(Beyond Pesticides, March 24, 2022) A range of essential oils can provide high levels of larvicidal and adulticidal activity against a commonly found species of mosquito, according to research published last week in Scientific Reports. The use of essential oils in mosquito management has generally been limited to personal protection, with synthetic pesticides often the first choice for vector control activities. This research highlights the potential role of these natural compounds to replace hazardous synthetics in managing larval sources and killing adult mosquitoes under last-resort scenarios.

The team of Egyptian-based scientists conducting the study purchased 32 different essential oils from a regional retailer in order to test them on both the larval and adult stages of Culex pipiens. C. pipiens, often referred to as the common house mosquito, is the most abundant mosquito in the Northern U.S., and is known to vector West Nile virus and Saint Louis encephalitis, among other diseases.

Larval efficacy was tested on the fourth instar larvae of C. pipiens, delivered through a mixture of the essential oil, water, and the solvent Tween-20, which contains the surfactant Polysorbate-20, used to emulsify the mixture. All oils tested had some level of larvicidal activity (between 60-100%). Researchers classified the oils into three different groups: highly, moderately, and least effective. Highly effective oils achieved 95-100% mortality over a 48-hour period, and included garlic (Allium sativum), dill (Anethum graveolens), tea plant (Camellia sinensis), fennel (Foeniculum vulgare), fennel flower (Nigella sativa), sage (Salvia officinalis), garden thyme (T. vulgaris), and sweet violet (Viola odorata). In the moderately effective group, Salai guggul (B. serrata), cumin (C. cyminum), wild tumeric (C. aromatic), garden cress (L. sativum), tea tree (M. alternifolia), black pepper (P. nigrum), and magnolia berry (S. chinensis) recorded 81-92% mortality over 48 hours. Of the 17 least effective oils remaining, sesame (S. indicum) and cannabis (C. sativus) exhibited the lowest mortality rates, at roughly 60% over a 48-hour period.

Researchers then tested the high larval efficacy group on adult mosquitoes, utilizing the U.S. Centers for Disease Control and Prevention’s bottle bioassay testing protocol. In a solution of 10% essential oil, mortality rates post treatment were 49% for garlic (Allium sativum), 88% for dill (Anethum graveolens),  64% for the tea plant (Camellia sinensis), 51% for fennel (Foeniculum vulgare), 93% for fennel flower (Nigella sativa), 44% for sage (Salvia officinalis), 72% for garden thyme (T. vulgaris), and 100% for sweet violet (Viola odorata).

In sum, the researchers note, “Camellia sinensis [tea plant] and F. vulgare [fennel] were the most potent larvicides whereas V. odorata [sweet violet], T. vulgaris [garden thyme], An. Graveolens [dill] and N. sativa [fennel flower] were the best adulticides and they could be used for integrated mosquito control… EOs could serve as suitable alternatives to synthetic insecticides because they are relatively safe, available, and biodegradable.”

The results of the study line up with research on the efficacy of essential oil-based sprays for adulticide applications. A 2019 study in the Florida Journal of Mosquito Control found the product Nature-Cide, containing .5% clove and .5% cottonseed oil to be more effective at managing adult mosquitoes that three of the most commonly used synthetic pyrethroid-based mosquito sprays.

A model approach to mosquito management is a science-based, and prioritizes preventive measures first and foremost. These measures include surveillance, monitoring, public education on eliminating breeding sites and personal protective actions, consideration of local ecology and habitat manipulation. While moving from hazardous synthetics to less toxic, natural and more readily biodegradable products like essential oils present a range of benefits, even these products should only be used based upon monitoring data. Applying any product with insecticidal activity presents risks to nontarget animals and plants in the environment. The use of larvicides should be governed by actions levels established based on prior monitoring data. Some communities, like the City of Boulder, Colorado, are working to limit their use of biological larvicides like bacillus thuringiensis by embracing ecological mosquito management — hiring wetland ecologists to analyze ecosystem health and its capacity to naturally address overabundant mosquito populations.

In the case of adulticides, even least-toxic products should only be considered as a last resort, under strict thresholds, and when the spread of mosquito-borne disease places public and animal health at imminent risk. Aerially applied mosquito adulticides in any form are excessively risky in exposures to people and nontarget organisms, are relatively ineffective in relation to those risks, and should never be considered as part of a sustainable mosquito management program.

For more information on safer mosquito management, see Beyond Pesticides program page. Specific recommendations for least-toxic repellents can be found here, and residents working to change their community mosquito management approach are encouraged to reach out to [email protected].

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

Source: Scientific Reports

(Beyond Pesticides, March 23, 2022) A study published in Nature Reviews Earth & Environment warns that thawing of permafrost (a ground that remains completely frozen for two or more years) in the Arctic region can prompt the reemergence of greenhouse gases (e.g., methane and carbon dioxide), microbes, and chemicals (e.g., banned pesticides like DDT). Past research finds gases, microbes, and chemicals drift near the poles, becoming entrapped in ice under the accumulating snowfall. As the global climate continues to rise and the climate crisis worsens, studies like this show significant effects, as ice encapsulating these toxic chemicals is melting. Upon melting, some chemicals can volatilize back into the atmosphere, releasing toxicants into the air and aquatic systems, with the ensuing consequences. Microbes frozen for thousands to millions of years can also emerge from thawing permafrost, with unknown implications on human, animal, and ecosystem health. The melting permafrost is already beginning to impact infrastructure, creating sinkholes that damage roads, trees, and utility poles. Moreover, mixtures of chemicals, microbes, and greenhouse gases (GHGs) in permafrost are difficult to assess. Therefore, studies like this highlight the need to evaluate the health and ecological effects of melting arctic permafrost (and glaciers) from anthropogenic (human)-induced climate change. [For related pieces, see Silent Snow: The unimaginable impact of toxic chemical use and DDT in Glacial Melt Puts Alaskan Communities at Risk.]

Approximately 1,700 billion metric tons of carbon, including GHGs like carbon dioxide and methane, are present in permafrost, over 51 times more than the amount of carbon released from 2019 fossil fuel emissions. The remaining organic matter, frozen in permafrost, will decay after thawing, further increasing atmospheric carbon emissions. Although current models predict an increase in carbon released from permafrost in the coming decades to hundreds of years, scientists lack knowledge on how much, how long, and the specific carbon source. Therefore, researchers in this study used ground, air, and satellite data to evaluate the effects of subsequent permafrost melting.

Using ground measurements, researchers can monitor changes in specific areas, while airborne and space-based (satellite) measurements monitor changes over broader areas. Airborne and ground measurements represent time-specific monitoring data, and satellite measurements monitor data continuously. Moreover, ground measurements mainly focus on microbial communities in thawing permafrost. Airborne measurements focus on GHG emission with satellite and airborne data mapping GHG hotspots. The combination of data forms a holistic (complete) overview of changes in the arctic region.

The study determines that Earth’s polar regions are warming the fastest, approximately two to four times faster than average, and these changes can have a cascading adverse impact on lower and higher latitudes. The scientists note that the polar regions (Arctic and Antarctic) stabilize Earth’s climate and drive heat transfer, powering jet streams and other fluxes/currents. Researchers cannot identify specific microbes encased in permafrost, nor whether GHGs emissions will be gradual or rapid. Thus, polar warming has future consequences that threaten regular weather, climate, and chemical exposure patterns.

Many scientists consider Arctic environments “pristine,” void of direct chemical inputs from chemicals used in more temperate and industrial climates. However, the Arctic has become a sink for these toxic chemicals, as studies find evidence that airborne Arctic chemical concentrations are comparable to that of industrialized regions in the U.S., Europe, and Asia. Additional investigations find the presence of chemicals and microbes in soil and ice samples taken from Arctic regions. The Arctic is highly susceptible to global pollution, as warmer air contaminated with industrial and agricultural chemicals from manufacturing regions move poleward toward cooler air. Environmental pollutants can condense into snowflakes high in the atmosphere and deposit onto the Arctic surface. Although deposition of these chemicals via long-range atmospheric transport and condensation are significant contributors to Arctic contamination, the chemical properties allowing these substances to persist in the environment so long are concerning. Some of these long-lived chemicals include regionally banned pesticides like DDT, heptachlor, and lindane, which are highly toxic to humans and animals, causing a range of adverse effects, from respiratory issues to nervous system disorders and birth deformities to various common and uncommon cancers. Although banned chemicals remain a global issue, as much of the developing world still report usage, banned/past-use compounds are not the only contaminants in the Arctic. Current-use chemicals like chlorpyrifos, dacthal (DCPA), and trans-nonachlor (a component of the banned insecticide chlordane) readily contaminate the arctic, and continued use will result in an increased probability of atmospheric transportation and deposition of chemicals on Arctic glacier tops via precipitation. According to Brettania Walker, Ph.D., toxics officer at World Wildlife Fund’s Arctic Program, “Not only is chemical contamination increasing in the Arctic but also modern chemicals are now appearing in many Arctic species alongside older chemicals, some of them banned for over [30] years.”

The climate crisis adds another level of concern, especially regarding passive pesticide and microbial exposure from snowmelt. Pesticide contamination is already an issue in the U.S., as results of the United States Geological Survey’s (USGS) and National Water-Quality Assessment (NAWQA) show that pesticides and their breakdown products are present in all U.S. streams and widespread in groundwater throughout the country. For instance, a Chicago-based 2020 study shows black women who consume more tap water per day have higher bodily residues of the DDT metabolite (DDE). Permafrost and glacial melting will only add to water source contamination as volatile chemicals can enter waterways at the same concentration levels as before ice entrapment, even after several decades. Moreover, several banned chemicals are not soluble in water (e.g., DDT, lindane, chlordane) but bioaccumulate in the fatty tissue of many Arctic species, such as polar bears, seals, whales, and some fatty fish like salmon, herring, and catfish. The level of DDT in Arctic penguins’ blubber is similar to levels during initial banning more than 30 years ago. Unfortunately, some indigenous tribes in Arctic regions rely on these very mammals and fish for sustenance, and ingesting these pollutants is inevitable, putting their health at risk. Higher bodily concentrations of chemicals are evident in those who consume contaminated meat with associated health risks, including immune system disorder, increased susceptibility to disease, central nervous system disorders, learning disabilities among children, reproductive issues, and cancer. Studies find that adults and children who regularly consume fish from contaminated streams are at increased risk of cancer from dietary and cumulative exposure, in many cases above EPA thresholds.

This study adds to the growing body of literature demonstrating disproportionate warming in arctic regions. Arctic thawing has implications for carbon release and landscape changes that are difficult to predict, including alternations in arctic vegetation and density. The combination of data measurements (e.g., ground, airborne, satellite) can aid in monitoring the carbon system, from microbial decay of organic matter to volatilization of chemicals from permafrost and glacier ice. As global warming progresses, exposure concerns will increase significantly, especially for children who are more vulnerable to the toxic effects of chemical exposure. To mitigate the risks associated with chemical exposure from toxic pesticides, advocates say the manufacturing and use of pesticides need addressing, first and foremost. It falls to global leaders to curtail the continued manufacturing of chemical pollutants that readily contaminate polar regions. Recently, agrochemicals like pesticides and fertilizers overtook the fossil fuel industry as the leading contributor to environmental sulfur emissions. If pesticide use and manufacturing are amplifying the impacts of the climate crisis, advocates argue that it is essential to incite change by enhancing pesticide policy and regulation that eliminates use. The study concluded, “Scientific cooperation across diverse fields has already increased the modeling accuracy and data integration for carbon transport, permafrost thaw, and climate scenarios. However, further international collaboration, monitoring, and exploration is needed to determine the areas of greatest change. All efforts to quantify carbon release expand scientific understanding of complex, changing and emergent dynamics of a warming Arctic.”

Lack of adequate persistent pesticide regulations highlights the need for better policies surrounding pesticide use, especially when a toxic pesticide is banned for use in the U.S., but not for production and export to other countries. A switch from chemical-intensive agriculture to regenerative organic agriculture can significantly reduce the threat of the climate crisis by eliminating toxic, petroleum-based pesticide use, building soil health, and sequestering carbon. The Intergovernmental Panel on Climate Change (IPCC) finds that agriculture, forestry, and other land use contributes about 23% of total net anthropogenic emissions of greenhouse gases, while organic production reduces greenhouse gas emissions and sequesters carbon in the soil. Learn more about how it is possible to sequester more than 100% of current annual CO2 emissions by switching to organic management practices by reading Regenerative Organic Agriculture and Climate Change: A Down-to-Earth Solution to Global Warming. For more information about organic food production, visit the Beyond Pesticides Keep Organic Strong webpage. Learn more about the adverse health and environmental effects chemical-intensive farming poses for various crops and how eating organic produce reduces pesticide exposure.

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

Source: Nature Reviews Earth & Environment, NASA

(Beyond Pesticides, March 22, 2022) German cockroaches collected from U.S. residential homes have evolved resistance mechanisms so strong that many can consume ten times the pesticide required to kill a laboratory-susceptible strain and still not die. These are the findings of recent research published in the Journal of Economic Entomology, which focused on determining cockroach resistance levels to commonly used gel bait insecticides in infested Southern California homes. The findings underscore the importance of an integrated approach to cockroach management that recognizes and responds to pest ecology, rather than search for an ever-elusive silver bullet.

Researchers collected five different strains of German cockroaches from various locations around Southern California, two from public housing and three from apartment dwellers. All sites had long-standing cockroach infestations, with varying treatment histories that generally included significant use of common gel bait insecticides. Tests were conducted on male cockroaches as they are gregarious foragers and thus more susceptible to baited food; it was indicated that if an insecticide cannot kill a male, it is highly unlikely to kill a juvenile or female roach. A separate group of cockroaches reared in the laboratory and never exposed to insecticides was used as a baseline for comparison.

This never-exposed laboratory strain of roaches were then exposed to varying levels of commonly used bait insecticides, including fipronil, clothianidin, indoxacarb, abamectin, hydramethylnon, and deltamethrin. Researchers determined lethal doses (LD) that killed 50% of the laboratory strain, as well as the dose that killed 95%.

Scientists then exposed the residential strains to commercial products containing the insecticides listed above. Mortality was recorded 14 days after exposure. Responses varied significantly between different residential strains, and while all baits completed killed off the laboratory strain, no pesticide was able to achieve 100% knockdown across the board.

Referred to as “diagnostic doses,” each cockroach strain was then directly treated with three times the lethal dose that killed 95% (LD95) of the laboratory strain. With the synthetic pyrethroid deltamethrin, no cockroaches died at that dose. While a mere 0-3% of fipronil, 13-27% of clothianidin, and 13-63% of indoxacarb exposed roaches died at the 3 x LD95 rate. Only abamectin and hydramethylnon recorded high mortality rates from this exposure. Scientists then took it a step further and exposed the cockroaches to ten times the LD95. At this rate, upwards of 80% of deltamethrin-exposed roaches still lived, while with fipronil that rate killed off 20-70%. The clothianidin and indoxacarb exposed roaches exhibited a significant negative correlation between survival time after exposure to 10 x LD95 and mortality, while with those exposed to fipronil and hydramethylnon the correlation was insignificant. Scientists say this indicates that resistance is more physiological for the former products, while the insignificant correlation may indicate the development of cockroach aversion to the latter two baits.

Only abamectin exhibits a knockdown that would suggest a level of effectiveness in a cockroach infestation. However, researchers add caution to that finding by referencing a 2019 study that found rapid increases in abamectin resistance in field settings. In that study, roughly 10% of cockroaches in a certain site were resistant to abamectin. But after an application, the 10% that did not die were able to rapidly repopulate. These scenarios drive home the flaws in a product-centric approach to cockroach management.

In order to be successful, bait insecticides must consistently achieve knockdown rates near 100%. But as the present study shows, even doses ten times higher than what should successfully kill a cockroach can leave a breeding population to repopulate.  

In the 2019 study, researchers tested one active ingredient that was not tested in the present study: boric acid. No evidence was found that cockroaches have developed widespread resistance to boric acid, likely to due its mode of action.

In its powder form, boric acid can be placed along cracks and crevices that cockroaches walk on. It can dry out and desiccate insects, but is generally most effective once consumed, as it acts as an acute stomach poison. The product is found in some commercial pest products, formulated with a food attractant. The powdered form, however, can be more effective when used in proper context. Cockroaches are social animals that regularly groom themselves and each other. Leaving a thin line of boric acid for cockroaches to crawl over will get the boric acid on their feet, which they will subsequently groom off. Cockroaches groom by running their legs and antennae through their mouths, resulting in ingestion of the boric acid stuck to their feet. Young cockroaches feed off the waste material of older cockroaches, providing an add-on route of exposure to the original boric acid meal, and cockroaches generally eat other dead cockroaches, providing yet another route once the target cockroach is dead, making it an effective source-sink.

But even a product as effective as boric acid is unlikely to eliminate an infestation unless other approaches are also integrated. An approach that responds to pest ecology recognizes that pests, like all life, need food, water, and shelter to survive. Make sure food and water is never left out, and all surfaces are regularly clean/vacuumed. Cracks, crevices, and other entryways into one’s home or apartment should be completely sealed; consider products like doorsweeps and fine-meshed screens to further impede movement. Throughout the process, monitor populations with traps to gauge areas of activity, and the intensity of the infestation. Once you have done everything you can to deny food, water, and shelter, boric acid gels and dusts can be applied to manage the remaining infestation.

Think about this impact of these actions from the cockroach’s perspective. By monitoring with traps you’ve identified problem areas and the major sites of infestation in your home. By sealing up entryways, you’ve cut off the infestation from reinforcements. By impeding movement you’ve slowed down the ability of the remaining cockroaches to find new mates. By applying thin dusts of boric acid near where you’ve located the infestation, every movement is potentially deadly. By denying access to food and water, you’ve created a situation where the only food available will be boric acid bait poisons. Such as approach requires a bit more forethought, but is significantly more effective than one that focuses solely on chemical use while ignoring pest ecology.

For a step-by-step checklist and guide to take care of a German cockroach problem, see Beyond Pesticides ManageSafe entry on this atrocious pest.

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

Source: Journal of Economic Entomology

(Beyond Pesticides, March 21, 2022) With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that spins its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” This just the latest example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.

Tell EPA to protect endangered species. Tell Congress to make sure the Biden administration protects endangered species. 

