(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.

(Beyond Pesticides, September 30, 2021) Individuals working or living in areas with frequent neurotoxic pesticide use experience more amyotrophic lateral sclerosis (ALS) incidences than the general population. The study, published in NeuroToxicology, finds a positive association between sporadic (non-genetic, spontaneous) ALS incidences among individuals exposed to neurotoxic pesticides. 

Amyotrophic lateral sclerosis (or Lou Gehrig’s disease) is a neurodegenerative disease that affects the nerves in the brain and spinal cord. As many as 16,000 – 20,000 Americans live with this condition, which weakens muscle/motor function leading to loss of muscle control for walking, talking, eating/swallowing, and breathing. Severe ALS progression is fatal and has no current cure. Although research supports genetic factors play a role in disease etiology (cause), most ALS cases do not result from genetic inheritance. Several research studies demonstrate exposure to environmental or work-related toxicants (i.e., pesticides) predispose humans to the disease. With researchers predicting a global ALS incidence increase of 69% by 2040, identifying ALS’s causal factors are important to future research. Therefore, research like this showcases the importance of assessing aggregate health risks associated with toxic chemical exposure, especially for illnesses, which are not curable. In this study, the researchers note, “[W]e identified pesticides applied to crops in the area of residences associated with risk of ALS in a large healthcare claims network. Our analysis identified several herbicides, insecticides, and fungicides that have been implicated in the literature as being neurotoxic as potential ALS risk factors. Other less-studied pesticides that we identified also may warrant further investigation in the laboratory to assess mechanisms, their potential as etiologic contributors to sporadic ALS risk, and as targets for exposure mitigation.”

Using U.S. Geological Survey (USGS) data, researchers estimated potential exposure to pesticides, including insecticides, herbicides, and fungicides, at residential locations. The USGS data includes applications of 423 pesticides on crops and compared results to the geospatial diagnosis of approximately 26,000 ALS patients identified through the medical claims database, SYMPHONY Integrated Dataverse®. The study split patients from the SYMPHONY dataset into two groups, with researchers confirming results via residential information on ALS mortality from various state studies (e.g., New Hampshire, Vermont, Ohio). Both the study results and the confirmation studies validate pesticides have the highest positive association with neurotoxicity. Scientists find and 2,4-D (herbicide), glyphosate (herbicide), carbaryl (insecticide), and chlorpyrifos (insecticide) significantly increase ALS risk among residentially exposed populations.

ALS is a nervous system disorder that is progressive and fatal, affecting the brain, spinal cord, a vast network of nerves and neurons. The nervous system is responsible for many bodily functions, from the five senses to motor function. However, exposure to chemical toxicants, like pesticides, can cause neurotoxic effects or exacerbate preexisting chemical damage to the nervous system. The impacts of pesticides on the nervous system, including the brain, are hazardous. Mounting evidence over the past years shows that chronic exposure to sublethal (low) levels of pesticides adversely affects the central nervous system (CNS). Specifically, researchers identify agricultural chemical exposure as a cause of many adverse CNS impacts. In addition to CNS effects, pesticide exposure can impact a plethora of neurological diseases. These diseases include amyotrophic lateral sclerosis (ALS) and Parkinson’s disease, dementia-like diseases such as Alzheimer’s, and other effects on cognitive function.

The agricultural industry has a long-standing history of synthetic chemical use, which disproportionally affects farmworkers’ health. Farmworkers’ children are at greater risk as their immune system response is immature and especially vulnerable to stressors from pesticide exposure. Synthetic chemicals present in pesticides can accumulate in bodies, causing an amalgamation of health effects. Pesticides expose farmers, farmworkers, landscapers, and their families to heightened risks of various cancers (i.e., prostate, hepatic, liver, etc.), mental health problems (i.e., depression), respiratory illnesses (asthma), endocrine disruption, and many other pesticide-induced diseases. However, pesticide exposure is ubiquitous and not only confined to a field. The general population encounters pesticides from chemical applications and, most likely, residues in food and water resources.

Various studies indicate agricultural occupations as frontrunners for major pesticide exposure scenarios significantly associated with ALS development. However, this study is one of the few to evaluate ALS incidents among residential populations living near chemical-intensive agricultural fields. Like this study, past studies indicate that specific pesticide groups (e.g., herbicides) have higher associations with ALS risk and demonstrate neurotoxicity. For instance, herbicides glyphosate and 2,4-D increase the risk for neurological anomalies, including Parkinson’s disease. Particularly, glyphosate induces toxicity similar to paraquat, another herbicide associated with increased ALS risk. These compounds increase ALS risk through oxidization and reduction in ATP (adenosine triphosphate) levels that provide energy to cells in all organisms. The insecticide carbaryl is a notoriously dangerous carbamate insecticide with the ability to inhibit acetylcholinesterase (AChE), an enzyme important for the transmission of nerve impulses. Acetylcholine inhibition leads to overstimulation of neurotransmitters, resulting in muscle weakness, confusion, and paralysis, among other symptoms. Exposure to chlorpyrifos causes neurotoxicity among children, who may develop learning/developmental disabilities, as well as increasing Parkinson’s disease risk for all individuals living close to agricultural areas. These chemicals represent some of the most used compounds throughout the U.S. Even with residential uses of glyphosate and uses of chlorpyrifos on food crops (already banned for residential use) ending in February 2022, these compounds will remain in the environment for years, further contaminating the ecosystem. Moreover, the pesticide marketplace still contains many chemicals that cause neurotoxic health effects. 

Although the study demonstrates ALS incidents are highest in the Midwest, where pesticide use is most chemically intensive, proximity to agricultural fields does not generally result in higher rates of ALS. In fact, geospatial analysis suggests certain chemical compounds used in agricultural areas, especially the Midwest, have neurotoxic effects that increase disease risk. However, scientists suggest future studies should focus on the relationship between exposure patterns and how that influences ALS incidents in specific regions. The researchers conclude, “Detailed residential history studies centered in high exposure areas would help elucidate the etiologic period. in situ sampling at varying distances from fields during various pesticide application events and weather conditions would aid exposure estimation efforts. Additional approaches such as behavioral questionnaires and biosample pesticide measurements in prospective longitudinal studies could provide a more complete picture of pre-diagnostic exposures.”

There is a lack of understanding on the etiology of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiological data. Exposure to pesticides can increase the risk of developing chronic illnesses that may be rare and disproportionately impact various populations. Therefore, studies related to pesticides and neurological disorders can help scientists understand the underlying mechanisms that cause neurodegenerative diseases. Although occupational and environmental factors, like pesticides, adversely affect human health, there are several limitations in defining real-world poisoning, as captured by epidemiologic studies in Beyond Pesticides’ Pesticide-Induced Diseases Database (PIDD) and Daily News Blog. The adverse health effects of pesticides, exposure, and the aggregate risk of pesticides showcase a need for more precise research surrounding occupational and residential pesticide exposure in order to make complete determinations. However, current evidence suggests the need for a precautionary approach. Existing information, including this study, supports the clear need for a strategic shift away from pesticide dependency. For more information on pesticides’ harm to human health, see PIDD pages on brain and nervous system disorders (including ALS) and other diseases. 

Beyond Pesticides advocates a precautionary approach to pest management in land management and agriculture by transitioning to organic. Buying, growing, and supporting organic can help eliminate the extensive use of pesticides in the environment and from your diet. A complement to buying organic is contacting various organic farming organizations to learn more about what you can do. For more information on why organic is the right choice for consumers and the farmworkers who grow our food, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture. Those impacted by pesticide drift can refer to Beyond Pesticides’ webpage on What to Do in a Pesticide Emergency and contact the organization for additional information.

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

Source: NeuroToxicology

(Beyond Pesticides, September 29, 2021) Bats foraging in chemical-intensive banana plantations have much less gut diversity than bats foraging in organic banana fields and natural forestland, finds research published this month in the journal Frontiers in Ecology and Evolution. Although there is increasing recognition that a diet of conventional, chemically grown food leads to adverse disruptions of the gut microbiome (also known as dysbiosis), little research has been conducted on the effect of production practices on the gut of wild foraging species. According to the present study there are significant differences that regulators must begin to account for in pesticide risk assessments, and consumers should consider when making choices at the supermarket.

Researchers focused their investigation on Pallas’s long-tongued bat (Glossophaga soricina), a nectar feeding bat native to Central and South America. The bat is highly adapted to human environments, sustaining populations in both conventional and organic banana plantations, as well as surrounding forest land. For the study, researchers trapped nearly 200 bats across the country of Costa Rica over a 22-month time span. After trapping, physiological characteristics, like size and body weight, were measured, and bat guano was analyzed for its microbial population. All sampled bats were released back into their habitat.

Bats that forage in agricultural land – whether organic or conventional, were found to be overall larger in size and weight than bats that live primarily in the forest. This was likely a result of a diet heavily reliant on the nectar from banana plants. However, bats in organic plantations had significantly higher levels of gut biodiversity than those in conventional plantations (based on a range of analyses, including observed amplicon sequence variants, Shannon diversity index, and Faith’s Phylogenetic Diversity index). Gut diversity in organic bats was found to be similar to the diversity analyzed in forest bats. The study indicates that it is likely that organic practices are maintaining a “high diversity of commensal microbiota,” while on the other hand, “less diverse gut microbiota in bats foraging in conventional monocultures may suggest that these habitats potentially have negative physiological consequences for the animals (e.g., gut inflammation and metabolic disease), and may act as ecological trap.”

The authors conclude that sustainable, organic farming methods are healthier for bat populations. “Our study shows that more sustainable agricultural practices can have less of an impact on wildlife,” said Priscilla Alpízar, a doctoral student at the University of Ulm in Germany. “Hopefully, our findings can lead the efforts to work together with producers and consumers to find more sustainable and bat-friendlier agricultural practices.”

Organic practices are also healthier for the human microbiome. A study published in 2019 found that organically grown apples contain a much more diverse bacterial community than their conventional counterparts. Research on the benefits of organic production to human gut bacteria follow other studies on the add-on benefits of organic to our health, for milk, meat, strawberries, tomatoes, and a range of other foods.

On the other hand, gut dysbiosis from diets based on conventional, pesticide-laden, and highly processed foods has been linked to a range of adverse health effects. In a 2020 study, researchers identified developmental defects, diabetes, cardiovascular disease, liver disease, obesity, thyroid disorders, and improper immune operation all to be associated with changes to the gut after exposure to environmental contaminants. Glyphosate herbicides have received particular attention in this arena, with a finding from a study earlier this year showing 54% of species in the human gut sensitive to glyphosate exposure.

Despite the growing body of work linking gut bacteria to overall health, the concept is generally ignored by pesticide regulators around the world. As with other issues, like endocrine disruption and trophic cascades, it is critical that regulators consider the emerging science on the dangers of pesticides and adjust restrictions on their use. In this context, scientists are considering complex issues beyond contributors to the mortality of humans, animals, and plants, and are studying overall health and fitness and the myriad of examples of how pesticides harm fitness in unexpected ways. For that reason, it is critical that consumers join in calling on the U.S. Environmental Protection Agency to consider emerging science in pesticide decision-making.

The way we grow food is directly connected to the nourishment it provides. For more information on the connection between soil ecology, growing practices, and the gut microbiome, read the article Sustaining Life, From Soil Microbiota to Gut Microbiome, published in Pesticides in You, by David Montgomery, who presented this discussion to Beyond Pesticides 35^th National Pesticide Forum in Minneapolis, MN.  And for more information on why buying organic whenever possible is the right choice, see Beyond Pesticides Organic Agriculture program page.

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

 Source: Frontiers in Ecology and Evolution, Phys.Org press release

(Beyond Pesticides, September 28, 2021) A widely used mosquito pesticide may exacerbate the effect of the Zika virus on fetal brain development, according to research published by an international team of scientists in the journal Environmental Pollution. Pyriproxyfen, an insect growth regulator often used as a mosquito larvicide, is registered for use in hundreds of commonly used pesticide products. But scientists have discovered that the pesticide’s mode of action has the potential to worsen the public health mosquito diseases the chemical aims to control. The research reinforces the extent of unknowns associated with synthetic pesticide exposure, underlining the need for a focus on nontoxic and ecological mosquito management.

Scientists base their research on reports that in Brazil, during the 2015 Zika epidemic, certain areas of the country experienced higher rates of microcephaly. Microcephaly is a rare condition that causes pregnant women’s fetus to develop severe cranial deformities, alongside a range of other symptoms that include vision problems, hearing loss, feeding issues, developmental delays and seizures. The present study aimed to see how pyriproxyfen, used at higher rates in areas where microcephaly Zika cases were recorded, may interact with the virus.

In an article published in The Conversation, researchers note that until now data on the role of pyriproxyfen in the microcephaly epidemic showed contradictory results. Based on prior research, it was hypothesized that a particular metabolite of pyriproxyfen (4′–OH–PPF), rapidly metabolized in the body of both people and wildlife (vertebrates and invertebrates), was playing a role due to its effects on thyroid hormone production. As the study notes, “[thyroid hormones] THs are key to evolutionary expansion of brain size and complexity, a primary characteristic of humans.”

To test this hypothesis, researchers used genetically engineered tadpoles developed to light up green in the presence of thyroid hormone. Once these tadpoles were dosed with the chemical, their green coloring diminished significantly, indicating that pyriproxyfen was blocking the production of thyroid hormones.

