(Beyond Pesticides, November 2, 2021) Cover crops create habitat that draw in pest predators and help mitigate crop injury, finds research published in the journals Agroecosystems and Biological Control from scientists at the University of Georgia. Expanded predator diversity can reduce pest pressure that drives conventional chemical farmers to apply toxic pesticides, and the authors of the study find the practice to be economically viable within these cropping systems. “There’s a motion of change going on where growers are thinking more about using natural systems instead of just using pesticides,” said co-author Jason Schmidt, PhD in a news release. “Producers must use all tools available to make a profit, so if they can promote beneficial insects in the system to aid in pest control,  fewer inputs are needed and that should lead to reduced costs of production. ”

To determine how beneficial cover crops were to cotton production, researchers began with experimental crops established over two years in 2016 and 2017 in Georgia. Twelve cover crops plots were established with crimson clover and rye, while a plot not planted with cover crops was used as a control. Researchers planted the cover crop in early November after the previous cotton crop was harvested, and terminated and rolled the cover crop 2 weeks prior to a May cotton planting. Cover crop residue was sucked up with a reverse leaf blower the scientists created and sampled six times at random locations. Analysis was then conducted on the gut content of the pest predators retrieved in order to determine what pests they were consuming.

Predator communities were found to be much more diverse (7 to 10x more) in cover cropped fields. While the cover cropped fields contained a range of spiders and other predaceous bugs, control fields mostly contained a specific type of beneficial beetle. Researchers found the benefits of cover cropping to be most pronounced in the early spring. But as the cover crop degrades, differences between cover cropped and control plot predator communities began to even out.

“There are early-season benefits of cover crops when cotton plants are small, said Dr. Schmidt. “The cover crop residue forms a complex habitat matrix with cotton seedlings popping out of it and there are insect predators in there that can defend those young plants from pests.” Dr. Schmidt indicates that the change occurs when there is more of the cotton crop above ground than the cover crop.  “Later in the season, you see similar communities. So, even though there’s a little bit of habitat on the ground from those cover crops, it doesn’t seem to matter in terms of the overall community in the system when cotton plants become the primary habitat available.”

A deeper review of the findings show that thrip populations, which can often hinder cotton crops in early growth stages, are mitigated by increased cover cropping. Cover crops also bring in predators that hamper stink bug damage to cotton bolls. An economic analysis found cover cropping to be a cost effective approach comparable in expense to a completely conventional chemically managed system. “These results suggest that conventional growers utilizing cover crops could reduce insecticide inputs through natural reductions in pest pressure, and overall do not incur additional production costs,” reads the study in Biological Control.

The scientists indicate that they will continue their work to better understand the complex interactions that occur between pest and predator in crop fields. “That’s our ultimate goal, understanding the functioning of diversity and the beneficial roles species play in production systems and best harvest these services for production systems, like cotton,” said Dr. Schmidt.

The study’s results are likely to be unsurprising for organic farmers and even many home gardeners that make certain they keep their soil covered with organic matter year-round. Key to soil conservation are practices that minimize soil disturbance, increase plant diversity, and continually keep soil covered with live plants or roots in the ground.

The study results are encouraging in the context of a system primarily reliant on chemical inputs. Termination of the cover crop utilized an unnamed chemical herbicide, for instance. Although herbicides are intended to target plant material, products like glyphosate threaten a broad range of species. A federal biological assessment published late last year found that glyphosate itself is likely to affect 93% of endangered species. Thus a range of predator insects that may have assisted in further, or more sustained pest management may have been killed off by the use of a chemical to terminate the cover crop. Non-toxic cover crop termination options include mowing, or the utilization a roller/crimper machine that bends plant residue uniformly over the surface of soil.

In study after study, results show that creating habitat that increases diversity enhances plant productivity and reduces toxic pesticide use.  Conventional cotton production can utilize these practices and see some ephemeral benefits, but when properly maintained, these practices decrease pest pressure and create more stable ecological systems that provide lasting ecological and economic benefits. To truly break out of a reliance on chemical inputs, conventional systems must move not only towards cover crop diversity, but crop diversity in general, as multi-crop farming practices produce higher yields than monoculture farmlands.

Most organic farmers, required to maintain or improve soil health under organic standards, are already conducting practices that work with natural systems. Help continue to grow organic, so that more farmers will adopt these safer practices, by purchasing organic products whenever possible. To help become part of the organic solution, join Beyond Pesticides today, and support our fight to maintain the integrity of organic standards from attacks by the conventional chemical industry.

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

Source: Agroecosystems, Biological Control, University of Georgia news release

(Beyond Pesticides, November 1, 2021) Join with 37 environmental and health groups, farm organizations, and beekeeper councils, who have delivered a letter to the Environmental Protection Agency (EPA) leaders seeking major reforms in the Office of Pesticide Programs (OPP). They provided a comprehensive list of OPP’s major failures as the lead federal office for pesticide regulation and management, including:

• Allowing chlorpyrifos to stay registered for more than 14 years after health experts and affected farmworkers petitioned for its removal based on its known neurological danger,
• Allowing unlimited use of Roundup (glyphosate) long after it was shown to contribute to deadly non-Hodgkin’s lymphoma in heavy users and it devastated the treasured monarch butterfly, now driven to near extinction in North America,
• Approving hundreds of neonicotinoid systemic insecticides, now the most widespread insecticide in the country where they are decimating honey and native bees and other key pollinators and beneficial species; and
• Registering dicamba in a highly volatile herbicide, a shocking blunder later overruled by a federal court ruling that stated OPP “not only substantially understated the risks …. It also entirely failed to acknowledge other risks, including those it was statutorily required to consider.”

Take action: Tell EPA and Congress that the failed pesticide program needs a new start.

These serious failures have emerged from systemic problems at EPA, through which OPP has undermined the purposes of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (which establishes the registration standards for pesticide use) and the Federal Food, Drug, and Cosmetic Act (FFDCA) (which requires the setting of allowable residues or tolerances on food) by, for example: 

• pushing through “Yes packages” of pesticide registration proposals that are approved because of industry lobbying and political pressure,
• suppressing the scientific opinions of many of its own professionals unless they are consistent with the registrants’ (chemical manufacturers’) goals,
• excessive, outrageous waivers of vital toxicity study requirements and the use of “conditional” registrations by which OPP allows pesticide uses to proceed despite missing key data,
• engaging in what likely is one of the worst “revolving door” situations in the Federal government in which regulatory officials retire from OPP and then work for or consult with the regulated companies,
• willful noncompliance with Section 7 of the Endangered Species Act, which requires proposed registrations to include consultations with the wildlife agencies (Fish and Wildlife Service and National Marine Fisheries Service) to take into account and mitigate potential impacts on our nation’s threatened and endangered species, and
• failure to review and regulate endocrine-disrupting pesticides, as required by the Food Quality Protection Act of 1996, which amended FIFRA and FFDCA.

An urgent need exists for OPP to re-think its application of current standards in law to meet the crises of the day. To do this, the agency must embrace a series of underlying principles to guide its decisions into the future:

1. Use powers under the “unreasonable adverse effects” standard of FIFRA to be more holistic and precautionary. A risk or hazard analysis requires a deeper analysis of costs, including externalities, secondary pest populations, and other factors. When evaluating pesticide registrations, EPA should determine the full range of practices available to achieve submitters’ goals of pesticide registration or reregistration, including chemical and nonchemical strategies. In conducting its risk/hazard assessment to meet its statutory duty, the agency must evaluate the complete pesticide formulation to which the public/environment is exposed, taking into account the active and inert ingredients, contaminants, and metabolites. Mixtures resulting in additive and synergistic effects must be evaluated and, where the full range of data are not available on adverse effects, reasonableness of risk should not be assumed.
2. Conduct proper alternatives analyses. A broader application of the FIFRA “unreasonable adverse effects” standard includes an assessment by the agency of the range of alternatives – non- or least-toxic practices and materials – that could be used to achieve the ultimate agricultural, landscape, or building management goal. Only in doing so can EPA establish findings on whether food can be grown, landscapes can be managed, and quality of life can be achieved without the use of toxic chemicals. OPP’s findings regarding alternatives will be important to: a) incentivizing the market to move to non- and least-toxic alternative practices and products that can eliminate petroleum-based pesticides that contribute to the climate crisis, b) protecting those who are disproportionately at risk, and c) responding to the dramatic decline of biodiversity. Climate change will likely lead to vector-borne illnesses spreading into new areas, and scientists warn that insecticide exposure under warming temperatures is not well understood.
3. Reject corrupt data. OPP should not rely on corrupt data, as documented by the Midwest Center for Investigative Reporting piece in December, 2020. OPP must cancel registrations based on false data and establish a moratorium for future pesticide registrations from manufacturers found to have submitted fraudulent data—until the agency can assure the public that the science supporting pesticide registrations is not corrupt.
4. Apply science of endocrine disruption. OPP must end its failure to meet the agency’s statutory responsibility to fully protect people and wildlife from the dire consequences of exposure to endocrine-disrupting chemicals (EDCs) that affect the full functioning of organisms. More than 50 pesticide active ingredients (more when considering contaminants, “inerts,” etc.) have been identified as EDCs that mimic the action of a naturally produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; block hormone receptors in cells, thereby preventing the action of normal hormones; or affect the synthesis, transport, metabolism and excretion of hormones, thus altering the concentrations of natural hormones. Endocrine disruptors have been linked to attention deficit hyperactivity disorder (ADHD), Parkinson’s and Alzheimer’s diseases, diabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorders, childhood and adult cancers, and other metabolic disorders. OPP has a statutory responsibility to look at the explosion of these diseases, including multigenerational epigenetic effects, analyze the role pesticides play in these diseases, and take protective regulatory action.
5. Engage in holistic reform. OPP should aggressively implement the Presidential Memorandum for the Heads of Executive Departments and Agencies (January 20, 2021) regarding Modernizing Regulatory Review, which 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. It sets the stage for the urgent adoption of agency policy across government to seriously confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism) and those with comorbidities/underlying health conditions. If OPP’s pesticide registration decisions are to be consistent with this memorandum, it must facilitate the widespread adoption of organic farming and land care practices, which reduce greenhouse gas emissions, sequester carbon in the soil, and protect the lives of essential workers, farmworkers, and fenceline communities.

Take action: Tell EPA and Congress that the failed pesticide program needs a new start.

EPA and U.S. Congress

EPA’s Office of Pesticide Programs (OPP) has failed miserably at protecting human health and the ecosystem and needs a complete re-set, with a focus on using statutory authorities to meet today’s crises and ensure a future for the Earth’s inhabitants. The agency can no longer continue to ignore science showing the impacts of pesticides to all life. I join with the 37 environmental and health groups, farm organizations, and beekeeper councils, who have delivered a letter to EPA seeking major reforms at OPP. I am asking EPA to:

1. Use powers under the “unreasonable adverse effects” standard of FIFRA to be holistic and precautionary.
2. Conduct proper alternatives analyses using organic practices as a standard—providing a basis for determining reasonableness of risk, and establishing findings on whether food can be grown, landscapes can be managed, and quality of life can be achieved without the use of toxic chemicals.
3. Reject corrupt data. Cancel registrations based on false data and establish a moratorium for future pesticide registrations from manufacturers found to have submitted fraudulent data.
4. Apply science on endocrine disruption. More than 50 pesticide active ingredients (plus contaminants, “inerts,” etc.) have been identified as endocrine-disrupting chemicals that mimic naturally produced hormones, block hormone receptors in cells, or affect the synthesis, transport, metabolism and excretion of hormones. OPP has a statutory responsibility to look at the explosion of diseases resulting from endocrine disruption, including multigenerational epigenetic effects, analyze the role pesticides play in these diseases, and take protective regulatory action.
5. Engage in holistic reform. OPP should aggressively implement the Presidential Memorandum for the Heads of Executive Departments and Agencies (January 20, 2021) regarding Modernizing Regulatory Review, directing 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. If OPP’s pesticide registration decisions are to be consistent with this memorandum, it must facilitate the widespread adoption of organic farming and land care practices, which reduce greenhouse gas emissions, sequester carbon in the soil, and protect the lives of essential workers, farmworkers, and fenceline communities.

Thank you for your attention to these critical concerns. I urge that these issues, summarized above (see bp-dc.org/EPAoppReform), are urgently addressed to respond in a meaningful way to the existential public health and environmental crises facing the nation and world.

(Beyond Pesticides, October 29, 2021) As more than 200 of the world’s countries convene, starting October 31 in Glasgow, Scotland, for the 26th U.N. Climate Change Conference (COP26), it is important to sound the alarm unequivocally. We are in a climate emergency. This reality was confirmed, yet again, by the U.N. Intergovernmental Panel on Climate Change (IPCC) August 2021 release of part of its sixth report, from Working Group I, Climate Change 2021: The Physical Science Basis. The other parts of the report, to be issued over the next few months, are new assessments from Working Group II on impacts, vulnerability, and adaptation, and from Working Group III on mitigation/averting further climate change. Below we address the urgent need to eliminate petroleum (fossil fuel)-based pesticides and fertilizers in agriculture and land management (parks, playing fields, rights-of-way, and open space) and put in place an urgent and strategic transition to organic practices without being distracted and diverted by claims of “regenerative” practices that do not meet the crisis in a meaningful way.

Headline takeaways from this first report are that, failing immediate and large-scale reductions in greenhouse gas emissions:

• the planet’s climate will likely blow by the much-vaunted 1.5°C threshold (average global temperature increase over the pre-industrial average) by 2040
• impacts of the heating atmosphere and oceans will heighten significantly, including more-intensified and/or more-frequent heat waves, droughts, storms with massive rainfall, flooding, and wildfires (all of which cause additional downstream health, environmental, property, and commerce disruption, dislocation, and destruction)
• the possibilities of intensified climate forcings and thresholds/tipping points being breached are rising significantly

The task for Working Group I was to assess “new scientific evidence relevant for a world whose climate system is rapidly changing, overwhelmingly due to human influence. The five IPCC assessment cycles since 1990 have comprehensively and consistently laid out the rapidly accumulating evidence of a changing climate system, with the Fourth Assessment Report in 2007 being the first to conclude that warming of the climate system is unequivocal. Sustained changes have been documented in all major elements of the climate system: the atmosphere, land, cryosphere, biosphere and ocean. Multiple lines of evidence indicate the recent large-scale climatic changes are unprecedented in a multi-millennial context, and that they represent a millennial-scale commitment for the slow-responding elements of the climate system, resulting in continued worldwide loss of ice, increase in ocean heat content, sea level rise and deep ocean acidification.” (See page 54 of the Physical Science Basis report; for details on the changes since the fifth IPCC report, see page 51).

For readers who may look at the report: it has adopted an “architecture” that includes several average surface temperature scenarios (based on the nexus of multiple influences), from low to very high emissions resulting in global average temperature increases of 1.9°C, 2.6°C, 4.5°C, 7.0°C, and 8.5°C. It also attaches to any projections and assumptions it includes in its analysis the attendant degree of confidence with which it states them (e.g., low, medium, or high). Any conclusions or analytical forecasts the reports makes exist within the contexts of these considerations. An example from the report: “This Report reaffirms with high confidence the . . . finding that there is a near-linear relationship between cumulative anthropogenic CO2 emissions and the global warming they cause.”

All of the work done by Beyond Pesticides and others — on the importance of moving agriculture and land management systems away from conventional, chemical-intensive approaches (via synthetic pesticides and fertilizers) and to organic practices — happens within the meta-context of the climate emergency, and is not unrelated. A 2019 IPCC report on climate and food security identifies that the food system, which includes conventional agriculture dominantly, is responsible for 25–30% of total greenhouse gas (GHG) emissions worldwide. Multiple strands of Beyond Pesticides’ work converge in the climate issue: the climate, air quality, health, and soil impacts of synthetic fertilizers; declining soil health, caused by conventional growing practices that degrade soil’s ability to drawn down and hold carbon; collapsing biodiversity; and emissions, water, air, and ecosystem impacts of large livestock operations, among others.

Agricultural emissions come from multiple sources, as reported by the Institute for Agriculture and Trade Policy (IATP): crop and livestock activity; food processing, transportation, and retail operations; and supply chain activities, such as the manufacture of pesticides, fertilizers, and fuels. Agricultural emissions alone increased by 10% from 1990 to 2019, with this breakdown: CO₂ emissions rose by 16.2%, methane by 14.4%, and nitrous oxide by 7.3%. Further, says IATP, much of agricultural GHG emissions is “linked to industrial systems of crop production and the rise of factory farm systems of animal production.” Ben Lilliston, writing for IATP and using data from the U.S. Environmental Protection Agency (EPA) for 2017, found that the top three agricultural contributors to GHG emissions were soil management, enteric fermentation, and manure management.

Factory farms and CAFOs (concentrated animal feeding operations) are virtually always conventionally operated. They use massive amounts of synthetic fertilizers and pesticides on silage crops, generally treat animals poorly, are a source of development of antibiotic resistance, and generate animal waste and “enteric fermentation” (which produces methane) on a huge scale. These operations often use enormous lagoons to “store” animal waste; there, it decomposes anaerobically and releases methane and volatile organic compounds (VOCs) into the atmosphere. Management of animal waste at CAFOs contributes mightily to GHG emissions, environmental degradation, and human health issues.

The IPCC 2021 report notes an alarming metric on methane, finding “a resumption of atmospheric methane concentration growth since 2007. . . . faster growth over 2014–2019 . . . and growth since 2007 . . . largely driven by emissions from the fossil fuels and agriculture (dominated by livestock) sectors.” Methane (CH₄) is a potent GHG with 80–85 times the planet-heating impact of carbon dioxide over its first 20 years in the atmosphere.

The Environmental Defense Fund (and many others) have recognized that “at least 25% of today’s warming is driven by methane from human actions. One of the largest methane sources is the oil and gas industry.” It is these industries that provide the petrochemical feedstocks for the production of synthetic fertilizers and pesticides. As the role of this sector in the climate emergency has become increasingly recognized over the past decade-plus, these industries have come to see fertilizer, pesticide, and plastics production as important markets for its products.

The use of synthetic fertilizers is a particular and noxious contributor to the rising planetary temperature. This happens largely through these products’ emissions of nitrous oxide, or NO_x — another potent greenhouse gas that also pollutes the air and feeds the development of ozone. NO_x is roughly 300 times as potent in trapping heat as CO₂. (In addition, runoff of high-nitrogen, synthetic fertilizers contaminates water bodies and contributes to eutrophication.) Nitrous oxide levels have increased, compared to pre-industrial levels, by 20% from all sources. Earlier in 2021, Beyond Pesticides asserted, “The excess nitrogen in these fertilizers is . . . driving global nitrous oxide emissions dangerously high, exacerbating the climate crisis.”

Many organic agricultural and land management practices, on the other hand, do not exacerbate emissions and related problems, but actually mitigate them. Under organic management, healthy soil can absorb and store 1,000 pounds of carbon per acre foot of soil annually. This translates to about 3,500 pounds of carbon dioxide per acre drawn down from the air and sequestered into organic matter in soil. (It is noteworthy that use of synthetic fertilizers actually compromises the carbon-capture ability of some kinds of terrain, such as salt marshes.) A fact often overlooked by policy makers in generating climate strategies is that carbon-sequestering soil practices are federally mandated in certified organic agriculture.

In addition, the healthy soils nurtured by organic practices make landscapes and crops more resilient, buffering them from some impacts of the warming climate, such as flooding and drought, and supporting healthier ecosystems in both the soil and its surrounds. The California Certified Organic Farmers Foundation’s policy report details why and how organic agriculture is key to tackling the climate crisis, and focuses on the importance of organic integrity to ensure that toxic pesticides and synthetic fertilizers have no part to play in the future of agriculture.

Organic regenerative practices that support soil health (and carbon capacity) include use of cover crops and compost; reduced tillage of the soil; interplanting, crop rotation, and avoidance of monocropping large parcels; shifting some production to perennial crops; and others. Please note, in that last sentence, the use of “organic regenerative.” This is very intentional, and points to an issue that Beyond Pesticides has covered and on which it continues to educate and advocate. “Regenerative” agriculture that is not organic is not a meaningful step forward, and has become a red herring of sorts.

“Regenerative” is a term that has been sometimes sloppily, and sometimes intentionally, tossed around without benefit of clear definition or any regulation. In the Spring of 2021 Beyond Pesticides wrote, “‘Regenerative’ agriculture is widely considered to be a solution for reducing or even reversing [climate] impacts. Unfortunately, a movement by promoters of chemical-intensive agriculture has fooled some environmentalists into supporting toxic ‘regenerative’ agriculture. The so-called ‘regenerative agriculture’ promoted by these groups ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels — as key ingredients [not only for these products, but] as well, for the heat and energy driving chemical reactions. It is important to see through this deception.”

Two examples of industry’s push on “regenerative” agriculture: (1) the Soil Health Institute’s launch of the U.S. Regenerative Cotton Fund, “an initiative to draw down 1 million metric tons of CO₂e from the atmosphere by 2026 through increased adoption of regenerative soil health practices by cotton producers,” and (2) General Mills’s 2019 announcement of a commitment to convert one million acres of farmland to regenerative practices by 2030.

The “no till” strategy started as an approach to limiting soil erosion, and can be, within organic management, a useful strategy to protect soil structure and microorganisms. However, its promotion in some quarters has been “code” for reducing tillage and using chemical herbicides. Indeed, a recent study found that “While no-till agriculture can conserve soil and energy, it relies primarily on herbicides for weed control and to terminate cover crops and perennial crops. . . . When farmers are no longer using tillage to disrupt weed growth, they typically use more herbicides to control weeds.”