The announcement follows the release of a final biological opinion by U.S. Fish and Wildlife Service (FWS), which, according to the Center for Biological Diversity (CBD), “relies on scientifically unfounded assessment methods imposed during the Trump administration [and] stands in sharp contrast to the agency’s 2017 conclusion that 1,284 species would likely be jeopardized by malathion.” Meanwhile, the National Marine Fisheries Service, a sister agency to the U.S. Fish and Wildlife Service, released an updated biological opinion that determined malathion and two other toxic organophosphate pesticides are causing jeopardy to virtually every endangered U.S. salmon, sturgeon, and steelhead species, as well as to Puget Sound orcas.

The current decision by EPA is a result of corporate and political intervention following the 2017 biological opinion by FWS. Dow AgroSciences—now called Corteva—asked the Administration to suspend the assessments. Then-acting Department of Interior Secretary David Bernhardt complied after becoming aware of the fact that the Service’s analysis had determined that malathion jeopardized the continued existence of 1,284 protected species.

Agency decisions like this call into question the Biden administration’s commitment to protecting the environment and human health. As stated by CBD’s Lori Ann Burd, “The Biden administration has squandered a historic opportunity to rein in the dangerous use of one of the world’s worst neurotoxic pesticides. By ignoring the best available science and choosing to rely on unenforceable promises of good behavior by the pesticide makers rather than real, on-the- ground conservation measures, the Biden administration is condemning wildlife to extinction with a wink and a nod. This decision to cave to powerful special interest groups will do far-reaching harm to our most endangered wildlife.”

The insistence that labeling restrictions can prevent harm to endangered species flies in the face of past experience, which has produced an insect apocalypse and extinction crisis. EPA must protect endangered species by banning the use of hazardous pesticides like malathion and other organophosphates.

Tell EPA to protect endangered species. Tell Congress to make sure the Biden administration protects endangered species. 

Letter to EPA Administrator and OPP

With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at

it again with its latest announcement that spins its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” This just the latest example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.

The recent final biological opinion on malathion by U.S. Fish and Wildlife Service (FWS) relies on scientifically unfounded assessment methods imposed during the Trump administration and stands in sharp contrast to the agency’s 2017 conclusion that 1,284 species would likely be jeopardized by malathion. Meanwhile, the National Marine Fisheries Service has released an updated biological opinion that determined malathion and two other toxic organophosphate pesticides are causing jeopardy to virtually every endangered U.S. salmon, sturgeon, and steelhead species, as well as to Puget Sound orcas.

The current decision by EPA is a result of corporate and political intervention following the 2017 biological opinion by FWS. Dow AgroSciences—now called Corteva—asked the administration to suspend the assessments. Then-acting Department of Interior Secretary David Bernhardt complied after becoming aware of the fact that the Service’s analysis had determined that malathion jeopardized the continued existence of 1,284 protected species.

Agency decisions like this call into question the Biden administration’s commitment toprotecting the environment and human health. As stated by Lori Ann Burd of the Center for Biological Diversity, “The Biden administration has squandered a historic opportunity to rein in the dangerous use of one of the world’s worst neurotoxic pesticides. By ignoring the best available science and choosing to rely on unenforceable promises of good behavior by the pesticide makers rather than real, on-the-ground conservation measures, the Biden administration is condemning wildlife to extinction with a wink and a nod. This decision to cave to powerful special interest groups will do far-reaching harm to our most endangered wildlife.”

The insistence that labeling restrictions can prevent harm to endangered species flies in the face of past experience, which has produced an insect apocalypse and extinction crisis. EPA must protect endangered species by banning the use of hazardous pesticides like malathion and other organophosphates.

Thank you.

Letter to U.S. Representative and Senators

Please ensure that the Biden administration protects endangered species.

With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that spins its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” This just the latest example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.

The recent final biological opinion on malathion by U.S. Fish and Wildlife Service (FWS) relies on scientifically unfounded assessment methods imposed during the Trump administration and stands in sharp contrast to the agency’s 2017 conclusion that 1,284 species would likely be jeopardized by malathion. Meanwhile, the National Marine Fisheries Service has released an updated biological opinion that determined malathion and two other toxic organophosphate pesticides are causing jeopardy to virtually every endangered U.S. salmon, sturgeon, and steelhead species, as well as to Puget Sound orcas.

The current decision by EPA is a result of corporate and political intervention following the 2017 biological opinion by FWS. Dow AgroSciences—now called Corteva—asked the administration to suspend the assessments. Then-acting Department of Interior Secretary David Bernhardt complied after becoming aware of the fact that the Service’s analysis had determined that malathion jeopardized the continued existence of 1,284 protected species.

Agency decisions like this call into question the Biden administration’s commitment to protecting the environment and human health. As stated by Lori Ann Burd of the Center for Biological Diversity, “The Biden administration has squandered a historic opportunity to rein in the dangerous use of one of the world’s worst neurotoxic pesticides. By ignoring the best available science and choosing to rely on unenforceable promises of good behavior by the pesticide makers rather than real, on-the-ground conservation measures, the Biden administration is condemning wildlife to extinction with a wink and a nod. This decision to cave to powerful special interest groups will do far-reaching harm to our most endangered wildlife.”

The insistence that labeling restrictions can prevent harm to endangered species flies in the face of past experience, which has produced an insect apocalypse and extinction crisis. EPA must protect endangered species by banning the use of hazardous pesticides like malathion and other organophosphates.

Thank you.

(Beyond Pesticides, March 18, 2022) A 2020 lawsuit related to pesticide drift was resolved on March 8, 2022 in San Joaquin (California) Superior Court with the finding that Alpine Helicopter Services, which specializes in pesticide applications for government and tourism entities, had violated pesticide drift laws and endangered public health and safety. The court further found Alpine liable for damage related to its actions, though penalties in the case, brought by California state prosecutors and the California Department of Pesticide Regulation (DPR), have yet to be determined. The case exposes a handful of the many instances of pesticide drift, also known as “chemical trespass,” that occur every year in the U.S. In 2004, Beyond Pesticides covered the issue with Getting the Drift on Chemical Trespass; its monitoring of drift issues is ongoing, as can be seen in its “Pesticide Drift” archives. The long history of nontarget exposure, contamination, and poisoning teaches that drift is a function of pesticide use, but not considered adequately by regulators who allow the marketing of poisons that are known to move through the environment uncontrolled. Cases like the Alpine case highlight a relentless problem associated with the daily use of pesticides.

Pesticide drift is any airborne movement of pesticides from the target application site to any unintended area; pesticides can drift, according to multiple studies, for as much as several miles. Drifting pesticides might be apparent as a cloud of droplets or vapor, as “dust” particles during application, or as a noxious odor that lingers after application. However, drift can also have no odor, be invisible, and persist for days. Drift can happen whether the application is via aerial or ground spraying, as well as from applications that volatize and move through air currents, exposing people, animals, crops, trees, and non-crop plants to the toxic chemical compounds — most typically, insecticides, herbicides, and/or fungicides. In addition, soil and water resources can become contaminated, as well as the very air that people and animals are breathing.

Pesticide drift can cause acute poisoning and/or chronic health impacts in farmworkers or anyone in the application area or working in nearby fields being treated. Included among those at high risk from drift are families of farmworkers who live near agricultural parcels. Yet, as in this subject litigation, it also happens in other settings. Schools, playground, recreational fields, and other facilities at which children are frequent visitors, have been affected by pesticide drift, which is all the more concerning because children have elevated vulnerability to chemicals, given their sizes and developmental stages.

This litigation charged Alpine with pesticides applications in four “spray drift,” or “chemical trespass” incidents. Three of those were in San Joaquin County; one was at a school (in 2017), another at a sports complex (2019), a third saw herbicides applied to nearly 5,000 acres of land, resulting in massive crop losses (2014), and a fourth occurred on a residential yard (2020). That sports complex was the San Joaquin County Regional Sports Complex in Stockton, a facility that serves environmental justice communities that already experience disproportionate exposure to, and impacts of, environmental pollution.

California officials registered their takes on the suit and the decision: DPR acting chief deputy director, Karen Morrison, commented, “The blatantly careless actions of Alpine threaten the health and safety of children and communities.” California Attorney General Rob Bonta commented, “Today’s decision is an important win for the many in our state who live and work in agricultural communities. Alpine’s careless approach to pesticide application is unacceptable.” According to Agri-Pulse, he also said that the decision ought to send a powerful message to agricultural enterprises that the state “will hold them accountable if they violate the law when using ‘toxic chemicals.’”

In 2018, the California DPR published its Pesticide Drift: Pocket Guide as a primer on pesticide drift, geared to the general public and those who may have experienced or witnessed this kind of chemical trespass. It notes that in California, not all drift is illegal, but that “Pesticide laws focus on spray drift that causes harm, or has the potential to do so. The law specifically recognizes that pesticides may drift but says that ‘substantial’ drift is not allowed. The law prohibits applications if there is a reasonable possibility of harm to people or property.” Pesticide Action Network North America (PANNA) created something similar in 2017: In Case of Drift: A Toolkit for Responding to Pesticide Drift. It had issued the 2004 report titled Chemical Trespass: Pesticides in our Bodies and Corporate Accountability.

A sense of the scale of pesticide applications — not all of which result in drift — can be gleaned from the Environmental Working Group’s (EWG’s) coverage of just one California county’s experience. Of course, Ventura County hosts a lot of agricultural activity, so is not representative of all U.S. counties. But EWG research found that, from 2015 through 2020, roughly 963 acres were sprayed with more than 9.1 million pounds of pesticides — an average of more than 1.5 million pounds annually. This chemical intensity happened in just one county.

Some pesticides are far more prone than others to drift: the herbicide dicamba has been the poster child for this scourge. It is extremely prone to drift in warm temperatures, and even more so, when it is mixed with glyphosate, another notorious herbicide. Dicamba, alone or paired with glyphosate, has been responsible for massive levels of damage to non–genetically modified crops (and other plants) that have no protection against the compound. As damage from dicamba has mounted, farmers have litigated left and right, legislators in the states have taken up measures to try to control the application (and therefore, the damage), and manufacturers are scrambling to keep the compound “palatable” to farmers. See more on dicamba here and here.

In a Beyond Pesticides’ 2021 National Pesticide Forum session titled “Fighting Chemical Trespass,” several victims of the phenomenon spoke about their experiences of damage to their farms, crops, livelihoods, and bodies. All of the participants suffered unwanted aerial spraying of their properties, and subsequent, lingering drift of the chemicals. (In one instance, inspectors found that pesticide residue levels were even higher seven days after the incident than at two days out, likely due to pesticide compounds that had landed on surfaces and then volatilized into the air.)

Two participants are organic farmers who could not sell their then-contaminated crops as organic, and one of them could not sell them at all because the compounds that were sprayed are illegal for use on food crops. That same farmer, who was formerly in robust health, has had massive chronic health consequences, is now legally disabled, and has acquired $100,000 in medical debt as a result of the chemical poisoning she endured across multiple incidents.

One of the farmers summarized that, as an organic producer, he has huge concerns about such chemical trespass — for the safety of the food he produces, for farmworker safety and health, for the health and integrity of pollinators and other organisms, and the surrounding environment, and of course, economic issues of lost production and income. Towering over the immediate financial concerns is that, once contaminated, a USDA (U.S. Department of Agriculture) Certified Organic farm (or at least the affected parts) must exit the certification program for three years — a huge blow to a modest organic operation.

That same farmer contends that reform of drift policy at the state level — currently a kaleidoscope of varying, or no, regulations — is critical. He also suggests that organic farmers, in particular, secure personal liability insurance for any health/medical debt they might incur as the result of a drift or spray incident. Another farmer notes that there is a huge need for medical toxicology experts who can assist victims in the often-years-long process of discovery and documentation of evidence of the harms of the trespass incidents.

Most instances of chemical trespass are never litigated. When they have been, outcomes have been mixed, as evidenced here, here, here, and here. One of the real slogs for victims of drift is that the onus for proving what happened is entirely on them: getting inspectors out immediately, and subsequently, to validate and attach metrics to the damage, quantifying ongoing economic, health, and environmental damage, and more. Most people find these prospects entirely too daunting and expensive, and applicators and manufacturers are, thus, rarely held accountable.

The U.S. Environmental Protection Agency (EPA) addresses the drift issue on its website, and assures the public that it “evaluate[s] potential for drift as a routine part of [its] pesticide risk assessments and [is] using new approaches for estimating drift impacts on communities living near fields where crops are grown, farmworkers, water sources, and the environment.” Beyond Pesticides Executive Director Jay Feldman notes, “It is rare, however, that EPA factors drift into its calculation of harm associated with pesticide use, and it is just as rare for those whose pesticide applications drift to be held accountable for the harm (short- and long-term) it causes.”

That same EPA web page also says the quiet part out loud: “As we assess new pesticides and re-evaluate older pesticides, we evaluate the potential for each pesticide to drift and strengthen labeling as needed.” Advocates say “strengthening labeling as needed” is a feeble solution to the problem. Indeed, the many lawsuits that attempt to hold applicators responsible for health, crop, and environmental harms caused by pesticide drift — and the far, far greater number of incidents that never get reported or litigated — do not tend to happen because the labeling on the pesticide containers is not quite “strong” enough. They more often happen because, as in this subject lawsuit, human negligence, indifference, or error — and the profit motive — are at work.

The nonprofit Community Environmental Legal Defense Fund (CELDF) describes the systemic situation well: “The Environmental Protection Agency, or EPA, is an appointed government agency that is charged with ‘protecting’ people and the environment. But instead, it operates more as an agency that regulates how much harm can occur before government action is required. The requirements of EPA testing, especially its lack of preventative measures, are alarming. In order to require testing of a new chemical, the EPA must first show the potential risk. No evidence of harm is interpreted as no harm, from their perspective. The problem with this way of thinking is that many of the harmful effects of chemical trespass are worsened through prolonged exposure and are often not immediately seen in testing. It’s a system designed to let corporations put toxins in our environment with no repercussions to them — but serious repercussions for people, communities, and nature.”

One genuine fix for the problem would be to deregister pesticides, such as dicamba, that are prone to drift. (Such action would be far more possible did industry not exert undue influence over EPA.) Another welcome development, surely, would be more and improved legal, medical, forensic, and technical supports for those who are exposed to chemical trespass (whether through drift or application to non-targets), at the federal and state levels. Beyond Pesticides, recognizing how vulnerable organic farms can be to impacts of these chemical trespass incidents, might recommend that USDA’s National Organic Program consider the issue of supports for organic farms in this unhappy “trespassed” circumstance. Ultimately, EPA must acknowledge the commonplace fact of drift and calculate the resulting exposure pattern and harm to people and property. If drift effects are fully calculated for their adverse impact, the “reasonableness” standard of allowable harm under EPA assessments is quickly exceeded. In this context, toxic pesticide use is unacceptable, especially given the availability and economic viability of organic practices.

Source: https://www.sfgate.com/news/bayarea/article/Helicopter-Company-Found-Liable-For-Illegal-16987408.php

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

(Beyond Pesticides, March 16, 2022) Pest damaged plants release volatile chemical “scents” that alert other nearby plants of potential predators and give them time to prepare their defenses, according to research recently published in Plant Physiology by researchers at Tokyo University of Science. The findings have important implications for agriculture, including new practices that utilize this novel process. “The effective use of plants’ natural survival strategies in production systems will bring us closer to the realization of a sustainable society that simultaneously solves environmental and food problems,” says study coauthor Gen-ichiro Arimura, PhD.

Budding research conducted since the turn of the century has discovered and confirmed that plants can communicate through specific volatile organic compounds (VOCs).  These compounds, referred to by researchers as “infochemicals,” can act as airborne signals that an herbivore danger is in the vicinity. Not only can plants within the same species communicate, there is evidence that plants will react to infochemicals produced by different species the other plant cannot produce, and may never have encountered. A recent experiment found, for instance, that soybean plants grown near mint are better able to withstand pest pressure by “eavesdropping” on VOCs produced by mint. Likewise, corn and tomato plants grown near tobacco that has emitted the VOC β-ocimene have been shown to produce defenses that indirectly attract parasitic wasps.  

Authors of the current study suspect that plant defense responses to infochemicals produced by nearby plants is initiated by epigenetic changes. “Surrounding undamaged plants exposed to odors emitted from plants eaten by pests can develop resistance to the pests. Although the induction of the expression of defense genes in odor-responsive plants is key to this resistance, the precise molecular mechanisms for turning the induced state on or off have not been understood. In this study, we hypothesized that histone acetylation, or the so-called epigenetic regulation, is involved in the phenomenon of resistance development,” explains Dr. Gen-ichiro Arimura.

Epigenetic changes are those that turn on or off the expression of certain genes in response to external stimuli. To test their theory, researchers exposed thale cress (Arabidopsis thaliana), a small flowering plant in the brassica family often used as a model test organism, to the infochemical VOC β-ocimene. The tobacco cutworm (Spodoptera litura), a common moth pest, was subsequently introduced and allowed to feed on the thale cress.  Results showed that A. thaliana plants did not respond significantly to lower levels of β-ocimene, but did respond to a higher amount that would be equivalent to that emitted by other plants (such as lima beans, or cotton). At this level, tobacco cutworm larvae exhibited significantly lower weight gain than control plants unexposed to known plant infochemcials. This enhanced defense was sustained for a period of roughly five days, generally no longer than 10.

Gene sequencing and analysis was able to follow a trail of histone acetylation, an epigenetic modification that can activate or repress gene expression, and found increased expression of defense gene regulators after VOC exposure. Scientists were able to pinpoint certain plant enzymes as responsible for activation of plant defense mechanisms.

According to a Tokyo University of Science press release, researchers are “ecstatic” to find the connection to epigenetics. The authors indicate that the process has the potential to be applied to organic agricultural systems, increasing plant resiliency, and reducing dependence on hazardous pesticides.  

There is immense untapped potential in the natural processes occurring right under our noses in agricultural fields. While chemical-dependent industrialized agriculture focuses on simplifying the landscape with man-made synthetic chemicals that harm pest and predator alike, organic farmers and incentivized to leverage the work nature is already doing, subsequently growing a safer, more sustainable food crop. Take action today to ensure organic maintains its integrity and carries along the spirit of continuous improvement by submitting a comment to the National Organic Standards Board.