Effects on the thyroid were targeted for analysis because of the critical role thyroid hormones play in the development of brain cells. In a follow up experiment, scientists took stem cells created from mouse brains and exposed them to varying levels of the pyriproxyfen metabolite. As dosage increased, so did the death of brain cells.

Researchers discovered that tadpole brains exposed to the chemical display altered gene expression. Focus increases on one particular gene – Msi1, which contains the protein Musaschi-1. Zika employs that protein in order to transmit the virus to other cells in an individual’s body. In the mouse experiment, brain cells that did not die after chemical exposure were found to contain higher levels of this protein.

“That’s why we hypothesized that, through increasing Musaschi-1, pyriproxyfen could allow the virus to replicate faster,” the authors wrote in The Conversation. While the study does not provide support for the chemical increasing viral infection rates, scientists did find that exposure could exacerbate an existing infection, resulting in more harmful health impacts when exposed to both pyriproxyfen and Zika together.

The scientists note that similarly concerning findings have been made for other diseases and pesticides on the market. A study published in October 2020 found that the commonly used fungicide fludioxonil has the potential to decrease human immune defenses against Covid-19. Subsequent research published in February of this year found that Covid-19 vulnerability could increase with exposure to organophosphate pesticides.

Although the public is generally familiar with the concept of pesticides causing specific health outcomes like cancer, there is a growing body of science showing how pesticides can exacerbate certain illnesses, or cause a range of deleterious impacts in the environment that ultimately lead to human disease.  

As the author’s write, “…for many other ubiquitous pesticides to which we are continuously exposed in our daily life, we have no clue as to how they affect us, and whether they interact with viral diseases… Our study emphasizes again how little we know about the harmful effects of pesticides on human health, notably on brain development, but also the natural environment as a whole.”

Take action to tell EPA to consider cutting edge science in agency decision makings, and follow the precautionary approach when deciding whether to register a pesticide.

Proper mosquito management does not rely on the use of any one particular product but takes a holistic, ecological approach that places emphasis on nontoxic practices first. This includes an emphasis on mosquito monitoring and surveillance, public education, ecological analysis, and habitat alterations. Toxic synthetic larvicides and insect growth regulators like pyriproxyfen should be eschewed in favor of biological materials like Bacillus thuringiensis israelensis (Bti). Adulticides should always be a last resort and used only in the sustained presence of a disease vector. For more information about safer mosquito control, see Beyond Pesticides webpage on Mosquito Management and Insect-Borne Diseases.

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

Source: Environmental Pollution, The Conversation

(Beyond Pesticides, September 27, 2021) The National Organic Standards Board (NOSB) is receiving written comments from the public through September 30. This precedes the upcoming public comment webinar on October 13-14 and online meeting October 19-21—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov.

As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong (KOS) and the Fall 2021 issues page. In the spirit of “continuous improvement,” we urge you to submit comments (please feel free to use our comments on the KOS page) that contribute to an increasingly improved organic production system.

The Organic Foods Production Act (OFPA) requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. Among the issues up for consideration at this meeting is a material that the National Organic Program (NOP) has taken off the NOSB’s sunset agenda for several years—sodium nitrate. There are also issues affecting organic integrity that need to be addressed—systemic fraud and plastic—as well as decisions about other materials that are described on the Fall 2021 issues page. We earlier conducted an action on priority issues. The issues below add to the earlier list, if you have the time.

Sodium nitrate (aka Chilean nitrate) is a mined mineral that is used as a highly soluble nitrogen source in agriculture. In recognition of the fact that its high solubility makes it inconsistent with organic production, which “feeds the soil, not the plant,” it was added to the National List of Allowed and Prohibited Materials, originally with the annotation as prohibited “unless use is restricted to no more than 20 percent of the crop’s total nitrogen requirement.” In 2011, the NOSB voted to remove the annotation, thus making sodium nitrate a prohibited natural. NOP never acted on this recommendation, nor did it allow the NOSB to vote on the listing during five-year sunset evaluations. OFPA requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. It also requires that the National List be “based on” recommendations of the NOSB. The NOSB is considering whether to back down on its 2011 recommendation. It must stand firm and tell NOP to follow the recommendation that the board made 10 years ago.

Preventing Fraud. The NOSB is asking for comments on proposals to “modernize supply chain traceability” in order to reduce fraud in organic production. While improved technology can contribute to increased compliance, the most important barriers to organic integrity are systemic. We offer as an example the plight of organic dairy farmers who have been left high and dry after being abandoned by their main processor, Danone/Horizon, which has announced that it is terminating its contracts with 89 small-to-medium-sized organic dairy producers in the Northeast as of August 2022. At that point, all of Horizon’s contracted organic dairy farms in Vermont, New Hampshire, Maine, and northern New York may well have no buyers for their milk and will likely face a very uncertain future. Why is Danone cancelling contracts as organic milk production in the Northeast is increasing? In Danone’s words, the company “will be supporting new partners that better align with our manufacturing footprint.” In other words, the company doesn’t need to depend on local fresh milk suppliers when low cost, ultra-pasteurized milk that is easily transported and warehoused has become a staple on the organic shelf. More importantly for the future of organic dairy is the expectation that USDA will promulgate a weak regulation on origin of livestock—that will allow the massive loophole of being able to sell or transfer transitioned animals as certified organic. Such a regulation, in combination with the continued failure to enforce rules requiring organic livestock to have access to pasture, makes it profitable to produce “organic” milk in industrial concentrated animal feeding operations (CAFOs), where cows are fed cheap imported “organic” grain instead of pasture. Organic consumers do not want CAFO milk, but many will have no other choice without strong regulations. In other words, this serious problem of fraud in organic grain and dairy is not due to a lack of “tools” available to certifiers and inspectors, but to the systematic problems—caused by a system that creates incentives to replace pasture with imported grain. Better enforcement tools can assist in returning integrity to organic dairy, but only if NOP and certifiers enforce access to pasture and promulgate a strong regulation on origin of livestock that closes the loophole allowing dairies to sell or transfer transitioned animals as certified organic.

Plastic is increasingly identified as a source of environmental and health problems, and therefore, should be eliminated in organic production and packaging. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Some studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Soil organisms and edible plants have been shown to ingest microplastic particles. Earthworms can move microplastics through the soil, and microplastics can move through the food chain to human food. Microplastics can have a wide range of negative impacts on the soil, which are only beginning to be studied, but include reduction in growth and reproduction of soil microfauna. Microplastics can serve as hotspots of gene exchange between phylogenetically different microorganisms by introducing additional surface, thus having a potential to increase the spread of antibiotic resistance gene] and antibiotic resistant pathogens in water and sediments. Plastic mulches, including those called Biodegradable Biobased Mulch Film (which do not fully degrade), should be replaced with natural mulches such as straw, hay, wood chips, and cover crops that add organic matter to the soil. Replacement of plastic in packaging should be a research priority.

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(Beyond Pesticides, September 24, 2021) Recent research out of California sought to compare (and quantify) differences in total pesticide use, and in use of pesticides of specific concern, across conventional and organic agricultural fields in the state. The research team, from the Bren School of Environmental Science and Management, University of California, Santa Barbara, finds an 18–31% likely reduction in spraying of pesticides on organically managed fields compared to conventional, and a 27% likely reduction in use of pesticide products with high acute human toxicity for organic versus conventional fields. Readers may be gasping, and thinking, “Wait, what?! I thought organic farming does not use pesticides! Help?”

There is a world of difference between the pesticides used in organic and in conventional production. Though conventional growers are allowed to use thousands of synthetic compounds on their crops, seeds, and soils — no matter their toxicity, as long as EPA has permitted them — Certified Organic growers are permitted to use only “natural” or naturally derived pesticide products, and a very limited number, at that. Organic growers may use any of the products listed in “The National List of Allowed and Prohibited Substances,” as established by the NOP’s (National Organic Program’s) National Organic Standards Board. In this case, natural materials subject to “chemical change” may be used if they do not cause adverse effects, are organic-compatible, and deemed essential. Growers may not use the prohibited substances on that list (except as outlined below).

Organic producers are not left “defenseless” against pests, but operate within stringent limits on what is allowed — a virtual handful of compounds, as compared with the 17,000 pesticide products on the market and available to conventional growers. The allowed compounds for organic production, overall, are far less toxic for human and environmental health than many of the conventionally deployed pesticides. And, although the National Organic Standards (NOS) default to a prohibition of synthetic pesticides, the National List process permits very few synthetic materials in certain categories of agricultural production. All natural substances are allowed, unless prohibited. The synthetic substances are limited to those “used in production and contains an active synthetic ingredient in the following categories: copper and sulfur compounds; toxins derived from bacteria; pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and minerals; livestock parasiticides and medicines and production  aids including netting, tree wraps and seals, insect traps, sticky barriers, row covers, and equipment cleansers; [. . .] [Section 2118, Organic Foods Production Act (OFPA) (c))(1)(B(i) [U.S.C. 6517] National List.]

The researchers assert in their paper, published in Nature Communications, that “Notwithstanding popular perception, the environmental impacts of organic agriculture, particularly with respect to pesticide use, are not well established. Fueling the impasse is the general lack of data on comparable organic and conventional agricultural fields. . . . Organic agriculture is commonly perceived to be chemical-free, though organic as a regulatory definition, at least in the U.S., generally restricts the type of inputs applied rather than the amount. The regulation does not itself require chemical-free farming [per Section 2118 of OFPA (cited above)], and organic compliance does not always imply low toxicity to ecological or environmental endpoints. For example, organic-acceptable active ingredients such as copper, pyrethrin, and azadirachtin are toxic to aquatic organisms. Furthermore, since pesticide residue testing often focuses on synthetic chemicals of high human toxicity and field-level data on production or certification are rarely available, little is known about pesticide use practices on organic fields.”

The researchers sought to understand more granularly the environmental pros and cons of organic vs. conventional production systems. There are myriad lenses through which to evaluate such environmental pros and cons; this team focused on “how being organic relative to conventional affects decisions to spray pesticides and, if spraying, how much to spray.” They write, “Pesticide use, though only one component of environmental or health aspects of organic production, is of paramount importance to consumers due to potential environmental and human health impacts such as water quality contamination and consumer and farm-worker wellbeing.”

The paper acknowledges the toxic history of synthetic pesticide use and its impacts on human and environmental health, noting, “Historically, widespread use of persistent, broad-spectrum, and bioaccumulating chemicals such as organochlorines and organophosphates had severe negative impacts on humans, other mammals, and birds. . . . As those risks were increasingly recognized, a new generation of chemicals was developed with a particular focus on reducing human-health risks. While the development and uptake of these pesticides have limited direct mammal and bird mortality . . . many remain highly toxic to other organisms. Further, population-level ecological effects through food web interactions or sub-lethal impacts (e.g., behavioral changes and reduced migratory navigation) remain a concern for higher taxa.” Beyond Pesticides recommends that readers review its coverage of the Impacts of Pesticides on Wildlife — many of which, though not acutely lethal, are nevertheless extremely damaging.

The team began with this question: does the “reduction in negative ecological and environmental impacts on-field compensate for the reduction in yields and increased yield variability that ha[ve] been observed for most organically produced crops in actual field surveys?” They also write, “Understanding the difference between organic and conventional fields in real-world settings is crucial for understanding the merits of organic production practices at scale.” (Beyond Pesticides refers readers to information about the performance of organic production methods here, here, and here.)

Globally, agricultural activity uses approximately 40% of arable land; a mere 1.5% of that land is farmed organically, though both the acreage devoted to, and the sales of, organic food are rising dramatically. Since 2000, for example, organically managed agricultural land has grown from 15 million to 73 million hectares (37+ million acres to 180+ million acres).

This study reviewed data from 2013 to 2019 for nearly 100,000 agricultural fields in Kern County — a very large sample — 9,100 of which were organically managed fields. (The number of fields and acreage of each varied year-to-year, so these metrics represent averages across the time period.) The organic fields in the study were roughly 44% smaller than conventional fields. The chief crops grown on the organic fields included carrot, potato, lettuce leaf, and tomato; almond, pistachio, grape, and alfalfa were primary on conventional fields. Seven to 11% (over the course of the seven years of data) of the production in the county came from Certified Organic fields.

Of their methods, the team writes, “We harmonize and aggregate several data sources to identify the spatial location of organic crop fields and rely on unique, field-level crop and pesticide use data . . . to understand pesticide use differences. . . . Due to the number of different products and chemicals applied in our study area, we rely on pesticide use and coarse metrics of ecotoxicity based on the pesticide product label. . . . We evaluate (1) overall differences between organic and conventional fields with respect to the decisions to spray and how much to spray for total pesticide use and pesticides of potential hazard to a range of different endpoints, (2) crop-specific differences in pesticide use decisions between organic and conventional fields for five crops commonly grown with both organic and conventional practices, and (3) how adjusting for yield gaps may influence the overall results.”

On average, researchers conclude, organic fields in the County are more likely (than conventional fields) to be pesticide-free — with the relative absence of spraying (18–31% reduced likelihood) implying a reduction of ecotoxicological impacts. They also noted the 27% lower likelihood of use, in organic fields, of compounds with high acute human toxicity. (High toxicity is defined as EPA acute toxicity category one or two in the U.S. Environmental Protection Agency’s [EPA’s] rubric.) The study also asserts that spraying of organic fields uses similar amounts of pesticides as that done by conventional farms in the study; however, what is being sprayed is quite different.