Regenerative agriculture that is not also organic — the National Organic Standards prohibit the use of synthetic pesticides and fertilizers — is not a meaningful advance on climate or other environmental concerns. In February 2021, Beyond Pesticides wrote, “As aptly stated by Jeff Moyer of the Rodale Institute, ‘We believe that in order to be regenerative, you have to start by being organic. It’s a little disingenuous to say you can regenerate soil health and sequester carbon and still use nitrogen fertilizers and synthetic pesticides. What you’re really saying is equivalent to saying, “I want to be healthy as a person, but I still want to smoke cigarettes.”’” Beyond Pesticides has repeatedly called out the importance of organic regenerative approaches; see its coverage of the 2021 Rockefeller Foundation report on the true cost of food, and its reporting on unintended consequences of “no till” in Vermont.

A high-level example of well-intentioned policy that lacks holistic awareness is a feature of the Lima-Paris Action Agenda, an international initiative recognized by the Paris Climate Accord. As reported by Californians for Pesticide Reform, “Countries around the world are now recognizing the unique role that agriculture can play in sequestering carbon. Nearly the entire European Union joined a host of nations in signing onto the international initiative 4 per 1000. . . . The initiative recognizes that a 4% annual growth rate of soil carbon stock would make it possible to stop the present increase in atmospheric CO₂. Countries are called on to do this by scaling up regenerative farming, grazing and land-use practices with a focus on soil health.”

Another example is the carbon market approach embodied in President Biden’s Climate 21 Project, according to Beyond Pesticides, which wrote that it does not “adequately and comprehensively respond to the current and looming interconnected threats to public health and the environment. The focus on carbon to the exclusion of a holistic approach that addresses complex, life-supporting, biological communities allows the continuation of disproportionate hazards to people of color and communities living adjacent to toxic sites. The mechanisms of carbon trading or the purchasing of carbon offsets under consideration do not establish an end date for admittedly unacceptable materials and practices, nor do they ensure a transition to life-sustaining practices.”

A final, egregious example from the U.S. Department of Agriculture is Agriculture Secretary Tom Vilsack’s current push for a “market-oriented, incentive-based, voluntary system” to address climate and other issues in agriculture. Anyone familiar with industrial agriculture will recognize that language as promotion of chemical-intensive agriculture that focuses far more on profit and production than on precaution or the climate emergency. Secretary Vilsack recently touted his “Coalition for Productivity Growth” as a response to the European Union’s “Farm to Fork” initiative that forwards organic agriculture for multiple reasons, including addressing the climate crisis. Beyond Pesticides Executive Director Jay Feldman commented, “It is fine to create a structure for communication and coordination, but it is unacceptable to trash an international effort to transition to organic.” By contrast, a co-author of a 2020 study on agriculture’s NO_x contributions to accelerating climate change, wrote, “Europe is the only region in the world that has successfully reduced nitrous oxide emissions over the past two decades.”

Industry, policy makers, and even some in the advocacy world continue to approach the climate crisis as if it were not the most urgent and existential issue humans face, and as if there is, somehow, plenty of time to solve it. There is not! As the IPCC report all but says outright, humanity is on the precipice of climate chaos. Though the climate scientists who worked on this report do not say so in so many words (such messages will likely arrive with the reports from Working Groups II and III), the bottom line is clear. Humans have nearly run out of time to tackle this emergency with the boldness required to preserve a climate close to that to which all life is adapted. Even a 2°C increase in average global temperature — to which we are easily headed, and beyond — would have massive repercussions for Earth’s natural and human systems.

Earlier in 2021 Beyond Pesticides wrote — and it is truer than ever — that the climate emergency and the related network of environmental and health issues are “existential crises that threaten life [that,] to be successfully thwarted, require a meaningful holistic strategy that commits our nation to ending our fossil fuel-based economy and use of petroleum-based materials that release harmful levels of carbon and noxious gases (including greenhouse gases/GHG) into the environment. Just as there are proposals to end production of the combustion engine and move to electric vehicles, we must demand that agriculture — across the board and on an expedited five-year schedule — shift to organic practices, whose standards are already codified in federal law. Organic production and handling practices have a proven, commercially viable track record, and both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. And importantly, the data show that this sector of agriculture is now operating without sacrificing productivity or profitability. The only problem: the vested economic interests in the petroleum and chemical industry are holding on to the status quo.”

Among the prefatory efforts leading to COP26 is a voluntary one led by the U.S. and the UAE (United Arab Emirates); more than 30 countries have joined the effort, as have the U.N.’s Food and Agriculture Organization and the Bill & Melinda Gates Foundation. Operating under the moniker “Agriculture Innovation Mission for Climate (AIM),” the initiative’s goal is “to catalyze greater investments in climate-smart agriculture and global food systems innovation to enhance resilience in the often-overlooked agricultural sector to climate change impacts and create co-benefits of climate action.”

As countries meet in Glasgow, they will wrestle with all manner of complex scientific, political, and economic challenges in trying to hammer out agreements that are bold enough and rapid enough to meet the scale and scope of the climate emergency. According to Beyond Pesticides, incremental, narrow, and/or glacially paced approaches will not do. Leaders must insist on ambitious and binding emissions targets and timelines, and must plan and deploy, as part of the massive climate work ahead, the transition to organic systems, beginning immediately.

Source: https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf

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

(Beyond Pesticides, October 28, 2021) A study published in Frontiers in Environmental Science finds the popular herbicide glyphosate negatively affects microbial communities, indirectly influencing plant, animal, and human health. Exposure to sublethal concentrations of glyphosate shifts microbial community composition, destroying beneficial microorganisms while preserving pathogenic organisms. Glyphosate is the most commonly used active ingredient worldwide, appearing in many herbicide formulas, including Bayer’s (formerly Monsanto) Roundup®. The use of this chemical has been increasing since the inception of crops genetically modified to tolerate glyphosate over two decades ago. The toxic herbicide readily contaminates the ecosystem with residues pervasive in both food and water commodities. In addition to this study, the scientific literature commonly associates glyphosate with human, biotic, and ecosystem harm, as a doubling of toxic effects on invertebrates, like pollinators, has been recorded since 2004. The authors caution, “[O]utbreaks of several animal and plant diseases have been related to glyphosate accumulation in the environment. Long-term glyphosate effects have been underreported, and new standards will be needed for residues in plant and animal products and the environment.” With an increasing number of reports on the relationship between glyphosate and human health, including potential effects on the human gut microbiome, advocates are calling on global leaders to eliminate chemical use.

The report investigates the indirect impacts that glyphosate-based herbicides (GBHs) have on plant, animal, and human health. Using the scientific literature, researchers evaluate shifts in microbial community composition among different habitats. These habitats include soils for plants and the gut microbiome for animals and humans. Authors focused on three main issues: the accumulation of glyphosate in the ecosystem (including animal and plant products), the effects the chemical has on microbes in soils, animals, and humans, and whether impacts on microbes induce subsequent adverse effects on plants, animals, and humans.

The report begins with a discussion of glyphosate’s fate in soil and water. The chemical breaks down into its primary metabolite AMPA (aminomethylphosphonic acid) in a matter of a few days. However, clay and organic matter in soils absorb both glyphosate and its metabolite, slowing the breakdown process and making both compounds more ecologically pervasive. Soil type, environmental conditions, and previous exposure of soil microorganisms to glyphosate determine the rate at which the chemical compounds break down. Clay and organic matter in soils do not absorb all chemical constituents, as residues make their way into groundwater during heavy rainfall and contaminate surface water via runoff and erosion. North and South America have the highest concentrations of glyphosate in surface waters. However, rain, treated wastewater, drinking water, and the surrounding air contain glyphosate and AMPA residues.

The authors assess the fate of glyphosate residues on plant and animal products finding the U.S. Environmental Protection Agency (EPA) established Maximum Residue Limits (MRLs) for these products in 1974. However, the agency recently began incorporating AMPA residues in MRL evaluations for food and feed products from glyphosate biotransformation. Overall, the MRL of glyphosate and AMPA in products differs depending on product type and regulatory practices. In animal feed, MRL levels increase over time to compensate for more pervasive glyphosate use. A Danish study finds chemical concentrations in animal feed are occasionally high enough to cause malformations and infertility among swine, botulism among cows, and pathogenic bacterial disease among chickens. Furthermore, studies find these farm animals ingesting glyphosate-contaminated fodder excrete the chemical via urine and feces, with up to 96 percent of the compound present in farm animal urine samples. Even among domestic cats and dogs, glyphosate concentrations in urine is relatively high due to high chemical levels in pet food, similar to farm animal fodder. In human urine samples, 90 percent of farmworkers, 60 to 95 percent of the general U.S. population, and 30 percent of newborns have high concentrations of glyphosate.

The report also covers the impact glyphosate has on microbes in soils, animals, and humans. Glyphosate acts on the shikimate pathway, present in plants, fungi, bacteria, archaea, and protozoa. Thus, many taxonomic groups of microorganisms are sensitive to glyphosate. There are two classes of microbial reactions to glyphosate exposure: glyphosate sensitive class I EPSPS and glyphosate-tolerant class II EPSPS. Additionally, classes III and IV include some bacterial and archaeal (single cell organisms that are not bacteria) microbes associated with glyphosate resistance. Class I and II reactions occur more frequently as intensive and chronic pesticide use renders some bacteria and fungi resistant to glyphosate. These microbes can become resistant by decreasing cell wall permeability or altering the EPSPS enzymatic binding sites. For instance, the study finds glyphosate-resistant bacterial strains like E. coli and Pseudomonas alter gene function to enhance the outflow of glyphosate from the bacterial cell. Thus, the authors suggest this resistance mechanism encourages cross-resistance against antibiotics for pathogenic bacterial species like E. coli and Salmonella. The authors note that 50 years of extensive glyphosate use also increased human/animal pathogenic bacteria to break down the chemical compound. Bacillus species like B. cereus and B. anthracis can detoxify glyphosate, breaking down the chemical compound. However, the process can increase B. anthracis (the causative proxy of toxic anthrax) concentrations in the environment over time.

Lastly, the authors review the indirect impacts that glyphosate has on plant, animal, and human health, as these species rely on the diversity and stability of microbial communities. Microorganisms travel through the food chain, interconnecting the health of all organisms. For plants, glyphosate and AMPA indirectly impact plant health through changes in the endophytic and rhizosphere microbiome responsible for plant health and growth, reducing antimicrobial production against pathogens. Furthermore, glyphosate can negatively affect plant nutrient uptake by disrupting microbes that make plant nutrients like nitrogen, phosphorus, copper, iron, manganese, and zinc available. Among insects, pollinators like bees can experience severe negative impacts on gut health from glyphosate exposure. The chemical can alter microbes in the gut, resulting in disease outcomes that reduce pollinator fitness. These diseases include deformed wing syndrome (DWS) and increased susceptibility to varroa mites. In humans and animals, a shift in microbial communities within the gut can result in dysbiosis, causing an imbalance between beneficial and pathogenic gut microorganisms. Dysbiosis affects the function of the gastrointestinal tract, limiting the ability to prevent disease and interact with the endocrine (hormone), immune, and nervous system. Considering pathogenic microbes are less sensitive or insensitive to glyphosate, these disease-causing microbes can accumulate to worsen adverse health effects. Furthermore, the authors note a connection between gut health and neurological diseases as individuals exposed to glyphosate also experience a higher incidence of ADD/ADHD, autism, Parkinson’s Disease, Alzheimer’s.

Glyphosate has been the subject of extensive controversy about its safety for humans, non-human organisms, and ecosystems. Beyond Pesticides has reported on EPA’s ongoing failures to protect people and the environment from GBH compounds. Evidence includes the fact that the presence of glyphosate in human bodies has risen dramatically during the past three decades. Research out of the University of California San Diego found that, between two data collection periods (1993–1996 and 2014–2016), the percentage of people testing positive for the presence of glyphosate (or its metabolites) in their urine rose by 500 percent, and levels of the compound spiked by 1,208 percent. Furthermore, Bayer/Monsanto controls an extraordinarily high market percentage of seeds genetically engineered (GE) to tolerate glyphosate for corn, soy, and cotton. As of 2018, more than 90% of these crops in the U.S. are from GE seeds. All those seeds require the use of the GBH herbicide, Roundup. Science and environmental advocates have noted the multiple risks that glyphosate use represents, with Beyond Pesticides listing glyphosate as having endocrine, reproductive, neurotoxic, hepatic, renal, developmental, and carcinogenic effects on human health.

Gut microbiota plays a crucial role in lifelong digestion, immune, and central nervous system regulation, as wells as other bodily functions. Through the gut biome, pesticide exposure can enhance or exacerbate the adverse effects of additional environmental toxicants on the body. Since the gut microbiome shapes metabolism, it can mediate some toxic effects of environmental chemicals. However, with prolonged exposure to various environmental contaminants, critical chemical-induced changes may occur in the gut microbes, influencing adverse health outcomes.

Similar to gut microbes, soil microbiota are essential for the normal functionality of the soil ecosystem. Toxic chemicals damage the soil microbiota by decreasing and altering microbial biomass and soil microbiome composition (diversity). Pesticide use contaminates soil and results in a bacteria-dominant ecosystem as these chemicals cause “vacant ecological niches, so organisms that were rare become abundant and vice versa.” The bacteria outcompete beneficial fungi, which improves soil productivity and increases carbon sequestration capacity. The resulting soil ecosystem is unhealthy and imbalanced, with a reduction in the natural cycling of nutrients and resilience. Thus, plants grown in such conditions are more vulnerable to parasites and pathogens. The effects of climate change only exacerbate threats on soil health as studies show a link between global climate change and a high loss of microbial organisms in the soil ecosystem.

Not only do health officials warn that continuous use of glyphosate will perpetuate adverse health and environmental effects, but that use also highlights recent concerns over antibiotic resistance. Bayer/Monsanto patents glyphosate as an antibiotic since exposure hinders enzymatic pathways in many bacteria and parasites, serving as an antimicrobial. However, glyphosate kills bacterial species beneficial to humans and incorporated in probiotics yet allows harmful bacteria to persist, leading to resistance. Similarly, glyphosate-exposed soils contain a greater abundance of genes associated with antibiotic resistance, as well as a higher number of inter-species transferable genetic material. 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. Antibiotic resistance can trigger longer-lasting infections, higher medical expenses, the need for more expensive or hazardous medications, and the inability to treat life-threatening illnesses. Resistance to pesticides is also growing at similar rates among 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 stated purpose of GE crops is to reduce pesticide use, an increase in resistance can result in additional pesticide use to compensate. 

The report demonstrates that many studies used for regulatory agency assessments focus on glyphosate’s direct impact on ecosystem health. For instance, glyphosate directly affects the shikimate pathway in some bacteria. However, these agencies fail to consider how chemical exposure may indirectly impact plant, animal, and human health through other mechanisms. In this report, glyphosate is resistant to complete environmental degradation. Specific molecular linkages in the compound break down slowly in water, soil, and dead plant material by various microorganisms. However, with glyphosate causing a shift in microbial communities, there may be insufficient or non-beneficial microorganisms available to break down the toxic compound.

The authors recommend regulatory agencies set combined glyphosate and AMPA tolerance levels for products intended for plant, animal, and human consumption. The report concludes, “We recommend additional interdisciplinary research on the associations between low-level chronic glyphosate exposure, distortions in microbial communities at the species level, and the emergence of animal, human, and plant diseases. A potential connection between glyphosate exposure, populations of pks + bacterial species such as E. coli, and intestinal cancer development needs to be investigated. Connections between glyphosate resistance in bacteria and antibiotic resistance also deserve more attention. As suggested by us earlier, independent and trustworthy research is needed to revisit the tolerance thresholds for glyphosate residues in water, food, and animal feed, taking all possible health risks into account.”

To improve and sustain microbial communities, and thus human, animal, and environmental health, toxic pesticide use must stop. 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. Instead, emphasis on converting to regenerative-organic systems and using least-toxic pest control to mitigate harmful exposure to pesticides, restore soil health, and reduce carbon emissions, should be the main focus. Public policy must advance this shift, rather than continue to allow unnecessary reliance on pesticides. Considering glyphosate levels in the human body decrease by 70% through a one-week switch to an organic diet, purchasing organic food whenever possible—which never allows glyphosate use—can help curb exposure and resulting adverse health effects.

Learn more about soil microbiota and its importance via Beyond Pesticide’s journal Pesticides and You. 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. Moreover, Beyond Pesticides provides tools, information, and support to take local action: check out our factsheet on glyphosate/Roundup and our report, Monsanto’s Roundup (Glyphosate) Exposed. Contact us for help with local efforts and stay informed of developments through our Daily News Blog and our journal, Pesticides and You. Additionally, check out Carey Gillam’s talk on Monsanto’s corruption on glyphosate/Roundup at Beyond Pesticides’ 36th National Pesticide Forum.

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

Source: Frontiers in Environmental Science 

(Beyond Pesticides, October 27, 2021) Declines in pollinator populations throughout the world may result in the loss of tens of thousands of wild flowering plants that rely on their services, according to research published this month in the journal Science Advances. “Our paper provides the first global estimate of how many plant species mostly or completely rely on animal pollinators to make seeds and thus to reproduce,” wrote author James Rodger, PhD, in an article in The Conversation. “We found that it’s about 175,000 plant species – half of all flowering plants. This means declines in pollinators could cause major disruptions in natural ecosystems, including loss of biodiversity.”

Pollinators are being threatened with multiple interacting stressors, from climate change, to pesticide use, disease, habitat destruction, and other factors. In the US, an increasing number of pollinators, including iconic species like the American bumblebee and monarch butterfly, are being added or in consideration for listing under the Endangered Species Act. Systemic neonicotinoid insecticides implicated for their earth-spanning hazards to pollinator populations themselves put 89% or more of U.S. endangered species at risk.

Many are aware of the fact that pollinators help make available one in three bites of food. Research studies show that pollinators are part of a complex ecosystem that contributes to farm productivity, income, and environmental protection, and their protection provides greater benefits across the board than pesticide use.  But the effect of pollinator losses could stretch even further – with cascading impacts that could harm entire ecosystems. To determine how needed pollinators are for plant reproduction worldwide, the authors of the current study amassed a dataset of prior pollen research containing over 1,174 plant species, providing a globally representative analysis of pollinator contributions to flowering plants.

After working through variables relating to pollinator dependency, including self-fertilized, and pollen limited plants that improve seed production when pollinators were present, researchers were able to characterize what would happen in the absence of pollinators. Accordingly, without pollinators half of plant species would experience a reduction in fertility by over 80%, and one third of flowering plant species with no longer produce seeds at all.

Tree species appear to be at greatest risk, as well as plants reliant on highly specialized pollinators, those requiring multiple visits by pollinators, and plants in tropical regions. In the face of declining pollinators, some plants will be able to adapt new strategies. “Even through some plants might evolve to be more auto-fertile on the one hand, or more attractive to the remaining pollinators on the other hand, this will not be possible for all plant species,” Dr. Rodger writes. “Some plants will be at risk of extinction.”

This trend could become a positive feedback spiral for pollinator populations. As plants die-off or adapt to fewer pollinators, pollinators play less of a role, finding less food and resulting in further stress. But the study does provide some hopeful signs if pollinator declines are addressed quickly.  “Most plants are quite long-lived, so it will take some years for these plant populations to start to decline and go extinct, even if pollinator declines reduce their reproduction,” Dr. Rodger notes. He further suggests work to avoid pesticide use harming pollinators, and to conserve their remaining habitat.

Concerned residents and pollinator advocates are encouraged to take these steps not only in and around their properties, but at their place of work, and in their community in local parks and natural areas. For Pollinator Week 2021 Beyond Pesticides suggested actions to create pollinator habitat, go organic with your community, and urge comprehensive action at the federal level to protect declining populations. With the crisis continuing, we must redouble these efforts. Commit to taking meaningful action to protect pollinators, the plants, people, and entire ecosystems that rely upon them.

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

Source: The Conversation, Science Advances

(Beyond Pesticides, October 26, 2021) The Office of Pesticides Programs within the U.S. Environmental Protection Agency has become so captured by industry that it has lost sight of its health and environmental mission, according to a scathing critique issued today by 37 environmental, public health, and sustainable agriculture groups, including beekeeper councils. Led by Public Employees for Environmental Responsibility (PEER) and Beyond Pesticides, the groups are urging the Biden administration to adopt reforms within OPP to ensure pesticide approval and use decisions are science-based.

EPA’s OPP has registered more than 18,000 separate pesticide products — far more than any other country — and more than 2 billion pounds of pesticides are sold annually in the U.S. They are used annually over roughly 250 million acres of farmland, across millions of acres of urban and suburban lands, and inside millions of homes, schools, and other buildings. 

The coalition letter points to employee reports that managers within  OPP –

• Push through “Yes packages” of pesticide approvals greased by industry lobbying;
• Suppress toxicological and other concerns raised by professional staff; and
• Engage in outrageous waivers of vital toxicity study requirements, instead relying on “conditional” registrations to allow pesticide uses, despite missing key data. Seeing these waivers as accomplishments, OPP managers recently threw a party to “celebrate 1,000 studies waived,” with a notation in the staff invitation that “cake will be served.”

“EPA’s Office of Pesticide Programs has bent so far over backwards to accommodate industry desires that it is now beyond chiropractic help – major surgery is required,” stated PEER Senior Counsel Peter Jenkins, noting that while problems within OPP worsened under Trump, they preexisted his term but continue today. “Inside OPP, marginalization of science remains cause for celebration and the result has been repeated ecological and public health disasters.”