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

Source: Tokyo University of Science press release, Plant Physiology

Photo Source: Tokyo University of Science press release

(Beyond Pesticides, March 16, 2022) The U.S. Environmental Protection Agency has authorized the “experimental use” and release of 2.5 billion genetically engineered (GE) mosquitoes in Florida and California by the British-based firm Oxitec. While the goal of eliminating disease carrying mosquitoes is an important public health challenge, public opinion has been consistently against the use of these animals, with nearly 240,000 individuals opposing a pilot program in the Florida Keys. Health and environmental advocates have a range of concerns with Oxitec’s approach, including the size of its latest experiment, lack of publicly verifiable efficacy data, and availability of alternative management practices not requiring GE mosquitoes.

Oxitec began public releases of its GE mosquitoes at least a decade ago, when mosquito larvae were introduced in the Brazilian town of Itaberaba. The company has consistently angled to launch its mosquitoes in the United States under the claim that the animals will reduce numbers of Aedes aegypti, a highly problematic mosquito known to vector a range of diseases, including dengue, yellow fever chikungunya, and Zika. Research analyzing Oxitec’s proposals note that the risk of dengue and other disease from Aedes aegypti is low in the United States. In a recent study in Globalization and Health that reviews the U.S. government’s approval of the Florida Keys release, the author indicates the decision,  “…is as inappropriate as the decision to propose an area where there is no fire (and virtually no risk of fire) as the site of the field test of a product that is supposed to prevent fires and act as a fire retardant.” In this context, the importance of U.S. trials to Oxitec could be to encourage other countries with higher Aedes aegypti populations to embrace their new technology, as the decisions of U.S. regulators are often used as the basis for decisions made in other countries. This would position U.S. residents and local environments as variable in an experiment approved by EPA and conducted by a foreign company for foreign buyers.

Those opposed to the massive 2.5 billion mosquito release (which is now permitted in Monroe County, Florida and Stanislaus, Fresno, Tulare, and San Bernardino counties, California) say that it is too large, and that more limited testing in a controlled environment should be conducted first. “What we would have liked to have seen is something closer to what Oxitec and the U.S. Department of Agriculture did regarding their diamondback moth releases in New York state,” said JD Hansen of the Center for Food Safety to the San Bernadino Sun. “What the (department) did, in part at our urging, were tented trials: You have an enclosed environment where you try to replicate the environment you’re releasing the insect into, as much as you can, to see what happens.”

Oxitec’s technology breeds mosquitoes to include a genetic sequence that makes the mosquito dependent on the antibiotic tetracycline. Without tetracycline, mosquitoes will not develop into adulthood. The company releases male mosquitoes with this genetic sequence into the environment to breed with females. When it works correctly, the offspring produced will also have tetracycline dependency and not develop into adulthood.

A spokesperson for Oxitec told the San Bernadino Sun that it had reduced A. aegypti numbers in an area by 98%. But that claim is not publicly verifiable, as U.S. regulators permit companies to maintain their internal data as confidential business information. What publicly available data there is on GE mosquitoes do not indicate efficacy at that level. In 2012, confidential Oxitec documents obtained by the British group Genewatch UK showed that 15% of GE animals were able to survive to adulthood. This was because mosquitoes were being reared on canned chicken cat food that contained trace levels of tetracycline from its production process. In the context of the current proposed releases in agricultural areas of California, EPA’s authorization limits release within 500 meters of a wastewater treatment plant, orchard crops, and livestock facilities, but it still remains highly likely that low levels of tetracycline in the environment will be encountered.

The experience of the Cayman Islands provides the clearest indication of the program’s limited efficacy. After contracting with Oxitec for two years and releasing millions of GE mosquitoes, Cayman Island officials were set to renew their contract. But data from the trials indicated serious problems, leading the territory’s environmental health minister to tell the Edmonton Journal, “The scheme wasn’t getting the results we were looking for.” Briefing, documents again uncovered by Genewatch indicated “no significant reduction in the abundance of mosquitoes in the released area,” and further found that the number of biting, disease-spreading females had actually increased. Cayman Island Officials indicated concern that the approach could be spreading antibiotic resistance or make mosquito-borne diseases worse by lowering immunity. Tellingly, Oxitec’s failed proposed plan with the Caymans would have included supplemental use of mosquito adulticides, a practice the company claims the GE technology would eliminate.

Neither GE mosquitoes nor highly hazardous insecticides should be the primary line of defense against mosquito problems. Control of disease-carrying mosquitoes can be successful when emphasis is placed on public education and preventative strategies. Individuals can take action by eliminating standing water, introducing mosquito-eating fish, encouraging predators such as bats, birds, dragonflies and frogs, and using least-toxic larvicides like bacillus thuringiensis israelensis (Bti). Community based programs should encourage residents to employ these effective techniques, focus on eliminating breeding sites on public lands, and promote monitoring and action levels in order to determine what, where, and when control measures might be needed. Through education of proper cultural controls, and least-toxic and cost effective biological alternatives, the use of risky toxic pesticides and experimental technologies like GE mosquitoes can be avoided.

For additional information and resources on least-toxic mosquito control alternatives, see Beyond Pesticides’ Mosquito Management program page.

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

Source: San Bernadino Sun, Globalization and Health, Regulations.gov

(Beyond Pesticides, March 15, 2022) Adding animal diversity to rice paddy farms reduces weed pressure, increases food production, and makes fertilizer use more efficient, according to a study published late last month in the journal eLife. As chemical-dependent, industrialized agriculture has spread across the world, local farmers are increasingly pressured into eschewing traditional agricultural practices in favor of monocultures in an attempt to meet the demands of global markets. This one-size-fits-all approach oversimplifies the interdependency within ecosystems, failing to incorporate the complexity of nature that many traditional and organic practices embrace. As the present study shows, research and investment into systems that promote natural diversity can provide insights that allow these approaches to leapfrog the chemical-dependent, monoculture paradigm of industrial agriculture.

Rice paddy fields are intentionally flooded, and crops are often grown in shallow water. In industrialized fields, monocultures of rice are planted out, and fertilizers and weed killers are applied at regular intervals. However, many traditional rice farmers around the world integrate aquatic animals into their paddies. In the present experiment, researchers conducted a 4-year long evaluation comparing the benefits of monoculture production against co-cultures of rice and aquatic animals. Co-culturing animals and rice differs slightly from traditional practices that incorporates the additional direct feeding of aquatic animals for market (in traditional practices, animals generally are not provided supplemental feed).

To compare the different systems, researchers established field plots with rice-carp, rice-crab, and rice-turtle co-cultures (these animals are widely eaten in rice-growing regions), as well as a rice monoculture. A mesocosm (an enclosed environment that examines natural processes under controlled conditions) experiment was also established with the same systems to evaluate nutrient efficiency. Animals in the diverse fields were introduced one week after rice transplant, provided with supplemental feed in the form of spent soybean residue (a waste product after soybean oil is extracted), and remained in the fields until rice harvest.

When compared to monoculture rice production, rice yield was on average 8% higher in the rice-turtle system, 9% higher in the rice-carp co-culture, and 12% higher for rice-crabs. Animal yields were 2.66, 0.85, and 0.56 metric tons per hectare for the rice-turtle, rice-carp, and rice-crab systems, respectively. Prior research conducted by the authors found that rice-turtle, rice-carp, and rice-crab systems increased total economic output by 710%, 205%, and 78%, respectively, over a monoculture rice system.

The diversified animal system also significantly lowered weed pressure on the farms in comparison to the monoculture fields. Weeds and other food (e.g., algae, plankton) from the paddy environment ended up comprising a significant portion of the aquatic animals’ food; for carp, crab, and turtle systems, 50%, 35%, and 16%, respectively. The researchers used no herbicide in any of the experimental plots, and there is evidence from the diverse plots that no herbicide use would be needed based on the weed pressure alleviated.

Diverse animal paddies also displayed faster rates of organic matter decomposition, indicating improved nutrient cycling. In the mesocosm experiments, feed that was not consumed by animals made its way into the crop, accounting for upwards of 30% of rice biomass. Compared to the monoculture fields, by the end of the experiment soil nitrogen content was higher in animal fields.

In aquatic rice cultures, the introduction of animals represented a multifunctional boon – reducing weed pressure, increasing nutrient recycling and availability, and subsequently yields. This process provided significant benefits to farmers, who received a higher price for their work. The authors note, “Although costs of the cocultures are higher than the costs of monoculture because of the feed input and increased labor required for the management of two species, net income was still higher for cocultures than for monocultures because of the higher prices of the products and the reduced use of fertilizers and pesticides.”

The forced simplicity of monoculture farming in a diverse and complex environment is ultimately unsustainable. It is common sense that clearing land of all flora and fauna and replacing it solely with human-focused crops leads to biodiversity decline and the loss of pollinators and other beneficial species, but scientific research has backed up these judgements. Agricultural soils under monocultures are not nearly as healthy as those that embrace diversity. Soil organic matter and nutrient cycling, critical for sustainable crop growth, is lower in monoculture systems by two to three fold, according to recent research.

The solution is as simple as the problem that was created. Adding back in plant diversity and moving from monoculture to multi-cropping systems produces higher biomass and seed yields, and reduces pest pressure and the need for pesticide use.

Organic agriculture provides the closest approximation to the sustainable food system the future requires. While organic has not yet eliminate monocultures, it requires farmers to maintain or improve soil health, which has the effect of encouraging practices that embrace natural diversity and complexity. Organic laws and rulemaking also support the concept of continuous improvement, incentivizing the development of safer and more sustainable practices once they become available. Naysayers of diverse organic systems point to yield gaps and cost, but fail to recognize the research and development gap between conventional and organic. As this study reveals, analysis of an enhanced traditional cropping system displays yield gains over an industrialized approach. With further research and development into traditional and organic cropping systems, the next agricultural revolution has the potential to be significantly more sustainable than the current paradigm.

For more information on the benefits of organic see Beyond Pesticides Why Organic webpage.

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

Source: eLife

(Beyond Pesticides, March 14, 2022) The National Organic Standards Board (NOSB) is receiving written comments from the public through April 1. This precedes the upcoming public hearing on April 19 and 21—concerning how organic food is produced. Written comments must be submitted through Regulations.gov. For details on the all the issues of importance to organic integrity, please see Beyond Pesticides’ Keeping Organic Strong webpage.

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

The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2022 issues page. Here are some high priority issues for us:

Cetylpyridinium chloride (CPC) is a quaternary ammonium compound (quat or QAC) that is being petitioned for use on raw organic poultry. The class of QACs includes several toxic sanitizers and disinfectants as well as the highly toxic herbicides paraquat and diquat. CPC is highly toxic, and poses a particular hazard to workers. CPC residues have been discovered on treated surfaces and poultry skin, exposing consumers to unlabeled pesticide residues. It is unnecessary in organic production, and the petition should be denied.

The NOSB is considering a proposal limiting the use of highly soluble nitrogen fertilizers in organic production. This follows on recommendations by the NOSB in Fall 2021, prohibiting the use of stripped ammonia and concentrated ammonia as fertilizers in organic crop production. In recognition of the fact that their high solubility makes them inconsistent with organic

production, which “feeds the soil, not the plant,” the Crops Subcommittee proposes to generalize the prohibition unless use is restricted to no more than 20 percent of the crop’s total nitrogen requirement. USDA has stated that it will not implement the prohibition of stripped ammonia and concentrated ammonia unless this proposal passes. The NOSB should pass this proposal to protect organic integrity.

Biodegradable Biobased (Bioplastic) Mulch Film (BBMF) is under consideration for sunset this year. Although the NOSB will not vote on BBMF until the Fall 2022 meeting, this is part of a larger issue of the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles to which it degrades—on human health and the environment. BBMF should not be relisted. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic production and handling—including packaging.

Please feel free to use the text above to highlight for the NOSB the concerns of these key issues.

>>Submit Comments Now.

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the three comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)

Thank you for keeping organic strong!

(Beyond Pesticides, March 11, 2022) With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that allows the continued use of the deadly organophosphate insecticide malathion. This just the latest example of what advocates see as an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases.  

In a head-spinning development, the U.S. Fish and Wildlife Service (FWS) announced on March 8 its final Biological Opinion (BiOp) on malathion, which opinion claims that the commonly used insecticide poses no extinction risk to any protected animal or plant. The FWS review and BiOp are part of EPA’s evaluation of whether malathion — an organophosphate insecticide that causes serious damage to many organisms — should retain its registration. The Executive Summary of the BiOp concludes: “Our findings suggest that no proposed species or candidate species would experience species-level effects from the action [i.e., registration and thus, permitted use of malathion], and, therefore, are not likely to be jeopardized. We also conclude the proposed action is not likely to destroy or adversely modify any proposed critical habitats.” Advocates view this BiOp as a terrible setback for biodiversity and wildlife, including pollinators, aquatic organisms, and birds, and for fragile ecosystems.

More than a million pounds of malathion are used annually in the U.S. on cotton, corn, and other crops; as of 2018, another two million pounds was also in use for home gardens, miscellaneous purposes, and mosquito control. Pest management entities, whether private companies, states, or localities, deploy malathion for adulticiding of mosquitos — a notoriously ineffective strategy that uses spray trucks in the hope of “knocking down” mosquitoes that happen to be in the immediate area at a given moment.

Malathion spray, whether for mosquitoes or on crops, can travel and impact a wide area, exposing nontarget organisms and humans alike. In humans, malathion exposure is linked with reproductive, endocrine, neurological, hepatic, renal, and developmental harms. Its terrible impacts on wildlife are well-documented. Further, as Beyond Pesticides covered in February 2022, widespread, intensive pesticide use for mosquito control has catalyzed development of resistance to those same pesticides in some mosquito populations — an inevitable outcome of chemical treatment of pests. A shift to alternative strategies is overdue.

The history of EPA and malathion is fraught. In 2017, after an EPA finding that use of organophosphate insecticides has negative impacts on more than 1,000 endangered and threatened species — and that malathion, specifically, threatens 1,284 species — Dow Chemical pressured the Trump administration to ignore the studies that underlay that finding. Later that year, the administration sought a two-year delay in EPA’s review of malathion. In 2019, the Center for Biological Diversity (CBD) discovered documents that showed that the Trump administration had this information on the harms to species in 2017 and suppressed it. Indeed, top officials at the Department of the Interior, including Acting Secretary David Bernhardt, knew of and stopped the release of a FWS BiOp that showed the extent of the dangers of this class of pesticides.

According to the Associated Press, “[FWS] officials now say malathion could cause limited harm to hundreds of species, but is unlikely to jeopardize any of them with extinction as long as labels that dictate its use are changed,” but advocates insist that proposed changes to labels would do little to protect species that in some cases have dwindled to very few individuals.” In addition, this “no extinction” claim, even if borne out, would depend utterly on the voluntary compliance of farmers, pesticide applicators, and consumers to use the insecticide exactly according to label instructions — which will not even be developed for another 18 months. This BiOp represents an unacceptable gamble with endangered ecosystems and organisms.

The FWS opinion contradicts the agency’s 2021 BiOp (no longer available on the EPA website), which asserted that, due to registration and use of the insecticide, “78 listed species could be jeopardized, and 23 critical habitats could be adversely modified by the use of malathion.” This final, 2022 BiOp also contradicts the agency’s 2017 conclusion “that 1,284 species would likely be jeopardized by malathion.” According to the Center for Biological Diversity, both that 2021 assertion and this final BiOp used “debunked Trump-era methodology promoted by the pesticide industry” as the bases for the opinion.

Only a week prior to the March 8 release of the final BiOp, FWS’s co-equal agency, the National Marine Fisheries Service (NMFS), issued an updated draft BiOp, which concluded in part: “For malathion, we present draft conclusions that EPA’s action is likely to jeopardize the continued existence of 37 species, and likely to destroy or adversely modify critical habitat for 36 species.” It also asserted that malathion (and two notorious cousin organophosphate pesticides) threaten nearly every endangered salmon, sturgeon, and steelhead species in the U.S.

CBD notes that this NMFS BiOp “debunks the Trump methodology that based harm analyses on historic use data known to be incomplete and unreliable. . . . Yet the Fish and Wildlife Service continued to heavily rely on the same historic use data in its analyses to reach conclusions that the pesticide would not harm endangered species.” CBD also writes, “The widely disparate findings by the two agencies were highlighted in harm assessments for bull trout and salmon, biologically similar species that share habitat in the Pacific Northwest. [FWS says] that malathion won’t harm bull trout in Pacific Northwest streams; meanwhile [NMFS] has concluded that the use of the very same chemical in the very same streams is pushing every Pacific salmon to extinction.” CBD’s environmental health director, Lori Ann Burd, commented: “One’s based on sound science, and one’s based on industry-driven politics. [NMFS] is bravely taking a stand to prevent extinctions while [FWS] is continuing to cower to an anti-science, anti-endangered species agenda.”

EPA struck a cheerier note in its press release on the BiOp with the headline, “EPA Takes Steps to Protect Endangered and Threatened Species from Insecticide.” And FWS’s assistant director for ecological services, Gary Frazer, frames the BiOp differently, saying that despite the 2021 BiOp, FWS “worked with EPA, the malathion registrants and USDA to develop general and species-specific conservation measures that significantly reduce many of the effects of malathion use on listed species and their critical habitats.”

FWS insists that implementation of new conservation measures — changes in the text on the pesticide’s label, reductions in the maximum number of allowable applications per year, establishment of buffers from aquatic habitats, and restrictions from application when rain is forecast or when certain crops are in bloom — will eliminate “the problems identified earlier.” EPA has said it will provide online details for protocols that users of malathion should follow, such as no spray zones in areas of critical wildlife habitat. But many of these have been designated as voluntary “guidelines,” rather than compulsory rules.

CBD has decried this final BiOp; Beyond Pesticides joins in this response to EPA’s shocking avoidance of the scientific evidence on malathion. CBD’s Brett Hartl commented, “This is an enormous punt. There’s not a single endangered species that will see anything change on the ground because of this biological opinion for at least 18 months, but probably never.”

CBD’s Lori Ann Burd issued this statement: “The Biden administration has squandered a[n] historic opportunity to rein in the dangerous use of one of the world’s worst neurotoxic pesticides. By ignoring the best available science and choosing to rely on unenforceable promises of good behavior by the pesticide makers rather than real, on-the-ground conservation measures, the Biden administration is condemning wildlife to extinction with a wink and a nod. This decision to cave to powerful special interest groups will do far-reaching harm to our most endangered wildlife.”