For crops that are commonly grown in the county both organically and conventionally, the study notes a consistent reduction in the probability of using any pesticides. The study homed in on pesticide outcomes for two crops — carrots and grapes. It found that a switch to organic production protocols reduced the probability of using a given class of pesticide by 27–51% for carrots, and 21–23% for grapes. A switch to organic for carrots reduced the use of most types of pesticides by 80% (± 9%) to 98% (± 1%), and increased use of low-toxicity chemicals by 72% (± 12%). Switching to organics for grapes, however, increased (NOS allowed) pesticide use by 126% (± 34%) to 286% (± 98%). It should be noted that grapes are notoriously vulnerable to a variety of fungal infestations, in particular.

The research concludes: “Our analysis provides four main innovations: (1) for the first time, we have isolated the spatial location of thousands of organic fields using production and pesticide use data; (2) organic fields are generally smaller in size, part of larger farms, and on better soil than their conventional counterparts; (3) organic agriculture, on average, uses less pesticides than conventional production and this manifests in a lower probability of using any pesticides, and similar use on fields that do spray; and (4) different crop types vary considerably from the average, and in some cases, the reverse relationship is present and significant [such as that noted for grape production].”

The study does underscore the complexity of analyzing what is actually happening on organically farmed fields (at least in this one county in California, but very likely in many locations). Organic agriculture is not magically “free” of all chemicals — as the study notes, for example, about copper, pyrethrin, and azadirachtin [the active ingredient in neem oil], above. (Indeed, all living organisms and non-living materials are chemically based!)

But organic regenerative practices do nearly eliminate the use of highly toxic, synthetic chemical compounds, as well as their myriad downstream impacts on ecosystems, non-target organisms, and the health and safety of waterways and water bodies. Further, organic agriculture provides multiple ecosystem functions and services at greater economic benefit to farmers than conventional, chemical-intensive cropping systems, as a recent study demonstrated. And food produced organically is healthier for humans. Note the relationships of pesticide exposures to health compromise at this web page on pesticide induced diseases.

The reality of the use of NOS-approved pesticides in organic agriculture may have been a small shock to some readers, but it is worth emphasizing, once again, that both the nature and the number of allowed compounds in Certified Organic agriculture are far more benign, and fewer (by orders of magnitude), respectively, than those registered by EPA and used on conventionally grown crops. The prevalence and toxicity of synthetic pesticides is — and has been — so extreme that recent research has found that their legacy is showing up as toxic pesticide residues on some organic farms, emphasizing the threat of a history of weak regulatory standards, and the urgent need to transition to organic.

Beyond Pesticides is also vigilant about the details and strength of the National Organic Standards — see the webpage, Save Our Organic — because those details matter. The NOS are a powerful tool to shape the future of agriculture and of the environment broadly, as this August 2021 Daily News Blog article underscores. Regular readers will know how frequently and adamantly Beyond Pesticides drives home the point that a transition to organic regenerative agriculture (and land management broadly) is imperative and urgent.

At nearly every meeting of the NOS Board, there are proposals for substances to be added to The National List of Allowed and Prohibited Substances. Beyond Pesticides regularly reviews these, writes about them in its Daily News Blog, weighs in with NOSB, and encourages the public to do the same. In Spring 2021, for example, the NOSB dealt with a petition to permit use of antibiotics in organic pear and apple production, and Beyond Pesticides advocated to keep antibiotics out of organic. The Fall 2021 NOSB meeting is scheduled for October 13–21; keep an eye out for Beyond Pesticides discussions of items on that agenda that may need public advocacy.

Source: https://www.nature.com/articles/s41467-021-25502-w#MOESM1

Nature Communications is an open access journal that publishes high-quality research from all areas of the natural sciences. Papers published by the journal represent important advances of significance to specialists within each field.

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

(Beyond Pesticides, September 23, 2021) A study by Claremont Graduate University finds exposure to agricultural pesticides increases brain cancer risk up to 20 percent. This study expands on a 1998 study evaluating brain cancer risk among the farm population using epidemiologic studies.

The etiology (cause) of brain cancer is inconclusive for many forms, including glioma and meningioma. Brain cancer risk factors include family history and exposure to radiation. However, geographical variance in brain cancer incidents suggests environmental pollutants like pesticides contribute to risk. Various research studies already note the adverse effects pesticide exposure has on the brain. These effects range from headaches and tumors to learning and developmental disabilities among children and adults. Although general cancer incidents are decreasing, brain and nervous system cancers are rising. Therefore, studies like this highlight the need to reevaluate pesticide exposure limits for those working with or around agricultural chemicals to prevent chronic, deadly diseases. The study researchers note, “This comprehensive review and meta-analysis encompassing 42 years of the epidemiologic literature and updating two previous meta-analyses by 20 years supports an association between farming and brain cancer incidence and mortality.[…]Our analyses suggest that the elevated risk has been consistent over time, and the addition of newer studies (i.e., those published since 2000) does not change this conclusion.”

Researchers conducted a literature review using PubMed and Agricola databases to assess studies evaluating the relationship between farming and brain cancer. The researchers reviewed meta-analysis studies to harmonize findings published between January 1997 and August 2019. In total, researchers evaluated 52 different studies.

The study results demonstrate that 77 percent of studies have a positive association between brain cancer and farming, with an elevated risk factor between 1.03 to 6.53 times. Therefore, the meta-risk analysis finds the brain cancer mortality/morbidity rate to be 13 percent. According to demographic information, white farmers have the highest rate of brain cancer. However, those managing livestock, where insecticides are widely used, have higher rates of brain cancer incidents than those managing crops. Overall, farmers experiencing pesticide exposure have a greater than 20 percent increased risk of brain cancer. Although there are discrepancies among studies, evidence from the previous 40 years, including the 20 years evaluated in this study, supports associations between brain cancer and chemical pesticide exposure from farming.

The nervous system is an integral part of the human body and includes the brain, spinal cord, a vast network of nerves and neurons. These components are responsible for many of our bodily functions—from the senses to movement. However, exposure to chemical toxicants, like pesticides, may cause neurotoxic effects or exacerbate preexisting chemical damage to the nervous system. The impacts of pesticides on the nervous system, including the brain, are hazardous, especially for chronically exposed individuals (e.g., farmers and farmworkers) or during critical windows of vulnerability and development (e.g., childhood, pregnancy). Mounting evidence over the past years shows that chronic exposure to sublethal (low) levels of pesticides adversely affects the central nervous system (CNS). Specifically, researchers identify agricultural chemical exposure as a cause of many adverse CNS impacts. In addition to CNS effects, pesticide exposure can impact a plethora of neurological diseases. For instance, farmworkers and their children experience higher rates of neurological diseases from exposure to carcinogenic (cancer-causing) and neurotoxic compounds readily used in conventional, chemical-intensive agriculture. These diseases include amyotrophic lateral sclerosis (ALS) and Parkinson’s disease, dementia-like diseases such as Alzheimer’s, and other effects on cognitive function. Therefore, advocates say it is essential to avoid toxic chemical exposure to lessen potential acute and chronic health risks.

Pesticide use is widespread and direct exposure from applications or indirect exposure from residues pose a threat to human health. Children are more vulnerable to the impact of pesticides as their bodies are still developing. Furthermore, a mother’s exposure to environmental toxicants while pregnant may increase the likelihood of developing brain malformations as most developmental disabilities begin before birth. A plethora of studies not only link childhood pesticide exposure, but prenatal pesticide exposure, as well, to brain tumor development. The number of children with neurodevelopmental disabilities is increasing in the U.S., and many children in rural areas—where pesticide use is most prevalent—have a higher rate of neurological disabilities. Children living on or in proximity to farms are more likely to encounter these toxic chemicals from performing farm-related activities (i.e., storing/handling pesticides, fieldwork) or leisure activities around farms (i.e., swimming in nearby contaminated water, eating crops from the field). Pesticides can have various impacts on cognitive function that are not easily classifiable with exposure-response. Headaches are the most common symptom of pesticide applications, but exposure can have confounding impacts on human health as headaches often accompany other pesticide poising symptoms. Therefore, it is essential to effectively monitor and assess pesticide exposure for the sake of human health.

The study results find an increased risk for brain cancer among those working with livestock. Many pesticides used on livestock are insecticides that specifically impact the nervous system of invertebrates. However, many studies demonstrate that exposure to pesticides, such as organophosphate insecticides, like chlorpyrifos, have endocrine disruption properties that induce neurotoxicity via acetylcholinesterase (AChE) inhibition. A 2015 Harvard University meta-analysis found that indoor use of insecticides was associated with a 47 percent increase in childhood leukemia and a 43 percent increase in childhood lymphoma. However, various herbicides, including paraquat, have links to neurotoxic impacts like Parkinson’s disease and loss of senses (i.e., hearing, smell, sight). Furthermore, a 2008 study found that women who reported using herbicides have a more than doubled risk for meningioma brain cancer compared with women who never use herbicides. The brain cancer risk increases significantly with increasing years of cumulative herbicide exposure. A majority of exposure comes from handling herbicide-contaminated produce in grocery stores/restaurants, rather than direct pesticide application.

This study adds to the growing body of research supporting a link between neurological problems and individuals with frequent exposure to pesticides. 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, especially gliomas – a tumor of the nervous system. Furthermore, this study confirms previous studies  that find farmworkers experience higher rates of specific cancers, like brain cancer. Farmworkers are at the greatest risk of pesticide-induced disease 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. The researchers conclude “…that the synthesis of evidence from over 40 years of epidemiologic literature supports an increased risk of brain cancer from farming with its potential for exposure to chemical pesticides. Increasing organic farming practices is one means to reduce the exposure of farmers to chemical pesticides.”

Globally, cancer is one of the leading causes of death, 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 to increase from 19.3 million to 30.2 million per year by 2040. 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). Therefore, studies related to pesticides and cancer will aid in future understand of the underlying mechanisms that cause the disease.

It is essential to understand the health implications of pesticide use and exposure on humans, especially if pesticides increase chronic disease risk. 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 brain cancer), brain and nervous system disorders, endocrine disruption, and other diseases. 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: Claremont Graduate University 

(Beyond Pesticides, September 22, 2021) Health and environmental organizations are urging the U.S. Environmental Protection Agency (EPA) and state pesticide regulators to immediately stop the use and sale of dangerous and misbranded Eco-MIGHT and W.O.W. (Whack Out Weeds!) products, falsely labeled as 25(b) minimum risk. Recent laboratory testing by the state of California found the presence of hazardous pesticides, including glyphosate, bifenthrin, permethrin, cypermethrin, and carbaryl in these products. “From organic farmers to municipal landscapers and home gardeners, consumers employing minimum risk products are working intentionally to avoid the dangers associated with toxic pesticide exposure,” said Jay Feldman, executive director of Beyond Pesticides. “It is critical that EPA and state regulators coordinate to ensure the integrity of the minimum risk program.”

Coordination is critical yet reports indicate that EPA is falling down on the job. The issue first 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 adultered Eco-MIGHT and W.O.W products. The products make a range of claims, marketed as “organic,” “natural,” “glyphosate-free,” and “non-toxic and safe.” As CDFA Secretary Karen Ross noted, “It is imperative that we alert California organic growers that these EcoMIGHT products contain substances that are prohibited in organic production, in order to preserve the integrity of the California organic label and to protect our growers,” said CDFA Secretary Karen Ross.

At the same time as CFDA’s Stop Use Notice, the California Department of Pesticide Regulation (the state’s primary enforcement agent for pesticides) sent a warning letter to EcoMIGHT LLC, the parent company that 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 the Federal Insecticide Fungicide and Rodenticide Act (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.  

While those actions do show a degree of coordination to protect California growers and consumers, these warnings are not reaching other state regulatory agencies. Emails forwarded to Beyond Pesticides from Connecticut advocate Mary Wilson of the group Protect Our Pollinators, sent in mid-September, questioned state regulators on the status of the product, which had been registered under state law as of July 19, according to a company press release.  In that press release, EcoMIGHT LLC indicates that registration of its product helps the state’s Governor, Ned Lamont, “fulfill his campaign promise” to eliminate toxic pesticides. Ms. Wilson and her organization were told that the state’s Department of Energy and Environmental Protection (DEEP) was not aware of California’s concerns over adulteration until they had sent the email. DEEP indicated that it is looking into the advertising statements mentioning the Governor, and that EPA Region 1 is now coordinating with EPA Region 9 regarding the issue and will provide guidance to the state if the adulteration is confirmed.

However, the lack of swift action has advocates concerned that DEEP is being saddled with the consequences of EPA’s poor track record for oversight and enforcement. “We in Connecticut are not satisfied when mislabeled and potentially dangerous products are sold in our state,” Ms. Wilson said.

“When one state issues a stop use order on a misbranded product, the problem is not siloed in that state,” said Mr. Feldman of Beyond Pesticides. “It is not enough to simply send a letter to the manufacturer. EPA must establish a process to alert all state pesticide regulatory agencies of enforcement actions that could affect the status of organic farmer certifications, consumer health, and environmental protection in their state.”

In addition to coordination, advocates urge increased EPA accountability over minimum risk products, to ensure that these products live up to their namesake. Minimum risk products are limited to a specific list of ingredients, and all ingredients, including inert ingredients, are required to be listed on the label.  