The letter recounts a litany of improper pesticide approvals decisions, some of which were blocked in court, while still others are being reversed under Biden. But, the groups say these cases are symptomatic of a larger institutional illness that calls for thoroughgoing reforms.

The cumulative effects of years and decades of this regulatory abuse are untold human deaths, disabilities, and illnesses. Industry has been forced to pay out billions of dollars for damages claims over OPP-approved products. The groups also point to the decline of pollinators – the key to American food security – due to the indiscriminate application of highly potent pesticides. The health of non-target wildlife, as well as our soil and waters, is under chemical siege. Even pets are at risk from irresponsibly approved flea and tick control products.

“We call on the Biden Administration to be a hero for health – the fastest thing it can do is immediately revoke the worst pesticides,” said Beyond Pesticides Executive Director  Jay Feldman, pointing to the 25 specific steps the coalition identifies that OPP can take to avoid or mitigate its mistakes going forward, all within its current authority. “Horror stories have piled up for too long and Americans no longer are safe from the very agency charged with protecting them.”

Groups signing on include: 350 Maine, Beyond Pesticides, Center for an Ecology-Based Economy Center for Food Safety, Climate Action Now – Western Massachusetts, Climate Xchange Community Action Works, Environment Maine, Farmworker Association of Florida Friends of the Earth, Green State Solutions, Hawaii Alliance for Progressive Action Hawai’i SEED, International Center for Technology Assessment, Land Stewardship Project Laudato Si’ Movement – Boston Chapter, LEAD for Pollinators, Maine Organic Farmers and Gardeners Association, Maine Unitarian Universalist Advocacy Network, Maryland Pesticide Education Network, Montana Organic Association, Mothers Out Front, Northeast Organic Farming Association – Mass., Ocean River Institute, Northwest Center for Alternatives to Pesticides, Ohio Ecological Food and Farm Association, Pasa Sustainable Agriculture Pesticide Action Network, Pesticide Research Institute, Pollinate Minnesota Pollinator Stewardship Council, Powder River Basin Resource Council Public Employees for Environmental Responsibility (PEER), Regeneration Massachusetts Sierra Club, Sustainable Tompkins, Toxic Free North Carolina.

Read organizations’ letter to EPA.

October 25, 2021

The Honorable Joseph R. Biden, President
Michael S. Regan, EPA Administrator
Edward Messina, EPA Office of Pesticide Programs Director
Michal Ilana Freedhoff, Assistant Administrator, Office of Chemical Safety and Pollution Prevention 
Jake Li, Deputy Assistant Administrator for Pesticide Programs

Re:  Major Reform is Needed in EPA OPP’s Pesticide Regulation

Dear President Biden, Administrator Regan, Director Messina, Assistant Administrator Freedhoff, and Deputy Assistant Administrator Li,

We, the undersigned [[34 ]] environmental, health, farmworker, beekeeper, agricultural and other organizations, on behalf of our millions of members nationwide, write to express that we have serious concerns about the failure of the Environmental Protection Agency (EPA) to protect people and the environment from the dangers of pesticides. In this letter we list a series of actions or inactions that put people and the environment in harm’s way and identify overarching need for reform in a short timeframe.  We know that toxic pesticide use in the United States is widespread. EPA has registered more than 18,000 separate pesticide products — far more than any other nation — and more than 2 billion pounds of pesticides are sold annually in the U.S. They are used annually over roughly 250 million acres of farmland, across millions of acres of urban and suburban lands, and inside millions of homes, schools, and other buildings. In recent decades the Office of Pesticide Programs (OPP) has made a series of crucial regulatory mistakes that have caused human deaths, disabilities, and illnesses; caused disproportionate harm to people of color; destroyed beekeeper livelihoods; largely eliminated the iconic monarch butterfly; decimated bird and invertebrate populations; killed or sickened people’s beloved dogs and cats; contributed to the climate crisis; and otherwise harmed the welfare of this country.

A June 30, 2021, article in The Intercept, exposes OPPs malfeasance.[1] Entitled “The Department of Yes – How Pesticide Companies Corrupted the EPA and Poisoned America,” it confirms our own experiences in confronting an OPP that has seemed determined to undermine EPA’s fundamental mandate to protect human health and the environment. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which establishes a system for registering pesticides, recognizes that these toxic chemicals are economic poisons—inherently dangerous materials whose dispersal into the environment is allowed for largely economic reasons—and whose use can therefore be permitted only when the benefits of use outweigh the risks (adverse effects). The Federal Food, Drug, and Cosmetic Act (FFDCA), which establishes the standard for allowable pesticide residues in food, creates a risk assessment-based standard that has been interpreted to permit harm to human health despite the availability and economic viability of less toxic approaches to food productions.

EPA and the administration have the ability under existing law to steer the nation away from toxic chemical dependency with a clear strategy to address the existential crises associated with public health decline, biodiversity decline, and the climate crisis.

OPP has undermined the purposes of FIFRA and the FFDCA by, for example:

– pushing through “Yes packages” of pesticide registration proposals that are approved because of industry lobbying and political pressure,
– suppressing the scientific opinions of many of its own professionals unless they are consistent with the registrants’ goals,
– excessive, outrageous waivers of vital toxicity study requirements and the use of “conditional” registrations by which OPP allows pesticide uses to proceed despite missing key data,
– engaging in what likely is one of the worst “revolving door” situations in the Federal government in which regulatory officials retire from OPP and then work for or consult with the regulated companies,
– willful noncompliance with Section 7 of the Endangered Species Act, which requires proposed registrations to include consultations with the wildlife agencies (Fish and Wildlife Service and National Marine Fisheries Service) to take into account and mitigate potential impacts on our nation’s threatened and endangered species, and
– failure to review and regulate endocrine-disrupting pesticides, as required by the Food Quality Protection Act of 1996, which amended FIFRA and FFDCA.

An urgent need exists for OPP to re-think its application of current standards in law to meet the crises of the day. To do this, the agency must embrace a series of underlying principles to guide its decisions into the future.

1. Utilize unreasonable risk. We urge OPP to use its powers under the “unreasonable adverse effects” standard of FIFRA to be more holistic and precautionary. A risk or hazard analysis requires a deeper analysis of costs, including externalities, secondary pest populations, and other factors. When evaluating pesticide registrations, EPA should determine the full range of practices available to achieve   submitters’ goals of pesticide registration or reregistration, including chemical and nonchemical strategies. In conducting its risk/hazard assessment to meet its statutory duty, the agency must evaluate the complete pesticide formulation to which the public/environment is exposed, taking into account the active and inert ingredients, contaminants, and metabolites. Mixtures resulting in additive and synergistic effects must be evaluated and, where the full range of data are not available on adverse effects, reasonableness of risk should not be assumed.

2. Conduct proper alternatives analyses. A broader application of the FIFRA “unreasonable adverse effects” standard includes an assessment by the agency of the range of alternatives – non- or least-toxic practices and materials – that could be used to achieve the ultimate agricultural, landscape or building management goal. This information provides the basis for determining reasonableness of risk, and in so doing establishes findings on whether food can be grown, landscapes can be managed, and quality of life can be achieved without the use of toxic chemicals. OPP’s findings regarding alternatives will be important to: a) incentivizing the market to move to non- and least-toxic alternative practices and products that can eliminate petroleum-based pesticides that contribute to the climate crisis, b) protecting those who are disproportionately at risk, and c) responding to the dramatic decline of biodiversity. Climate change will likely lead to vector-borne illnesses spreading into new areas, and scientists warn that insecticide exposure under warming temperatures is not well understood. 

3. Reject corrupt data. OPP should not rely on corrupt data, as documented by theMidwest Center for Investigative Reporting piece last December. OPP must cancel registrations based on false data and establish a moratorium for future pesticide registrations from manufacturers found to have submitted fraudulent data—until the agency can assure the public that the science supporting pesticide registrations is not corrupt. 

4. Apply science of endocrine disruption. OPP must end its failure to meet the agency’s statutory responsibility to fully protect people and wildlife from the dire consequences of exposure to endocrine-disrupting chemicals (EDCs) that affect the full functioning of organisms. More than 50 pesticide active ingredients (more when considering contaminants, inerts, etc.) have been identified as EDCs that mimic the action of a naturally produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; block hormone receptors in cells, thereby preventing the action of normal hormones; or affect the synthesis, transport, metabolism and excretion of hormones, thus altering the concentrations of natural hormones. Endocrine disruptors have been linked to attention deficit hyperactivity disorder (ADHD), Parkinson’s and Alzheimer’s diseases, diabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorders, childhood and adult cancers, and other metabolic disorders. OPP has a statutory responsibility to look at the explosion of these diseases, including multigenerational epigenetic effects, analyze the role pesticides play in these diseases, and take protective regulatory action.

5. Engage in holistic reform. OPP should aggressively implement the Presidential Memorandum for the Heads of Executive Departments and Agencies (January 20, 2021) regarding Modernizing Regulatory Review. This memorandum 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. It sets the stage for the urgent adoption of agency policy across government to seriously confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism) and those with comorbidities/underlying health conditions. If OPP’s pesticide registration decisions are to be consistent with this memorandum, it must facilitate the widespread adoption of organic farming and land care practices, which reduce greenhouse gas emissions, sequester carbon in the soil, and protect the lives of essential workers, farmworkers, and fenceline communities.

. . . more content in original letter. See entire letter to EPA.

[1] Author: Sharon Lerner. Online at: https://theintercept.com/2021/06/30/epa-pesticides-exposure-opp/.

(Beyond Pesticides, October 25, 2021) The Environmental Protection Agency (EPA) is requesting public comments on its draft Biological Evaluations (BEs) for neonicotinoid insecticides imidacloprid, clothianidin, and thiamethoxam by 11:59 pm (EDT) on Monday, October 25, 2021. The BEs will factor into EPA’s registration review decisions on the three bee-toxic insecticides. Written comments must be submitted through Regulations.gov. Please feel free to cut and paste parts of  Beyond Pesticides’ comments (linked here) or cut and paste into Regulations.gov the suggested comment language at the very bottom of this alert. 

Tell EPA to protect endangered species from pesticides.

EPA’s Biological Evaluations for these highly toxic chemicals make no agency conclusion or recommendation that would trigger a request to initiate formal Endangered Species Act (ESA) §7(a)(2) consultations with the U.S. Fish and Wildlife Service (USFWS) to determine a possible jeopardy finding for the listed species and requisite mandatory use restrictions of the relevant pesticide. This, despite the fact that for imidacloprid the agency’s draft Biological Evaluation made a May Affect determination for 89% of the 1821 species considered and 90% of the 791 critical habitats considered. Strikingly, a May Affect determination was made for 100% of amphibian and avian listed species and their critical habitat. It was also determined that imidacloprid is Likely to Adversely Affect 100% of the listed amphibian species exposed. The Biological Evaluation for each of the three neonicotinoids makes effects determinations—NE (no effect), MA (may affect), NLAA (not likely to adversely affect), or LAA (likely to adversely affect)—that could affect 1821 listed species, and 791 designated critical habitats.

These serious risk findings for endangered and threatened species made for imidacloprid, clothianidin, and thiamethoxam account for existing product labels and mitigation efforts. The Endangered Species Act requires, “Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency…is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species….”

The complete Biological Evaluations (BEs)—with all determinations and species considered—must be included with the formal consultation request and not just the LAA determinations. This will allow USFWS to also corroborate the agency findings of NLAA and LAA as part of the consultation.

A No Effect determination was made for only 11% of listed species considered because these species have a limited geographic distribution and would likely not be exposed to imidacloprid under the existing label use and mitigation instructions. Thus, any species listed and exposed to imidacloprid is potentially adversely affected.         

For clothianidin, a similar May Affect determination was made for 86% of listed species considered and 83% of the critical habitats considered. Likely to Adversely Affect findings overall were made for 67% of listed species and 56% of critical habitats considered. As imidacloprid, 100% of listed amphibian species are likely to be adversely affected by clothianidin uses.

Thiamethoxam degrades to clothianidin and therefore shares similar fate and behavior in the environment. May Affect determinations were made for 88% of species and 89% of critical habitats considered. Likely to Adversely Affect findings overall were made for 77% of listed species and 81% of critical habitats considered. As reported for the other neonicotinoids, 100% of amphibian species and critical habitat are likely to be adversely affected.

EPA should also include the American bumble bee (Bombus pensylvanicus) in its revised Biological Evaluations for the neonicotinoid insecticides. Although this insect is not a currently listed species, the Fish and Wildlife Service has recently determined a petition including substantial scientific and commercial information indicating that listing the American bumble bee as an endangered or threatened species may be warranted. Bumble bee species are highly susceptible to neonicotinoid exposures and are likely jeopardized by continued use of these insecticides.

Must we wait until species are listed as threatened or endangered to protect them? Given the systemic character of neonicotinoids and their extreme toxicity to insects, EPA must assume that they will ultimately lead to the demise of insects that consume nectar, pollen, plant exudates, or plant tissues. The burden of proof is on the registrant(s) to demonstrate that these products will not further exacerbate the ongoing insect apocalypse—and lead to further biodiversity loss through decimation of this essential link in food webs.

Furthermore, EPA must use organic production as the standard against which pesticide “benefits” are weighed. Any crop that can be produced with chemical-intensive methods can be produced organically. Organic producers use very few synthetic pesticides and no neonicotinoids. Therefore, the potential jeopardy of extinction to the 1445+ species identified by these biological evaluations must be considered unreasonable under the definition in FIFRA.

EPA has determined unequivocally that neonicotinoids pose risks to the environment that cannot be acceptably mitigated in any long-term, sustainable way. The agency in its proposed interim decisions for these chemicals identifies several uses for imidacloprid and clothianidin that must be cancelled. However, EPA believes that the benefits of other uses outweigh these serious risks and is proposing limited or no mitigation measures. Given the frequency of detection in U.S. waterways, soil, and plants, the recognized acute and chronic risks posed to pollinators, aquatic invertebrates, vertebrate wildlife, and human health, the risk/benefit determination is pitifully insufficient, especially in light of the BEs identifying the majority of listed species as potentially jeopardized by these neonicotinoid insecticides. Therefore, EPA must quickly suspend all remaining neonicotinoid uses as it pursues the ESA §7(a)(2) consultations with the Services. Additional data to address existing uncertainties and gaps will not alter or lessen the environmental and health risks already unmistakably recognized.

Submit comments to EPA using Regulations.gov.

Suggested Comment To EPA (feel free to cut and paste the following into Regulations.gov):

EPA has determined unequivocally that neonicotinoids pose risks to the environment that cannot be acceptably mitigated in any long-term, sustainable way. The agency in its proposed interim decisions for these chemicals identifies several uses for imidacloprid and clothianidin that must be cancelled. However, EPA believes that the benefits of other uses outweigh these serious risks and is proposing limited or no mitigation measures. Given the frequency of detection in U.S. waterways, soil, and plants, the recognized acute and chronic risks posed to pollinators, aquatic invertebrates, vertebrate wildlife, and human health, the risk/benefit determination is pitifully insufficient, especially in light of the Biological Evaluations identifying the majority of listed species as potentially jeopardized by these neonicotinoid insecticides.

The agency’s draft Biological Evaluation made a May Affect determination for 89% of the 1821 species considered and 90% of the 791 critical habitats considered. Strikingly, a May Affect determination was made for 100% of amphibian and avian listed species and their critical habitat.

Therefore, EPA must quickly suspend all neonicotinoid uses as it pursues the Endangered Species Act §7(a)(2) consultations with the U.S. Fish and Wildlife Service. Additional data to address existing uncertainties and gaps will not alter or lessen the environmental and health risks already unmistakably recognized.

Thank you for your consideration.

(Beyond Pesticides, October 22, 2021) The California Court of Appeal (Third District, Sacramento) has ruled that a statewide pesticide spraying program violates state law. The court found that the program, launched in 2014 and administered by the California Department of Food and Agriculture (CDFA), contravenes California’s landmark 1970 Environmental Quality Act (CEQA). It does so, the court found, by failing to: assess and reduce damages of pesticide applications to bees, other pollinators, and water bodies; conduct site-specific environmental reviews; and notify the public before spraying is conducted. This decision is a victory, and a step toward a less-toxic California, say plaintiffs and many health and environmental advocates, including Beyond Pesticides.

The history of CDFA’s actions in the state is riddled with invocations of emergency provisions of California’s Food and Agriculture Code. These emergency declarations have allowed CDFA to conduct pesticide spraying for invasive species nearly anywhere — in back yards, on school and recreational grounds, on organic farms, on public lands, and sometimes, across entire neighborhoods — without any analysis of the health and environmental impacts of those applications, or any notice to the public or opportunity to comment on the program. From 2014 to 2018, CDFA conducted more than 1,000 such pesticide applications.

Petitioners before the Court of Appeal comprise two groups: those from the original case that was adjudicated in 2018 by Sacramento County Superior Court, and the additional parties in the current case — an appeal of that 2018 decision by CDFA. Plaintiffs in the original case included the City of Berkeley, Environmental Working Group (EWG), Center for Biological Diversity (CBD), Beyond Pesticides, California Environmental Health Initiative, MOMS Advocating Sustainability, Center for Food Safety, Pesticide Action Network North America, Center for Environmental Health, Environmental Action Committee of West Marin, Californians for Pesticide Reform, and Safe Alternatives for our Forest Environment. Additional petitioners in the appeal case are North Coast Rivers Alliance, Pesticide Free Zone, Inc., Health and Habitat, Inc., Californians for Alternatives to Toxics and Gayle McLaughlin (former mayor of Richmond, California).

The petitioners sought writs of mandate challenging the CDFA pesticide program’s environmental impact report (EIR). A writ of mandate is a procedure in California that allows superior courts, courts of appeal, and the state Supreme Court to command lower courts and state agencies to take, or not take, specific actions. When a writ is issued, the responsibility for enacting the content of the writ falls to the lower body. In this case, this means that, although the appeal court agreed with a host of the petitioners’ claims, it did not explicitly set aside the program’s EIR or tell CDFA to stop carrying out the program. Rather, it will send its ruling back to the lower court, which by law should issue orders consistent with the appeal court’s decision. Unfortunately, this means that CDFA can continue this pesticide spraying program until the lower, trial court issues such orders.

The CDFA pesticide program at issue uses — on public and private property, on agricultural lands, and even on wild lands — pesticides known to be carcinogenic and teratogenic (causing birth defects), and toxic to, especially, bees, birds, fish, and butterflies. Among those pesticide compounds are, according to CBD:

• neonicotinoid pesticides (highly toxic to pollinatorssuch as bees and aquatic invertebrates)
• methyl bromide, (a toxic fumigant that causes significant health harms and depletes the ozone layer)
• chloropicrin (a chemical warfare agent that causes significant lung and genetic damage)

The appeal court’s October 15 ruling should result in writs saying that CDFA’s certification of the program’s environmental impact report (EIR) and its approval of the program must be set aside, and enjoining the agency from any further activities within the program “until the Department certifies an EIR correcting the CEQA violations identified in the trial court’s ruling.” Among other stipulations, CEQA requires EIRs for all major projects by state agencies that might have environmental impacts; unlike the federal National Environmental Quality Act, the California statute also requires the state to prevent or mitigate negative impacts it discovers. The appeal court’s written ruling identifies multiple instances of CDFA failing to analyze adequately the health and environmental dangers of more than 75 pesticides the agency greenlighted for its program use across the state.

The court also found that CDFA understated existing levels of pesticide use, and failed to assess, and reduce, the damage done by pesticide spraying to pollinators and to water bodies. The ruling states: “We agree with EWG that the program EIR fails to mitigate potential significant adverse impacts on bees. . . . The program EIR discloses that use of pesticides for Program activities could harm bees. . . . The program EIR’s Ecological Risk Assessment and Appendix K likewise state that pesticides can poison bees. . . . [and] Appendix K further notes sublethal impacts to bees from pesticides, including reducing the foraging success of bees. Because the program EIR discloses that Program activities could have substantial adverse impacts on bees, it must discuss mitigation measures for those impacts and the program EIR does not do so.”

In addition, the ruling notes that, although CDFA’s EIR for the pesticide program indicates that the agency “would implement avoidance and minimization measures discussed [in the EIR] . . . the program EIR does not explain how the management practices . . . would minimize the potential adverse impacts on bees. . . . The Department’s statement in the program EIR that implementation of enumerated measures would reduce or avoid potential impacts on bees, without facts or analysis, is inadequate.”

The decision asserts, “The program EIR is deficient for another reason. . . . any additional contribution by the . . . Program to an impairment [i.e., existing chemical contamination of a water body] would be a considerable contribution to a cumulatively significant impact. . . . The analysis in the program EIR does not lead to the conclusion of no cumulative impact on impaired waterbodies.”

The court also states that, although “the program EIR recognizes that the cumulative risk to ecological receptors and human health from Program activities ‘would depend on the pesticide chemicals used, other chemical additives used, how a pesticide is applied, where pesticide use occurs, the quantity and concentration of the pesticides applied, exposure pathways, and the biological characteristics of the receptor,’” CDFA’s defense that “the program EIR adequately evaluated the Program’s cumulative impacts” relies on program components that contain no “information about the factors the program EIR acknowledges are relevant.”0

According to CBD, the court “highlighted that the proposal was made largely without public notice and without evaluating local impacts or allowing opportunity for affected communities to opt out.” On the other side of the coin, the court said, “The EWG petitioners fail[ed] to show that the program EIR’s analysis of human health impacts is misleading or inadequate.”

