(Beyond Pesticides, September 6, 2021) This Labor Day, as we live through our second year of the coronavirus pandemic, it is especially appropriate that we continue to express gratitude to all essential workers—healthcare workers, farmworkers, food processors, grocery workers, and others that put their lives on the line every day. But our gratitude does not protect anyone’s health. Nobody should have to risk their health for a job. That’s why, on this Labor Day, we must renew our commitment to eliminate the racial and economic inequities in our society that contribute to disproportionate risk to the health and well-being of workers, especially people of color. We can do this through the adoption of local, state, and national policies that eliminate toxic pesticide use, which disproportionately affects workers.

As we as a nation recognize that systemic change is needed to fight racial and economic injustice, we are faced with questions that go to the core of our society—the distribution of wealth, a livable wage, investment in and access to education and health care, protection of the right to vote, and an environment that sustains life.

This is a moment for building coalitions in our communities to advance policies that ensure all aspects of a healthful life and environment, supported by our social structures. In doing this, we recognize that we must join together to build the necessary power to effect meaningful and transformational change that confronts the existential public health (including worker health), climate, and ecological crises.

Our work to advance systemic change will continue to seek changes in underlying policies that codify disproportionate harm, such as federal pesticide law that is built on a foundation that allows elevated and disproportionate risk to workers who are excluded from EPA’s cumulative risk assessment (under the Food Quality Protection Act, amendments to the Federal Food, Drug and Cosmetic Act and the Federal Insecticide, Fungicide, and Rodenticide Act), which aggregates dietary and non-dietary, but explicitly not occupational, exposure to pesticides, while including a mandate to protect children. With this, the law effectively requires EPA to allow higher rates of harm for workers, particularly farmworkers, landscapers (workers who are disproportionately people of color), and others occupationally exposed to pesticides.

EPA’s recent decision to ban food uses of chlorpyrifos, but still allow it to be applied on golf courses, road medians, processed wood products, and more, is just one more glaring example of EPA’s failure to protect workers who handle toxic pesticides, and the general population and planet.

Change starts in our communities. The coronavirus pandemic has increased our understanding of disproportionate harm from Covid, with the recognition of elevated illness and death among essential Black and brown workers in our community. We have learned that those with preexisting adverse health conditions (or comorbidities) are at elevated risk. As we rethink our approach to pesticide reform, we ask: Does a science-based, public health-oriented, occupational safety focused, children-concerned, ecologically protective society allow the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? The answer, of course, is “no.”

Now is the time to eliminate worker and community hazards with the adoption of organic land management practices and policies in all our communities. We can eliminate petroleum-based toxic pesticides and fertilizers, protecting workers, and achieve beautiful landscapes and safe playing fields and parks. With increased momentum nationwide, in all parts of the country, all communities can make the transition, as we work with states and the federal government to eliminate our unnecessary dependence on toxic pesticides.

In our communities, let’s protect the workers, public health, and the environment. To discuss transitioning your community to organic land management, contact [email protected].

—Jay Feldman, executive director of Beyond Pesticides.

(Beyond Pesticides, September 3, 2021) Groupe Danone, multinational corporate owner of Horizon Organic, has announced that it is terminating its contracts with 89 small-to-medium-sized organic dairy producers in the Northeast as of August 2022. At that point, all of Horizon’s contracted organic dairy farms in Vermont, New Hampshire, Maine, and northern New York may well have no buyers for their milk and will likely face a very uncertain future. In July 2021, Beyond Pesticides covered a major contributor to this development — the failure of the NOP (National Organic Program) to protect the integrity of organic dairy, which failure has advantaged large producers over smaller operations (see more on this below). This development in a region with historically strong demand for organic dairy products is of concern on several fronts, not the least of which is the fate of these small producers.

A letter with the news was sent by Danone to 28 Vermont producers, 14 in Maine, 2 in New Hampshire, and 45 in New York State’s three northernmost counties. The company plans, instead, to source milk primarily from larger producers, including “organic” concentrated animal feeding operations (CAFOs) — in Ohio, Pennsylvania, the Midwest, and some Western states — that can produce milk at lower cost, leaving the Northeast region’s small and medium size organic dairy farms in the lurch.

In email communication between Danone and the Northeast Organic Dairy Producers Alliance (NODPA), the company cited “growing transportation and operational challenges in the dairy industry, particularly in the Northeast” as justification for the move. CBS Boston reports that,“The company told Vermont officials that it did not want to transport milk from the [Northeast] region to its plant in New York.” Marion Nestle’s “Food Politics” blog reports the company’s additional comment: “We will be supporting new partners that better align with our manufacturing footprint,” and translates those comments to the real reason — “organic milk in the Northeast costs more, so Danone is cutting its losses.”

As Dr. Nestle points out, the larger dairies, and CAFO operations in particular (especially in Texas) have huge herds and operate with the cost advantages of that scale. Danone indicates that it is cheaper to purchase milk from these producers and ship it East, despite their distance from the Western New York processing plant the company is choosing to use, than to buy from smaller, Northeast producers. Danone insists it did not make this decision lightly, adding that “We are committed to continuing to support organic dairy in the East, and in the last 12 months alone, we have onboarded more than 50 producers new to Horizon Organic that better fit our manufacturing footprint.”

In a Beyond Pesticides interview, NODPA Executive Director Ed Maltby explained Danone’s dropping of contracts with these 89 dairies and at the same time, entering into new contracts with 50 others in the region. This at first blush appears odd, and certainly it contradicts Danone’s comment about not wanting to transport milk from the Northeast to its processing plant near Buffalo. (This plant can process ultra-pasteurized milk, which is easily warehoused and transported, and has become a staple of the organic dairy sections of retail stores.)

But as Mr. Maltby set out, those 50 new suppliers are larger dairies (which mean fewer tanker stops to pick up milk) that are also located along more major routes, making pickup trips easier than visiting many small dairies that may be located in more outlying areas. Danone is looking to amplify savings associated with what it deems more-efficient milk collection.

Mr. Maltby adds that the impacts of Danone’s abandonment of smaller Northeast organic dairy farms will be felt throughout their rural communities. The potential damage extends beyond the potential shuttering of the affected dairy farms. Nicole Dehne, director of Vermont Organic Farmers, notes that if these dairy farms are forced to shut down, “the ripple effect[s] on the local economy would be notable. Producers employ breeders, vets and grain companies, for example. Organic farmers are also required to manage their farms so they’re hospitable to the local ecosystem. They have to improve soil health on their farms. They have to plan and manage for biodiversity. So it’s also kind of devastating to think that we might lose that acreage that’s being managed in that way.” Marion Nestle says in her “Food Politics” blog: “This is Big Organic Dairy in action, and it’s not pretty.”

The Portland Press Herald reports more of Ed Maltby’s commentary, which goes to Dr. Nestle’s point: “Danone is effectively consolidating their supply base. The way they’ve done it is (what) any large conglomerate company would do. They do it impersonally. It’s not as if they are holding meetings with farmers in the area and saying these are the challenges we’re having in transporting milk and can we work together.”

A bit of the relevant corporate consolidation history: Stonyfield Farm, a long-standing independent manufacturer based in New Hampshire, was fully acquired by Groupe Danone in 2014. Then, Danone announced its intention to sell the Stonyfield subsidiary to avoid antitrust claims and to clear the way for the acquisition of the organic food producer WhiteWave Foods (owner of Horizon Organics). In 2017, Lactalis bought Stonyfield. Antitrust claims have been leveled against Danone previously, including by NODPA, over concerns about monopsony — a market situation in which there is only one buyer.

The Portland Press Herald article notes that this move by Danone is the most recent in a pattern of consolidation that has happened in other agricultural sectors. When the demand for organic milk took off from the late 1990s through the first decade or so of the 2000s, the organic milk sector grew rapidly, by 10–15% annually. This was likely fueled, in part, by public reaction to the use of rBGH, recombinant growth hormone, on conventional dairy herds.

Mr. Maltby is quoted again: “The rocket-ship growth drew in smaller farmers who saw the potential to earn a more stable living while also taking better care of the land and their animals . . . especially in the Northeast, where the climate is friendly to growing the pasture grass that organic dairy thrives on. The stable price plus the more natural way of farming was very attractive. . . . (At one point) there were over 200 organic dairy farms in Vermont and up to 17 in Maine, and that was because the brand and the buyers at that time were looking for farms near to their major markets,” including Boston and the New York City region.

But the “consolidation” ethos that prevails in the corporate universe has come to much of the agricultural landscape, including organic dairy. Some have called this moment an inflection point for the industry. The aggregate forces of (1) rising and disparate production costs (which are higher for smaller operations and in the Northeast), (2) slowing of demand as supply has increased, due to more “industrial/CAFO “organic” dairy coming on line, and (3) increased demand for non-milk, plant-based alternatives, are resulting in developments such as Danone’s bailing on small Northeast organic milk suppliers. Some consider that the decision signals a cooling of the organic dairy sector following 20 years of unrelenting growth.

An additional, and fairly invisible-to-the-public factor in this fraught landscape is the long-standing and unresolved “Origin of Livestock” issue. An ambiguity in the NOP definition of what constitutes an organic herd of cows has enabled very large dairy CAFOs to develop in the Midwest and parts of the West — the very suppliers to which Danone will turn. (Read more on CAFOs and “organic” CAFOs here, here and here.)

Under NOP rules, milk sold or represented as organic must be from livestock that have been under continuous organic management for at least one year. But this one-year transition period was created for conversion of a conventional herd to organic — an important feature when the National Organic Standards were created and the certified organic program and label were just launching in the U.S. Once a herd has been converted to organic production, all dairy animals must be under organic management from the last third of gestation.

The Organic Trade Association offers this description of the problem: “Due to a lack of specificity in the regulations, some USDA-accredited certifiers allow dairies to routinely bring [cheaper,] non-organic animals into an organic operation, and transition them for one year, rather than raise their own replacement animals under organic management from the last third of gestation. . . . [This] is a violation of the organic standards and creates an economic disadvantage for organic farmers who raise their own organic replacement animals under organic management in accordance with the regulations.”

This ambiguity has been exploited by what Dr. Nestle calls “Big Organic” — industrial producers (e.g., “organic” CAFOs) and processors such as Danone. Beyond Pesticides has noted that this loophole allows large industrial operations to undercut dairy farmers who operate with integrity — raising and managing their calves from birth organically — and compromises the organic nature of the product the consumer buys, threatening the integrity of the certified organic standard.

The loophole should have been remedied years ago; a revised rule was proposed in 2015, but no Final Rule has yet been issued. Beyond Pesticides wrote in July 2021: “We need a Final Rule on the origin of livestock and we need it now. At the beginning of the organic dairy movement, one of the big drivers was economic justice for farmers. We have lost thousands of farmers since then. Organic production was a viable alternative for family-scale producers and it has worked. However, much of the growth in the industry has been usurped by industrial scale operations gaming the system. If it wasn’t for the factory farms there could have been thousands of additional dairies saved and converted to organic.” Beyond Pesticides wrote in July to the Deputy Administrator of the NOP with its recommendations, including that the sale of transitioned animals as certified organic should be prohibited, among others aimed at preventing abuse of the transition option.

The uphill slog for small Northeast organic dairy farmers trying to compete with large industrial operations is exacerbated by the relatively higher costs of production in the region. Ed Maltby notes that costs for labor, land, insurance, and taxes are all higher in the Northeast than in most other regions of the country. He compared the producer cost for production of 100 pounds of organic milk: $36 in the Northeast, compared to $27–32 in the Midwest and West.

Another exploited loophole in enforcement of NOP rules relates to the “Pasture Rule” — how dairy herds feed. The NOP’s Pasture Rule for Organic Ruminant Livestock (established in 2011) sets out requirements for the grazing season. Organic ruminant livestock—such as cattle, sheep, and goats—must have free access to certified organic pasture for the entire grazing season. This period is specific to the farm’s geographic climate, but must be at least 120 days. In most cases, it will be much longer than 120 days. (There are also “dry matter” and documentation requirements in the rule.) The Pasture Rule explicitly says, “Organic producers should strive to maximize the number of days their animals are on pasture. The intent of the Pasture Rule is to ensure that organic ruminant operations are pasture-based systems, as well as to increase pasture productivity and pasture quality over time.”

This pasturing provision reflects a fundamental feature of organic dairy that distinguishes it from conventional dairy production. Yet, industrial “organic” dairy operations are using huge amounts of imported organic grain (corn and soy, in particular) to feed their herds. As the Cornucopia Institute documents in its 2018 report, The Industrialization of Organic Dairy, there have occurred many violations of the Pasture Rule during the past decade, particularly by industrial “organic” CAFOs. The report notes: “Large dairies have shifted from trying to justify their lack of grazing and pasture for their lactating dairy cows to creating the illusion of meeting the low standard set by the USDA. This illusion is made possible by a number of agreeable accredited organic certifying agents who are willing to collect large certification fees while looking the other way, facilitated by deficient oversight of these agents by the NOP.” Obviously, poor enforcement of standards via certifiers is also a wrench in the system.

Beyond Pesticides wrote, a few years ago: “We have ‘organic’ dairy CAFOs with 15,000 cows in a feedlot in a desert, with compelling evidence by an investigative reporter that the CAFO is not meeting the grazing rule — by a long shot.” The National Organic Coalition writes, “The lack of consistent enforcement with regard to dairy pasture requirements as well as origin of livestock rules have contributed to the oversupply of organic milk in the market. This has had a devastating effect on organic dairy prices to farmers, and left many organic farmers and those transitioning to organic with stranded investments because there are no buyers for their milk.”

What do Northeast dairy farmers and other make of this development? And what are they to do? This action by Danone is a very big deal in the region, and response from producers, advocates, and officials in the region has been more vociferous than the company may have been expecting. Damage to its public face and the goodwill of consumers may be at some risk.

Abbie Corse, an organic dairy farmer who sells to Organic Valley and is a board member of both the Northeast Organic Farming Association (NOFA) of Vermont and the Vermont Climate Council, had this to say: “Organic farms are beginning to follow the same consolidation trends as conventional farms. It’s attributable to loopholes in the National Organic Program. . . . Larger farms can now become certified, which has caused the market to become flooded. It’s allowing larger farms to enter into the marketplace where small farmers were. . . . I know that it has been an articulated priority of our congressional delegation to continue to push on the loopholes being closed, specifically for the origin of livestock and the pasture rule. . . . That would go a long way towards correcting for the equitable access in the marketplace for small farmers and their ability to thrive.”

Ms. Corse added that the mental stress of Danone’s action on producers is significant. “These aren’t just jobs. These aren’t just pieces of the economy. These are entire lives that are tied up in a farm. Even having to go through a process of receiving a letter like this . . . I don’t think the average person understands what that means for these folks.”

Maine Dairy farmer Lauren Webber called the move by Danone “perplexing,” given that Horizon had just “recently required that all of its Maine producers go through an extensive audit and documentation process for their operations, only to dump them a few weeks later.”

Officials in the affected states are working to call together stakeholders to try to address and solve this crisis. In Vermont, the Secretary of the Agency of Agriculture, Food and Markets, Anson Tebbets, is putting together a task force to address the problem; it is expected to include farmers, economic development officials, the Northeast Organic Farming Association (NOFA) of Vermont, the University of Vermont Extension, and the Vermont Farm Bureau. NOFA Vermont’s Policy Director Maddie Kempner commented, “Not having a buyer for your milk is a really severe position to be in for these farmers. So we’re doing our best to make sure we’re seeking solutions for alternative markets for their milk, but also, [to] make sure the farmers feel as individually supported as possible.”

According to Ed Maltby, these Northeast producers are really between a rock and a hard place, with few viable options. Some hope to find other buyers for their milk, such as Organic Valley/CROPP Cooperative, the largest remaining processor in the region, but as VTDigger reports, “Other buyers in the area, including Stonyfield Organic, Organic Valley and Upstate Niagara Cooperative, appear to have limited capacity to accept new producers.” Organic Valley CEO Bob Kirchoff said in a written statement that he does not yet know if the company will be able to help the Northeast farmers, adding that, “Organic farming is facing the same crisis we’ve seen in conventional agriculture — consolidation, industrialization, ‘get big or get out.’ It will take a lot of people working together to solve it, but we all must be bold enough to believe we can.”

Other producers will, as Ed Maltby suggests, likely switch to corn or hay production, or retire from farming and try to sell off their assets and reconcile their debt, which may leave them with relatively little cushion in the end. The ripple effects referred to earlier could include impacts on other rural businesses, and potentially, the sale of some valuable agricultural land to developers, which means more farmland loss (already a major problem, according to the American Farmland Trust).

As for potential solutions for Northeast organic producers, Mr. Maltby says there are few immediate ones, and refers readers to NODPA’s website coverage of the matter and actions the public can take to advocate for resolution. One of those is to communicate directly with USDA (the U.S. Department of Agriculture, under which the NOP operates) and Congressional representatives to ensure that the Origin of Livestock is a strong regulation that does not allow transitioned animals to retain organic certification when they are transferred or sold.

Mr. Maltby posits that one sensible approach would be for Danone to establish a processing plant near New York City — which it could easily afford to do. This would allow it to sell more easily to huge and critical markets in the greater New York City and Boston areas, but also, to service the milk supply it could buy from Northeast, some mid-Atlantic, and Pennsylvania producers. But he is not betting the farm on that outcome.

He also notes there may be some opportunity for Danone’s “B Corp” legal status to be challenged, given its behavior. (B Corporations are businesses whose legal classification requires them “to consider the impact of their decisions on their workers, customers, suppliers, community, and the environment.”) Dr. Nestle apparently concurs, writing, “Danone proudly proclaims its B Corp status [and] cites its B Corp ambition: ‘an expression of our long-time commitment to sustainable business and to Danone’s dual project of economic success and social progress.’ Social progress, anyone?”

The squeezing out of small organic producers who operate with integrity is a major concern for the organic dairy sector, of course, but also, for the larger issue of organic integrity and the public’s trust in the meaning of the certified organic label. Is the milk that comes from an “organic” CAFO the same product as milk that comes from a small Vermont dairy whose herd is on pasture for half the year? Many believe it is not. In 2018, Beyond Pesticides wrote of “organic” CAFO-produced milk: “The Washington Post’s 2017 report found that Aurora Organic Dairy, a major milk supplier for big box retailers like Walmart and Safeway, is producing milk that was less nutrient dense compared to small-scale organic family farms. . . . The subsequent [report] . . . found that the living conditions indicated by the photos [of CAFOs] did result in cows producing nutritionally deficient milk.”

The NOP must clarify rules, tighten enforcement of standards, and level the playing field for small- and medium-sized producers, who are currently disadvantaged by the competitive perquisites the large conglomerate operations enjoy. Members of the public are encouraged to contact federal elected officials and the USDA itself to advocate for such changes. Meanwhile, consumers can consider their own dairy purchases and vote with their food dollars to support ethical, sustainable, and transparent organic brands that source from smaller, regional producers. For more information on why it is so important to not only protect, but strengthen the organic label, see Beyond Pesticides’ Keeping Organic Strong webpage.

Sources: https://www.foodpolitics.com/2021/08/24686/, https://vtdigger.org/2021/08/23/danone-owner-of-horizon-organic-terminates-contracts-with-vermont-farmers/ and https://nodpa.com/n/5995/URGENT-ORGANIC-DAIRY-NEWS-Updated-82921-Danone-Exiting-the-Northeast-Region

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

(Beyond Pesticides, September 2, 2021) A McMaster University (Canada) study demonstrates exposure to the recently banned, commonly used insecticide chlorpyrifos promotes obesity development, even at low doses. Obesity generally occurs following a caloric imbalance between food intake, absorption, and energy expenditure. Although various factors can promote obesity, researchers suggest environmental toxicants like chlorpyrifos play a role in obesity development through protein/enzyme suppression.

According to the Center for Disease Control, 42 percent of the U.S. population is obese and at risk for type two diabetes, cardiovascular (heart) disease, stroke, several cancers, and other critical health issues. Therefore, research like this highlights the significance of investigating how toxic chemical exposure can impact health to prevent adverse disease outcomes. Researchers note, “These studies suggest that the effects of environmental toxicants on the development of obesity may have been underestimated as all studies to date have been conducted in mice housed at RT [room temperature]. Future studies examining the mechanisms driving reductions in β-AR [beta adrenergic receptors] signaling and whether there are associations between BAT [brown adipose tissue] metabolic activity and CPF [chlorpyrifos] in humans will be important.”

Several environmental pollutants have links to obesity development via the effects on gut health, endocrine (hormone) and metabolic system, and adipose (fat) tissues development. However, few studies consider how environmental toxicants impact brown adipose tissue (BAT) activation and the body’s ability to burn calories (thermogenesis). Thus, researchers used a stepwise screening approach to assess 34 commonly used pesticides and herbicides in brown fat cells (brown adipose tissue). Furthermore, scientists specifically tested the effects of chlorpyrifos among mice on high-calorie diets.