While this finding does damage the minimum risk designation, it speaks to a broader problem of EPA failing to provide oversight to manufacturers over pesticide contamination and adulteration. Late last year, independent testing by Public Employees for Environmental Responsibility (PEER) found that mosquito pesticides were being tainted with highly hazardous PFAS (per and polyfluorinated alykyl substances) ‘forever chemicals.’ Although the state of Massachusetts stopped using the initially tested product, Anvil 10+10, PEER determined that localities in at least 25 states have used Anvil 10+10 as part of their mosquito spray program. While EPA continues to look into the problem, further testing has shown the issue to be much more widespread. In Maryland, testing from PEER and Maryland Pesticide Education Network found significant levels of PFAS in Permanone 30-30, a mosquito adulticide regularly used by the Maryland Department of Agriculture in their mosquito control program.

The recent history of contamination in both minimum risk and registered pesticides bodes very poorly for a pesticide office already on its heels from in-depth reporting about its corruption. To restore public trust, the agency must step up enforcement and coordination, and ensure, when problems spring up in one location, swift action is taken to protect farmers and consumers throughout the United States.

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

Source: California Department of Food and Agriculture, California Department of Pesticide Regulation, EPA, Personal communication with the author and Mary Wilson of Protect Our Pollinators

(Beyond Pesticides, September 21, 2021) Processed organic foods are healthier than their conventional, chemical-intensive counterparts in important ways, according to a new peer-reviewed study published in the journal Nutrients led by scientists at the Environmental Working Group. While a steady diet of whole, unprocessed foods is ideal, packaged foods are ubiquitous in U.S. supermarkets and often unavoidable. In addition to eliminating concerns over highly toxic pesticide use, according to this new research, choosing packaged organic is an effective means of evading highly processed ingredients associated with adverse health outcomes.

Researchers began with a food product dataset including over 72,000 conventional and 8,000 organic packaged foods, representing 85% of all food products sold to U.S. consumers. These products and their ingredients were then classified into four groups corresponding with the amount of processing, with one being unprocessed or minimally processed and four being ultra-processed. A statistical analysis was then conducted on a range of product variables to differentiate various health concerns between organic and conventional products.  

Results show that organic packaged foods present far fewer health concerns than conventional products. Processed organic products were likely to have lower amounts of salt, saturated fat, sugar and added sugar. According to the analysis conducted by researchers, for every ultra-processed ingredient in a product, the likelihood of that product being organic declined by 32%. The same held for a range of concerning factors – the odds of a product being organic likewise decreased as sugar, salt, and trans-fats were added to conventional foods. On the other hand, organic products are associated with higher amounts of potassium in processed foods.  

“Here, with the finding that the odds of being labeled organic decreased as ultra-processed ingredient number or cosmetic additive number increased, we show that organic product certification can be a proxy for less ultra-processed and thus more healthful products,” the study reads. These conclusions appear to line up with research published in November 2020, finding that eating organic food lowers risk of developing type two diabetes. While there is ample evidence to relate this finding to the use of toxic, endocrine-disrupting pesticides in conventional agriculture, the present study shows that the ingredient label is also playing an important role.

Across a range of previous studies, it was found that organic options are healthier than chemical-intensive foods. A 2010 study found that organically growth strawberries had a longer shelf life, higher antioxidant activity and larger concentrations of Vitamin C and other phenolic compounds. Research published in 2016 found organic dairy and meet to be higher in essential nutrients like omega-3 fatty acids than conventional chemically grown products, and a 2018 study found similar results in organic cows, particularly those grass-fed. In 2019, an Australian research team found that organic even makes a difference when it comes to the microbiome, with organic apples containing much more diverse bacterial communities that are ultimately healthier for one’s gut.

With level of processing, ingredient profiles, nutrient and antioxidant content, and microbial diversity all providing evidence of health benefits over conventionally produced and processed foods, it is little wonder that recent research published in July of this year found students who eat organic score higher on cognitive tests.

While processed organic does have a better health profile than chemical-intensive foods, it is critical that it remains so. Agrichemical companies that have long specialized in ultra-processed conventional foods want to produce organic counterparts, and regularly pressure the National Organic Standards Board (NOSB) to allow new risky additives. As it currently stands, there are less than 40 synthetic materials allowed in certified organic processing under the National List of Allowed and Prohibited Substance. It is critically important that, in order to preserve the health benefits of organic products, this list not be expanded, but shrunk.

Beyond Pesticides works to keep consumers apprised of the latest in organic production and processing through the Keeping Organic Strong program page. Only through continued engagement by consumers in the standard setting process can we ensure that organic integrity will be maintained. For instance, despite the controversial food additive carrageenan being voted off the National List by the NOSB in 2016, the National Organic Program has failed to remove it. While most processors have eliminated its use, we are using consumers to tell the NOSB to insist the material be removed from the list once and for all.

Join Beyond Pesticides in calling on the NOSB to make decisions that uphold the integrity of the organic label by reviewing the Fall 2021 issues page, and making a comment to the NOSB by September 30, 2021.

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

Source: Environmental Working Group, Nutrients

(Beyond Pesticides, September 20, 2021) Scientists warn that humanity is causing the sixth mass extinction in the planet’s history. A series of reports from the United Nations Environment Program (UNEP) highlights how human activities threaten the healthy functioning of ecosystems that produce food and water, as well as one million species now at risk of extinction. The UNEP report, Food System Impacts on Biodiversity Loss, identifies the global food system as the primary driver of biodiversity loss. The report points to the conversion of natural ecosystems to crop production and pasture, with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases.

 In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow use of chemicals that it recognizes will contribute to the problems.

The United Nations Convention on Biological Diversity (CBD) is the international legal instrument for “the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources.” It has been ratified by 196 nations—all the members of the United Nations except the United States and the Vatican. The CBD includes 21 action targets to be achieved by 2030, including reducing pesticide use by two-thirds, eliminating plastic waste, and “fully integrating biodiversity values into policies, regulations, planning, development processes, poverty reduction strategies, accounts, and assessments of environmental impacts at all levels of government and across all sectors of the economy, ensuring that all activities and financial flows are aligned with biodiversity values.”

Tell Congress to ratify the Convention on Biological Diversity. Tell EPA to incorporate CBD targets into its programs.

Letter to Congressional Representative and Senators

Scientists warn that humanity is causing the sixth mass extinction in the planet’s history. A series of reports from the United Nations Environment Program (UNEP) highlights how human activities threaten the healthy functioning of ecosystems that produce food and water, as well as one million species now at risk of extinction. The UNEP report Food System Impacts on Biodiversity Loss identifies the global food system as the primary driver of biodiversity loss. The report points to the conversion of natural ecosystems to crop production and pasture, with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases.

In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow use of chemicals that it recognizes will contribute to the problems.

The United Nations Convention on Biological Diversity (CBD) is the international legal instrument for “the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources.” It has been ratified by 196 nations—all the members of the United Nations except the United States and the Vatican. The CBD includes 21 action targets to be achieved by 2030, including reducing pesticide use by two-thirds, eliminating plastic waste, and “fully integrating biodiversity values into policies, regulations, planning, development processes, poverty reduction strategies, accounts, and assessments of environmental impacts at all levels of government and across all sectors of the economy, ensuring that all activities and financial flows are aligned with biodiversity values.”

Please ensure that the United States becomes a party to the CBD.

Thank you.

Letter to EPA Administrator Regan

Scientists warn that humanity is causing the sixth mass extinction in the planet’s history. A series of reports from the United Nations Environment Program highlights how human activities threaten the healthy functioning of ecosystems that produce food and water, as well as one million species now at risk of extinction. The UNEP report Food System Impacts on Biodiversity Loss identifies the global food system as the primary driver of biodiversity loss. The report points to the conversion of natural ecosystems to crop production and pasture, with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases.

In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow use of chemicals that it recognizes will contribute to the problems. 

The United Nations Convention on Biological Diversity (CBD) is the international legal instrument for “the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources.” It has been ratified by 196 nations—all the members of the United Nations except the United States and the Vatican. The CBD includes 21 action targets to be achieved by 2030, including reducing pesticide use by two-thirds, eliminating plastic waste, and “fully integrating biodiversity values into policies, regulations, planning, development processes, poverty reduction strategies, accounts, and assessments of environmental impacts at all levels of government and across all sectors of the economy, ensuring that all activities and financial flows are aligned with biodiversity values.”

Until Congress acts to make the United States a party to the CBD, EPA should, as an agency, take actions that are consistent with the action targets of the CBD. In particular, registrations of all pesticides that threaten pollinators, threatened and endangered species, or the functioning of ecosystems should be cancelled as soon as possible.

Thank you.

(Beyond Pesticides, September 17, 2021) Against the backdrop of what The New York Times in 2018 called the “insect apocalypse,” and the dire plight of pollinators in particular, Friends of the Earth (FOE) recently issued its retailer scorecard, which benchmarks “25 of the largest U.S. grocery stores on pesticides, organic offerings and pollinator health”— with the vast majority of retailers failing to protect pollinators. FOE reporting shows some, but far too slow and anemic, progress by corporate actors in enacting pollinator- and bee-friendly policies across both retail sites and supply chains. Such policies, to be genuinely effective and protective of pollinators (and human health), would eliminate or at least dramatically reduce the presence of pesticides in the food supply. The path out of the chemical pesticide quagmire is organic: companies must do more to move suppliers to organic, regenerative production practices, and EPA should be pulling these toxic compounds from the market.

Tracking the pollinator policies and enforcement activities of various huge companies yields a useful barometer in monitoring the travel of pesticides to the consumer. Yet the results in the FOE scorecard — e.g., only two of those 25 retailers scored even in the “B” range, and 21 scored “D” or “F” — do underline powerfully the folly of the U.S. Environmental Protection Agency’s (EPA’s) allowance of these compounds, whose uses damage the very organisms (and ecosystems) on which one-third of the domestic food supply depends.

FOE evaluated these 25 retailers, including entities that are not grocers, per se, but do sell food, such as 7-Eleven, CVS, Dollar General, Dollar Tree, Rite Aid, and Walgreens. These categories of “pollinator protection performance” were considered and assigned points: presence of a pollinator health policy for groceries (maximum of 45 points); implementation of the policy in supply chains (max 90); transparency and accountability (max 21); collaboration (max 10); and complementary home and garden policies for live goods, such as plants, and pesticide products for outdoor use (max 9). The highest possible number of total points was 175.

A few highlights of the rubric include: for the pollinator health policy category, a commitment to reducing pesticide use, avoiding “regrettable” substitutes, and expanding USDA (U.S. Department of Agriculture) Certified Organic offerings; and for implementation, evidence of phasing out or reducing pesticides in products sold, and bonus points for using domestic organic producers. (See details of the FOE rubric here.)

The overall scores generated by FOE’s analysis are grim; apart from the overall scores and grades of Giant Eagle (score 102, grade B), Whole Foods Market (score 88, grade B-), Walmart (score 82, grade C+), and Costco (score 70, grade C), all the other retailers came in below the 48-point mark, yielding grades of D+ and below. Eleven received “Fs” and three scored zero total points (7-Eleven, Meijer, and Wakefern Food). Those 11 received zeros in multiple of the evaluated categories. Many well-known companies also scored extremely poorly (below 20 points overall): Wegman’s (overall score of 17), Amazon.com (15), Walgreen’s (15), BJ’s Wholesale Club (14), H-E-B (14), Southeastern Grocers (5), Dollar General (5), and Hy-Vee (5).

These ratings can leave a pretty bitter taste in a consumer’s mouth, particularly if one’s local grocery has rated poorly. As FOE points out, it can be tricky to know which of these entities may own a local grocery store; some of those evaluated, such as Target, Costco, Aldi, Wegman’s, and CVS, hold only their single, branded retail facilities. But many others have multiple subsidiary holdings; indeed, Kroger has 22 subsidiary grocery retail outlets, and Albertson’s holds 12. Helpfully, FOE has provided a guide to the subsidiary holdings of these 25 companies. It also provides perspective on the size of these entities in what is an increasingly consolidated food system landscape.

FOE hopes that its scorecard will help “spur a race to the top” — essentially, publicly pressure retailers to create pollinator-protective policies for their operations. Since 2018, the FOE reports notes, 10 retailers have created such policies, but only Giant Eagle and Walmart have committed to time frames. Giant Eagle (which operates primarily in Pennsylvania, with some locations in Maryland) will eliminate nitroguanidine neonicotinoid pesticides from its produce supply chain by 2025. (Nitroguanidines include imidacloprid, clothianidin, thiamethoxam, dinotefuran, and acetamiprid — all of which are highly toxic to bees.)

Both retailers will require that their produce suppliers adopt IPM (Integrated Pest Management) protocols that will be verified by independent certifiers, by 2025. Beyond Pesticides is not a fan of IPM in agriculture because there is no standardized and enforceable definition or particular federal authorization that oversees the IPM moniker and practices, and as the multitude of definitions show, nearly any chemical might be used in an IPM protocol. (See the USDA and EPA web pages on IPM.) In the context of controls in buildings, Beyond Pesticides supports only well-defined IPM, which outlines allowed practices and substances.

Other companies — Albertsons, Aldi, Costco, Dollar Tree, Kroger, Meijer, Rite Aid, and Target — have established policies “encouraging” suppliers to reduce their use of “pesticides of concern” (such as these, according to FOE, but it is unclear how the companies define the term), and to move to less-toxic production practices. However, these policies include neither metrics nor implementation targets.

In its review, FOE considered whether the companies were doing anything to increase their organic offerings, and whether they are active in encouraging and/or incentivizing conventional producers to transition to less-toxic approaches, such as organic, regenerative farming (or IPM). Last, FOE assessed whether the companies are educating consumers about pesticide-and-pollinator issues, and advocating for public policies “that shift government support from pesticide-intensive agriculture to organic and ecological farming systems.”