The Superior Court’s 2018 findings (in the original litigation) echo much of what the appeal court decision now sets out. As reported by Beyond Pesticides in 2018, “In its implementation outline for the program, the PEIR gave CDFA carte blanche to use more pesticides in a state already over-burdened with pesticides in the environment. The court labeled as ‘woefully deficient’ CDFA’s analysis of the cumulative impacts of adding pesticides to the state’s already hefty environmental burden of over 150 million pounds released annually. It cited ‘unsupported assumptions and speculations’ contained in the PEIR as a basis for concluding that pesticides would not contaminate waterbodies. Potentially significant pollinator impacts were also ‘improperly ignored.’ The court further concluded that in the PEIR document CDFA had granted itself authority ‘to implement a broad range of practices without evaluating the site-specific conditions’ as a basis for determining their impacts.”

As was the case in 2018, this current ruling does not prevent CDFA from conducting non-pesticide related activities, including pest identification, site inspections, and the imposition of quarantines, nor does it prevent the agency from producing specific EIRs for individual projects. And the decision has no impact on the actions of farmers, other institutions, companies, or residents from spraying pesticides on their land. But, as CBD’s Environmental Health Legal Director Jonathan Evans noted in 2018, the state “can’t use pesticides until [it] addresses how those pesticides are going to impact communities affected and the sensitive wildlife species and watersheds that [would] be sprayed.”

Advocates are pleased with this Court of Appeal decision. CBD reports the comment of Nan Wishner of the California Environmental Health Initiative: “This ruling sends an important message to the Department of Food and Agriculture to make protecting the health of our communities and food supply the top priority by joining the transition to sustainable pest-management practices.” CBD’s Jonathan Evans also commented, “The court affirmed Californians have the right to know when dangerous pesticides are sprayed in their communities and what the risks are to people and to pollinators crucial to our food supply.”

The Environmental Working Group’s California Director of Government Affairs, Bill Allayaud, weighed in, saying, “The court was right to rule against the Department of Food and Agriculture’s outrageous effort to hide from the public where toxic pesticides are being sprayed and to downplay the risks these chemicals pose to pollinators, the environment, and the health of those who live near farm fields. It is our hope the department accepts the court’s ruling and joins the state’s movement toward sustainable pest management, represented by the governor’s recently released Sustainable Agriculture budget initiative and the state Department of Pesticide Registration’s Sustainable Pest Management Work Group.”

CDFA could appeal this decision of the Third District Court of Appeal to the California Supreme Court. Thus far, that is not expected by the petitioners, who hope for an order from the trial court in the next few months that will set aside the current EIR and prevent CDFA from continuing its activities covered by that EIR — which comprise most of the agency’s chemical pest management.

Beyond Pesticides welcomes this decision, which is an important roadmap for advocates and other states to follow. According to Jay Feldman, executive director of Beyond Pesticides, “All state agencies that deal with pesticides, health, environment, and land management should be engaged in evaluating the real-world impacts of pesticide use against invasive species, and the sustainable alternatives prior to any broad-scale state application programs.” “Still, such a piecemeal and “fractured” approach to the use of pesticides underscores the need for precautionary federal action on these toxic compounds,” he continued.

Individuals can adopt a variety of least-toxic practices for dealing with pests of all sorts in their home, garden, school, and community environments. See Beyond Pesticides resource pages: Least Toxic Control of Pests in the Home and Garden, Meeting the Invasive Species Challenge, ManageSafe^TM, and Ecological Management of Problem Vegetation, among others. The public is encouraged by Beyond Pesticides to organize in municipalities, counties, and/or states to pressure governments to do better on getting poisons out of the materials streams, human bodies, and the environment. Beyond Pesticides offers Tools for Change, a resource for activism, and an older-but-still-useful document, Now Hear This: The Nine Laws of Successful Advocacy Communications. In addition, always feel free to reach out to Beyond Pesticides for guidance on local advocacy via email at [email protected], or at 1.202.543.5450.

Sources: https://biologicaldiversity.org/w/news/press-releases/court-of-appeal-rejects-californias-blanket-approval-of-pesticide-spraying-2021-10-18/ and https://www.courts.ca.gov/opinions/nonpub/C086957.pdf

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

(Beyond Pesticides, October 21, 2021) A study published in Environment International finds higher rates of various cancers among agricultural workers, with multiple myeloma (blood cancer) and melanoma (skin cancer) disproportionately impacting female farmers. Although research studies link cancer risk to genetic and external factors (e.g., cigarette smoke), there are increasing reports and scientific studies that pesticide exposure augments the risk of developing common cancers like melanoma and less common cancers like multiple myeloma. This study highlights the importance of understanding how pesticide use can increase the risk of latent diseases, which do not immediately develop upon initial exposure. The researchers note, “Given the large size of the agricultural population worldwide and the presence of various potential hazards in its working environment, such epidemiological data are important in improving occupational health measures and ensuring better workers’ health.”

To investigate the cancer incidence patterns, researchers evaluated data from the AGRICOH database involving various international studies. The studies assessed pesticide exposure scenarios, which researchers use to determine the etiological (causal) agent of cancer incidences among farmers relative to the general population. Researchers analyzed data from eight different AGRICOH groups in various countries: France (AGRICAN), the U.S. (AHS, MESA), Norway (CNAP), Republic of Korea (KMCC), Denmark (SUS), and Australia (Pesticide Exposed Workers cohort, and the Victorian Grain Farmers cohort). Each cohort included male and female participants over 15 years old who currently or previously worked in agriculture, nurseries, or lawn care.

The study finds a total of 23,188 cancer cases in which melanoma of the skin and multiple myeloma (MM) instances are higher among women compared to the general population. In addition, the study finds elevated rates of prostate cancer among men compared to the general population. However, there is an inverse association between pesticide exposure and specific cancers, including bladder, breast (female), colorectum, esophagus, larynx, lung, and pancreas. Moreover, researchers find vast differences in disease risk for specific cancers among the cohorts, including lung and liver cancer among men and women and stomach, skin, and colon/rectal cancer among men. The researchers suggest cancer risk variation is most likely due to differences in the underlying risk factors from pesticide exposure and external stimuli.

The connection between pesticides and associated cancer risks is not a new finding. Several studies link pesticide use and residue to various cancers, from more prevalent forms like breast cancer to rare forms like kidney cancer nephroblastoma (Wilms’ tumor). Applying the same U.S. Agricultural Health Study (AHS) cohort in this study, a past report demonstrates an association between cancer and pesticides such as 2,4-D, glyphosate, lindane, and DDT. Furthermore, this study confirms previous studies that find farmworkers experience higher rates of specific cancers, like brain cancer. The journal Occupational and Environmental Medicine indicates that farmworkers and persons exposed to high levels of pesticides have an increased risk of developing brain tumors. Farmworkers are at the greatest risk of pesticide-induced diseases, and their average life expectancy bears this out. According to the National Farm Worker Ministry, farmworkers have an average life span of 49 years, a 29 year difference from the general U.S. population.

Multiple myeloma (MM) is a relatively rare type of blood cancer of the plasma cells, killing nearly 40 percent of 32,270 people it afflicts in the U.S. annually. Although MM mainly impacts older individuals, the elderly population faces a distinct set of challenges such as age-related immune dysfunction. Since MM causes plasma cells to function abnormally, older people with weak immune function can experience more life-threatening symptoms like renal (kidney) failure. Moreover, recent studies find an association between the blood disease monoclonal gammopathy of undetermined significance (MGUS) and pesticide exposure. MGUS is a likely precursor for MM development, where risk increases in people whose MGUS protein levels are abnormally high. Abnormally high protein levels can occur upon repeated exposure to endocrine-disrupting chemicals, like pesticides, with the British National Health Service finding 1 in every 100 people with MGUS go on to develop MM annually. These findings provide reliable evidence establishing a link between pesticides and MM development. Further research should assess the mechanisms by which pesticides impact biological pathways to cause MM and other cancers.

The study results find disparities between cancer outcomes, with female agricultural workers experiencing higher rates of MM and skin cancer relative to male agricultural workers and the general population. However, this study is not the first to demonstrate the sex-specific effect of pesticide exposure. In 2017, scientists demonstrated exposure to commonly used pyrethroid insecticides results in the early onset of puberty in boys, as presented in a study at the 99th meeting of the Endocrine Society. Furthermore, a 2021 study finds exposure to current-use pesticides like organophosphates pose a greater health risk to women. Women with organophosphate exposure are more likely to develop cardiovascular disease, bronchitis, asthma, and various cancers. Given the recent rise in the use of these chemicals for household pest control, there is a concern about the range of implications these chemicals could be having on young children in the U.S. and abroad. Therefore, it is necessary to assess chemical exposure effect on human health to safeguard future generations.

Regardless of geographical location and agricultural practices, cancer incidents are consistent among cohorts, suggesting an underlying common risk factor for women and men agricultural workers. However, the study finds a lower risk for specific cancers among cohort participants. Researchers imply lower rates of smoking and more work-related physical activity lessens certain cancer risks. For instance, the prevalence of smoking is much lower among the farmworker cohorts than the general population. Moreover, the study participants have less cancer incidence associated with the lungs, mouth, throat, kidney, and liver, all of which are consistent with tobacco smoking among the general population. Researchers also attribute the differences in cancer risk to the type of pesticide and exposure rate. Epidemiological studies assessing risk factors for MM suggest exposure to pesticides like permethrin, chlordane, carbaryl, captan, and DDT, play a role in disease development. Additionally, researchers indicate female farmers may experience increased skin cancer incidences due to outdoor farming tasks (i.e., harvesting) that expose women to a combination of UV light and toxic pesticides. Since farming duties differ due to various practices, exposure to pesticides depends on several factors. According to the authors, these factors include “the type of agro-production, environmental conditions present, application methods, use of machinery and personal protective equipment, and local legislation.” Therefore, researchers advocate further investigation of cancer development from chemical exposure, especially for instances where the disease rate differs and has gender disproportionate effects.

Cancer is one of the leading causes of death across the globe, with over eight million people succumbing to the disease every year. Notably, the International Agency for Research on Cancer (IARC) predicts an increase in new cancer cases from 19.3 million to 30.2 million per year by 2040. Therefore, studies related to pesticides and cancer will aid in a prospective understanding of the underlying mechanisms that cause the disease. It is essential to recognize the health implications of pesticide use and exposure on humans, particularly if pesticides increase chronic disease risk. Thus, Beyond Pesticides tracks the most recent news and studies related to pesticides through the Daily News Blog and Pesticide-Induced Diseases Database (PIDD). This database supports the clear need for strategic action to shift away from pesticide dependency. For more information on the adverse effects of pesticides on human health, see PIDD pages on cancer (including melanoma and multiple myeloma), endocrine disruption, and other diseases.

One way to reduce human and environmental contamination from pesticides is buying, growing, and supporting organic. Numerous studies find that levels of pesticide metabolites in urine significantly drop when switching to an all-organic diet. Furthermore, given the wide availability of non-pesticidal alternative strategies, families and the agricultural sector 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 consumers, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture. Furthermore, to learn more about farmworker protection, please visit Beyond Pesticide’s Agricultural Justice page.

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

Source: DocWire News, Environment International

(Beyond Pesticides, October 20, 2021) The U.S. Environmental Protection Agency (EPA) announced last week plans to establish a new position and two advisory councils in order to enhance scientific integrity within the agency’s Office of Chemical Safety and Pollution Prevention (OCSPP). The move is being widely seen as a response to recent reporting over how EPA has allowed the chemical industry to distort and unduly influence its process for reviewing and approving toxic pesticides and other chemicals. “Scientific integrity is the backbone of the work we do to ensure the safety of chemicals used in our everyday lives,” said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff, PhD. “Strong, sound science underpins confidence in our decision-making among the public that we serve. Today’s announcements are the latest in a series of steps OCSPP is taking to reaffirm our commitment to scientific integrity and restore the public trust.”

EPA will create a new internal advisory group called the OSCPP Science Policy Council “to provide advisory support and recommendations on science policy and scientific integrity issues that arise within its Office of Pollution Prevention and Toxics and Office of Pesticide Programs.” The chair of this advisory group will be a new position, a science policy advisor, who will report to the EPA Assistant Administrator. In addition to providing “guidance on emerging science policy and scientific integrity matters,” the new science policy advisor will also be named the deputy scientific integrity official for OSCPP.

EPA imagines the OCSPP Science Policy Council as providing an “advisory perspective” on scientific integrity, looking at issues at are of “broad interest within OCSPP for informal review” while also fostering informal opportunities for scientific collaboration.

Advocates see the move as a step in the right direction but note that problems within OCSPP run deep. “While these processes and procedures can improve the situation within the offices, they cannot change the culture within the agency,” said Tim Whitehouse, executive director of Public Employees for Environmental Responsibility (PEER) to The Intercept. “The core problem at EPA that needs to be addressed is that mid-level managers who violate scientific integrity rules and policies need to be held accountable. And that does not appear to be happening.” 

Previous reporting by The Intercept’s Sharon Lerner detailed a range of troubling issues running through OSCPP’s Office of Pesticide Programs. Whistleblowers describe an agency captured by the industry it is charged with regulating. Staffers ignore or bury scientific data relating to public health dangers, and create “yes packages” at the behest of powerful elected officials to push a pesticide to market without required scientific review. The controversy raises concerns about complicit behavior in institutions, often directed from the top (political appointees), that mandate mid- and lower-level employees to engage in processes and behaviors that undermine science and the health protective mission.

While the Biden administration has ‘talked the talk’ since the start, EPA actions have not matched its lofty language. Assistant Administrator Freedhoff’s said earlier this year, in an open letter to EPA employees, “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.” Yet, four months after that statement, the agency carried on with an appalling Trump-era decision to re-approve the Parkinson-causing herbicide paraquat. In fact, the agency did not just reapprove paraquat, it allowed aerial spray uses the Trump administration planned to eliminate.

In making its decision EPA said that, “No direct one-to-one alternatives to paraquat are available;” a statement that is factually untrue and reeks of industry influence, according to advocates. Further reporting shows that EPA relied on data provided by an industry group called the Agricultural Handler Exposure Task Force, which includes in its ranks, Bayer Monsanto, BASF, Corteva, FMC, and Syngenta/ChemChina, the primary producer of paraquat.

These moves leave advocates to question how EPA thinks an agency with scientific integrity operates. While advisory boards can help shape that response, how the agency arrives at its decisions must be rebuilt from the ground up.

In addition to the science policy advisors, OSCPP also plans an advisory group for reviews of new chemicals, another area where whistleblower reporting has uncovered industry rot. EPA indicates that a New Chemicals Advisory Committee will review science and policy related issues regarding new chemical submissions under the Toxic Substances Control Act (TSCA), which regulates industrial chemicals (of which some overlap with pesticides). EPA’s press release describes the body as “an opportunity for additional independent subject matter experts to participate in the discussion on scientific work products and cross cutting science policies.”

Within OSCPP New Chemicals Division, reporting also conducted by The Intercept’s Sharon Lerner uncovered a range of unethical and corrupt practices. Staff scientists were directed to remove language from risk assessments relating to important health endpoints, revise conclusions to make chemicals look safer than they were, and shift work to less-experienced employees in order to approve inadequate scientific reviews.  

The last action EPA plans to take as part of its integrity drive is to work with an independent contractors on a “workplace climate assessment” that will “capture feedback from employees and management about any potential workplace barriers and opportunities for organizational improvement.” Accordingly, EPA leaders indicate that will employ the feedback reviewed in order to “if necessary, make changes in OCSPP’s work practices and culture.” Watchdog groups note that the only way work practice and culture changes would not be necessary is if this announcement was simply a way to provide cover for the agency to continue to conduct business as usual.

Pesticides and other chemicals are linked to a growing list of diseases that are far too common in today’s day and age. It is critical for so many Americans’ health that OSCPP embrace real reforms, root out industry influence, and stop the revolving door between employees at EPA and the chemical industry. EPA notes that it may include EPA experts outside of OSCPP within its advisory boards. Although EPA has a long road ahead to restore public trust in its actions, truly independent advisors, internal shifts in culture, and final decisions that embrace the full variety of less and non-toxic alternative to pesticides and other toxic substances can help the agency make considerable progress in the eyes of the public.

For more information on the way the pesticide and chemical industry have hollowed out the agency charged with protecting our health and environment, see previous reporting from The Intercept’s Sharon Lerner, as well as Beyond Pesticides coverage (1, 2, 3). Send a letter today urging EPA to take actions that hold the chemical industry accountable for the poisoning and damage they cause.

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

Source: EPA press release, The Intercept

(Beyond Pesticides, October 19, 2021) Exposure to the insecticide malathion increases risk of developing chronic kidney disease (CKD), according to a study recently published in the International Journal of Environmental Research and Public Health. According to study co-author Nicholas Osborne, PhD, CKD is on the rise in developing countries in Southeast Asia and Central America, and, “[n]early one in 10 people in high income countries show signs of CKD, which is permanent kidney damage and loss of renal function.” Although CKD risk increases with age, and is associated with other health factors like smoking, heart disease, and diabetes, cases without clear cause are increasingly common, indicating the that environmental factors are likely playing a role.

Researchers began with data drawn from the United States’ National Health and Nutrition Examination Survey (NHANES), an ongoing study that assesses Americans’ health and nutritional status through interviews, physicals, and other health tests. Urine samples taken from individuals enrolled in NHANES 2001-2004 and 2007-2010 (tests within years between these dates did not analyze specific pesticides) were reviewed for the presence of pesticides, and compared against data collected on kidney function. In addition to malathion, 2,4-D, chlorpyrifos, and 3-PBA, the major metabolite for most synthetic pyrethroid insecticides, were analyzed for their link to CKD. Scientists adjusted their statistical analysis to incorporate a range of confounders, and conducted a more sensitive analysis that excluded individuals with hypertension and a history of diabetes.

The data reveal malathion to be significantly associated with increased risk of low kidney functioning and CKD. Risk was not significantly increased by exposure to the other pesticides studied. However, malathion retained a significant association even under the sensitivity analysis adjusting for known CKD factors. “The findings suggest we should limit our exposure to pesticides, even in very small doses, as chronic exposure may lead to negative health outcomes,” Dr. Osborne said.

While organophosphate class insecticides like malathion are often cited for their high acute toxicity, it is long-term, chronic exposure to these pesticides that put the general public at greatest risk. Individuals can be exposed to these small amounts by eating conventional, chemical-dependent foods, through mosquito spray programs, drift from nearby landscape applications, and other public recreational areas.

Malathion was first registered in the U.S. in 1956, yet new information on how it harms health is still being uncovered. In addition to damage to kidney function, are concerns over its carcinogenicity. A recent report in The Intercept outlines how rank and file staff at the U.S. Environmental Protection Agency were railroaded by pesticide industry interests into reapproving malathion despite grave concerns over the chemical’s safety.

“When malathion was up for reregistration, when the heads of the various divisions who were looking at health effects were sitting around the table and planning to address the issue, the science adviser poked his head in the door and said, ‘This is a big-ticket pesticide, and we don’t want to have any problems,’” recounted Bill Hirzy, PhD a former EPA official to The Intercept.  Despite strong links between malathion and a range of different cancers, EPA deigned the chemical as having “suggestive evidence of carcinogenicity,” not the stronger “likely carcinogen” designation initially proposed by EPA staff.

Advocates working towards improved public health protections note that the pesticide industry often treats the health effects presented by its products as simply obstacles in the way of future profit. In addition to malathion, glyphosate is the other pesticide that has been strongly associated with the increase in CKD throughout the world. In 2019, two scientists were presented the American Association for the Advancement of Science’s (AAAS) Scientific Freedom and Responsibility Award for their research linking glyphosate to CKD in Sri Lanka. Their work resulted in coordinated attacks on the scientists’ integrity, as well as death threats. The industry’s response to AAAS was swift, placing intense pressure on the group, resulting in a suspension of the decision. After a months long process, science prevailed over industry politics, and the researchers officially received their award. However, these examples show the lengths to which the industry will go work around or discredit those who uncover the dangers of their products.

“Initially, it was suspected the condition [CKD] was associated with agricultural workplaces through exposure to heat stress, dehydration, pesticide spraying, heavy metals and agrochemicals,” Dr. Osborne, coauthor of the current study, said. “However, environmental contamination, pesticide residues and herbal medicines potentially containing heavy metals may also be contributing to CKD.” Dr. Osborne indicates that his team will be looking specifically into the rise of CKD in Sri Lanka. “We will continue to investigate if other pesticides may be involved and are planning to collect data on Sri Lankan farmer behaviours to examine their level of exposure when using pesticides in the field.”

With EPA lacking public trust, there are few available resources that pull together the independent literature and provide a cutting-edge look at the health and environmental hazards of commonly used pesticides. To that end, Beyond Pesticides recently updated and released fact sheets on the Health Effects, and Environmental Effects, of 40 commonly used Lawn Pesticides. As Beyond Pesticides notes, malathion a probable carcinogen by the World Health Organization, and is linked to kidney, liver damage and a range of other health problems that are all too common in today’s world. In addition to the fact sheets on common lawn care pesticides, dig into the Pesticide Gateway for more in-depth analysis on specific pesticides, and the Pesticide Induced Diseases Database for references to cutting-edge scientific studies on pesticide dangers.

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

Source: The University of Queensland press release, International Journal of Environmental Research and Public Health

(Beyond Pesticides, October 18, 2021) The most recent science on pesticides raises serious health and environmental effects associated with pesticide use for lawn and landscape management. While the data is often not assembled in one place, updated factsheets bring together the science on the 40 commonly used pesticides used for conventional landscape management. Governors have the authority to stop the use of these hazardous materials that are used on parks and playgrounds, either by executive order or through their work with their state legislature, and transition land management to organic practices.