To learn more about impacts of malathion and other pesticides on biodiverse and functional organisms, wildlife, and ecosystems, see the work of the Center for Biological Diversity, and Beyond Pesticides’ coverage: Mosquito Control and Pollinator Health, The Truth About Mosquitoes, The Health Effects of Pesticides Used for Mosquito Control, Pesticide Use Harming Key Species Ripples through the Ecosystem, and its Daily News Blog archives on malathion.

Sources: https://biologicaldiversity.org/w/news/press-releases/us-fish-and-wildlife-service-refuses-to-protect-any-endangered-species-from-neurotoxic-pesticide-2022-03-08/ and https://apnews.com/article/science-business-animals-wildlife-billings-e3443e0a0ff76211d1e1bb0275f9385b

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

(Beyond Pesticides, March 10, 2022) Glyphosate and glyphosate-based herbicides (GBH) like Roundup® induce DNA damage and alter biological mechanisms (gene regulatory microRNAs [miRNAs or miRs]) associated with cancer development. According to the study published in Toxicological Sciences, DNA damage mainly occurs through oxidative stress from GBH exposure. Moreover, DNA damage and other biological mechanisms that cause carcinogenicity (cancer) occur at doses assumed “safe” by pesticide regulators such as the U.S. Environmental Protection Agency (EPA).

Glyphosate is the most commonly used active ingredient worldwide, appearing in many herbicide formulas, not just Bayer’s (formerly Monsanto) Roundup®. The use of this chemical has been increasing since the inception of crops genetically modified to tolerate glyphosate over two decades ago. The toxic herbicide readily contaminates the ecosystem with residues pervasive in food and water commodities. In addition to this study, literature proves time and time again that glyphosate has an association with cancer development, as well as human, biotic, and ecosystem harm. 

Study lead author Michael Antoniou, Ph.D., cautions, “Our results are the first to simultaneously show glyphosate and Roundup toxicity in a whole mammalian animal model system and provide a mechanism – oxidative stress – by which DNA damage has been observed in other systems, such as mammalian tissue culture cells. These findings show that glyphosate and Roundup score positive in various tests of carcinogenicity – transcriptome/epigenome/miRNA changes, oxidative stress, protein misfolding, and DNA damage – in a living animal (rat) that is accepted as a surrogate for human health effects. In my view, this strengthens the argument that exposure to Roundup herbicides can lead to the type of cancer suffered by the plaintiffs in many of the court cases – non-Hodgkin lymphoma.”

This study represents a follow-up that builds on the finding of a previous one by the same authors. The previous study compared the effects of MON 5227 (an active ingredient in Roundup) and glyphosate alone in rats and found both ingredients to cause gut microbiome disruption and oxidative stress related to possible liver damage. Thus, the present study intends to determine damages in the liver by analyzing tissue samples. Following standard regulatory testing for pesticide approval, researchers investigated biochemical changes in the blood of the kidneys and liver after exposure to glyphosate and four active ingredients in Roundup formulas: MON 52276 (European Union), MON 76473 (United Kingdom), and MON 76207 (United States). Additionally, researchers performed tests not carried out by standard testing, including observation on molecular changes in the biological function of gene expression and epigenetics (e.g., DNA methylation that changes the activity but not the sequence of a DNA segment) in the kidneys and liver. To highlight changes in biological function linked to cancer, researchers used genetically engineered (GE) cell lines and tested them for direct DNA damage.

The results confirm that liver damage occurs from exposure to glyphosate and Roundup, leading to alterations of gene expression and miRNA (small RNA) in the liver. Specifically, glyphosate and MON 52276 alter nine gene expressions in the liver and kidneys responsible for oxidative stress and DNA damage, prompting cancer development. Researchers suggest changes in miRNA can disrupt the regular function of cell growth regulator genes, like p53, resulting in cancer. The changes in gene expression of p53 strongly indicate a possible pathway for DNA damage and thus a major cancer development risk factor. Furthermore, various research, including this one, demonstrates increases in small RNA, like miR-10 from GBH exposure, have an association with blood cancer development, particularly leukemia and non-Hodgkin lymphoma. Dr. Antoniou notes, “The new data showing changes in miRNA patterns add yet more evidence to the cancer-causing potential of glyphosate and Roundup. What is more, our results show that it is not just Roundup, which is a mixture of glyphosate with various additives, that has carcinogenic potential, but also glyphosate alone.”

Almost five decades of extensive glyphosate-based herbicide use has put human, animal, and environmental health at risk. The chemical’s ubiquity threatens 93 percent of all U.S. endangered species, resulting in biodiversity loss and ecosystem disruption (e.g., soil erosion, loss of services). Exposure to GBHs has implications for specific alterations in microbial gut composition and trophic cascades. Similar to this paper, past studies find a strong association between glyphosate exposure and the development of various health anomalies, including cancer, Parkinson’s disease, and autism. Although EPA classifies glyphosate herbicides as “not likely to be carcinogenic to humans,” stark evidence demonstrates links to various cancers, including non-Hodgkin lymphoma. Thus, EPA’s classification perpetuates environmental injustice among individuals disproportionately exposed to chemicals like farmworkers, especially in marginalized communities.  Chemical companies knowingly failed and continue to fail to warn farmers adequately about the dangers of the pesticide, and that the manufacturer’s (Bayer/Monsanto) chemical review conclusions are supported by accurate science.

The territory for research on pesticides’ potential carcinogenicity, and other impacts on human health, is almost ridiculously complicated. Yet there is some convergence across research that exposure to certain pesticides increases the risk of developing some cancers. The association that has been in the blinding spotlight for the past few years is between exposures to glyphosate and glyphosate-based herbicides and the risk of developing cancer, particularly non-Hodgkin Lymphoma (NHL). Beyond Pesticides has covered the mounting evidence of the dangers of glyphosate, including a meta-study that suggests a compelling link between exposures to glyphosate-based herbicides and increased risk of NHL.

In addition, it has written extensively on developments in the science and regulatory arena, including:

• the International Agency for Research on Cancer (IARC) 2015 landmark designation of glyphosate as potentially carcinogenic
• evidence that the Environmental Protection Agency colluded with Monsanto (maker of Roundup, the most widely used glyphosate-based herbicide) to advantage industry and that Monsanto had ghostwritten research that countered scientific conclusions on the cancer associations of the compound
• And California’s 2017 listing of glyphosate under Proposition 65 as a probable carcinogen and a 2018 Appellate Court affirmation of its ability to do so.

Glyphosate has been the subject of a great deal of public advocacy and regulatory attention, as well as the target of thousands of lawsuits. Beyond Pesticides has covered the glyphosate tragedy extensively; see its litigation archives for multiple articles on glyphosate lawsuits. In June 2020, facing approximately 125,000 suits for Roundup’s role in cancer outcomes, Bayer announced a $10 billion settlement to resolve roughly 75% of current and potential future litigation. However, roughly 30,000 complainants ultimately did not sign on to the settlement, so the queue of potential lawsuits is still potentially enormous. Although Bayer tried for a second settlement (~ $2 billion) to handle future claims, a U.S. District Court judge for the Northern District of California rejected Bayer’s 2021 settlement proposal. The judge stated that the settlement was inadequate for future victims diagnosed with cancer after using the herbicide. Bayer has never acknowledged any harm caused by glyphosate, maintaining the chemical is safe for use. However, in July 2021, Bayer announced its plan to end sales of its glyphosate-based herbicides (including its flagship product, Roundup) in the domestic U.S. residential lawn and garden market in 2023.

For the first time, this study demonstrates epigenetic changes in DNA, proteins, and small RNA profiles in the liver of organisms exposed to glyphosate and Roundup formula MON 52276. Researchers observed activation of DNA repair mechanisms in response to DNA damage from glyphosate. Moreover, oxidative stress and the unfolding of proteins occurred at lower concentrations of Roundup, in which the same concentration of glyphosate produced no effect. The researchers recommend regulators rely on methods to detect metabolic changes that conventional biochemical and tissue analyses overlook. Glyphosate acts on the shikimate pathway, present in plants, fungi, bacteria, archaea, and protozoa. Thus, many taxonomic groups of microorganisms are sensitive to glyphosate. Moreover, chronic exposures to the herbicide could lead to the dominance of resistant strains in bacterial communities. Some glyphosate-vulnerable bacterial strains can become resistant to glyphosate (glyphosate-tolerant class II EPSPS). For instance, glyphosate-resistant bacterial strains like E. coli and Pseudomonas alter gene function to enhance the outflow of glyphosate from the bacterial cell. Thus, this resistance mechanism encourages cross-resistance against antibiotics for pathogenic bacterial species like E. coli and Salmonella, altering the microbiome.  

Overall, the researchers determined oxidative stress, an imbalance between reactive oxygen species (ROS) and biological mechanisms to detoxify ROS, likely causes liver damage. This liver damage, in turn, leads to inflammation that can damage DNA and prompt carcinogenicity. Similar to this study, others suggest that glyphosate may impact other metabolic pathways beyond the known Shikimate. A report by the University of Turku, Finland stated, “Even in glyphosate-resistant species, the interference of the herbicide on mitochondrial metabolism may induce oxidative stress and lead to toxic effects.”

Although Bayer announced the end of glyphosate sales by 2023, sales of Roundup will continue with different active ingredients. It is essential to note that the study also demonstrates ingredients in Roundup are even more toxic than glyphosate itself. Therefore, new formulations without glyphosate do little to mitigate the problem, especially regarding synergistic (combined) impacts of so-called “inert” ingredients in glyphosate formulations.

Considering pesticide exposure does not affect just one part of the body, but multiple organs, more studies need to assess what other organs or biological mechanisms glyphosate targets, triggering cancer development. These results could strengthen the legal cases of cancer patients in the U.S. who are suing Bayer/Monsanto because they have evidence that their exposure to Roundup caused their disease. The authors conclude, “[A]doption by regulatory agencies of multi-omics analyses would result in more accurate evaluation of a chemical’s toxicity and therefore better protection measures being enacted with major public health benefits.”

Cancer is one of the leading causes of death worldwide, with over eight million people succumbing to the disease every year. Notably, IARC predicts an increase in new cancer cases from 19.3 million to 30.2 million per year by 2040. Therefore, studies related to pesticides and cancer will aid in understanding the underlying mechanisms that cause the disease. Beyond Pesticides challenges the registration of chemicals like glyphosate in court due to their impacts on soil, air, water, and our health. While legal battles press on, government officials must eliminate the use of toxic synthetic herbicides to avoid the adverse effects of chemical exposure and contamination. Instead, emphasis on converting to regenerative-organic systems and using least-toxic pest control to mitigate harmful exposure to pesticides, restore soil health, and reduce carbon emissions, should be the main focus. Public policy must advance a shift to organic rather than allow unnecessary reliance on pesticides. Considering glyphosate levels in the human body decrease by 70% through a one-week switch to an organic diet, purchasing organic food whenever possible—which never allows glyphosate use—can help curb exposure and resulting adverse health effects.

It is essential to understand the health implications of pesticide use and exposure for humans, especially if pesticides increase chronic disease risk. Beyond Pesticides tracks news and studies related to pesticides through the Daily News Blog and Pesticide-Induced Diseases Database (PIDD). This database supports the clear need for strategic action to shift from pesticide dependency. For more information on the adverse effects of pesticides on human health, see PIDD pages on cancer (including lymphoma) and other diseases. Moreover, Beyond Pesticides provides tools, information, and support to take local action: check out our factsheet on glyphosate/Roundup and our report, Monsanto’s Roundup (Glyphosate) Exposed. Contact us for help with local efforts and stay informed of developments through our Daily News Blog and our journal, Pesticides and You. Additionally, check out Carey Gillam’s talk on Monsanto’s corruption on glyphosate/Roundup at Beyond Pesticides’ 36th National Pesticide Forum.

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

Source: GM Watch, Toxicological Sciences 

(Beyond Pesticides, March 9, 2022) In response to local concerns around children’s environmental exposures, the Minnesota Department of Health (MDH) recently published biomonitoring data collected from young children living in urban and rural areas of the state. The findings provide local residents and lawmakers with baseline data on the hazards children are encountering where they live, learn, or play, and point to ways in which families can reduce or eliminate these dangers. With evidence that early life exposures during “critical windows of vulnerability” increase risk of long-term health problems, it is critical for state agencies to both collect data, and take meaningful action to protect children from future harms.

Minnesota lawmakers established a state biomonitoring program in 2007, and have since expanded the project. The current report represents the results of MDH’s Healthy Rural and Urban Kids Project aimed at biomonitoring chemicals in young children. For this round, the agency focused on preschool-aged children living in MN’s rural Becker, Todd, and Wadena counties, as well as those living in urban North Minneapolis. MDH enrolled 232 families during the summer of 2018, provided them with a questionnaire, and tested children for 21 different chemicals in their urine. The chemicals tested were chosen with community input and guidance from a scientific advisory panel. The focus was placed on understanding the impact of air pollution, pesticides, and toxic metals in the environment.

The results did show differences in exposures between rural and urban children. Pesticide exposure also displayed a level of urban/rural divide. Children living within roughly ½ mile of a corn field (which included 61% of rural children tested) were more likely to have traces of the herbicide 2,4-D in their urine than children not living near farm fields. Likewise, living near a soybean field was correlated with higher rates of 3PBA, a metabolite for the synthetic pyrethroid class of insecticides. In urban areas, pesticide use in the home was most closely associated with higher urinary levels of 3PBA. Twenty-three percent of all families had used pesticides in their homes within the last three months. Most concerning, children in urban areas who had pesticides used in the home more than two times within the last three months had urinary levels of 3PBA that were 3x higher than urban families that did not use pesticides.

Of the air pollution chemicals measured, including various polycyclic aromatic hydrocarbons (PAH) and other chemicals created from burning or combustion, researchers found that kids in urban areas had higher rates of exposure than those living in rural areas. Additionally, children whose families used incense in the home had higher rates of the PAH 2-Hydroxynaphthalene (2NAP). The connection is not certain, but no other links were found between 2NAP and other potential environmental exposures. Children living in homes where incense was used recorded nearly 2x higher rates of 2NAP in their urine. Among the metals tested (arsenic, chromium, cobalt, manganese, and nickel), high levels of arsenic were found in children that ate rice frequently; kids who ate rice more than 3x per day had over 2x as much arsenic their urine than those who did not.

The results of this project generally line up with prior research on public exposure to environmental hazards. Data published just last month finds that one-third of Americans have detectable levels of 2,4-D in their bodies. As Marlaina Freisthler, a PhD student and researcher at the George Washington University, noted, “These findings raise concerns with regard to whether this heavily used weed-killer might cause health problems, especially for young children who are very sensitive to chemical exposures.”

Likewise, synthetic pyrethroids are frequently detected in the general population. These chemicals are used on farms, landscapes, as well as in the home in commonly sold spray products like RAID®, HOT SHOT®. Widespread use is particularly concerning in light of peer-reviewed data on the dangers these chemicals pose to children’s health. Multiple studies have been published linking synthetic pyrethroids and household pesticide use to developmental problems in children, including ADHD and impacts on motor skill development. Research finds that young boys exposed to synthetic pyrethroids are more likely to experience early onset of puberty, and exposed children are in general at greater risk of developing a respiratory disease.

MDH’s biomonitoring project reveals timely and helpful data that can provide individual families, the general public, and lawmakers with the support necessary to make positive changes that safeguard children’s health. The state expects to both follow-up on and expand this project into a larger statewide program called Healthy Kids Minnesota. “The point is to more systematically move across the state to include more kids and more chemicals,” said Jessica Nelson of MDH to DL-Online. “Each year we’ll do a new non-metro area and five areas in the metro.”

As the state collects data and residents wait for action to reign in toxic exposures to pesticides and other environmental hazards, U.S. residents throughout the country can find steps to move protective action forward in their state or community on Beyond Pesticides Children and Schools program page.

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

Source: DL-Online, Minnesota Department of Health

(Beyond Pesticides, March 8, 2022) A silver lining has emerged from the past two devastating Covid years, according to Civil Eats. A large California school district has used pandemic changes — in the regulatory schema of the federal and state governments, in supply chain function, and in available funding — to catalyze the transition to organic food in school-based feeding programs. For the past decade or so, U.S. school districts have, here and there, been moving gradually in this direction. The West Contra Costa Unified School District (WWCUSD) is robustly making the transition to organic, in no small part through its collaboration with Conscious Kitchen, a local nonprofit that seeks to “break the cycle of conventional, packaged, overly processed food, [and] transitioning to meals based on five foundational attributes: fresh, local, organic, seasonal and nutritious.” Beyond Pesticides has long pointed to the importance of shifting school-based meals to organic for multiple reasons, but centrally, because the pesticides with which conventional food is generally contaminated have outsized health and developmental impacts on children.

The WWCUSD, which is northeast of San Francisco, boasts 30,000 students — 75% of whom come from low-income households. The district’s food service director, Barbara Jellison, and other food service leaders in the state have seized the moment of Covid disruption and the “pause” in standard operating procedures to shift toward what she sees as better food for her students. Food service in many, if not most, schools in the U.S. was turned upside down with the twists and turns of navigating Covid protocols amid remote learning, hybrid learning, and in-person learning, as well as constantly changing attendance patterns, masking requirements, and staffing shortages, among other factors.

In addition, as Civil Eats reports, “numerous disruptions loosened regulations that [have made] it difficult for any supplier other than the largest conventional food companies to get their food into cafeterias. The federal and state government both sent extra funds to California schools to ensure children would not go hungry. And global supply-chain snags gave smaller, local farms a leg up; many of those farms in Northern California are organic.”

As Covid arrived, WWCUSD’s food service teams first made hot meals available for pick-up by low-income families. That then shifted, because of a U.S. Department of Agriculture (USDA) waiver, to distribution of boxes of raw ingredients — with enough ingredients for a week’s worth of three daily meals plus snacks. In the fall of 2020, when the district was in remote mode, Ms. Jellison called Judi Shils of Conscious Kitchen to ask for help. She wanted to shift at least some of the contents of the food boxes to organic.

Ms. Shils contacted some of those local Northern California organic farms and food vendors, including Full Belly Farm, Earl’s Organic, and Lundberg Family Farms, and the organic transition was soon under way. In short order, Ms. Jellison’s team was distributing more than 20,000 boxes each week, and could provide items such as ground beef, beans, grains, fruits, and vegetables. By March 2021, the food boxes were 100% organic, and the district had invested $17 million in the purchase of 10.7 million pounds of organic food for students’ low-income families. The Conscious Kitchen website provides an excellent array of infographics and other information on the program here.