FOE says, “The majority of the company policies state a commitment to expand organic offerings, which are grown without the use of over 900 pesticides otherwise allowed in agriculture.” FOE calls these “important first steps,” but adds that “the extinction crisis demands that all food retailers make time-bound commitments to phase out toxic pesticides and support a transition to organic and regenerative agriculture, which is better for pollinators, people and the planet.”

The key findings of the FOE report are:
• There is growing momentum around addressing pesticide use in the U.S. food retail sector, but stronger leadership is needed to protect pollinators.

• The majority of American consumers believe grocery stores should help protect pollinators.
• Walmart and Giant Eagle have the leading pollinator health policies.
• Walmart, Meijer, Dollar Tree and Target established new pollinator health policies this year, making 10 major grocery retailers taking steps to address toxic pesticides in their food supply chains.
• Major grocery retailers are failing to set measurable goals to reduce toxic pesticide use in their food supply chains.
• Major grocery retailers don’t know which pesticides are being used in their supply chains or how much is being used. 
• Major grocery retailers must step up to support conventional growers to shift to the least-toxic approaches.
• Companies must disclose organic sales data and include organic sales in formal sustainability goals.
• Companies must report organic and “natural” sales separately.
• Whole Foods and Trader Joe’s are leading major grocery retailers on organic as a percent of overall grocery sales.
• Independent grocery stores far surpass the largest U.S. food retailers on organic as a percent of overall sales. 
• Companies must support the expansion of organic agriculture in the U.S.
• Dollar Tree committed to eliminate use of nitroguanidine neonicotinoids and glyphosate in flowers by 2024, and Giant Eagle removed all neonicotinoid and glyphosate products from store shelves, making 11 companies with pesticide commitments in their home and garden supply chains.
• It is time for grocery retailers to implement policies that reflect the interrelated biodiversity and climate crises.

Pressure from advocacy organizations, such as FOE, Beyond Pesticides, the Center for Biological Diversity, and The Xerces Society, and from the public, has moved the needle for some retailers on the presence of pesticides in their products and supply chains. FOE has attended to grocery purveyors (of all sorts), and did look at the “home garden” or live plant sales activity at those companies reviewed in this report. Beyond Pesticides teamed up with FOE in June 2021 to analyze herbicide products at Lowe’s and Home Depot, and to advocate for their removal and replacement with nontoxic alternatives.

As Beyond Pesticides reported, “Friends of the Earth composed a comprehensive list of products sold by Home Depot and Lowe’s by browsing online and local stores. . . . Beyond Pesticides evaluated active ingredients in all products and performed a toxicity analysis using available epidemiological and laboratory and studies.” That analysis found that 24 of 51 herbicide products on Home Depot’s shelves and 23 of 40 herbicide products at Lowe’s contain ingredients considered Highly Hazardous Pesticides, classified by the U.N. Food and Agriculture Organization as “pesticides linked with a high incidence of severe or irreversible adverse effects on human health or the environment.” 

As FOE noted in its report, Walmart committed in Spring of 2021 to “new pollinator commitments that will further our efforts to help reverse nature loss and ultimately bring us closer to meeting new nature commitments made by Walmart and the Walmart Foundation. We have invited our suppliers, stakeholders and customers to join us on this journey as we continue to take action to help protect our planet.

These new commitments serve as the largest pollinator health effort from a U.S. grocery retailer to-date, aiming to reduce several pollinator threats through promoting integrated pest management (IPM) practices and improving and expanding pollinator habitats.”

In Massachusetts, “encouragement” has come from the state level: in March 2021, the Massachusetts Pesticide Board Subcommittee approved new regulations to restrict the use of neonicotinoid pesticides (“neonics”). After years of advocate work to pass a more-comprehensive bill in the state legislature — An Act to protect Massachusetts pollinators, sponsored by Representative Carolyn Dykema — the legislature in 2020 again failed to approve it. Advocacy focus then shifted to the pesticide board, which endorsed this more limited regulation; it will go into effect in 2022 and will restrict outdoor consumer use of neonics by removal of neonicotinoid pesticide products from retail stores. Only licensed pesticide applicators will be allowed to use such products for care of lawns, turf, trees, shrubs, and gardens.

Human dependence on pollinators for food production is significant. As FOE writes, “Without pollinators, grocery stores would run short of a wide assortment of fruits and vegetables, nuts, beans and delicious treats like chocolate and coffee. And because bees pollinate alfalfa and other crops eaten by cows, even the dairy and meat shelves would look bare.” Learn more about the economic risks of pollinator declines.

Given that dependence on pollinators — never mind their intrinsic value and their roles in biodiverse ecosystems — the continued, widespread use of synthetic pesticides that are lethal or otherwise damaging to pollinators is foolhardy, at best. Add to the pollinator impacts the other human health, ecosystem, biodiversity, and water quality impacts of pesticides, and the conclusion cannot help but be that continued use of these compounds in agriculture is risky in the extreme.

The rapid transition of agricultural (and land management) practices to organic, regenerative approaches is the definitive solution to the pollinator crisis (and multiple other health and environmental crises). Protecting pollinators by hastening that shift ought to be the job of everyone — government, private enterprise, agricultural and turf management operations, and the public. Members of the public can advocate via nonprofit organizations; local, state, and federal elected officials; and state and federal agencies that have authority over pesticide use, such as state departments of agriculture, and federally, EPA, USDA, and BLM (the Bureau of Land Management). As for more-immediate and local actions: people can create organic habitat on their own property and in community spaces, such as parks, community gardens, and grounds of municipal and school buildings. For more such ideas and resources, see this Beyond Pesticides Daily News Blog entry from June 2021, and the many resources at the BEE Protective web pages.

Source: https://foe.org/retailer-report-card/

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

(Beyond Pesticides, September 16, 2021) A study published in Chemosphere finds persistent organic pollutants (POPs), including organochlorine pesticides (OCPs), polychlorinated biphenyls (PCBs), and polybrominated diphenyl ethers (PBDEs), are present in the serum and placenta of pregnant mothers, as well as multiple fetal organs. Many studies indicate prenatal and early-life exposure to environmental toxicants increases susceptibility to diseases, from learning and developmental disabilities to cancer. However, this study is one of the first to demonstrate the presence of chemical toxicants in fetal tissue that are not present in maternal serum or placental samples. Prenatal development is one of the most vulnerable periods of exposure when the fetus is most susceptible to the harmful effects of chemical contaminants. Therefore, studies like these help government and health officials better identify fetal exposure contaminants and subsequent health concerns otherwise missed by current chemical monitoring methods. The researchers note, “These findings call for further evaluation of the current matrices used to estimate fetal exposure and establish a possible correction factor for a more accurate assessment of exposure in utero. We disclose the full data set on individual exposure concentrations to assist in building in silico models for prediction of human fetal exposure to chemicals.”

Several studies associate early-life exposure to toxic chemicals with adverse birth/health effects. However, fetal exposure measurements typically use maternal and placenta chemical concentrations rather than actual fetal exposure. Researchers used tandem mass spectrometry to measure chemical concentrations from maternal blood and placenta samples, as well as the liver, heart, lungs, brain, and fatty (adipose) tissues of fetuses. Using gas chromatography, the researchers tested for concentrations of nine different OCPs, ten different PCBs, and three different PBDEs. The cohort included women from 20 pregnancies who gave birth to a stillborn infant. Furthermore, scientists incorporated data from fetal exposure to perfluoroalkyl substances (PFASs) in the same cohort.

All 22 POPs are detectable in fetal fatty tissue samples regardless of chemical detection in the mother. Chemical concentrations are highest among later gestations (pregnancy), male infants, and pregnancies with standard placental function. Of chemical measurements, organochlorine pesticides are present in the highest amount in tissue and blood serum samples, followed by PCBs and PFAS. Adipose (fatty) tissue within the fetal organs has the highest chemical burden, while the brain has the lowest. Overall, more chemicals are detectable in fetal tissue samples than maternal blood/placenta samples.

Environmental contaminants like pesticides are ubiquitous in the environment, with 90 percent of Americans having at least one pesticide compound in their body. Although the 2001 Stockholm Convention treaty bans persistent organic pollutants (POPs) like well-known organochlorine compounds, these chemicals are still the primary pollutants of concern (UNEP, 2009). Their persistence and toxicity adversely affect environmental and biological health. These pollutants have a global distribution, with evaporation and precipitation facilitating long-range atmospheric transport, deposition, and bioaccumulation of hazardous chemicals in the environment. The U.S. was a signatory to the treaty, but U.S. Senate never ratified it, relegating U.S. officials to observer status. While various POPs on the Stockholm Convention annex lists are no longer manufactured or utilized, many of these chemical compounds remain in soils, water (solid and liquid), and the surrounding air at levels exceeding U.S. Environmental Protection Agency (EPA) standards. Therefore, individuals still encounter various POPs at varying concentrations, adding to the toxic body burden of those toxic chemicals currently in use.

Pesticides’ presence in the body has implications for human health, especially during vulnerable life stages like childhood, puberty, pregnancy, and old age. Pesticide exposure during pregnancy is of specific concern as health effects for all life stages can be long-lasting. Just as nutrients are transferable between mother and fetus, so are chemical contaminants. Studies find pesticide compounds present in the mother’s blood can transfer to the fetus via the umbilical cord. Furthermore, pregnant women already have over detectable 100 chemicals in blood and umbilical cord samples, including banned POPs. However, 89 percent of these chemical contaminants are from unidentified sources, lack adequate information, or were not previously detectable in humans. Therefore, pesticide exposure during pregnancy has implications for both mother and child’s health. Many studies indicate prenatal and early-life exposure to environmental toxins increases susceptibility to disease. A 2020 study finds the first few weeks of pregnancy are the most vulnerable periods during which prenatal exposure to pesticides can increase the risk of the rare fetal disorder holoprosencephaly. This disorder prevents the embryonic forebrain from developing into two separate hemispheres. Moreover, women living near agricultural areas experience higher exposure rates that increase the risk of birthing a baby with abnormalities. Some of these birth abnormalities include acute lymphoblastic leukemia and Attention-Deficit/Hyperactivity Disorder (ADHD). Even regular household pesticide use during pregnancy can increase nephroblastoma (kidney cancer) and brain tumor risk in children.

Pesticide exposure not only poses a risk to mothers and their offspring but also future generations. Studies find that although glyphosate (herbicide) exposure has a negligible impact on pregnant rats’ health, incidents of prostate, ovarian, and kidney cancer increase in the two subsequent generations. However, chemical exposure encompasses more than just current-use, toxic pesticides like glyphosate. The metabolites (or breakdown products) of many long-banned pesticides still impart adverse effects on human health. Researchers at Drexel University report that higher levels of some organochlorine compounds, like DDT, during pregnancy are associated with autism spectrum disorder (ASD) and intellectual disability (ID). Since many organochlorine compounds have long been banned in the U.S., the ongoing poisoning and contamination underscores how pervasive and persistent these chemicals are and their continued adverse impact on human health.

Not only are these compounds readily present in soil and water samples, but they are also in arctic ice. Therefore, the accompanying glacial melt from the climate crisis will only increase chemical bioavailability in the environment. The increasing ubiquity of pesticides is concerning to public health advocates because they say that current measures safeguarding against pesticide use do not adequately detect and assess total environmental chemical contaminants.

This study is one of the first to demonstrate differences in chemical contamination between fetus and mother. The results indicate that current pesticide detection methods for fetal exposure fail to capture the full scope of chemical detection. Numerous studies indicate chemical exposure mainly stems from dietary exposure, like food and drinking water, and researchers caution that there are hundreds to thousands of chemicals humans are likely to encounter that the study did not assess. The scientific literature demonstrates pesticides’ long history of severe adverse effects on human health (i.e., endocrine disruption, cancer, reproductive/birth problems, neurotoxicity, loss of biodiversity, etc.) and wildlife and biodiversity. There is a growing consensus that exposure to environmental toxicants before pregnancy can impair fertility, pregnancy, and fetal development. These adverse effects can continue into childhood and adulthood and may have multigenerational consequences. Therefore, researchers stress that future studies must evaluate chemical exposure within the fetus and not only rely on maternal or placental exposure.

The study notes sex-specific differences in birth outcomes between boys and girls. Compared to females, male fetuses have higher concentrations of POPs, resulting in a decrease in birth weight. Differences in placental function between male and female fetuses may play a role in chemical concentration distribution. Pregnancies with male fetuses have lower vascular resistance allowing greater blood flow and higher transfer of chemical concentrations. However, female fetuses display higher rates of learning and developmental disabilities, including attention-deficit/hyperactivity disorder (ADD/ADHD)upon PFAS exposure. Thus, the scientists suggest sex-specific distribution of chemicals may play a role in sexually dimorphic birth outcomes.

This study is not the first to demonstrate sex-specific effect of pesticide exposure. In 2017, scientists presented a study at the 99^th meeting of the Endocrine Society demonstrating exposure to commonly used pyrethroid insecticides results in the early onset of puberty in boys. Furthermore, a 2021 study demonstrates 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 recent data on the rise in use of these chemicals for household pest control, both researchers and advocates are concerned about the range of implications these chemicals could be having on young children in the U.S. and abroad. Previous research finds these chemicals are associated with behavioral problems in children, including externalizing and internalizing disorders, ADHD, and delayed cognitive and motor development.  Proximity to heavy use of these chemicals in agriculture is associated with an 87% increased risk of a child developing autism when applied during pregnant mother’s third trimester. Considering rates of preterm births, miscarriages/stillbirths, and birth malformations are increasing, it is necessary to assess chemical exposure effect on mothers and offspring to safeguard future generations’ health.