Tell your governor to stop hazardous pesticide use on state lands and transition to organic land management.

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

What do the factsheets disclose? Of the 40 most commonly used lawn and landscape pesticides, in reference to adverse health effects…

• 26 are possible and/or known carcinogens
• 24 have the potential to disrupt the endocrine (hormonal) system
• 29 are linked to reproductive effects and sexual dysfunction
• 21 have been linked to birth defects
• 24 are neurotoxic
• 32 can cause kidney or liver damage
• 33 are sensitizers and/or irritants

Regarding adverse environmental effects…

• 21 are detected in groundwater
• 24 have the ability to leach into drinking water sources
• 39 are toxic to fish and other aquatic organisms vital to our ecosystem
• 33 are toxic to bees
• 18 are toxic to mammals
• 28 are toxic to birds

In addition to the factsheets, Beyond Pesticides manages the Gateway on Pesticide Hazards and Safe Pest Management (Pesticide Gateway) and Pesticide-Induced Diseases Database to track the scientific literature and the federal and state regulatory process governing pesticides. Additionally, the organization manages a database, ManageSafe, to provide information on nontoxic methods for common pest management issues.

Tell your governor to stop hazardous pesticide use on state lands and transition to organic land management.

The factsheets distill a large amount of scientific data. For example, the main chemical ingredient in “Roundup® — glyphosate — is the world’s most widely used herbicide. The factsheet identifies glyphosate as a probable human carcinogen, based on findings from the World Health Organization’s (W.H.O.) International Agency for Research on Cancer (IARC). Additionally, research has linked glyphosate to high rates of kidney disease in farming communities and to shortened pregnancy in a cohort of women in the Midwest. Animal studies and bioassays link it to endocrine disruption, DNA damage, decreased sperm function, disruption of the gut microbiome, and fatty liver disease. Glyphosate is also linked to environmental damage. The EPA warns that glyphosate can injure or kill 93% of U.S. endangered species. It is a primary driver of the decimation of monarch butterfly populations because it destroys the milkweed plants their young depend on. Recent research has also shown that glyphosate can disrupt honey bee gut microbiomes, affect larval development, increase colony vulnerability to pathogen infestation, reduce productivity, and impair honeybee navigation, linking the herbicide to declines in bee populations.

Letter to Governor

I am writing to urge you to use your leadership to require the management of our state parks with organic land management practices. My concern about the management of public spaces that are frequented by children and families, those with health vulnerabilities, pets, and wildlife stems from the hazardous nature of the pesticides that are commonly used. These adverse health and environmental effects are displayed in two easy-to-use factsheets, 40 Commonly Used Lawn Pesticides, available at bp-dc.org/lawnfactsheets. With this information, we urge you to issue an executive order to stop the use of these hazardous chemicals and transition park land to organic land management.

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

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

For more in-depth information on additional studies and regulatory information, please visit Beyond pesticides Gateway on Pesticide Hazards and Alternatives at bp-dc.org/gateway. And, the national organization, Beyond Pesticides, is offering to assist you and land managers of our state land to adopt organic land management practices. You can contact them at [email protected].

The factsheets distill a large amount of scientific data. For example, the main chemical ingredient in “Roundup® — glyphosate — is the world’s most widely used herbicide. The factsheet identifies glyphosate as a probable human carcinogen, based on findings from the World Health Organization’s (W.H.O.) International Agency for Research on Cancer (IARC). Additionally, research has linked glyphosate to high rates of kidney disease in farming communities and to shortened pregnancy in a cohort of women in the Midwest. Animal studies and bioassays link it to endocrine disruption, DNA damage, decreased sperm function, disruption of the gut microbiome, and fatty liver disease. Glyphosate is also linked to environmental damage. The EPA warns that glyphosate can injure or kill 93% of U.S. endangered species. It is a primary driver of the decimation of monarch butterfly populations because it destroys the milkweed plants their young depend on. Recent research has also shown that glyphosate can disrupt honey bee gut microbiomes, affect larval development, increase colony vulnerability to pathogen infestation, reduce productivity, and impair honeybee navigation, linking the herbicide to declines in bee populations.

Thank you for your attention to this critical public health and environmental issue. I look forward to your reply.

(Beyond Pesticides, October 15, 2021) Integrated Pest Management (IPM) is a 60-year-old approach to agricultural practice that, when first conceived and implemented, had among its goals a significant reduction of synthetic pesticide use, and the health, environmental, and ecosystemic benefits that would flow from that. However, as a study published earlier in 2021 concluded, IPM has overall been unsuccessful in achieving those goals. The researchers propose to replace IPM with “Agroecological Crop Protection [ACP],” the application of agroecology to protecting crops from damage (usually by insects or weeds). Beyond Pesticides has long embraced the foundations of ACP, which focus on cooperation with natural systems that keep all organisms in healthy, dynamic balance (and avoid overpopulation and trophic cascades).

The research was conducted by scientists from France, Cambodia, and Vietnam; the research paper was published in Agronomy for Sustainable Development. The authors offer myriad reasons for their conclusion that, “More than half a century after its conception, IPM has not been adopted to a satisfactory extent and has largely failed to deliver on its promise. . . . Despite six decades of good intentions, harsh realities need to be faced for the future. . . . IPM has arguably reached its limits.”

The research team, all of whom have worked as IPM scientists and proponents, seems to mourn that IPM has “lost its way” over the decades — moving from ecological and health concerns as primary to its current state, in which (usually chemical) control methods are central. They note, “In cases where the concept of ecology is used in IPM, environmentalism is referenced more often than ecology, i.e., the aim to reduce negative environmental impacts, rather than using ecological processes to replace chemical pesticides.” 

The explanations for IPM’s failure to be adopted effectively and to achieve its goals, as yielded by their research, include: (1) the plethora of definitions of IPM has meant confusion and varying interpretations of the concept by practitioners; (2) there have been inconsistencies between IPM concepts and practices, and public policies; (3) commonly, there is a lack of basic understanding by farmers of the ecological concepts behind IPM; (4) in many IPM programs, chemical controls remain a cornerstone, and that use as a “last resort” is rarely adopted by farmers; (5) IPM research has been paltry, both in scientific and programmatic realms; and (6) “ecology” has been inadequately prioritized in IPM.

Other factors contributing to IPM’s poor record include termination of programs that trained, supported, and guided practitioners; industry meddling; farmer perception of IPM as risky (and therefore not adopting it and/or returning to intensive chemical inputs); lack of effective decision thresholds established for specific crops in specific geographic and pest contexts; and shifting political realities. Overall, once supportive training and funding disappears, the authors assert, pesticide use again surges. The researchers also write, “In settings with resource-poor smallholders, subsistence farming systems, no organic certification schemes, or lagging demand for high-value commodities, the availability of cheap pesticides hinders adoption of IPM.”

There have been some successes with IPM, such as Southeast Asian farmer training programs yielding a 92% pesticide reduction in rice production in Bangladesh, and a 50–70% reduction in tea and cabbage in Vietnam (in the early 2000s). In 2014, research showed that in 500+ IPM programs across the globe, 13% increases in crop yields and 19% increases in farm profits were realized.

Although many years ago, Beyond Pesticides was prepared to consider IPM a tool in the kit bag of reducing pesticide use, even then it recognized the problem of “varied [IPM] definitions and policies . . . numerous perspectives, and critical disagreements among public health and environmental advocates, regulators, and the pesticide and pest management industry.” But currently, given what the study authors call “a quasi-infinite number of definitions and interpretations” of IPM (see more, below), this absence of any standardized definition for IPM means that in the U.S., any registered pesticide can be used and the management system still be considered “IPM.”

Organic agriculture, on the other hand, operates within the codified organic regulations of the National Organic Program (NOP), is bound by the very restrictive National List of Allowed and Prohibited Substances, and is subject to inspection to ensure compliance with NOP standards. Beyond Pesticides understood years ago, and continues to maintain, that organic land management and agriculture are the solution to our agrochemically induced crises — in health, in ecosystem degradation, in biodiversity loss and potential pollinator collapse, in depleted soils, and in water, air, and soil pollution, among others.

Indeed, the landscape is such that, depending on what IPM definition a farmer adopts and employs, management can look very different. One producer might follow a more-original, ecologically oriented set of protocols that prioritize practices such as crop rotation, interplanting, use of cover crops and green manures, and mechanical and biological pest controls. Such an approach might use a low-toxicity pesticide only as a last resort against a particular infestation. Yet, another farmer, using a different definition, may treat pests chemically much of the time. The authors write, “In the majority of cases, chemical control still remains the basis of [most IPM] plant health programs. . . . IPM is not consistent and not compatible with objectives of sustainability, particularly ecological [objectives].”

The researchers take to task the agrochemical industry for its “extensive lobbying, marketing, and wide-ranging manipulation” to advance chemical controls. They write, “Across the globe, IPM technologies struggle to find fertile ground and flourish in settings where farm advisers are paid (or decision-support tools are designed) by this industry, where farmers annually draw loans from chemical suppliers, or where the only accessible source of pest management information is to be found behind the counter of the pesticide shop. Biased information about IPM and pesticide safety thus abounds while the only behavior change that is fervently pursued is the one leading to sustained or enhanced company profits. There are now innumerable accounts of direct and covert interference by agrochemical companies and concerted efforts to sustain IPM beliefs that are aligned with their business plans.” 

IPM was created in the 1950s, and defined by the United Nations Food and Agricultural Organization (FAO) as “the careful consideration of all available pest control techniques and subsequent integration of appropriate measures that discourage the development of pest populations and keep pesticides and other interventions to levels that are economically justified and reduce or minimize risks to human health and the environment. IPM promotes the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms.”

In 1979, its core principles were set out by the White House Council on Environmental Quality: “(i) potentially harmful species will continue to exist at tolerable levels of abundance; (ii) the ecosystem is the management unit; (iii) use of natural control agents is maximized; (iv) any control procedure may produce unexpected and undesirable effects; [and] (v) an interdisciplinary approach is essential.” The accompanying guidelines were these: “Analyze the pest status and establish thresholds; devise schemes to lower equilibrium positions; during emergency situations, seek remedial measures that cause minimum ecological disruption; and devise monitoring techniques.” Last, the federal definition asserted that IPM is about more than “integrating pest management technologies,” saying it should prioritize practices such that pesticides are used as a measure of last resort.

However, through the ensuing decades, the authors note, the number of varying definitions of IPM exploded; some researchers counted 67 various iterations between 1959 and 2000; others identified 42 between 1959 and 2016. The authors write, “It is likely that there are more than a hundred definitions of IPM today [and that] for each definition that emphasizes one particular feature of IPM, another can be found contradicting it. This has led to confusion and to highly inconsistent levels of implementation in the field.” They call out the “the swarm of definitions and interpretations of IPM, which mean we no longer know what we are referring to when we talk about IPM.”

They add that it is actually hard to find characteristics common to all definitions of IPM, though the researchers do proffer several they consider relatively common:

• The primary aim is to integrate the different pest management techniques (regular cropping practices along with genetic, physical, biological, and chemical means).
• [IPM] promotes socio-economic viability and a reduction in use of chemical pesticides to minimize the risks to the environment and public health.
• IPM aims to make chemical and biological techniques compatible and synergistic.
• The use of chemical pesticides is authorized only as a last resort, as implied in the universally accepted FAO definition.

The authors write, “Today, intensive farming has been shown to have reached its limits,” citing “the many harmful consequences of the massive use of pesticides . . . mounting pollution of water, soil and the atmosphere,” and the erosion of biodiversity (especially among insects and birds). They conclude, “This really is the breaking point that must bring about change among farmers. Also, to give more weight to this statement, mankind not only pollutes the planet and puts his health in danger, but the polluters themselves run economic losses. This system cannot be sustainable.”

They add, “It has been recognized that the sustainability of ecosystems in general, and agroecosystems in particular, depends on ecosystem health and functioning, of which the driving force is biodiversity (namely plant, animal and microbial communities — the latter represented by fungal, bacterial and viral organisms).” Having evaluated the failures of IPM, particularly as it has advanced the degradation of functional ecosystems, the research team advocates for a global transition to Agroecological Crop Protection (ACP), an “interdisciplinary scientific field that comprises an orderly strategy (and clear prioritization) of practices at the field, farm, and agricultural landscape level and a dimension of social and organizational ecology.”

ACP is a system whose principles are grounded in ecological concerns and inspired by some approaches to crop protection used in organic agriculture and/or permaculture. The researchers describe it as comprising three components: a scientific discipline, an ordered strategy of cropping practices, and a sociological movement within food systems. ACP seeks to establish (or re-establish) eco-biological balance of communities above and below the soil surface. It does so through preventative measures, and optimization of cropping practices and pest management methods so as to promote functional habitat for wildlife and counter nuisances affecting flora and fauna.

ACP shares features with early definitions of IPM and many, as well, with organic regenerative agriculture. As mentioned above, Beyond Pesticides understands and advances the need for a paradigmatic shift from dominant, chemically intensive approaches in agriculture to “nature cooperative” ones that embody, as Fred Kirschenmann, PhD has called it, our “ecological conscience.” Here in the U.S., the ACP concept might be seen as a similar “meta” rationale for the organic and regenerative agricultural sectors, as well as for the National Organic Program. As intense discussions (and machinations) about the future of agriculture ensue across the globe, Beyond Pesticides continues its advocacy for the transition to organic approaches to agricultural, and all, land management. Please join in to support this vital work.

Source: https://link.springer.com/article/10.1007/s13593-021-00689-w#Sec22

Agronomy for Sustainable Development is an international, peer-reviewed scientific journal that publishes original experimental, empirical, and theoretical research articles, review articles, and meta-analyses leading to enhanced sustainability for agricultural and food systems. The journal’s objective is to interface agronomy, cropping, and farming system research with ecological, genetic, environmental, economic, and/or social sciences.

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

Health and environmental effects disclosed on factsheets to guide community decisions on lawn and landscape management that do not poison people and contaminate the environment.

WASHINGTON, D.C. (October 14, 2021) — Today, the national environmental and public health group Beyond Pesticides is releasing its health and environmental effects factsheets for “40 Commonly Used Lawn Pesticides,” updating and expanding on previous factsheets on 30 pesticides. These comprehensive factsheets documents with scientific citations a wide range of diseases and ecological effects linked to pesticides. The underlying analysis supporting the adverse health and environmental effects identified in the factsheets are based on toxicity determinations in government reviews and university studies and databases.

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

In addition to the factsheets, Beyond Pesticides manages the Gateway on Pesticide Hazards and Safe Pest Management (Pesticide Gateway) and Pesticide-Induced Diseases Database to track the scientific literature and the federal and state regulatory process governing pesticides. Additionally, the organization manages a database, ManageSafe, to address nontoxic methods for common pest management issues.

The 40 commonly used factsheets are a tool for local land management decision-making. Empty cells in the factsheet chart may refer to either insufficient data or if currently available data considers the chemical relatively non-toxic. The ledger following the common chemicals chart includes information on how to interpret the categorization of specific compounds. For instance, the ¥ symbol next to atrazine indicates that this chemical has residential uses specific to the Southeast United States. However, atrazine is also heavily used on Midwestern farms and readily contaminates midwestern waterways, leading to nationwide contamination, information that will be found on the Pesticide Gateway.

“People and community decision-makers need an easy-to-use tool to make informed choices on protecting health and the environment,” said Akayla Bracey, Beyond Pesticides’ science and regulatory manager. “Using this tool in combination with additional tools for sustainable management practices is critical to community and ecological health,” Ms. Bracey continued.

The factsheets distill a large amount of scientific data. For example, the main chemical ingredient in Roundup® — glyphosate — is the world’s most widely used herbicide. The factsheet identifies glyphosate as a probable human carcinogen, based on findings from the World Health Organization’s (W.H.O.) International Agency for Research on Cancer (IARC). Additionally, research has linked glyphosate to high rates of kidney disease in farming communities and to shortened pregnancy in a cohort of women in the Midwest. Animal studies and bioassays link it to endocrine disruption, DNA damage, decreased sperm function, disruption of the gut microbiome, and fatty liver disease. Glyphosate is also linked to environmental damage. The EPA warns that glyphosate can injure or kill 93% of U.S. endangered species. It is a primary driver of the decimation of monarch butterfly populations because it destroys the milkweed plants their young depend on. Recent research has also shown that glyphosate can disrupt honey bee gut microbiomes, affect larval development, increase colony vulnerability to pathogen infestation, reduce productivity, and impair honeybee navigation, linking the herbicide to declines in bee populations.

View the new factsheets for both Health and Environmental Effects of 40 commonly used lawn and landscape pesticides: Health Effects of 40 Lawn Pesticides 2021.pdf (beyondpesticides.org); Environmental Effects 40 Lawn Pesticides 2021.pdf (beyondpesticides.org)

About Beyond Pesticides
Beyond Pesticides is a 501(c)3 nonprofit organization headquartered in Washington, D.C., which works with allies in protecting health and the environment with science, policy, and action to lead the transition to a world free of toxic pesticides.

(Beyond Pesticides, October 13, 2021) Pesticide use in conventional chemical-intensive farming is so pervasive that weeds are developing resistance to herbicides they have never encountered before. According to research published in Plant and Cell Physiology and New Phytologist, the notoriously difficult-to-control weed waterhemp (Amaranthus tuberculatus) is outpacing commercial crops in its ability to detoxify after herbicide exposure. “This is probably the first known example where waterhemp has evolved a detox mechanism that a crop doesn’t have. It’s using a completely different mechanism, adding to the complexity of controlling this weed,” says Dean Riechers, PhD, study co-author and professor at University of Illinois.

Researchers found waterhemp resistant to the chemical syncarpic acid-3 (SA3). SA3 is one of the earliest versions of a 4-Hydroxyphenylpyruvate dioxygenase (HPPD) inhibiting herbicide. HPPD inhibiting herbicides, which include herbicides like isoxaflutole and mesotrione, are selective (ie plant-specific) and break down amino acids that are required for plant growth and development. Corn generally tolerates HPPD-inhibiting chemicals, detoxifying them through different channels depending upon the specific type of HPPD herbicide. Weeds that grow in and around corn fields where these chemicals are regularly sprayed, like waterhemp, have likewise evolved the ability to detoxify HPPD-inhibitors, mostly mimicking the process that corn uses.

However, the current research finds that waterhemp has the ability to detoxify SA3, which corn cannot withstand. Analysis conducted by the University of Illinois scientists determined that waterhemp developed a process completely novel and separate from how corn detoxifies the compounds. While it is usually the Cytochromes P450 enzymes that breakdown hazardous molecules, waterhemp used different enzymes called glutathione S-transferases (GSTs). Instead of breaking down the hazardous substance, waterhemp added electrons to SA3 to dilute the toxicity of the substance. “It’s surprising because not only did the phase-one reactions not proceed as expected, we didn’t even anticipate GSTs to be involved for this class of herbicides,” said study coauthor Crystal Concepcion, PhD. “We don’t see corn preparing chemicals for attack by GSTs. This is very, very rare for herbicides.”

With this novel detoxification process, researchers indicate that waterhemp is likely immune to herbicides it has not yet encountered, and possibly even those that haven’t yet been developed.

The research team was thrown through another loop with waterhemp when it began looking at how it detoxifies other herbicides, particular S-metolachlor, another selective herbicide that is often drenched over soil as a pre-emergent, prior to planting. In this instance, the script was flipped again. Corn, soy and other row crops in this instance employ GSTs to detoxify S-metolachlor. However, while waterhemp did display GST activity, activity of the cytochrome p450 enzymes were 20 fold higher what was found in corn crops or waterhemp plants that were otherwise sensitive to the toxic effects of S-metolachlor. “In this case, we were thinking it was GSTs all the way. But the data told us otherwise. The metabolomics approach we took informed us that GSTs are not the main mechanism to detoxify S-metolachlor in resistant waterhemp. It’s actually p450s,” said Dr. Riechers, who participated in both studies.

Waterhemp is a particularly virulent weed. However, it is not invasive – it is native to the central U.S., and waterhemp was not even a problem for farmers until the early 1990s. Iowa State University points to larger farm sizes, reduced tillage, increased herbicide use, and potentially a hybridized waterhemp species as the culprits, leaving room for some yet “still unknown” factor. However, it is increasingly clear that herbicide use is the prevailing driver of the ever-evolving adaptability of waterhemp plants.

A study published in 2018 found waterhemp in the Midwest to be resistant to six different herbicides from multiple different classes, including mesotrione,  2,4-D, atrazine, chlorimuron, fomesafen, and glyphosate. In response to widespread herbicide resistance, the US Environmental Protection Agency, the pesticide industry, and unfortunately, even the authors of the present study, discuss the problem in the context of finding new chemical classes or mechanisms that will not elicit weed resistance, while allowing the factors that constitute the source of the problem to continue.

A observant study published in 2018 laid out the solution clearly: the best method to reduce herbicide resistance in target weeds is to reduce the overall use of herbicides. Looking at black-grass, a highly adaptable weed found throughout England, researchers tried mixing and rotating herbicides, as well as crop rotation, but the only factor that corresponded with the prevalence of resistant weeds with the amount of herbicide used. Similar patterns have emerged in other chemical-dependent cropping systems. In 2013, researchers found evidence that “stacking” multiple insecticides within insecticide-incorporated genetically engineered (GE) crops increases both the likelihood and speed at which target pests develop resistance.