The study finds that chlorpyrifos (an organophosphate insecticide) suppresses uncoupling protein 1 (UCP1), responsible for regulating BAT thermogenesis, at concentrations as low as 1 (picomolar) pM. The primary exposure route is through diet, as the major cause of obesity is diet-induced thermogenesis suppression. Notably, the study focuses on thermoneutral housing for mice participants, which better mimic human conditions modeling metabolic disease development. Thus, chlorpyrifos exposure impairs BAT activation in thermoneutral mice on a high-fat diet, resulting in a greater risk of obesity, non-alcoholic fatty liver disease (NAFLD), and insulin resistance. Chlorpyrifos alters protein modifying enzymes, protein kinases responsible for maintaining UCP1 function, thus resulting in activation of BAT and suppression of calorie burning. (See “Pesticides and the Obesity Epidemic.”)

The obesity rate is increasing and has been over the last five decades. Although general over-eating and under-exercising attribute to obesity, researchers find the current obesity epidemic has alternative factors contributing to development. Besides genetics, exposure to obesogenic compounds like pesticides can promote obesity development. These compounds routinely cause reproductive, cardiovascular, and endocrine (hormone) issues among exposed individuals, especially farmers. Bruce Blumberg, Ph.D., professor of Developmental and Cell Biology, University of California, Irvine, defines obesogens “as chemicals that inappropriately stimulate the development of fat cells or the storage of fat into those cells, either directly by fiddling with how the cells work, or indirectly altering appetites tied to metabolism.” Many obesogenic compounds are endocrine disruptors that directly impact hormone and receptor function and include pesticides like organochlorines, organophosphates, carbamates, and pyrethroids. Furthermore, endocrine disruption can negatively impact reproductive function, nervous system function, metabolic/immune function, hormone-related cancers, and fetal/body development.

Several studies link pesticide exposure to endocrine disruption with epigenetic (non-genetic influence on gene expression) effects. As far back as 15 years ago, a Washington State University study linked pesticide exposure to multi-generational impacts on male fertility in rodents. According to multiple studies, glyphosate exposure has adverse multi-generational effects causing negligible observable effects on pregnant rodents but severe effects on the two subsequent generations. These impacts include reproductive (prostate and ovarian) and kidney diseases, obesity, and birth anomalies. Therefore, obesogenic compounds also impact the general population and have implications for future generational health. For instance, studies demonstrate that ancestral DDT exposure increases the risk of breast cancer and cardiometabolic disorder—promoting an epigenetic inheritance of obesity—up to three successive generations. Although the U.S. banned DDT over five decades ago, the insecticide is still environmentally persistent in all ecosystems and remains in use in some countries. Like DDT, exposure to other POPs like per- and polyfluoroalkyl substances (PFAS) during pregnancy can increase cardiometabolic disorders like obesity, diabetes, and cardiovascular diseases among offspring. Since DDT/DDE residues, current-use pesticides, and other chemical pollutants contaminate the environment, exposure to these chemical mixtures can synergize to increase toxicity and disease effects.

The study results indicate that chlorpyrifos negatively affects metabolic function, playing a role in inhibiting calorie burning or thermogenesis. The suppression of thermogenesis allows calories to accumulate in the adipose tissue rather than convert to energy. Scientists partially attribute the obesity epidemic to environmental toxicant exposure. Many of these contaminants are lipophilic, bioaccumulating in fatty adipose tissue. Therefore, these results explain why lifestyle changes around diet and exercise rarely sustain weight loss. Senior author and professor at McMaster University, Gregory Steinberg (PhD), notes, “chlorpyrifos would only need to inhibit energy use in brown fat by 40 calories every day to trigger obesity in adults, which would translate to an extra five lbs of weight gain per year.”

This study is the first toxicological assessment to investigate obesity and obesity-related illnesses in rodents under thermoneutral conditions, or the temperature at which an organism does not need to regulate body heat. Thermoneutral conditions are a better predictor of health effects among humans associated with chemical exposure. Past studies using room temperature mice fail to capture the scope of obesity-related health effects, even at chemical concentrations known to cause toxicity in animal studies (i.e., neurotoxic effect and reproductive effects). However, researchers discovered that exposure to real-world concentrations of chlorpyrifos under thermoneutral conditions promotes weight gain, non-acholic fatty liver disease, and insulin resistance.

The U.S. Environmental Protection Agency (EPA) recently announced the cancellation of all chlorpyrifos food production uses in the U.S., as chemical contamination among the general population remained considerable even after implementing residential use restrictions over two decades ago. However, the pesticide marketplaces still contain many chemicals that cause similar endocrine-disrupting, cancer-causing, neurotoxic health effects. This study takes place in Canada, which has long banned chlorpyrifos for food uses. However, imported goods can still contain chemical residues, as indicated by this study. Furthermore, chlorpyrifos residues do not disappear immediately after end-use and will persist in our environment for quite some time. Therefore, studies like this can help government and health officials understand the mechanism chemical toxicants use to alter metabolic function, promoting the obesity epidemic.

It is essential to understand the effects that obesogenic pesticides may have on the health of current and future generations. Beyond Pesticides believes that we must mitigate the multi-generational impacts pesticides pose on human and animal health.  However, there is a lack of understanding behind the cause of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiological data. Therefore, lawmakers and regulators should consider taking a more precautionary approach before introducing these chemicals into the environment. With far too many diseases in the U.S. associated with pesticide exposure, reducing pesticide use is a critically important aspect of safeguarding public health and addressing cost burdens for local communities.

Learn more about the effects of pesticides on human health by visiting Beyond Pesticides’ Pesticide-Induced Diseases Database, supporting a shift away from pesticide dependency. This database is a fantastic resource for additional scientific literature documenting elevated rates of body burdens, including obesity, endocrine disruption, cancer, and other chronic diseases and illnesses among people exposed to pesticides. Adopting regenerative-organic practices and using least-toxic pest control can reduce harmful exposure to pesticides. Solutions like buying, growing, and supporting organic can help eliminate the extensive use of pesticides in the environment. Learn more about the multi-generation impacts of pesticides on our health via Beyond Pesticide’s journal Pesticides and You. Furthermore, view Michael Skinner’s (Ph.D.) talk on Epigenetic Transgenerational Actions of Endocrine Disruptors on Reproduction and Disease delivered at Beyond Pesticides’ 2014 National Pesticide Forum.

Advocate for toxic pesticide use elimination by telling EPA to ban all uses of chlorpyrifos and other environmental toxicants through Beyond Pesticides’ Action of the Week. 

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

Source: Science Daily, Nature Communications

(Beyond Pesticides, September 1, 2021) A study published in Environmental Pollution finds the risk of acute childhood leukemia (AL) increases with prenatal and newborn exposure to pesticides (i.e., insecticides and herbicides). The study results support the hypothesis that chronic environmental pesticide exposure increases childhood leukemia risk up to two times. Maternal exposure has a stronger association with leukemia than childhood exposure. Insecticides and herbicides are of particular significance in increasing leukemia risk, especially for acute lymphoblastic leukemia. Although medical advancements in disease survival are more prominent nowadays, childhood AL remains the secondary cause of child mortality following physical injury. Furthermore, childhood leukemia survivors can suffer from chronic or long-term health complications that may be life-threatening.

Although the etiology or cause of childhood AL involves the interaction of multiple components like lifestyle and genetics, emerging evidence indicates that environmental contaminants like pesticides (e.g., occupational exposures, air pollution, pesticides, solvents, diet, etc.) play a role in disease etiology. Pesticide contamination is widespread in all ecosystems, and chemical compounds can accumulate in human tissues resulting in chronic health effects. Children are particularly vulnerable to the impacts of pesticide exposure as their developing bodies cannot adequately combat exposure effects. Already, studies find low levels of pesticide exposure during pregnancy or childhood cause adverse health effects from metabolic disorders to mental and physical disabilities. Moreover, several studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer, specifically focusing on leukemia.

Acute leukemia is the most common type of childhood cancer, affecting one out of three individuals, ages 0 to 14 years. Although the disease is rare, incidents are steadily increasing among adolescents and have been over the last 30 years. Therefore, studies like these highlight the importance of understanding how pesticide use can increase the risk of latent diseases (e.g., cancers) among vulnerable populations, such as children/infants. The authors note, “…[T]he findings of the present meta-analysis provide some evidence that low-dose long-term exposure to pesticides, mainly during pregnancy, increases the risk of childhood AL, especially among infants, supporting the still harmful role of pesticides…Moreover, mechanistic studies are deemed necessary to shed light into potentially relevant molecular pathways that underlie these associations, if replicated in future research.”

Despite several scientific studies demonstrating an association between pesticide exposure and adverse health outcomes like acute childhood leukemia (AL), methodological evidence remains inconclusive. The researchers evaluate the currently available, peer-reviewed literature on the association between pesticide exposure and different types of childhood AL, including acute lymphoblastic (ALL), acute myeloid (AML), and infant leukemia. The literature review focuses on studies published until January 2021 with specific attention to methodology. Researchers categorize effects by pesticide type, exposure-outcome (e.g., leukemia type), window/timeframe of exposure, and exposed population in evaluating the vast array of current studies.

The study results identify 55 studies from over 30 countries pertaining to over 200 different pesticide exposures from over 160,000 participants. Regardless of pesticide type, leukemia type, exposure timeframe, and population group, methodological studies demonstrate pesticide exposure increases the risk of childhood leukemia, particularly for infants. Maternal exposure to pesticides during gestation results in a more elevated leukemia risk for children than childhood (postnatal) exposure. Whether pesticide exposure is occupational or mixed, parental exposure to pesticides has the highest association with AL risk, including paternal (father) exposure. Exposure during pregnancy results in a 1.5 times greater risk of developing AL, with a 2.5 times increase in risk for acute lymphoblastic leukemia. When assessing pesticide subtypes, maternal exposure to insecticides and herbicides augments AL risk by a ratio of 1.6 and 1.4, respectively. Infant leukemia incidents depend on maternal pesticide exposure during pregnancy, with a higher risk for acute lymphoblastic and the highest risk for infant acute myeloid leukemia.

Environmental contaminants like pesticides are ubiquitous in the environment, with 90 percent of Americans having at least one pesticide compound in their body. This bodily contamination has implications for human health, especially during vulnerable life stages like childhood, puberty, pregnancy, and old age. Pesticide exposure during pregnancy is of specific concern as health effects for all life stages can be long-lasting. A 2020 study finds the first few weeks of pregnancy are the most vulnerable periods during which prenatal pesticide exposure can increase the risk of the rare fetal disorder holoprosencephaly. This disorder prevents the embryonic forebrain from developing into two separate hemispheres. Moreover, women living near agricultural areas experience higher exposure rates that increase the risk of birthing a baby with abnormalities. Just as nutrients are transferable between mother and fetus, so are chemical contaminants. Studies find pesticide compounds present in the mother’s blood can transfer to the fetus via the umbilical cord. Therefore, pesticide exposure during pregnancy has implications for both mother and child’s health. 

Many studies indicate prenatal and early-life exposure to environmental toxicants increase susceptibility to diseases. For decades, studies have long demonstrated that childhood and in utero exposure to the U.S. banned insecticide DDT increases the risk of developing breast cancer later in life. Moreover, a 2021 study finds previous maternal exposure to the chemical compound during pregnancy can increase the risk of breast cancer and cardiometabolic disorders (e.g., heart disease, obesity, diabetes) up to three successive generations. However, studies find numerous current-use pesticides and chemical contaminants play a role in similar disease outcomes, including mammary tumor formation. Recent research from the Silent Spring Institute links 28 different EPA registered pesticides with the development of mammary gland tumors in animal studies. Many of these said chemicals are endocrine disruptors, thus have implications for breast cancer risk. Even household cleaners, many of which are pesticides, can increase nephroblastoma (kidney cancer) and brain tumor risk in children. Furthermore, long-term exposure to organophosphate (OP) pesticides increases adverse health and cancer risk, specifically among women. Since DDT and its metabolite DDE residues, current-use pesticides, and other chemical pollutants contaminate the environment, exposure to these chemical mixtures can synergize to increase toxicity and disease effects.

The scientific connection between pesticides and associated cancer risks is nothing new. Several studies link pesticide use and residues to various cancers, from more prevalent forms like breast cancer to rare forms like kidney cancer nephroblastoma (Wilms’ tumor). Sixty-six percent of all cancers have links to environmental factors, especially in occupations of high chemical use. In addition to the link between agricultural practices and pesticide-related illnesses being robust, over 63 percent of commonly used lawn pesticides and 70 percent commonly used school pesticides have links to cancer. U.S. National Institutes of Health’s National Cancer Institute also finds many cancer-causing substances are endocrine disruptors. Globally, cancer is one of the leading causes of death, with over 8 million people succumbing to the disease every year. Notably, the International Agency for Cancer Research (IARC) predicts new cancer cases to rise 67.4% by 2030. Therefore, it is essential to understand how external stimuli—like environmental pollution from pesticides—can drive cancer development to avoid exposure and lessen potential cancer risks.

Although pesticides products are subject to an extensive toxicological assessment before registration, current regulatory guideline studies fail to assess genotoxicity and carcinogenicity in utero that induces infant leukemia incidents. Children are more susceptible to the toxic effect of pesticide exposure as their endocrine and metabolic systems cannot adequately detoxify and excrete chemical compounds. Moreover, pesticides can hinder childhood development making children more vulnerable to acute health effects like asthma/respiratory issues, gut dysbiosis, cardiovascular diseases, and other physical and mental birth abnormalities.

Cancer is a leading cause of death worldwide. Hence, studies concerning pesticides and cancer help future epidemiologic research understand the underlying mechanisms that cause the disease. There is a serious deficiency in understanding the etiology of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiologic data. Therefore, advocates maintain that lawmakers and regulators should take a more precautionary approach before introducing these chemicals into the environment. With far too many diseases in the U.S. associated with pesticide exposure, eliminating pesticide use is a critically important aspect of safeguarding public health and addressing cost burdens for local communities. Beyond Pesticides’ Pesticide-Induced Diseases Database (PIDD) is a vital resource for additional scientific literature that documents elevated cancer rates and other chronic diseases and illnesses among people exposed to pesticides. This database supports the clear need for strategic action to shift away from pesticide dependency. For more information on pesticide exposure’s multiple harms, see PIDD pages on leukemia and other cancers, birth/fetal defects, endocrine disruption, and other diseases.

One way to reduce human and environmental contamination from pesticides is buying, growing, and supporting organic land management. Organic agriculture has many health and environmental benefits, which curtail the need for chemical-intensive agricultural practices. Numerous studies find that levels of pesticide metabolites in urine drop greatly when switching to an all-organic diet. Furthermore, given the wide availability of non-pesticidal alternative strategies, families and agricultural industry workers alike can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. For more information on how organic is the right choice for both consumers and the farmworkers that grow our food, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture.

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

Source: Environmental Pollution 

(Beyond Pesticides, August 31 2021) To ensure long-term ecological, human health, and socioeconomic benefits, food production, distribution and consumption must transition from conventional to regenerative, organic food value chains, as outlined in research published in the journal Productions and Operations Management. “We are paying a high price for a lack of transparency in our food supply and realize that taking shortcuts, or efficiencies, is not sustainable,” said Aleda Roth, PhD, study coauthor and professor in the Wilbur O. and Ann Powers College of Business at Clemson University. “We need to look at multiple performance outcomes, and in doing so, it will become evident that a regenerative, socially responsible approach to agriculture is imperative to a sustainable food supply, but it also extends across other business sectors.” This research is the latest to underscore the importance of revamping the U.S. food system towards a focus on organic practices that account for externalities and provide multiple add-on benefits for society at large.  

To make the case, Dr. Roth and her co-author Yanchong Zheng, PhD, an associate professor in the Sloan School of Management at MIT, define and contrast conventional and regenerative, organic food value chains, with an eye toward “quadruple aim performance (QAP).” This is defined as a supply chain outcome that synergizes positive financial results with benefits to human, ecological and socioeconomic well-being.

A range of deleterious “upstream” production practices are identified within each QAP component. To begin, the authors make the case that “squeezing market prices and rising expenses” within conventional chemical agriculture are causing significant financial strain on most farmers. The data show that the wealthy top 1% of farmers accepted nearly $2 million in federal subsidies on average while the bottom 80% garnered an average of only $8,000. Genetically engineered crops are singled out for their poor financial record with farmers, noting that patent holders, not farmers, own GE seeds, and must repurchase them every year, putting most farmers in a “financial straight jacket.” Further, farmers that develop a pesticide-induced disease after growing pesticide-tolerant GE crops are unlikely to find quick financial restitution and thus are likely to suffer lost income, increased health care costs, and other expenses.

In outlining the human and ecological impacts of conventional chemical food production, Rachael Carson is used to frame the discussion, highlighting the prophetic nature of her work and the frustrating reality that the situation today is in many ways worse than in Carson’s era. Excessive use of nitrogen fertilizers and significant release of greenhouse gasses, the rampant poisoning of the earth through toxic pesticide use, contributing to a worldwide insect decline are cited as evidence that, “Time is running out, as we cannot escape the accelerated rate and magnitude of conventional farming on the destruction of our planet’s natural ecosystem.” It is noted that the discussion around pesticide impacts in conventional agriculture pit federal regulators and the chemical industry against public health scientists and the non-profit sector. Federal regulators are cited for allowing a range of pesticides restricted in other countries, as well as chemicals like glyphosate, putting human health at increased risk.

From a socioeconomic standpoint, the conventional food chain is cited for its failure to protect the most vulnerable residents, including farmworkers, infants and young children. Cheap, highly processed food is accessible, but “food deserts” make it so that many cannot access healthy options.

Unfortunately, the damage caused by conventional chemical-intensive production has both up and “downstream” effects. Once conventional goods are produced, they enter a complex supply chain that is significantly lacking in transparency, and controlled by few processors and manufacturers. Although this enables economy of scale, small-scale producers are financially hard hit within this paradigm, subject to downward price pressures and price manipulation. The complex, far-flung supply chain also results in harm to the environment due to the use of greenhouse gases in transportation, and the waste stream associated with product packaging. Human health is often an afterthought, with fraudulent food a rampant problem in developing countries, concerning issues around food safety and contamination, and the spillover health impacts from the a chemical-reliant production system. In a drive for profit above all else, the conventional chemical-intensive system results in socioeconomic harm to workers, with the authors citing recent incidents regarding the treatment of workers at Smithfield meat packing plants during Covid-19 outbreaks.

“Conventional chains cut corners in many ways and are not viable, nor renewable,” Dr. Roth said. “Toxins, like pesticides, herbicides, and heavy metals often found in global food chains have human well-being impacts that, among other things, degrade soil, water, and air. Extensive use of synthetic chemicals and pollution creates a vicious cycle that lowers public health and heightens the needs for the intensity of health-care services, which drives up societal costs.”

Regenerative, organic food chains, which include practices like crop rotation, no tillage, cover crops and the use of compost, are cited for their ability to reduce hazardous inputs that are part and parcel to the conventional chemical supply chain. Through organic practices, the authors note that “farmers can build more resilient food supplies that simultaneously act to clean the environment, reduce toxins, improve nutrients, provide farmer families with more financial stability—and improve socioeconomic well-being in terms of food security and health.” While the upstream benefits of organic production are relatively cut and dry, the authors note the need for changes in the downstream food chain. This includes: (i) increasing the use of contracts with guaranteed sales, (ii) fostering the development of more farmer co-ops, (iii) shortening supply chains by increasing local sales through CSAs [community supported agriculture] or other local models, (iv) educating consumers to close the loop in the supply chain by encouraging composting, and (v) meaningfully increasing the transparency and traceability of products within the food supply chain.

“There is mounting scientific evidence that the cost of not acknowledging conventional food chains’ undesirable and frequently hidden spillover effects is no longer defensible or viable. Increasingly, the many hidden costs associated with chemically reliant factory farming are being revealed, and many of the cracks in efficiency-oriented food supply chains surfaced with COVID-19,” Dr. Roth said. “We find that forward-thinking farmers and ranchers are making radical changes toward environmental stewardship, and there is growing evidence that consumers are positively responding and demanding a safer, yet cost-effective, way to bring food from farm to the table.”

The authors argue that QAP “is essential to the well-being of democracy,” and that it is important to apply these principles to one’s daily life. Ignoring the hazardous effects of conventional chemical food supply chains is no longer acceptable, the study notes. “There is mounting scientific evidence that the cost of not acknowledging these undesirable and frequently hidden spillover effects is no longer defensible or viable.”

