holiday season is an opportunity to explore shared thinking and action on what we can do together with our families, communities, elected and local governmental officials, health care providers, teachers, and farmers—how we can work to build this universal organic solution even when we hear rhetoric that denies the urgency of the existential threats.

We are working for holistic change in food production and land management—from farms to homes, gardens, parks, playing fields, and schools. We are building on a foundation for this change that we helped create. And now, we are taking this work to the next level, calling for and working toward the universal adoption of organic practices in communities and on farms.

Our team trusts that we share this vision for a sustainable future with you. Please consider a donation to Beyond Pesticides this holiday season. Your support is of tremendous value and deeply appreciated! 

Please consider a gift on our secure website at bp-dc.org/give2024. Your support of any size makes a tremendous difference! *Now featuring Apple Pay on our contribution page!

➡️ Click here to read a personal Thanksgiving message from Jay Feldman, executive director!

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

Art page highlight! Our thanks to Margaret from Orlando, Florida for sharing her photo, “Appalachian Ridge (Green Mountain, NC).”