With EPA guidance suggesting rotating and tank mixing different highly toxic herbicides as methods to “delay” the onset of resistance with a focus on “preserving the useful life of pesticides,” it is little wonder that research is finding that humans are surpassing ‘planetary boundaries’ for resistance. According to a 2018 review, surpassing these boundaries means that civilization cannot continue to rely on the biocides for the same purposes and expect the same outcome. The problems are most pronounced in the realm of drug-resistant antibiotics (which it must be noted, are likely exacerbated by herbicide use), but increasingly noted in conventional and GE agriculture.

Addressing resistance is agriculture requires an approach that embraces natural processes and biological diversity, rather than simplifying the landscape through chemical controls. Stopping herbicide use is the right step, but it must be done in a way that accounts for why herbicides were being used in the first place. Large monoculture cropping systems are a drain against biodiversity and soil health, whereas those that embrace variety within landscape and crop plantings produce higher yields.  

Organic agriculture provides a framework for this shift in thinking. By eschewing harsh synthetic pesticides and fertilizers, and requiring farmers to maintain soil health, organic incentivizes growers to employ natural, nontoxic and biologically based management techniques to bring balance between pest, predator, and crop protection in a landscape.  For background and more information on the dangers of pesticide resistance, see this Pesticide Resistance article in Pesticides and You, and visit Beyond Pesticides insecticide and herbicide tolerant GE crop pages.

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

Source:  University of Illinois press release, Plant and Cell Physiology, New Phytologist

(Beyond Pesticides, October 12, 2021) Tell President Biden and Congress that there is no room for agriculture policies that are not in line with the Executive Memorandum and directive Modernizing Regulatory Review. USDA must remove all barriers to a national transition to organic agriculture.

One of President Biden’s first actions, on the day of his inauguration, was the Executive Memorandum and directive Modernizing Regulatory Review, requiring 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. This mandate should reverse the trend of regulatory review, which has so far protected the status quo, rather than advancing urgently needed change.

Why, then, do we see Secretary of the U.S. Department of Agriculture Tom Vilsack opposing moves in the direction laid out by the Presidential directive? A recent Mother Jones article by Tom Philpott focuses on Mr. Vilsack’s opposition to the “Farm to Fork” initiative in the European Union, which aims to “push the continent’s agriculture in a healthier, more resilient direction, to reduce the use of toxic chemicals in farming, and encourage people to eat less meat.”

As Mr. Philpott points out, “Vilsack’s disdain for the EU’s plan—which dates to last year when he worked as a dairy industry executive—cannot arise from a sense of U.S. superiority. Our diet-related public health troubles are deeper than Europe’s; and climate change and widespread water pollution are ravaging our two most important farming regions, California’s Central Valley and the Midwestern corn belt.”

Farm to Fork sets its sights on reducing reliance on polluting, energy-intensive agrochemicals by setting targets of reducing fertilizer use by 20% and pesticide use by 50% by 2030. It also calls for a 50% reduction in antibiotics in livestock—a major contributor to antibiotic resistance—and a reduction in red meat and processed food. These goals are eminently consistent with President Biden’s goals as expressed in the Executive Memorandum. Is Secretary Vilsack out of step with his boss? Or is the directive just a whitewash concealing business as usual?

Mr. Philpott believes that clues lie in Mr. Vilsack’s friendship with leaders of the United Arab Emirates (UAE) and Brazil. UAE, with its large reserves of oil and natural gas, provides the raw material for synthetic nitrogen fertilizer, a driver for chemical-intensive agriculture, as well as the basis for pesticide manufacture. Brazil is the world’s third-largest user of pesticides (after China and the U.S.), is home to meatpacking giants JBS and Marfig that supply U.S. markets and is known for its environmental and human rights abuses in transforming rainforests into industrial agriculture. UAE and Brazil may be ideal partners for promoting industrial agriculture, but their policies are antithetical to those advanced by the mandates issued by the president.

We urgently need a new direction for agriculture—one that moves toward organic agriculture and away from the use of pesticides, synthetic fertilizers, and abusive land practices. Mr. Vilsack should get with the president’s agenda or get out! 

Tell President Biden and Congress that there is no room for agriculture policies that are not in line with the Executive Memorandum and directive Modernizing Regulatory Review. USDA must remove all barriers to a national transition to organic agriculture.

Letter to President Biden

One of your first actions, on the day of your inauguration, was the Executive Memorandum and directive Modernizing Regulatory Review, requiring 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. This Executive Directive should reverse the trend of regulatory review, which has so far protected the status quo, rather than advancing urgently needed change.

Why, then, do we see Secretary of the U.S Department of Agriculture Tom Vilsack opposing moves in the direction laid out by the Presidential directive? A recent Mother Jones article by Tom Philpott focuses on Mr. Vilsack’s opposition to the “Farm to Fork” initiative in the European Union, which aims to “push the continent’s agriculture in a healthier, more resilient direction, to reduce the use of toxic chemicals in farming, and encourage people to eat less meat.”

As Mr. Philpott points out, “Vilsack’s disdain for the EU’s plan—which dates to last year, when he worked as a dairy industry executive—cannot arise from a sense of US superiority. Our diet-related public health troubles are deeper than Europe’s; and climate change and widespread water pollution are ravaging our two most important farming regions, California’s Central Valley and the Midwestern corn belt.”

Farm to Fork sets its sights on reducing reliance on polluting, energy-intensive agrochemicals by setting targets of reducing fertilizer use by 20% and pesticide use by 50% by 2030. It also calls for a 50% reduction in antibiotics in livestock—a major contributor to antibiotic resistance—and a reduction in red meat and processed food. These goals are eminently consistent with your goals as expressed in the Executive Memorandum. Is Secretary Vilsack out of step with his boss? Or is the directive just a whitewash concealing business as usual?

Mr. Philpott believes that clues lie in Mr. Vilsack’s friendship with leaders of the United Arab Emirates (UAE) and Brazil. UAE, with its large reserves of oil and natural gas, provides the raw material for synthetic nitrogen fertilizer, a driver for chemical-intensive agriculture, as well as the basis for pesticide manufacture. Brazil is the world’s third-largest user of pesticides (after China and the U.S.), is home to meatpacking giants JBS and Marfig that supply U.S. markets and is known for its environmental and human rights abuses in transforming rainforests into industrial agriculture. UAE and Brazil may be ideal partners for promoting industrial agriculture, but their policies are antithetical to those advanced by the mandates issued by the President.

We urgently need a new direction for agriculture—one that moves towards organic agriculture and away from the use of pesticides, synthetic fertilizers, and abusive land practices. Mr. Vilsack should get with the agenda or get out!

Please insist that your Secretary of Agriculture moves USDA in the direction you set out in your Executive Memorandum, Modernizing Regulatory Review.

Thank you.

Letter to Congress

One of President Biden’s first actions, on the day of his inauguration, was the Executive Memorandum and directive Modernizing Regulatory Review, requiring 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. This Executive Directive should reverse the trend of regulatory review, which has so far protected the status quo, rather than advancing urgently needed change.

Why, then, do we see Secretary of the U.S Department of Agriculture Tom Vilsack opposing moves in the direction laid out by the Presidential directive? A recent Mother Jones article by Tom Philpott focuses on Mr. Vilsack’s opposition to the “Farm to Fork” initiative in the European Union, which aims to “push the continent’s agriculture in a healthier, more resilient direction, to reduce the use of toxic chemicals in farming, and encourage people to eat less meat.”

As Mr. Philpott points out, “Vilsack’s disdain for the EU’s plan—which dates to last year, when he worked as a dairy industry executive—cannot arise from a sense of US superiority. Our diet-related public health troubles are deeper than Europe’s; and climate change and widespread water pollution are ravaging our two most important farming regions, California’s Central Valley and the Midwestern corn belt.”

Farm to Fork sets its sights on reducing reliance on polluting, energy-intensive agrochemicals by setting targets of reducing fertilizer use by 20% and pesticide use by 50% by 2030. It also calls for a 50% reduction in antibiotics in livestock—a major contributor to antibiotic resistance—and a reduction in red meat and processed food. These goals are eminently consistent with President Bident’s goals as expressed in the Executive Memorandum. Is Secretary Vilsack out of step with his boss? Or is the Executive Memorandum just a whitewash concealing business as usual?

Mr. Philpott believes that clues lie in Mr. Vilsack’s friendship with leaders of the United Arab Emirates (UAE) and Brazil. UAE, with its large reserves of oil and natural gas, provides the raw material for synthetic nitrogen fertilizer, a driver for chemical-intensive agriculture, as well as the basis for pesticide manufacture. Brazil is the world’s third-largest user of pesticides (after China and the U.S.), is home to meatpacking giants JBS and Marfig that supply U.S. markets and is known for its environmental and human rights abuses in transforming rainforests into industrial agriculture. UAE and Brazil may be ideal partners for promoting industrial agriculture, but their policies are antithetical to those advanced by the mandates issued by the President.

We urgently need a new direction for agriculture—one that moves toward organic agriculture and away from the use of pesticides, synthetic fertilizers, and abusive land practices. Mr. Vilsack should get with the agenda or get out!

Please insist that the Secretary of Agriculture moves USDA in the direction set out in the Presidential Executive Memorandum, Modernizing Regulatory Review.

Thank you.

(Beyond Pesticides, October 11, 2021) The National Museum of the American Indian, a part of the Smithsonian Institution, sits on the National Mall in Washington, DC and as a part of its history program is commemorating Indigenous Peoples’ Day on October 11. This year, President Biden, while commemorating Columbus Day, issued a Presidential Proclamation commemorating Indigenous Peoples’ Day, the first President to do so. The National Museum of the American Indian marks the day with an effort to teach the true history of the United States. This history is introduced on the Museum’s website with the following:

Unlearning Columbus Day Myths: Celebrating Indigenous Peoples’ Day
“Many students learn the phrase, “In 1492, Columbus sailed the ocean blue”. But Columbus was not the first foreign explorer to land in the Americas. Neither he nor those that came before him discovered America—because Indigenous Peoples have populated the Western Hemisphere for tens of thousands of years. European contact resulted in devastating loss of life, disruption of tradition, and enormous loss of lands for Indigenous Peoples in the Americas. It is estimated that in the 130 years following first contact, Native America lost 95 percent of its population.”

“Indigenous Peoples of the Western Hemisphere immediately experienced enslavement and theft of resources by the explorers turned settlers. Colonies created by the Portuguese, Spanish, French, Dutch, and English grew throughout the Americas and increasingly encroached upon Native lives and lands. Warfare, enslavement, and forced relocation disrupted and altered the lives of Indigenous Peoples in the Americas. Celebrating Columbus and other explorers like him dismisses the devastating losses experienced by Indigenous Peoples of the Western Hemisphere in the past and the ongoing effects of colonialism today.”

“Indigenous Peoples are still here. Contemporary Native Americans have led numerous movements to advocate for their own rights. Native people continue to fight to maintain the integrity and viability of Indigenous societies. American Indian history is one of cultural persistence, creative adaptation, renewal, and resilience. Native Peoples, students, and allies are responsible for official celebrations of Indigenous Peoples’ Day in such states as Maine, Oregon, Louisiana, New Mexico, Iowa, and Washington, DC. Indigenous Peoples’ Day is celebrated on the second Monday of October and recognizes the resilience and diversity of Indigenous Peoples in the United States.”

“We promote including Indigenous perspectives, like those of the Taíno Peoples, to provide a more complete narrative when teaching about Columbus. We encourage students to advocate for Indigenous Peoples’ Day as a replacement for Columbus Day in their school, city, state, and beyond.”

Presidential Proclamation and Statement of the Secretary of Interior
The President’s proclamation says: “Our country was conceived on a promise of equality and opportunity for all people — a promise that, despite the extraordinary progress we have made through the years, we have never fully lived up to.  That is especially true when it comes to upholding the rights and dignity of the Indigenous people who were here long before colonization of the Americas began.  For generations, Federal policies systematically sought to assimilate and displace Native people and eradicate Native cultures.  Today, we recognize Indigenous peoples’ resilience and strength as well as the immeasurable positive impact that they have made on every aspect of American society.  We also recommit to supporting a new, brighter future of promise and equity for Tribal Nations — a future grounded in Tribal sovereignty and respect for the human rights of Indigenous people in the Americas and around the world.”

The President also used the occasion of Indigenous People’s Day to announce that he is restoring the original boundaries of Bears Ears and Grand Staircase-Escalante national monuments in Utah. Two million acres had been stripped from the sites by the Trump administration. President Biden said that Bears Ears “is the first national monument in the country to be established at the request of federally recognized tribes. [It’s] a place of healing, a place of reverence, a sacred homeland of hundreds of generations of native peoples.” Secretary of Interior (and former U.S. Representative from New Mexico) Deb Haaland—and the first Native American to hold this position—said. “I am proud to stand with President Biden in restoring these monuments and fulfilling his commitment to the American people.” She continued, “On my visit to Utah, I had the distinct honor to speak with many people who care deeply about this land. The historical connection between Indigenous peoples and Bears Ears is undeniable; our Native American ancestors sustained themselves on the landscape since time immemorial and evidence of their rich lives is everywhere one looks. This living landscape must be protected so that all Americans have the profound opportunity to learn and cherish our history.”  

Source: Washington Post, Salt Lake Tribune

(Beyond Pesticides, October 8, 2021) Taking a page from the playbook of Trump Administration Secretary of Agriculture Sonny Perdue, the current secretary, Tom Vilsack, used a September G20 summit in Italy to target the European Union’s “Farm to Fork” (F2F) strategy, a part of its European Green Deal. Mr. Perdue had said that F2F is “more . . . ‘political science’ than demonstrated agricultural science”; Secretary Vilsack called it “a path very different from the one the U.S. is pursuing.” The F2F initiative aims to transition the EU to a sustainable food system such that it also achieves significant mitigation of climate change. But Mr. Vilsack chose to counter the F2F efforts by promoting an “alternative strategy” — under the moniker “Coalition for Productivity Growth” — through which “other nations pledge not to follow the European path on farm policy.” He has described this alternative, U.S.-led strategy as “a market-oriented, incentive-based, voluntary system [that] is effective” at slashing agricultural carbon emissions.

Climate, pesticide, organics, and other environmental and health advocates, including Beyond Pesticides, are troubled by these actions. Mother Jones poses the central question in the headline of its September 30 article: Why is Secretary Vilsack So Afraid of a Plan to Cut Pesticides and Meat? The central F2F tenets that the secretary seems to find unnerving are those that would slash use of synthetic pesticides and fertilizers, and move one-quarter of European farmland to organic production by 2030.

Mother Jones writes, “The Farm to Fork program, part of the European Commission’s response to the continent’s own accelerating climate chaos and steady rise in illnesses related to highly processed food, aims to ‘make food systems fair, healthy and environmentally friendly.’ At its heart lies the goal of slashing farmers’ reliance on water-polluting, energy-intensive agrochemicals: It requires a 20 percent drop in fertilizer use by 2030, and a 50 percent cut in pesticides. The plan . . . also mandates a 50 percent reduction [in] food waste; calls on farmers to halve their use of antibiotics for livestock, a key driver in the global crisis of antibiotic resistance in human medicine; and aims to nudge Europeans to adopt a ‘diet with less red and processed meat and with more fruits and vegetables.’”

The EU’s F2F strategy — housed within the European Green Deal — is a comprehensive plan to address the climate emergency, and to improve and protect environmental and human health. The F2F strategy sets out a framework for “building a food chain that works for consumers, producers, climate, and the environment.” Elements of the plan include ensuring production levels and food security; extending sustainability practices into the processing, wholesaling, and retail sectors; facilitating a shift to more-healthful diets; reducing food loss and waste; rectifying “food fraud” in supply chains; and supporting research, technology, and investment for the transition to a far more sustainable food system.

The European Commission’s (EC’s) official F2F strategy document emphasizes the “urgent need to reduce dependency on pesticides and antimicrobials, reduce excess fertilisation, increase organic farming, improve animal welfare, and reverse biodiversity loss.” That plan description notes that, because of the groundwork already laid, EU agriculture is the only major production system in the world that has reduced its greenhouse gas emissions in recent years — by 20% over 1990 levels. It aims to increase that to 55% by 2030. The EC wants food produced in the EU to become the “gold standard” for sustainability.

Secretary Vilsack apparently believes that, enacted dominantly across the globe, the tenets of F2F would “reduce crop yields, push up food prices and threaten food security. The U.S. Department of Agriculture (USDA) has released economic models saying world food production would drop by 11 percent and prices would shoot up 89 percent if all countries followed the European model,” according to Politico. The secretary commented, “The world’s got to get fed, and it’s got to get fed in a sustainable way. And we can’t basically sacrifice one for the other.”

His USDA is alarmed at the prospect that this EU approach might spread and result in more trade barriers that could limit markets for U.S. agricultural goods. With intensifying impacts of a worsening climate and pesticide use, he may have a point. In recent years and in the absence of global standards, concerns in Europe and some other countries about intense U.S. use of synthetic pesticides and genetically engineered/modified seeds and foodstuffs have led to restrictions on the import of some U.S. goods.

For example, France is currently seeking to bar food imports produced under what it considers lax environmental, health, and worker standards. Mexico’s announcement of its proposed plan to ban glyphosate and genetically modified maize set some U.S. officials’ hair on fire — so much so that they worked alongside agrichemical companies to persuade President Obrador to quash it. This notion that the U.S. is seen as having inferior standards looms for Big Ag as a threat to its business model and bottom line. Politico writes, “Vilsack’s overarching fear is that Europe would use its diverging food standards to throw up more barriers to trade.”

Now, Secretary Vilsack is assembling an unsavory coalition of the willing, and looking for more adherents, to reject the EU model and pledge to use the industry-friendly approach to agriculture-related environmental policy he is promoting. (The secretary claims there are 10–15 countries interested, though has not publicly named them.) He is pushing the Coalition for Productivity Growth approach, which he hopes will sway producers away from the EU’s F2F model. To date, the UAE (United Arab Emirates) has joined this effort, and the secretary is courting Brazil to do the same.

The secretary’s choice to partner with these two countries could hardly be more transparent, some advocates say. The UAE does very little farming (it imports 80% of its food), but it has huge reserves of oil and natural gas — the latter being the primary feedstock for the production of synthetic nitrogen fertilizers. Such fertilizers are critical to industrial food production in the ag-intensive regions of the United States and Europe.

Mother Jones reports that Brazil is captive to the products of the same agrochemical giants as is the U.S. — Bayer (owner of Monsanto), Syngenta (owned by China), and Corteva (the merger product of Dow and DuPont) — and is the third largest user of synthetic pesticides, behind the U.S. and China. Pesticide use in the country is reportedly rampant. The Bolsonaro-appointed agriculture minister Tereza Cristina — whom environmental journalists have dubbed the “muse of poison” — greenlighted 262 new synthetic pesticides in the seven months of her first year in office (2019); 82 of those were identified by Brazil’s own National Health Surveillance Agency as “extremely toxic.”

Given these facts, it is no surprise that the UAE, and perhaps Brazil, as well as industry groups, such as the International Fertilizer Development Center and the North American Meat Institute, are already on board for the Coalition for Productivity Growth.

The political and environmental records of these state “partners” are very concerning. The UAE is a close ally with the Trump family; Brazil’s president, Jair Bolsonaro, is also a Trump ally and shares, with Donald Trump, an adviser in Steve Bannon. Mr. Bolsonaro’s administration, Mother Jones reports, has “utterly savaged the Amazon rainforest, a crucial store of carbon and home to nearly 1 million indigenous people, opening it to cattle ranching and undermining decades of efforts to preserve it. A July 2021 Bloomberg investigation found that ‘Brazil’s government is engaged in an active campaign to open up the Amazon to privatization and development — first by turning a blind eye as public and protected lands are raided and cleared, and then by systematically pardoning the people responsible and granting them legal title to the stolen lands.’”

Mother Jones offers this critique: “Given the steamrolling of the Amazon and the pesticide free-for-all, Vilsack is essentially embracing the agriculture policies of what counts as a rogue state in climate- and broader environmental-policy terms. At a time when climate change can’t be ignored — with droughts, floods, and fires menacing our key farming regions — a Democratic agriculture secretary is ambling down the same pesticide-scented path trod by Trump.”

By contrast, the head of the EU’s Green Deal, Frans Timmermans, has emphasized that agricultural productivity growth can no longer be the only or primary concern: “We’ve created a system that pushes farmers to increase and go bigger all the time. But that system has pushed the Earth past its limits. We’ve got to stop counting success in terms of the number of ‘wagons of food’ we produce.” 

Many members of the public, and those in the advocacy communities, might have expected better from a Biden Secretary of Agriculture, particularly given the administration’s understanding of the threats of the climate emergency. Indeed, there was optimism at the early flurry of executive orders that signaled the new administration’s appreciation for the need for systemic-level review and climate action across federal agencies.

It appears now that Secretary Vilsack missed the memo; his endorsement of this industry-friendly Coalition for Productivity Growth signals serious inattention — or downright ignoring — of the harmful impacts of industrial agriculture on climate, health, environment, biodiversity, and natural resources. Beyond Pesticides maintains that the transition to organic regenerative agriculture, which counters environmental and other harms, is imperative and urgent.

When he nominated Tom Vilsack for a second turn as the nation’s agriculture secretary (and head of USDA), there was mixed reaction among advocates and the public. Some, such as the nonprofit Farmworker Justice, embraced the choice, largely because during his previous tenure in the Obama administration, Mr. Vilsack had engaged with the farmworker community in relatively unprecedented ways. Others were less thrilled; the nomination was criticized on multiple fronts. Beyond Pesticides wrote, in December 2020, “Judging from his past record, President-elect Biden’s announced pick for Secretary of Agriculture, Tom Vilsack, will need to dramatically change many previous positions in order to implement the elements of President-elect Biden’s policy framework.” 