“We must move away from a linear, efficiency-oriented food system toward a more circular, regenerative design, where wastes are reused and recycled. This paradigm shift requires systemic efforts from all parties in the food chain from producers to processors, manufacturers, wholesale, retail, food services, and eventually consumers, to all who contribute to a circular, closed-loop ecosystem,” said Dr. Zheng.

Studies increasingly show that organic practices provide multiple functional benefits for health, the environment, and society writ large. Help Beyond Pesticides promote the organic future we all deserve, and the world desperately needs. Learn more through the Why Organic webpage, and visit the Action of the Week archives for ways to take action to strengthen and defend the organic label.

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

Source: Clemson University, Productions and Operations Management

(Beyond Pesticides, August 30, 2021) As with other actions on pesticides, EPA’s chlorpyrifos decision is filled with exceptions that respond to vested interests seeking to ignore or deflect the science. EPA, since announcing its decision in 1999 to ban “residential” uses of chlorpyrifos, continues to allow the following uses: (i) Residential use of containerized baits; (ii) Indoor areas where children will not be exposed, including only ship holds, railroad boxcars, industrial plants, manufacturing plants, or food processing plants; (iii) Outdoor areas where children will not be exposed, including only: golf courses, road medians, Industrial plant sites; (iv) Non-structural wood treatments including: fenceposts, utility poles, railroad ties, landscape timers, logs, pallets, wooden containers, poles, posts, and processed wood products; (v) Public health uses: Fire ant mounds (drench and granular treatment); (vi) nurseries and greenhouses; and (vii) Mosquito control. These uses are unaffected by EPA’s announcement.

We need to finish the chlorpyrifos job. Tell EPA to ban all uses of chlorpyrifos.

The collective effort to remove this one chemical is a tremendous feat in eliminating one exposure to a hazardous material for children. Achieving the ban on food uses required an enormously resource-intensive effort at a time in history when we are running against the clock in an urgent race to transition our society and global community away from the use of petroleum-based, toxic pesticides—to move to meaningful practices that sustain, nurture, and regenerate life.

EPA was forced into its decision by a court order that was precipitated by an agency decision to reverse course after proposing to stop food uses of chlorpyrifos in 2017. Despite a mountain of scientific data challenging chlorpyrifos’s safety, it was embraced by industrial agriculture, the golf industry, and others, and deemed too valuable to the bottom line of its manufacturer, Corteva (formerly Dow AgroSciences). Pesticide manufacturers are also motivated to steer EPA away from adverse health and environmental effects findings on their products in order to avoid potential litigation by those harmed. The U.S. Court of Appeals for the 9th Circuit in San Francisco in its ruling in May, 2021, in which it mandated EPA action, said, “The EPA has had nearly 14 years to publish a legally sufficient response to the 2007 Petition [filed by environmental and farmworker groups].” The court continued, “During that time, the EPA’s egregious delay exposed a generation of American children to unsafe levels of chlorpyrifos.”

But before all the recent activity, in 1999, EPA had negotiated a compromise with Dow that stopped most residential uses of chlorpyrifos. Why? For the same reason that EPA finally acted on food. This neurotoxic chemical is harmful to children. That was 22 years ago and followed a campaign by Beyond Pesticides and others to remove Dursban/chlorpyrifos from the market because of indoor ambient air contamination of homes and buildings and lawn and landscape exposure. It should be noted that Dursban had been viewed with promise by regulators as the alternative to the organochlorine insecticide chlordane, which Beyond Pesticides sued to remove from the termite use market—a remaining use after the agricultural, lawn, and garden uses were finally taken off the market in 1983, with decades of review by numerous agencies. Its cancer-causing properties and ecological effects could no longer be defended. The cancellation of termite use followed in 1988 after millions of homes were potentially contaminated, with high risk factors for cancer.

It all comes down to this: Do we want a society that is science-based, public health-oriented, occupational safety focused, children-concerned, ecologically protective or one that allows the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? Should victims of poisoning have to plead with regulators to protect them? Should organizations have to fight chemical-by-chemical to achieve basic levels of protection from individual neurotoxic, cancer causing, endocrine disrupting pesticides? Of course not. This is exactly what has happened with the insecticide chlorpyrifos and continues to occur with other pesticides. There’s no question, we need an EPA that doesn’t play politics with health and the environment.

With all this as context for the chemical treadmill, next up after chlorpyrifos may be the insecticide bifenthrin, a synthetic pyrethroid. It too is a neurotoxic, cancer-causing, endocrine disrupting pesticide. And if that is not enough, there are others waiting in the wings. 

But first we need to finish the chlorpyrifos job. Tell EPA to ban all uses of chlorpyrifos.

U.S. EPA Administrator Michael Regan

I am writing to ask EPA to finish the chlorpyrifos job. Ban all uses of chlorpyrifos.

Does a science-based, public health-oriented, occupational safety focused, children-concerned, ecologically protective society allow the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? Should victims of poisoning have to plead with regulators to protect them? Should organizations have to fight chemical-by-chemical to achieve basic levels of protection from individual neurotoxic, cancer causing, endocrine disrupting pesticides? Of course not. Yet, this is exactly what has happened with the insecticide chlorpyrifos and continues to occur with other pesticides. The U.S. Environmental Protection Agency’s (EPA) announcement that the food uses of the chlorpyrifos will be banned after being registered 65 years ago should be cause to end its remaining uses.

As with other actions on pesticides, EPA’s chlorpyrifos decision is filled with exceptions that respond to vested interests seeking to ignore or deflect the science. EPA, since announcing its decision in 1999 to ban “residential” uses of chlorpyrifos, continues to allow the following uses: (i) Residential use of containerized baits; (ii) Indoor areas where children will not be exposed, including only ship holds, railroad boxcars, industrial plants, manufacturing plants, or food processing plants; (iii) Outdoor areas where children will not be exposed, including only: golf courses, road medians, Industrial plant sites; (iv) Non-structural wood treatments including: fenceposts, utility poles, railroad ties, landscape timers, logs, pallets, wooden containers, poles, posts, and processed wood products; (v) Public health uses: Fire ant mounds (drench and granular treatment); (vi) nurseries and greenhouses; and (vii) Mosquito control. These uses are unaffected by EPA’s announcement.

EPA was forced into its decision by a court order that was precipitated by an agency decision to reverse course after proposing to stop food uses of chlorpyrifos in 2017. Despite a mountain of scientific data challenging chlorpyrifos’s safety, it was embraced by industrial agriculture, the golf industry, and others, and deemed too valuable to the bottom line of its manufacturer, Corteva (formerly Dow AgroSciences). The U.S. Court of Appeals for the 9th Circuit in San Francisco in its ruling in May, 2021, in which it mandated EPA action, said, “The EPA has had nearly 14 years to publish a legally sufficient response to the 2007 Petition [filed by environmental and farmworker groups].” The court continued, “During that time, the EPA’s egregious delay exposed a generation of American children to unsafe levels of chlorpyrifos.”

But before all the recent activity, in 1999, EPA had negotiated a compromise with Dow that stopped most residential uses of chlorpyrifos. Why? For the same reason that EPA finally acted on food. This neurotoxic chemical is harmful to children. That was 22 years ago, and followed a campaign by Beyond Pesticides and others to remove Dursban/chlorpyrifos from the market because of indoor ambient air contamination of homes and buildings and lawn and landscape exposure. It should be noted that Dursban had been viewed with promise by regulators as the alternative to the organochlorine insecticide chlordane, which Beyond Pesticides sued to remove from the termite use market—a remaining use after the agricultural, lawn, and garden uses were finally taken off the market in 1983, with decades of review by numerous agencies. Its cancer-causing properties and ecological effects could no longer be defended. The cancellation of termite use followed in 1988 after millions of homes were potentially contaminated, with high risk factors for cancer.

It is time to ban all uses of chlorpyrifos.

Thank you.

(Beyond Pesticides, August 27, 2021) On August 24, as reported by The Maui News, the Maui (Hawai’i) County Council approved legislation that will stop use of toxic pesticides and fertilizers in county land management practices, allowing only those materials permitted under federal organic law. The approach set out in the bill is the creation of a comprehensive list of such materials that will be either allowed or prohibited for use, as the legislation indicates, on “any County highway, drainageway, sidewalk, right-of-way, park, building, community center, or other facility.” This decision comes on the heels of years of grassroots work and advocacy, including that of Beyond Pesticides Director of Hawai’i Organic Land Management Program Autumn Ness.

The legislation (CR 21-56), which passed with a vote of 8–0 (with one member excused), will regulate pesticide and fertilizer use on county properties broadly, but will not affect property managed by the state or private owners, county agricultural parks, or county property used for agricultural purposes. The new ordinance will take effect for most county parcels one year from the August 24 approval date; the effective date for Maui’s War Memorial Stadium Complex and Ichiro “Iron” Maehara Baseball Stadium is two years from approval, and for the Waiehu golf course, three years hence.

The legislation sets out the stipulations of the federal National Organic Program (NOP), asserting that no synthetic pesticides and fertilizers may be used unless they are compatible with organic systems as permitted under NOP, with some specific exemptions. (The sections of the federal code cited in the legislation, which detail such compatible materials, are found under the Title 7 Code of Federal Regulations: 205.601, 205.603, 205.605, and 205.606.)

At the county council meeting, community members gave testimony in support of the legislation, citing worries about impacts of synthetic pesticide and fertilizer use on young people who use county sports fields and parks, and about environmental impacts, including those on marine life. (Maui County has numerous oceanfront parcels under its management.) Council Member Shane Sinenci, who introduced the proposed legislation, said of its final passage, “This shows that we are very responsible stewards for our keiki [children], kupuna [ancestors], and the kai [sea].”

At a previous, July 21, meeting of the Council’s Climate Action, Resilience, and Environment (CARE) Committee, members voted 6–0 to recommend the bill, The Maui News reported at the time, moving the legislation forward to consideration by the full council.

At that July committee meeting, the Maui Department of Parks and Recreation spoke in support of working toward “eliminating hazardous substances and using organic alternatives on golf courses, fields and public parks,” noting that beach parks are not currently treated with chemicals. The point was reiterated at the August 24 full council meeting when Chair Alice Lee pointed out that the county and the Department of Parks and Recreation have already been taking steps to reduce pesticides and fertilizers. 

Advocates at the CARE meeting included the Maui Nui Marine Resource Council, Sierra Club–Maui Group, West Maui Green Cycle LLC, and the Napili-based Hawaii Association for Marine Education and Research. These organizations pushed for reduction or full elimination of synthetic pesticides and fertilizers because of their damaging environmental impacts.

Communication and outreach director for the Maui Nui Marine Resource Council, Anne Rillero, said, “We believe that this bill is critical as the county is the owner of numerous coastal properties. . . . It has a responsibility for caring for its lands in a manner that protects the health of our nearshore coral reefs, marine wildlife, water quality, and also for the people who enjoy the ocean — we use it for fishing, recreation, [and] cultural connections.”

In commenting on the CARE Committee’s decision, Beyond Pesticides executive director Jay Feldman said, “We need to stop the use of hazardous chemicals, pesticides, and synthetic fertilizers, and replace them with a different approach. We do not need toxic pesticides to achieve our community goals for aesthetic[s] or safety in the parks, [on] playing fields or sports fields, and along the roadside. We are not talking about product substitution. We are talking about a systems change” — to organic, regenerative approaches to all land management.

Beyond Pesticides has long educated the public and policymakers about the many damaging effects of synthetic chemical pesticide (and petrochemical fertilizer) use in agriculture and other land management. It has also identified the efforts of the agrochemical industry to dominate the marketplace, “greenwash” its toxic products, distort scientific research, compromise the U.S. Environmental Protection Agency (EPA), and push back against pesticide regulation of nearly any kind until economic pressures become so extreme that companies strike deals with EPA to remove a single ingredient from the marketplace.

Industry sometimes creates trade groups and so-called “astro-turf” organizations — those that purport to represent the grassroots, but are in fact industry funded and led, and often have “green” names — to do the sector’s messaging. Sometimes, farmers who have grown conventionally (with chemicals) for decades and have little or no experience with anything else band together and resist pesticide regulation. Mr. Feldman noted, in his August testimony to the Maui County Council, that, “In my experience, those questioning the viability and cost-effectiveness of organic practices typically do not have experience with organic land management. The council can be confident that organic management systems work, whether we are producing food, growing grass, or managing rights of way. Historically, the companies represented by the ‘farm’ groups you’re hearing from in opposition to [CR] 21-56 [maintained that] organic food production was not commercially viable; it is now a $60 billion industry. As a parks manager in Montana said to me last week — whether you’re growing crops or growing grass, managing in sync with the ecosystem is the same.”

Mr. Feldman also offered testimony on CR 21-56 to the full Maui County Council in early August. He emphasized that such regulation is scientifically valid, whether assessed from the perspective of public health impacts, risks to ecological systems, the climate emergency, or the biodiversity crisis — all of which would be mitigated by enactment of this legislation.

Mr. Feldman endorsed the transition to a “whole systems” approach to county land management that this law would launch, saying that it “creates a framework for nurturing desirable plant life in a management system, like the one we developed for the organic transition plan provided to Maui County.” Beyond Pesticides has been working on Mau’i, Kaua’i, and the Big Island, and — with Osborne Organics — has developed organic land management plans for public parks and playing fields. The plans include soil testing (for soil chemistry and soil biology), development of protocols, and training of county landscaping staff.

Autumn Ness, director of Beyond Pesticides Hawai’i organic land management program, commented on passage of CR 21-56 [via personal communication with author]: “This bill has been at least six years in the making. Maui has a very strong grassroots movement of people who have been organizing . . . for years. Maui residents are educated on issues surrounding pesticides, GE [genetically engineered] crops, and the influence of chemical companies in the agriculture and landscaping industries. This grassroots movement has organized around . . . state policies such as the law banning chlorpyrifos in Hawaii in 2018, and around this bill, and is a force working to increase organic agriculture to be a larger part of our island economy. This bill shows that long-term movement building, elections work, [and] collaboration with scientists and organic landscape experts are all essential to long-term systems change. Beyond Pesticides’ support, collaboration, and scientific and technical expertise were a big part of this bill’s success. Beyond Pesticides Hawaiʻi is committed to supporting the Maui County departments in whatever ways necessary, and to continuing our work with Kauaʻi and Hawaiʻi counties as they work on pilot projects and legislation that will protect residents there from pesticide exposures.”

Ms. Ness shared the comment of Kelly King, Chair of the Maui County CARE Committee: “The pesticide ordinance is a great step in reducing the chemical applications in our parks and around county facilities. While I fully understand the challenges in the agricultural sector, we need to take steps where we can to reduce the harmful effects of pesticide residue where it has potential to directly affect our residents — parks and ballfields especially, but also in runoff that is negatively impacting our reefs and natural marine habitats. The ‘inconvenient truth’ is that many of the chemicals and materials (e.g., plastics and Styrofoam [polystyrene]) that were invented to make our lives easier are now being shown to have unintended negative consequences; and, despite the economic interests that are now deeply invested in these products, we must come together for the good of all to rethink our ‘modern practices.’”

Responding to the county council’s August 24 approval of the legislation, Mr. Feldman added, “This legislation represents the most comprehensive restriction of pesticides and synthetic fertilizers on public lands in a major county in the U.S. It represents a clear commitment to the elimination of petroleum-based pesticides and fertilizers and an incredibly important effort to confront the climate crisis, biodiversity collapse, and the protection of the health of workers and communities.”

For the myriad crises the country and world face, and for the benefits that a shift away from chemical land management would confer, Beyond Pesticides advocates for an urgent transition to organic regenerative agriculture and organic land management, and seeks robust federal leadership and planning to achieve this goal. The organization remains steadfast in its mission to reverse the destructive environmental and public health path on which industry interests and compromised federal agencies have set the nation, and to advance the adoption of organic practices and policies that respect the fundaments — the natural resources and dynamics, biological and biochemical processes, and ecosystem interdependency that allow and support all life.

Sources: https://www.mauinews.com/news/local-news/2021/08/pesticides-and-fertilizers-to-be-reduced-and-managed/, https://www.mauinews.com/news/local-news/2021/07/bill-would-regulate-pesticide-use-on-maui-county-property/, and author’s personal communication with Beyond Pesticides Executive Director Jay Feldman, and Beyond Pesticides Director of Hawai’i Organic Land Management Program Autumn Ness

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

(Beyond Pesticides, August 26, 2021) A recent study published in Environmental Research demonstrates that exposure to the herbicide glyphosate and its breakdown product reduces pregnancy length, increasing the risk of preterm birth. Preterm births occur when a fetus is born early or before 37 weeks of complete gestation. Premature births can result in chronic (long-term) illnesses among infants from lack of proper organ development and even death.

Birth and reproductive complications are very common among individuals exposed to environmental toxicants, like pesticides. Considering the Center for Disease Control (CDC) reports the preterm birth rate is increasing annually, studies like this can help government and health officials safeguard human health by assessing adverse health effects following prevalent chemical exposure. The study notes, “Given the prevalent and rising exposures to glyphosate and GBHs [glyphosate-based herbicides], confirmatory studies are needed to explore reproductive effects of glyphosate and GBHs to re-assess their safety on human health and to explore possible programming consequences to lifelong health.”

GBHs are the most commonly used herbicides, readily contaminating soil, water, and food globally. Although GBHs’ ubiquitous nature has been linked to carcinogenic effects, specifically non-Hodgkin lymphoma, much less research considers exposure effects on reproductive health. The study’s scientists aimed to examine the relationship between prenatal glyphosate exposure and pregnancy length. During the second trimester, researchers gathered urine samples from 163 pregnant American women in The Infant Development and the Environment Study (TIDES). They measured each sample for concentrations of glyphosate and the primary metabolite (breakdown product), aminomethylphosphonic acid (AMPA).

The results demonstrate that 94 percent of all urine samples contain detectable amounts of glyphosate and AMPA. Of the 163 participants, 69 gave birth prematurely, with almost 53.6 percent being spontaneous deliveries (unassisted vaginal births), 40.6 percent medically induced, and 5.8 percent unclassifiable. Maternal glyphosate and AMPA levels associated with shorter gestation, or pregnancy length, are significantly higher among women giving spontaneous premature births.

Almost five decades of extensive glyphosate-based herbicide use (e.g., Roundup) 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 the U.S. Environmental Protection Agency (EPA) classifies glyphosate herbicides as “not likely to be carcinogenic to humans,” stark evidence demonstrates links to various cancers, including non-Hodgkin lymphoma. EPA’s classification perpetuates adverse impacts especially among vulnerable individuals, like pregnant women and infants. Recent research detects over 100 chemicals in pregnant women’s bodies, with 89% of compounds of unknown origin or lacking adequate data. Many of these environmental pollutants (i.e., heavy metals, polychlorinated biphenyl, and pesticides) are chemicals that can move from the mother to the developing fetus at higher exposure rates. Hence, prenatal exposure to these chemicals may increase the prevalence of birth-related health consequences like natal abnormalities and learning/developmental disabilities. With the range of ever-present environmental hazards, advocates argue that regulators act quickly and embrace a precautionary approach. Because of disproportionate risk in people of color communities, the contamination and poisoning associated with glyphosate is an environmental justice issue.

Not only do health officials warn that continuous use of glyphosate will perpetuate adverse health effects, but that use also highlights recent concerns over antibiotic resistance. Agrochemical company Bayer/Monsanto patents glyphosate as an antibiotic. Exposure hinders enzymatic pathways in many bacteria and parasites. However, studies find glyphosate exposure disrupts the microbial composition in both soil and animals—including humans—discerningly eliminating beneficial bacteria while preserving unhealthy microbes. Moreover, resistance to pesticides is also growing at similar rates among genetically engineered (GE) and non-GE conventionally grown crops. This increase in resistance is evident among herbicide-tolerant GE crops, including seeds genetically engineered to be glyphosate-tolerant. Although one industry-stated purpose of GE crops is to reduce pesticide use, crops have become more pesticide-dependent, resulting in increased weed and insect resistance. Therefore, the use of antibiotics like glyphosate allows residues of antibiotics and antibiotic-resistant bacteria on agricultural lands to move through the environment, contaminate waterways, and ultimately reach consumers in food. Both human gut and environmental contamination can promote antibiotic resistance, triggering longer-lasting infections, higher medical expenses, and the inability to treat life-threatening illnesses.

Glyphosate-based herbicides’ impact on reproductive health is an increasingly common phenomenon, and this study adds to the growing scientific evidence that glyphosate is a reproductive toxicant. A recent University of Michigan study already demonstrates high levels of glyphosate in urine during the third trimester of pregnancy have significant associations with preterm birth outcomes. In 2017, Beyond Pesticides reported that prior research finds detectable levels of glyphosate in 63 of 69 expectant mothers. Women with higher chemical levels have significantly shorter pregnancies and babies with lower birth weights. While studies are now findings concerning associations, there has been evidence of glyphosate’s impact on birth outcomes for decades.

