(Beyond Pesticides, August 13, 2024) With novel methods to provide a big-picture view of the overlap between high pesticide use and cancer incidence across the U.S, a new study has again linked pesticide exposure to a range of cancers. The study by Jacob Gerkin, D.O. and colleagues, “Comprehensive assessment of pesticide use patterns and increased cancer risk,” published in Frontiers in Cancer Control and Society, examines the association between high-pesticide use and cancer diagnoses along with smoking incidence data and the Social Vulnerability Index, a measure used by the Centers for Disease Control and Prevention (CDC) that includes variables such as poverty, poor housing, and exposures to natural disasters and chemical spills. The researchers consider 69 pesticides used in agriculture that are monitored by the U.S. Department of Agriculture. They use U.S. Geological Survey data to map areas of similar crops and pesticide use patterns and incorporate public health data from the CDC to develop their final picture. In terms of threats to health, cancer remains top of mind for most people. Globally, about ten million people die of cancer each year. And while treatments for cancer and survival times have burgeoned over the years, many cancers—particularly colorectal and breast […]

(Beyond Pesticides, August 5, 2024) As the longstanding problem of involuntary pesticide exposure through chemical drift continues unabated, EPA announced “new, earlier protections” that are being criticized by Beyond Pesticides as inadequate. The organization is calling on the public to let EPA and Congress know that it must comprehensively eliminate nontarget chemical trespass. Beyond Pesticides notes that the recent EPA announcement does not stop the movement of pesticides off the target sites restricted by pesticide product labels and therefore does not protect the public and environment in agricultural, rural, suburban, and urban areas from resulting health and ecological threats. EPA’s July 15, 2024, press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift” states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.” >> Tell EPA and Congress that EPA must protect against all forms of pesticide drift. Pesticide drift—more properly designated “chemical trespass”—is a threat to people living in agricultural, rural, suburban, and urban areas, […]

(Beyond Pesticides, July 30, 2024) The U.S. Environmental Protection Agency (EPA) announced on July 15 what it described as a new process for evaluating the risks of spray drift—the migration of pesticides from their target area to off-site zones. According to a statement by EPA Chemical Safety and Pollution Prevention Assistant Administrator Michal Freedhoff, PhD in an Oregon Public Broadcasting story, the agency took the step so that “people don’t have to wait years for the protections they deserve and need.” However, EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in [its] 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” EPA has said, “Spray drift is governed by a variety of factors which govern how much of the pesticide application deposits on surfaces where contact with residues can eventually lead to indirect exposures (e.g., children playing on lawns that are next to treated fields and where residues have deposited).” The new policy will add spray drift evaluation to occasions when the agency receives an application for a new pesticide and when a registered pesticide is intended for a new use or applied to a new crop. […]

(Beyond Pesticides, July 1, 2024) Comments on proposed new dicamba uses are due Friday, July 5 The U.S. Environmental Protection Agency (EPA) is accepting public comments until July 5 on whether it should allow the expanded use of the weed killer dicamba, which has been associated with adverse impacts related to its propensity to drift off of the target application site. The comment period addresses a BASF chemical company proposal for additional food use of a dicamba product on dicamba-tolerant cotton and dicamba-tolerant soybeans. (See Beyond Pesticides’ comments.) This application is similar to Bayer CropScience’s application for XtendiMax®, for which Beyond Pesticides submitted comments in June. The proposed label for BASF’s Engenia® allows for application preplant, at-planting, preemergence, and postemergence (in-crop) for broadleaf weeds. >> Tell EPA to ban use of dicamba and other drift-prone pesticides. The U.S. Supreme Court Reversal This proposal is under consideration on the heels of a U.S. Supreme Court decision on June 28 that reverses a 40-year old decision in Chevron v. Natural Resources Defense Council, which created a deference to federal agencies in the rulemaking process. In the dissent to this 6-3 decision of the court, the dissenters focus on the role of executive […]