As governor of Iowa in the early 2000s, he got cozy with the state’s industrial agriculture and biotech sectors. The Counter reported in a 2019 investigation that “employees alleged that Vilsack’s USDA repeatedly ran out the statute of limitations clock on discrimination complaints, while attempting to foreclose on farmers whose cases hadn’t yet been resolved. Employees also said that USDA manipulated Census data to obscure a decline in Black farming, which in turn allowed Vilsack to paint a rosy but inaccurate picture of his tenure.” During that tenure, he “allowed big agribusiness to carry out inspections themselves, rather than [be inspected by] federal government inspectors,” and allowed a significant increase in slaughter line speeds in poultry plants — raising the risks of processing worker injury.

Immediately prior to his current tenure, Secretary Vilsack worked as a lobbyist for the Dairy Export Council, during which time “he made clear his opposition to policies that . . . would break up corporate agriculture conglomerates.” He also, for all his talk early in the Obama era of concern about the plight of small farmers, went on to allow rapid consolidation in the agricultural sector, which often squeezes out small farmers. The Center for Food Safety wrote that he “promoted factory farms with funds intended to reduce agricultural greenhouse gas emissions” by supporting methane digesters on site at CAFOs (Concentrated Animal Feeding Operations), absent evidence of their efficacy. He was also on watch at USDA when he expedited the approval process for GMOs (genetically modified organisms), and when Bayer purchased GMO giant Monsanto. (He has been dubbed “Mr. Monsanto” by some critics.)

Politico writes that the kerfuffle over F2F represents a “food fight” over how to transform the global food system, and suggests that at risk may be not only billions of euros in annual agricultural trade, but also, progress on reining in climate change through cooperation around respective food systems. This is not “small potatoes” because agricultural enterprises are responsible, globally, for roughly one-third of greenhouse gas emissions — due in large part to the use of synthetic chemical pesticides and fertilizers, and animal wastes. The outlet writes that in an interview with him, Secretary Vilsack “barely veiled his criticism of the EU’s farming philosophy.”

Secretary Vilsack’s enthusiasm for industry interests has been covered repeatedly. His rationale for his challenge to the EU’s plan comports with those interests, but is being cloaked in language about “market-based” approaches, “considering impacts and tradeoffs among multiple objectives,” and “linking” climate, environment, and resource goals to the production goals. For some in the environmental and health advocacy communities, it sounds a lot like the greenwashing in which industry engages. See the USDA web page describing the initiative.

How goals for climate and resources and health survive this initiative — never mind potentially experience any success — remains to be seen. All of which begs the question: what will President Biden do about this apparent deviation from his climate mandates for federal agencies? Advocates and the public would do well to let President Biden know that this initiative is not only wrong-headed and destructive, but also, violates the mandates he set out and promised to enforce. Contact President Biden here.

Source: https://www.motherjones.com/food/2021/09/vilsack-agriculture-pesticides-eu-farm-to-fork-brazil-rainforest-meat/

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

(Beyond Pesticides, October 7, 2021) The Arizona State Auditor General reports a lack of groundwater monitoring for pesticides and other contaminants by the Arizona Department of Environmental Quality (ADEQ). For over six years, the agency failed to monitor groundwater and soil for agricultural pesticide contamination. Furthermore, the agency did not implement key groundwater monitoring processes over four years, despite law requirements. This lack of waterway monitoring resulted in an increased number of impaired surface waters across the state.  

Pesticide contamination in waterways is historically commonplace and widespread throughout U.S. rivers and streams, with at least five or more different pesticides present in 90 percent of water samples. Thousands of tons of pesticides enter waterways (e.g., rivers, streams, lakes, oceans) around the U.S. from agricultural and nonagricultural sources, contaminating essential drinking water sources, such as surface water and groundwater. Reports like these are essential in determining appropriate regulatory action to protect human, animal, and environmental health from chemical toxicant contamination. The report states, “[The] Department has not developed all required aquifer water quality standards, conducted key ongoing groundwater monitoring of the State’s aquifers, monitored for agricultural pesticides in groundwater and surrounding soil, or reduced the number of impaired surface waters in the State, limiting its ability to keep these waters safe from pollution.”

Arizona’s state Auditor General established this report to determine whether the ADEQ upheld the responsibility to develop aquifer water quality standards (AWQS). ADEQ’s Water Quality Division is responsible for waterway protection and improvement systems, including developing an AWQS to protect Arizona groundwater. These standards include conducting ambient groundwater monitoring, monitoring agricultural pesticides in groundwater and the surrounding soil, and reducing impaired surface waters in Arizona. Moreover, the report investigates whether ADEQ provided information related to per- and polyfluroralkyl substance (PFAS) contamination in waterways. To determine if ADEQ upheld its responsibility to protect groundwater, the auditors reviewed state and federal water laws, ADEQ website information, and documentation (i.e., policies, procedures, finances, annual reports, and staff interviews).

The report finds ADEQ did not develop the required AWQS for eight different toxicants, including arsenic, uranium, coliform bacteria, chlorite, chlorobenzene, haloacetic acid, bromate, and trihalomethane (e.g., chloroform). Therefore, aquifers that transmit liquid to groundwater tables lack protection from these contaminants, decreasing drinking water safety, especially for private well users. Additionally, the report finds that ADEQ did not fulfill AWQS development objectives for these eight contaminants for the past seven to 29 years. Since 2017, ADEQ evaded monitoring ambient groundwater responsible for detecting and evaluating the impact of chemical contamination. Furthermore, the Department failed to conduct state-required monitoring of groundwater and adjacent soil for agricultural pesticides. The ADEQ established a goal to reduce the total amount of impaired or contaminated surface water to meet federal surface water quality standards. However, between 2014 and 2020, the number of impaired surface waters in Arizona increased from 136 to 155. Lastly, although the Department aims to address the issue through various steps (i.e., monitorization, investigation, remediation), PFAS continues to contaminate Arizona’s (and the nation’s) waterways.

Pesticide contamination of surface and groundwater raises another issue of deficient waterway monitoring and regulations that allow pesticides to accumulate in waterways. One of the ways the U.S. Environmental Protection Agency (EPA) protects human and environmental health is by regulating pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and point source pollution in waterways as regulated by the Clean Water Act and Safe Drinking Water Act. However, EPA under the previous administration rolled back waterway regulations, which do little to protect aquatic ecosystem health that marine, and terrestrial species, including humans, require. Previously, U.S. Geological Survey (USGS)-National Water-Quality Assessment (NAWQA) has criticized EPA for not establishing sufficient water quality benchmarks for pesticides. According to NAWQA, “Current standards and guidelines do not completely eliminate risks posed by pesticides in waterways because: (1) values are not established for many pesticides, (2) mixtures and breakdown products are not considered, (3) the effects of seasonal exposure to high concentrations have not been evaluated, and (4) some types of potential effects, such as endocrine disruption and unique responses of sensitive individuals, have not yet been assessed.”  

According to advocates, this report represents an all too familiar pattern of government and state agencies failing to uphold their responsibility to protect the public from toxic pollutants. Aquatic environments continuously encounter environmental pollutants, and this study demonstrates that certain unmonitored toxic compounds exceed federal drinking water standards. All eight contaminants lacking adequate AWQS have links to severe health problems, especially among vulnerable individuals such as infants/children, pregnant individuals, and the elderly or immunocompromised. These health issues range from kidney problems to an increase in various cancers. However, the ubiquity and persistence of certain compounds make it difficult to limit the number of toxicants that enter waterways. Many of the most commonly used pesticides in the U.S. are detectable in both surface and groundwater, which serve as drinking water sources for half of the U.S. population. As the number of pesticides in waterways increases, it has detrimental impacts on aquatic ecosystem health, especially as some chemicals work synergistically (together) with others to increase the severity of the effect. In addition to adverse health effects on marine organisms, these chemicals harm terrestrial organisms relying on surface or groundwater. The report, “Human Health and Ocean Pollution,” finds that the combination of nonpoint source chemical contamination from pesticide runoff can have an adverse synergistic effect on species’ health and ecosystem. Many of these chemicals cause endocrine disruption, reproductive defects, neurotoxicity, and cancer in humans and animals while being highly toxic to aquatic species. 

Between 2009 and 2013, preceding this report, pesticide monitoring data show that ten pesticides have the potential to contaminate groundwater, including those containing active ingredients like chlorpyrifos, diuron, and quaternary ammonium compounds (quats). However, ADEQ states the Department halted pesticide groundwater monitoring owing to a lack of funding and staff. Although these pesticides were not present at concentrations polluting groundwater, these compounds can accumulate in soil and water, increasing concentrations over time. Furthermore, these pesticides cause adverse health effects: chlorpyrifos is neurotoxic, diuron is carcinogenic, and quats sensitize and irritate the respiratory system. Groundwater pollution is a significant issue, especially in the Southwestern United States. For the first time, the U.S. government announced a Colorado River water shortage. The river supplies water to nearly 40 percent of Arizona residents, in addition to other adjacent states. This announcement follows a 2020 groundwater model update from the Arizona Department of Water Resources that reveals there is not enough groundwater to legally meet dozens of developmental requirements and ensure a water supply for 100 years. 

All aquatic environments are essential to human health and well-being, feeding billions, supporting millions of jobs, and supplying medicinal materials. Therefore, this report recommends ADEQ adopt legislation for AWQS to match that of federal drinking water standards or establish AWQS for the eight contaminants. The report recommends the following: 

• “Conduct statutorily required ambient groundwater monitoring and agricultural pesticide monitoring in groundwater and soil.
• Perform a workload analysis to assess its costs for developing AWQS and conduct ambient groundwater and agricultural pesticide monitoring and then work with the Legislature to obtain the needed resources.
• Reduce the number of impaired surface waters in the State by developing and reviewing implementation plans for reducing impaired surface waters in a timely manner.”

Government and health officials must address chemical pollution to safeguard 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 pesticides and other persistent organic pollutants trapped in ice. Beyond Pesticides has long advocated for healthier and more environmentally friendly pest management practices to protect the environment and wildlife, particularly water resources. Therefore, pesticide use should be phased out and ultimately eliminated 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 regenerative systems conserves water, nurtures soil fertility, reduces surface runoff and erosion, and reduces the need for nutrient input (i.e., fertilizers). Most critically, organic systems eliminate the use of toxic chemicals that threaten so many aspects of human and ecosystem life, including water resources. For more information about pesticide contamination in water, see Beyond Pesticides’ article Pesticides in My Drinking Water? Individual Precautionary Measures and Community Action, where Beyond Pesticides states: “This problem requires individual precautionary measures and preventive, community-based action to protect [individual and public health] and ultimately, stop ongoing pesticide use that ends up in drinking water from numerous agricultural, public land, and home and garden use. Beyond Pesticides urges a solution that keeps pesticides out of the water, rather than trying to clean them up after they enter our waterways and drinking water supply.”

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

Source: Arizonia Public Media, State Auditor Review

(Beyond Pesticides, October 6, 2021) Agricultural soils under monoculture cropping systems are not as healthy as soils with diverse plantings, finds research recently published in the journal Agrosystems, Geosciences and Environment. Soil and soil quality are declining rapidly in the United States and around the world, with recent data indicating that the U.S. Corn Belt has lost 35% of its topsoil. Advocates say it is critical that the response to this problem focus on practices that conserve and improve the soil health by building organic matter and healthy microbial populations. “Understanding the management practices that lead to healthier soils will allow farmers to grow the same crops while reducing costly chemical inputs (fertilizers, pesticides, herbicides) and protecting the environment,” said study coauthor Lori Phillips, PhD.

To investigate disparities in soil health between cropping systems, researchers analyzed a long-term cropping system that includes 18 years of continuously grown soy, corn, and perennial grasses. Each cropping system was evaluated for its bacterial and fungal population, as well as a test called CNPS, which measures the enzymes produced by microbes specifically related to the soil’s carbon, nitrogen, phosphorous, and sulfur cycles. Researchers indicate that these measurements create “a holistic measure of biological activity,” according to a press release. While soil organic matter has long been the standard indicator of soil health, its measurement changes very slowly in soils. The CNPS test, which researchers have found correlates with soil organic matter, helps provide a more detailed snapshot of soil health at a given point in time.

Unsurprisingly, perennial grasses are found to contain the best soil health indicators. Within the perennial grasses, the community consisting of red fescue and birdsfoot trefoil (a legume) was found to contain healthier soil than a system with only tall fescue grass. Both soil organic matter and CNPS activity are higher for the grasses than for the monoculture crops by 2- or 3-fold. Microbial communities are also markedly different between monoculture crop and perennial grass soils. The study notes these perennial systems have much more microbial diversity, over eight times more mycorrhizal fungi, and higher ratios of fungi to bacteria.

The higher ratio of fungi to bacteria is likely indicative of the frequency of plowing in the monoculture systems, which occurred each year after harvest, according to the study. Repeated tillage breaks fungal connections that help stabilize soil, which can lead to worsening soil structure. “Intensively managed agricultural soils, with more frequent tillage and high fertilizer inputs, tend to be dominated by bacteria. In contrast, more sustainable management practices increase the overall amount of fungi in soil,” Dr. Phillips notes.

Both monoculture corn and soy are found to have low soil organic matter and CNPS indicators, and high bacterial counts in their soils. However, the soil in soybean crops are found to be the least healthy. “Many people assume that because soybean is a legume and legumes provide their own nitrogen through nitrogen fixation, that soybean must be healthy for the soils,” said Dr. Phillips, noting that soybeans take up most of the available nitrogen during their growing period. “So, it’s the cumulative effect of smaller roots, less residue returned, and the residue that is returned gets broken down too quickly to be stable.”

Although the authors did not delve into specifics over synthetic fertilizer and pesticide usage on the monoculture sites, prior studies that utilize the long-term cropping systems studied in the current paper indicated the regular use of 28% urea-ammonium nitrate fertilizer, glyphosate, glufosinate, and atrazine (perennial grasses were mowed regularly). All of these products have a strong propensity to harm soil health. A review on glyphosate published in 2017 found risks to soil that include the reduction of nutrient availability for plants and organisms, lower diversity, specifically, reductions of beneficial soil bacteria, increases in plant root pathogens, disturbed earthworm activity, reduced nitrogen fixing at plant roots, and compromised growth and reproduction in some soil and aquatic organisms. Synthetic fertilizers are particularly problematic, requiring high amounts of fossil fuels to produce, and releasing toxic carbon-trapping byproducts into air and waterways after application. Because synthetic fertilizers are in plant available form, whatever is not immediately taken up by a plant most simply runs off through the soil. Microbial populations are likewise harmed by these quick influxes of nutrients, resulting in damage to soil structure, soil diversity, and nutrient availability.  

Poor soil health impacts the ecosystem services that a given area can provide. From decomposition of organic matter to carbon fixation and nutrient cycling, a healthy stock of soil microbes are critical. Research finds that the less diverse soil microbes are, the less functional a landscape will be.

“Agricultural management practices that reduce soil disturbance, reduce chemical inputs, and increase the amount of time the soil is covered by a living crop all contribute to improved soil biological health,” said Dr. Phillips. “Improved soil biological health will lead to more profitable and sustainable farms.”

When deciding how to manage land, whether for a farm, garden, natural land, or right-of-way, it is critical to think holistically about management practices. Working with and mimicking natural processes should be the focus, with product inputs used only to support sustainable cultural practices. Organic agriculture provides a successful framework for this approach, eschewing toxic synthetic products in favor of natural materials that are compatible with organic systems. Research finds that organic production provides multiple benefits to human society, including long-term ecological, public health, and socioeconomic advantages over conventional, chemical-dependent systems that are often monoculture focused and only work at industrial scales.

For more information on creating holistic organic systems, see Beyond Pesticides article in our quarterly newsletter Pesticides and You, Thinking Holistically When Making Land Management Decisions.  

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

Source: Agrosystems, Geosciences and Environment

(Beyond Pesticides, October 5, 2021) The U.S. Fish and Wildlife Service (USFWS) will consider listing the American bumblebee (Bombus pensylvanicus) under the Endangered Species Act, according to a notice published in the Federal Register late last month. Earlier this year, the Bombus Pollinator Association of Law Students at Albany Law School and the Center for Biological Diversity petitioned the agency to list the species. USFWS review of the petition indicates that it found “substantial scientific or commercial information indicating that the petitioned actions may be warranted,” and will determine over the next year whether final listing and further protective actions are warranted. 

With the American bumblebee experiencing an 89% decline in its population over the last 20 years, scientists and advocates  believe it is critical for USFWS to take steps to protect what remains of this iconic species. At one time, the American bumblebee’s range extended from eastern Canada south through the United States into Florida, and as far west as California. Oregon is the only state in the continental US where the species has never been spotted. Declines are particularly pronounced in the northern part of its range, where recent sightings are nil, and assessments for states like New York, Michigan, and West Virginia indicate the species is subsisting at 1% of its historical population levels. While populations are slightly more stable in its southern range, overall abundance is rapidly dropping in states like Arkansas and Georgia, which have experienced 72% and 74% declines, respectively.  

Like the Rusty-patched bumblebee, which was recently listed as endangered by USFWS, declines are related to pesticide use, habitat loss, climate change, and disease spread. While bumblebees are generalist foragers, each year a multitude of factors must come together to ensure their population grows. Choosing a spot to nest and overwinter can be fraught with challenges. American bumblebees often nest on the surface, right below ground, or in old logs with mere inches of cover (usually consisting of leaves and twigs). While queen bumblebees do their best to find a quiet, undisturbed site, human activity – ranging from tillage and other agricultural activities to site preparation and construction can destroy overwintering colonies. Mistiming arousal from hibernation with the availability of floral resources due to climate change can likewise stress bumblebees. To respond to climate change, bumblebees must be successful in both moving from away from inhabitable locations and building their population in these new locations – the American bumblebee has so far failed in both accounts. While foraging, diseases can spread between domesticated pollinators and wild bumblebees.

Pesticide use represents one of the most significant threats to bumblebees, and places their entire life cycle at risk. A 2018 study found that commonly used neonicotinoid insecticides begin to kill off bumblebees during their nest building phase, as exposure makes it more difficult for a queen to establish a nest. Then, even if they are successful in setting up a nest, neonicotinoids inhibit bumblebee queens from laying eggs, according to a 2017 study. Exposure to neonicotinoids unsurprisingly results in bumblebee colonies that are much smaller than colonies not exposed to the systemic insecticide, per research published in 2016. And the workers that hatch from these pesticide-exposed queens, that are likely to again be exposed in the field? A 2017 study finds that neonicotinoid exposure decreases pollination frequency and results in fewer social interactions. That is likely because neonicotinoids alter bumblebee feeding behavior, and degrade the effectiveness of bumblebee’s classic “buzz pollination” process.

It is evident that while each of the factors contributing to the decline of the American bumblebee are problematic in their own right, pollinators are exposed to multiple stressors at once. When looking at pesticide exposure, neonicotinoids represent only one class out of thousands of agrichemicals that pollinators could be exposed to. Research published in 2017 determined that fungicides, particularly the chemical chlorothalonil, are playing important roles in bumblebee declines by increasing susceptibility to pathogens like Nosema bombi.

As a result, the most critical aspect of any potential listing under the Endangered Species Act will have to do with what is known as “critical habitat.” This is the area deemed essential to conserving a threatened or endangered species. Such a designation provides the opportunity to establish a range of additional protections within the species’ range. Unfortunately, actions by USFWS do not bode well for recently listed pollinators. For the Rusty-Patched Bumblebee, USFWS determined that declaring critical habitat was not warranted. USFWS claimed that the bumblebee “can find the habitat it needs in a variety of habitats,” and instead has appeared to place priority on mapping potential habitat and public education. While these steps are important, it is critical that meaningful protections be placed around pesticide use and development within the bumblebee’s range. For the monarch butterfly, USFWS actions were even more disturbing. In late 2020, USFWS concluded that monarchs met the criteria for listing, but doing so was precluded due to other higher-priority listing actions. Despite recognizing the dangers that the iconic butterfly faces, USFWS deferred to ongoing state and local efforts to protect the species, merely indicating that the status of the species will be reviewed yearly.

To protect the habitat of endangered species, the U.S. Environmental Protection Agency is required to consult with USFWS and other wildlife agencies when pesticide exposure is likely to affect a listed species. However, the agency regularly fails to perform this role, requiring conservation and environmental organizations to sue in order to prioritize protective actions. Frustrated with this process, in 2019 the Center for Biological Diversity submitted a petition to USFWS and the National Marine Fisheries Services calling on agencies to prohibit pesticide use in all areas deemed critical habitat under the Endangered Species Act.

In light of recent news, U.S. government agencies must prioritize the strongest protections possible for threatened and endangered species. USFWS announced last week that 22 animals and one plant are officially extinct, with causes linked to human-driven habitat destruction, climate change, and other forms of industrial development. Perversely, declaring these species extinct eliminates protections, and any critical habitat that was designated to protect the declining plant or animals. In the future, such a process could result in additional allowances for damaging practices like pesticide use or development. It is not acceptable for taxpayer-funded agencies fail at their purpose, and then weaken protections after that failure.

Take action by urging federal agencies to address mass extinction like the crisis it is by incorporating biodiversity goals into the decision-making process for pesticide approvals. And for more information on the dangers pesticides pose to wildlife and endangered species, see Beyond Pesticides Wildlife program page.