Despite external exposure to glyphosate being lower than regulatory limits, the study finds exposure remains widespread among the general U.S. population. Ubiquitous exposure is concerning as increasing evidence suggests current EPA regulatory limits may not be safe for human health. The study suggests that glyphosate-inducing oxidative stress and uterine inflammation are the biological mechanisms that play a role in preterm births. Biomarkers for oxidative stress and inflammation have associations with preterm births and shorter pregnancy duration. Furthermore, recent studies demonstrate glyphosate is an endocrine disruptor and thus warrants a re-evaluation of safety to protect human health, particularly among vulnerable populations. While laboratory evidence (most often produced by the chemical manufacturers themselves) may indicate associations with birth abnormalities, it is all too easy for regulators to hide behind risk and chance. Substantial epidemiological data is building for birth abnormalities as it has now been for cancer effects. Regulators are adamant that label changes will avert these dangers or even that the risks are too low for any action at all. However, regulators at EPA lean on risk calculations, which advocates say subvert their responsibility to protect the public.

Bayer announced the removal of glyphosate from all “residential” lawn and garden products sold in the U.S. by 2023. However, no changes are to come for professional and agricultural products that constitute most GBH use. It is still unclear whether Bayer’s cancellation announcement will affect only the residential do-it-yourselfer or all applications to residential areas. Therefore, researchers caution, “Future studies may benefit from assessing exposure at multiple time points. However, continuous exposure could occur in the general population because diet is the most likely source of glyphosate.”

Beyond Pesticides challenges the registration of chemicals like glyphosate in court due to their impacts on soil, air, water, and our health. While legal battles press on, the agricultural system should eliminate the use of toxic synthetic herbicides to avoid the myriad of problems they cause. In the absence of protective regulations from the widespread use of pesticides like glyphosate, U.S. residents, particularly vulnerable populations like pregnant mothers, should take precautions. One important step can be switching to organic. Organic agriculture is necessary to eliminate toxic chemical use and ensure the long-term sustainability of food production, the environment, and the economy. Organically managed systems support biodiversity, improve soil health, sequester carbon (which helps mitigate the climate crisis), and safeguard surface- and groundwater quality. Moreover, considering glyphosate levels in the human body reduces 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.

Learn more about how purchasing and consuming organic products can reduce pesticide exposure and the harmful health and environmental impacts of chemical-intensive farming produces. Additionally, learn more about the effects of pesticides on human health by visiting Beyond Pesticides’ Pesticide-Induced Diseases Database. This database supports the clear need for strategic action to shift away from pesticide dependency. Find out more about how organic is the right choice for both consumers and farmers by visiting Beyond Pesticides’ webpages on Health Benefits of Organic Agriculture and Keeping Organic Strong.

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

Source: Environmental Health News, Environmental Research

(Beyond Pesticides, August 25, 2021) Scientists at Oregon State University have found a highly effective bait for slugs and snails: bread dough. Although not quite as exciting as the slug-liquefying nematodes the OSU research team published data on last year, bread dough has the potential to revamp mollusk management, particularly in developing countries where resources are limited. “Bread dough is a nontoxic, generic, and effective tool that could be used in the detection and management of gastropods worldwide,” said study lead author Rory Mc Donnell, PhD. “It represents a tool to aid in managing pest gastropod infestations, either using baited traps or in attract-and-kill approaches. It could also be incorporated into existing baits to improve their attractiveness.”

Critically, bread dough was found to be a more effective bait than commercial attractants like the product Deadline® M-Ps™, which contains the hazardous compound metaldehyde. To test effectiveness, researchers began by making the bread dough using a combination of flour, water and yeast. In a lab setting, slugs were starved for 24 hrs, and then given the option of either bread dough or water (water was used as a control to test if the slugs were simply attracted to humidity). Researchers determined through this trial that slugs were most attracted to bread dough aged between 2 and 8 days.

A similar setup compared the attractiveness of bread dough against Deadline® M-Ps™ using the common garden snail C. aspersum. Of 20 slugs tested, 14 went for the dough, three went for the commercial bait, while three were unresponsive. Field trials were then established to determine real world efficacy. The traps employed, including the Snailer, which allows entry but bars exist, as well as a simple Petri dish, were loaded with bread dough, and a liquid form of metaldehyde was added to the bottom. A control using water and liquid metaldehyde was also used. Slugs and snails overwhelmingly chose to feed on the bread dough baited traps. At one site, on mining reclamation land infested with the land snail X. obvia, researchers were able to trap over 18,000 over the course of two days. Only roughly 850 snails were collected in control bait.

“We gave them a choice of food and they consistently went for the bread dough,” Dr. Mc Donnell said. “They really, really like it. They went bonkers for it. Bread dough outperformed everything.” Although researchers used toxic metaldehyde to kill slugs when they got to the bait, discretely located traps can ensure that a pesticide is not used in a broadcast manner and disposed of properly. However, many traps and baits, such as the Snailer, will work with bread dough and water without the need for additional pesticide, as they bar pests from exiting and cause the slug or snail to drown. Use of metaldehyde should generally be discouraged as the chemical is a suggestive carcinogen, with evidence of neurotoxicity, kidney and liver damage, and reproductive harm. Although the National Organic Program permits the use of the iron phosphate in slug and snail control, its efficacy relies on a synergy between iron phosphate and a so-called “inert” ingredient known as EDTA. In 2014, Beyond Pesticides called on the National Organic Standards Board to delist iron phosphate slug products due to the risks EDTA poses to soil organisms, as well its ability to contaminant soil, sediment and local waterways.

Beyond these concerns lies the fact that current data shows that common commercial slug-control products only kill between 10% to 60% of slugs in a given population. Efficacious biological controls are on the horizon, and have long been registered in Europe, but their cost is often quite high as to be prohibitive for many farmers. Bread dough thus provides a near universally available bait for farmers and gardeners around the globe.  

“With worldwide trade and travel, we are getting a homogenization of slugs and snails on planet Earth because of the widespread introduction of species,” Dr. Mc Donnell said. “This is not just a modern phenomenon. Slugs and snails have been traveling with humans for thousands of years. But it’s getting more severe because of purposeful introductions, global trade, intensification of agriculture and development of new crops.”

Managing slugs can be frustrating and often stomach churning. Cultural practices can help get a handle on slug populations, but some form of direct control is often needed. If slugs are suspected of causing crop damage, populations should be regularly monitored using a baiting system. Work to reduce moisture and consider the type of mulch that is being applied. Never water at night, and consider tactics like drip irrigation in particularly damp, slug-prone areas. Hand-picking slugs out of the garden with a disposable glove and placing them into soapy water is one of those stomach-churning activities associated with a slug infestation, but an effective way to reduce populations in a garden. Domestic foul can be helpful at lowering slug populations but need to be closely monitored around growing crops.

See Beyond Pesticides ManageSafe webpage on least toxic control of snails and slugs for more information about how to address these pests without toxic pesticides.

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

Source: Oregon State University, MDPI

(Beyond Pesticides, August 24, 2021) Organic agriculture provides multiple ecosystem functions and services at greater economic benefit to farmers than conventional, chemical-intensive cropping systems, according to research recently published in the journal Science Advances. The study, conducted by a team of scientists based in Switzerland, goes beyond farming evaluations based solely on ecosystem services to include socioeconomic elements. “We did this because agroecosystems also have a socioeconomic dimension for producers and policy makers,” the authors note. While it is unsurprising based on prior research that organic practices provide greater environmental and economic benefits, the study lays bare the true cost of policies that myopically focus on yield while ignoring other factors.

Researchers conducted their study using data derived from a long-running Farming System and Tillage Experiment (FAST) based in Switzerland. FAST tracked four types of cropping systems: conventional intensive tillage, conventional no tillage, organic intensive tillage, and organic reduced tillage. Cropping systems were evaluated based on four broad categories, including provisioning (ie food production), regulating (ie water, air, and soil management), and supporting (ie biodiversity and soil health) ecosystem services, as well as socioeconomic well-being. These categories were subsequently broken down into nine assessments: soil health preservation, erosion control, biodiversity conservation, water and air pollution control, food production, income, work efficiency, and financial autonomy.

Organic farming significantly increased soil health preservation and erosion control when compared to intensively tilled conventional systems. These benefits were   primarily seen in the organic reduced tillage approach, highlighting the benefits of that practice. Researchers found that yields dropped from conventional to organic systems, although differences were seen between particular crops – with less pronounced disparities between legume crops compared to corn. Organic systems also resulted in higher income, due to the higher price organic products command in the marketplace.

In general, researchers see the greatest differences between the conventional intensive tillage and organic reduced tillage systems. Both of these cropping systems have pronounced trade-offs. High productivity is negatively associated with supporting services like soil health and biodiversity conservation. Supporting and regulating services, however, are strongly associated with each other. For example, good soil management interacts with greater soil diversity to foster improved soil health.

The study provides a tool (located here: https://apps.agroscope.info/sp/fast) for researchers and policymakers to employ to review how emphasis on different ecosystem services or economic factors effect the trade offs that result on the ground.

Scientists note that although there is a tradeoff between productivity and environmental benefits, focus has been traditionally placed on productivity because the hazards conventional agriculture poses to the environment are often not considered, and generally externalized to society at large. The authors note that policy changes can help fill this gap – explaining that direct payments to farmers can help compensate them for reductions in yield while other ecosystem services improve.

It is evident that agriculture that is solely focused on yield is unsustainable. While negatively impacting a range of environmental factors that can affect harvests in the long term, conventional chemical cropping systems nonetheless do not provide a better economic outlook for farmers.  

Past research shows that organic farming can help address economic insecurity, the climate crisis, and public health disparities. In organic hotspots, considered counties with high levels of organic agricultural activity whose neighboring counties also have high organic activity, median household incomes are $2,000 higher than average and poverty levels are lower on average by 1.3%.

Organic agriculture can and must feed the world. But it is also critical that organic standards maintain the beneficial practices that continue to protect ecosystems and the critical services that provide for humanity. Act today to tell USDA to ensure that organic farming protects native ecosystems.

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

Source: Science Advances

(Beyond Pesticides, August 23, 2021) “Biopesticides”—widely regarded as an alternative to chemical pesticides and hence given a special status in regulation—need a better definition. “Biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term can be misleading and mixes contradictory approaches. It is troublesome when we continue to look for product replacements or substitutions for agricultural practices that are clearly ineffective, and in the process avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions.

The U.S. Environmental Protection Agency (EPA) uses the following definition for “biopesticides”:

• Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals);
• Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient;
• Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce.

Tell EPA it’s time to redefine “biopesticide.” It is deceptive and misleading. The definition should not include genetically modified organisms or synthetic analogs of naturally occurring biochemicals.

EPA requires much less data to register a biopesticide and registers it in much less time. There are currently 390 biochemical and microbial active ingredients registered as biopesticides and 34 PIP active ingredients. In effect, EPA encourages their use by regulating them less stringently, characterizing them in the following ways: (i) they are “usually inherently less toxic,” (ii) that they “generally affect only the target pest and closely related organisms,” (iii) that they “often are effective in very small quantities and often decompose quickly,” and (iv) that “used as a component of Integrated Pest Management (IPM) programs, biopesticides can greatly reduce the use of conventional pesticides” [emphasis added]. The broad category “biopesticides” and waffle words used by EPA reflect hidden hazards.

For example, PIPs are certain to result in pesticide resistance because they are incorporated into plant tissue, thus exposing insects to the pesticide regardless of whether the plant is under serious attack. These certainly should not be part of IPM because their use is prophylactic. The vast majority of PIPs incorporate Bacillus thuringiensis, which has resulted in widespread resistance to a relatively innocuous biological insecticide, making it unusable as a rescue treatment. PIPs occur throughout the plant, resulting in broad exposure—principally to livestock, but sometimes to humans—to not only the active ingredient, but the “genetic material necessary for its production.” Little is known about the persistence of these genetic bits in the environment, nor what their impacts on ecosystems might be.

With less data required, we have less information concerning potential hazards of biopesticides. Besides genetically engineered organisms, these include synthetic analogues of naturally occurring biochemicals. Synthetic pheromones have effects on human health that depend on the application method, “inert ingredients,” and retrieval/disposal. In addition, only a small fraction of known insect pheromones (which have effects that are mimicked by commercially available synthetic pheromones) have been thoroughly examined for their toxic or other pharmacological effects on non-target (including mammalian) species. Pheromones as used in pest management are synthetic analogs of parts of the pheromones found in nature. Because they lack the complexity of natural pheromones, they also lack the specificity of those pheromones. Thus, some pheromone products designed to disrupt the mating of pest insects can affect the behavior of many non-pests. In addition, microencapsulated pheromones may be a hazard to honeybees.

Some bioprotectant products may be ecologically sound and nontoxic; indeed, some fungi appear to hold great promise. Despite the lack of specificity, pheromone products have permitted growers to avoid the use of more toxic controls. They can be used in a way that complements alternative pest management methods, but synthetic analogs must be fully tested.

Tell EPA it’s time to redefine “biopesticide” and remove genetically modified organisms from this category. It is deceptive and misleading. Synthetic analogs of naturally occurring biochemicals should not be included in the definition.

Letter to EPA Administrator Michael Regan

“Biopesticides” are widely regarded as an alternative to chemical pesticides and hence given a special status in regulation. However, “biopesticide” is generally poorly understood, and defined differently by various entities and stakeholders. The term is misleading in that it does not, as defined by EPA or others, denote a group of materials that naturally produced. It is also troublesome to encourage product replacements or substitutions and, in the process, avoid the changes necessary to transition to organic practices, which represent the real, long-term solution to concerns among chemical-intensive farmers that they are losing pesticides in their arsenal, either to organism resistance or regulatory restrictions.

The U.S. Environmental Protection Agency (EPA) includes as “biopesticides”:

1) Substances that interfere with mating, such as insect sex pheromones, as well as various scented plant extracts that attract insect pests to traps (and synthetic analogs of such biochemicals);

2) Microbial pesticides consisting of a microorganism (e.g., a bacterium, fungus, virus or protozoan) as the active ingredient;

3) Plant-Incorporated-Protectants (PIPs), pesticidal substances that plants are genetically engineered to produce.

EPA requires much less data and time to register a biopesticide. In effect, EPA encourages their use by regulating them less stringently, characterizing them in the following ways: (i) they are “usually inherently less toxic,” (ii) that they “generally affect only the target pest and closely related organisms,” (iii) that they “often are effective in very small quantities and often decompose quickly,” and (iv) that “used as a component of Integrated Pest Management (IPM) programs, biopesticides can greatly reduce the use of conventional pesticides.” The broad category “biopesticides” and waffle words used by EPA reflect hidden hazards.

For example, PIPs are certain to result in pesticide resistance because they are incorporated into plant tissue, thus exposing insects to the pesticide regardless of whether the plant is under serious attack. These certainly should not be part of IPM because their use is prophylactic. The use of PIPs incorporating Bacillus thuringiensis has resulted in widespread resistance to a relatively innocuous biological insecticide, making it unusable as a rescue treatment. PIPs occur throughout the plant, resulting in broad exposure—principally to livestock, but sometimes to humans—to not only the active ingredient, but the “genetic material necessary for its production.” Little is known about the persistence of these genetic bits in the environment, nor what their impacts on ecosystems might be.

With less data required, we have less information concerning potential hazards of biopesticides. Besides genetically engineered organisms, these include synthetic analogs of naturally occurring biochemicals. Only a small fraction of known insect pheromones (or the synthetic analogs in commercially available synthetic pheromones) have been thoroughly examined for their toxic or other pharmacological effects on non-target species. Pheromones as used in pest management lack the complexity and specificity of natural pheromones. Thus, some pheromone products designed to disrupt the mating of pest insects can affect the behavior of many non-pests. In addition, microencapsulated pheromones may be a hazard to honeybees.

Some bioprotectant products may be ecologically sound and nontoxic. Indeed, some fungi appear to hold great promise. Despite the lack of specificity, pheromone products have permitted growers to avoid the use of more toxic controls and can complement alternative pest management methods, but synthetic analogs must be fully tested.

It’s time for EPA to redefine “biopesticide.”  It is deceptive and misleading. The definition should not include genetically modified organisms or synthetic analogs of naturally occurring biochemicals.

Thank you.

(Beyond Pesticides, August 20, 2021) The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) has issued a damning report on the agency’s progress in protecting the population from potentially damaging endocrine disruption impacts of exposures to synthetic chemical pesticides (and other chemicals of concern). The report’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” This OIG report identifies and details the failings that Beyond Pesticides covered in an April 2021 Daily News Blog article, and many more — the net of which is that “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.”

The OIG report chronicles a litany of failures. It finds that EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP), which is responsible for testing all pesticide chemicals for endocrine disrupting activity in humans, has failed to do so. Specifically, it has not implemented a section of the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by the 1996 Food Quality Protection Act — the legislation that requires such testing. In addition, the report states that OCSPP’s Office of Pesticide Programs (OPP) has not implemented a 2015 recommendation that 17 pesticides undergo additional testing for endocrine disruption (ED) in wildlife so that an ecological risk assessment could be effectively conducted.

The report indicates that EPA has not created the tools (e.g., strategic guidance documents or performance measures) necessary to implement effectively the agency’s Endocrine Disruptor Screening Program (EDSP), created in 1998. According to the report, EDSP has not “conducted annual internal program reviews to monitor or assess progress in fulfilling regulatory requirements, and the EDSP has not effectively communicated with internal and external stakeholders. Moreover, previous OCSPP leadership provided acceptable corrective actions to meet the recommendations in a 2011 EPA Office of Inspector General report regarding the EDSP, yet failed to actually implement those corrective actions beyond an initial period of compliance with them. Lastly, some EPA staff indicated that they were instructed to function as if the EDSP was eliminated from the EPA’s budget. Because the EDSP has not had effective internal controls in place since 2015, it cannot have reasonable assurance that the objectives of the program will be accomplished and that resources will be allocated efficiently and effectively. ”

The human body’s endocrine system, comprising a variety of glands and the hormones they produce, is responsible for the activation, regulation, and de-activation of a huge variety of functions in, especially, development, reproduction, growth, metabolism, the cardiac and circulatory system, sleep, mood, and behavior, among others. The hormones secreted by the endocrine glands travel through the bloodstream to various organs and tissues, where they communicate critical regulatory messages.

The ingredients in many pesticides (and in many consumer products) act as endocrine disruptors in humans and other animals in several ways. They may: (1) mimic actions of hormones the body produces (e.g., estrogen or testosterone), causing reactions similar to those generated by the naturally produced hormones; (2) block hormone receptor cells, thereby preventing the actions of natural hormones; or (3) affect the synthesis, transport, metabolism, and/or excretion of hormones, thus altering the concentrations of natural hormones in tissues or at receptor sites. (See a Beyond Pesticides primer on pesticides and ED here.)

As the OIG report notes, “Small disturbances in endocrine function, particularly during certain highly sensitive stages of the life cycle, such as pregnancy and lactation, can lead to profound and lasting effects. Adverse endocrine-related effects in humans may include breast cancer, diabetes, obesity, infertility, and learning disabilities.” Beyond Pesticides would add to that list both direct and indirect implications of ED chemicals, such as other cancers, Parkinson’s disease, multiple reproductive disorders and anomalies (e.g., polycystic ovary syndrome, testicular dysgenesis syndrome, endometriosis, and reduced sperm count), alteration of the gut biome and resultant dysfunction, and metabolic disorders apart from diagnosable diabetes.

See Beyond Pesticides’ Pesticide-Induced Diseases Database’s ED page devoted to diseases and disorders associated with exposures to ingredients in endocrine-disrupting pesticides and in consumer products, such as plastics, disinfectants, linings of canned food containers, toys, cosmetics, flame retardants, detergents. Given the omnipresence of such compounds in pesticides and in the materials stream broadly, exposures to ED chemicals can be frequent and even chronic.

In 2017, Europe’s Pesticide Action Network refined an earlier estimate by the European Union that more than 50 pesticide active ingredients operate as endocrine disruptors. (That earlier list included those identified by TEDX, The Endocrine Disruption Exchange, which was launched by pioneering ED scientist Theo Colborn, PhD.) The update short-listed 37 pesticides of ED concern out of the nearly 500 on the market in Europe in 2015. In 2009, EPA created an EDSP “List 1” of 67 pesticides and “high production volume chemicals” used as pesticide inert ingredients that the agency deemed should be evaluated first for ED impacts. (EPA later reduced this list to 52 chemicals because 15 were subsequently canceled or discontinued.)