(Beyond Pesticides, June 18, 2024) As part of its update to the proposed U.S. Environmental Protection Agency (EPA) Endangered Species Act (ESA) Workplan, the agency held a public webinar on June 18, 2024, which provided an overview of the agency’s “Mitigation Menu Website” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” [Check back to see webinar when posted by EPA.] After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Despite this acknowledgement, the agency said it would “provide flexibility to growers to choose mitigations that work best for their situation.” In this spirit, a range of people, including grower groups, gathered earlier in the year for a series of workshops in the Pacific Northwest to discuss possible mitigation measures. According to a report written by commercial beekeeper Steve Ellis (more background), concrete decisions were not reached at the workshops as participants recognized the complexities in crafting pesticide product label restrictions to protect endangered species. Mr. Ellis concluded: “If it’s so complex that it’s impossible, then no one […]

(Beyond Pesticides, June 17, 2024) Every year, Beyond Pesticides announces National Pollinator Week—this year beginning today, June 17—to remind eaters of food, gardeners, farmers, communities (including park districts to school districts), civic organizations, responsible corporations, policy makers, and legislators that there are actions that can be taken that are transformative. All the opportunities for action to protect pollinators, and the ecosystems that are critical to their survival, can collectively be transformational in eliminating toxic pesticides that are major contributors to the collapse of biodiversity. This is why Beyond Pesticides starts most discussions and strategic actions for meaningful pollinator and biodiversity protection with the transition to practicing and supporting organic. In launching National Pollinator Week, Beyond Pesticides makes suggestions for individual actions to increase efforts to think and act holistically to protect the environment that supports pollinators. The impact that people have starts with grocery store purchases and the management of gardens, parks, playing fields, and pubic lands. The introduction of pesticides into our food supply and our managed lands has contributed to a downward spiral that is unsustainable. The good news is that it is now proven that we do not need toxic pesticides to grow food productively and profitably […]

(Beyond Pesticides, June 11, 2024) Published in Science of The Total Environment in May, a comprehensive literature review of population-based studies finds strong linkages between direct and acute pesticide exposure and elevated risk of breast cancer (BC). A majority of the studies analyzed in this review were based on population groups in the United States, but also extends to Australia and three European countries (Greece, France, and Italy). Included in these studies are women who worked in chemical-intensive agricultural settings, directly sprayed pesticides in their at-home gardens, and/or handled pesticide-contaminated clothing. The findings in this literature review underscore organic advocates’ concerns of relying on pesticide substitution models that inevitably impact the health of land stewards, farmers, farmworkers, and the broader public rather than transforming food systems to an organic model that bans the use of toxic petrochemical-based pesticides. The goal of this review was to synthesize existing literature on pesticide exposure and breast cancer to determine the specific pathways and underlying mechanisms that contribute to female participants’ heightened risk. This literature review was published online by researchers at the University of Arizona’s R. Ken Coit College of Pharmacy and Coit Center for Longevity and Neurotherapeutics and the Laboratory of Tumor […]

(Beyond Pesticides, June 10, 2024) Expanding the planting of genetically engineered crops is the major focus of “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology” (Framework), released in May by three federal agencies. In its Framework, the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) use the words “exempt” or “exemption” in reference to federal safety regulations 21 times. Then, another 21 times the agencies identify their efforts to “streamline” the process for bringing genetically engineered “plant-incorporated protectants” (PIPs) to market. Without including the word “resistance” even once, the Framework advances the interests of the biotech and allied industries, ignoring the serious scientific issues regarding health and environmental effects and the economic failure for farmers facing crop loss. Meanwhile, the issue of resistance is not new to EPA, which has for years acknowledged the resistance problem despite allowing continued weed resistance to weed killers used with herbicide-tolerant crops and insect resistance to the pesticides incorporated into plants.   >> Tell USDA, FDA, and EPA to replace agricultural provisions in the Framework with policies that discourage GE crops […]