Civil Eats notes Ms. Shils’s comment: “It was incredible to see what can happen during a pandemic, when all [the farms] needed was business and when all families needed was food. And then I thought, ‘Okay, we’re going to go back to school someday. How do we keep the integrity of the supply chain in a district that has never had organic food?’” Previously, such small organic producers would have had little chance of participating in the school lunch bid process because USDA regulations made it difficult for suppliers other than large, conventional food processors/companies to get a foot in the cafeteria door. Now, all these small, organic producers had become vendors in the system. This has had knock-on effects on local organic growers and producers, many of whom had lost wholesale restaurant and other accounts because of lowered demand during the pandemic.

Another salutary outcome of the push for organics in schools was their introduction into federal food purchasing programs, and especially into one called “DoD Fresh.” With the full and unwieldy moniker, “U.S. Department of Agriculture (USDA) Department of Defense (DoD) Fresh Fruit and Vegetable Program,” DoD Fresh had historically had no organics available in the subsidized, bulk food program for schools; policy advocacy by Friends of the Earth and other organizations changed that.

Deputy director of food and agriculture at Friends of the Earth (FOE), Kari Hamerschlag, commented, “Until recently there was no organic available [in the program]. So we worked with the suppliers in both Northern California and Southern California . . . and we got them to add a whole slew of different organic products.” Civil Eats reports FOE’s estimate that, in a three-month period in late 2021, that change resulted in 80,000 pounds of organic food (worth $100,000) showing up in California school-based meals.

So, though further progress will not be free of challenges, the two women believe they have sufficient sourcing and coordination infrastructure and protocols in place so that what they have accomplished can be replicated in other districts. Ms. Shils notes that already, they can see ripple effects: “Those companies that we were connected to and supported us and we supported them through the majority of the pandemic . . . they’re learning how to work with schools and how to reformulate some of their items to meet our requirements, and hopefully will be able to support other school districts in time.”

One example of that ripple was the work Ms. Shils and Ms. Jellison did with Mindful Meats (purveyor of organic, grass-fed beef from retired dairy cows) to develop a pre-cooked burger patty that would work once students returned to in-person school. That burger was then added to the repertoire of food service in the San Francisco Unified school district, which lacks “from scratch” cooking facilities. Then came sourcing of organic burger buns from Alvarado Bakery. Item by item, districts are ratcheting up the organic content of school meals. Ms. Jellison “is checking off each organic box,” according to Civil Eats; she adds, “Since we’ve gone back into the schools, we’ve made tremendous gains that we weren’t able to do during that pilot year.”

The women believe that the best path for districts in this pursuit is to partner with nonprofits working in the sector. For WWCUSD, the partnership with Conscious Kitchen was transformative, allowing an already stressed and challenged food service system to make significant headway. Ms. Shils commented, “Most food service directors are up to their eyeballs, especially now, in regulations and they don’t have time to think. Every community I believe could have a partner. There are lots of nonprofits out there.”

A focus on getting organics into school feeding programs has been afoot for years, and has proponents in multiple places, including in Congress and in state houses. A 2020 study out of the University of California Berkeley found that roughly 30% of school districts in the state are purchasing some organic food items. Farm-to-School nonprofits and programs have sprouted up in many states, and USDA’s Food and Nutrition Service conducts a grant program for such initiatives. The California Department of Food & Agriculture recently published its report on the farm-to-school movement, Planting the Seed, which provides guidance on how to expand, support, and strengthen such programs in the state.

The report emphasizes the potential for such programs to address multiple critical issues, noting that farm-to-school programs “serve as a powerful tool to build demand and expand markets for producers that use . . . verified climate smart agriculture production systems, including certified organic and transitioning to organic certification systems.” Civil Eats notes that one of the report’s working groups recommended that building relationships between organic producers and schools should be a top priority.

Multiple school districts across the nation — in Boston, New York City, Buffalo, Washington, DC, Los Angeles, Denver, Austin, Chicago, Cincinnati, Pittsburgh, and a few others — are working with the nonprofit Center for Good Food Purchasing to move the needle on organic purchasing. The center “uses the power of procurement to create a transparent and equitable food system that prioritizes the health and well-being of people, animals, and the environment. We do this through the nationally networked adoption and implementation of the Good Food Purchasing Program by major institutions.”

The mission is shared and is being advanced by many advocacy organizations, as well — including Beyond Pesticides. Ms. Hamerschlag of FOE, who has worked for half a decade on getting more organic food into schools, comments, “The benefits of organic are significant in terms of climate, soil health, and reducing toxic pesticide exposure.”

Beyond Pesticides has written often about the many upsides of organic food production and consumption, which advance multiple health and environmental goals: reduced health harms to children and farmworkers from synthetic pesticide and fertilizer use, improved health outcomes for children and adults (including lowered obesity rates), reduction of environmental/ecosystem and biodiversity degradation, and greater equity for environmental justice communities and populations.

Indeed, the whole Conscious Kitchen model is based on getting “all-organic, scratch-cooked, plant-forward meals to districts that serve a large proportion of low-income students.” Ms. Shils notes that because organic food often costs more than conventional food (i.e., food raised with synthetic pesticides and fertilizers), it can be economically infeasible for some students’ families to purchase organic. Thus, school lunch is an opportunity to provide the most healthful possible fare for students.

She emphasizes that this helps rebalance the equity scales and shifts the local food system in a more sustainable direction. “When you have hundreds of thousands of children needing to be fed, it creates a lot of leverage, and food prices go down, our land is healthy, the agricultural practices [are better for the workers], and we mitigate climate change,” Ms. Shils commented. Conscious Kitchen generated a case study of the WWCUSD initiative — Organic, Plant-Forward, Scratch-Cooked School Meals: A California Case Study.

Lena Brook of the Natural Resources Defense Council (NRDC), which has advocated with California state government agencies to integrate more organic-specific incentives into their grants programs, notes: “We can’t afford to be solving one problem at a time anymore. We have a climate crisis, various public health crises, biodiversity [loss], drought, wildfires, etc. Where do we put our investments in order to tackle more than one at a time? For me, organic sits at the center of this.”

Beyond Pesticides concurs. To learn more about the harms of pesticides in children’s diets, and the benefits of organic foods, see the Factsheet, Children Need Organic Food, and these webpages: Kids Who Eat Organic Food Score Higher on Cognitive Tests, Health Benefits of Organic Agriculture, Study Shows Organic Food Diet Reduces Residues of Glyphosate in Body, and Hazards of Pesticides for Children’s Health, among others.

Source: https://civileats.com/2022/02/28/coronavirus-pandemic-disruptions-organic-school-food-meals-opportunity/

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

(Beyond Pesticides, March 7, 2022) Contrary to the demands of consumers for hormone-free organic dairy products and the requirements of the Organic Foods Production Act (OFPA), the U.S. Department of Agriculture (USDA) will allow continued use of the synthetic hormone oxytocin in organic dairy production. The National Organic Standards Board (NOSB) voted unanimously in 2017 to reject the use of the synthetic hormone oxytocin in livestock production. Since administration of oxytocin has been linked to a range of serious health problems and early onset puberty, autism, and psychiatric disorders, it is important to avoid residues in food that may cause a hormone imbalance in food consumers.

Tell USDA Secretary Vilsack to reverse the decision to allow oxytocin in organic dairy. Tell Congress that greater oversight is needed to ensure that USDA upholds the Organic Foods Production Act. 

Substances on the National List are reconsidered every five years to determine whether they still meet criteria in OFPA—that is, that their use is (1) not harmful to human health or the environment, (2) necessary for organic production, and (3) consistent with organic practices. In the case of oxytocin, a hormone involved in the milk “let-down” reflex, there is longstanding concern that misuse of the hormone to increase milk production may be at the expense of the health of the cows. Increased milk production may also be at the expense of the organic dairy industry. USDA, with its mentality of increasing production, ignores the greater importance of organic principles to organic consumers.

In 2017, the NOSB unanimously recommended the sunsetting (removal) of oxytocin from the National List of Allowed and Prohibited Substances (National List). Oxytocin had been allowed to be used for “use in postparturition therapeutic applications” since 2000. In deciding not to relist oxytocin, the NOSB said, “[M]ethods and materials have been developed that make oxytocin less essential for maintaining animal health and welfare. The expectations and awareness of dairy production tools by consumers has changed over time. They now expect organic milk be produced without the use of synthetic hormones. The Livestock Subcommittee realizes that some producers may need to learn new methods to address post parturition issues, but we believe the knowledge and materials are present, so that there will be no interruption in commerce, economic hardship, or lessening of animal welfare if this material is removed from the National List of approved synthetics.”

Thus, the NOSB decided that oxytocin meets neither the essentiality nor the compatibility criterion. USDA ignored the NOSB decision and, contrary to OFPA, which prohibits USDA from adding any synthetic to the National List that has not been recommended by the NOSB, issued a final rule—which goes into effect March 30, 2022—relisting oxytocin.

Tell USDA Secretary Vilsack to reverse the decision to allow oxytocin in organic dairy. Tell Congress that greater oversight is needed to ensure that USDA upholds the Organic Foods Production Act. 

Letter to USDA Secretary Vilsack:

USDA’s decision to relist oxytocin on the National List of synthetic materials allowed in organic production is contrary to the expectations of organic consumers and to the letter of the Organic Foods Production Act (OFPA).

Organic consumers expect that organic milk is produced without added hormones. Milk, because it is an important food for children, is especially critical for organic integrity.

Furthermore, taking an action to relist a synthetic material on the National List in spite of a recommendation to the contrary by the National Organic Standards Board is expressly prohibited by OFPA’s “no additions” clause (§6517(d)(2)).

I am extremely disturbed by actions taken by USDA that threaten organic integrity and the role of the NOSB in representing the organic community. The final rule is due to take effect on March 30. I request that you revoke the rule before that date.

Thank you.

Letter to U.S. Representative and Senators:

I am writing out of concern that USDA’s administration of the Organic Foods Production Act (OFPA) does not comply with either the law or the needs of the people it was designed to serve. In particular, USDA’s recent decision to relist oxytocin on the National List of synthetic materials allowed in organic production is contrary to the expectations of organic consumers and to the letter of OFPA.

Organic consumers expect that organic milk is produced without added hormones. Milk, because it is an important food for children, is especially critical for organic integrity. And yet, USDA, contrary to the recommendation of the National Organic Standards Board (NOSB), has relisted oxytocin, a synthetic hormone, for use in organic dairy.

Furthermore, taking an action to relist a synthetic material on the National List in spite of a recommendation to the contrary by the NOSB is expressly prohibited by OFPA’s “no additions” clause (§6517(d)(2)).

I am extremely disturbed by actions taken by USDA that threaten organic integrity and the role of the NOSB in representing the organic community. The final rule is due to take effect on March 30. Please ask USDA to revoke the rule before that date.

Thank you.

(Beyond Pesticides, March 4, 2022) An article in My London reported by Finn Byrne, finds labeling on conventionally grown fruits and vegetables marked as non-vegan. The non-vegan label shocked many shoppers who buy the produce with chemical-intensive practices, as fruits and vegetables are inherently vegan. However, pesticides used in the production of fruits and vegetables render these foods non-vegan because of the harm that pesticides cause to animals and since a wax coating on fruits and vegetables made of shellac, a resin secreted from female lac beetles and thus non-vegan.

Recent studies indicate plant-based diets can mitigate excessive pesticide use and exposure if they are organically grown. However, a plant-based diet reliant on pesticides does little to lessen the health and ecological effects of conventional agriculture. Fungicides are ubiquitous in agricultural and residential settings puts human and animal health at risk. Exposure to fungicides can manifest adverse health effects, including reproductive dysfunction, birth/developmental effects, kidney/liver damage, and cancer. Several researchers find that fungicide use promotes more drug-resistant fungal infections in humans as these fungicides are structurally similar to medical antifungal medications.

After investigating fruits and vegetables at various United Kingdom (UK) grocery stores (i.e., Tesco, Morrisons, and Marks and Spencer), the report finds fungicides imazalil and propiconazole present on fruits like oranges. The European Union (EU) bans both chemicals with some exceptions. Furthermore, an alternate version of imazalil (E904) is a wax coating on fruits and vegetables made of shellac, a resin secreted from female lac beetles and thus non-vegan. Since it is no longer a part of the EU, the UK does not have to adhere to these chemical bans. However, the article notes that the toxic health and ecological impacts of these chemicals are the reason why the EU bans imazalil and propiconazole. With that in mind, the use of these chemicals, even in small amounts, can be detrimental.

Fungicide use is becoming a bigger issues with the climate crisis and changes to moisture and temperature conditions that promote the spread of fungi, according to studies. Climate warming may cause fungi to become significantly more heat-tolerant, increasing pesticide use to combat the spread. However, heat tolerance also increases fungi’s ability to infect a host with higher body temperatures as the difference between environmental and body temperature will decrease. Additionally, extreme weather conditions associated with climate change, like flooding from hurricanes, or drought, can promote fungus growth (e.g., mold), resulting in more extensive fungicide use. In addition to containing potentially dangerous compounds, fungicide use in agriculture is often in conjunction with other chemical pesticides to increase potency. The synergy between fungicides and other pesticides can further worsen the adverse effect on human and animal health. Since humans and animals encounter these pesticides through various mediums (e.g., residues on food and in water and air), it is essential to understand how these chemicals work to cause toxicity in humans and animals.

This report adds to the growing body of work evaluating the impacts that pesticides have on dietary lifestyle (e.g., vegan, pescatarian, vegetarian, meat-eater, etc.), indicating a change in dietary habit alone does not prevent exposure to pesticides. Both fungicides in the article have adverse health effects, including kidney/liver damage. Imazalil negatively affects the reproductive system, is a sensitizer/irritant, and can cause developmental delays. The U.S. Environmental Protection Agency (EPA) classifies imazalil as “likely to be carcinogenic to humans,” one of the highest cancer designations, and propiconazole as “possibly carcinogenic to humans.” Furthermore, these chemicals have ecological effects that are toxic to birds and aquatic organisms/fish. The vegan and organic movements share the same critique of conventional agriculture in the treatment of animals, over-feeding and production of crops, and chemical use.

Although the vegan movement excludes animal and their byproducts for consumption or use, intensive chemical use limits the ecosystem services (e.g., wild bee pollination) veganism relies upon. Regardless of dietary lifestyle, the article recommends buying organic when possible.  The commentators conclude, “When fruit isn’t suitable for vegans you know something bad is happening. Imazalil & propiconazole are fungicides & are the reason why we should’ve been(long before now) scrubbing citrus fruits before using the peel & washing hands after peeling & before eating treated fruit. Better to buy organic, untreated fruits when available.”

Chemical interventions to “control” pests of any sort, beyond all the potential toxicity issues, fundamentally cause imbalances in ecological systems. When humans use toxic synthetic chemicals to protect “systems” that violate ecological laws, such as monocultures, the natural predators that exist in those ecosystems disappear. Chemical inputs in agriculture reduce the biodiversity that keeps these systems functional. Moreover, the concern about human infection by antifungal-resistant fungi is a distinct echo of the mounting public health threat from antibiotic-resistant bacteria.

With the negative impacts on human and environmental health, including the mounting resistance issues, chemical-intensive agriculture should be understood as a sign of the ineffectiveness of conventional, chemical approaches to pest management.Organic agricultural practices can support biodiversity and protect global health and the environment. Organic agriculture seeks to prevent pest problems by creating healthy agroecosystems. Moreover, switching from a chemical-intensive to an organic diet will drastically reduce the levels of pesticide in one’s body, with one week of an organic food diet showing a 70% reduction in bodily glyphosate levels. 

Eating organic should not be a choice to make as all food should be grown with high-quality standards that reject toxic pesticides and protect the environment. Learn more about the adverse health and environmental effects chemical-intensive farming poses for various crops and how eating organic produce reduces pesticide exposure. For more information on determining when to eat organic vs. chemically grown food, see Beyond Pesticides article on The Real Story on the Affordability of Organic Food. Join Beyond Pesticides as the organization continues to push for that reality.

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

Source: My London

(Beyond Pesticides, March 3, 2022) Children’s exposure to synthetic pyrethroid insecticides, particularly during the course of mosquito control operations, is associated with increased occurrence of certain respiratory diseases and allergic outcomes, finds research published in the journal Thorax late last month. With a pandemic respiratory virus continuing to spread throughout the world, it has become increasingly important to avoid environmental exposures that can harm lung health. This research underscores the critical need for homeowners, farmers, and vector control officials to shift away from chemical use as the first line of defense against pest problems in order to safeguard children’s health.

A total of 303 women and their children participated in the study, which tracked pesticide exposure during pregnancy and then at age five. All participants in the study lived within roughly three miles of a banana plantation. A structured questionnaire captured a range of variables, from socioeconomic status to medical history, local environmental conditions, occupation, and demographics. Researchers collected urine samples from pregnant mothers during the first visit, and their children during the 5-year follow-up.

Urine samples were analyzed for metabolites concerning a range of pesticides, including chlorpyrifos, synthetic pyrethroids, the fungicides mancozeb, pyrimethanil, and thiabendazole, and the herbicide 2,4-D. During the second follow-up, mothers filled out another questionnaire regarding their children’s respiratory and allergic outcomes

Of the pesticides tested, 80% are frequently detected within tested mothers, and 68% within children during the course of the study. Researchers thus differentiated between high and low levels of pesticide concentration in making their findings.

While researchers find inconsistent links between prenatal pesticide exposure and adverse health outcomes, current pesticide use is associated with a range of respiratory and allergic complications in children. High levels of metabolites from the fungicide mancozeb are correlated with increased incidence of lower respiratory tract infections. However, synthetic pyrethroid insecticides are the primary offenders, associated with higher odds of current asthma, ever being diagnosed with asthma, recent lower respiratory tract infections, and cough. The strongest association between pyrethroids and adverse health impacts is for wheeze. Increased exposure exhibits stronger correlations, with each 10x increase showing a greater likelihood of developing asthma, wheeze, lower respiratory tract infections, and itchy rash.