EPA’s EDSP uses a tiered testing process. Tier 1 Screening (which looks at high-exposure chemicals) aims to determine if a chemical could interact with the estrogen, androgen, and/or thyroid pathways, the three hormonal pathways in the body’s endocrine system. Tier 2 testing attempts to determine whether a chemical causes adverse effects, and to establish a dose–adverse response metric. EPA has decided that Tier 1 Screening results are insufficient to implicate a chemical as an endocrine disruptor — even when results show that a chemical can or does interact with the endocrine system. But Tier 1 results do determine which chemicals move on to Tier 2 testing — the results of which can influence regulatory decision making.

On this front, the OIG report says, “The OCSPP has not implemented Section 408(p)(3) of the FFDCA to test all pesticide chemicals for endocrine-disruption activity. In June 2015, the EPA recommended that 18 pesticides from List 1 needed additional Tier 2 testing. As of early 2021, the OCSPP has not issued any List 1–Tier 2 test orders for wildlife studies and has only issued test orders for two pesticides for human health studies. Likewise, although the EPA developed and published List 2 with 109 chemicals, the EPA did not issue any List 2–Tier 1 test orders. As a result, the EPA has not made meaningful progress in meeting its statutory obligation to test all pesticide chemicals for endocrine-disruption activity.” The report adds, pointedly, “Endocrine Disruptor Screening Program testing delays are inconsistent with the Federal Food, Drug, and Cosmetic Act, which directs the EPA to take appropriate action to protect public health if a substance is found to have an effect on the human endocrine system.”

Clearly, ED testing has been profoundly stalled. The report indicates that EPA failed to meet a directive from the House Appropriations Committee to publish a List 2 by October of 2010. In reality, the agency did so two and a half years after the deadline (in June 2013). Another directive — to issue, beginning in 2011, 25 test orders per year from List 2 — has been ignored: as of February 2021, EPA had not issued any List 2 / Tier 1 test orders. According to the OIG, responses from OPP staff laid the blame for this faulty record on a lack of overall support and direction for the EDSP from previous OCSPP leadership.

That explanation would appear to comport with some of the evidence unearthed by Sharon Lerner and reported in her The Intercept article, “Whistleblowers Expose Corruption in EPA Chemical Safety Office.” The article evinced not only laxity and managerial allegiance to industry interests, but also, downright corruption on the part of some managers at EPA. Beyond Pesticides reported the comment of Tim White, executive director of PEER (Public Employees for Environmental Responsibility, “It will take new EPA Administrator Michael Regan, [MPA], new Assistant Administrator for Chemical Safety and Pollution Prevention Michal Ilana Freedhoff, [PhD], and Congress to remedy the culture . . . and to rebuild both the science staff at EPA (which was severely eroded during the Trump administration), and the agency’s morale and culture, which were also badly damaged. He noted that as one of his first acts, Administrator Regan issued a memorandum outlining concrete steps to reinforce EPA’s commitment to science.”

The OIG report also cites EPA for: (1) not having adequate internal controls (e.g., strategic guidance documents or performance measures re: meeting statutory requirements) in place to ensure effective program implementation of the EDSP; (2) having conducted no internal review on progress in meeting the dictates of FFDCA; and (3) having no strategic planning document that makes priorities clear or guides program activities. It adds that EDSP needs to improve communication with stakeholders, both internal and external.

The report concludes: “In 1996, Congress directed the EPA to establish the EDSP, and the program received approximately $7.5 million in funding in fiscal year 2021. Yet, the EDSP can show only limited results. Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.”

The OIG report issued a series of 10 recommendations, directed to OCSPP Assistant Administrator Freedhoff, that address:
• tiered testing for ED impacts

• timelines for such testing
• strategic planning
• development of performance metrics
• improved communication, including to the public
• internal program review
• improved transparency

The report adds that EPA “generally agreed with our recommendations and provided acceptable corrective actions and estimated completion dates for all ten recommendations. The recommendations are considered resolved with corrective actions pending. We also revised our report where appropriate based on technical comments provided by [EPA].”

A response letter (included in the report) from Dr. Freedhoff confirms that OCSPP is in “general agreement with the 10 recommendations in the Draft Report regarding the Endocrine Disruptor Screening Program.” She outlined several change initiatives, including development of a Strategic Plan and a new organizational structure to ensure management accountability for the EDSP. She also acknowledges “the challenges faced by the EDSP in the past, including efforts from previous OCSPP leadership to not fully implement the EDSP and its funding,” but also pushes back somewhat on the charge of not making “meaningful progress in meeting [EPA’s] statutory obligation to test all pesticides for endocrine-disruption activity.”

Dr. Freedhoff identifies several achievements in that realm, although the items she proffers in her response are not dated, making it difficult to understand which, if any, of the actions she cites might be recent (as opposed to several years old). She did note that EPA has directed considerable effort and funding, over the past decade, to development of NAMs — New Approach Methods for testing chemicals for ED potential that are faster and more efficient, and that provide “more human-relevant and mechanistically driven data for use in the evaluation of estrogen, androgen, and thyroid bioactivity.” She wrote that she and OPP leadership are working on a transition of EDSP so as to make it more responsive, timely, and accountable.

Beyond Pesticides summed up the situation in a recent Daily News Blog that also advocated for members of the public to weigh in with EPA. “EPA is stalled and ignoring its responsibility. EPA now issues Proposed Interim Decisions (PIDs) on pesticide registrations [with] . . . no human health or environmental safety findings associated with the potential for endocrine disruption, or [without] identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption. In the absence of such findings, EPA must cancel and suspend the registration of each pesticide lacking data or findings. Please ensure that your agency meets its responsibility to protect the health of people and wildlife.” EPA must do better.

See While France Bans a Common Endocrine Disrupting Pesticides, EPA Goes Silent: EPA ignores statutory mandate to review pesticides that cause deadly illnesses at minute doses, defying classical toxicology.

Source: https://www.epa.gov/system/files/documents/2021-07/_epaoig_20210728-21-e-0186.pdf

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

(Beyond Pesticides, August 19, 2021) Does a science-based, public health-oriented, occupational safety focused, children-concerned, ecologically protective society allow the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? Should victims of poisoning have to plead with regulators to protect them? Should organizations have to fight chemical-by-chemical to achieve basic levels of protection from individual neurotoxic, cancer causing, endocrine disrupting pesticides? Of course not. But, the U.S. Environmental Protection Agency’s (EPA) announcement that it is stopping food uses of the insecticide chlorpyrifos after being registered 65 years ago provides us with an important opportunity for reflection, not just celebration. The collective effort to remove this one chemical is a tremendous feat in eliminating one exposure to a hazardous material for children. That is the point. The action we’re celebrating required an amazingly resource-intensive effort at a time in history when we are running against the clock in an urgent race to transition our society and global community away from the use of petroleum-based, toxic pesticides—to move to meaningful practices that sustain, nurture, and regenerate life.

In this context, let’s put chlorpyrifos in perspective. EPA was forced into its decision by a court order that was precipitated by an agency decision to reverse course after proposing to stop food uses of chlorpyrifos in 2017. Despite a mountain of scientific data challenging chlorpyrifos’s safety, it was embraced by industrial agriculture, the golf industry, and others, and deemed too valuable to the bottom line of its manufacturer, Corteva (formerly Dow AgroSciences). Pesticide manufacturers are also motivated to steer EPA away from adverse health and environmental effects findings on their products in order to avoid potential litigation by those harmed. The U.S. Court of Appeals for the 9th Circuit in San Francisco in its ruling in May, 2021, in which it mandated EPA action, said, “The EPA has had nearly 14 years to publish a legally sufficient response to the 2007 Petition [filed by environmental and farmworker groups].” The court continued, “During that time, the EPA’s egregious delay exposed a generation of American children to unsafe levels of chlorpyrifos.”

But before all the recent activity, in 1999, EPA had negotiated a compromise with Dow that stopped most residential uses of chlorpyrifos. Why? For the same reason that EPA finally acted on food. This neurotoxic chemical is harmful to children. That was 22 years ago, and followed a campaign by Beyond Pesticides and others to remove Dursban/chlorpyrifos from the market because of indoor ambient air contamination of homes and buildings and lawn and landscape exposure. It should be noted that Dursban was viewed with promise by regulators as the alternative to the organochlorine insecticide chlordane, which Beyond Pesticides sued to remove from the termite use market—a remaining use after the agricultural, lawn, and garden uses were finally taken off the market in 1983, with decades of review by numerous agencies. Its cancer-causing properties and ecological effects could no longer be defended. The cancellation of termite use followed in 1988 after millions of homes were potentially contaminated, with high risk factors for cancer.

With all this as context for the chemical treadmill, next up after chlorpyrifos may be the insecticide bifenthrin. It too is a neurotoxic, cancer-causing, endocrine disrupting pesticide. And if that is not enough, there are others waiting in the wings. The picture is clear.

Even in a victory, like EPA’s chlorpyrifos decision, the action is typically filled with exceptions that respond to vested interests seeking to ignore or deflect the science. With chlorpyrifos, EPA, since announcing its decision in 1999 to ban “residential” uses of chlorpyrifos, continues to allow the following uses: (i) Residential use of containerized baits; (ii) Indoor areas where children will not be exposed, including only ship holds, railroad boxcars, industrial plants, manufacturing plants, or food processing plants; (iii) Outdoor areas where children will not be exposed, including only: golf courses, road medians, Industrial plant sites; (iv) Non-structural wood treatments including: fenceposts, utility poles, railroad ties, landscape timers, logs, pallets, wooden containers, poles, posts, and processed wood products; (v) Public health uses: Fire ant mounds (drench and granular treatment); (vi) nurseries and greenhouses; and (vii) Mosquito control. These uses are unaffected by EPA’s announcement yesterday.

Corteva’s statement prior to the EPA announcement was predictable, as the company and the chemical industry generally pushes pesticide dependency: “Chlorpyrifos is a critical pest management tool used by growers around the world to manage many pests. . . We will continue to support the growers who need this important product.” Similarly, the pesticide industry’s partner, the Golf Course Superintendents Association, stated, “Chlorpyrifos is a vital tool for controlling damaging pests on golf courses.” These are self-serving statements because the industry’s products create ongoing product dependency by focusing on killing organisms and life in the soil, rather than preventing pest problems with cultural practices and soil supplements that work in concert with nature and create resiliency.

In the absence of a functional federal system that sticks to the science in an effort to protect public health and the environment, states have intervened to fill the void. The pattern with chlorpyrifos is not any different than the history of state intervention on chemicals like DDT, 2,4,5-T, Ethylene Dibromide, and numerous others, where states have acted to curtail specific pesticide use, in some cases years ahead of EPA. Hawaii, New York, Maryland, and Maine all acted to different degrees to restrict chloroyrifos in advance of EPA. 

In response to the Maine chlorpyrifos ban in June, 2021, Rick Deadwyler, a lobbyist with Corteva AgriScience, was quoted as saying that studies “have shown that current uses of chlorpyrifos meet the U.S. regulatory standard of a “reasonable certainty of no harm.” Therein lies the systemic problem. EPA is subject to a standard (spelled out in the law’s legislative history or report language) that utilizes a risk assessment process that determines reasonableness. That standard has enabled the agency to assume the need for the chemical and adopt self-described protections from exposure that do not reflect reality. In so doing, EPA applies margins of safety that are meaningless, or simply ignores mechanisms like synergism, the effect of mixtures, or a lack of information on health outcomes (like endocrine disruption, for which the agency has not established review protocol). To make matters worse, the reasonable certainty of no harm standard only applies to pesticides that have agricultural uses, while those pesticides with only non-agricultural uses are subject to an “unreasonable adverse effects” standard. In this case, EPA does not evaluate the necessity of pesticides in light of the availability of less or nontoxic alternative practices or products. When safer alternatives exist, is it reasonable to allow exposure to a hazardous pesticide with known adverse effects and the large uncertainties that are inherent to risk assessments?

Local governments are intervening to stop toxic pesticide use on their public lands and, in cases where they are not preempted by state law, on private property. The nationwide momentum is leading the nation from the grassroots in proving that toxic pesticides and fertilizers are not necessary in land management.

The history of chlorpyrifos is a shining example of the failure of pesticide law and policy, which has set a course for the nation that is inherently destructive of life. The good news is that we have the tools to course correct at a time when pesticides, like chlorpyrifos, not only have direct adverse health effects but are contributing to the climate crisis, biodiversity collapse, and disproportionate levels of illness in people of color communities.

Let’s collectively congratulate all who worked on exposing the societal failure of pesticide law, policy, and use in fighting agricultural uses of chlorpyrifos. We can and must use this occasion as an example of the abject failure of the current system and advance systemic change that rejects toxic pesticides and moves society to the adoption of organic practices. This will take a concerted effort that rejects the chemical-by-chemical approach to reform, which at the current pace will not meet the urgency of the existential crises that we face as a nation and globe. The solution is within our grasp. We know how to manage agricultural production, land spaces, and buildings without toxic chemicals. Reform legislation in Congress must meet the urgent need to make this a transformational moment. This is our charge.

(Beyond Pesticides, August 18, 2021) Multinational chemical company Bayer filed a petition with the U.S. Supreme Court this week, seeking a reversal of a lower court verdict that established Bayer liable for damages from the use of its weed killer Roundup. After purchasing Roundup-maker Monsanto in 2018, Bayer has been mired in a deluge of court battles from injured customers throughout the country who assert that their use of the glyphosate-based herbicide resulted in their cancer diagnosis. Bayer, for its part, has consistently lost these court cases. The company’s Supreme Court petition is now regarded as its best and last chance to avert responsibility for the ongoing harm to public health caused by its carcinogenic herbicide.

Bayer’s Supreme Court challenge pertains to the Hardeman v. Monsanto case. In that suit, a California court found unanimously in favor of the plaintiff, Edwin Hardeman. Mr. Hardeman told the jury he had used Roundup since the 1980s to spray poison oak and weeds around his property, resulting in his diagnosis of non-Hodgkin lymphoma in 2014. He was awarded $5.27 million, while his punitive damages were ultimately reduced from $75 to $20 million.

Bayer is bringing two main arguments to the Supreme court. First, the company is making a preemption argument, saying that U.S. federal pesticide law, the Federal Insecticide Fungicide and Rodenticide Act (FIFRA), preempts state-level “failure-to-warn” claims that act as the basis for the Hardeman suit. To prevail under California’s failure-to-warn law, plaintiffs must prove that the product had knowable risks, the risks presented were substantial if used in a reasonably foreseeable manner, consumers would not have recognized those risks, defendants failed to warn consumers, and consumers were thus injured as a result.

On this issue, the U.S. Ninth Circuit Court of Appeals affirmed a lower court ruling that state failure-to-warn claims were “equivalent to” and “fully consistent with” FIFRA, and that because the company had the ability to comply with both FIFRA and California law, FIFRA did not preempt plaintiff claims. Bayer’s argument to the Supreme Court rests upon the cover that the U.S. Environmental Protection Agency provided the company over the years. Bayer argues that because EPA did not approve labels with a cancer warning, and the agency has repeatedly said that such a label was not appropriate, failure-to-warn claims should not apply.

Bayer’s second argument centers around the Ninth Circuit’s admission of expert testimony, which the company says violates court precedent and federal rules. The Ninth Circuit held that a district court applied the correct standards in admitting expert testimony in the Hardeman case. This issue centers significantly around causation experts use of epidemiological evidence, a strong and growing body of literature linking glyphosate to cancer which EPA and pesticide manufacturers have regularly discounted.  

In apparent attempts to calm the market, the company has gamed out scenarios where it does and doesn’t win at the Supreme Court. Prior to the filing the petition, Bayer announced that it would end sales of Roundup to residential consumers, as part of a “five-point” planned aimed solely at averting litigation risk – not in order to protect U.S. residents from its hazardous product.

Mr. Hardeman’s lawyers told U.S. Right to Know (USRTK) they were prepared for this fight. “While paying out billions of dollars to settle claims, Monsanto continues to refuse to pay Mr. Hardeman’s verdict. That doesn’t seem fair to Mr. Hardeman. Even so, this is Monsanto’s last chance Hail Mary,” attorney Aimee Wagstaff told USRTK. “We are eager and ready to beat Monsanto at the Supreme Court and put this baseless preemption defense behind us once and for all.”

Bayers purchase of Monsanto has been characterized as “One of the Worst Corporate Deals” in recent times by the Wall Street Journal. Its first major loss centered around California school groundskeeper Dewayne “Lee” Johnson, who won an initial $289 million jury verdict against Monsanto in 2018 for his development of non-Hodgkin lymphoma (NHL) after exposure to Roundup. The first $39 million was awarded for compensation, while $250 million in punitive damages came after a finding that Monsanto acted with “malice or oppression” by suppressing the link between its product and cancer. That amount was later amended by a judge to $78 million. In addition to the Hardeman case now up for Supreme Court consideration, earlier this month Bayer lost its third appeal in its third major glyphosate trial, involving the Pilliods, a California couple that had used Roundup for more than 30 years to kill weeds on properties they owned. The couple was originally awarded a staggering $2.055 billion by a jury in 2019, which was ultimately reduced to $86 million. A California appeals court ruling on August 10 upheld the award amount.

While the company has been able to cut back large jury awards to victims, it has been ineffective at stopping the claims from winning on the merits. This is because, despite claims from captured regulatory agencies like EPA, there is a strong body of evidence linking glyphosate and its formulated products to cancer. And significant evidence that the company worked to keep that information under wraps. Over the last four years, the U.S. Environmental Protection Agency and U.S. Department of Agriculture have worked to provide cover for Bayer/Monsanto by reregistering Roundup and other glyphosate-based products, intervening in court cases, and coordinating with the company to stop glyphosate bans in other countries.

Bayer, as of June, had settled 125,000 claims for $9.6 billion with people who link their non-Hodgkin lymphoma to use of Roundup. There are still 30,000 cases that have not been resolved. Advocates are hoping that the Supreme Court will reject the company’s petition so that the full repercussions of the harm caused by Bayer and Monsanto can be realized.

Looming large over the entire saga around Roundup in the courts is the fact that a court case should never have been necessary. EPA is responsible for protecting the public from unnecessary and unreasonable harm caused by toxic pesticide exposure. But the agency’s corruption spans administrations and is independent of any one political party.  It’s time for the agency to stop allowing the pesticide industry free rein to regulate itself, and place economic concerns over the health and wellbeing of people and the environment. Tell EPA today to stand up to corporate influence and start truly protecting the environment.

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

               Source: USRTK, Reuters, Supreme Court petition

(Beyond Pesticides, August 17, 2021) “If the bee disappears from the surface of the earth, man would have no more than four years to live.” This quote is often attributed to Albert Einstein (although its true origins are unknown), but it begs an important question: What are the consequences to humankind of a world where pollinators are rapidly declining? Modern-day scientists have begun to explore that question, and a group of 20 experts recently published a global-scale assessment of the risks associated with the ongoing worldwide decline of pollinator populations in the journal Nature Ecology and Evolution. While the study experts do not provide such a dire time frame, the message unfortunately is not too far off from the Einstein-attributed quote. “What happens to pollinators could have huge knock-on effects for humanity,” said lead study author Lynn Dicks, PhD from the University of Cambridge, UK. “These small creatures play central roles in the world’s ecosystems, including many that humans and other animals rely on for nutrition. If they go, we may be in serious trouble.”

With a study objective of identifying the key drivers and implications for global pollinator decline, a group of 20 pollinator experts from throughout the world were brought together for discussion. A process called the Delphi technique, which included multiple rounds of discussion and anonymous scoring, was used to create consensus among the experts. Drivers of pollinator decline were ranked based on impacts identified by an assessment conducted by Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), a global review similar to the Intergovernmental Panel on Climate Change (IPCC). Drivers include: land management, pesticide use, land cover (land use type), pests and pathogens, pollinator management practices, genetically engineered organisms, invasive species, and climate change.

Overall, land cover, land management, and pesticide use are identified as ‘very important’ or ‘important’ drivers of pollinator declines in nearly every geographic region of the world. While climate change is also identified as such, experts do not have as much confidence in its importance when compared to other factors putting pollinators at risk. Pests and pathogens are identified as very important risks in North America and Latin America, and generally rank above concerns over pollinator management and invasive species. Genetically engineered cropping systems are identified as a lower threat in most regions of the world, but very important threat in Latin America, where hazards are identified due to high use of glyphosate resistant crops and subsequent data on the dangers of that chemical to pollinators.

After identifying the primary drivers of pollinator decline, the experts assess the risks pollinator losses have on human well-being. The impacts evaluated include: pollination deficits, food system resilience, wild fruit availability, plant diversity, yield instability, honey production, wild pollinator diversity, managed pollinator status, and aesthetic and cultural values. In sum, impacts on crop pollination and the decline of wild pollinator diversity were seen as the biggest impacts in any given area of the world. Researchers note a specific concern for crop pollination in Asia and Africa, where insect-pollinated foods are critically important for nutrition. Both China and Kenya have already had experiences where local pollinator die-offs now require humans to hand pollinate crops. Latin America may be the hardest hit – it had the largest number of ‘high risk’ designations – for pollination deficits, wild pollinator diversity, yield instability, and food system resilience, and ‘serious’ concerns are listed for all other potential impacts. The study indicates that in Latin America, “Continuing losses of pollinators are therefore likely to destabilize both regional food production and international trade, affecting livelihoods across the region.”