(Beyond Pesticides, May 21, 2024) In a first-of-its kind series of biomonitoring studies published in Agrochemicals, researchers identified the presence of the herbicides dicamba and 2,4-D in all pregnant participants from both cohorts in 2010-2012 and 2020-2022. The findings from this research are not surprising given the explosion of toxic petrochemical pesticides in the Midwest region of the United States. “The overall level of dicamba use (kilograms applied in one hundred thousands) in the U.S. has increased for soybeans since 2015 and slightly increased for cotton and corn,” the authors report, based on U.S. Department of Agriculture National Agriculture Statistics Service surveys. “The overall level of 2,4-D use (kilograms applied in one hundred thousands) in the U.S. was highest in 2010 for wheat, soybeans, and corn. The amount of 2,4-D applied increased the most for soybeans and corn from 2010 to 2020.” The researchers focused on the states of Illinois, Indiana, and Ohio, given the increase in dicamba and 2,4-D during the study period for both cohorts (2010-2022). The researchers are based at Indiana University School of Medicine in the Department of Biostatistics and Health Data Science and Department of Obstetrics and Gynecology, Quebec Toxicology Center within the Institut national […]

(Beyond Pesticides, April 24, 2024) On April 16, 2024, the U.S. Environmental Protection Agency (EPA) posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency’s efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers’ “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, advocates are again questioning EPA’s commitment to fulfilling legal requirements under the Endangered Species Act (ESA) or protecting endangered species and their habitats in the midst of an unprecedented rate of global extinction. ESA is celebrated as one of the most far-reaching conservation laws globally, credited with preventing the extinction of 99 percent of those species the government targets for protection, according to the U.S. Fish and Wildlife Service (USFWS). ESA establishes a framework to categorize species as “endangered” or “threatened,” granting them specific protections. Under ESA, EPA is required to consult with relevant agencies […]

(Beyond Pesticides, March 26, 2024) The authors of a case study in Canale D’Aiedda, Taranto, Italy, published in Scientific Reports, conclude that, “[T]he results of monitoring and modeling activities revealed a chronic risk associated with the presence of Cu [copper] from November to April in several river reaches and acute risk associated to the presence of glyphosate in several reaches mainly in the wet season.”  According to the authors, “The most important factor influencing the chronic risk for Cu were the combination of two factors: the high surface runoff and the Cu applications. The most important factor influencing the glyphosate peaks of concentration is the streamflow.” The authors of the study measure the flow of pesticide concentrations through the soil and water assessment tool (SWAT). The ecotoxicological data was collected at two stations in Germany that flow into Italy, within the Canale d’Aiedda basin. The streamflow was monitored between August 2017 and December 2019. Out of hundreds of pesticides and six metabolities investigated in this study, “only traces of copper and glyphosate were found.” The authors continue, “The banks and the bed of the river system are almost all covered by concrete. The hydrological regime is natural and intermittent in […]

(Beyond Pesticides, March 20, 2024) A report by CBAN unpacks the ecosystem and wildlife health impacts of genetically engineered (GE) corn in the context of Mexico’s 2023 decision to stop its importation into the country. The phase out of genetically modified (GM) corn imports into Mexico was immediately challenged by the U.S. and Canadian governments as a trade violation under the 2020 U.S.-Mexico-Canada Agreement (USMCA), which replaced the North American Free Trade Agreement (NAFTA) as the primary vehicle for North American trade policy. In August 2023, the U.S. Trade Representative set up a dispute settlement panel under USMCA to stop Mexico from going forward with its ban. There has been no public update from the Office of the U.S. Trade Representative as of this writing. The CBAN report highlights the scientific rationale underpinning Mexico’s decision to “safeguard the integrity of native corn from GM contamination and to protect human health” with this ban. In 2020, Mexico announced a four-year phase-out of the weed killer glyphosate, which along with other petrochemical herbicides is integral to GM corn production. When Mexico’s Minister of the Environment announced the phase-out, he said it is part of an effort to transform the country’s food system […]