Doctors and pediatricians strongly agree that pregnant mothers should avoid pesticide exposure during critical development periods. Exposure concerns about POPs are increasing significantly, especially for adults and children more vulnerable to their toxic effects. Moreover, many contaminants are subject to regulatory standards that do not fully evaluate disease implications associated with exposure. Advocates say that addressing the manufacturing and use of pesticides is essential to mitigate risks from chemical exposure to toxic pesticides. Therefore, advocates urge that policies strengthen pesticide regulations and increase research on the long-term impacts of pesticide exposure. Beyond Pesticides tracks the most recent studies related to pesticide exposure through the 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 multiple harms of pesticide exposure, see PIDD pages on Birth/Fetal Effects, Sexual and Reproductive Dysfunction, Body Burdens, and other diseases. To learn more about how the lack of adequate pesticide regulations can adversely affect human and environmental health, see Beyond Pesticides’ Pesticides and You article “Highly Destructive Pesticide Effects Unregulated.”

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 agro-industry workers alike can apply these methods to promote a safe and healthy environment, especially among chemically vulnerable individuals. For more information on how organic is the right choice for consumers, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture.

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

Source: Chemosphere

(Beyond Pesticides, September 15, 2021) Toxic pesticide use, and glyphosate in particular, degrades the health of freshwater ecosystems by harming species that form the basis of aquatic food chains, according to research published by scientists at McGill University. In a series of studies, scientists investigated how freshwater bacteria and zooplankton were affected by varying levels the weed killer glyphosate, the neonicotinoid insecticide imidacloprid, and nutrient levels. “Because plankton form the foundation of the food chain in freshwater ecosystems, it is very important to understand how plankton communities respond to widely used pesticides,” said Jesse Shapiro, PhD, an Associate Professor in McGill’s Department of Microbiology and Immunology. “Our research shows that the structure of these communities can be impaired under currently acceptable North American water quality guidelines.”

Two separate experiments were conducted under similar conditions in order to properly investigate the effects of pesticide exposure on either zooplankton or freshwater bacteria. For both studies, target species were exposed to varying rates of glyphosate, imidacloprid, or both chemicals at either high or low water nutrient levels. Researchers conducted this study by establishing a series of outdoor experimental ponds, intended to mimic freshwater ecosystems by using Lake water and evenly distributing organisms throughout the ponds.

Zooplankton were found to be much more sensitive to pesticide exposure than freshwater bacteria. However, glyphosate was found to be the most damaging exposure within both experiments. “We found that when we applied the pesticides and fertilizers alone and in combination, at a wide range of concentrations, that glyphosate was the most influential driver of community structure among the agrochemicals,” said Andrew Gonzalez, PhD, a professor in McGill’s Biology Department and the Liber Ero Chair in Biodiversity Conservation.

In the zooplankton study, low levels (.3 parts per million) of glyphosate resulted in persistent declines in rotifer populations, while both pesticides harmed populations of copepod crustaceans (at 3 parts per billion with imidacloprid and 5.5 parts per million with glyphosate). At higher, yet still environmental relevant rates, scientists observed synergy between the two pesticides that resulted in significant declines in overall zooplankton biomass.

In both studies, pesticide use drove changes in community structure. In the bacterial study, glyphosate use at its highest dose (15 ppm) altered the community structure over the long term. Initial reductions in biomass recovered over a 24 day period, but shifted slightly in favor of bacteria that were able to flourish in the presence of glyphosate. “We believe that they were able to recover because they came from a pristine lake and the initial community was diverse enough to “buffer” such a large impact,” said Naila Barbosa da Costa, a PhD student in Biology at l’Université de Montréal. “We do not know if bacterial communities from less diverse ecosystems would be able to cope with a strong contamination the same way.”

Zooplankton populations experienced a more damaging long-term shift. Glyphosate-exposed zooplankton exhibited a fast knockdown, and many species that were killed off in the initial exposure did not return. Eventually, biomass recovered, but the diversity of species was much lower than before. Glyphosate killed off a range of diverse sensitive species, allowing a small subset of glyphosate-tolerant species to thrive. “Long-lasting species loss and compositional shifts have clear implications for the functioning and stability of freshwater ecosystems, even when zooplankton abundance appears unaffected,” said Marie-Pier Hébert, a PhD candidate in McGill’s Department of Biology. “How the effects of glyphosate cascade through freshwater ecosystems to affect their health in the long-term deserves much more study.”

Previous research has shown a range of nontarget effects from glyphosate that are not adequately captured by current pesticide regulations in the United States. Previous research from McGill University on phytoplankton found similar results; communities were able to withstand glyphosate exposure, but diversity ultimately declined as a result. A study published earlier this year from UK researchers found that a specific zooplankton, the water flea Daphnia spp, experiences genotoxic damage that harms its fitness in the wild, a danger not considered by current pesticide toxicity testing undertaken by regulatory agencies around the world.

The neonicotinoid imidacloprid has also been linked to the decline of freshwater ecosystems in previous research, and the findings of damage to copepod crustaceans line up well with studies showing significant threats to benthic organisms from the neonicotinoid insecticides.

Pesticides do not need to decimate species in order for ecosystems to degrade or become irreparably damaged. Subtle shifts in community composition and diversity can drive changes that ripple up and down food chains, as evidenced by emerging research on how pesticides cause trophic cascades.

The diet of weak poisons that humans and the ecosystems we rely upon continue to suffer through does not need to go on. Organic agriculture and land management provide the framework for an interaction between humans and the environment that does not seriously disrupt ecosystem functioning as a result of toxic chemical use. But even this approach is under threat from agrichemical industry interests that want to garner higher prices while sapping the core of what makes organic sustainable. Help make sure organic continues to lead the way in environmental and health protection by engaging with the National Organic Standards Board during the upcoming public comment period.

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

Source: McGill University press release, Molecular Ecology, Ecological Applications

(Beyond Pesticides, September 14, 2021) Last week, Stamford, CT became the latest U.S. City to pass an organic community ordinance, restricting toxic pesticide use on public spaces in favor of safer, natural land care practices. The ordinance, championed by Nina Sherwood of the Stamford Board of Representatives with strong support from Stamford Mayor David Martin, is an outgrowth of years of research and coordination within city government. Advocates note that strong support from both national, state, and local groups like Pollinator Pathway Stamford helped make the case at public hearings. “By garnering support for the public hearing, many Stamford Pollinator Pathway members, Stamford residents and organizations from around the country let their voices be heard,” said Melanie Hollas, co-chair of Pollinator Pathway Stamford and a Stamford Parks and Recreation Commissioner. “Today, I am proud to be a Stamford resident and want to thank everyone, including Beyond Pesticides, for all their hard work to make this goal achievable.”

Ms. Hollas describes the ordinance as, “a comprehensive easy to use system to help employees shift from long-term usage patterns of chemicals to products, and more importantly practices, that create a healthy ecosystem along with beautiful landscaping and usable sports fields.” The ordinance recognizes the dangers of non-organic pesticides registered by the U.S. Environmental Protection Agency (EPA) with glaring data gaps, little oversight, and an increasing lack of public accountability. In the face of EPA inaction to protect local communities from toxic pesticides, Stamford’s ordinance allows only the use of materials permitted within the U.S. Department of Agriculture’s National Organic Program to be used on publicly owned property. These products represent the least-toxic, yet still effective pesticides on the market. In further recognition of EPA’s lax approach to pesticide regulation, Stamford established a list of “permanently banned products” that include the highly toxic substances glyphosate, 2,4-D, 1,3-D, the neonicotinoids, and chlorpyrifos, none of which are allowed under federal organic law.

The ordinance provides for few exemptions. City employees may apply to the Director of Operations to apply a prohibited pesticide but must show that: i) attempts to address the pest problem have already utilized organic products, ii) the attempt was unsuccessful, and that iii) a prohibited product will be effective. If approved to use a prohibited product, the applicant must also have a plan to prevent recurrence of the pest problem utilizing an organic approach. Otherwise, prohibited products can only be used in the case of an imminent threat to public health or the environment, as determined by the city’s Director of Health. Products listed as “permanently banned” are only permitted to be used at the city’s municipal golf course, by the fire department when engaging in public safety activities, and to manage invasive species under state law.

City agencies are tasked with providing the Mayor and Stamford Board of Representatives a written report on the use of pesticide products in the city each year.

Stamford is the latest community along the Eastern Seaboard to pass a strong pesticide reform ordinance and be added to Beyond Pesticides’ Map of U.S. Pesticide Reform. Its passage follows recent policies enacted in Maui County, HI, New York City, NY, Philadelphia, PA, Baltimore, MD, and Portland, ME. Stamford’s policy is also an approach quite similar to restrictions enacted at the state level to protect Connecticut schoolchildren from toxic pesticides. Connecticut has one of the strongest school pesticide bills in the nation. The state already bans toxic pesticide use on all municipal playgrounds, and allows only minimum risk pesticides to be applied on school grounds.

Unfortunately, cities in Connecticut cannot ban pesticides on private property due to the state’s regressive preemption statute. Recognizing this, efforts are ongoing within the state to overturn this provision.  

In addition to toxic pesticide use, Stamford’s policy recognizes the dangers posed by fossil-fuel based synthetic fertilizers both to the climate, and local waterways, due to nutrient runoff. Like the ordinance recently passed by the Maui County Council, and the ordinance update enacted last year in South Portland, ME, local communities are increasingly recognizing that natural land care policies must address both toxic pesticides and toxic fertilizers in order to achieve sustainability and ensure the natural cycling of nutrients critical to resilient organic practices.

As Stamford advocate Melanie Hollas notes, “One person really can make a difference.” Help turn your community into the next Stamford, Maui, Portland, or New York City by starting your own local movement. Use Beyond Pesticides resources on our Children and Schools and Tools for Change webpages to help make your case to local leaders. Reach out at [email protected] or 202-543-5450 for one on one assistance with your advocacy efforts.

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

Source: Stamford, CT Board of Representatives, and author’s personal communication with Melanie Hollas of Pollinator Pathway Stamford

(Beyond Pesticides, September 13, 2021) The National Organic Standards Board (NOSB) is receiving written comments from the public through September 30. This precedes the upcoming public comment webinar on October 13-14 and online meeting October 19-21—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov.

As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong (KOS) and the Fall 2021 issues page. In the spirit of “continuous improvement,” we urge you to submit comments (please feel free to use our comments on the KOS page) that contribute to an increasingly improved organic production system.

The Organic Foods Production Act (OFPA) requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. Among those up for sunset review this Fall are some controversial materials—copper sulfate, carrageenan, and list 3 “inerts.” In addition, the NOSB is once more considering a petition to allow the antibiotic kasugamycin in fruit production.

Copper sulfate is used in organic rice production to control algae and an invertebrate known as tadpole shrimp. It poses health threats, particularly to workers—including damage to the gastrointestinal tract, liver, kidneys, and the immune system resulting from inhalation exposure. Respiratory effects have been seen in animals exposed to copper sulfate aerosols (such as might be experienced by workers). Copper is considered the etiologic agent in the occupational disease referred to as “vineyard sprayer’s lung.” Copper sulfate is also a reproductive toxicant.

Copper sulfate is hazardous to aquatic plants, animals, and aquatic ecosystems. This is particularly important in rice production, where rice paddies replace natural wetlands and provide alternative habitat for animals threatened by the loss of wetlands. For example, one animal inhabiting rice paddies is the western toad (Bufo boreas).  Tadpoles of the western toad feed on filamentous algae, detritus, and may even scavenge carrion. Application rates of copper sulfate exceed levels that are lethal to tadpoles of Bufo boreas by up to two orders of magnitude. Other amphibians at risk are the bullfrog and Pacific treefrog, whose tadpoles consume algae, organic debris, and small aquatic invertebrates.

The negative impacts on amphibians found in rice fields not only have a negative impact on biodiversity, but they also reduce possibilities for biological control of algae and tadpole shrimp.  Thus, the use of copper sulfate in an aquatic environment like a rice field is inconsistent with a system of organic and sustainable agriculture. In addition, since copper sulfate is water soluble, when the fields are drained, it is released through drainage ditches to streams, and ultimately, the ocean.

The NOSB has previously discussed alternative growing systems that would eliminate the need for copper sulfate and made such alternatives a research priority. Most of the world transplants rice seedlings into paddies. Dryland rice is also grown. Neither of these systems requires killing algae and tadpole shrimp—in fact tadpole shrimp are regarded as a biological control for algae. It is time to eliminate the use of copper sulfate, bringing organic rice production in line with organic principles.

List 3 “inerts” should be removed from the National List. One of the most egregious failures of the National Organic Program (NOP) has been its repeated lack of action on so-called “inert” ingredients. Because of that failure, every sunset brings to a new NOSB a listing that has not been changed in response to over a decade of NOSB recommendations. Fifteen years ago, EPA stopped updating the “inerts” lists upon which the NOP relies. Ever since EPA’s action in 2006, the NOSB has been recommending the review of individual “inert” ingredients, but has instead been given the option by NOP of relisting the outdated lists.