While Africa is at risk from pollination deficits, wild fruit availability, wild pollinator diversity, and wild plant diversity, it ranks low for risks to managed pollinators. Evidence indicates that native honey bees (A. mellifera) are thriving on the African continent, due to a more genetically diverse stock than other regions of the world. The story is different in North America, where dependency on honey bees in large, industrial agricultural systems risks significant disruptions.

The most difficult to score were impacts to the aesthetic and cultural value pollinators provide. On one hand, the study argues that this aspect may be increasing due to increased public awareness about their importance, and changes in cultural perceptions as a result. However, this would make their eventual loss even more impactful on society. “Pollinators have been sources of inspiration for art, music, literature and technology since the dawn of human history,” said Dr. Dicks. “All the major world religions have sacred passages about bees. When tragedy struck Manchester in 2017, people reached for bees as a symbol of community strength.” Dr. Dicks was referring to the Manchester Arena bombing in the UK, where 22 attendees were killed by a suicide bomber. Manchester had long associated itself with ‘busy bees’ and the ‘worker bee,’ but the bombings brought the community together around the pollinator, and the victims have since been honored by murals, tattoos, and other bee-focused commemorations.

“Pollinators are often the most immediate representatives of the natural world in our daily lives. These are the creatures that captivate us early in life. We notice and feel their loss,” Dr. Dicks says. “Where are the clouds of butterflies in the late summer garden, or the myriad moths fluttering in through open windows at night? We are in the midst of a species extinction crisis, but for many people that is intangible. Perhaps pollinators are the bellwether of mass extinction,” he concludes.

Although there remain a number of unknowns in regards to the impacts of pollinator losses, there can be no question that they are under global threat from a range of harmful drivers, with toxic pesticide use chief among them. It is incumbent upon every global resident to take action to protect these critically important species – not only for the services they provide humanity, but also for their inherent value and right to exist.

In depth reviews and expert consensus-making could change the trajectory of pollinator declines – particularly in the United States. A bill in Congress that would save bees and other pollinators, the Saving America’s Pollinators Act (SAPA), introduced by Earl Blumenauer (D-OR), would put experts in charge of determining threats and remedies to ongoing pollinator declines. With the U.S. Environmental Protection Agency failing to take action on pollinators due to corrupt industry influence, it is time for EPA to take a back seat, and let pollinator experts determine the best path forward for pollinator health. Send a message to your Congressional rep urging them to cosponsor SAPA – consider following up with a direct call to their office, and if they’ve already signed on, be sure to thank them.

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

Source: University of Cambridge press release, Nature Ecology and Evolution

(Beyond Pesticides, August 16, 2021) The failure of the U.S. Environmental Protection Agency (EPA) to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine-disrupting chemicals must end. The Office of the Inspector General (OIG) for EPA has issued a damning report on the agency’s progress in protecting the population from potentially damaging endocrine disruption impacts of exposures to synthetic chemical pesticides (and other chemicals of concern) that shows the situation to be even worse than previously reported. The OIG’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” As a result, according to the OIG, “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.”

Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.

Over recent decades, evidence has mounted showing that many pesticides interfere with hormones—and are therefore endocrine-disrupting chemicals (EDCs). In 1996, the promise of screening pesticides for endocrine disruption generated support from environmentalists and public health advocates for the Food Quality Protection Act (FQPA), which traded the absolute prohibition of carcinogens in food of the Delaney Clause for a risk assessment standard that is subject to manipulation and an underestimation of real-life hazards. And now, 25 years later, we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.

The endocrine system consists of a set of glands (thyroid, gonads, adrenal and pituitary) and the hormones they produce (thyroxine, estrogen, testosterone and adrenaline), which are responsible for the activation, regulation, and de-activation of a huge variety of functions in, especially, development, reproduction, growth, metabolism, the cardiac and circulatory system, sleep, mood, and behavior, among others. Hormones are signaling molecules that travel through the bloodstream and elicit responses in other parts of the body. The hormones secreted by the endocrine glands travel through the bloodstream to various organs and tissues, where they communicate critical regulatory messages.

The ingredients in many pesticides (and in many consumer products) act as endocrine disruptors in humans and other animals in several ways. They may: (1) mimic actions of hormones the body produces (e.g., estrogen or testosterone), causing reactions similar to those generated by the naturally produced hormones; (2) block hormone receptor cells, thereby preventing the actions of natural hormones; or (3) affect the synthesis, transport, metabolism, and/or excretion of hormones, thus altering the concentrations of natural hormones in tissues or at receptor sites. 

As the OIG report notes, “Small disturbances in endocrine function, particularly during certain highly sensitive stages of the life cycle, such as pregnancy and lactation, can lead to profound and lasting effects. Adverse endocrine-related effects in humans may include breast cancer, diabetes, obesity, infertility, and learning disabilities.” In addition, there are both direct and indirect implications of EDCs, such as other cancers, Parkinson’s disease, multiple reproductive disorders and anomalies (e.g., polycystic ovary syndrome, testicular dysgenesis syndrome, endometriosis, and reduced sperm count), alteration of the gut biome and resultant dysfunction, and metabolic disorders apart from diagnosable diabetes. 

The OIG report finds that EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP), which is responsible for testing all pesticide chemicals for endocrine-disrupting activity in humans, has failed to implement a section of the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by the 1996 Food Quality Protection Act — the legislation that requires such testing. In addition, the report states that OCSPP’s Office of Pesticide Programs (OPP) has not implemented a 2015 recommendation that 17 pesticides undergo additional testing as EDCs in wildlife so that an ecological risk assessment could be effectively conducted.

The report indicates that EPA has not created the tools (e.g., strategic guidance documents or performance measures) necessary to implement effectively the agency’s Endocrine Disruptor Screening Program (EDSP), created in 1998. In particular, EDSP has not “conducted annual internal program reviews to monitor or assess progress in fulfilling regulatory requirements, and the EDSP has not effectively communicated with internal and external stakeholders. Moreover, previous OCSPP leadership provided acceptable corrective actions to meet the recommendations in a 2011 EPA Office of Inspector General report regarding the EDSP, yet failed to actually implement those corrective actions beyond an initial period of compliance with them. Lastly, some EPA staff indicated that they were instructed to function as if the EDSP was eliminated from the EPA’s budget. Because the EDSP has not had effective internal controls in place since 2015, it cannot have reasonable assurance that the objectives of the program will be accomplished and that resources will be allocated efficiently and effectively.”

In 2017, Europe’s Pesticide Action Network refined an earlier estimate by the European Union that more than 50 pesticide active ingredients operate as endocrine disruptors. (That earlier list included those identified by TEDX, The Endocrine Disruption Exchange, which was launched by pioneering ED scientist Theo Colborn, PhD.) The update short-listed 37 pesticides of ED concern out of the nearly 500 on the market in Europe in 2015. In 2009, EPA created an EDSP “List 1” of 67 pesticides and “high production volume chemicals” used as pesticide inert ingredients that the agency deemed should be evaluated first for ED impacts. (EPA later reduced this list to 52 chemicals because 15 were subsequently canceled or discontinued.)

It is not only humans who are affected. Hermaphroditic frogs, polar bears with penis-like stumps, panthers with atrophied testicles and intersex fish with immature eggs in their testicles have all been linked to endocrine disruption. The popular herbicide atrazine chemically castrates and feminizes exposed male tadpoles. The mosquito-killing S-methoprene larvicide alters early frog embryo development. Distorted sex organ development and function in alligators is linked to the organochlorine insecticide dicofol. The ubiquitous antibacterial chemical triclosan alters thyroid function in frogs, while its chemical cousin triclocarban enhances sex hormones in rats and in human cells. In her book, Our Stolen Future, Dr. Colborn states that the decline of animal species can no longer be simply explained by habitat destruction and human disturbance, but also by reproductive failures within populations brought on by the influence of endocrine-disrupting chemicals.
The OIG report documents the repeated failures of EPA to meet deadlines set by Congress to develop and implement EDC testing. OIG findings are consistent with those reported by Sharon Lerner in her article in The Intercept, “Whistleblowers Expose Corruption in EPA Chemical Safety Office.” The article evinced not only laxity and managerial allegiance to industry interests, but also, downright corruption on the part of some managers at EPA.

EPA now issues Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption.

The report concludes: “In 1996, Congress directed the EPA to establish the EDSP, and the program received approximately $7.5 million in funding in fiscal year 2021. Yet, the EDSP can show only limited results. Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.”

The OIG report issued a series of 10 recommendations, directed to OCSPP Assistant Administrator Freedhoff, that address:

1. tiered testing for ED impacts
2. timelines for such testing
3. strategic planning
4. development of performance metrics
5. improved communication, including to the public
6. internal program review
7. improved transparencyns

Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.

Letter to U.S. Environmental Protection Agency Administrator Michael Regan

I am writing to ask you to act now to meet a statutory mandate to protect humans and wildlife from dire health consequences. The failure of EPA to meet its statutory responsibility to protect against exposure to endocrine-disrupting chemicals (EDCs) must end. The Office of the Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA) has issued a damning report on the agency’s progress in protecting the population from EDCs used as pesticides, as mandated by the Food Quality Protection Act (FQPA) of 1996, which required EPA to establish a program to screen and test pesticides and other widespread chemical substances for endocrine-disrupting effects. The OIG’s summary statement says, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward complying with statutory requirements or safeguarding human health and the environment against risks from endocrine-disrupting chemicals.” As a result, according to the OIG, “we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.”

As the OIG report notes, “Small disturbances in endocrine function, particularly during certain highly sensitive stages of the life cycle, such as pregnancy and lactation, can lead to profound and lasting effects. Adverse endocrine-related effects in humans may include breast cancer, diabetes, obesity, infertility, and learning disabilities.” There are other direct and indirect implications of EDCs, such as other cancers, Parkinson’s disease, multiple reproductive disorders and anomalies (e.g., polycystic ovary syndrome, testicular dysgenesis syndrome, endometriosis, and reduced sperm count), alteration of the gut biome and resultant dysfunction, and metabolic disorders apart from diagnosable diabetes.

The OIG report finds that EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP), which is responsible for testing all pesticide chemicals for endocrine-disrupting activity in humans, has failed to implement the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by the 1996 Food Quality Protection Act. In addition, the report states that OCSPP’s Office of Pesticide Programs (OPP) has not implemented a 2015 recommendation that 17 pesticides undergo additional testing as EDCs in wildlife so that an ecological risk assessment could be effectively conducted.

The report indicates that EPA has not created the tools necessary to implement the agency’s Endocrine Disruptor Screening Program (EDSP), created in 1998. The OIG report documents the repeated failures of EPA to meet deadlines set by Congress to develop and implement EDC testing. “In 1996, Congress directed the EPA to establish the EDSP, and the program received approximately $7.5 million in funding in fiscal year 2021. Yet, the EDSP can show only limited results. Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.”

The OIG statement that “some EPA staff indicated that they were instructed to function as if the EDSP was eliminated from the EPA’s budget” is consistent with those reported by Sharon Lerner in her The Intercept article, “Whistleblowers Expose Corruption in EPA Chemical Safety Office,” which showed not only laxity and managerial allegiance to industry interests, but also downright corruption on the part of some managers at EPA.

The OIG report issued a series of 10 recommendations that address:

• tiered testing for ED impacts
• timelines for such testing
• strategic planning
• development of performance metrics
• improved communication, including to the public
• internal program review
• improved transparency

Please ensure that your agency meets its responsibility to protect the health of people and wildlife.

Thank you.

(Beyond Pesticides, August 13, 2021) Across the pond in the UK, two years of trials with spring and winter wheat varieties have shown, according to the Farmer Scientist Network (FSN), which conducted the study as Crop Health North, that so-called “biopesticides,” alone or in combination with conventional pesticides, can be useful in generating yield and grain quality comparable to those obtained through use of conventional “crop chemistry” (aka, synthetic chemical pesticides). According to Beyond Pesticides Executive Director Jay Feldman, biopesticides are a “mixed bag,” generally poorly understood, and defined differently by various entities and stakeholders. He notes that the term can be misleading and mixes contradictory approaches, adding that, “It’s troublesome when we continue to look for product replacements or substitutions for agricultural practices that are clearly ineffective, and in the process avoid the changes necessary to transition to organic practices,” which represent the real, long-term solution to the problems efforts such as these trials seek to remedy.

The project was sponsored and supported by the Yorkshire Agricultural Society (YAS) through the European Innovation Partnership (EIP-AGRI). YAS collaborated with universities, farmers, research institutes, agricultural organizations, and technology and food testing centers to conduct trials on three farms in the north of England. The wheat crops were monitored throughout their lifecycles, over the course of three harvests, to identify any diseases, and then manage them via chemicals, biological agents, or some combination of the two. The wheat varieties studied were spring varieties Willow and Mulika (in 2017); winter varieties Skyfall and Leeds (2018); and the winter wheat variety Sundance (in 2019).

The EIP-AGRI website notes, “The crops were analysed in terms of disease severity, yield and quality, looking specifically at whether the biological agents were as effective as the chemical compounds, and whether the new biological compounds work with existing agricultural practice. By using three independent sites, the project was also able to test performance on different soils and in varied climatic conditions.”

The project investigators cite the need to find alternatives to synthetic chemical pesticides not only because some of those are disappearing from the market, but also, because the concerns about pesticide use — for human health and environmental integrity — are real and growing, including among farmers. As asserted by YAS on its website and in a video it produced, there is growing worry in the agricultural community about the removal of pesticide products and their active ingredients from the marketplace. There is particular concern among farmers about how to address some fungal diseases that affect wheat; thus, the biopesticides used in the trial were biological alternatives to conventional fungicides. FSN notes that research into viable alternatives is limited and that these wheat trials aimed to address this dearth of information.

In the YAS video, James Standen, Farms Director for Newcastle University Farms, spoke of the importance of looking at “bioprotectant” products for use on wheat crops as farmers “lose active ingredients, with bans coming in for product safety, [and] the Precautionary Principle, and as resistance builds up to various chemicals.” Tom King, UK Regional Base Manager for Eurofins Agroscience Services, added (in the video) that bioprotectant products are most successful in an IPM (Integrated Pest Management) approach.

Essentially, as toxic chemicals are removed from the conventional agricultural toolkit, producers want other substances with which to treat agricultural pests, keeping the whole system in a perpetual “chase” for the next pest “fix,” whether chemical or biological. Apart from the toxicity and other “downstream” issues related to many synthetic control chemicals is the relentless issue of resistance — which all organisms will develop against harmful substances to which they are chronically exposed.

The study sought to compare the efficacy of biological controls (aka, biopesticides, bioprotectants, biologic products, biologic reagents) on disease resistance with that of conventional synthetic pesticides. But how do the investigating organizations define these products? According to Dr. Roma Gwynn, a bioprotectant specialist and director of Rationale (an organization of biopesticide strategists), “Bioprotectants (including microbial and botanical plant protection products) are substances that have been found in nature or derived from it, so they naturally break down and degrade very easily, and therefore you’re having a much lower impact on the environment and on non-target organisms.”

The U.S. Environmental Protection Agency (EPA) says, “Biopesticides are certain types of pesticides derived from such natural materials as animals, plants, bacteria, and certain minerals. . . . Biopesticides include naturally occurring substances that control pests (biochemical pesticides), microorganisms that control pests (microbial pesticides), and pesticidal substances produced by plants containing added genetic material (plant-incorporated protectants) or PIPs.”

Professor Rob Edwards, PhD, Head of Newcastle University’s School of Agriculture, Food and Rural Development and chair of FSN, writes of the “biologic products” used in the trials, “The biologic reagents are micro-organisms used to coat seeds before sowing or [to] spray onto the plant. They work, rather like probiotics in human medicine, to strengthen the plant’s natural resistance. These are relatively new to the UK but likely to become widely available over the next few years.”

Information on biopesticide active ingredients is available in the Pesticide Chemical Search database. (Enter an ingredient name and look under the Regulatory Actions tab for available information, and/or use the Filter by Pesticide Type link on the right side of the page to see a list of all biopesticides. From that list, access information about each ingredient.)

Recent research published in the journal plants calls biopesticides “natural, biologically occurring compounds that are used to control various agricultural pests infesting plants,” but also discusses “biocontrol agents composed of microorganisms including bacteria, cyanobacteria, and microalgae, plant-based compounds, and recently applied RNAi-based technology.” Those researchers identified multiple categories of biopesticides: microbial pesticides, biochemical pesticides, insect pheromones, plant-based extracts and essential oils, insect growth regulators, and GMO (genetically modified organism) products.

Some of those categories of biopesticides may well be compatible with organic agricultural practices, while others would not because they fail to meet the requirements of the National Organic Program, which operates within the U.S. Department of Agriculture (USDA). The USDA website explains that “Organic producers rely on natural substances and physical, mechanical, or biologically based farming methods.” Beyond Pesticides expects that there will be pressure to incorporate the use of biopesticides into the rules for organic production, and believes that could easily undermine the USDA Certified Organic brand and label if a fine-grained evaluation of each kind of biopesticide is not conducted before any such decisions.

Professor Edwards’s claim that the bioprotectants used in the subject trials work, like probiotics in human medicine, to strengthen plants’ natural disease resistance may be true. But this is not the MO of all biopesticides. For example, one category of bioprotectants uses, as noted above, “applied RNAi-based technology” to modify crop plants so they can “neutralize” pests. This is a genetically engineered (GE) technology that uses gene silencing — GE regulation of gene expression in a cell, as is employed in developing Roundup Ready seeds. This tinkering with gene expression is supposed to impact (lethally) target pests when they ingest the GE plant.

But there are significant, and largely unexplored, downsides to RNAi “biopesticides”; as researchers have identified, an “off-target effect is one of the major limitations associated [with] RNAi technology. Off-target effects are describe[d] as the silencing of non-target genes in the same organism or in non-target organisms.” As other scientists identified in the journal Bio-Science: “RNAi pesticide technology . . . produces those small ‘bits’ of genetic material. . . . [which] often have off-target binding elsewhere in a nontarget species’ genome that makes predicting toxic effects and designing maximum-hazard dose assays challenging for the wide range of species potentially exposed. . . . Knowledge gaps in the genomics and physiologies of highly exposed nontarget organisms currently preclude our ability to assess the activity spectrum of RNAi, determine whether toxicity assays will be sufficient in predicting the risks of RNAi-based crops, and explain how these risks may affect food webs associated with agroecosystems.”

In addition, little is known about the persistence of these genetic bits in the environment, nor what their impacts on ecosystems might be. There is something counterintuitive in labeling something a “bio” product (which connotes something “natural”) when in fact it involves genetic engineering — an entirely synthetic process. 

Nevertheless, many researchers and agricultural organizations are very interested in the development of new, biopesticide substances or technologies that appear to be relatively “quick fixes” to the perceived problems of disappearing synthetic chemical pesticides and resistance to others. The UK entities involved in these wheat trials have indicated that the next step is to take the products that performed well in the study and figure out how to “optimize their use.”

Beyond Pesticides and other organic advocates recognize that some bioprotectant products may be ecologically sound and nontoxic; indeed, some fungi appear to hold great promise. But the fundamental quest ought not be one of seeking an endless stream of “substitute” products or controls as resistance to conventional pest controls continues to develop. Rather, the central and critical need is making the transition from conventional chemical farming to organic, regenerative agriculture — which involves shifts in both understanding and practices. That transition is the solution to the multiple threats of conventional pesticide use — harmful human health impacts, biodiversity collapse, the climate emergency, and environmental and ecosystem degradation. Development and adoption of GE and other dubious biopesticides represents functional “delay and diversion” from that necessary shift in how food is produced. See Beyond Pesticides Organic Agriculture page.

Sources: https://ec.europa.eu/eip/agriculture/en/news/inspirational-ideas-crop-health-and-pesticide and https://iapps2010.me/2021/08/03/uk-biopesticides-protect-wheat/

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

(Beyond Pesticides, August 12, 2021) A recent study published in Chemosphere identifies the concentration, consequences, and potential sources of 22 organochlorine pesticides (OCPs) among corals in the South China Sea (SCS) for the first time. SCS corals exhibit a higher affinity toward bioaccumulation of OCPs, which are legacy persistent organic pollutants (POPs) under the Stockholm Convention—a global treaty to eliminate POPs. The study finds the distribution of OCPs in coral tissue matches that of the surrounding oceanic air samples. Hence, atmospheric concentrations of OCPs—influenced by continental air masses—migrate from the atmosphere to seawater through gas exchange.