(Beyond Pesticides, March 5, 2024) Buried in a court decision in February that determined that the U.S. Environmental Protection Agency (EPA) violated the law in allowing harm associated with the herbicide dicamba’s registration is language that permits the damages to continue through this year’s growing season. The judge’s ruling, deferring to EPA’s interpretation of the existing stock provision in the federal pesticide law, continues a pattern of “existing stock” allowances that permit hazards to continue well after a finding of harm or noncompliance. This process contrasts with the issuance of a product recall, which is typically done when pharmaceuticals are found to violate safety standards. Despite the finding of dicamba’s harm and EPA’s failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA’s 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. EPA’s pattern of allowing the use of existing stocks has long been a concern for public health and environmental advocates, who have called for the discontinuance of use upon findings of […]

(Beyond Pesticides, February 28, 2024) The U.S. Environmental Protection Agency (EPA) is putting on hold its Vulnerable Species Project (VSP) after vociferous comments from the petrochemical pesticide industry to instead, “create a narrow, tailored policy rather than a sweeping, burdensome one,” according to a recent op-ed in the Wall Street Journal. Upon heavy pushback from the petrochemical pesticide industry and agribusiness, EPA is hosting a variety of workshops and openings for the public to provide feedback not just on VSP, but the Endangered Species Act (ESA) Workplan the Biden Administration originally introduced in 2021 in its entirety. Advocates are calling for the strengthening of pesticide regulation given the impending decisions that may shape the fate of ESA-FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) compliance for years to come. As EPA continues through its pesticide registration program to advance continued dependency on pesticides through its interpretation of FIFRA, despite the availability of nontoxic alternatives, endangered species extinction and biodiversity collapse has never been a high priority. While EPA has initiated efforts to address a significant backlog of pesticide evaluations, Civil Eats has reported that the agency faces a task so extensive that it may require several additional decades to fully catch up. EPA officials stated, “Even if EPA completed […]

(Beyond Pesticides, February 14, 2024) The latest in a series of reports on the state of farmworker protection, released last December, highlights the long history of health threats, regulatory failures, and structural racism that is imbued in the chemical-intensive agricultural system that feeds the nation and world. The authors conclude that farmworkers “face a level of occupational risk unrivaled by most workers.” They continue: “From repeated exposure to pesticides and extreme heat, to injuries from machinery and repetitive motion, conditions on American farms involve myriad hazards. Meanwhile, a lack of access to healthcare and legal services, low wages, marginalization, language barriers, racism, and the threat of deportation among these largely immigrant communities compound their many challenges.” Describing the U.S. food system and the workers who serve as its foundation, Precarious Protection: Analyzing Compliance with Pesticide Regulations for Farmworker Safety is the third publication in a series of reports on farmworker health and safety, led by the Center for Agriculture and Food Systems (CAFS) at Vermont Law and Graduate School and written with the Harvard Law School Food Law and Policy Clinic and the nonprofit group Farmworker Justice. Johns Hopkins Center for a Livable Future and Farmworker Justice partnered on the […]

(Beyond Pesticides, February 13, 2024) Last week, the United States District Court for the District of Arizona struck down the U.S. Environmental Protection Agency’s (EPA) 2021 approval of three dicamba-based herbicides. This is the second lawsuit since 2020 to call out EPA’s violation to both the Endangered Species Act (ESA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to authorize the use of over-the-top (OTT) dicamba-based herbicide products from Bayer and other petrochemical pesticide companies. This rejection of dicamba-based herbicides fuels advocates’ push for stronger regulatory actions by EPA for all petrochemical pesticides and their push for the more widespread adoption of organic practices that do not use these chemicals. The case was filed by Center for Food Safety (CFS), Center for Biological Diversity, National Family Farm Coalition, and Pesticide Action Network North America. Beyond Pesticides has covered the dicamba tragedy for years, including the EPA Office of the Inspector General’s critical 2021 report, EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision. The report identifies EPA’s abandonment of science and assault on agency integrity. In addition to citing adverse impact on nontarget crops and the environment, the Court zeroes in on EPA’s failure to adequately manage […]