While studies show that levels of synthetic pyrethroids in one’s body can be rapidly reduced by switching to an organic diet, individuals have significantly less control over exposures that come from nearby chemical farming operations or mosquito vector disease practices. In fact, researchers are able to identify risks directly related to vector control operations. Over half (56%) of all study participants report nearby adulticide use for mosquito control within the last year. This is associated with increased incidence of both cough and lower respiratory tract infections in tested children.

Data on the link between pesticide exposure and respiratory harms, particularly in children, have grown over the last decade. While researchers did not find links between prenatal pyrethroid use and childhood respiratory problems, a 2012 study looking at PBO, a pesticide “synergist” often combined with synthetic pyrethroids in consumer products was found to be linked to childhood cough after a mother’s exposure. In 2015, a study from University of California, Berkeley found that general exposure to organophosphates (not only chlorpyrifos) corresponds with a measurable decrease in lung function.

Agricultural workers and their families are at greatest risk from these health hazards. A 2016 study linked an astounding 78 pesticides to allergic and non-allergic wheeze among male farmers. Agricultural work with toxic pesticides was associated with an increased risk of the potentially deadly diseases idiopathic pulmonary fibrosis (IPF) in a 2021 study, and chronic obstructive pulmonary disease (COPD) in a recent February 2022 report. Unsurprisingly, a comprehensive literature review published in 2020 finds pesticide exposure to be strongly correlated with the development of respiratory diseases.

Current laws do not adequately protect local residents from toxic pesticide exposure coming from farms and mosquito control operations. Oftentimes, it can be difficult for individuals to obtain basic information about the pesticides being sprayed near their homes and schools their children attend. As a respiratory pandemic continues to spread, it is critical that environmental factors that weaken individual immune systems be avoided if at all possible. While personal protective measures are important, residents throughout the U.S. are encouraged to engage with their elected officials to rein in toxic pesticide use in their community. Through collective action, we can stop the regular use of hazardous, lung-harming pesticides in homes, on farms, and in mosquito management. Reach out to Beyond Pesticides at [email protected] or 202-543-5450 for assistance with your local advocacy efforts.

For more information about the link between pesticides and respiratory health, see Beyond Pesticides Pesticide Induced Diseases Database.

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

Source: Thorax

(Beyond Pesticides, March 2, 2022) Covid (SARS-CoV-2) is being detected in wastewater, sludge, and biosolids, providing a “safe haven” for the virus and creating a health risk for wastewater workers and farmers. Published in Geoscience Frontiers, an international team of researchers systematically reviewed the available literature on the prevalence of pandemic coronavirus in wastewater in order to better determine risks to workers and public health. The timely review comes as many communities and states are reevaluating their use reclaimed human effluent due to a range of toxic contaminants, including per and polyfluoroalkyl substances (PFAS).

Researchers found 20 articles from published literature that met the criteria for their review. Each of three environmental materials –wastewater effluent, sludge, and biosolids were analyzed for the presence of Covid. Effluent is the liquid that remains after a sewage treatment process, sludge is organic matter separated from effluent, and biosolids are the fully processed product that is then often applied to farm fields.

Of the three materials, sludge contained the highest prevalence of covid RNA, followed by biosolids and then effluent, according to modeling of the data employed by researchers. Covid amounts were found to be related to the number of infected individuals living within the bounds of a treatment plant, as well as the treatment approach utilized by the plant.

Covid is an enveloped virus, and as such contains a hydrophobic envelope layer. As a result, the virus is apt to latch on to solid particles present in the wastewater stream. Researchers found that greater amount of solids and longer retention times (amount of time the effluent is stored) increase the rate of Covid RNA detection. Further, suspended solids in wastewater retention tanks have the potential to block UV light that may otherwise breakup the virus.

Scientists indicate that if proper guidelines are not in place, the routes of transmission through environmental materials are “numerous.” Accordingly, wastewater workers, who can be exposed to these materials for long periods of time, are at high risk. “The inevitable inhalation of the virus-laden aerosols generated during the wastewater and sludge processing activities, especially without adequate protection, could also lead to fecal-oral transmission of the virus,” the authors write.

The data indicates that conventional wastewater treatment is not effective at entirely removing Covid RNA from the waste stream as it processes these materials for reuse. Although citing studies on potential transmission, authors do note that there is not clear agreement in the literature that the genetic materials found in these waste streams are directly contributing to the spread of viral infection.

The authors suggest the use of “adequate protections, including the use of personal protective equipment should be ensured for the wastewater/sludge workers, while the use of reclaimed wastewater and other materials like sludge and biosolids should be done with caution, especially in rural settings of developing and low-income countries where water, sanitation, and hygiene are insufficiently deployed.” The article also suggests methods to better ensure the elimination of Covid RNA, including best practice treatment measures.

However, even if concerns over Covid RNA are addressed, wastewater products still pose a range of pubic health concerns. Biosolid/sludge products have been found in the past to contain residues of hazardous pesticides, heavy metals, antibiotics and other pharmaceuticals, personal care products, and a range of other toxicants. A 2018 report from the U.S. Environmental Protection Agency’s Office of Inspector General identified over 350 pollutants in biosolids, 61 of which are considered hazardous. A recent study conducted by the Sierra Club and the Ecology Center found PFAS in every biosolid fertilizer sold to consumers at hardware stores. With even the most highly processed consumer-forward biosolids contaminated with hazardous materials, many communities and states are rethinking their use of these products.

In Oklahoma, the small town of Luther in 2020 voted to ban the use of biosolids on farmland. This has led Oklahoma state senator Shane Jett to introduce a state-level prohibition on the use of human raw sewage on agricultural land. Concern over PFAS in Maine led to legislation that would likewise ban the use of sludge or sludge-derived products unless a laboratory test confirms PFAS below a certain level to be determined by state agencies.

As the worst of the coronavirus pandemic appears to be in the rear-view mirror, it is critical that steps are taken to address all potential routes of exposure. As Beyond Pesticides continues to track this story, read more about the hazards associated with the use of environmental materials in agriculture through the reports Wastewater Irrigation on Farms Contaminates Food, and Biosolids or Biohazards.

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

Source: Geoscience Frontiers, News-Medical

(Beyond Pesticides, March 1, 2022) A report by the Independent finds chemical-intensive farming of crops for animal feed puts thousands of endangered species at risk. U.S. farmlands use more than 235 million pounds of pesticide (i.e., herbicides and insecticides) solely for animal feed production, many of which are highly hazardous pesticides (HHPs). Several HHP hazard categories include acutely toxic, chronic health hazards, and environmental hazards. Therefore, animal feed production intensifies global pollution, increases pesticide exposure, and degrades human, animal, and ecological health. 

Although the report demonstrates a need to eliminate toxic pesticide use for the sake of human, animal, and ecosystem health, it will take more than eliminating the worst chemicals to address the impending biodiversity collapse and the climate crisis. Experts highlight the need for an urgent shift to organic land and agricultural management practices. The study notes, “These pesticides are taking a toll on our environment and biodiversity. Endangered species like the highly imperiled whooping crane, monarch butterflies, all species of salmon, the rusty-patched bumble bee, the San Joaquin kit fox, and the northern long-eared bat, as examples, all face significant threats from industrial agricultural operations and the chemicals applied. In order to conserve biodiversity and better protect vulnerable species and their habitats, we must reduce the production and consumption of animal protein and shift to a food system that prioritizes diverse plant foods.”

Over 10 billion animals involved in factory farming (chemical-intensive farming of crops for animal feed) endure increased amounts of stress, pain, and suffering to meet the demand for cheap meat. Many studies find enormous amounts of feed crop, mainly corn and soy results in habitat loss for wild animals, declining biodiversity, water pollution, pesticide pollution, soil degradation, and greenhouse gas emissions. The production of massive amounts of animal feed contributes to abnormal growth rates among animals, leading to many health issues. Furthermore, these chemicals also take an enormous toll on the planet.

The World Animal Protection and Center for Biological Diversity (CBD) report investigated the impacts pesticides have on the relationship between the factory farm industry and the worldwide decline of human, farmed animal, and wild species health. Researchers assessed data on glyphosate, atrazine, paraquat, dicamba, 2,4-D, neonicotinoids, and bifenthrin to determine the uses on crops, as well as related health and environmental effects. These six individual chemicals and one class of chemicals have common uses on corn and soybeans in the U.S. and are continuously increasing annually.

Using the most recent, comprehensive data from 2018 on U.S. pesticide use, researchers determined that farms applied nearly 172 million pounds of glyphosate to corn and soy, with 100 million pounds attributed to farm animal feed production. A CBD report finds glyphosate likely to adversely affect the health, survivability, and habitat of 93 percent of plants and animals protected under the Endangered Species Act. However, the report also notes the impacts on human health, highlighting over 13,000 lawsuits asserting glyphosate’s role in non-Hodgkin’s lymphoma development as recognized by The World Health Organization’s International Agency for Research on Cancer (WHO-IARC).

Following the same comprehensive data, farms applied nearly 61 million pounds of atrazine on corn and soybean crops, a 17 percent increase from 2012 levels. About 25 million pounds of atrazine use was on animal feed. The report notes that the endocrine disruption properties and persistent water contamination resulted in a ban in 35 countries and the European Union (EU). However, the chemical’s use in the U.S. puts over 1,000 endangered species (56 percent) at risk, including the whooping crane, the San Joaquin kit fox, and the California red-legged frog.

In 2018, U.S. farms applied 4.2 million pounds of paraquat to corn and soybeans, with over half (2.9 million pounds) attributable to animal feed production. Like atrazine, the EU and 53 other countries banned paraquat. The report notes paraquat toxicity to bird embryos, including the Japanese quail, mallards, bobwhite quail, and ring-necked pheasant. Furthermore, many studies demonstrate paraquat’s role in human poisonings, most notoriously Parkinson’s disease.

Dicamba use was another concern as farms applied 17 million pounds on corn and soy crops in 2018, a 1200 percent increase from 2012 application levels. However, farms used 11 million pounds solely for animal feed crop production. Despite the approval of genetically engineered (GE) soy crops to reduce dicamba use in 2016, the opposite effect occurred, increasing chemical use. The report notes dicamba use threatens monarch butterflies, and people who work with this chemical have an increased risk of developing various cancers. For the pesticide bifenthrin, farms applied over 700,000 pounds of the chemical on U.S. corn and soy crops, a 130 percent increase from 2012 use, with nearly 370,000 pounds used solely for animal feed. The report notes that bifenthrin is neurotoxic, highly toxic to insects and aquatic species, and impairs the ability of various insect and animal species.

In 2018, U.S. farms applied over 14.6 million pounds of 2,4-D to corn and soybean crops, with almost nine million pounds solely used for animal feed production. The report highlights the harmful effects 2,4-D has on beneficial insects and animals that provide ecosystem services, as well as the endocrine, immune, and neurotoxic influences on human health.

Lastly, U.S. farms used 2.6 million pounds of three neonicotinoids (neonics) on corn and soy, clothianidin, thiamethoxam, imidacloprid. Farm applied nearly 1.5 million pounds solely to animal feed production. The U.S. Environmental Protection Agency (EPA) determined these three chemicals to cause toxicity among all 38 protected amphibian species and three-fourths of all endangered plants and animals in the U.S. Specifically, the report notes that neonics pose the greatest risks to pollinators like bees, birds, butterflies, and bats. Furthermore, a single treated seed, or seed coated in these neonics, can kill a songbird upon ingestion. Furthermore, as little as 1/10th of a seed can decrease reproduction among the bird population.

The researchers warn, “With projections showing a likely continued increase in the production and consumption of meat and dairy in the US if nothing changes, it can be assumed that these pesticide use levels will also continue to increase alongside demand for industrially-produced feed, unless something changes.”

Agricultural land is subject to chemical-intensive farming that uses toxic pesticides to manage pests (e.g., weeds, insects, fungi) on animal feed crops. Nearly half of all global HHP use was on soybean and corn, staple crops in animal feed, with pesticide use on soybeans being the highest. Most soy and corn crops in the U.S. are genetically engineered (GE) to tolerate pesticides, including two highly hazardous pesticides commonly used on animal feed, glyphosate and atrazine. However, pesticide-resistant crops can increase chemical use, causing a rise in pesticide-resistant weeds (i.e., superweeds). As pesticide resistance grows at similar rates among GE and non-GE conventionally grown crops, health and environmental harm can be more severe. The increase in resistance is evident among herbicide-tolerant GE crops, including seeds genetically engineered to be glyphosate-tolerant. Although one stated purpose of GE crops is to reduce pesticide use, increasing resistance can result in additional pesticide use to compensate. Furthermore, most corn and soy crops are monocultures that can exacerbate the impact of pesticide exposure. As farms convert farmlands into single-crop agriculture to sustain animal feed production, the demands for feed exceed requests for diverse crop production. Perversely, monoculture crops induce biodiversity loss and pollinator decline via pesticide exposure and habitat destruction. 

This report highlights how unsustainable factory farming with regard to chemical pollution and intensive reliance on resources. Thus, the expansion of factory farming threatens wildlife and humans, especially children, farmworkers, and their families. The Food and Agriculture Organization of the United Nations said back in 2013, “Livestock health is the weakest link in our global health chain.” Alternatively, organic principles offer an existing federal guideline for ecologically and environmentally viable conditions for agriculture.

The report offers many recommendations that governmental officials, businesses, and individuals can adopt to protect endangered species and humans from toxic chemical use. In addition to reducing conventional (non-organic) meat and dairy consumption, the report recommends creating a more sustainable food production system less reliant on factory farming to mitigate hazardous chemical exposure.

The study concludes, “Government agencies and programs should instead support a shift to a more humane and sustainable food system that prioritizes the production of crops for human consumption and farming practices that foster rather than deplete biodiversity. This requires a reconceptualization of how we produce and consume protein. Our appetite and demand for animal proteins is fueling the further expansion of factory farming systems that are propped up by millions of pounds of herbicides and insecticides. This model is not only causing the suffering of billions of cows, pigs, turkeys, and chickens, but countless wild species exposed to these toxic chemicals. By significantly reducing the amount of meat and dairy we produce and ensuring that the farmed animals that remain in production systems are living in higher welfare conditions we can create a more planet- and animal-friendly food system.”

Pesticides should be phased out and ultimately eliminated to protect the world’s wildlife and reduce the number of endangered species exposed to dangerous. Additionally, Beyond Pesticides has long fought against GE crops and pesticide use in agriculture and advocated for federal regulations that consider all potential impacts of pesticides on ecosystems and organisms. Chemical-intensive farming contributes to pesticide global market sales as farmers apply various herbicides and insecticides to many staple animal feed crops. International sales of pesticides pose a serious global health risk as 18 out of 19 analyzed highly hazardous pesticides are available in the U.S. pesticide market for use. Most Americans want stricter oversight of general large-scale livestock operations. Therefore, organic agriculture can offer more oversight on farming practices that curtail the need for toxic pesticides to protect global health and the environment. Regenerative organic agriculture revitalizes soil health through organic carbon sequestration while reducing pests and generating higher profits than chemical-intensive agriculture. Learn more about the adverse health and environmental effects chemical-intensive farming poses for various crops and how eating organic produce reduces pesticide exposure.

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

Source: the Independent, World Animal Protection

(Beyond Pesticides, February 28, 2022) When bacteria and fungi become resistant to pesticides, it is a signal that the toxic chemical approach to controlling pathogens does not work. But resistance also poses a direct threat to human health when the pesticide (or a related chemical) is used in human medicine.

Tell EPA to cancel all uses of a pesticide when resistance is discovered or predicted to occur. Tell Congress to ensure that EPA protects public health from deadly antifungal and antibiotic resistance.

The threat of resistance in bacterial human pathogens has long been widely recognized. Although research sponsored by the Environmental Protection Agency (EPA) recognizes the spread of resistance to antibiotics important in human medicine through horizontal gene transfer in the environment, EPA inaction both on antibiotic and antifungal resistance has become a growing crisis.

EPA does recognize the existence of resistance to fungicides. It uses codes produced by the Fungicide Resistance Action Committee in decisions regarding fungicide registration. Although EPA says resistance “may be considered in the risk-benefit decision-making process,” there is no evidence that the agency actually considers the failure of EPA-registered pesticides to control the target organisms in registering pesticides. That failure has a serious impact on human and environmental health as users of the chemical increase use and as medical uses of antibiotics and fungicides become ineffective.

The threat of resistance is evident with a number of fungicides, as well as bactericides and viricides. For example, Candida auris is an emerging fungal pathogen that threatens those with compromised or immature immune systems, such as infants, the elderly, people taking steroids for autoimmune disorders, diabetics, those undergoing chemotherapy, and even smokers. Nearly half of those who contract a C. auris infection die within 90 days. One of the factors making this fungus so deadly is that it has developed resistance to existing antifungal medicines, with 90% of infections resistant to one drug, and 30% to two or more. As is true for resistant bacteria, culprits in C. auris’s development of resistance include the use of antifungal medications in health care and reliance on fungicides in agriculture.

A recent study conducted by scientists at the University of Georgia finds fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens. Of 700 Aspergillus fumigatus samples collected, nearly 20% (123) displayed some level of resistance to the commonly used azole fungicide tebuconazole. Twelve of the 123 were highly resistant at clinically relevant levels for human health care. No samples taken from organic sites contained  resistant fungi.

Azole-resistant strains also displayed resistance  to methyl benzimidazole carbamate (MBC) fungicides like carbendazim, and quinone outside inhibitors (Qol) like azoxystrobin.

A review of genome sequences shows that genetically those with broad resistance to azole fungicides show a close match between those discovered on farms and those found in human clinical settings. Of 25 pan-azole resistant samples analyzed, eight farm samples and 12 human clinical samples also display resistance to non-azole fungicides.

These results indicate a need for a shift toward eliminating reliance on toxic fungicides.

Unfortunately, regulators and politicians are neither heeding the science, nor listening to scientists. EPA’s recent response to the rise   of drug-resistant Candida auris is a case in point. The agency failed to assess the efficacy of any pesticides that are not used for public health purposes; EPA only evaluated the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related—thus ignoring the impact of other antimicrobial pesticides on resistance in human pathogens.

At the international level, a Freedom of Information Act request revealed officials at the U.S. Department of Agriculture working to downplay the role of synthetic fungicide use in chemical agriculture as a factor in the rise of drug-resistant fungal infections worldwide by denying the truth on the ground and attempting to halt protective actions, as EPA did with pentachlorophenol (recently cancelled with a 5-year phaseout after the manufacturer pulled out of the market).  Prior research on resistance in agriculture has shown that the only true way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century. Rising resistance, and the need to retain life-saving medications for protecting people’s health is another reason why investing in organic is the right choice for the future.