In 2012, the NOSB has already recommended an expiration date for these chemicals, but NOP refused—in violation of the law—to codify this recommendation. The NOSB identified the “inerts” formerly on List 3 that were covered by this listing. They are BHT (antioxidant), 2-Hydroxy-4-n-octyloxybenzophenone (UV absorber), and 2-(2-Hydroxy-3-tert-butyl-5-methylphenyl)-chlorobenzotriazole (UV stabilizer). In addition to the three List 3 “inerts” identified in 2012, a fourth chemical formerly on List 3 has been identified as being in use in passive pheromone dispensers in organic production—benzaldehyde, CAS #100-52-7. Benzaldehyde is not approved for food use. It is approved for nonfood use and as a fragrance in nonfood uses. The addition of another chemical to the known List 3 “inerts” used in organic production shows a hazard of delaying the review of these chemicals as recommended by the NOSB. The NOSB must insist that List 3 “inerts” be delisted and that the individual chemicals be specifically reviewed.

Carrageenan is a controversial food additive that most organic processors have removed from their products. The NOSB voted in 2016 to remove carrageenan from the National List. In 2018, NOP announced that it was refusing to remove carrageenan. The Organic Foods Production Act (OFPA) §6517(d)(1) requires that, “The National List established by the Secretary shall be based upon a proposed national list or proposed amendments to the National List developed by the National Organic Standards Board.” The National List is not “based on” the recommendations of the NOSB if it is directly contradictory to those recommendations. NOP based its decision on testimony received by the NOSB and should not be second-guessing the advisory board for which establishing the National List is an expressly stated statutory responsibility.

The NOSB should insist that carrageenan be removed from the National List. The evidence summarized by the 2015 Technical Review came up with a verdict of mixed results on virtually every issue regarding food grade (high molecular weight) carrageenan. However, there is widespread agreement that poligeenan, which contaminates food grade carrageenan at unknown and uncontrollable levels, does cause adverse effects, including cancer. The production causes adverse environmental impacts. And it is not necessary–organic processors have been moving away from the use of carrageen because of consumer pressure since it was last considered for sunset. This is made more urgent by the fact that NOP ignored the recommendation of the NOSB in spring of 2012 to remove carrageenan from infant foods, as well as the 2016 recommendation to remove carrageenan from the National List altogether.

Kasugamycin is an antibiotic used in fruit production. The NOSB is considering a petition to allow it to be used in organic apple and pear production. Earlier NOSB members struggled long and hard to erase the stigma of antibiotic use in organic fruit production—something that was left over from the transition of so many chemical-intensive fruit orchards after the Alar “scare” in which apple and apple products were contaminated with the cancer-causing plant growth regulator daminozide. Do we now want to step on that treadmill again? The reasons for rejecting the kasugamycin petition are the same as the reasons for eliminating the antibiotics streptomycin and tetracycline in crop production.

Now that we have learned what a pandemic looks and feels like, with the astounding levels of infection, hospitalization, and death from COVID-19, we must take serious steps to prevent another pandemic on the horizon—this one tied to bacterial resistance to antibiotics. An important article in The Lancet points to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”

When streptomycin and tetracycline were presented for their final votes by the Crops Subcommittee, the committee was unanimous that the antibiotics needed to go—the question was how fast. How fast could growers of these crops get over their dependence on these antibiotics that pose threats to human health and the environment and are unpopular with organic consumers? Streptomycin and tetracycline are gone, and we do not need another antibiotic.

We said “No!” to antibiotics in organic fruit, and now we must affirm that we mean it. Kasugamycin does not meet any of the OFPA criteria for the National List—it poses health and environmental dangers, is not necessary, and is incompatible with organic practices.

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(Beyond Pesticides, September 10, 2021) Research conducted in Thailand shows that exposures to pesticides, even at low levels, can impact the human endocrine system and distort thyroid function. The study looked specifically at interactions of genetics and environment: it investigated associations between variations in genes involved in pesticide metabolism and altered thyroid hormone concentrations in agricultural workers. This research underscores some of the complexity and difficulty of determining human vulnerability to impacts of pesticide exposures, given genetic variables. Beyond Pesticides believes that this very complexity is a cogent argument for anchoring regulation of pesticides in the Precautionary Principle. If exposure to a pesticide can cause damage to human (or environmental) health, it sometimes will do so. Thus, to protect people’s health, agriculture and other land management practices must transition from the use of synthetic pesticides to broad adoption of organic regenerative approaches that obviate the need for such chemicals.

This research is part of a longitudinal study that seeks to evaluate sub-chronic impacts, on thyroid hormone levels, of repeated exposures to a variety of pesticides. The farmworkers studied in this phase comprise two groups: those working on organically managed farms (216 subjects), and those working on conventional farms that use pesticides (229 subjects). Participants were recruited from an area of Thailand whose agricultural activity is broadly representative of that throughout the country — primarily, rice, fruit, vegetable, and sugarcane production. Those in the chemical pesticide–using group most commonly employed, from greater to lesser amounts used, herbicides (largely glyphosate, paraquat, and 2,4-D), insecticides (chlorpyrifos, cypermethrin, carbaryl, and carbosulfan), and fungicides. Workers in the “chemicals” group had used pesticides in their work for an average of 25 years; however, more than 35% of them had worked with the chemicals for more than 30 years.

The study furthers understanding of how pesticides can disrupt or distort endocrine function. The thyroid gland is an important part of the human endocrine system, which comprises a number of glands and the hormones they produce and secrete. Those hormones travel through the circulatory system to organs and tissues to transmit important regulatory messages regarding metabolism, stress response, reproduction, development, and other functions. The other major glands of the endocrine system are the hypothalamus, pituitary, parathyroids, adrenals, ovaries, testes, and the pineal body.

Beyond Pesticides has long covered the roles of synthetic chemical pesticides, including endocrine-disrupting (ED) ingredients in them, in endocrine dysfunction. Beyond their ED impacts: a May 2021 Daily News Blog entry reported on a U.S. National Institutes of Health (NIH) study showing that exposures to either of the pesticides lindane and metalaxyl increases the risk of developing thyroid cancer.

A recent Daily News Blog article said, “The ingredients in many pesticides (and in many consumer products) act as endocrine disruptors in humans and other animals in several ways. They may: (1) mimic actions of hormones the body produces (e.g., estrogen or testosterone), causing reactions similar to those generated by the naturally produced hormones; (2) block hormone receptor cells, thereby preventing the actions of natural hormones; or (3) affect the synthesis, transport, metabolism, and/or excretion of hormones, thus altering the concentrations of natural hormones in tissues or at receptor sites.” Pesticides acting as EDs can, through disruption of the activities in #3, distort hormone levels in the body. The research paper concurs that there is increasing evidence of pesticides acting as ED chemicals to disrupt thyroid function.

Human susceptibility to harmful pesticide impacts can be influenced and mediated by multiple factors, including age, sex, health status, lifestyle features, and genetic factors, among others. The study notes, “Genetic polymorphisms are one determinant of pesticide-induced adverse health effects, especially polymorphisms of genes related to pesticide metabolism.” Genetic polymorphisms — variations in phenotypes caused by expression of different alleles of a given gene, such as happens with the human blood groups O, A, B, and AB, for example — can alter reactions in the multiple steps of pesticide metabolism.

This research investigated disruptions of the HPT (hypothalamic-pituitary-thyroid) axis or pathway of the endocrine system — a set of interacting hormones and transporter enzymes that regulate metabolism and some of the body’s stress responses. The metabolism of ED pesticides that impact the thyroid gland is regulated in part by the activity of this axis.

Hormone levels and specific genetic SNPs (single nucleotide polymorphisms — variations at single positions in DNA sequences) were determined from blood samples taken after a 12-hour, overnight fast. The study assessed thyroid-stimulating hormone (TSH), free triiodothyronine (FT3), and free thyroxine (FT4) in the farmworkers, and found significant differences in the TSH and FT3 concentrations between the chemical pesticide and the organic worker groups; however, the nature of those differences was highly correlated to the presence of specific SNPs.

The study asserts, “Thyroid dysfunction has long been recognized as abnormal TSH, FT4, and FT3 concentrations, which can result from exposure to endocrine-disrupting pesticides. The[se] results suggest that the long-term use of pesticides by the chemical workers may have contributed to their significantly higher concentrations of TSH and FT3 compared with the organic workers. . . . Changes in thyroid hormone concentrations may involve the effects of insecticides, herbicides, and/or fungicides on the molecular regulation of the HTP axis.”

The researchers believe that theirs is the first study to explore whether genetic polymorphisms are associated with pesticide-induced alterations in thyroid hormones, and the first to investigate “a large number of SNPs in agricultural workers to assess the potential risk of thyroid dysfunction.” The co-authors write, “The genetic analysis of enzymes involved in pesticide metabolism provides valuable information regarding individuals or populations that may have an increased health risk because of their polymorphism profile. Genetic variations of these genes can lead to pesticides forming highly toxic intermediates and ultimately damaging various molecular targets.”

The researchers note that such variations in individuals’ genetic polymorphisms may explain, at least in part, why people can differ in their response to pesticide exposure. The study asserts: “These findings support a possible role of pesticide exposure in adverse thyroid function and should focus public and environmental health concerns regarding the occupational risk associated with pesticide use.”

The bottom line for farmworkers — who would virtually never know anything about their “polymorphism profile” — is that they are at significant risk of thyroid dysfunction or/and disease from their chronic exposures to ED pesticides. Frontline agricultural workers have been the canaries in the coalmine for many decades — since agricultural production shifted in the mid-20^th century to chemical-intensive management. Those working in conventional farming are exposed chronically to multiple toxic pesticide compounds, many of which have been registered for use by the U.S. Environmental Protection Agency (EPA) without evidence of their safety. Many agricultural workers in the U.S. are people of color, making pesticide use not only a health and environmental morass, but also, a major environmental justice issue.

Beyond Pesticides and other advocates have repeatedly called attention to the ED impacts of many pesticides, and especially, their negative human health impacts. See these recent articles: “Ban Endocrine Disrupting Pesticides Now,” and “Tell EPA: It Must Ban Pesticides Unless Shown Not to Be Endocrine Disruptors.” For years advocates have worked to bring ED (and many other) pesticide issues to the public’s attention, persuade policymakers, and enter into litigation to get EPA to act protectively on human and environmental health. But the people and their representatives, whether elected or in advocacy, should not have to fight against their own government to secure the protections that EPA is tasked with providing.

Just days ago, Beyond Pesticides wrote, in a commentary on the EPA announcement on ending chlorpyrifos use on food: “Does a science-based, public health–oriented, occupational safety–focused, children-concerned, ecologically protective society allow the use of toxic pesticides that are unnecessary to achieve land management, quality of life, and food productivity goals? Should victims of poisoning have to plead with regulators to protect them? Should organizations have to fight, chemical by chemical, to achieve basic levels of protection from individual neurotoxic, cancer causing, endocrine disrupting pesticides? Of course not. But . . . EPA’s announcement that it is stopping food uses of the insecticide chlorpyrifos, after being registered 65 years ago, provides us with an important opportunity for reflection. The collective effort to remove this one chemical is a tremendous feat in eliminating one exposure to a hazardous material for children. That is the point. The action we’re celebrating required an amazingly resource-intensive effort at a time in history when we are running against the clock in an urgent race to transition our society and global community away from the use of petroleum-based, toxic pesticides [and] to . . . meaningful practices that sustain, nurture, and regenerate life.” Those practices happen in approaches that respect Nature, exercise precaution, and take seriously their stewardship role.

Beyond Pesticides believes that organic regenerative agriculture and land management must be the future. And EPA must do better — now — to get us there.

Source: https://www.dovepress.com/risk-management-and-healthcare-policy-journal

ISSN: 1179-1594
Risk Management and Healthcare Policy is an international, peer-reviewed, open access journal focusing on all aspects of public health, policy, and preventative measures to promote good health and improve morbidity and mortality in the population. It is a member of and subscribes to the principles of the Committee on Publication Ethics (COPE).

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

(Beyond Pesticides, September 9, 2021) A new study published in Toxicology Reports finds the same chemicals that disrupt the endocrine (hormone) system also disrupt the nervous system. Endocrine disruptors are xenobiotics (i.e., chemical substances like toxic pesticides foreign to an organism or ecosystem) present in nearly all organisms and ecosystems. The World Health Organization (WHO), European Union (EU), and endocrine disruptor expert (deceased) Theo Colborn, Ph.D., classify over 55 to 177 chemical compounds as endocrine disruptors, including various household products like detergents, disinfectants, plastics, and pesticides. Past research shows exposure to endocrine-disrupting pesticides adversely affects human health, from reproductive function to cancer development, and effects can span generations. However, this study is one of the few to evaluate associations between endocrine-disrupting chemicals and neurological function. Although the etiology (cause) of many sporadic (non-heritable) neurological diseases are unknown, scientists suggest exposure to environmental toxicants plays a role in disease development. Therefore, government and health officials have been urged to consider how exposure to endocrine-disrupting chemicals can impact bodily function and development apart from hormone disruption.  

In the body, cells communicate through electrical or chemical signals transmitted within the nervous or endocrine system. Studies find exposure to endocrine-disrupting chemicals has a direct and indirect impact on hormone function and development. However, researchers investigated whether the chemicals play a similar role in neurological development and functionality: Do endocrine-disrupting chemicals impact the nervous system via neuroendocrine or general mechanisms? These mechanisms include direct effects on the neurons/nervous system or indirect effects on the nervous system via thyroid regulation. Using scientific studies based on neurotoxicity, cognition, and behavior from PubMed and Google scholar, researchers assessed 176, WHO classified, endocrine-disrupting compounds, in addition to Roundup (177), for neurological effects.