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

Source:  Federal Register, Center for Biological Diversity press release

(Beyond Pesticides, October 4, 2021) Recent findings of high levels of toxic pesticides in products permitted to be used as “minimum risk pesticides” (terminology used for essentially nontoxic) point to the need for greater oversight of these products and more severe penalties for violations. Pesticides classified as minimum risk are allowed under Section 25(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) [40 CFR 152.25(f)] to be used without going through EPA’s pesticide registration process. These products are limited to a specific list of ingredients, and all ingredients, including “inert” ingredients, are required to be listed on the label. 

Minimum risk pesticides are used by organic growers, municipalities, and others who are not permitted to use, or choose to avoid, toxic chemicals. 

Tell EPA and Congress to protect the integrity of minimum risk pesticides.

Organic growers can lose their organic certification if they apply materials that are prohibited, which include the toxic ingredients glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl, found by the state of California in dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Contamination of these products came to light in late July, when the California Department of Food and Agriculture’s (CDFA) State Organic Program issued a Stop Use Notice to farmers, alerting them to adulteration of Eco-MIGHT and W.O.W products. The California Department of Pesticide Regulation (the state’s primary enforcement agent for pesticides) sent a warning letter to EcoMIGHT LLC, which produces both of the products in question, alerting them that they “may be in violation” of state law. EPA sent a similar advisory letter to the company indicating that it may be in violation of FIFRA by misbranding, selling an unregistered pesticide (given the presence of ingredients disallowed in 25(b) minimum risk products), and false and misleading label statements, which could make the company “subject to penalties of not more than $7,500 for each independently assessable violation.”

While these warning letters may be the first step in criminal enforcement action, they are inadequate to protect the organic farmers and other users who depend on the integrity of the products as represented by the company. The process for action is slow, the initial penalties are inconsequential, and real people will be hurt as a result. 

EPA must initiate better oversight over the manufacture and sale of minimum risk pesticides. It must take immediate action to stop sale of products misbranded as minimum risk pesticides. There must be real penalties—severe enough to incentivize against fraudulent practices—assessed against violators.

Tell EPA and Congress to protect the integrity of minimum risk pesticides.

Letter to U.S. Congress

Recent findings of high levels of toxic pesticides in products permitted to be used as “minimum risk pesticides” point to the need for greater oversight of these products and more severe penalties for violations. Pesticides classified as minimum risk are allowed under Section 25(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) [40 CFR 152.25(f)] to be used without going through EPA’s pesticide registration process. These products are limited to a specific list of ingredients, and all ingredients, including “inert” ingredients, are required to be listed on the label.

Minimum risk pesticides are used by organic growers, municipalities, and others who are not permitted to, or choose to avoid, toxic chemicals.

Organic growers can lose their organic certification if they apply materials that are prohibited, which include the toxic ingredients glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl, found by the state of California in dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Contamination of these products came to light in late July, when the California Department of Food and Agriculture’s (CDFA) State Organic Program issued a Stop Use Notice to farmers, alerting them to adulteration in Eco-MIGHT and W.O.W products. The California Department of Pesticide Regulation (the state’s primary enforcement agent for pesticides) sent a warning letter to EcoMIGHT LLC, which produces both of the products in question, alerting them that they may be in violation of state law. EPA sent a similar advisory letter to the company indicating that it “may be in violation” of FIFRA by misbranding, selling an unregistered pesticide (given the presence of ingredients disallowed in 25(b) minimum risk products), and false and misleading label statements, which could make the company “subject to penalties of not more than $7,500 for each independently assessable violation.”

While these warning letters may be the first step in criminal enforcement action, they are inadequate to protect the organic farmers and other users who depend on the integrity of the products as represented by the company. The process for action is slow, the initial penalties are inconsequential, and real people will be hurt as a result.

EPA must initiate better oversight over the manufacture and sale of minimum risk pesticides. It must take immediate action to stop sale of products misbranded as minimum risk pesticides. There must be real penalties—severe enough to incentivize against fraudulent practices—assessed against violators.

Congress must ensure that penalties in FIFRA are sufficient to eliminate abuse of Section 25(b).

Thank you for your consideration of this important issue.

Letter to EPA Administrator Michael Regan

Recent findings of high levels of toxic pesticides in products permitted to be used as “minimum risk pesticides” point to the need for greater oversight of these products and more severe penalties for violations. Pesticides classified as minimum risk are allowed under Section 25(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) [40 CFR 152.25(f)] to be used without going through EPA’s pesticide registration process. These products are limited to a specific list of ingredients, and all ingredients, including “inert” ingredients, are required to be listed on the label.

Minimum risk pesticides are used by organic growers, municipalities, and others who are not permitted to, or choose to avoid, toxic chemicals.

Organic growers can lose their organic certification if they apply materials that are prohibited, which include the toxic ingredients glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl, found by the state of California in dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Contamination of these products came to light in late July, when the California Department of Food and Agriculture’s (CDFA) State Organic Program issued a Stop Use Notice to farmers, alerting them to adulteration in Eco-MIGHT and W.O.W products. The California Department of Pesticide Regulation (the state’s primary enforcement agent for pesticides) sent a warning letter to EcoMIGHT LLC, which produces both of the products in question, alerting them that they may be in violation of state law. EPA sent a similar advisory letter to the company indicating that it “may be in violation” of FIFRA by misbranding, selling an unregistered pesticide (given the presence of ingredients disallowed in 25(b) minimum risk products), and false and misleading label statements, which could make the company “subject to penalties of not more than $7,500 for each independently assessable violation.”

While these warning letters may be the first step in criminal enforcement action, they are inadequate to protect the organic farmers and other users who depend on the integrity of the products as represented by the company. The process for action is slow, the initial penalties are inconsequential, and real people will be hurt as a result

EPA must initiate better oversight over the manufacture and sale of minimum risk pesticides. It must take immediate action to stop sale of products misbranded as minimum risk pesticides. There must be real penalties—severe enough to incentivize against fraudulent practices—assessed against violators. If penalties in FIFRA are not sufficient, then EPA should request Congress to increase the penalties.

Thank you for your consideration of this important issue.

(Beyond Pesticides, October 1, 2021) With this article, Beyond Pesticides rounds out its coverage of recent revelations about compromised science integrity at the U.S. Environmental Protection Agency (EPA). As Sharon Lerner reports in her September 18 (and third in a series) article in The Intercept, new documents and whistleblower interviews reveal additional means by which EPA officials have gone out of their way to avoid assessing potential health risks of hundreds of new chemicals. Ms. Lerner writes that “senior staff have made chemicals appear safer — sometimes dodging restrictions on their use — by minimizing the estimates of how much is released into the environment.” Beyond Pesticides regularly monitors and reports on scientific integrity at EPA, including two recent articles that reference Ms. Lerner’s The Intercept reporting; see “EPA Agenda Undermined by Its Embrace of Industry Influence,” and “Whistleblowers Say EPA Managers Engaged in Corrupt and Unethical Practices, Removed Findings, and Revised Conclusions.”

Whistleblowers had already provided evidence of agency malfeasance, particularly in EPA’s New Chemicals Division (NCD), such as “managers and other officials . . . pressuring [EPA scientists] to assess chemicals to be less toxic than they actually are — and sometimes removing references to their harms from chemical assessments.” Now, these career scientists have added new revelations to that tranche of disturbing information, evidenced by internal emails, meeting summaries, screenshots from EPA’s internal computer system, and testimony offered in interviews with them and other EPA scientists.

In its August 6 Daily News Blog article, Beyond Pesticides also wrote about the whistleblowers’ experiences of management retaliation for their outspokenness and advocacy for public health — including functional reassignment or demotion. A high-profile case is that of Ruth Etzel, MD, PhD, the former director of the EPA’s Office of Children’s Health Protection, who is among the (now five) current or former EPA scientists who have recently come forward with allegations of corruption at the agency. Dr. Etzel maintains that EPA officials tried to silence her because of her insistence on stronger lead poisoning prevention programs. She was placed on leave without pay in September 2018; in a mid-September 2021 hearing before the federal Merit Systems Protection Board she testified that EPA had “issued public statements designed to discredit and intimidate her,” and that the agency has become deeply corrupted by corporate and political influence.

A little context for the recent revelations: EPA uses two measures to assess a chemical’s potential health risks. One is its toxicity; the other is the amount of the compound people are likely to be exposed to in the environment. Previous whistleblower evidence, as noted above, shows that officials have pressured agency scientists to distort toxicity assessments. On the exposure front: since 1995, EPA has operated under a rubric that says, basically, if exposures are below a given threshold — the “below modeling threshold” — safety is presumed. If exposures are considered to rise above that threshold, EPA scientists are required to quantify the precise risk posed by the chemical.

However, in recent years, scientists have determined that “some of the chemicals allowed onto the market using this [threshold] loophole do in fact present a danger, particularly to the people living in ‘fence-line communities’ near industrial plants,” or proximate to other sources of chemical pollution, including chemically managed (with synthetic pesticides) agricultural fields. Agency scientists became increasingly concerned, given emerging information on low-level exposures, that use of these “exposure thresholds” might be putting the public at unnecessary risk, including for cancers.

The recent reports from whistleblowers indicate that in 2018, a manager in EPA’s Office of Pollution Prevention and Toxics (OPPT) instructed agency scientists “to change the language they used to classify chemicals that were exempted from risk calculation because they were deemed to have low exposure levels. Up to that point, they had described them in reports as ‘below modeling thresholds.’ From then on, the manager explained, the scientists were to [use] the words ‘expects to be negligible’ — a phrase that implies there’s no reason for concern.”

Several of the scientists involved with risk calculations were unhappy about this; they also understood that using this “threshold” protocol leaves people at risk for health effects of low-level chemical exposures. They suggested to managers that instead, the thresholds be lowered so as to capture more risk data, and that they do calculations for each individual chemical under consideration — a task they noted would add mere minutes to their assessment process.

But, as Ms. Lerner reports, “The managers refused to heed their request, which would have not only changed how chemicals were assessed moving forward, but would have also had implications for hundreds of assessments in the past. ‘They told us that the use of the thresholds was a policy decision and, as such, we could not simply stop applying them,’ one of the scientists who worked in the office explained to The Intercept.” Documents provided by some whistleblowers show that NCD managers have repeatedly been unresponsive to or dismissive of calls to change that policy — even when scientists have demonstrated that it puts the public at risk.

In February 2021, a small group of agency scientists reviewed EPA’s “safety” thresholds for every one of the 368 new chemicals submitted to the agency in 2020. They found that more than half of the chemicals could pose health risks — including chemicals whose exposure potentials had already been deemed “expect[ed] to be negligible,” and thus, for which specific risk calculations had not been done. Once more, the scientists brought this issue to NCD managers, explained their analysis, and requested that the use of these thresholds be terminated. The response from division managers? Crickets. As The Intercept writes, “Seven months later, the thresholds remain in use and the risk posed by chemicals deemed to have low exposure levels is still not being calculated and included in chemical assessments.”

Such problematic dynamics comprise a substantial part of what the EPA whistleblowers have reported, and would appear to be, efforts by senior staff to undermine and contravene EPA’s actual mission — “to protect human health and the environment.” The Intercept article quotes one of the two scientists who filed new disclosures with EPA’s Office of the Inspector General (OIG) on August 31: “Our work on new chemicals often felt like an exercise in finding ways to approve new chemicals rather than reviewing them for approval.”

Ms. Lerner asks why it is that “some senior staff and managers within the EPA’s New Chemicals Division seem to feel an obligation not to burden the companies they regulate with restrictions.” Advocates suggest a variety of answers. “That’s the $64,000 question,” commented PEER (Public Employees for Environmental Responsibility) Director of Science Policy Dr. Kyla Bennett. She has said that some career staff at EPA have been “captured by industry.” Government watchdog organizations, such as PEER, as well as Beyond Pesticides, have noted the dysfunctional “revolving door” between EPA and industry. Dr. Bennett noted (in a PEER webinar attended by the author on September 22) that one agency manager moved back and forth between EPA and the private chemicals industry four times.

According to reporting by Carey Gillam for U.S. Right to Know (RTK), a research project out of Harvard University’s Edmond J. Safra Center for Ethics reported that, though EPA has “‘many dedicated employees who truly believe in its mission,’ the agency has been ‘corrupted by numerous routine practices,’ including a ‘revolving door’ between EPA and industry in which corporate lawyers and lobbyists gain positions of agency power, [and there is] constant industry lobbying against environmental regulations, pressure from lawmakers who are beholden to donors, and meddling by the White House.”

Dr. Bennett has noted that, “EPA staffers may enhance their post-agency job prospects within the industry if they stay in the good graces of chemical companies. . . . [and that] managers’ performance within the division is assessed partly based on how many chemicals they approve. ‘The bean counting is driving their actions,’ said Bennett. ‘The performance metrics should be, how many chemicals did you prevent from going onto the market, rather than how many did you get onto the market.’”

Both Dr. Richard Denison of the Environmental Defense Fund, and Tim Whitehouse of PEER (the nonprofit that represents the whistleblowers and has filed complaints on their behalf with the OIG), have described the culture of the Office of Chemical Safety and Pollution Prevention, and of OPPT’s New Chemicals Division, especially. Dr. Denison has said, “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.” Mr. Whitehouse asserted that “politics has overtaken professionalism among managers at EPA.”

Dr. Denison also (in the September 22 webinar) pointed to the insularity of NCD, noting that it has little-to-no engagement with non-industry stakeholders, such as advocates in the health or labor sectors. Further, he charges the program with nurturing a “culture of secrecy” that results in failures to provide timely public access to industry data on chemicals or EPA’s own safety evaluations, and often yields massively redacted health and safety information. This violates stipulations of the Toxic Substances Control Act (TSCA), the authorizing law created in 1976 to protect the public from “unreasonable risk of injury to health or the environment” by regulating the manufacture and commercial sale of chemicals.

Ms. Lerner’s The Intercept article dives into specifics on how NCD’s failure to attend to low-level exposure risks is exacerbating cancer risks. Cancer is a health outcome that can result from even micro-exposures to certain chemical compounds; indeed, EPA’s Guidelines for Carcinogenic Risk Assessment instruct agency scientists “to assume that there is no safe level of agents that are ‘DNA-reactive’ and have ‘direct mutagenic activity.’” In spite of this, NCD managers have inappropriately ignored or dismissed cancer risks about cancer risks based on the assumption that a chemical would be diluted in the air, according to evidence presented by the whistleblowers.

This was the case for at least two chemicals “assessed” in 2021. EPA deemed one of those (a component of adhesives) “not likely to present an unreasonable risk of harm.” The other — a dialkyl sulfate that is one of a class of chemicals that causes cancer in animals — was one of 13 similar chemical submissions the agency received between June 2020 and August 2021.

According to a whistleblower’s account in late August, “EPA managers took several steps to make the dialkyl sulfate chemical appear safer than it really is. . . . Because they didn’t have sufficient testing of the substance itself, the scientist assessing it chose a closely related compound to gauge its risks. But a manager replaced that analogue, which causes miscarriages in animal experiments, with another, less harmful chemical, which allowed the agency to officially dismiss concerns about harms to the developing human fetus.”

In addition, exposure information was added to the dialkyl sulfate assessment without notification to the scientist who wrote it. The assessment indicated that the compound poses a cancer risk and acknowledged it could cause genotoxicity; a manager’s change to the assessment added language to indicate that “genotoxicity is not a concern ‘due to the dilution of the chemical substance in the media [such as the air].’”

The scientists dissented, citing evidence that related compounds are known to remain in the air for at least eight days. Although EPA has not (officially) calculated potential cancer risks for all the submitted chemicals in the class, one of the whistleblowing scientists has — and found that some do represent significant cancer risks. In their complaint to the OIG, the scientists wrote: “The Agency is failing to calculate potential cancer risks to the general population based on the fallacy that a chemical is expected to be ‘diluted’ in the air. . . . You don’t always find risk when you look for it. But they’re not even trying.”

The Intercept requested comment on its September 18 article from EPA; the agency referred the outlet to the same statement it had provided in response to the first two pieces in the series. As The Intercept wrote, “That statement said, in part, ‘This Administration is committed to investigating alleged violations of scientific integrity. It is critical that all EPA decisions are informed by rigorous scientific information and standards. As one of his first acts as Administrator, Administrator Regan issued a memorandum outlining concrete steps to reinforce the agency’s commitment to science.’”

According to advocates, this seem to be a feeble response to reporting of malfeasance in EPA’s own house. The references to scientific integrity, they say, ring a bit hollow, given the flagrant violations of that very integrity alleged by the whistleblowers.

EPA does, indeed, have a Scientific Integrity Policy. It emphasizes the importance of adherence to professional values and practices when conducting and applying the results of science and scholarship. The policy is supposed to ensure objectivity, clarity, reproducibility, and utility, and to “provide insulation” from bias, fabrication, falsification, plagiarism, outside interference, censorship, and inadequate procedural and informational security.

However, as PEER has written on its website, “During Trump’s tenure, the record indicates EPA’s Scientific Integrity program was inoperative and it has yet to revive. . . . EPA’s Scientific Integrity program is a beacon of false hope and, in that sense, is worse than useless.” PEER goes on to enumerate the problems: “Major hindrances in EPA’s Scientific Integrity program include the total lack of investigative staff, the inability to draw upon expertise needed to assess technical issues, and the absence of any protocol for reviewing or investigating complaints. Further, EPA’s Scientific Integrity Policy carries no penalties for violations. As a result, the only tool the program has is trying to persuade non-compliant managers to address their own violations when raised by their subordinates.”

PEER reports that EPA’s last annual report on the Scientific Integrity (SI) program was in 2018. PEER obtained outcome data for the period from mid-2018 through mid-2021: 35 allegations were filed, 22 remained “active” (i.e., unresolved), 12 had been closed or referred — and exactly one complaint was deemed “substantiated.” That case was about a staff allegation, brought in November 2020, that a memo that changed policy — such that human health assessments would be far less likely to find risk for new chemicals being evaluated — was ignored for months by managers. 

Of that case PEER writes, “The allegations in the complaint were ‘sustained,’ and this resulted in managers temporarily revoking the policy memo in question. However, it appears that the memo may be reissued, and the altered assessments were not corrected. Notably, this was the only complaint classified as ‘sustained’ during the past 30 months.” Dr. Kyla Bennett commented, “‘It has become clear that the only way to force EPA to address scientific malpractice is to avoid the Scientific Integrity program altogether and go public.’ [She notes] that the Scientific Integrity program repeatedly acts as if it is a branch of Human Resources, seeking to deflect or suppress staff complaints. ‘EPA needs to stop protecting managers who violate EPA’s scientific integrity policy and deal with them appropriately.’”

The above-referenced September 22 PEER webinar — a panel discussion of how EPA risk assessments for new chemicals have been improperly altered to eliminate or minimize risk calculations — surfaced a number of reforms promoted by PEER. (The webinar panelists were Dr. Kyla Bennett, Science Policy Director at PEER; Mindi Messmer, Co-founder of New Hampshire Science and Public Health and NH Safe Water Alliance; and Richard Denison, Lead Senior Scientist at the Environmental Defense Fund.)

The top-level recommendation is that NCD needs a “massive overhaul.” More specifically, Drs. Denison and Bennett point to these reforms:

• There must be public access, early in the review process of a new proposed chemical, to documents submitted by industry and being generated by EPA with only legal redactions.
• The public must be able to weigh in on proposed new chemicals.
• All data need to be submitted before the 90-day clock starts ticking; a 30-day public comment period would be useful, with time allotted for consideration of comments before agency determination on a chemical.
• EPA managers or other officials who have engaged in corrupt practices should be publicly identified, terminated, and replaced.
• A pre-application meeting of agency scientists and the industry applicant before the application is submitted would be a wise initiative.

Dr. Denison commented that “applicant understanding of any agency concerns and what would alleviate them would be a fine thing; but to let industry strongly lobby for alteration of science or conclusions is awful. Any discussion of the science between EPA and industry must be publicly accessible.” Dr. Bennett added, “Pre-application discussion can be appropriate — a ‘tell us what you need to make a good assessment’ kind of conversation. This 90-day deadline drives some of the abuse. Industry must bring forward all the information needed to make science-based risk assessments; currently, EPA is often looking only at industry studies, or sometimes, receives no data at all.”

In addition, improved protection of government whistleblowers should be a priority. As PEER asserts, “We are all too aware of the precarious health of our planet, and to protect it we must also protect our democracy. Those who would enable the wholesale poisoning, bulldozing, and privatization of our nation can rely on exploiting flaws in our democratic processes, but we are in a unique position to correct those flaws.”

The Protecting Our Democracy Act, or PODA, is a bill first introduced in 2020, and reintroduced in the House of Representatives on September 21, 2021. It contains many democracy-protective features, as well as more-robust protections of government whistleblowers. PEER continues: “The Protecting Our Democracy Act is a critical patch to our nation’s operating system, correcting fundamental security flaws which have been exploited for far too long by malicious actors who want to see government and public protections for the environment emaciated, corrupted, or outright destroyed.”

In July 2021, Beyond Pesticides added these recommendations: “EPA [must] recalibrate itself in alignment with a precautionary approach, and move aggressively and authoritatively on its protective mission. Other [important reforms] are: Congressional funding of the agency at levels required to perform well . . . [and] EPA Office of the Inspector General and Congressional crackdowns on the ability of industry to interact with the agency, and on the ability of the revolving door to continue to operate. The public can pressure elected officials to take up such measures; find your U.S. Senator and Representatives here.”

Source: https://theintercept.com/2021/09/18/epa-corruption-harmful-chemicals-testing/

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