Coral reefs are one of the largest ecosystems in the ocean, sustaining marine biodiversity and providing many goods and services. However, living coral populations are rapidly declining due to ocean acidification, oceanic warming, habitat destruction, and pollution from human activity across the globe. From rare corals off the coast of Florida to well-established hard corals in the Great Barrier Reef, these communal organisms are sensitive to various environmental stressors that threaten biodiversity. Although several studies demonstrate the volatile, toxic nature of POPs, much less research evaluates the impact POPs have on biodiversity over time. The globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk. With the increasing rate of biodiversity loss, advocates say it is essential for government agencies to research how previous and ongoing use of POPs can impact present-day species. Likewise, collaborative, global monitoring of POPs can help leaders identify the effect on vulnerable species of the chemicals’ long-range transport and the most effective unified global strategy. The researchers note, “Understanding the dynamics of air-seawater exchange and the within-ocean processing of POPs in the SCS is critical to obtain better insight into their global fate and behavior.”

Researchers investigated the occurrence, taxonomic profiles, and geographical distribution of organochlorine pesticides in coral tissue. They compared results to ambient air and seawater OCP distribution/concentration from the South China Sea. Target chemicals included 22 OCPs: six DDT compounds, four hexachlorocyclohexane compounds (HCHs), five chlordane compounds (CHLs), heptachlor, heptachlor epoxide A and B, two endosulfans (ENDOs), hexachlorobenzene (HCB), p,p′-methoxychlor (MXC), and three Drins (aldrin, endrin, and dieldrin). Using gas chromatography-tandem, researchers measured OCP concentration in SCS coral tissue, air, and water samples.

The study results indicate 17 of the 22 OCPs are detectable in seawater, and all 22 OCPs are detectable in ambient air samples from the SCS. The most prominent chemicals amid air and water samples are CHLs, HCBs, DDTs, and Drins. Although coastal corals have higher chemical concentrations than offshore species, the chemical composition is similar, with DDT and CHL  compounds dominant among tissue samples. Researchers attribute the difference in OCP concentration among coastal and offshore corals to oceanic currents and storms influencing pollution distribution.

Long-range atmospheric transport and condensation are significant contributors to the global contamination of environmental pollutants like OCPs. Most concerning are the persistent properties of OCPs that allow these substances to remain in the environment long after use. Some of these long-lived chemicals include regionally banned pesticides that are highly toxic to humans and animals: DDT, heptachlor, and lindane. These pesticides cause various adverse effects, from respiratory issues, nervous system disorders, and birth deformities to various common and uncommon cancers. Although some, but not all, manufacturing and use of specific OCPs have declined in the U.S., OCPs remain a global issue, as much of the developing world still report usage. Continued manufacturing and utilization of OCPs increase the probability of long-range transport of these chemicals and their deposition across the globe via precipitation. However, OCPs still mobilize and accumulate in regions void of industrial or agricultural activities, like glacier tops and remote territories. Arctic snowmelt threatens to re-release chemicals entrapped in ice, further contributing to toxic chemical transportation and passive pesticide exposure globally. The glacial melting caused by the climate crisis will only add to atmospheric and waterway contamination. The release of volatile OCPs will enter waterways at the same concentration levels as before ice entrapment, even after several decades.

Pesticide contamination is already a global issue. Clean air, water, and healthy soils are integral to ecosystem function to support life. However, toxic pesticide residues readily contaminate all ecosystems, frequently existing in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) set standards. Scientific literature demonstrates pesticides’ long history of adverse effects on the environment, including wildlife, biodiversity, and human health. Pesticides can present acute and long-term health impacts worldwide, especially to farmers, 44 percent of whom experience pesticide poisoning every year. Furthermore, a recent study discovered DDT metabolite (DDE’) residues are detectable in residents of Chicago who consume more glasses of tap water per day. Therefore, the ubiquitous nature of pesticides impacting all ecosystems and the health of their inhabitants is a cause of concern for future human, animal, and environmental well-being.

Although this study is the first to identify organochlorine pesticides in corals specific to the South China Sea, numerous studies identify risks to coral reef habitats from chemical pollution. In March 2020, coverage of a report by the Australian government showed that agricultural pesticides are severely damaging the Great Barrier Reef. A University of Queensland study finds pesticide mixtures discharging from rivers and streams contaminate the Great Barrier Reef Lagoon, with 99.8 percent of samples containing up to 20 different pesticide compounds. Moreover, the combined impact, or synergism, between pesticides and warmer oceanic temperatures puts coral reef fish at a greater risk of adverse health effects, including endocrine disruption. The discovery of such intensive penetration of pesticides among coral reefs adds to the growing record of damage on these marine ecosystems.

Overall, OCP concentrations are declining in the South China Sea as many nations ban organochlorine compounds, yet chemical concentrations remain highest in corals near continental areas. The study identifies various routes of OCP exposure among corals, including dietary uptake and partitioning behavior or absorption. Isomer ratios reveal that most OCP contamination stems from the current use of technical chlordane (termiticide) and historical uses of other OCPs. Previous records indicate air and sediments from China, Vietnam, and Pakistan contain inputs of chlordane and DDTs. However, researchers find higher levels of DDT among the coral population relative to chlordane, due to the extensive use of the chemical in counties around the South China Sea. India and Vietnam permit the use of DDT to control mosquitoes under the Stockholm Convention. Furthermore, high temperatures and chemical volatility play a role in organochlorine pesticide availability as primarily gas residues rather than particles in the SCS. Thus, researchers determine that atmospheric deposition of OCPs is a main route of contamination among corals in the SCS. The study concludes, “The present study provides baseline data for future studies of OCPs in CRRs. Nevertheless, studies linking pollution monitoring and ecotoxicology are needed to assess the potential environmental effect of OCPs on corals in future studies. Additionally, analyzing the level of OCPs on a larger temporal-spatial scale is needed.”

Chemical contamination is ubiquitous in marine environments. Consequently, it is essential to understand the impacts of interactions with other environmental pollutants, especially in contaminated ecosystems like waterways. Furthermore, climate crisis implications like melting glaciers present a new concern over the high levels of chemical concentrations in the oceans from DDT, its metabolites, and other persistent organic pollutants, trapped in ice. Therefore, to protect the nation’s and world’s waterways and reduce the number of pesticides that make their way into drinking water, toxic pesticide use must end.

Beyond Pesticides has long advocated for federal regulation that considers potential synergistic and additive threats to ecosystems and organisms. Replacing pesticides with organic, nontoxic alternatives is crucial for safeguarding public health, particularly communities vulnerable to pesticide toxicity. Learn more about pesticide hazards and their impact on wildlife through Beyond Pesticides’ wildlife program page. For more information about pesticide contamination in water, see the Threatened Waters program page and Beyond Pesticides’ article Pesticides in My Drinking Water? Individual Precautionary Measures and Community Action.

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

Source: Chemosphere

(Beyond Pesticides, August 11, 2021) Multiple stressors, including pesticides, parasites, and poor nutrition, act synergistically to increase the risk of bee mortality, according to a meta-analysis recently published in the journal Nature. The findings are yet another indictment of the U.S. pesticide regulatory system’s ability to protect pollinators, as the authors note that their results, “…demonstrate that the regulatory process in its current form does not protect bees from the unwanted consequences of complex agrochemical exposure.” As scientific community continues to confirm the dangers of pesticides and other anthropogenic stressors to pollinators, it remains up to advocates and other concerned residents to get regulators and policymakers to listen to and act on these critically important conclusions.  

Scientists aimed to evaluate how combinations of multiple pesticides, parasites, and lack of floral resulted in bee death or subchronic effects that impacted overall fitness (reproductive ability, colony health, etc), behavior, parasite load, or immune response. The effects of multiple stressors can be characterized as antagonistic when stressors cancel themselves out, additive when the impacts seen are what would be predicted when summing the individual effects, and synergistic when the effects are multiple times more harmful than what would be predicted additively. To conduct the analysis, researchers began with nearly 15,000 papers on bee health, and narrowed down their review to 90 studies that observed over 350 interactions between multiple stressors.  

At the most general level, multiple stressors were synergistic in the context of bee mortality, but additive for effects on overall fitness. Looking further into the data, it was determined that exposure to multiple pesticides had the most robust connection to synergistic impacts. Researchers suspected that studies exposing pollinators above field-realistic doses may have contributed to that result, but a reanalysis that focused solely on pesticide levels pollinators would encounter in the wild found the same results. “Interactions between multiple agrochemicals significantly increase bee mortality,” said lead author Harry Siviter, PhD.

Most other stressors exhibited additive impacts on bee mortality and health. Interactions between nutritional health, parasite load, and pesticide exposure were summed predictably for bee mortality. Differences, however, were seen for the overall combined effects of multiple stressors on parasite load. These effects are characterized as antagonistic. Scientists suspect that the cause is likely because two parasites will attempt to outcompete each other, but note that this could vary by parasite type and may be due to variability in the study dataset.

“Our results show that although many classes of anthropogenic stressors may have additive effects on bee mortality and fitness proxies, exposure to combined agrochemicals can have synergistic effects that are more detrimental than would be predicted by independent risk assessments,” the study reads.

The U.S. Environmental Protection Agency has access to the same studies analyzed as part of this meta-analysis. Yet, the agency continues to register bee-toxic pesticides and permit them to be used in combination with other active and inert pesticide ingredients. Unfortunately, a large part of the problem is that the data EPA relies upon is not the data these scientists are analyzing in the open literature – instead, EPA primarily uses data supplied by the pesticide industry to determine risk. In just one example of EPA’s lack of adequate oversight and transparency, in 2019, the agency reregistered the bee-toxic insecticide sulfoxaflor (a pesticide beekeepers had, just a few years earlier, successfully banned in the courts). As part of its new registration, EPA relied on studies from pesticide manufacturers and decided to waive prior restrictions on ‘tank mixing’ the insecticide with other toxic pesticides. This was done “because data show that there is no additional risk when sulfoxaflor is tank mixed with other compounds,” EPA wrote.

Authors of the current meta-study indicate that their results should not be ignored by regulators. They suggest a range of prescriptions to enhance the ability for regulators to determine risk, such as requiring tests on common pesticide tank mixtures, or conducting post-licensing analysis – monitoring pesticide product applications in the field as a last step in the regulatory review process.

While these changes would improve understanding, there are other forces at play in regards to the pesticide review process. Most notably is the depth of corruption within EPA’s Office of Pesticide Programs. According to recent reporting in the Intercept, rank and file EPA employees have been bullied and brow beat into approving toxic chemicals that they know are unsafe. Many advocates wonder how effective new studies and protocols could be if the agency continues to act as a revolving door between the pesticide and agrichemical industry.

Structural changes are needed to shake up EPA and hold pesticide manufacturers accountable. The Saving America’s Pollinators Act (SAPA), introduced in Congress this year as HR4079, would start that process. The bill that saves the bees would put pollinator experts in charge, not EPA’s pesticide industry flunkies. These experts would be empowered to review all data of concern for pollinators and require EPA to restrict them if the chemicals are found to be an unacceptable hazard to pollinators or the habitat they rely upon. This is a common sense proposal that cannot succeed without strong support from the public. Take action today to urge your member of Congress to cosponsor SAPA, and follow up with a phone call. If your member is already a cosponsor, make sure to send a note thanking them for their support.

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

Source: Phys.Org, Nature

(Beyond Pesticides, August 10, 2021) President Biden’s Environmental Protection Agency (EPA), under Administrator Michael Regan, is set to reapprove the highly hazardous herbicide paraquat with fewer protections than those proposed by the Trump administration. Despite strong links to Parkinson’s, and bans on the herbicide in the European Union, China, Brazil, and many other countries, EPA’s press release inexplicably states, “No direct one-to-one alternatives to paraquat are available.” The move is part of a string of actions that have pesticide reform advocates increasingly concerned that the Biden Administration is not living up to his initial promises to improve health and environmental protections.

Paraquat is the most toxic herbicide still on the market. As EPA readily admits, one small sip of paraquat can be fatal. Apart from its acute toxicity, chronic exposure to the herbicide is strongly linked to the development of Parkinson’s disease. But its association with Parkinson’s is merely the most well-known health concern – the chemical is a likely carcinogen, harms the reproductive system, and damages organs like the kidney and liver. It is hazardous to birds and bees, and prone to leaching into groundwater, where it disrupts the health of aquatic ecosystems.

The Trump administration’s decision to reapprove paraquat last year was characterized by Beyond Pesticides as “a broken EPA” with an “extremist pro pesticide agenda.” Reapproval of this chemical in the first place highlights an incredible lack of concern for the health and prosperity of many Americans who will continue to be at risk of being included in the future Parkinson’s pandemic. Yet the Biden Administration, which has consistently ‘talked the talk’ around the need to reverse dangerous decisions made by the previous administration, and pledged a new path toward improved public health and environmental protection, has not only endorsed the Trump EPA’s decision to reapprove the chemical, its new proposal weakens and rolls back critical protections.

While the Trump EPA proposed reapproving paraquat while prohibiting aerial applications, the Biden EPA determined that aerial applications of paraquat are acceptable.

According to reporting from EENews, the agency used information provided by the Agricultural Handler Exposure Task Force, a consortium of chemical companies that includes BASF, Bayer Monsanto, Corteva, FMC, and Syngenta/ChemChina, the primary manufacturer of paraquat. The data produced by the chemical companies indicate that EPA had miscalculated the dangers posed to farmworkers, and that an all-out ban on aerial use was not warranted. Despite a long history of criticism directed at the agency for simply allowing pesticide companies to write the rules, the agency did exactly that.

“With this recent move, the Biden EPA has endorsed the continued crop dusting of American food and farmland with paraquat, a chemical that is strongly linked to Parkinson’s disease, and can kill an individual with a single sip,” said Drew Toher, community resource and policy director at Beyond Pesticides. He continued: “This is an economic decision – one that aims to maintain the profits of chemical companies at the expense of farmworker lives and livelihood. Americans should be ashamed of their taxpayer dollars being used to support this dangerous action.”

The move on paraquat is reminiscent of other decisions EPA made at the behest of industry.  In 2018, EPA stripped away protections that reduced children’s exposure to synthetic pyrethroids, a group of neurotoxic pesticides strongly linked to childhood cancer, autism, and other learning disorders. In that case, CropLife America, the main pesticide industry lobby group, urged EPA to rely on a health model developed by a group known as the Council for the Advancement of Pyrethroid Human Risk Assessment. Under the CAPHRA model, pyrethroids were estimated to be metabolized by children at the same rate as adults. As a result, EPA lowered the safety factor on synthetic pyrethroids from 3x to 1x for children under 6 years of age, permitting children’s exposure rates to these widely used chemicals to triple.

Most frustrating to pesticide reform advocates is that the Biden administration has acknowledged many of the mistakes of the past. In March 2021, Michal Freedhoff, PhD, acting assistant administrator for EPA’s Office of Chemical Safety and Pollution Prevention wrote an open letter to EPA employees noting, “Over the past few years, I am aware that political interference sometimes compromised the integrity of our science.” And continuing, “This is a new day, about communication, trust, transparency and the importance of science in our regulatory decision-making process.” Dr. Freedhoff specifically cited the agency’s decision to approve volatile dicamba formulations on genetically engineered crops. As Beyond Pesticides noted at the time, despite the recriminations, EPA announced no plans for corrective action.

Opportunities for the agency to show off environmental bona fides have been numerous, but there is little for advocates to point to with the new administration. The lack have progress has brought Beyond Pesticides to question: “What is going on at the Environmental Protection Agency?”  On a range of chemicals decisions, including glyphosate, chlorpyrifos, dicamba, the neonicotinoids, the synthetic pyrethroids, atrazine, and paraquat, EPA has raised expectations while failing to deliver.

There is still time for the agency to reverse its approach, and eschew chemical company influence in its decision-making. Despite affirming earlier decisions around the risks that glyphosate pose to human health, the agency has asked the court for a redo on its 2020 decision to reapprove glyphosate products like Roundup. The agency is also on an impending deadline to provide a response to a federal court on the status of chlorpyrifos’ registration. Based on recent decisions, some advocates question whether President Biden EPA’s will affect a significant shift from the Trump administration’s industry friendly positions.

The pressure is on. A detailed report in The Intercept shined a spotlight on the depths of corruption within EPA’s Office of Pesticide Programs (see Beyond Pesticides coverage here).  Whistleblowers are filing complaints with EPA’s Office of Inspector General for the pressure they felt to deliver results in line with industry wishes. Increasingly, experts are sounding the alarm about the need for updates to U.S. pesticide law, and bills like the Saving America’s Pollinators Act, and Protect American Children from Toxic Pesticides Act are gaining increased attention in Congress.

Like glyphosate, paraquat’s major manufacturer – Syngenta/ChemChina – is now in court over links between its herbicide and chronic disease. But it’s not acceptable for the courts to institute environmental protections when EPA – a taxpayer funded executive agency – was created specifically to provide that service for the American people. Urge the Biden EPA to stand up to pesticide manufacturers by holding them accountable for the dangers associated with their products.

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

Source: EPA’s press release, EENews

(Beyond Pesticides, August 9, 2021) What’s going on at the Environmental Protection Agency (EPA)? Last month, Bayer/Monsanto announced it would voluntarily cancel “residential lawn and garden” uses of glyphosate products, “exclusively to manage litigation risk and not because of any safety concerns.” EPA has done virtually nothing to restrict glyphosate/Roundup since the World Health Organization/International Agency for Research on Cancer in 2015 classified the chemical as probably carcinogenic. It is now expected, as with other voluntary cancellations, that EPA will make no health or environmental findings that could affect other uses (e.g., agricultural) of glyphosate, but will accept the action by Bayer/Monsanto. The company refers to its action as “risk mitigation”—that’s risk to the company’s profitability, economic viability, and shareholder investment, not public health or environmental protection. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, offering a shield from liability, and unencumbered international marketing.

The Biden administration began with high hopes for the environment. Combating climate change is a priority. On his first day in office, President Biden issued an executive memorandum, Modernizing Regulatory Review, that appears to establish a new framework supporting healthy people and ecosystems, as it directs the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations.

But what’s happening at EPA? The announced voluntary cancellation of glyphosate products highlights EPA’s failure to correct dangerous decisions made under the Trump administration. EPA has not corrected actions on chlorpyrifos, atrazine, dicamba, or neonicotinoids that allow poisonings of humans, pollinators, and others to continue.

Tell EPA to stop allowing the pesticide industry free rein to regulate itself based on financial risks instead of the risks to health and environment that the law requires to drive decisions. 

A report by the Office of the Inspector General for EPA concludes that scientific analyses by the agency were altered so as to favor top Trump administration officials’ policy choices in the 2018 reapproval of the highly toxic and problematic pesticide, dicamba. The report, “EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision,” was publicly released on May 24. It confirms aspects of what Beyond Pesticides and many others in the science, advocacy, public health, and environmental communities have been saying and reporting since 2016: The Trump administration executed a wholesale assault on scientific integrity in federal decision-making. But where is the Biden EPA correction of the Trump policy?

An article in The Intercept reveals how far EPA’s credibility has slipped, in view of sloppy or corrupt science, a well-greased revolving door between EPA and the pesticide industry, responsiveness to political pressure from pesticide companies, and actions that lag behind other countries. If EPA is to fulfill its statutory responsibilities, it must reverse these realities, re-examine Trump-era decisions, and act on behalf of the public and the environment.

EPA must not continue to allow pesticide manufacturers to regulate themselves based on financial risk. While they may have been forced in courts to pay damages for certain uses—generally those where exposure to specific people can be proven—these same pesticides continue to harm others, from neighboring chemical-intensive and organic farmers, to those living near production plants and those with pre-existing conditions, to bees and frogs, to consumers. When a company seeks to voluntarily cancel uses of a pesticide, EPA should immediately suspend all registrations and begin cancellation proceedings for all uses.

Tell EPA to stop allowing the pesticide industry free rein to regulate itself based on financial risks instead of the risks to health and environment that the law requires to drive decisions.

Letter of EPA Administrator Michael Regan

I am writing to express profound disappointment with the Biden EPA’s record on pesticide regulation. Bayer/Monsanto just announced that it would voluntarily cancel “residential” uses of glyphosate products, “exclusively to manage litigation risk and not because of any safety concerns.” If the past is prologue, EPA will accept Bayer’s voluntary cancellation of residential uses and make no findings that could affect other uses (e.g., agricultural) of glyphosate. The company refers to its action as “risk mitigation”—that’s risk to the company’s profitability, economic viability, and shareholder investment, not public health or environmental protection. Voluntary actions by the companies are highly compromised and do not include agency determinations or findings—allowing false claims of safety, a shield from liability, and unencumbered international marketing.