Tell EPA to cancel all uses of a pesticide when resistance is discovered or predicted to occur. Tell Congress to ensure that EPA protects public health from deadly antifungal and antibiotic resistance.

Letter to EPA:

When bacteria and fungi become resistant to pesticides, it signals that the toxic chemical approach to controlling pathogens does not work. But resistance also poses a direct threat to human health when the pesticide (or a related chemical) is used in human medicine. EPA must cancel all uses of a pesticide found to cause resistance.

The threat of resistance in bacterial human pathogens has long been widely recognized. Although research sponsored by the Environmental Protection Agency (EPA) shows the spread of resistance to antibiotics important in human medicine through horizontal gene transfer in the environment, EPA inaction both on antibiotic and antifungal resistance has become a growing crisis..

EPA recognizes the existence of resistance to fungicides by using codes produced by the Fungicide Resistance Action Committee in registration decisions. Although EPA says resistance “may be considered in the risk-benefit decision-making process,” there is no evidence that the agency actually considers the failure of EPA-registered pesticides to control the target organisms in registration—a failure that affects human and environmental health because those who depend on the pesticide use ever-higher amounts, as medical uses of antibiotics and fungicides become ineffective.

The resistance threat to human health is evident with a number of fungicides, bactericides, and viricides. For example, Candida auris is an emerging fungal pathogen that threatens those with compromised or immature immune systems, such as infants, the elderly, people taking steroids for autoimmune disorders, diabetics, those undergoing chemotherapy, and even smokers. Nearly half of those who contract a C. auris infection die within 90 days. One of the factors making this fungus so deadly is that it has developed resistance to existing antifungal medicines, with 90% of infections resistant to one drug, and 30% to two or more. Culprits in C. auris’s development of resistance include the use of antifungal medications in health care and reliance on fungicides in agriculture.

A recent study conducted by scientists at the University of Georgia finds fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens. Of 700 Aspergillus fumigatus samples collected, nearly 20% (123) displayed some level of resistance to the commonly used azole fungicide tebuconazole. Twelve of the 123 were highly resistant at clinically relevant levels for human health care. No samples taken from organic sites contained resistant fungi.

Azole-resistant strains also display resistance to methyl benzimidazole carbamate fungicides like carbendazim, and quinone outside inhibitors like azoxystrobin. A review of genome sequences shows that genetically, those with broad resistance to azole fungicides show a close match between those discovered on farms and those found in human clinical settings.

These results indicate a need for a shift toward eliminating reliance on toxic fungicides.

EPA’s recent response to the rise of drug-resistant C. auris demonstrates EPA’s failure to use the science. The agency failed to assess the efficacy of pesticides not used for public health purposes, only evaluating the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related—thus ignoring the impact of other antimicrobial pesticides on resistance in human pathogens.

Research shows that the only way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century.

Rising resistance, and the need to retain life-saving medications for protecting people’s health require that EPA cancel all uses of a pesticide found to cause resistance.

Letter to U.S. Senators and Representative:

When bacteria and fungi become resistant to pesticides, it signals that the toxic chemical approach to controlling pathogens does not work. But resistance also poses a direct threat to human health when the pesticide (or a related chemical) is used in human medicine. EPA must cancel all uses of a pesticide found to cause resistance.

The threat of resistance in bacterial human pathogens has long been widely recognized. Although research sponsored by the Environmental Protection Agency (EPA) shows the spread of resistance to antibiotics important in human medicine through horizontal gene transfer in the environment, EPA inaction both on antibiotic and antifungal resistance has become a growing crisis..

EPA recognizes the existence of resistance to fungicides by using codes produced by the Fungicide Resistance Action Committee in registration decisions. Although EPA says resistance “may be considered in the risk-benefit decision-making process,” there is no evidence that the agency actually considers the failure of EPA-registered pesticides to control the target organisms in registration—a failure that affects human and environmental health because those who depend on the pesticide use ever-higher amounts, as medical uses of antibiotics and fungicides become ineffective.

The resistance threat to human health is evident with a number of fungicides, bactericides, and viricides. For example, Candida auris is an emerging fungal pathogen that threatens those with compromised or immature immune systems, such as infants, the elderly, people taking steroids for autoimmune disorders, diabetics, those undergoing chemotherapy, and even smokers. Nearly half of those who contract a C. auris infection die within 90 days. One of the factors making this fungus so deadly is that it has developed resistance to existing antifungal medicines, with 90% of infections resistant to one drug, and 30% to two or more. Culprits in C. auris’s development of resistance include the use of antifungal medications in health care and reliance on fungicides in agriculture.

A recent study conducted by scientists at the University of Georgia finds fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens. Of 700 Aspergillus fumigatus samples collected, nearly 20% (123) displayed some level of resistance to the commonly used azole fungicide tebuconazole. Twelve of the 123 were highly resistant at clinically relevant levels for human health care. No samples taken from organic sites contained resistant fungi.

Azole-resistant strains also display resistance to methyl benzimidazole carbamate fungicides like carbendazim, and quinone outside inhibitors like azoxystrobin. A review of genome sequences shows that genetically, those with broad resistance to azole fungicides show a close match between those discovered on farms and those found in human clinical settings.

These results indicate a need for a shift toward eliminating reliance on toxic fungicides.

EPA’s recent response to the rise of drug-resistant C. auris demonstrates EPA’s failure to use the science. The agency failed to assess the efficacy of pesticides not used for public health purposes, only evaluating the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related—thus ignoring the impact of other antimicrobial pesticides on resistance in human pathogens.

Research shows that the only way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century.

Please ensure that in view of rising resistance, and the need to retain life-saving medications for protecting people’s health, that EPA cancels all uses of a pesticide found to cause resistance.

(Beyond Pesticides, February 25, 2022) Together, governments of the world over are spending at least $1.8 trillion annually — 2% of global gross domestic product — on subsidies that drive the destruction of ecosystems and species extinction, and exacerbate the climate crisis. This news comes from a study commissioned by The B Team and Business for Nature, and released in a joint brief, Financing Our Survival: Building a Nature Positive Economy through Subsidy Reform. The Business for Nature website offers a remedy to this entropy: “With political determination and radical public–private sector collaboration, we can reform these harmful subsidies and create opportunities for an equitable, nature-positive and net-zero economy.” To that end, the two organizations have issued, in their brief, calls to action to multiple sectors, including one to the governments participating in the coming UN Biodiversity Conference (COP15): “Adopt a clear and ambitious target within the Global Biodiversity Framework . . . that commits governments to redirect, repurpose, or eliminate all environmentally harmful subsidies by 2030 and increase positive incentives to enable an equitable, net-zero, nature-positive world.”

A press release from The B Team reports that the fossil fuel, agriculture, and water sectors are the recipients of more than 80% of all environmentally harmful subsidies (EHS) annually, thus “depleting natural resources, degrading global ecosystems, and perpetuating unsustainable levels of production and consumption, in addition to exacerbating global inequalities.” Other recipients of significant subsidy include the forestry, construction, marine capture fishery, and transport sectors. Business for Nature (BFN) comments, “In other words, public money is financing our own extinction.”

The release of the brief and study is timely, given the early March UN Convention on Biological Diversity (CBD) COP15 Open Ended Working Group meeting in Geneva; the follow-on UN Biodiversity Conference (COP15) scheduled for April 25–May 8 in Kunming, China; and the next UN Climate Change Conference (COP27) in Sharm El-Sheikh, Egypt (rescheduled for November 2022). The study and report hope to inform decision makers in government and business on the case for, and how to, reform these environmentally damaging subsidies.

EHS, as the brief defines them, are government support programs that — though often established (at least ostensibly) to solve socioeconomic problems — ultimately encourage unsustainable production and/or consumption patterns, largely because they were deployed without consideration of environmental impacts. Beyond Pesticides notes that many of the health and environmental crises we face have arisen because of such a “siloed” approach to problems, and that broadly, precautionary and holistic approaches can avoid such unintended and harmful impacts; see “Scientific Findings Support Replacing Poisons with Precaution” (p. 9).

The World Economic Forum puts failure to act robustly on climate, resulting extreme weather events, and biodiversity loss as the leading threats to humanity — catalyzed in part by the enormous amounts of money given by governments to support harmful industries and practices. The research finds that globally, the fossil fuel industry receives $640 billion in EHS annually; the agriculture sector, $520B; water, $350B; forestry, $155B; construction, $90B; transport, $85B; and marine capture fisheries, $50B. (The report also mentions that, though no metrics are available on EHS for it, illegal gold mining accounts for billions of dollars in damage each year.)

These subsidies are significant contributors to many of the crises the world faces: the rapidly heating climate, ecosystem and biodiversity loss, air and water pollution, land degradation, and social and economic inequality. A UN Development Programme and Food and Agriculture Organization report suggests, for example, that of the subsidies provided to farmers, nearly 90% distort prices or cause other harm, and that most fossil fuel subsidies hamper the critical and urgent need to transition to a clean energy economy globally.

The report also scolds governments for terrible follow-through on pledges made — and then ignored or unrealized. It notes, “During the 2010 UN CBD Summit, 190 countries committed to phasing out or reforming subsidies harmful to biodiversity by 2020 as part of the Aichi targets. Governments missed the target, and we cannot afford for history to repeat itself.”

The brief acknowledges the extreme difficulty of reforming these subsidies: “Many of [them] are so deeply embedded in our economies that attempts to define, measure and track them often struggle to be comprehensive, and progress to reform them has been slow. This is due not only to the power of vested interests, but also because both the governments and beneficiaries — including business — are unaware of the full scale of the subsidies and their impacts. Businesses often lobby for continued or increased government support that often has negative unintended environmental consequences.”

Among its observations are the needs for greater public awareness and visibility of EHS, and much more transparency and disclosure about subsidies from governments and recipient businesses. In the U.S., such subsidies tend to be “worked out” behind semi-closed doors among legislators, federal agencies, lobbyists, and private business entities, and occasionally reported on by journalists — hardly the stuff of open, democratic, and accountable governance.

The report’s summary asserts that reform adequate to the goals of reversing “nature loss” by 2030, and achieving net zero carbon emissions by 2050, will require roughly $700 billion annually — far less than is currently spent on funding climate- and nature-destructive governmental subsidy programs. The researchers and authors, Doug Koplow and Ronald Steenblik, say that these government efforts need to occur in parallel with (1) a realignment of all private financial flows so as to be “nature-positive,” and (2) increased public and private financing that can deliver innovative financial solutions to protect, restore, and conserve nature.

“Nature-positive” is not comprehensively defined in the brief, but these outcomes can be inferred, from the brief itself and commentary on the BFN and The B Team websites, as qualifying: emissions reductions and the transition to renewably powered economies; restoration of damaged ecosystems and initiatives to arrest further biodiversity loss and restore damaged and endangered populations; support of social and economic needs of human populations, including redress of economic and environmental inequities; and support of nature-based solutions broadly. Importantly, BFN asserts that EHS reform must consider social and economic forces at play as it pursues “the imperative for a just and equitable transition. Reform managed sensitively means providing support for the poorest households and most vulnerable communities, such as via targeted cash transfers.”

In the authors’ view, such redirection of resources from harmful subsidies toward nature-positive outcomes would:

• free up substantial government resources to support social needs and local livelihoods
• redirect capital toward ecological restoration, including nature-based solutions
• close the biodiversity finance gap by reducing environmental degradation and unlocking the funding needed to mitigate it
• send more accurate signals to public and private investors and producers on where to direct R&D efforts and future investments
• accelerate innovation to reduce greenhouse gases and environmental damage
• create a level playing field for businesses, which would further encourage rapid transformation of business models
• unlock social benefits such as poverty reduction, improvements in education and other social services, and more sustainable approaches to providing basic access to energy, clean air, and water

The brief calls on businesses and investors to advocate with governments for reform of EHS through their repurposing or redirection, or elimination, and funding of “an equitable, net-zero, and nature-positive world by 2030.” In addition, it asks that businesses (1) collaborate broadly to increase awareness of reputational, competitive, and investor advantages of subsidy disclosure, and (2) support the development of international standards, frameworks, and guidance for mandatory ESG (environmental, social, and governance) disclosures, including subsidies.

The report goes on to make a compelling business case for reforming systems of subsidies that fund destructive entities and practices by identifying risks and opportunities. Central to the risks is the inescapable fact that virtually all businesses rely on functional natural systems and resources for every aspect of their value chains. In addition, EHS, as noted above, distort pricing, investment decisions, and resource allocation; encourage unsustainable production and consumption (chickens will eventually come home to roost!), and unfair competition; and generate supply chain, reputational, and operational risks.

On the other side of the ledger, the draft points to opportunities that EHS reform and redirection of funding to nature-positive objectives would present. The authors assert that among those would be increased competitive positioning, increased ESG investor interest, reduction of the risks noted above, and progress on the “ambitions of the Paris Climate Agreement.” (Inadequate as that particular set of accords is, that would still be a giant step in the right direction for many private enterprises.)

The brief summarizes: “Informed reform of subsidies can boost business and investment opportunities, create jobs, reverse nature loss and help ensure a sustainable future for our planet. Businesses can mobilize and implement change with speed (often faster than policy-makers), setting a precedent for improvement across industry. Investors are starting to acknowledge the financial and sustainability risks of environmentally harmful subsidies and forward-looking companies recognize they need to prepare for subsidy reform.”

The brief ends with a slew of endorsing comments from members of The B Team, business leaders, and advocacy groups. Several stand out to Beyond Pesticides:

• “It’s time to stop the self-serving, short-sighted lobbying instead directing public money towards supporting responsible companies transition to nature positive business models.” — Paul Polman, business leader and The B Team member
• “It is more important than ever to put in place ambitious targets to reverse nature loss and to redirect, repurpose or eliminate all subsidies that harm our natural world.” — Marco Lambertini, Director General of World Wildlife Fund International
• “We must break down the siloed approach that has led to putting subsidies in place without consideration of their long-term environmental costs.” — Jennifer Morris, CEO, The Nature Conservancy

Activist 360 reports the comment of Mary Robinson, former president of Ireland and member of The B Team: “Climate action is at a crossroads, in part because of the large scale of public money flowing to harmful industries and practices. We need to see thorough subsidy reform from governments and businesses, with social and environmental considerations at the heart, to ensure a just and equitable transition for all.”

Enacted, EHS reform could go a long way to mitigating climate and environmental harm, but such reform will likely be a slog, given the complexity and entrenched nature of national and international economic systems, the inherent conservatism — never mind the centrality of the profit motive — of most private enterprise, and the typically glacial pace of governments on reform efforts. Still, it is encouraging to see some portion of the business community stepping up to recognize its responsibility to remedy what it (as well as governments, militaries, and others) have caused, and advance the possibility of a livable and functional climate and environment.

Beyond Pesticides would add to the ambitious scope of this brief and its sponsors that EHS reform, and the implied reform of supply chains, should directly address the toxicity of so much of the global materials stream — particularly, synthetic pesticides and fertilizers, plastics, and chemical ingredients of industrial and consumer products (see, e.g., this Daily News Blog article on PFAS and other toxics). Multiple other articles have covered the need for companies to clean up their supply chains, and Beyond Pesticides advocacy on the issues — whether about garden center and other retail sale of plants treated with toxic pesticides, sale of contaminated “biosludge” as fertilizer, the ubiquity of untested chemicals, including those in plastics, or myriad others. Beyond Pesticides has also detailed the systemic ecosystem impacts of toxic chemicals and their damage to biodiversity.

Many, many products and ingredients are integral in causing the harms this brief addresses, and whose authors and supporters hope will inform decision makers at COP15 (the UN Biodiversity Conference). Beyond Pesticides encourages that the report be taken seriously, and that its influence leads to a genuine shift across the global business community toward nature-positive goals — redirection of policy and investment to repair and restore, rather than ravage, the climate and natural systems of this world.

Sources: https://static1.squarespace.com/static/5d777de8109c315fd22faf3a/t/620d33b868c7486475f06303/1645032379783/Financing_Our_Survival_Brief_FINAL.pdf and https://www.businessfornature.org/news/subsidy-reform

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

(Beyond Pesticides, February 24, 2022) Widespread, intensive pesticide use for mosquito control has allowed genetic mutations to persist among mosquito populations, causing subsequent resistance to future chemical exposure. According to a study published in Scientific Reports, two common species of female mosquitoes learned to evade pesticides following non-fatal exposure through smell. More concerning is the survival rate of these pre-exposed mosquitoes, as it is more than double that of unexposed mosquitoes. Insects, including mosquitoes, use various sensory and cognitive abilities like vision, smell, and hearing to navigate the ecosystem for survival and reproduction. Mosquitoes associate sensory stimuli like smell to a positive or negative experience, thus facilitating a response. Considering the two species of mosquitoes in this study are a vector for numerous diseases in humans, including dengue and Zika and West Nile viruses. Hence, this study highlights the significance of addressing pest resistance in pest management strategies, particularly to mitigate disease exposure and effects. The study notes, “[The] findings highlight the importance of mosquito cognition as determinants of pesticide resistance in mosquito populations targeted by chemical control.”

It is essential to understand insect behavior that propagates vector-borne disease transmission that exacerbates the widespread public health crisis. Scientists attribute memory and associative learning to behavioral changes occurring in responses to chemical exposure. The study focused on female Aedes aegypti and Culex quinquefasciastus mosquitoes that researchers exposed to a sublethal dose of five pesticide compounds. Using the World Health Organization (WHO) bioassays, researchers observe associative learning by exposing mosquitoes to sublethal doses of deltamethrin  (pyrethroid), permethrin (pyrethroid), lambda-cyhalothrin (pyrethroid), propoxur (carbamate), and malathion  (organophosphate). These chemicals represent the pesticides primarily used for vector control. Researchers then exposed female mosquitoes to the same chemical in the assay.

The result demonstrates that female mosquitoes previously exposed to a chemical avoid the same chemical when associated with adverse survival odds, seeking out blood to ensure survival. Thus, following a single exposure, mosquitoes can associate the smell of pesticides with their harmful effect to avoid contact with the said chemical. Female mosquitoes prefer to rest in a pesticide-free area rather than one prone to pesticide use.