The results demonstrate that all classifiable endocrine-disrupting chemicals, including Roundup/glyphosate, negatively affect the nervous system, causing neurological disruption (neurodisruption). Although previous research notes the primary mechanism of endocrine disruption is through the thyroid, only 20 percent of endocrine disruptors in this study operate via the thyroid to cause nervous system impacts. The remaining 80 percent of endocrine disruptors function via other general mechanisms to produce adverse nervous system effects. Therefore, the researchers establish the novel concept that endocrine disruptors are neurological disruptors (neurodisruptors) and collectively refer to these chemicals as endocrine and nervous disruptors (ENDs).

Past research shows exposures to endocrine-disrupting chemicals can adversely impact human, animal—and thus environmental—health, by altering the natural hormones in the body responsible for conventional fertile, physical, and mental development. Research demonstrates that endocrine disruption is prevalent among many pesticide products like herbicides, fungicides, insecticides, and even pesticide manufacturing by-products like dioxin (TCDD). These chemical ingredients can enter the body, disrupting hormones and causing adverse developmental, disease, and reproductive problems. The endocrine system consists of glands (thyroid, gonads, adrenal, and pituitary) and the hormones they produce (thyroxine, estrogen, testosterone, and adrenaline). These glands and their respective hormones guide the development, growth, reproduction, and behavior of animals, including humans. Endocrine disruption is an ever-present, growing issue that plagues the global population. Hence, advocates maintain that policies should enforce stricter pesticide regulations and increase research on the long-term impacts of pesticide exposure.

The nervous system is an integral part of the human body and includes the brain, spinal cord, a vast network of nerves and neurons, all of which are responsible for many of our bodily functions—from what we sense to how we move. However, exposure to chemical toxicants, like pesticides, can cause neurotoxic effects or exacerbate preexisting chemical damage to the nervous system. The impacts of pesticides on the nervous system, including the brain, are hazardous, especially for chronically exposed individuals (e.g., farm workers) or during critical windows of vulnerability and development (e.g., childhood, pregnancy). Mounting evidence over the past years shows that chronic exposure to sublethal (low) levels of pesticides adversely affects the central nervous system (CNS). Specifically, researchers identify agricultural chemical exposure as a cause of many adverse CNS impacts. In addition to CNS effects, pesticide exposure can impact a plethora of neurological diseases. These diseases include amyotrophic lateral sclerosis (ALS) and Parkinson’s disease, dementia-like diseases such as Alzheimer’s, and other effects on cognitive function. Overall, endocrine disruption can negatively impact reproductive function, nervous system function, metabolic/immune function, hormone-related cancers, and fetal/body development. Therefore, advocates say it is essential to avoid toxic chemical exposure to lessen potential acute and chronic health risks.

Not only do researchers find exposure to sublethal doses of endocrine-disrupting chemicals affect hormone receptors, but neural receptors such as connections between nerves, the brain, enzymes, and DNA, as well. This study adds to the growing body of research surrounding pesticide neurotoxicity. In addition to this research, several studies demonstrate autism, mood disorders (e.g., depression), and degenerative neurological conditions (e.g., ALS, Alzheimer’s, Parkinson’s) among aquatic and terrestrial animals, including humans, exposed to pesticides. Pesticides themselves, mixtures of chemicals such as Agent Orange or dioxins, and therapeutic hormones or pharmaceutical products are endocrine disruptors that possess the ability to disrupt neurological function. Furthermore, studies suggest pesticides formulants (adjuvants) such as POEA (polyoxyethylene tallow amine) have both neurological and endocrine-disrupting activity. POEA is present in some glyphosate-based herbicides like Roundup and has higher nervous system toxicity than the active ingredient (glyphosate). Although the biological function and cause/effect of neurotoxicity related to endocrine and nervous disruptors is unclear, scientists note synchronized communication within and between cells. Many of these endocrine compounds are petroleum derivatives that have a mechanism of action of “spamming” communication signals. 

The U.S. Environmental Protection Agency lacks comprehensive pesticide testing protocol and fails to evaluate the full impact of pesticide products, severely limiting real-world exposure concerns. The Office of the Inspector General (OIG) reports EPA’s Endocrine Disruptor Screening Program fails to adequately assess endocrine-disrupting pesticides and protect the general population from exposure. The OIG report concludes, “Without the required testing and an effective system of internal controls, the EPA cannot make measurable progress toward compliance with statutory requirements or safeguard human health and the environment against risk from endocrine-disrupting chemicals.” (See Beyond Pesticides report.)

The endocrine and nervous systems are integral to everyday human activities and the body’s ability to function normally. There is a lack of understanding of the etiology of pesticide-induced diseases, including predictable lag time between chemical exposure, health impacts, and epidemiological data. Exposure to pesticides can increase the risk of developing chronic illnesses, and studies related to pesticides and endocrine disruption can help scientists understand the underlying mechanisms that indirectly or directly cause neurotoxicity. Therefore, advocates are calling for policies that enforce stricter pesticide regulations and increase research on the long-term impacts of pesticide exposure.

There are several limitations in defining real-world poisoning as captured by epidemiologic studies in Beyond Pesticides’ Pesticide-Induced Diseases Database (PIDD). The adverse health effects of pesticides, exposure, and the aggregate risk of pesticides showcase a need for more extensive research on occupational and non-occupational pesticide exposure, especially in agriculture. However, the PIDD database supports the clear need for strategic action to shift away from pesticide dependency. For more information on the multiple harms of pesticides exposure on human health, see PIDD pages on endocrine disruption, brain and nervous system disorders, cancer, and other diseases. 

Beyond Pesticides advocates for a precautionary approach to pest management in land management and agriculture by transitioning to organic practices. Buying, growing, and supporting organic can help eliminate the extensive use of pesticides in the environment and from your diet. For more information on why organic is the right choice for consumers and the farmworkers who grow our food, see Beyond Pesticides webpage, Health Benefits of Organic Agriculture. 

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

Source: GM Watch, Toxicology Reports

(Beyond Pesticides, September 8, 2021) The U.S. Environmental Protection Agency (EPA) last month released a long-overdue biological evaluation of the three most commonly used neonicotinoid (neonic) insecticides, finding that the chemicals are likely to adversely affect the lion’s share of endangered species and their habitat. While the public may be most familiar with the damage neonics cause to pollinator populations, EPA’s evaluation highlights the widespread, indiscriminate harm scientists throughout the world have been sounding the alarm about for years. Advocates say the findings make it clear that neonicotinoids must be immediately banned from use.

Under the Endangered Species Act (ESA), EPA is required to consult with federal wildlife agencies and conduct a biological evaluation of the impacts a pesticide may have on endangered species and their habitats, prior to the agency formally registering the pesticide. This almost never happens. EPA regularly fails to conduct this evaluation, requiring environmental and conservation organizations to sue the agency in order to force compliance with the law.  

EPA has been subject to a number of legal challenges over the last decade for its failure to comply with ESA when it registered neonics pesticides. In 2019, Ellis v Housenger (EPA), a lawsuit filed by beekeeper Steve Ellis of Old Mill Honey Co in Minnesota, alongside environmental organizations Beyond Pesticides, Center for Food Safety, and others, concluded that EPA violated ESA. The judge in that case ordered the parties involved to negotiate a settlement to resolve the dispute. This resulted in the cancellation of 12 neonicotinoid products, but allowed a broad range of similar products to remain on the market.

Separate lawsuits filed by the Natural Resources Defense Council and Center for Biological Diversity resulted in settlements that required EPA to fulfill its original legal requirement and publish a biological evaluation on the effects of neonics on endangered species. EPA’s current release is considered a draft, and it has until June 2022 to complete its work. Finalizing the evaluation will initiate a consultation process that could result in restrictions on the chemicals in order to alleviate risks to endangered species or their habitat.

Under EPA’s current draft, each neonic was found to adversely affect over 1,000 endangered species out of 1,821 listed under the law. Specifically, the neonics were found to adversely effect nontarget endangered species: imidacloprid – 1,445  (79%), clothianidin – 1,225 (67%), and thiamethoxam- 1,396 (77%). Harmful effects were not limited to a specific subgroup – dozens of species were affected within all groups, including mammals, birds, amphibians, reptiles, fish, plants, and aquatic and terrestrial invertebrates.

These findings are stark in the context of actions by the previous administration to weaken the biological evaluation process. Under new “Revised Methods” the agency released, many of the ways that protected species are commonly hurt or killed by pesticides are ignored, such as down stream impacts, and secondary effects like for instance, when harm to a pollinator population effects the fitness of an endangered plant. It is critical that EPA and wildlife agencies conduct more research on the trophic impacts of pesticides, not less.

Thus, while even these grim determinations are likely significantly underplaying the danger posed by neonics, reports indicate the pesticide industry is concerned with how the Biden administration will ultimately act on these data. In its press release, EPA noted that these reviews came after the agency’s lackluster rubber stamp of the chemical class in early 2020. The agency indicates that, “Additional mitigation measures may be developed through formal consultation on the neonicotinoid pesticides. EPA is interested in finding ways, through discussions with stakeholders, to implement mitigation measures that further protect endangered and threatened species earlier in the ESA consultation process.”

While that does provide a small ray of hope, to date, agency actions under President Biden and Administrator Regan have resulted in the renewal of the highly toxic herbicide paraquat, defending a decision to allow use of once-banned aldicarb, and the re-approval of another bee-killing insecticide sulfoxaflor. The agency recently took overdue action on the insecticide chlorpyrifos, yet significant concerns remain over the precedent established by the way EPA made its decision.

Ultimately, any action taken by the administration to limit one chemical or chemical class without a broad-scale reorganization of how EPA conducts its pesticide reviews is insufficient. Real reform is necessary to stop industry influence over American’s health, environmental safety, and the dwindling species whose protection are critical for our long-term welfare. Help reinforce the message that the Biden administration must have EPA hold pesticide manufacturers accountable for the poisoning and damage they cause.

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: EPA, C&EN

(Beyond Pesticides, September 7, 2021) If regulations concerning “origin of organic livestock” and “access to pasture” seem beyond your comprehension as an organic consumer, think again. Lacking enforcement of strong regulations on these topics, organic dairy is in imminent danger.

Multinational food conglomerate Danone, owner of Horizon Organic, has just sent notice to 89 organic milk producers in Maine, Vermont, New Hampshire and at least three counties (Clinton, Franklin and Saint Lawrence) in New York that it is cancelling their contracts. While this action is devastating to the affected farms and the economies of those states, it has much broader implications.

Why is Danone cancelling contracts as organic milk production in the Northeast is increasing? In Danone’s words, the company “will be supporting new partners that better align with our manufacturing footprint.” Ed Maltby, executive director of the Northeast Organic Dairy Producers, explains this “footprint,” with reference to low cost, ultra-pasteurized milk that is easily transported and warehoused, which has become a staple on the organic shelf. More importantly for the future of organic dairy is the expectation that USDA will promulgate a weak regulation on origin of livestock—that “will allow the massive loophole of being able to sell or transfer transitioned animals as certified organic.” Such a regulation, in combination with the continued failure to enforce rules requiring organic livestock to have access to pasture, makes it profitable to produce “organic” milk in industrial confined animal feeding operations (CAFOs), where cows are fed cheap imported “organic” grain instead of pasture. Organic consumers do not want CAFO [concentrated animal feeding operation] milk, but many will have no other choice without strong regulations.

Tell USDA that strong regulations are essential to protect organic dairy and consumer support for organic.

Letter to USDA Secretary Tom Vilsack and Deputy Administrator, National Organic Program 

As an organic consumer, I am very concerned about the future of organic dairy. Multinational food conglomerate Danone, owner of Horizon Organic, has just sent notice to 89 organic milk producers in Maine, Vermont, New Hampshire and at least three counties (Clinton, Franklin and Saint Lawrence) in New York that it is cancelling their contracts. While this action is devastating to the affected farms and the economies of those states, it has much broader implications that affect all organic consumers.

Why is Danone cancelling contracts as organic milk production in the Northeast is increasing? In Danone’s words, the company “will be supporting new partners that better align with our manufacturing footprint.” What is this “footprint”? Low cost, ultra-pasteurized milk that is easily transported and warehoused has become a staple on the organic shelf. That doesn’t live up to my expectations as an organic consumer.

But more importantly for the future of organic dairy is the expectation that USDA will promulgate a weak regulation on origin of livestock—that will allow the massive loophole of being able to sell or transfer transitioned animals as certified organic. Such a regulation, in combination with the continued failure to enforce rules requiring organic livestock to have access to pasture, makes it profitable to produce “organic” milk in industrial concentrated animal feeding operations (CAFOs), where cows are fed cheap imported “organic” grain instead of pasture. Organic consumers do not want CAFO milk, but many of us will have no other choice without strong regulations.

Please do the following:

* Adopt strong regulations governing origin of organic livestock that do not allow transitioned animals to retain their organic certification for milk when they are transferred or sold. The recent loss of Northeast organic dairy family farms can be blamed partly on USDA who created an un-level playing field with its failure to publish the regulation during the last decade.

* Enforce regulations requiring access to pasture. The recent loss of Northeast organic dairy family farms can be blamed partly on USDA, which allows some certifiers to fail to interpret or enforce the access to pasture regulation in their definition of the grazing season.

We pay a premium for organic milk because we want milk from farms that follow strict organic practices. Without strong enforcement, the organic label is a farce and will lose its value in the marketplace.

Thank you.

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

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

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

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

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

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

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

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

—Jay Feldman, executive director of Beyond Pesticides.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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