The administration began with high hopes for the environment. Combating climate change is a priority. On his first day in office, President Biden issued an executive order, “Modernizing Regulatory Review,” that appears to establish a new framework promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations.

But what’s happening at EPA? EPA is allowing the pesticide industry free rein to regulate itself based on financial risks instead of the hazards to health and environment that the law requires to drive decisions. Accepting a voluntary cancellation without a rigorous review of the science and the threats will only serve to highlight EPA’s failure to correct dangerous decisions made under the Trump administration. EPA, to date, has not corrected actions on chlorpyrifos, atrazine, dicamba, or neonicotinoids that allow poisoning to continue.

A report by the Office of the Inspector General for EPA “EPA Deviated from its Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision,” concludes that scientific analyses by the agency were altered to favor top Trump administration officials’ policy choices in the 2018 reapproval of the highly toxic and problematic pesticide dicamba, as the Trump administration executed a wholesale assault on scientific integrity in federal decision making. Where is the Biden EPA correction of Trump policy?

An article in The Intercept reveals how far EPA’s credibility has slipped, in view of sloppy or corrupt science, a well-greased revolving door between EPA and industry, responsiveness to political pressure from pesticide companies, and actions that lag behind other countries. If EPA is to fulfill its statutory responsibilities, it must reverse these trends, re-examine Trump-era decisions, and act on behalf of the public and the environment.

EPA must not continue to allow pesticide manufacturers to regulate themselves based on financial risk. While they may have been forced in the courts to pay damages for certain uses—generally those where exposure to specific humans can be proven—these same pesticides continue to harm others, from neighboring chemical-intensive and organic farmers, to those living near production plants and those with pre-existing conditions, to bees and frogs, to consumers. When a company seeks to voluntarily cancel uses of a pesticide, EPA should immediately suspend all registrations and begin cancellation proceedings for all uses.

Please take the following actions:

– Adopt conflict-of-interest policies that eliminate the revolving door between EPA and the pesticide industry.

– Re-examine Trump-era decisions to allow use of dangerous pesticides and act on behalf of the public and the environment.

– Stop the self-regulation of pesticide manufacturers based on financial risk. A proposal to voluntarily cancel uses of a pesticide should trigger immediate suspension and cancellation proceedings for all uses.

Thank you for your immediate attention to this critical public health and environmental issue.

(Beyond Pesticides, August 6, 2021) The organization Public Employees for Environmental Responsibility (PEER) has filed complaints with the U.S. Environmental Protection Agency’s (EPA’s) Office of the Inspector General (OIG) on behalf of four EPA whistleblower scientists. The scientists maintain that during the Trump administration, risk assessments for both new and existing chemicals were improperly changed by agency managers to eliminate or reduce calculations of risks; further, they assert that some of this behavior at EPA is ongoing. Beyond Pesticides recently covered a report in The Intercept, written by Sharon Lerner, that examined the multiple aspects of undue industry influence on the regulation of pesticide chemicals. The PEER complaints address regulation of other kinds of toxic chemicals, but Beyond Pesticides maintains that some of the problems the whistleblowers identify hold true for EPA’s Office of Pesticide Programs, as well.

Appropriately enough, the nation again recognized National Whistleblower Appreciation Day on July 30. In 1989, Congress established the Whistleblower Protection Act (WPA) to protect federal employees who report lawbreaking or other violations of rules or regulations; waste of funds; abuses of authority; gross mismanagement; or substantial and specific danger to public health or safety. In 2012, Congress passed the Whistleblower Protection Enhancement Act (WPEA) to expand and strengthen such protections. Despite these protections, these four have been subjected to reprisals for their multiple expressions of concern about dysfunction at EPA, and in the Office of Chemical Safety and Pollution Prevention, in particular.

Ms. Lerner’s coverage of the whistleblowers’ charges, in The Intercept’s July 2 piece, “Whistleblowers Expose Corruption in EPA Chemical Safety Office,” reports that the four “said that they told colleagues and supervisors within the agency about the interference with their work. Each of the scientists also filed complaints with either the EPA’s Inspector General or the Office of Science Integrity, which has pledged to investigate corruption within the agency. But because most of their concerns remained unaddressed months after they disclosed them — and because, in each case, the altering of the record presented a potential risk to human health — the scientists said they felt compelled to make their complaints public.”

EPA is tasked broadly with protection of human and environmental health; this mission flows to its subordinate divisions, as well. In 1976, Congress created the Toxic Substances Control Act (TSCA) to protect the public from “unreasonable risk of injury to health or the environment” by regulating the manufacture and commercial sale of chemicals. Several categories of chemicals were exempted from regulation through the law, such as those in tobacco products, pesticides (regulated by the 1947 Federal Insecticide, Fungicide, and Rodenticide Act, or FIFRA), food, and cosmetics.

Because TSCA had proven relatively ineffective at protecting the public from chemicals in myriad consumer products, an update to it, the Lautenberg Chemical Safety Act, was adopted in 2016. It sought to strengthen protections by mandating safety reviews, including for chemicals new to the market; increase transparency about information on subject chemicals; enhance EPA authority to require testing; reduce companies’ ability to claim chemical information as propriety or confidential and thus, withhold it from regulators; and explicitly protect vulnerable parts of the population, such as pregnant people and children, among other features.

The law gave rise to a new division within EPA: the New Chemicals Division (NCD), which operates within the Office of Pollution Prevention and Toxics (OPPT). OPPT functions under the aegis of EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP), as does the OPP (Office of Pesticide Programs), which is responsible for evaluating and registering all pesticides. (See the organizational chart here.)

The four whistleblowers worked under OCSPP (and NCD), which are supposed to evaluate risk assessment studies to gauge a new (or existing) chemical’s potential risk to humans. Such assessments can lead the agency to place limits on a chemical’s use or to ban it entirely. The four have reported that civil service managers at EPA, during the term of the Trump administration and continuing to today, have engaged in corrupt and unethical practices, such as regularly accessing risk assessments completed by staff scientists in order to, variously:

• remove language that identifies potential adverse effects, including developmental toxicity, neurotoxicity, mutagenicity, and/or carcinogenicity
• revise conclusions in risk assessment reports significantly to indicate no toxicity concerns despite data to the contrary
• reassign risk assessment work to less-experienced employees so as to remove content whose inclusion would protect human health and/or to secure sign-offs on faulty or inadequate assessments

Such activities are not only unethical and corrupt; it is downright dangerous to distort or withhold information about the kinds and degrees of risk of chemicals that may enter the materials stream and environment. In its website reporting on the matter, PEER writes, “In every case where this type of interference has occurred, the revised assessment was no longer as protective of worker safety and the environment. Moreover, the resulting Material Safety Data Sheets lack information vital to prevent harmful exposures, such as proper handling procedures, personal protection needed, accidental release measures, first aid, and firefighting measures.”

According to Richard Denison, PhD, lead senior scientist at the Environmental Defense Fund (EDF) and presenter in a webinar offered by PEER on July 28 (recorded and available soon via the PEER website and its YouTube channel), the NCD is a “black box” that courts excessive confidentiality claims from industry, withholds information from the public, and has an “insular, secretive culture” that works against the mission of EPA and the interests of the people. He asserted that often, the “only parties in room when decisions are made are EPA and chemical industry people,” adding how striking it is that decisions on chemicals cited in the whistleblowers’ complaints all fell in favor of industry.

PEER Director of Science Policy Kyla Bennett, PhD, a scientist and attorney formerly with EPA, adds, “These alterations of risk assessments are not just artifacts of the Trump administration; they are continuing on a weekly basis. All of these altered assessments need to be pulled back and corrected in order to protect both workers handling chemicals and the American public.” In the webinar, she mentioned that since these first four whistleblowers came forward, more are emerging. These four were very upset and having trouble sleeping; one “did not want to be the reason for the next PFOA to be out on the market, killing people.”

The updated TSCA requires that a company proposing to manufacture or import a new chemical provide to EPA a premanufacture notice at least 90 days before manufacture or importation commences. Both Dr. Denison and Dr. Bennett noted that evaluating a new chemical within that time frame is a nearly impossible task, not least because NCD scientists are often asked to evaluate new chemicals with insufficient, or sometimes entirely missing, data. Dr. Bennett explained: according to the whistleblowers, staff are sometimes given very little information to work with — sometimes as little as the name of a chemical and a summary paragraph from an industry study. Thus, staff members are sometimes forced to do what are called “desk audits” — assessments based on industry-produced studies to determine safety. In these cases, the scientists often end up looking at structurally similar chemicals to arrive at some conclusion about safety.

The whistleblowers report extreme pressure to sign off on inadequate evaluations, and say that staff are rewarded for doing so. When, as these four did, agency scientists have refused to do that, the assessments have been taken away from them and given to less-experienced employees who would. In addition, staff who have “blown the whistle” by reporting incidences of what the WPA specifically spells out — “violations of rules or regulations; abuses of authority; gross mismanagement; or substantial and specific danger to public health or safety” — have suffered reprisals, including functional reassignment or demotion.

National Public Radio’s “Science Friday” program spoke with two of the whistleblowers and with Sharon Lerner, author of The Intercept articles of June 30, “The Department of Yes,” and the July 2 Whistleblowers Expose Corruption in EP Chemical Safety Office. Science Friday reported whistleblower allegations in its coverage, EPA Whistleblowers Allege “Atmosphere of Fear.” As the whistleblowers wrote in a submission to both The Intercept and the office of Representative Ro Khanna of California, “The Office of Chemical Safety and Pollution Prevention is broken. . . . The entire New Chemicals program operates under an atmosphere of fear — scientists are afraid of retaliation for trying to implement TSCA the way Congress intended, and they fear that their actions (or inactions) at the direction of management are resulting in harm to human health and the environment.”

The net, as reported by Ms. Lerner, is that “EPA managers [have] removed information about the risks posed by dozens of chemicals.” She wrote, “On several occasions, information about hazards was deleted from agency assessments without informing or seeking the consent of the scientists who authored them. Some of these cases led the EPA to withhold critical information from the public about potentially dangerous chemical exposures. In other cases, the removal of the hazard information or the altering of the scientists’ conclusions in reports paved the way for the use of chemicals, which otherwise would not have been allowed on the market.”

During the July 28 webinar, Dr. Bennett commented that some career staff at EPA — and in particular, in NCD, have been “captured by industry.” She asserts that this is true not only of political appointees, but also, of career managerial staff, and not only during the Trump administration. She said it is a bipartisan problem that has occurred in the Bush, Clinton, and Obama administrations.

PEER reports that over the past few months, EPA scientists in the NCD have raised objections to the kinds of actions alleged in the complaints, even filing complaints under EPA’s Scientific Integrity Policy — the only significant results of which have been harassment of the scientists by the managers named in the complaints. PEER’s filing with the EPA OIG requests that the office “identify all the alterations and restore the correct risk information.”

PEER adds that “many of the altered risk assessment documents have been overwritten and intermediate comments have been erased in violation of EPA’s Records Management Policy.” PEER is calling for the removal, by the Inspector General, of any civil service managers found responsible for these infractions and violations. In PEER’s website coverage, Dr. Bennett wrote, “EPA’s lack of accountability for scientific misconduct poses a direct danger to public health. Inside EPA, scientific integrity has become an oxymoron and a cure will require a complete overhaul.”

EPA issued a statement in response to The Intercept’s query on the PEER complaint: “EPA takes seriously all allegations of violations of scientific integrity. EPA’s scientific integrity official and scientific integrity team members will thoroughly investigate any allegation of violation of EPA’s scientific integrity policy that they receive and work to safeguard EPA science. Additionally, EPA is currently reviewing agency policies, processes, and practices to ensure that the best available science and data inform Agency decisions. EPA is committed to fostering a culture of evaluation and continuous learning that promotes an open exchange of differing scientific and policy positions. Additionally, retaliation against EPA employees for reporting violations alleged to have occurred will not be tolerated in this administration. EPA leadership are reviewing these complaints, and any appropriate action will be taken.”

Yet, Ms. Lerner reports that although complaints to the OIG are typically kept confidential, somehow, “many mangers in the Office of Chemical Safety and Pollution Prevention had somehow obtained a copy of the whistleblowers’ allegations. ‘The fact that EPA released our clients’ names is inappropriate and troubling,’ said [Dr.] Bennett. ‘They’ve been put in an incredibly uncomfortable situation. This gives the managers the chance to circle the wagons trying to go after them.’”

Executive Director of PEER Tim Whitehouse, JD, maintained (in the July 28 webinar) that politics has overtaken professionalism among managers at EPA, and that managerial interference in the evaluations of potentially toxic chemicals is having real-world impacts on communities, livelihoods, and the health of populations. The risks may be especially acute for workers, in industry and agriculture, who cannot know the real risks of chemicals with which they may be working because of this corrupt activity at EPA.

He further noted that, although more than 20 federal agencies have scientific integrity policies, they are not working because staff in some agencies still cannot raise issues without fear of retaliation. Mr. Whitehouse adds that the Biden administration is reviewing these policies to improve them, but that unless there are enforcement measures that hold managers accountable, even this will not help. It will, he maintains, take new EPA Administrator Michael Regan, new Principal Deputy Assistant Administrator for Chemical Safety and Pollution Prevention Michal Ilana Freedhoff, and Congress to remedy the culture at NCD and to rebuild both the science staff at EPA (which was severely eroded during the Trump administration), and the agency’s morale and culture, which were also badly damaged. He noted that as one of his first acts, Administrator Regan issued a memorandum outlining concrete steps to reinforce EPA’s commitment to science.

Mr. White calls the whistleblowers “brave patriots,” and says it is the job of the advocacy community and the public to push the Biden administration to address this issue of problematic chemicals that are already in the materials stream and environment because “people are being harmed right now.” PEER maintains that, in response to the whistleblowers’ complaints, the OIG should do a comprehensive assessment of what chemicals have been approved to date and are “out there” so that they can be legitimately assessed and pulled from the market if necessary.

Beyond Pesticides has written on other EPA dysfunction, including lack of enforcement of regulation, the “revolving door” between government and industry, the assault on science, and industry influence on scientific integrity. Stay tuned to the Beyond Pesticides Daily News Blog for more on the story of the whistleblowers and what they have revealed, including coverage of other articles expected from The Intercept in coming weeks.

Sources: https://www.peer.org/epa-risk-assessments-doctored-to-mask-hazards/ and https://theintercept.com/2021/07/02/epa-chemical-safety-corruption-whistleblowers/

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

(Beyond Pesticides, August 5, 2021) A recent report by Turtle Rescue of the Hamptons finds Long Island, New York turtles are experiencing higher rates of deadly aural abscesses or ear blisters from pesticide use. Previous research documents the role chemical exposure from environmental toxicants play in inner ear abscess formation among turtles. However, synergism (collaboration) between viral infection and toxic chemical exposure increases aural abscess instances. Considering these infections are taking a toll on the Long Island turtle population, government and wildlife officials must assess how chemical exposure promotes disease development to safeguard human, animal, and environmental health. Karen Testa, executive director of Turtle Rescue of the Hamptons, cautions, “I’m urging Long Islanders to think about how these pesticides are negatively impacting the natural world. Is your perfect green lawn worth the life of a turtle?”

Aural abscesses are painful ear blisters that can grow as big as a golf ball. Medical intervention is necessary to remove abscesses from turtles and treat them with an antibiotic regimen to prevent death. Turtle Rescue facility workers report a staggering 50 percent of turtles currently within their care to have aural abscesses. The percentage of turtles with this diagnosis is much higher than in past years.

Pesticide residues readily contaminate all ecosystems and are prevalent in soils, water (solid and liquid), and the surrounding air. The scientific literature demonstrates pesticides’ long history of adverse effects on the environment, including wildlife, biodiversity, and human health. The impacts of pesticides on wildlife are extensive and expose animals in urban, suburban, and rural areas to unnecessary risks. Pesticides can affect animals through direct or indirect applications like drift, secondary poisoning, and runoff. Some animals could encounter direct spraying, while others may consume plants or prey contaminated with pesticides. According to a 2016 U.S. Environmental Protection Agency assessment, two commonly used pesticides (chlorpyrifos and malathion) are “likely to adversely affect” 97% of species listed under the Endangered Species Act (ESA). Furthermore, a more recent EPA assessment finds the excessive use of the most popular herbicide (weedkiller) glyphosate threatens 93 percent of all endangered species. This EPA announcement occurred only a few days following the agency’s report on atrazine (another commonly used and toxic herbicide) causing harm to more than half of endangered species.

This report demonstrates that exposure to chemical contaminants has implications for turtle health, not only in Long Island but around the world. Chemical contamination promoting disease/viral infection is not a new phenomenon among wildlife. Insects, other terrestrial and aquatic organisms, and marine and terrestrial mammals can all experience weakened immune function from viral and bacteria upon pesticide exposure. For instance, studies find pesticide exposure can limit immune response in honey bees, causing early onset of infection or increased probability of mortality from infection. Reports demonstrate neonicotinoid insecticide exposure impairs honey bees’ ability to groom Varroa mites responsible for a disease known as deformed wing virus (DWV). Additionally, California sea lions are experiencing high rates of urogenital carcinoma (UGC) cancer incidences from the combined effect of toxic “legacy” pesticides like DDT and the viral infection Otarine herpesvirus-1 (OtHV1). According to multiple studies, exposure to the weed killer glyphosate (patented as an antibiotic) changes the bacterial composition of the gut microbiome in cattle, rodents, and honey bees. Like glyphosate, atrazine has an association with gut microbiome disruption, causing sex-specific shifts in microbiota. Atrazine is notoriously associated with endocrine disruption among amphibians and reptiles, resulting in reproductive and behavioral changes. Even among humans, exposure to endocrine-disrupting pesticides impacts hormone regulation promoting metabolic diseases like diabetes.

There are various possible explanations for pesticide exposure to cause adverse health effects among Long Island turtles. A 2004 study supports that organochlorine-induced vitamin A deficiency causes aural abscesses. Past studies find toxic organochlorine compounds like DDT can readily accumulate in turtles and block vitamin A receptors responsible for respiratory tract and inner ear health. The lack of vitamin A absorption causes aural abscesses to form from bacterial infections. Although the U.S. bans most organochlorines, they persist in the environment for many decades. Therefore, turtles can encounter pesticide exposure from contaminated soil and water. Furthermore, current-use pesticides may have the ability to re-release soil-bound organochlorines. This phenomenon is occurring in the French West Indies islands as glyphosate use is causing soil erosion, releasing soil-bound organochlorine chlordecone into the surrounding waters. Another possibility is that current-use pesticides are producing similar impacts on vitamin deficiency among turtles. However, officials must not dismiss other causes of vitamin A deficiency —such as direct dietary deficiency, interference in the gastrointestinal absorption of vitamin A, the presence of other endocrine-disrupting chemicals, or other causes.

Turtles face multiple threats from environmental factors: from motor vehicle/appliance injuries to habitat destruction and overfishing. However, pesticides are ubiquitous and continuously expose these animals’ toxins in conjunction with environmental factors. Turtle Rescue facility workers note that aural abscess incidents are getting worse due to COVID-19. Advocates suggest that with more individuals remaining at home, chemical inputs are increasing, particularly for pesticides like disinfectants and lawn care chemicals. Testa notes, “We are seeing a staggering number of aural abscesses in the turtles that are being brought in to our center. These injuries are adversely affecting wildlife and it’s worse this year. Because of Covid and spending more time at home, homeowners are spraying toxins on their lawns. These chemicals are poisoning our turtles and at the same time, damaging our ecosystem.”

Furthermore, reports indicate that the excessive use of COVID disinfectants (registered as pesticides) harms wildlife. Therefore, the turtle may experience a weakened ability to overcome chemical exposure, thus leaving it vulnerable to disease development. Advocates advise homeowners and landscapers to significantly reduce the number of pesticides applied in and around the home and garden. Instead, homeowners and landscapers alike should rely on non-toxic, organic alternatives.

Chemical contamination is ubiquitous in terrestrial and marine environments. Thus, turtles and other animals can help identify risks to humans by exhibiting signs of environmental threat sooner than humans in the same area. Government and health officials must address chemical pollution before similar declines in human general health, fitness, and well-being. Furthermore, climate crisis implications like melting glaciers present a new concern over the levels of chemical concentrations in waterways from DDT, its metabolites, and other persistent organic pollutants trapped in ice. Toxic pesticide use must end to protect the nation’s and world’s waterways and reduce the number of pesticides that make their way into drinking water. Replacing pesticides with organic, non-toxic alternatives is crucial for safeguarding public health, particularly communities vulnerable to pesticide toxicity. Learn more about the hazards pesticides pose to wildlife and what you can do by visiting Beyond Pesticides’ wildlife program page.

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

Source: Patch