This study resembles an all too familiar phenomenon of resistance among pest populations. Scientists note resistance is an entirely normal, adaptive phenomenon: organisms evolve, “exploiting” beneficial genetic mutations that give them a survival advantage. However, resistance is growing in all sectors of pest control, including critically needed agriculture and medicine. For nearly a century, the human response to resistance is the development of a compound that kills the resistant organism (whether pest or weed or bacterium or fungus), which works for a while. However, the dependence on chemical solutions is increasingly failing. Whether it is antibiotics for bacterial infections, herbicides for weeds/pests, or insecticides to mitigate vector-borne diseases, organisms are becoming resistant to usually toxic compounds. Once an organism inevitably becomes resistant to a particular chemical control strategy, people — the chemical industry, researchers, applicators, farmers, public health workers, clinicians, et al. — will have typically moved on to the subsequent chemical “solution.” Pesticide Action Network North America (PANNA) notes, “The World Health Organization underscored the problem in their 2012 guidance on policymaking for Integrated Vector Management (IVM): ‘Resistance to insecticides is an increasing problem in vector control because of the reliance on chemical control and expanding operations…Furthermore, the chemical insecticides used can have adverse effects on health and the environment.’”

Beyond Pesticides has written extensively on the issue of resistance, particularly the relationship to the use of agricultural and other land management pesticides, with the central message: resistance is a symptom of the ineffectiveness of chemical-intensive agriculture and leads to increased use of more and more toxic pesticides. In addition, resistance in one of the “sectors” mentioned above can “crossover” to become problematic in another. Growing pesticide resistance often leads to an increase in chemical inputs to control pests. Exposure to permethrin already has implications for human health, including cancer, endocrine (hormone) disruption, reproductive dysfunction, neurotoxicity, and kidney/liver damage. Mosquito resistance can augment the use of chemical control methods, including the addition of toxic synergists like piperonyl butoxide (PBO), known to cause and exacerbate adverse health effects from exposure. Therefore, researchers need to understand the mechanisms prompting pesticide resistance among mosquito populations to safeguard human health from disease.

In the context of deadly pesticide use in developing countries, Jay Feldman, executive director of Beyond Pesticides, has noted, “We should be advocating for a just world where we no longer treat poverty and development with poisonous band-aids but join together to address the root causes of insect-borne disease because the chemical-dependent alternatives are ultimately deadly for everyone.” He also said, “We should focus on the deplorable living conditions and inequitable distribution of wealth and resources worldwide that give rise to squalor, inhumane living conditions, and the poor state of development that, together, breed insect-borne diseases like malaria.”

Even if dengue is not a local concern, there remains general concern surrounding the diseases mosquitoes can transmit, including the West Nile and Zika virus. Beyond Pesticides provides valuable information on mosquito management and insect-borne diseases on the Mosquito Management and Insect-Borne Diseases section devoted to these issues. Furthermore, keep up on pesticide-related science and news, including mosquitoes and pesticide resistance on Beyond Pesticides’ Daily News blog.

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

Source: ABC News, Scientific Reports

(Beyond Pesticides, February 23, 2022) Fungicide use in agriculture is driving the spread of multi-fungicide resistant human pathogens, finds a recent study conducted by scientists at the University of Georgia. While this occurrence has long been an assumption based on the rampant overuse of fungicides in chemical-dependent farming, scientists have now found clear evidence linking the development of widespread fungal resistance to farming practices, rather than health care use. Despite strong evidence that commonly used synthetic pesticides in chemical-intensive farming are driving resistance that threatens human health on a global scale, the U.S. government has not only failed to take action, it has fought against international efforts to slow the crisis, at the behest of the agrichemical industry.  

Scientists focused their research on Aspergillus fumigatus, a common mold that can infect humans and cause aspergillosis. Although some have problems with mild sensitivity to the fungus, virulent infections called invasive aspergillosis can occur in immunocompromised individuals and are on the rise. Cases of invasive aspergillosis increased 3% per annum between 2000 and 2013, and roughly 300,000 worldwide are diagnosed each year. On both farms and in human medical settings, antifungal compounds called azole fungicides are used in attempts to kill off A. fumigatus infection.

Samples were taken from soil, compost, or plant debris from 56 farms in Georgia and Florida, with 53 of those sites having previously used azole fungicides. Of the remaining three, two samples were taken from organic farms and one was taken from a compost pile.

Of 700 A. fumigatus samples collected, nearly 20% (123) displayed some level of resistance to the commonly used azole fungicide tebuconazole. Twelve of the 123 were highly resistant at clinically relevant levels for human health care. No samples taken from organic sites contained resistant fungi.

It was hypothesized that if the strain of A. fumigatus infecting people developed its resistance traits on a farm, that strain would also have developed some level of resistance to other, non-azole, agricultural fungicides. Sure enough, the azole-resistant strains also displayed resistance to methyl benzimidazole carbamate (MBC) fungicides like carbendazim, and quinone outside inhibitors (Qol) like azoxystrobin.

By sequencing the genomes of A. fumigatus samples both from the current study and those taken and stored  from clinical tests across the world, researchers were able to create a neighbor-joining tree — a sort of family tree of fungicide resistant A. fumigatus. That review showed that genetically, pan-azole resistant strains – those with broad resistance to azole fungicides – matched up closely between those discovered on farms and those found in human clinical settings.  Of 25 pan-azole resistant samples analyzed, eight farm samples and 12 human clinical samples also displayed resistance to non-azole fungicides.

“The strains that are from the environment and from people are very closely related to each other,” study co-author Marin T. Brewer, PhD, said. “It’s not like there are different strains that are developing resistance in people and in the environment. It’s all the same. So people who have these infections that are resistant have likely acquired them from the environment.”

Aspergillus fumigatus is commonly found both indoors and outside. Infection can occur by simply inhaling a small amount of the fungi.

This result is merely the latest resistant pathogen to trace its lineage back to on-farm use. Over the last decade, scientific evidence has built around the link between common herbicides and antibiotic resistant bacteria. A 2015 study found that Salmonella and E.coli exposed to the herbicides glyphosate, dicamba, and 2,4-D triggered a non-specific defense mechanism which, while building resistance to the toxic effects of the herbicides, also resulted in resistance to commonly used antibiotics. Subsequent research has found soil sprayed with these same herbicides to have higher numbers of antibiotic resistant bacteria than areas where the chemicals were not applied. The resistant genes move throughout the environment by ‘horizontal gene transfer,’ elevating the importance of land and agricultural management practices that eliminate antibiotics and fungicides. 

Another problematic fungal pathogen, the yeast Candida auris, continues to rapidly develop treatment resistance in human clinical settings, linked to the excessive use of fungicides.

Researchers say their results indicate a need for a shift toward less toxic fungicides that do not cause resistance to human pathogens. “This emergence severely limits the usefulness of fungicides to manage plant pathogens while still preserving the clinical usefulness of azoles,” Dr. Brewer said. “We urgently need effective agricultural fungicides that aren’t toxic to the environment that do not lead to the rapid development of widespread resistance in the clinic.”

While the call is laudable, regulators and politicians are neither heeding the science, nor listening to scientists. The U.S. Environmental Protection Agency’s recent response to the rise of drug-resistant Candida auris is case in point. The agency failed to assess the efficacy of any pesticides that are not used for public health purposes; EPA only evaluated the efficacy of antimicrobial compounds whose use patterns classify them as human-health-related.

At the international level, a Freedom of Information Act request revealed officials at the U.S. Department of Agriculture working to downplay the role of synthetic fungicide use in chemical agriculture as a factor in the rise of drug-resistant fungal infections worldwide. Not only did they work to deny the truth on the ground, efforts were made to halt protective actions. Emails showed top level officials at industry trade group Croplife America urging USDA officials to “make certain” that the United Nation’s (UN) Codex Alimentarius, a set of international guidelines and standards established to protect consumer health, made no mention of how fungicides contribute to antibiotic resistance.

Prior research on resistance in agriculture has shown that the only true way to eliminate resistance is to stop using the material that was causing resistance to occur in the first place. Organic agriculture, with its strong restrictions on allowed synthetic materials, provides a path out of the industrialized chemical farming system that overtook agricultural production over the last century. Rising resistance, and the need to retain life-saving medication for protecting people’s health, not growing crops, is another reason why investing in organic is the right choice for the future. For more reasons to go organic, see Beyond Pesticides Why Organic webpage.

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

Source: University of Georgia press release, G3 Genes|Genomes|Genetics

(Beyond Pesticides, February 22, 2022) Regulation of toxic chemicals must recognize the reality that, “The cocktail of chemical pollution that pervades the planet now threatens the stability of global ecosystems upon which humanity depends,” as stated by The Guardian. When the Environmental Protection Agency (EPA) recognizes the dangers of a toxic chemical—especially one persistent in the environment—it must take immediate action to prevent further contamination. So, allowing the phase-out of chemicals with long residual life can extend the poisoning and contamination for generations.

Tell EPA to immediately ban all uses of pentachlorophenol and other toxic wood preservatives. Tell Congress to ensure that EPA does its job. 

There is an ongoing crisis, widely reported, posed by the nearly ubiquitous presence of “forever chemicals”—poly- and perfluoroalkyl substances (PFAS) and their relatives. A report by the Centers for Disease Control and Prevention (CDC) finds that 97% of Americans have PFAS in their blood. The Safer States Network finds that more than 210 bills will be considered in at least 32 states in 2022 to try to address the problem. Even the U.S. Environmental Protection Agency has confirmed that ‘forever chemicals’ are contaminating containers that store pesticide products, and subsequently the products themselves.

PFAS are only the most recent persistent toxic chemicals to achieve notoriety. Ever since its inception, Beyond Pesticides has shown the need to ban highly toxic wood preservatives. According to Koppers Recovery, “43% of all new poles are treated with penta; 42% are treated with CCA; and 13% are treated with creosote.”

EPA has long known about the dangers pentachlorophenol (penta) poses to health, particularly the health of workers in penta production or wood treatment plants and opposed worldwide action to ban the chemical. In 2008, the agency determined that these occupational handlers have a 1 in 1,000 risk of developing cancer. Rather than cancel the chemical at that time to protect worker health, the agency opted to attempt additional mitigation measures, requiring further personal protective equipment, engineering controls, and changes to treatment procedures. With no real-world evidence that this would make a difference, the agency expected these changes to drop the cancer risk to workers. However, in its most recent draft risk assessment, EPA found that this drastically high cancer risk remained the same. The agency’s current action to phase-out penta over five years came only when the manufacturer in North America stopped production after being shut down in Mexico.

Similarly, EPA has known about the dangers of creosote and arsenical wood preservatives. Despite a high-profile tour of communities affected by toxic chemicals by EPA Administrator Michael Regan, the agency still fails to make connections that could help protect against the poisoning of workers, fenceline communities, and others. As Mr. Regan, in November, visited Houston, Texas, where thousands of residents are suing Union Pacific Railroad Company for contaminating their properties with highly hazardous creosote wood preservatives, EPA is in the process of reauthorizing creosote use for another 15 years with the knowledge that it is virtually impossible to produce and use without causing contamination and poisoning. When EPA proposed interim decision for creosote, it wrote, “Creosote-treated wood offers unique benefits in the preservation of railroad crossties, wooden utility poles, and round timber foundation piles for land, freshwater, and marine use.” In light of these “unique benefits,” the agency did not even consider the viability of alternatives, such as steel, composites, and fiberglass that could replace the hazardous wood preservative process with non or less toxic materials.

All of the wood preservatives are broadly highly toxic and persistent. There is no safe way to dispose of treated wood. As was seen firsthand by EPA Administrator Regan, it is evident from both history and the present day that chemical corporations target low income, BIPOC neighborhoods to site hazardous industrial processes, creating fence line communities with higher rates of disease incidence and other health problems. EPA must not only clean up contamination caused by past injustices, but also stop future injustice directed toward black and brown communities by suspending the registration of hazardous wood preservatives like creosote.

Unfortunately, when EPA takes action, it is delayed. Although after nearly a century of use, EPA is officially cancelling the highly toxic wood preservative pentachlorophenol (penta), it has done so with a 5-year phase-out period. But the first step to removing these “forever chemicals” from our environment is to quit adding them.

Tell EPA to immediately ban all uses of pentachlorophenol and other toxic wood preservatives. Tell Congress to ensure that EPA does its job. 

Letter to EPA:

Regulation of toxic chemicals must recognize the reality that “The cocktail of chemical pollution that pervades the planet now threatens the stability of global ecosystems upon which humanity depends,” according to The Guardian. When EPA recognizes the dangers of a toxic chemical—especially one persistent in the environment—it must take immediate action to prevent further contamination.There is a widely reported ongoing crisis posed by the nearly ubiquitous presence of “forever chemicals”—poly- and perfluoroalkyl substances (PFAS) and their relatives. 97% of Americans have PFAS in their blood, resulting in more than 210 bills that will be considered in at least 32 states in 2022 to try to address the problem.

But PFAS are only the most recent persistent toxic chemicals to achieve notoriety. Highly toxic wood preservatives pose a similar danger.

EPA has long known about the dangers pentachlorophenol (penta) poses to health, particularly the health of workers in penta production or wood treatment plants. In 2008, the agency determined that these occupational handlers have a 1 in 1,000 risk of developing cancer. Rather than cancel the chemical at that time to protect worker health, the agency opted to attempt additional mitigation measures, requiring further personal protective equipment, engineering controls, and changes to treatment procedures. With no real-world evidence that this would make a difference, the agency expected these changes to drop the cancer risk to workers. However, in its most recent draft risk assessment, EPA found that this drastically high cancer risk remained the same.

Similarly, EPA has known about the dangers of creosote and arsenical wood preservatives. Despite a high-profile tour of communities affected by toxic chemicals by EPA Administrator Michael Regan, EPA still fails to make connections that could help protect against poisoning of workers, fenceline communities, and others. As Mr. Regan, in November, visited Houston, Texas, where thousands of residents are suing Union Pacific Railroad Company for contaminating their properties with highly hazardous creosote wood preservatives, EPA is in the process of reauthorizing creosote use for another 15 years with the knowledge that it is virtually impossible to produce and use without causing contamination and poisoning. In its proposed interim decision for creosote, EPA wrote, “Creosote-treated wood offers unique benefits in the preservation of railroad crossties, wooden utility poles, and round timber foundation piles for land, freshwater, and marine use.” In light of these “unique benefits,” the agency did not even consider the viability of alternatives, such as steel, composites, and fiberglass that could replace the hazardous wood preservative process with non or less toxic materials.

All the wood preservatives are broadly highly toxic and persistent. As was seen firsthand by EPA Administrator Regan, it is evident from both history and the present day that chemical corporations target low income, BIPOC neighborhoods to site hazardous industrial processes, creating fence line communities with higher rates of disease incidence and other health problems. EPA must not only clean up contamination that caused past injustices, but also stop future injustice directed toward black and brown communities by eliminating the use of penta, creosote, and arsenical wood preservatives.

Unfortunately, when EPA takes action, it is delayed. Although after nearly a century of use, EPA is officially cancelling the highly toxic wood preservative pentachlorophenol (penta), it has done so with a 5-year phase-out period. But the first step to removing these “forever chemicals” from our environment is to quit adding them.

Please take action to eliminate use of these persistent toxic chemicals immediately.

Thank you.

Letter to U.S. Senators and Representative:

I am writing out of an urgent concern for our future, in view of increasing contamination with toxic “forever chemicals.”

Regulation of toxic chemicals must recognize the reality that, “The cocktail of chemical pollution that pervades the planet now threatens the stability of global ecosystems upon which humanity depends,” according to the Guardian. When EPA recognizes the dangers of a toxic chemical—especially one persistent in the environment—it must take immediate action to prevent further contamination.

Anyone who reads the news is aware of the crisis posed by the nearly ubiquitous presence of “forever chemicals”—poly- and perfluoroalkyl substances (PFAS) and their relatives. 97% of Americans have PFAS in their blood, resulting in more than 210 bills that will be considered in at least 32 states in 2022 to try to address the problem.

But PFAS are only the most recent persistent toxic chemicals to achieve notoriety. Highly toxic wood preservatives pose a similar danger.

EPA has long known about the dangers pentachlorophenol (penta) poses to health, particularly the health of workers in penta production or wood treatment plants. In 2008, the agency determined that these occupational handlers have a 1 in 1,000 risk of developing cancer. Rather than cancel the chemical at that time to protect worker health, the agency opted to attempt additional mitigation measures, requiring further personal protective equipment, engineering controls, and changes to treatment procedures. The agency expected these changes to drop the cancer risk to workers. However, in its most recent draft risk assessment, EPA found that this drastically high cancer risk remained the same.

Similarly, EPA has known about the dangers of creosote and arsenical wood preservatives. Despite a high-profile tour of communities affected by toxic chemicals by EPA Administrator Michael Regan, EPA still fails to make connections that could help protect against poisoning of workers, fenceline communities, and others. As Mr. Regan visited Houston, Texas, where thousands of residents are suing Union Pacific Railroad Company for contaminating their properties with highly hazardous creosote wood preservatives, EPA is in the process of reauthorizing creosote use for another 15 years with the knowledge that it is virtually impossible to produce and use without causing contamination and poisoning. In its proposed interim decision for creosote, EPA wrote, “Creosote-treated wood offers unique benefits in the preservation of railroad crossties, wooden utility poles, and round timber foundation piles for land, freshwater, and marine use.” In light of these “unique benefits,” the agency did not even consider the viability of alternatives, such as steel, composites, and fiberglass that could replace the hazardous wood preservative process with non or less toxic materials.

All wood preservatives are broadly highly toxic and persistent. As was seen firsthand by EPA Administrator Regan, chemical companies target low income, BIPOC neighborhoods to site hazardous industrial processes, creating fence line communities with higher rates of disease incidence and other health problems. EPA must not only clean up contamination that caused past injustices, but also stop future injustice directed toward black and brown communities by eliminating the use of penta, creosote, and arsenical wood preservatives.

Unfortunately, when EPA takes action, it is delayed. Although after nearly a century of use, EPA is officially cancelling the highly toxic wood preservative pentachlorophenol (penta), it has done so with a 5-year phase-out period. But the first step to removing these “forever chemicals” from our environment is to quit adding them.

Please ensure that EPA takes action to eliminate use of these persistent toxic chemicals immediately.

Thank you.