(Beyond Pesticides, January 23, 2024) Earlier this month, a coalition of over 140 local and state elected officials from over 30 states sent a letter to ranking members of the House and Senate Agriculture committees to reject the proposed Agricultural Labeling Uniformity Act (H.R. 4288), which would preempt local governments’ authority to protect their constituents from toxic pesticides. Members of Congress are negotiating language in the Farm Bill that would preempt local and state authority to restrict pesticides. “We write to express our strong opposition to any efforts to limit longstanding state and local authority to protect people, animals, and the environment by regulating pesticides,” says the signatories. “As Congress considers legislation related to agriculture, including the reauthorization of the Farm Bill and Fiscal Year 2024 appropriations bills, we urge you to ensure that state, county, and local governments retain the right to protect their communities and set policies that best suit our local needs.” The question of local rights to adopt more stringent restrictions on pesticide use has historically been left to the states. However, after the U.S. Supreme Court (Wisconsin v. Mortier, 1991) affirmed the rights of local communities under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), […]

(Beyond Pesticides, January 8, 2024) Despite successful litigation that stopped the unnecessary use of an antibiotic (streptomycin) in citrus production in December 2023, the court’s reasoning fails to grasp the science behind the biggest emerging threat to U.S. and global health—antibiotic resistance. What is most disturbing and challenging is that the U.S. Environmental Protection Agency (EPA), responsible for applying science in the protection of the public’s health, misled the court on the overwhelming worldwide scientific consensus on the contribution of agricultural antibiotic use to the human death and disability rate linked to antibiotic resistance. On this subject, Beyond Pesticides has written extensively about horizontal gene transfer, which explains the movement of antibiotic resistant bacteria throughout the environment, ultimately making their way to people, as medically necessary drugs become ineffective. As we’ve written, “The human pathogenic organisms themselves do not need to be sprayed by the antibiotic because movement of genes in bacteria is not solely “vertical,” that is from parent to progeny—but can be “horizontal”— from one bacterial species to another.” [Regarding the reliance of the court on EPA’s misrepresentation of the science, the court found, ”EPA emphasized that ‘there is no data that antibiotic use in agriculture leads to […]

(Beyond Pesticides, December 20, 2023) A federal district court decision last week (December 13) found illegal the U.S. Environmental Protection Agency’s (EPA) decision to register the antibiotic streptomycin for use in Florida citrus to control Huanglongbing (HLB), also known as “citrus greening,” a plant disease spread by the Asian citrus psyllid. This decision comes just as EPA may allow yet another controversial pesticide, aldicarb, whose registration faces similar issues of agency malfeasance. The streptomycin lawsuit, filed in 2021 by a coalition of farmworker and public interest groups including Beyond Pesticides, raises critical issues of antibiotic resistance, public health protection, and impacts on bees. The case was filed by: Natural Resources Defense Council and U.S. PIRG, represented by NRDC; Beyond Pesticides, Environmental Confederation of Southwest Florida (ECOSWF), Farmworker Association of Florida, Farmworker Justice, and Migrant Clinicians Network, represented by Earthjustice; and the Center for Biological Diversity, represented by in-house counsel. The Ninth Circuit Court of Appeals took EPA to task for its failure to conduct required analyses and issue findings to support the use of streptomycin for citrus greening. The court is particularly concerned about the agency’s failure to reach findings on the impacts on bees and the agency’s responsibility for […]

(Beyond Pesticides, November 9, 2023) Two-hundred-foot pesticide spray “buffer zones” around 4,028 U.S. elementary schools contiguous to crop fields—according to data evaluated by Environmental Working Group—are threatened by potential Farm Bill amendments now under consideration. Legislative language, if adopted, would take away (preempt) the authority of states and local jurisdictions to protect children and restrict agricultural pesticides used near schools. Pesticide drift is a widespread problem throughout the U.S. that has attracted national attention in recent years because of crop damage caused by the weed killer dicamba in numerous midwestern states. In the face of the U.S. Environmental Protection Agency’s (EPA) failure to mitigate drift hazards, states enact limits on when and how pesticides can be used, establish buffer zones around application sites, and in some cases, ban uses. In 2018, Arkansas banned dicamba use from mid-April through the end of October (and survived a Monsanto challenge to the ban. For a historical perspective on the drift issue, see Getting the Drift on Pesticide Trespass. Children, in particular, face unique risks from pesticide and toxic chemical exposures. Due to their smaller body size, they absorb a higher relative amount of pesticides through the food they consume and the air they breathe. Additionally, children’s developing […]

(Beyond Pesticides, October 30, 2023) TAKE ACTION. It is said that the definition of insanity is doing the same thing over and over again and expecting a different result. And so it goes with the U.S. Environmental Protection Agency’s (EPA) proposal to register a new genetically engineered pesticide for the Colorado Potato Beetle (CPB); this time with a pesticide that has not been fully evaluated for its adverse effects to people and the environment. [Submit a public comment before comment period ends today, October 30, 2023.] Chemical-intensive agriculture has failed to control CPB since resistance to DDT was identified in 1952 and has continued with every family of pesticides since then. CPB has been dubbed the billion-dollar-bug because of the investment in failed attempts of chemical manufacturers to control the insect, the profits generated by chemical companies despite this failure, and the resulting losses for chemical-intensive farmers—not to mention government expenditures for the registration of chemicals that have short efficacy, pollution costs associated with chemical production and use, and lost ecosystem services. But, EPA is at it again, registering a new novel pesticide active ingredient, Ledprona, which raises the stakes on potential harm. The only winners in this ongoing failure […]

(Beyond Pesticides, October 27, 2023) In a typical move, EPA proposes to greenlight a type of genetic engineering to solve a problem created by the industrial paradigm for pest control, i.e. vast acreages of monoculture treated with millions of tons of toxic pesticides leading to rapid resistance among crop pests. In this case EPA wants to approve using a nucleic acid—double-stranded RNA (dsRNA)–called “interfering RNA,” or RNAi—to silence a gene crucial to the survival of the Colorado Potato Beetle (CPB), the scourge of potato farmers around the world. But EPA has skipped over important steps in its decision-making process and rushed to judgment. Like chemical pesticides, genetically-based pesticides are regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). In 2020, Massachusetts-based GreenLight Biosciences applied for registration of its RNAi active ingredient, Ledprona, and its end-use product, Calantha. The company executive heading the effort is an alumnus of Monsanto and several other major chemical companies. Last May EPA granted GreenLight an Experimental Use Permit (EUP) authorizing field studies in states that produce tons of potatoes. A mere five months later, EPA announced its decision to approve the registration based almost entirely on incomplete EUP data and giving the public very […]

(Beyond Pesticides, October 20, 2023) Comments are due October 22. This action requires use of Regulations.gov. See instructions and proposed comment language that can be copy and pasted by clicking HERE. The U.S. Environmental Protection Agency’s (EPA) plan to “protect” endangered species, its Draft Herbicide Strategy Framework, continues a legacy of failed risk assessment and mitigation measures that do not meet the moment of looming biodiversity collapse. This is a critical time for the agency to embrace real fundamental change in how it regulates pesticides, recognizing that land management strategies, including in agriculture, exist that are no longer reliant on pesticides. This is not a time to tinker with strategies that EPA admits fall short. Recognizing that its Pesticide Program has failed to meet its obligation to protect endangered species from registered pesticides, EPA has come up with a strategy to redefine its responsibilities to protect endangered species in its pesticide registration and registration review program. According to EPA, “The proposed Strategy is structured to provide flexibility to growers to choose mitigations that work best for their situation. Additionally, the draft Strategy may require more or less mitigation for growers/pesticide applicators depending on their location.” Understandably, EPA has taken this approach, […]